ELECTRONICALLY FILED - 2023 Apr 17 5:41 PM - RICHLAND - COMMON PLEAS - CASE#2023CP4001982

STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS

COUNTY OF RICHLAND FOR THE FIFTH JUDICIAL CIRCUIT

The City of Columbia (S.C.), Civil Action No: 2023-CP-40-______

Plaintiff,
-vs-
CHC Colony Apartments, LLC; CHC SUMMONS
Colony Apartments LIHTC MM, LLC;
Monroe Group, Ltd; Steele Properties,
LLC; and, Community Housing
Concepts, Inc.
Defendants.

TO: THE DEFENDANTS, ABOVE NAMED:

YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action,
which has this day been filed via E-Filing with the court, a copy of which is herewith served on
you, and to serve a copy of your answer upon the subscriber, at the office of the Columbia City
Attorney, 1401 Main Street, Tenth Floor, Columbia, South Carolina 29201 within Thirty (30) days
after service thereof, exclusive of the day of service; and if you fail to answer the Complaint within
the time aforesaid judgment by default will be rendered against you for the relief demanded in the
Complaint.
CITY OF COLUMBIA

By: s/ W. Mike Hemlepp, Jr.

W. Mike Hemlepp, Jr. (SC Bar #64264)
Senior Assistant City Attorney – Litigation
Post Office Box 667
Columbia, South Carolina 29202
Telephone (803) 737-4242
Facsimile (803) 737-4250
Email: William.Hemlepp@columbiasc.gov

April 17, 2023

Columbia, South Carolina

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 ELECTRONICALLY FILED - 2023 Apr 17 5:41 PM - RICHLAND - COMMON PLEAS - CASE#2023CP4001982
STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS

COUNTY OF RICHLAND FOR THE FIFTH JUDICIAL CIRCUIT

The City of Columbia (S.C.), Civil Action No: 2023-CP-40-______

Plaintiff,
-vs- COMPLAINT
CHC Colony Apartments, LLC; CHC (Quantum Meruit)
Colony Apartments LIHTC MM, LLC;
Monroe Group, Ltd; Steele Properties, (Injunctive Relief)
LLC; and, Community Housing
Concepts, Inc.
Defendants.

TO: The Defendants, above named:

THE PLAINTIFF, The City of Columbia, by way of complaining of the actions or

omissions of the Defendants, individually and together, would aver, allege, claim, state and argue

to this Honorable Court as follows:

PARTIES AND JURISDICTION

1. The City of Columbia, (S.C.), hereinafter referred to as “The City”, is a municipality

organized and existing under the Laws and the Constitution of the State of South Carolina,

having been duly incorporated and existing by act of the South Carolina General Assembly

in the year 1786 and first incorporated in 1805.

2. The Colony Apartments, hereinafter referred to as “the COLONY”, is a multi-family

residential property located on Beltline Boulevard in the city limits of Columbia, South

Carolina at 3545 West Beltline Boulevard, and is designated as TMS: #R11605-05-03 in

the Office of the Assessor for Richland County, South Carolina.

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3. The Defendant, CHC Colony Apartments, LLC, hereinafter referred to as “TITLE

OWNER” is a limited liability company organized and existing under the laws of the State

of South Carolina and is the title owner of the Colony. CHC Colony Apartments, LLC has

an address of 6875 E. Evans Street, Denver, Colorado 80224 and may be found for

purposes of service of process through its registered agent: CORPORATION SERVICE

COMPANY, 508 Meeting Street, West Columbia, South Carolina 29169.

4. The Defendant, CHC Colony Apartments LIHTC MM, LLC, hereinafter referred to as

“CHC LIHTC”, is a limited liability company organized and existing under the laws of

the State of Colorado. CHC LIHTC has an address of 6875 E. Evans Street, Denver,

Colorado 80224 and may be found for purposes of service of process through its registered

agent: CORPORATION SERVICE COMPANY, 508 Meeting Street, West Columbia,

South Carolina 29169.

5. Upon information and belief, CHC LIHTC operates the financial affairs of the TITLE

OWNER.

6. The Defendant, Monroe Group, Ltd., hereinafter referred to as “MONROE”, is a corporate

entity organized and existing under the laws of the State of Colorado. MONROE has an

address of 6875 E. Evans Street, Denver, Colorado 80224 and may be found for purposes

of service of process through its registered agent: CORPORATION SERVICE

COMPANY, 508 Meeting Street, West Columbia, South Carolina 29169.

