Case 2020CP2606425

The case you provided involves Tuscan Sands at Barefoot Resort and Golf Homeowners’ Association, Inc. (Plaintiff) against Bill Clark Homes of Myrtle Beach, LLC and Jeff Farrell (Defendants), with additional legal action involving third-party defendants. Below is a summary in chronological order, including key filings and events:

Key Events and Filings

  1. November 5, 2020 – The Summons and Complaint was filed by Tuscan Sands HOA, alleging negligence and breach of fiduciary duty against Bill Clark Homes and Jeff Farrell. The Plaintiff claimed that defective drainage and infrastructure transferred by Bill Clark Homes led to flooding and other damages in the Tuscan Sands community【7†source】【8†source】.
  2. November 12, 2020 – Notification of the Summons and Complaint filing was electronically transmitted【7†source】.
  3. November 24, 2020 – Acceptance of Service was filed by the Defendants, acknowledging receipt of the Summons and Complaint【7†source】.
  4. February 11, 2021 – The Defendants filed an Answer, denying the majority of the allegations. Additionally, the Defendants filed a Cross-Claim and a Third-Party Complaint against the City of North Myrtle Beach, potentially implicating them in the case【7†source】【8†source】.
  5. June 29, 2023 – The parties filed a Stipulation of Dismissal, effectively dismissing the case【8†source】. This document would indicate an agreement between the parties to terminate the case, either through a settlement or some other mutual resolution.

Final Result

The Stipulation of Dismissal filed on June 29, 2023, marks the conclusion of the case. Since the case was dismissed, no judgment was made, and the dismissal likely indicates a settlement or agreement reached outside of court, with the specific terms typically confidential unless otherwise stated in the public record.

This dismissal means that the legal claims against Bill Clark Homes and Jeff Farrell were not adjudicated through a court decision, as the matter was resolved by the parties before a trial verdict.

Hinson Properties (Barefoot Lakes)

Detailed Narrative History of the Hinson Parcels

The Hinson Parcels, located in Horry County, South Carolina, have a rich and complex history shaped by land transactions, mineral rights negotiations, and public infrastructure development. Below is a comprehensive timeline of the significant events related to the parcels:

1. 1992 Deed to Hinson Family Limited Partnership (HFLP)

  • Date: December 31, 1992
  • Event: Wendell E. Hinson transferred his 50% interest in several properties, totaling 34.28 acres in Dogwood Neck Township, Horry County, to the HFLP for $10. These properties included portions of undeveloped land in rural areas.
  • Significance: This transfer established the Hinson Family Limited Partnership as the primary entity holding the rights to the Hinson Parcels【14†source】.

2. 1994 Acquisition of Apache Tract II from International Paper

  • Date: March 16, 1994
  • Event: HFLP acquired an additional 160 acres (Apache Tract II) from International Paper Realty Corporation, located in Dogwood Neck Township. This property was crucial for later transactions and the development of the area.
  • Significance: This acquisition increased HFLP’s holdings in the area and laid the groundwork for future development and sales【15†source】【17†source】.

3. 1999 Sale by Apache Group II to Hinson Family Limited Partnership

  • Date: November 1, 1999
  • Event: Apache Group II sold 160 acres, including the Apache Tract II, to the Hinson Family Limited Partnership and Hinson Properties, LLC. This transaction consolidated ownership of the Apache Tract II within the Hinson Family entities.
  • Significance: This sale marked the full transfer of rights to the Hinson entities, further strengthening their land portfolio in the region【17†source】.

4. 2001 Release of Mineral Rights by International Paper

  • Date: March 21, 2001
  • Event: International Paper Realty Corporation released its claim to certain mineral rights over 83.809 acres of the Hinson property. However, it retained a one-eighth (1/8) non-participating royalty interest in oil, gas, and hydrocarbons, and one-half of any bonuses, rentals, and royalties from future mineral leases.
  • Significance: While this release removed some mineral claims, it left limitations on future exploitation of subsurface resources【18†source】.

5. 2006 Condemnation for Public Infrastructure (Carolina Bays Parkway)

  • Date: December 29, 2006
  • Event: The South Carolina Department of Transportation (SCDOT) issued a condemnation notice for approximately 83.809 acres of the Hinson Parcels to be used for the Carolina Bays Parkway (SC 31) project. This land was critical for public infrastructure.
  • Significance: This reduced the available land for future private development but ensured compensation for the Hinson entities【19†source】.

6. 2007 Final Condemnation Settlement

  • Date: June 29, 2007
  • Event: The condemnation case concluded with a settlement where the SCDOT paid $309,800 for the acquisition of the 83.809 acres for public use.
  • Significance: This officially transferred a significant portion of the land to public control, limiting the Hinson Family’s use of the property【20†source】.

