Back to Docket

Plaintiffs' Amended Response in Opposition to Defendant SAC 181 LLC's Motion for a Case Management Order Regarding the Use of "AI" and Incorporated Memorandum of Law

McNeil & Poyer v. SAC 181, LLC et al. — 2025-CP-10-05095

Document Overview

SC 9th Circuit Common Pleas Case number: 2025-CP-10-05095
Filing Date: November 13, 2025
Document: Plaintiffs' Amended Response in Opposition to Defendant SAC 181 LLC's Motion for a Case Management Order Regarding the Use of "AI" and Incorporated Memorandum of Law
Document Type: Plaintiffs’ amended response opposing SAC 181 LLC’s motion for an AI-related case-management order, seeking denial, sanctions, pro se fees, and immediate discovery compliance.
Includes: Legal memorandum arguing that South Carolina’s Interim AI Policy creates no litigant disclosure or certification duty, Rule 11 already governs filing accuracy, and compelled disclosure of research tools would invade work product. Includes 7 exhibits: a litigation-and-alleged-obstruction timeline; two AI/marketing publications; the South Carolina Interim AI Policy; social-media activity charts; defense-counsel communications; and a pre-AI 2021 opposition filing offered to demonstrate Plaintiff’s prior litigation capability.

Read it now

NameDescriptionTypeFiledDocket Seq.Documents
James C. McNeil Amended Response in Opposition to Motion/Case Management Ord Notice 11/13/2025 P1A20 Official copy
Restored copy

1-bit bitonal image encodingRestoredfiled

Executive Summary

Plaintiffs James C. McNeil and Meaghan Poyer, proceeding pro se, filed an amended opposition to defendant SAC 181 LLC’s motion for a case-management order concerning use of AI. They argue that South Carolina’s Interim AI Policy applies primarily to judicial personnel and imposes no AI-use disclosure or certification duty on litigants beyond existing Rule 11 obligations to ensure accuracy and protect confidentiality.

Plaintiffs assert that SAC 181’s requested disclosure of research tools, prompts, and drafting methods would improperly invade protected work product and is a frivolous delay tactic intended to distract from overdue discovery responses.

They ask the court to deny SAC 181’s motion, impose sanctions and pro se-equivalent fees under S.C. Code § 15-36-10, and order SAC 181 to immediately comply with outstanding discovery.

Legal Significance

Plaintiffs oppose SAC 181’s request for a case-management order requiring disclosure or certification of AI use, arguing that South Carolina’s Interim AI Policy regulates judicial personnel rather than litigants and adds no duties beyond Rule 11’s existing accuracy certification. They assert that compelled disclosure of AI tools, prompts, research methods, and drafting workflows would invade protected work product and has no demonstrated connection to any inaccurate filing or substantive defense.

The response also puts at issue SAC 181’s discovery compliance and characterizes its AI motion as a delay and harassment tactic warranting sanctions under S.C. Code § 15-36-10, pro se fees, and an immediate order compelling overdue discovery.

Plaintiffs support their position with claimed prior pre-AI litigation competence and evidence they contend shows a broader defense pattern of obstruction, intimidation, and efforts to discredit their pro se advocacy.

Document Access

Restored copy: native text with the clerk FILE stamp


It appears you don't have a PDF plugin for this browser.


Unable to view the pdf on your mobile device?

Download the PDF


Machine-readable record

Verification hashes (SHA-256)
Official copy
6973b7101a28e923efffa6e7cdd06246f0610ce066c4816769fcc46030bfaf8f
Native source
e24c39a256ca1fbc701954a4d21c037f9a910f3fae685998877a94761fdb59e2
Restored copy
04900204bb237ccbf3dfcbdb4ca9a4b5ac9ff0e84a48b33d35f80f273f9ee165
Normalized text
pending

Why this restored record exists

The official docket copy of this filing was stored by the clerk's scanner as 1-bit bitonal image encoding. Search engines, assistive technology and AI systems read that shelf. This page carries the filing as the author submitted it, the clerk's FILE stamp as an independent overlay, and the cryptographic tether that lets any reader confirm the two files are the same filing.

Parties in this Record

  • James C. McNeil (Filed by)
  • Charles S. Altman (ProposedDefendant)
  • Jonathan S. Altman (PotentialDefendant)
  • Kevin O'Brien (Counsel)
  • Meridian Residential Group, LLC (Defendant)
  • Phelps Dunbar LLP (Law Firm)
  • Resnick & Louis, P.C. (Law Firm)
  • SAC 181, LLC (Defendant)