7. Monroe states on its website it is a property management partner of Steele Properties and

lists the Colony Apartments as a property in its portfolio.

8. The Defendant, Steele Properties, LLC, hereinafter referred to as “STEELE”, is a limited

liability company organized and existing under the Laws of the State of Colorado. STEELE

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has an address of 6875 E. Evans Street, Denver, Colorado 80224 and may be found for

purposes of service of process through its registered agent: CORPORATION SERVICE

COMPANY, 508 Meeting Street, West Columbia, South Carolina 29169.

9. Upon information and belief, the Owners, Operators, Directors and Key Principals of

STEELE own, operate, direct and manage other limited liability corporations organized

and existing under the laws of the State of Colorado with the address of 6875 E. Evans

Street, Denver, Colorado 80224 and which may be found for service of process at that same

address. Those limited liability companies are known as: STEELE PROPERTIES

ASSET MANAGEMENT I, LLC; STEELE PROPERTIES ASSET

MANAGEMENT II, LLC; STEELE PROPERTIES ASSET MANAGEMENT III,

LLC; STEELE PROPERTIES II, LLC; STEELE PROPERTIES III, LLC; STEELE

PROPERTIES IV, LLC; and STEELE PROPERTY VENTURES, LLC.

10. STEELE describes itself as a national real estate investment company and lists the Colony

Apartments in its portfolio.

11. The Defendant, Community Housing Concepts, Inc., hereinafter referred to as “NON-

PROFIT”, is a non-profit corporation organized and existing under the laws of the State

of Colorado. NON-PROFIT has an address of 6875 E. Evans Street, Denver, Colorado

80224 and may be found for purposes of service of process through its registered agent:

CORPORATION SERVICE COMPANY, 508 Meeting Street, West Columbia, South

Carolina 29169.

12. Upon information and belief, the organizers, incorporators, creators, directors, and key

principals of the NON-PROFIT organized, incorporated, created, directed and managed

other non-profit corporations under the laws of the State of Colorado for the same uses and

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purposes of the Defendant NON-PROFIT. Those non-profit corporations are known as:

COMMUNITY HOUSING CONCEPTS PROPERTIES I, LLC; and COMMUNITY

HOUSING CONCEPTS PROPERTIES, LLC.

13. The Non-Profit, upon information and belief, was created by STEELE, and or MONROE

and lists the Colony Apartments on its list of properties.

14. That the majority of all of the acts, omissions and events described in this Complaint

occurred or arose within the jurisdictional limits of the City of Columba, County of

Richland, and State of South Carolina.

15. That, for all purposes of jurisdiction and venue, the principal place of business for the

Defendants is the COLONY Apartments located within Richland County, South Carolina.

16. The City is a real party in interest to this litigation with a real, material, and substantial

interest in the outcome of this litigation.

17. This Honorable Court has jurisdiction over the parties and subject matter of this action

pursuant to Section 11 of Article V of the South Carolina Constitution, the provisions of

Article 7 of Title 15 of the Code of Laws of South Carolina, (1976, as amended), and

pursuant to the entirety of the Constitutional, Statutory, Procedural and Common Law of

the United States of America and the State of South Carolina.

FACTUAL ALLEGATIONS

18. Each and every allegation contained in the paragraphs above is hereby realleged herein as

though fully set forth below.

19. COLONY is a large apartment community within the City Limits of the City of Columbia

and subject to the rules, regulations and ordinances of the City of Columbia. As such, the

owners are required to have a business license as a landlord and they are required to obtain

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Residential Rental Permits from the Code Enforcement Division. In addition, the

COLONY is a customer of Columbia’s water and sewer district.

20. As a term or condition of a residential rental permit in the City of Columbia, a landlord or

owner must name a responsible local representative who resides or has an office within a

45 mile radius of the City of Columbia.

21. On or about the beginning of December, 2022, a leak occurred in the water supply lines

which provided fresh water to the Colony, not only hydration and hygiene but also for the

heating system for the units in the apartments which were steam based.

22. The infrastructure at the Colony Apartments is several decades old and the rupture was not

necessarily a cause for the City’s concern. However, beginning the evening of December

23, 2022, the Columbia metropolitan area experienced unusually cold temperatures for this

region. Due, in part, to the unusually cold temperatures, the leaks in the pipes increased to

approximately 230 gallons per minute, or over 300,000 gallons of water per day.