7. 2013 Sale to Barefoot Lakes Investments, LLC

  • Date: January 15, 2013
  • Event: Hinson Family Holdings, LLC sold the remaining 160 acres of the Apache Tract II to Barefoot Lakes Investments, LLC. The land transferred included 28.174 acres and 131.826 acres from the original tract.
  • Significance: This sale ended Hinson Family’s direct ownership of the remaining land, passing control to Barefoot Lakes Investments【21†source】.

Restrictions Summary

  1. Mineral Rights:
  • Retained by International Paper: International Paper retains a one-eighth (1/8) non-participating royalty interest in oil, gas, and hydrocarbons, as well as one-half of any bonuses, rentals, royalties, and payments from future mineral leases【18†source】.
  1. Condemnation for Public Use:
  • SC 31 Condemnation: Approximately 83.809 acres were condemned for the Carolina Bays Parkway, which is now controlled by the South Carolina Department of Transportation【19†source】【20†source】.
  1. Zoning and Easements:
  • Zoning Ordinances: The land is subject to local zoning laws and restrictions that govern permitted uses, building densities, and infrastructure requirements. Any future development will need to comply with Horry County’s zoning regulations【16†source】.
  • Easements: The property may also be subject to utility easements and rights-of-way that limit development options【16†source】.
  1. Wetlands and Environmental Considerations:
  • Wetlands: Portions of the land, particularly near water features and low-lying areas, may be classified as wetlands, which impose federal and state restrictions on land use. Development in wetlands is heavily regulated and often requires permits【22†source】.
  • Environmental Protection: Any construction or development may be subject to environmental regulations, including restrictions on runoff, water management, and preservation of natural habitats【22†source】.

Future Uses

Given the restrictions outlined above, potential future uses for the Hinson Parcels include:

  1. Conservation and Recreation:
  • The existence of wetlands and public infrastructure suggests that portions of the land could be preserved for environmental conservation or developed as public recreational spaces like parks or nature trails. This would align with the public use and preservation mandates and provide long-term environmental benefits.
  1. Limited Residential Development:
  • While some portions of the land are restricted, other areas could still support low-density residential development, especially in non-wetland areas. Any development would need to consider poor accessibility due to infrastructure limitations and the existing zoning ordinances.
  1. Agricultural or Forestry Use:
  • Given the rural nature of the land and restrictions on large-scale commercial or industrial development, the property could be used for sustainable agriculture or managed forestry. This would provide economic value while maintaining the environmental integrity of the area.

Full Text Footnotes and Download Links

  1. 1992 Deed to Hinson Family Limited Partnership
    Download: 19921231 Deed 1603,465 Hinson Deed
  2. 1994 Plat for Apache Tract II (International Paper)
    Download: 19940316 Plat 128,222 Apache Tract II
  3. 1999 Deed from Apache Group II to Hinson Family Limited Partnership
    Download: 19991101 Deed 2203,338 Apache Group
  4. 2001 Release of Mineral Rights by International Paper
    Download: 20010419 Deed 2363,445 International Paper
  5. 2006 Condemnation Notice
    Download: 20061229 Condemnation Notice
  6. 2007 Deed – Hinson Condemnation
    Download: 20070629 Deed 3257,5 Hinson Condemnation
  7. 2013 Sale to Barefoot Lakes Investments, LLC
    Download: 20130115 Deed 3632,614 Barefoot Lakes
  8. Environmental Impact Review
    Download: SAC-2012-00490

