|THE STATE OF SOUTH CAROLINA THE COUNTY OF OCONEE IN THE MATTER OF: DOYLE ELTON PIERCE, DECEASED JARED ADAM PIERCE (Petitioner) vs. DOROTHY PIERCE (Defendant)||IN THE PROBATE COURT CASE NO.:2020ES3700532 AMENDED MOTION FOR NEW TRIAL; & MEMORANDUM OF LAW IN SUPPORT OF AMENDED MOTION FOR NEW TRIAL|
COMES NOW, Defendant Dorothy Pierce (hereinafter “Defendant) and respectfully files this Amended Motion for New Trial herein and in support thereof would show unto the Court that the Defendant is entitled to a New Trial.
This motion, made pursuant to Rule 59 of the South Carolina Rules of Civil Procedure, will be based on the accompanying Memorandum of Points and Authorities, the attached Affidavit in Support, and any exhibits thereof, and on such oral and documentary evidence as may be presented at the hearing of the motion.
Dated: [ENTER DATE]
Defendant, pro se.
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF AMENDED MOTION FOR A NEW TRIAL
This case concerns the validity of a will made by the deceased. Accordingly, on August 18, 2021, a judgment entitled “ORDER ON MOTION TO DETERMINE VALIDITY OF WILL” was signed by this Court in this case. The Defendant subsequently filed a Motion for a New Trial on August 23, 2021. The Defendant seeks to file the instant Amended Motion for a New Trial in lieu of the already filed Motion for New Trial. The Defendant herein moves this Honorable Court to set aside its Judgment dated August 18, 2021, and to grant her a new trial.
In November 2017, Defendant was looking for a house to rent within a reasonable price tag. Since she had a small manufacturing business, she had a second requirement: she wanted a house with a spare storage space for my manufacturing business. Craigslist was the only cheapest platform to find houses for rent within the upstate community. She therefore searched a few houses and the Deceased, Doyle Pierce, had listed for lease, a room in his 3-bedroom brick house in a small city of Seneca, Oconee County, SC. After chatting to him, he had a room for rent and a 5000 Sf warehouse that Defendant could rent after clean up.
Defendant met Doyle in Greenville and they drove to Seneca to see the house. The Deceased had the dirtiest and the most disorganized house and yard Defendant had ever set her eyes on her entire life. The house looked like it had never been cleaned up for a decade. The Deceased told Defendant that if she wanted to leave, he would understand. On the contrary, Defendant told him that she would still rent the room if the Deceased allowed her to clean up his entire house. He was excited. It took Defendant fifteen days to clean the house including arranging Defendant’s new room.
During the clean-up, the Deceased helped the Defendant whenever he could. There were so many items to move to the dumpster. Sometimes the Deceased was running the bob cat while the Defendant loaded the trash on foot.
Two weeks later, the Deceased told the Defendant that he would have looked a thousand years and never found a woman like her. He asked Defendant to marry him, but he had not even asked her out on a date yet. Defendant told him to start from the beginning by asking her out on a date. The two joked and laughed about it. Subsequently, they went on a series of “cleaning dates” and fell head over heels for each other. A few weeks later, Defendant also discovered that the Defendant had also earlier posted another ad on craigslist looking for a young woman to bear him children. He was abandoned by his own children and family.
The two got married on February 14, 2018. The Defendant wondered why the Deceased wanted children at his age but the answer came in handy a few weeks later when the couple decided to visit the Deceased’s eldest son, Jared Adam Pierce, the plaintiff. It was 2:45pm in the afternoon when the Deceased knocked at his son’s door. Plaintiff opened the door slightly and immediately asked his father “What? What do you want? The Defendant blubbered, “I came to visit you, are you not going to let me in? “Hell no, go the F..k away.” Replied the Plaintiff. The Deceased left in shame. For a long time, he never said much. It took several months before he would want to talk to his son again. Accordingly, when the father and son rekindled their relationship, the Plaintiff asked his father for a piece of land so his wife and him could buy a trailer and move in. The Deceased, Plaintiff, Plaintiff’s wife Sandy Phillips Pierce and Defendant went down to cedar hill farm where Plaintiff picked up the best river front plot of land. He asked Deceased to cut the land and make the deed in his name, but the Deceased refused. He willed the land to Plaintiff on his last will and testament dated July 20, 2020.