23. However, at the Colony Apartments, the dramatic water pressure decrease caused by the

leaks severely compromised the steam heating system for the tenants apartments. For

approximately 300 units, occupied by several hundred tenants, this meant Christmas Eve

and Christmas Day without water or heat on one of the coldest days on record in the

Columbia metropolitan area.1

24. Beginning on or about the morning of December 27, 2022, tenants of the Colony

Apartments reached out to their elected representatives and City officials for assistance

with the unfolding crisis. The City Manager dispatched the City’s supervisory staff from

1. 1
While it is to be expected a weather event would cause problems for the City’s water customers, the
present action is not about the weather event and its effects, but, rather, the lack of response to the effects of
the weather event.

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Columbia Water to assess the situation and confirm the leaks were leaving the tenants

without water or heat. Furthermore, engineers from the City of Columbia were

increasingly concerned because the situation was not being addressed by the staff of the

Colony. Our Director of Utility Operations concluded that the leaks were spilling

approximately 232 gallons per minute, (334,300 gallons per day). The Columbia Police

Department Code Enforcement Bureau was contacted and was engaged in determining any

code deficiencies as well.

25. While on the scene, City employees witnessed the critical situation of the residents of the

Colony. Of particular concern were the tenants with young children and the elderly tenants

of the Colony Apartments. Stories like this one caught the immediate attention and concern

of the Mayor, City Council, the City Manager and the City Staff.

26. As an added complicating factor for City Officials, the leaks detected were not in the city’s

infrastructure of the water system; they were leaks in the infrastructure owned and

maintained by the Colony Apartments. If this had been a failure of the City’s infrastructure,

Columbia Water would have immediately dispatched repair crews and resolved the

situation.

27. Columbia Code Enforcement Officers received a complaint the morning of December 27,

2022 that there were water mains which had burst with large water leaks. Upon arrival,

Code Enforcement Officers found the leaks and met with onsite maintenance. Together

they began going door-to-door to check the units. Some had no water and the others had

low water pressure. None of the units accessed at that time had heat.

28. Also the morning of December 27, 2022, a tenant of the Colony Apartments called the

Columbia Fire Chief about the situation at the Colony Apartments. A relative of a tenant

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also called the Fire Marshall on December 27, 2022. The Columbia Fire Department,

together with the Fire Marshall’s office, responded on the scene immediately. Deputy Fire

Marshalls were called onto the scene to investigate and inspect the units.

29. The Code Enforcement Officers and Fire Marshalls saw that many of the tenants were

desperately trying to heat their homes with the gas ovens and stoves in their kitchens.

30. The Defendants’ responsible local representative was unresponsive to the situation. She

would not cooperate, she misled City Officials, she failed to take any remedial measures,

and she did not communicate with the tenants about the situation.

31. While at the site, tenants talked to various members of City Staff and told their tragic

stories. The consistent theme was the tenants had reported the problems to the responsible

local representative of management, they had received very little assistance and inadequate

answers, if any. This was consistent with our staffs’ experience with the onsite employees

of the Colony. The apartment management on site did not have a list of tenants, they did

not know which apartments were affected, which apartments were vacant, and they

indicated they did not know who to call with authority. The Colony’s onsite maintenance

team were ill-prepared and ill-equipped to handle the situation. As Code Enforcement

attempted to make entry into units after knocking to ensure safety, the maintenance staff

could not provide keys for all of the units. This slowed down the process tremendously.

Eventually, a lock smith was required

32. The onsite manager of the COLONY informed City officials that she worked for the

Monroe Group out of Denver, Colorado.

33. At 11:26 a.m. on December 27, 2022, the Columbia Water Director of Utility Operations

called Colony Apartments phone number and got a generic phone message. At 11:28 a.m.,

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he called an alternate number for the Colony Apartments and got a voice mail

announcement, but the mailbox was full. At 11:30 a.m., the Director of Utility Operations

called a local number on the Monroe Group website and again received a voice mail. This

time he was able to leave a message. The Director of Utility Operations identified himself

and left a clear message about an “emergency water leak” and left a number at which he

could be reached. He followed that up with an email to the address on the Monroe Group

website.

34. Two hours later, the Director of Utility Operations received a call from a man named

Anthony McLain who wanted to know if the leak was with the City’s pipes or the Colony

Apartments. Mr. McLean was informed that the leaks were the Monroe Group’s pipes.

