ELECTRONICALLY FILED - 2024 Feb 12 2:25 PM - ORANGEBURG - COMMON PLEAS - CASE#2024CP3800214

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

) FOR THE FIRST JUDICIAL CIRCUIT
COUNTY OF ORANGEBURG )
) DOCKET NO.: 2024-CP-38-________
Gwendolyn Snider, )
)
PLAINTIFF, )
) Summons
V. ) (Jury Trial Requested)
)
Crestlawn Memorial Gardens and Faithful )
Heritage Holdings, Inc., )
)
DEFENDANTS. )
____________________________________)

TO: THE DEFENDANTS ABOVE NAMED:

YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action
of which a copy is herewith served upon you, and to serve a copy of your Answer to the said
Complaint on the subscriber at her office, Post Office Box 2132, Orangeburg, South Carolina,
29116 within thirty (30) days after the service thereof, exclusive of the date of such service and if
you fail to answer, appear, or defend, judgment by default will be rendered against you for the relief
demanded in the Complaint.

s/Samantha D. Farlow-Moyd
Samantha D. Farlow-Moyd, Esquire
Attorney for Plaintiff
Post Office Box 2132
Orangeburg, South Carolina 29116
(803) 534-3557 (Telephone)
(803) 937-3181 (Facsimile)
[email protected]

Orangeburg, South Carolina

January 22, 2024
 ELECTRONICALLY FILED - 2024 Feb 12 2:25 PM - ORANGEBURG - COMMON PLEAS - CASE#2024CP3800214
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FOR THE FIRST JUDICIAL CIRCUIT
COUNTY OF ORANGEBURG )
) DOCKET NO.: 2024-CP-38-________
Gwendolyn Snider, )
)
PLAINTIFF, )
) Complaint
V. ) (Jury Trial Requested)
)
Crestlawn Memorial Gardens and Faithful )
Heritage Holdings, Inc., )
)
DEFENDANTS. )
____________________________________)

Plaintiff, complaining of Defendant, would respectfully show unto the Court:

JURISDICTION & VENUE

1. Plaintiff is a citizen and resident of Orangeburg County, South Carolina.

2. Defendant Faithful Heritage Holdings, Inc. is a company organized under the laws of

the State of Florida, doing and transacting business in Orangeburg County, South

Carolina through its agents, representatives, and/or employees.

3. Plaintiff is informed and believes Faithful Heritage Holdings, Inc. is the owner and

operator of Crestlawn Memorial Gardens located at 4830 Columbia Road in Orangeburg,

South Carolina.

4. This court has jurisdiction in this matter and venue is proper.

5. Plaintiff’s husband, Saint Julian Snider, Sr., died on October 10, 2022.

6. The parties entered into a Cemetery Purchase Agreement whereby the Defendants

were to provide mausoleum entombment services and an identification marker for the

burial chamber/mausoleum crypt. In consideration for these services, Plaintiff paid

$9,932.00 to the Defendants in November 2022.

 ELECTRONICALLY FILED - 2024 Feb 12 2:25 PM - ORANGEBURG - COMMON PLEAS - CASE#2024CP3800214
7. Pursuant to the contract, the remains of Plaintiff’s husband were to be placed in mausoleum

chamber #7. On the day of entombment, Defendants placed the remains in chamber #7. As

such, Plaintiff, her children, and their family would visit burial chamber #7 to honor the

decedent, share memories, and facilitate the grieving and healing process. They believed

decedent’s remains were in that particular chamber.

8. After the entombment services were performed, Plaintiff spoke with Ken, Defendants’

employee, who informed her it would take a couple of weeks to get the marker installed.

However, it took more than a year for the marker to be installed. During that year, Plaintiff

spoke numerous times with Defendants’ employees (Ken and Lee Mabe) who made a plethora of

excuses as to what caused the delay.

9. Each time Plaintiff spoke with the Defendants she was in distress and grieving the loss of her

beloved husband of more than 30 years.

10. Plaintiff and her family held a memorial service on October 8, 2023 at the mausoleum

(burial chamber #7). There was no marker on the burial chamber/crypt. Prior to the memorial

service, Defendants told Plaintiff a temporary marker would be installed so she and her family

could host a proper service. However, when Plaintiff arrived at the memorial service, there was

no temporary marker as promised by Defendants.

11. Due to the unreasonable delay in the installation of the marker and unresponsiveness from

Defendants, Plaintiff retained legal counsel. After legal involvement and more than one year

following decedent’s death, the Defendants finally installed the marker, but on the wrong burial

chamber.