The Deceased’s second son, Greg Pierce never talked to his father for over 10 years. Greg Pierce showed up in April 2020 when the Easter storm hit Seneca and destroyed almost everything the Deceased had worked for his entire life, three months before the Deceased passed away. After a few weeks of helping with cleanup after the storm, Greg Pierce asked the Deceased for land and a favor to pay for a trailer since he did not have any credit or a home. His credit was so bad that he could not get any mortgage or loan. He offered to pay the Deceased cash as his father paid the mortgage company. The Deceased refused to loan him but gave him the land on Cedar hill Farm and an old trailer where his daughter still lives in up to the time of this filing. The Deceased willed the land and Trailer to his son on his last will and testament dated July 7, 2020.
The Deceased‘s youngest daughter Donna Pierce stayed angry at the Deceased for several years for calling her daughter Ashley a Queer. For the last three years of the Deceased’s life, the Defendant was both light and hope to him. When everyone abandoned him, the Defendant accepted, respected, and loved him unconditionally irrespective of Defendant’s financial status. Defendant was the only one available when he needed someone. When he was sick, Defendant was always by his side. When he needed to go to the hospital for his appointments, it was Defendant who accompanied him. When his blood sugar dropped in the middle of the night, Defendant was the one that got up and made him something sweet to drink. When his sons humiliated him, it was Defendant who comforted him. When he was lonely, it was Defendant who gave him, company. When he was happy, it was Defendant that he shared his joy with. When Defendant got pregnant and had a miscarriage, the Deceased was there for her.
Before his death, the Deceased made a will and credible witnesses signed it. He passed away around three months after making the will. However, after his death, the Plaintiff contested the validity of the will
On or about July 7th, 2020, the Deceased executed the last will and testament in compliance with SC Code § 62-2-502 (2017). Notably, the will was in writing and was signed by at least two individuals, each of whom witnessed either the signing or the testator’s acknowledgment of the signature or of the will. Shortly thereafter, the decedent died at Prisma hospital, Oconee County on September 14th, 2020, at the age of 74 years, 3month, & 29 days.
On or about September 23rd, 2020, the Defendant was legally appointment Personal Representative of the Estate of Doyle Elton Pierce. The Plaintiff contested the will and testament of the Deceased dated July 7, 2020, with the Probate Court. He relied on handwriting experts who used signature exhibits as old as 1971-1992.
On November 11, 2020, the Plaintiff’s Attorney Rick McDuff reported an incident case to Oconee County Sheriff Department on the account of counterfeiting/forgery. The sheriff department investigated the case thoroughly and closed the investigation, after finding NO WRONGDOING on the part of the Defendant.
Furthermore, on January 22, 2021, the Plaintiff and his attorney further contacted five of the Defendants’ clients exhorting them to file complaints against the Defendant both in Court and with the police in a bid to make the Petitioner’s probate case stronger. Two clients of the Defendant filed cases of breach of trust with the sheriff department. After investigations, the Sheriff again closed their cases after finding NO ILLEGAL BEHAVIOR on the part of the Defendant.
On or about August 2, 2021, the Probate Court ruled to set aside the will.
- THE LAST WILL AND TESTAMENT WAS PREPARED AND EXECUTED IN FULL ACCORDANCE WITH SC. Code § 62-2-502.
“A will is an expression of a testator’s intent to dispose of the testator’s property after death.” In re Estate of Pallister, 363 S.C. 437, 448, 611 S.E.2d 250, 256 (2005).
SC. Code § 62-2-502 provides the requirements for a valid will. Accordingly, a valid will should meet the following requirements:
… every will shall be:
(1) in writing;
(2) signed by the testator or signed in the testator’s name by some other individual in the testator’s presence and by the testator’s direction; and
(3) signed by at least two individuals each of whom witnessed either the signing or the testator’s acknowledgment of the signature or of the will.
Pursuant to SC. Code § 62-2-506(a), a will or any part thereof is revoked: (1) by executing a subsequent will that revokes the previous will or part expressly or by inconsistency; or (2) by being burned, torn, canceled, obliterated, or destroyed, with the intent and for the purpose of revoking it by the testator or by another person in the testator’s presence and by the testator’s direction.