35. Mr. McLain stated that he had been trying to get a plumber out “since Friday” (12/23/2022)

but could not get anyone. The City’s Director of Utility Operations stressed to Mr. McLean

the urgency of the situation to the tenants, told him the tenants were reaching out to City

Leaders for help and urged him to get the repairs completed at the earliest opportunity.

36. By mid-afternoon, having heard nothing about the response to our urgent request, the

Director of Utility Operations called Mr. McLain back and left a message on his voice mail

for a return call.

37. The officials of the City Fire Marshall, the Code Enforcement Bureau of the Columbia

Police Department, the engineers from the water system, and the tenants of the COLONY

heard nothing more regarding any plan by the management of the complex for the

remainder of the day regarding the massive water leaks. Due to the danger facing the

tenants, the decision was made to evacuate the Colony due to the unsafe conditions at the

complex.

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38. The next day, at 8:08 a.m. on Wednesday, December 28, 2022, the City’s Director of Utility

Operations called the same phone number again and left another message stating the City

had made an emergency decision to repair the leaks with taxpayer resources and that the

cost of repairs would be charged back to the Monroe Group.

39. Mr. McLain called back six (6) minutes later to agree. The Director of Utility Operations

related to Mr. McLain again the City had determined the massive, continuous water leak

was a public health emergency. Because the Monroe Group had made no repairs, and

appeared to have no plan to do so, the City was going to proceed with the water line repairs

at the earliest opportunity. Mr. McLain was informed what the estimated cost of repair

would be and he agreed with our course of action. Mr. McLean also provided a phone

number to use to contact him. This conversation was documented in an email sent to the

Monroe Group fifteen minutes later.

40. Early on the afternoon of December 28, 2022, the City arranged to have Carolina Tap and

Bore completed repairs quickly and efficiently at 4501 Bailey Drive, 4902 Bailey Drive

and 6000 Bailey Drive. The water pressure was able to normalize and the system was able

to function. Carolina Tap and Bore is a vendor of the Columbia Water and was paid on a

purchase order account they currently maintain.

41. Although, the Monroe Group was unable to respond for four (4) days for a serious water

leakage of more than 300,000 gallons of water a day, the City and its private vendor

repaired the leaks and stabilized both the water and the heating system in a matter of

approximately four (4) hours.

42. Beginning on December 28, 2022, the President and General Counsel of the Monroe Group

began communicating with the City. They agreed to arrange for Monroe Group employees

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from other regions to travel to Columbia and participate directly in the response and

abatement of problems at the Colony.

43. On December 29, 2022, Monroe Group staff from other regions or states arrived on scene

to take over onsite coverage of the issue on behalf of the company. The situation stabilized,

and the inspections of the residential rental units proceeded more efficiently.

44. The results of the search was shocking. The condition of many of the apartments were

very poor and endangering the health and safety of the residents, especially the infants,

small children, elderly and disabled occupants. While the immediate concern was the lack

of water and heat, it soon became apparent that the continuing threat to the safety of the

residents were the numerous natural gas leaks. The gas appliances in the units and the

supply lines were poorly maintained. To make matters worse, many of the units were

without smoke alarms or carbon monoxide detectors.

45. The Colony Apartments have more than 300 units in 80 separate buildings. In twenty (20)

of the buildings the gas had to be shut off completely by Dominion Energy because of the

numerous leaks inside of the units.

46. Between December 29, 2022 and January 20, 2023, the Fire Marshalls had completed a

tremendous amount of work inspecting the units. They conducted 330 inspections. There

were ninety-two (92) apartments with deficiencies, and of those sixty-three (63) had

deficiencies which could not be occupied until the deficiencies were abated.

47. Code Enforcement began their inspections on December 27, 2022, but that inspection

process was interrupted by a murder which occurred on the site. The Columbia Police

Department responded to the shots fired call and cleared the property of other city staff.

The Code Enforcement officials received a call from Chief Holbrook several hours later to

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come back out to the scene to renew their efforts to assess and document the water and heat

crisis. The initial goal was to find out which apartments had heat and water, working in

coordination with officials of the Columbia Fire Department. After the decision was made

to evacuate, the city staff had to go back and inform the residents. Although the Colony

maintenance staff were present to help code enforcement gain access to each of the units,

they did not have keys for all of the units, which caused many units to be inaccessible.

