Using the South Carolina Rules of Civil Procedure, find out which court has proper jurisdiction and draft a complaint, and prepare a proof of service, a summons and a civil court coversheet.

For this exercise we will assume the plaintiff and defendant live in Richland County and Mr. Stamper the defendant has not obtained legal counsel.

LAW OFFICE OF SARAH JONES 1234 MAIN STREET COLUMBIA, SC 12345

January 1, 2021

Re: New Client I met with a Mr. Samuel Shealy today. Mr. Shealy sells gym equipment to body builders. He has come to our office because he wants to recover money for damages stemming from a visit to his former customer's place of work. Mr. Shealy stated that on December 1, 2019, he was visiting his customer, Mr. Harry Stamper, at Mr. Stamper's oil rig located at Stamper's Oil Rig, Inc. in Richland County. While he was walking underneath an area Mr. Stamper had been working on, a large wrench fell from a pipe and fractured Mr. Shealy's skull. According to Mr. Shealy, Mr. Stamper ran up and yelled, "I am so sorry! This is exactly why our safety standards tell us not leave the wrenches on pipes." Mr. Shealy claims that during his recovery Mr. Stamper told Mr. Shealy's other customers that the accident resulted because Mr. Shealy was incorrectly using his gym equipment. Mr. Stamper allegedly told one customer, "I would never buy gym equipment from a man who doesn't even know how to use it." Mr. Shealy left the hospital on February 1, 2020, having accumulated $80,000 in medical bills. Additionally, he suffered lost wages of approximately $30,000, and claims that as a direct result of Mr. Stamper's comments, he has seen a 50% drop in sales since his discharge. Mr. Shealy would like to recover damages for his medical bills, lost wages, lost business, and any other damages available to him. Please draft a complaint and the other appropriate paperwork needed to file this claim. Client Information Mr. Samuel Shealy 35 Ross Avenue Columbia, SC 12345 Defendant(s) Information Mr. Harry Stamper Stamper's Oil Rig, Inc. 13 Armageddon Drive Columbia, SC 1234