Besides, revocation by an act or by a subsequent instrument must be accompanied by an intention to revoke, and, without the intention, revocation does not take place. Johnson v. Brailsford, 11 S.C.L. 272 (1820) (mutilated will requires evidence that testator intended to destroy it).
In the instant action, the Court significantly erred in invalidating the last will and testament of the Decedent dated July 7th, 2020, even though the Will was executed in compliance with the South Carolina Code Laws. Notably, the said Will was in writing; was duly witnessed by two witnesses; each of the said witnesses appended their signatures thereon; and the Decedent appended his signature and/or initials.
Besides, the petitioner did not provide any verbal or factual evidence to show that the Decedent revoked the will. There is also no evidence that shows that the Decedent had intentions to revoke the will, as required by the law. Accordingly, the Decedent’s will was duly executed.
- DEFENDANT IS ENTITLED TO A NEW TRIAL TO PROVIDE ADDITIONAL TESTIMONY
According to S.c. R. Civ. P. 59, a Court’s previous judgment may be opened to provide additional testimony. S.c. R. Civ. P. 59(a)(2) provides in that regard that:
(a) Grounds. A new trial may be granted to all or any of the parties and on all or part of the issues … (2) in an action tried without a jury, for any of the reasons for which rehearings have heretofore been granted in the courts of the State. On a motion for a new trial in an action tried without a jury, the court may open the judgment if one has been entered, take additional testimony, amend findings of fact and conclusions of law or make new findings and conclusions, and direct the entry of a new judgment. (Emphasis added).
“Post-trial motions are … utilized to raise issues that could not have been raised at trial.” Jean H. Toal, Amelia W. Walker & Margaret E. Baker, Appellate Practice in South Carolina 189 (3d ed. 2016).
The Defendant’s expert document examiner, whose report dated, July 29th, 2021, validated that, the Decedent authored the last Will and Testament dated, July 7th, 2020, was not able to attend Court due to insufficient time to prepare. The Defendant’s expert witness testimony is crucial in validating the last Will and Testament of the Decedent. Justice will not be properly served unless the expert document examiner of the defendant testifies in Court.
- THE PLAINTIFF DID NOT MEET THE BURDEN OF PROOF REQUITRED TO SUCCESFULLY CHALLENGE A WILL
According to S.C.Code Ann. § 62-3-407, contestants of a will have the burden of establishing undue influence, fraud, duress, mistake, revocation, or lack of testamentary intent or capacity. See In re Estate of Cumbee, 333 S.C. 664, 671, 511 S.E.2d 390, 393 (Ct.App.1999).
The Supreme Court of South Carolina went ahead to state in Calhoun v. Calhoun, 277 S.C. 527, 530, 290 S.E.2d 415, 417 (1982) that:
When the formal execution of a will is admitted or proved, a prima facie case in favor of the will is made out, and the burden is then on the contestants to prove undue influence, incapacity or other basis of invalidation. The contestants continue to bear the burden of proof throughout the will contest. (Emphasis added).
The contestants of a will must do so by clear and convincing evidence. Russell v. Wachovia Bank, N.A., 353 S.C. 208, 217, 578 S.E.2d 329, 333 (2003).
A will that is prepared and duly executed according to the required procedure must be given due regard as a valid will unless controverted by sufficient evidence. The Court in Kaufman v. Kaufman, 49 S.C. 159, 27 S.E. 16, 61 Am. St. Rep. 808; Mordecai v. Canty, 86 S.C.  476, 68 S.E. 1049 held in that regard that:
It is true that ordinarily the proof of a paper writing, signed and witnessed according to the statute, and purporting to be a will, entitles it to be regarded as such. And it will be then presumed, as matter of fact, that the testator knew the contents of the paper. The contestant must show the contrary.
In the instant action, the Court erred in admitting the fraudulent third-party signature exhibit dated 2020, presented in court by the petitioner’s document examiner, Mr. John Jamieson as evidence. The document was not signed by the Decedent, in addition to that, it bears a wrong name of the Defendant written as, Dorothy Wells Pierce. The Defendant has never at any point in time used both Wells and Pierce at the same time, on the same document. Despite several attempts made by the Defendant to squash it, the court wrongly admitted the evidence that would have made a significant difference to the outcome of the trial. It follows; therefore, the Plaintiff has failed to provide a sufficient burden of proof to challenge the Decedent’s will. A new trial should be granted to correct the legal error.