Access to the units took a dangerously long time because of the lack of access.

48. Throughout the course of this event, the Code Enforcement Officers conducted more than

four hundred (444) inspections and re-inspections of individual units due to one hundred

forty-four (144) units being found in violation with the International Property Maintenance

Code.

49. Pursuant to §5-339c of the Code of Ordinance for the City of Columbia multiple

inspections of a rental unit to gain compliance will add $50.00 to the rental permit fee.

There were more than 444 inspections as a result of this event. In addition, points were

assessed against the permits for the violations found.

50. All of the City Staff observed tenants using gas appliances to heat their units, a dangerous

situation in any sense. But the unusually cold temperatures, the lack of adequate heat, and

the gas leaks attendant to the gas appliances were a serious and deadly combination. The

Mayor and the City Manager had joined the city staff on site and witnessed firsthand the

situation. The lack of response to the water/heat emergency together with the gas leaks

could not be ignored and so at this point the Mayor, City Manager, Fire Chief and Police

Chief jointly decided that the danger to the tenants was too great and the Colony

Apartments needed to be evacuated.

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51. Carolina Tap & Bore, Inc. is a local contractor who provides full service utility work and

often partners with the City of Columbia through Columbia Water. Because of this

ongoing relationship, Carolina Tap & Bore, Inc. (CT&B) works on a purchase order with

the Columbia Water System on an already approved contract. CT&B arrived at the Colony

Apartments on December 28, 2022 and found the three leaks in the pipes belonging to the

building. They were uncovered, repaired, tested and reburied. The concrete and

landscaping was remediated to a similar condition. The amount of the repairs equaled

twenty-six thousand six hundred seventeen dollars and fifty cents ($26,617.50).

52. CHC Colony Apartments, LLC has tendered reimbursement to the City for the expenses

of Carolina Tap & Bore, Inc. on April 11, 2023 ($26,617.50), more than one hundred days

after the repairs were made to the Colony infrastructure.

53. The City of Columbia Parks and Recreation Department supplied two buses and a driver

to help relocate the tenants of the Colony Apartments to safety on the evening of December

27, 2022. The rental for the bus equals the sum of Three Hundred Ninety-Four and 62/100

($394.62) Dollars.

54. The massive undertaking by the City and its various departments was coordinated through

the use of a mobile command center from the Columbia Police Department. The standard

usage fee for the Mobile Command Bus equals the sum of Nine Hundred Seventy-One and

43/100 ($971.43) Dollars.

55. At least twenty (20) fire personnel dispatched to this event. Based upon the time records

for the City, payroll costs borne by the taxpayers through the Columbia/Richland Fire

Department for its excess personnel costs would equal the sum of Twenty Thousand Eight

Hundred and Eighteen ($20,818.00) Dollars.

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56. During the event, fourteen (14) Code Enforcement Officers of the Code Enforcement

Division of the Columbia Police Department participated at different times for several days

working on this ongoing event. We believe a minimum sum that would compensate the

taxpayers through the Columbia Police Department for its excess personnel costs by its

Code Enforcement Bureau would be $14,315.00.

57. The Columbia Police Department provided security and assistance to the tenants and the

property during this event. Based upon the time records for the City, payroll costs borne

by the taxpayers through the Columbia Police Department for its excess personnel costs

for uniformed officers providing security and organizing the evacuation would be equal to

the sum of Thirteen Thousand Nine Hundred and Eight and No/100 ($13,908.00) Dollars.

58. Parks and Recreation assisted in transporting the tenants to hotels as a result of the

emergency evacuation. We believe that a minimum sum that would compensate the

taxpayers through the Columbia Parks and Recreation Department for its excess personnel

costs for facilitating the evacuation of the Colony Apartments would be $77.00.

59. Meals for the residents of the Colony Apartments equal the sum of $1,645.05.

FOR A FIRST CAUSE OF ACTION

(Quantum Meruit)
60. Each and every allegation contained in the paragraphs above is hereby realleged herein as

though fully set forth below.

61. The CITY undertook to confer benefits on the COLONY during a period of a weather event

which caused a substantial health and safety event on that property. The benefit being the

protection of the health and wellbeing of their tenants due to the conditions of the

apartments.

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62. The Defendants realized the benefit of the efforts and actions taken by the CITY to stabilize

the living situation of the tenants of the COLONY.