Evolution of Mineral Rights

  1. 1992 Deed Transfer to Hinson Family Limited Partnership:
  • In 1992, Wendell E. Hinson transferred a 50% interest in multiple parcels of land to the Hinson Family Limited Partnership (HFLP). There were no explicit mentions of mineral rights in this deed, but the transfer conveyed all associated rights, including appurtenances and hereditaments【14†source】.
  1. 1999 Acquisition from Apache Group II:
  • In October 1999, Hinson Family Limited Partnership and Hinson Properties, LLC acquired a significant 160-acre tract from Apache Group II. While this deed focused on the real estate transaction, the history of prior ownerships, including International Paper, hinted at the possibility of reserved mineral rights【17†source】.
  1. 2001 Release of Mineral Rights by International Paper:
  • A crucial development in the evolution of mineral rights occurred in 2001 when International Paper Realty Corporation released certain mineral reservations, exceptions, and conveyances regarding oil, gas, and hydrocarbons for 83.809 acres of the Hinson property. However, International Paper retained a one-eighth (1/8) non-participating royalty interest in any oil, gas, or hydrocarbons extracted from the land. Additionally, International Paper retained one-half of any bonuses, rentals, royalties, or payments associated with any future mineral leases on various other mineral substances such as coal, iron ore, zinc, sulfur, and fissionable materials【18†source】.
  • This release defined the ongoing interest that International Paper would hold in the event of future mineral development, thus limiting Hinson’s full control over potential mineral exploitation on these lands.
  1. Condemnation and Subsequent Transactions (2006–2013):
  • During the condemnation proceedings by the South Carolina Department of Transportation (SCDOT) in 2006-2007, the mineral rights were not the primary focus, as the condemnation centered around public infrastructure development. However, the retained mineral interests by International Paper likely remained unaffected during these transactions, as the focus was on surface land for highway expansion【19†source】【20†source】.
  1. 2013 Sale to Barefoot Lakes Investments, LLC:
  • In 2013, Hinson Family Holdings sold 160 acres to Barefoot Lakes Investments, LLC. The mineral rights reserved by International Paper in 2001 would still apply to this land transfer, meaning the new owners, Barefoot Lakes Investments, inherited the same limitations regarding mineral rights【21†source】.

Conclusion:

The mineral rights on the Hinson Parcels evolved through the actions of International Paper, particularly through its 2001 release, which left the Hinson Family with limited control over the subsurface mineral resources. The reservation of a non-participating royalty interest and half of the bonus or rental payments ensures that any future mineral development remains financially tied to International Paper.

Full Text Footnotes and Download Links

  1. 1992 Deed to Hinson Family Limited Partnership
    Download: 19921231 Deed 1603,465 Hinson Deed
  2. 1999 Deed from Apache Group II to Hinson Family Limited Partnership
    Download: 19991101 Deed 2203,338 Apache Group
  3. 2001 Release of Mineral Rights by International Paper Realty Corporation
    Download: 20010419 Deed 2363,445 International Paper
  4. 2006 Condemnation Notice
    Download: 20061229 Condemnation Notice
  5. 2007 Deed – Hinson Condemnation
    Download: 20070629 Deed 3257,5 Hinson Condemnation
  6. 2013 Sale to Barefoot Lakes Investments, LLC
    Download: 20130115 Deed 3632,614 Barefoot Lakes

Barefoot Resort Outfall #2 Lawsuit

Harbour Cove Condominium Association VS Barefoot Resort Joint Committee Inc , defendant, et al2020CP2601167

The case involves the Harbour Cove Condominium Association (plaintiff) and several defendants related to alleged water damage due to improper drainage maintenance at the Barefoot Resort in Horry County, South Carolina. The plaintiff claims that the defendants, including the Barefoot Resort Joint Committee, Inc., Tuscan Sands at Barefoot Resort and Golf Homeowners’ Association, Inc., BRGC, LLC, and the City of North Myrtle Beach, failed to maintain a drainage buffer, leading to property damage.

Background:

The plaintiff, Harbour Cove Condominium Association, asserts that negligence in maintaining the drainage system, particularly a buffer zone, caused significant water damage to its property. The plaintiff alleges that the defendants, tasked with maintaining the drainage system, failed in their duties. Tuscan Sands, another party in the litigation, has made similar claims, asserting that the lack of proper drainage system maintenance caused damage to its property as well.

Key Timeline:

  • February 2020: The lawsuit was initiated by the Harbour Cove Condominium Association in the Circuit Court of Horry County (Case No. 2020-CP-26-01167).
  • October 2020: A court order stayed the case to allow for arbitration on certain claims.
  • June 2021: The plaintiff resolved some claims through arbitration, leading to the dismissal of certain defendants, including the Greenbrier and Woodlands Condominium Associations.
  • February 2024: A first mediation was held, and a second mediation is scheduled for September 2024.
  • Trial: If the mediation efforts fail, the trial will occur no sooner than December 2024.

Legal Issues:

The litigation centers on the following legal issues:

  1. Liability for Drainage Maintenance: The plaintiff seeks a declaratory judgment to clarify which parties are responsible for maintaining the drainage buffer. The plaintiff argues that the failure to maintain this system led to water damage on its property. Defendants such as BRGC, LLC, and the City of North Myrtle Beach are also named as potentially liable for the drainage issues.
  2. Cross-Claims: Tuscan Sands at Barefoot Resort and Golf Homeowners’ Association has filed cross-claims against other defendants, including BRGC, LLC, and the City of North Myrtle Beach. These cross-claims similarly allege that failure to maintain the drainage buffer contributed to property damage.
  3. Consolidation for Discovery: A motion was filed by some defendants to consolidate the claims for discovery purposes, arguing that similar issues and facts between the cases would make consolidation more efficient.