- FAILURE TO GRANT DEFENDANT SUFFICIENT TIME TO REBUT PLAINTIFF’S EVIDENCE AMOUNTS TO A VIOLATION OF DEFENDANT’S DUE PROCESS RIGHTS
“Procedural due process requires (1) adequate notice; (2) adequate opportunity for a hearing; (3) the right to introduce evidence; and (4) the right to confront and cross-examine witnesses.” Moore v. Moore, 376. S.C. 467, 657 S.E.2d. 743 (2008). See also Clear Channel Outdoor v. City of Myrtle Beach, 372 S.C. 230, 235, 642 S.E.2d 565, 567 (2007).
“In order to prove a denial of substantive due process, a party must show that he was arbitrarily and capriciously deprived of a cognizable property interest footed in state law.” Sloan v. S.C. Bd. of Physical Therapy Examr’., 370 S.C. 452, 483, 636 S.E.2d 598, 614 (2006); see Mathews e. Eldridge, 424 U.S. 319, 332, 96 S. Ct. 893, 47 L. Ed. 2d 18 (1976) (recognizing that before due process *473 guarantees are implicated, there must be a deprivation by the government of constitutionally protected interest).
“[D]ue process is flexible and calls for such procedural protections as the particular situation demands.” Morrissey v. Brewer, 408 U.S. 471, 481, 92 S. Ct. 2593, 2600, 33 L. Ed. 2d 484, 494 (1972). The requirements in a particular case depend on the importance of the interest involved and the circumstances under which the deprivation may occur. S.C. Dept. of Soc. Servs. v. Beeks, 325 S.C. 243, 246, 481 S.E.2d 703, 705 (1997).
In the instant action, copies of the signature exhibits presented in court by the Petitioner’s document examiner, Mr. John Jamieson were not availed to the Defendant in advance to prepare a rebuttal. Such documents could only have been discovered during the hearing. The outcome of the judgment would have been different if the Defendant had the copies of signature exhibits used in the Petitioner’s handwriting report prior to the hearing of August 2nd, 2021. The Court’s failure to grant Defendant time to rebut the Plaintiff’s evidence amounts to a violation of Defendant’s due process rights.
- DEFENDANT IS NOT LIABLE FOR FRAUD AND/OR FORGERY
“‘[F]raud on the court’ . . . requires a showing that one has acted with an intent to deceive or defraud the court.” Chewning v. Ford Motor Co., 354 S.C. 72, 78, 579 S.E.2d 605, 608 (2003) (quoting United States v. Buck, 281 F.3d 1336, 1342 (10th Cir. 2002))); id. at 78-79, 579 S.E.2d at 608-09.
The Court erred in its judgment to find the Defendant guilty of a crime of forgery without factual evidence and due process of the law. The Petitioner/Plaintiff did not present any evidence that showed that the Defendant had intent to deceive or defraud. Besides, the Defendant could possibly have no motive to defraud the Petitioner. Notably, the will gave Defendant the residue of the Estate while the other beneficiaries contesting the will had eight acres of river front land, which is the most expensive part of the Decedent’s real estate.
Therefore, the Defendant will face irreparable harm should the lower court presume jurisdiction contrary to the following evidence/facts before Court. The Defendant further points out that:
a) The petitioner’s handwriting expert Mr. John Jamieson could not make any conclusions as to whether the signature on the 10th page of last will and testament of Doyle Elton Pierce, dated July 7th, 2020, was that of the Defendant.
b) On November 5, 2020, the Petitioner’s Attorney Rick McDuff reported an incident case to Oconee County Sheriff Department on the account of counterfeiting/forgery. The sheriff department investigated the case thoroughly and closed the investigation, after finding NO WRONGDOING on the part of the defendant.
c) Furthermore, on January 22, 2021, the Petitioner and his attorney further contacted five of the defendants’ clients exhorting them to file complaints against the Defendant both in Court and with the police in a bid to make the petitioner’s probate case stronger. Two clients of the defendant filed cases of breach of trust with the sheriff department. After investigations, the Sheriff again closed their cases after finding NO ILLEGAL BEHAVIOR on the part of the Defendant. A new trial should be granted so that the Defendant can produce additional evidence that could have only been deemed important after the judgment. Justice will be denied if a new trial is not granted to enable the Defendant to clear her name.
