ELECTRONICALLY FILED - 2021 Jun 24 4:37 PM - HORRY - COMMON PLEAS - CASE#2021CP2604199

STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS

State of South Carolina on the relation of

vs.

Vishu Bhambhani and Harkishin Bhambhani

RESPONDENTS.

TO THE RESPONDENTS ABOVE-NAMED:

YOU ARE HEREBY SUMMONED and required to answer the Petition in this action, a
copy of which is herewith served upon you, and to serve a copy of your Answer to said Petition
on the subscribers at their offices at Post Office Box 530, Conway, South Carolina 29528-0530,
within thirty (30) days after the service hereof, exclusive of the day of such service; and if you
fail to answer the Petition, or to otherwise responsively plead to the Petition, or to otherwise
appear and defend, within the time aforesaid, the Petitioner in this action will apply to the Court
for judgment by default against you, for the relief demanded in the Petition.

s/James R. Battle
SC Bar #73604
Special Prosecutor for the 15th Judicial Circuit
Battle Law Firm, LLC
P.O. Box 530
Conway, South Carolina 29528
P: 843-248-4321
[email protected]
June 24, 2021

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STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
THE FIFTEENTH JUDICIAL CIRCUIT
HORRY COUNTY CASE NO.: 2021-CP-26-

State of South Carolina on the relation of

PETITIONER, PETITIONER’S VERIFIED PETITION

Vishu Bhambhani and Harkishin Bhambhani

RESPONDENTS.

Petitioner respectfully alleges:

1. Petitioner is the duly elected Solicitor of the Fifteenth Judicial Circuit of the State of

South Carolina.

2. Petitioner brings this action in the name of the State of South Carolina, pursuant to South

Carolina Code §§ 15-43-10 through 130.

3. This action is brought and prosecuted for the purpose of temporarily and permanently

enjoining and abating a certain public and common nuisance, as defined by S.C. Code §§ 15-43-

10 through 130, existing as a motel called the Coral Sands Motel located at 301 N. Ocean

Boulevard, Myrtle Beach, South Carolina in Horry County (hereinafter the “Coral Sands”).

4. The Coral Sands sits on two separate lots. The main lot is on the west side of Ocean

Boulevard and is made up of three interconnected buildings. The smaller lot is on the east side of

Ocean Boulevard or ocean front side and is made up of one large building. The two lots are

across from each other.

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5. Respondent Vishu Bhambhani is the real property owner where the Coral Sands is

located.

6. Respondent Harkishin Bhambhani owns and operates the Corals Sands through Four

Nice Brothers, LLC.

7. Petitioner personally served written notice of the public nuisance on Respondent Vishu

Bhambhani on June 7, 2021.

8. More than ten days has elapsed since the service of the notice of public nuisance and to

date the nuisance remains unabated.

9. Petitioner is informed and believes that the Coral Sands Motel has the general reputation

for lewdness, assignation, prostitution, and repeated acts of unlawful possession or sale of

controlled substances, to wit:

For several years, guests and employees of the Coral Sands have used the Motel
to use and distribute illegal drugs and engage in prostitution.

Since February 2018, City of Myrtle Beach police officers and officials have met
with the business owner, Respondent Harkishin Bhambhani, and its manager to
address the Motel’s dilapidated condition and its high calls for service. Despite
working with the owner and manager, the Coral Sands’ nuisance activity
remained unabated.

In March 2021, the Myrtle Beach Police Department began an investigation of the
Coral Sands. This investigation determined most of the guests at the Coral Sands
use the Motel to distribute illegal drugs and engage in prostitution. Management
and security purchase illegal drugs from tenants and provide discounts on rooms
in exchange for drugs and sex acts. Management also accepts bribes in exchange
for allowing people to sell drugs at the Coral Sands and has a room set aside for
drug use and prostitution.

10. The above-mentioned acts and conduct which occur on the premises are offensive to

public decency, morals, peace, and health, and constitute a public nuisance which is subject to

abatement under S.C. Code Ann. §§ 15-43-10 through 130, and should be forthwith enjoined and

abated.

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11. Petitioner is further informed and believes that the furniture, personal property, and other

fixtures located on said premises are owned by the Respondents and are used for the purpose of

furthering the public nuisance.

12. Petitioner is informed and believes it is entitled to a temporary injunction closing the

Coral Sands Motel until such time that the matter can be heard on its merits.

13. Petitioner is informed and believes it is entitled to an injunction closing the Coral Sands

Motel for a period of one year pursuant to S.C. Code Ann. §§ 15-43-10 through 130.

14. Petitioner is informed and believes it is entitled to a judgment for its costs incurred in

abating the public nuisance of the Coral Sands Motel.

15. Petitioner is informed and believes that unless Respondents are enjoined by the court, the

Coral Sands Motel will continue to operate as a public nuisance to the harm and detriment of the

City of Myrtle Beach.

Wherefore, Petitioner requests:

a. All of the above-named Respondents and their agents, servants, subordinates, and

employees, and each and every one of them, be enjoined and restrained from using, maintaining,

and assisting in the using and maintaining of the Coral Sands Motel, as a place where the above

alleged conduct, acts and public nuisance are carried on in violation of S.C. Code Ann. §§ 15-43-

10 through 130.

b. This court shall by order direct and command the Myrtle Beach Police Department to

summarily abate the public and common nuisance now existing on the premises and for that

purpose to take possession of the premises and to close the same and take possession of all the

furniture, equipment, fixtures and other property now used on the premises in connection with

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the violation alleged above as constituting a nuisance and to remove the same and all of the same

to a place of safekeeping to await further order of this court;

c. This court shall forthwith issue a temporary injunction, pursuant to S.C. Code Ann. § 15-

43-30, restraining Respondents from conducting or permitting the continuance of the nuisance

and shall order that the building and premises be closed until the conclusion of the trial of this

case; and that such temporary injunction restrain Respondents, and their agents, servants,

subordinates, and employees and all persons, from removing or in any way interfering with the

furniture, equipment fixtures and other property used in connection with the violation of the

statute;

d. This court shall enter a decree perpetually restraining Respondents and their agents,

servants, subordinates, employees and each and every one of them, from maintaining or

permitting the nuisance and from using the premises or buildings in which the same is

maintained for any purpose for a period of one year, and perpetually restraining Respondents and

their agents, servants, subordinates, and employees, from maintaining any such nuisance within

the State of South Carolina;

e. This court shall enter an order of abatement as part of this decree, which order shall direct

the Chief of Police for the Myrtle Beach Police Department to remove from the building or

premises all fixtures and movable property used in conducting or aiding or abetting the nuisance,

and to sell the same in the manner provided by law for the sale of personal property, and to close

the building or premises or such place against its use for the purpose and to keep it closed for a

period of one year;

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f. This court shall order and direct that service of any orders in this matter, temporary or

perpetual, on the employees and affiliates of Respondents be accomplished by posting a copy of

the order in plain view on the main front door entrance of the Coral Sands Motel;

g. This court shall order the Respondents to pay the costs incurred by the Petitioner in

abating the public nuisance;

h. For such other relief as to this court may deem just and proper.

s/James R. Battle
SC Bar #73604
Special Prosecutor for the 15th Judicial Circuit
Battle Law Firm, LLC
P.O. Box 530
Conway, South Carolina 29528
P: 843-248-4321
[email protected]
June 24, 2021