Recent Developments:

The court has scheduled a second mediation for September 2024, following an earlier session in February 2024. If the mediation does not result in a settlement, the trial will not take place before December 2024.

This case reflects complex litigation involving multiple parties, cross-claims, and allegations of negligence in maintaining shared infrastructure, which allegedly led to substantial property damage.


  1. 2020.pdf, Complaint and Court Filings, Declaratory Judgment Request, February 2020​.
  2. 2021.pdf, Plaintiff’s Motion to Lift Stay, p. 1-2.
  3. 2022.pdf, Case Proceedings, Order Relieving Counsel and Motions for Consolidation, p. 1-2.
  4. 2023.pdf, Case Background, Notice of Transfer and Cross-claims, p. 1-3.
  5. 2024.pdf, Case Caption, State of South Carolina, County of Horry, Plaintiff: The Harbour Cove Condominium Association vs. Defendants: Barefoot Resort Joint Committee, Inc., et al., p. 1-3.
  6. Index, The Harbour Cove Condominium Association vs. Defendants: Barefoot Resort Joint Committee, Inc., et al.
Evaluate the roles of attorneys for the BRRA and BRJC through the entire case. Consider any conflicts. Discuss impact of their role reversal in the initial mediation.

The attorneys for the Barefoot Resort Residential Association (BRRA) and Barefoot Resort Joint Committee (BRJC) played distinct roles throughout the case, with a notable shift during the initial mediation. Preston Dawkins represented the BRRA, and Robert E. Lee represented the BRJC. The overlap in the obligations of both entities—specifically regarding Outfall #2—required both attorneys to negotiate not just with the plaintiff, Harbour Cove, but also to clarify the responsibilities between BRRA and BRJC under the Declaration of Covenants, Conditions, and Restrictions (CCRs).
Role Reversal in Initial Mediation
A key shift occurred during the initial mediation. Although Dawkins represented BRRA, his role expanded to negotiate points concerning the broader infrastructure obligations of the BRRA and BRJC, including Outfall #2. This put him in a delicate position as he negotiated responsibilities not only for BRRA but also for how they interacted with BRJC’s duties. Meanwhile, Robert E. Lee, representing BRJC, focused on limiting his client’s exposure by emphasizing shared responsibilities with BRRA.
The reversal happened in a subtle yet impactful way: BRJC, traditionally tasked with community-wide obligations, found itself with its duties limited to a few specific areas. At the same time, BRRA, through Dawkins’s efforts, was drawn into the discussion of broader responsibilities. This shift likely resulted in a negotiation where each party had to weigh its interest against not just the plaintiff’s claims but also the shared obligations under the CCRs.
Conflict and Ethical Considerations
This situation raised potential conflicts. Given the intertwined responsibilities of BRRA and BRJC, the attorneys had to ensure that neither party was disadvantaged, which is particularly challenging when the CCRs were ambiguous on the exact division of maintenance duties. If Dawkins or Lee had pushed too hard for a settlement that absolved their client at the expense of the other, it could have led to long-term governance and financial conflicts between BRRA and BRJC, whose roles overlapped in maintaining Outfall #2. Moreover, the shared maintenance duties between these entities created opportunities for disagreements over compliance with the community-wide standards under the CCRs.
This role reversal impacted the initial mediation’s outcome, where both BRRA and BRJC were eventually found responsible for maintaining parts of Outfall #2. Although no direct conflict of interest was noted in the arbitration order, it was crucial for both attorneys to ensure that their respective clients were not unduly burdened by the obligations of the other party.
Conclusion
The ethical challenge lay in the need for the attorneys to negotiate on behalf of entities with overlapping responsibilities without compromising their fiduciary duties to their respective clients. The mediation’s role reversal, wherein BRRA became more involved in obligations traditionally managed by BRJC, highlighted the delicate balance both attorneys had to maintain. This role shift was critical to resolving the mediation but could have led to further disputes if not carefully managed.

There is no notice of these attorneys changing client representation. It has verified by three signatories in the court records. Please advise.

The absence of formal notice regarding changes in client representation raises significant concerns, particularly given that attorneys Preston Dawkins and Robert E. Lee appear to have negotiated or represented interests that are overlapping or even conflicting during the mediation process. The court records do not indicate any proper notification or filing that reflects a shift in representation or changes in the roles of these attorneys, which could lead to both ethical and procedural issues.