- THE COURT ERRED WHEN IT ONLY CONSIDERED PETITIONER’S EVIDENCE
When the formal execution of a will is admitted or proved, a prima facie case in favor of the will is made out, and the burden is then on the contestants to prove undue influence, incapacity or other basis of invalidation. The contestants continue to bear the burden of proof throughout the will contest. In determining whether the contestants sustained such burden, the evidence has to be viewed in the light most favorable to the contestants. Calhoun v. Calhoun, 277 S.C. 527, 530, 290 S.E.2d 415, 417 (1982).
“Parties have the ultimate burden of persuasion as to matters with respect to which they have the initial burden of proof. “); Id., 277 S.C. at 530, 290 S.E.2d at 417.
“An abuse of discretion may be found if the conclusions reached by the court are without reasonable factual support.” Runyon v. Wright, 322 S.C. 15, 19, 471 S.E.2d 160, 162 (1996).
In the instant action, the Court erred in admitting and solely relying on the testimony of the Petitioner’s expert witness, Mr. John Jamieson whose report comprised of outdated and forged signature samples and yet, Unfairly Discredited all the testimonies of the Defendant and the witnesses.
The Court also unfairly discredited the testimonies of the eyewitnesses on the account that, they could not identify the exact name of the Church where the will was signed. Notably, SC Code § 62-2-502 does not limit the witnesses to specific location of the signing ceremony, neither does it provide guidance on the same. The witnesses were using GPS to reach the Decedent’s house and they are not natives of the local area of six miles hence it’s only natural that they would not remember the exact location. Nevertheless, the Defendant seeks a new trial to provide evidence that would have only been deemed important during or after the trial to validate the witness testimonies.
The Court also overruled objections to questions addressed to the Defendant, Dorothy Pierce, which were irrelevant to the matter before court. The Petitioner’s attorney continuously directed their questioning placing the Defendant in immoral position and allowing the leading questions to influence the judge. The Defendant was therefore denied a fair and impartial trial.
Further, the Court unfairly impeached the Defendant’s witnesses based on body language. The Defendant finds significant inconsistencies with Court’s narration on the events that transpired during the Court hearing on August 2nd, 2021. In the absence of a body language expert to confirm the courts findings, a new trial should be granted.
The Court also unfairly rejected the testimony of an eyewitness to the last will and testimony of Doyle Elton Pierce dated, July 7th, 2020, Tammy Youngblood, on the account of prior brain surgery or bad nerve and yet admitted the testimony of the petitioner, Jared Adam Pierce who has had SEVERE BRAIN INJURY and has been on treatment for brain damage and memory loss for years.
Furthermore, the court ignored important facts as per the testimony of the expert witness, Mr. John Jamieson that could not make any conclusions as to whether the initials on pages one through nine of the last will and testament of the Decedent, dated July 7th, 2020, was that of the Deceased or not.
Also, there was irregularity in the court’s narration of the Defendant’s testimony during the hearing.
Lastly, the Defendant was not informed by the Petitioner’s counsel in advance that she would testify as a witness during the hearing on August 2, 2021.
Accordingly, the verdict went against the requirements for evidence.
- THE COURT FAILED TO PROVIDE GUIDANCE ON THE PROCEDURE UNDER INTESTACY LAW IN THE EVENT IT FOUND THE WILL INVALID
According to S.C. Code § 62-2-102, one half of the property in the estate is inherited by the surviving spouse. It follows; absent a will, and in the event the Decedent left a spouse, the spouse is entitled to half of the Decedent’s property.
In the instant case, when the Court held in favor of the Petitioner that the Last Will was invalid, the Court ought to have divided the Decedent’s estate according to the said law by giving the Defendant half of the property.
- DEFENDANT’S COUNSEL IN THE TRIAL CASE FAILED TO DULY PERFORM HIS DUTIES EFFECTIVELY.