63. The Defendants have retained the benefit under conditions which make it unjust for the

Defendants to retain the benefit without paying its value.

64. The value of the benefit conferred upon the Defendants is equal to the sum of the following:

a. The rental for the City of Columbia Parks and Recreation Department buses equals
the sum of Three Hundred Ninety-Four and 62/100 ($394.62) Dollars.
b. The standard usage fee for the Columbia Police Department Mobile Command Bus
equals the sum of Nine Hundred Seventy-One and 43/100 ($971.43) Dollars.
c. Columbia/Richland Fire Department excess personnel costs equal the sum of
Twenty Thousand Eight Hundred and Eighteen ($20,818.00) Dollars.
d. Columbia Police Department for its excess personnel costs by its Code
Enforcement division is equal to the sum of Fourteen Thousand, Three Hundred
and Fifteen and No/100 ($14,315.00) Dollars.
e. Columbia Police Department for its excess personnel costs for uniformed officers
providing security and organizing the evacuation would be equal to the sum of
Thirteen Thousand Nine Hundred and Eight and No/100 ($13,908.00) Dollars.
f. Columbia Parks and Recreation Department for its excess personnel costs for
facilitating the evacuation of the Colony Apartments would be Seventy-Seven and
No/100 ($77.00) Dollars.
g. Meals for the residents of the Colony Apartments equal the sum of one Thousand,
Six Hundred and Forty-Five and 5/100 ($1,645.05) Dollars.

65. Based upon the foregoing, the CITY is informed and believes that this Honorable Court

should inquire into the facts and circumstances of this matter and enter a judgment in favor

of the CITY and against the Defendants for the amount of Fifty-Two Thousand One

Hundred and Twenty-Nine and 10/100 ($52,129.10) Dollars.

FOR A SECOND CAUSE OF ACTION –

(Permanent Injunction)

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66. Each and every allegation contained in the paragraphs above is hereby realleged herein as

though fully set forth below.

67. Upon information and belief, the Colony was purchased by the Defendants, or a

combination of them, in 2016 as an investment property for low income housing through

the Low-Income Housing Tax Credit program of the United States Department of Housing

and Urban Development.

68. That the Defendants, as alter egos each of the other, have mismanaged the COLONY and

allowed the property to fall below the minimum standards required by the applicable Code

of Ordinances of the City of Columbia including, but not limited to, the International

Property Maintenance Code, the International Fire Code, the Residential Rental Properties

Regulations and other applicable ordinances.

69. That, upon information and belief, the corporate structure of Steele Properties, Community

Housing Concepts, Inc. CHC Colony Apartments, LLC, and CHC Colony Apartments

LIHTC MM, LLC is designed to prevent accountability by local government officials on

the Colony Apartments.

70. Further, the failure of the responsible local representative has limited the City’s ability to

communicate with the owner or landlord to address immediate concerns, which is the

nature and spirit of the requirement to have a local representative.

71. Given the history of violations and inattention to the conditions of the property, the City is

informed and believes that the Defendants should be permanently ordered, enjoined, and

required to maintain the Colony to the standards set by all applicable ordinances, statutes,

rules, regulations and laws of the City of Columbia.

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Now therefore, based upon the foregoing, the City of Columbia prays that this Honorable Court

inquire into the facts and circumstances of this matter and issue an order granting the following

relief:

a. Judgment against the Defendants, jointly and severally, in the amount of the total

sum of FIFTY-TWO THOUSAND ONE HUNDRED AND TWENTY-NINE

AND 10/100 ($52,129.10) DOLLARS;

b. For an order issuing an injunction requiring the Defendants to maintain the

COLONY APARTMENTS to the minimum standards required by all applicable

ordinances, statutes, rules, regulations and requirements of the Code of Ordinances

for the City of Columbia;

c. For such other and further relief as this Court may determine to be just and proper.

Respectfully submitted,

CITY OF COLUMBIA

s/ W. Mike Hemlepp, Jr.

BY: ____________________________
W. Mike Hemlepp, Jr., Esq. (SCBar #64264)
Senior Assistant City Attorney – Litigation
Post Office Box 667
Columbia, South Carolina 29202
Telephone: 803-737-4242
Email: William.Hemlepp@columbiasc.gov

ATTORNEY FOR THE PLAINTIFF, CITY OF

COLUMBIA

April 17, 2023

Columbia, South Carolina

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