12. When Plaintiff went to inspect the marker, it was installed on Chamber #9 and not #7.

Plaintiff informed the Defendants that the marker was placed on the wrong chamber, and she
 ELECTRONICALLY FILED - 2024 Feb 12 2:25 PM - ORANGEBURG - COMMON PLEAS - CASE#2024CP3800214
proved her claim by showing the Defendants pictures of the chamber from the date of husband’s

entombment.

13. Thereafter, Plaintiff, a funeral home director, and the Defendants opened Chamber #7 and

discovered that the decedent’s remain were not inside. Defendants then opened Chamber #9 and

after checking the serial number on the urn in that chamber, it was discovered that decedent’s

remain were in Chamber #9 and not Chamber #7.

14. Defendants then admitted to Plaintiff that her husband’s remains were initially placed in

Chamber #7 on the date of entombment but moved to Chamber #9 sometime later without

Plaintiff’s permission or knowledge.

15. As a result of the foregoing, Plaintiff who was grieving the loss of her husband, was shocked

and in severe emotional distress. For more than a year, she had been visiting a burial chamber

where her husband’s remains had been removed. She was left with the horror and shock that her

husband’s burial chamber had been opened and remains removed without her permission and/or

knowledge. Plaintiff was in further distress due to the fact she had held her husband’s memorial

service at an empty burial chamber. Such distress caused headaches, humiliation, severe

sadness, anxiety, exacerbated grief, and intense suffering. As a result, Plaintiff sought spiritual

and medical counseling services.

FIRST CAUSE OF ACTION

(Intentional Infliction of Emotional Distress/Outrage)

16. The allegations above are incorporated by reference as if set forth herein.

17. Defendants recklessly or intentionally inflicted severe emotional distress or were certain or

substantially certain that such distress would result from their conduct.

18. Defendants’ conduct was so extreme and outrageous as to exceed all possible bounds of

decency and must be regarded as atrocious, and utterly intolerable in a civilized community.
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19. Defendants’ actions caused the Plaintiff’s emotional distress, and such distress was so severe

that no reasonable person could be expected to endure it.

20. As a direct and proximate result of the Defendants’ recklessness and willfulness, Plaintiff

suffered severe emotional distress, anxiety, humiliation, exacerbated grief, loss of capacity for

enjoyment of life, and medical expenses.

SECOND CAUSE OF ACTION

(Gross Negligence)

21. The allegations above are incorporated by reference as if set forth herein.

22. Defendants had a duty to properly perform the entombment process including adequately

placing and leaving the decedents’ remains in the proper burial chamber.

23. Such duty was breached when the Defendants engaged in grossly negligent acts and/or

omissions as follows:

A. Unsealing and opening the decedent’s burial chamber without the permission and
knowledge of Plaintiff;
B. Removing the decedent’s remains from the burial chamber without the permission and
knowledge of the Plaintiff;
C. Placing the marker on the incorrect burial chamber;
D. Permitting Plaintiff to hold a memorial service at a burial chamber that did not contain
her husband’s remains;
E. Causing Plaintiff to visit and grieve at an empty burial chamber;
F. Failing to install the temporary marker prior to the memorial service;
G. Failing to notify Plaintiff that her husband’s remains had been moved to a different
burial chamber; and
H. In other particulars that may be discovered throughout litigation.
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24. Such grossly negligent actions and/or omissions constitute the intentional, conscious failure

of the Defendants to perform its services as a reasonable cemetery under similar circumstances

would have done.

25. Defendants failed to exercise the slightest care in the performance of its services.

26. As a direct and proximate result of the Defendant’s gross negligence and recklessness,

Plaintiff suffered severe emotional distress, anxiety, humiliation, exacerbated grief, loss of

capacity for enjoyment of life, and medical expenses.

PRAYER FOR RELIEF

WHEREFORE Plaintiff demands judgment against the Defendant for such sum of actual

and punitive damages as a jury may find, for the costs of this action, and for such other relief as this

Court may deem just and proper.

s/Samantha D. Farlow-Moyd
Samantha D. Farlow-Moyd, Esquire
Attorney for Plaintiff
Post Office Box 2132
Orangeburg, South Carolina 29116
(803) 534-3557 (Telephone)
(803) 937-3181 (Facsimile)
[email protected]

Orangeburg, South Carolina

February 12, 2024