In order to establish a claim for ineffective assistance of counsel, a Defendant must prove that: counsel’s performance was deficient; and the deficient performance prejudiced the applicant’s case. See Edwards v. State, 392 S.C. 449, 455, 710 S.E.2d 60, 64 (2011).
In the instant action, the Defendant’s attorney failed to properly apply the correct strategy to counter the evidence adduced by the Petitioner. Besides, the Attorney failed to prepare sufficient evidence and to prepare Defendant’s witness(es) for hearing. For instance, the Defendant’s expert document examiner, whose report validated that the Decedent authored the last Will and Testament dated, July 7th, 2020, was not able to attend Court due to insufficient time to prepare. The Defendant’s attorney failed to follow-up with the said witness and have his evidence ready in due time before the hearing.
In that regard, the Defendant lost the case due to the attorney’s ineptitude and/or failure to perform his duties diligently.
- THE JUDGE’S COMMUNICATION WITH THE PETITIONER VIOLATED DEFENDANT’S DUE PROCESS RIGHTS
A fundamental requirement of due process is the opportunity to be heard. Armstrong v. Manzo, 380 U.S. 545, 85 S.Ct. 1187, 14 L.Ed.2d 62 (1965).”It is an opportunity which must be granted at a meaningful time and in a meaningful manner.” Id. at 552, 85 S.Ct. at 1191, 14 L.Ed.2d at 66.
The law considers the partiality of a Judge in a case as a very sensitive matter. It follows; for example, a judge should disqualify himself in a proceeding in which his impartiality might reasonably be questioned, including but not limited to, instances where he has a personal bias or prejudice against a party. Murphy v. Murphy, ___ S.C. ___, 461 S.E.2d 39 (1995).
It is the movant’s responsibility to provide some evidence of the existence of the judge’s impartiality. Lyvers v. Lyvers, 280 S.C. 361, 367, 312 S.E.2d 590, 594 (Ct.App.1984) (citation omitted).
In the instant case, the Judge kept constant communication with the Petitioner in private. Defendant has several Email evidence that details such communication. It is also worth noting that in the Emails, the Petitioner was tainting Defendant’s name by informing the Judge how bad Defendant is. For example, the Petitioner stated thus: “She is having the utilities disconnected by … for nonpayment, and is in default under the payment terms of the lease on that property… We have employee witnesses to testify that she has not paid them wages and are pursuing action with the Department of Labor.”
It is apparent that such communication sought to influence the Judge’s decision to rule in favor of the Petitioner, in violation of the Defendant’s due process rights. For that reason, the Defendant contends that the communication between Petitioner and the Judge corrupted the Judge’s view of the case. Accordingly, Defendant seeks a New Trial for that reason.
Based upon the foregoing arguments, and each of them, it is clear that Justice will not be properly served unless a new trial is granted. Accordingly, the Defendant prays that the Court set aside the judgment signed on August 18th, 2021 and in the interest of justice, grant a new trial.
Dated: [ENTER DATE]
Defendant, pro se.
|THE STATE OF SOUTH CAROLINA THE COUNTY OF OCONEE IN THE MATTER OF: DOYLE ELTON PIERCE, DECEASED|
JARED ADAM PIERCE (Petitioner) vs. DOROTHY PIERCE (Defendant)
|IN THE PROBATE COURT CASE NO.:2020ES3700532 AFFIDAVIT IN SUPPORT OF AMENDED MOTION FOR NEW TRIAL; & MEMORANDUM OF LAW IN SUPPORT OF AMENDED MOTION FOR NEW TRIAL|
I, DOROTHY PIERCE, hereby swear under oath and state as follows:
- THAT I am the Defendant in the captioned case.
- THAT I have gone through all facts and allegations in the Amended Motion for New Trial and the Memorandum of Law in Support thereof.
- THAT I hereby declare and affirm under penalty of perjury that all the facts and allegations therein are true to the best of my knowledge, information, and belief.
Dated: [ENTER DATE]
Defendant, pro se.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that she served a copy of the foregoing on the opposing party by depositing a copy, contained in a first-class, postage-paid wrapper, into a depository under the exclusive care and custody of the United States Postal Service, addressed as follows:
[ENTER PLAINTIFF’S ADDRESS]
Dated: [ENTER DATE]
Defendant, pro se.
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