Potential Ethical Violations:

  1. Failure to Notify the Court: Attorneys are ethically bound to inform the court and other parties of any changes in representation, especially when the change involves negotiations or legal actions that could impact the outcome of the case. If Dawkins and Lee began negotiating responsibilities beyond their initial scope without filing appropriate notices, this could be seen as a breach of professional conduct rules, particularly those regarding transparency and accountability to the court.
  2. Conflict of Interest: Attorneys representing different entities (BRRA and BRJC) with overlapping responsibilities are required to manage any potential conflicts carefully. The fact that these attorneys may have represented interests in a way that blurred their original roles without proper notice is concerning. It could be seen as a conflict of interest, especially if either attorney acted in ways that could disadvantage one client while benefiting another.
  3. Duty to the Client: The fiduciary duty to the client is paramount. If the attorneys negotiated terms that placed additional burdens or responsibilities on their clients without proper authorization, or if they shifted representation without consent, this could be a violation of that duty. Even if the clients were not disadvantaged, the failure to follow proper procedure could lead to mistrust and further disputes.

Court Record Verification:

If the court records verify the signatures of these attorneys without reflecting a formal change in representation, this confirms that the attorneys were likely negotiating within their original scope of representation but may have informally assumed duties beyond their clients’ mandates. This lack of transparency could be seen as problematic, particularly if it impacts the distribution of responsibilities under the CCRs.

Recommendations:

  1. Seek Clarification: A motion for clarification should be filed to formally address the roles these attorneys played during mediation. This would help ensure that the record accurately reflects their responsibilities and actions throughout the proceedings.
  2. Address Conflict: If any concerns about conflict of interest arise, a request for an ethical review or an independent mediator might be necessary to resolve the case without potential bias or unresolved conflicts between BRRA and BRJC.
  3. Notify the Court: If any shifts in attorney responsibilities occurred, even informally, a formal filing should be made to notify the court and all involved parties to ensure procedural correctness going forward.

Failing to follow proper procedures and filing notices of representation could leave the case open to appeals or challenges, especially if one party believes it was inadequately represented during the critical mediation phases.

Footnotes:
Public Index Search, Court Filings from 2020-2023 regarding roles of Preston Dawkins and Robert E. Lee

BRRA Cabana Lawsuit – October 2024

Here is a narrative of the Barefoot Resort Cabana Construction lawsuit with citations and download links to the documents I used as references:

The Barefoot Resort Cabana Construction case involves a lawsuit filed by the Barefoot Resort Residential Owners’ Association, Inc. against multiple parties involved in the design and construction of a beach cabana located at 4611 South Ocean Boulevard, North Myrtle Beach, South Carolina. The defendants include D3G Architects, Wingate Consulting Engineers, UFP Mid-Atlantic, JM Allen Construction, and Excel Custom Builders.

Background:

The Plaintiff contracted with these parties to complete the design and construction of the cabana, originally budgeted at $1.5 million and expected to be finished by June 2020. However, numerous design and construction defects were discovered, including improper installation of building materials like trusses, beams, and corrosion-resistant components. The Plaintiff has claimed that the project could not be completed on time or within budget due to these issues, resulting in substantial additional costs for redesign and repairs.

Legal Claims:

The lawsuit, filed in August 2020, alleges breach of contract and negligence. The Plaintiff asserts that:

  • D3G Architects failed to properly design the project and approved substandard work.
  • JM Allen Construction and Excel Custom Builders were negligent in their workmanship and installation of materials.
  • UFP Mid-Atlantic provided defective or substandard building materials.

Procedural Developments:

  • The case has been delayed several times due to the complexity of the issues and the involvement of multiple parties. Mediation efforts were attempted but failed to resolve the dispute by August 2024【11†source】【10†source】【15†source】.
  • The court has scheduled the case for trial after September 1, 2024【11†source】.

Third-Party Defendants and Crossclaims:

Defendants have filed crossclaims against each other, such as JM Allen Construction filing against D3G Architects for tortious interference with contracts【12†source】. Additionally, 84 Lumber brought third-party claims against suppliers like Weyerhaeuser NR Company for providing defective materials【11†source】.

The case is ongoing, with the court preparing for trial unless a settlement is reached before then.

Sources with Download Links:

  1. 2020 Complaint and Allegations: Download the 2020 file【10†source】.
  2. 2021 Crossclaims and Responses: Download the 2021 file【12†source】.
  3. 2022 Court Motions and Scheduling: Download the 2022 file【14†source】.
  4. 2023 Scheduling Orders and Mediation Failure: Download the 2023 file【13†source】.
  5. 2024 Latest Case Developments: Download the 2024 file【11†source】.
  6. Public Index of Case Information: Download the Public Index Search file【15†source】.

These documents contain the full legal filings, procedural updates, and ongoing developments in the case.