Scannergate

Caption and Preliminary Statement (p. 1-2)

PRELIMINARY STATEMENT: THE ROLE OF THIS FILING AND THE
PLAINTIFF WHO FILES IT
This brief builds directly on the February 9, 2026 hearing Brief and is offered in the same spirit
as a contribution to judicial efficiency from a systems analyst who entered the housing justice
system after seeing the need for systemic change. Studying it this way acknowledges that a
system’s effectiveness is equivalent to its resilience and resilience can be determined by how
well it treats its most vulnerable member.
Given that, like in the show Undercover Boss, McNeil examined the system response from the
role of its Most Vulnerable Member, a self-represented tenant who could not afford an attorney.
He also utilized the “Study from the Outside In from End Customer Point of View” method from
the Vanguard Method in the UK, which was used in the Systems Thinking in Housing Study that
achieved profound results.
Deliberately, methodologically, and with documented professional expertise, he studied and
reported on a failure pattern that has injured Plaintiffs and will continue injuring others until it is
made visible and accountable.
That positioning matters procedurally. Plaintiff James C. Chris McNeil is a systems thinking
consultant, creator of the Strategic Thought Leadership framework, and strategic
communications professional with prior expert witness experience in complex technology
litigation. He did not intend to remain pro se through 167 days of multi-firm opposition. He
crossed the case-complexity threshold for handing off to counsel months ago. The conduct
documented in this record, including coordinated misrepresentation, obstruction of a regulatory
investigation, and clinical-level psychological harm documented at PCL-5 severity 76–80, is
precisely why institutional betrayal (Smith & Freyd, Dangerous Safe Havens, 69 Am.
Psychologist 119 (2014)) makes that handoff extraordinarily difficult: it raises the standard of
due diligence before responsibly entrusting this case to any firm. That process is underway. This
may be the last major pro se filing.
The Court may use this brief to orient quickly, act efficiently, and clear a docket that has been
deliberately burdened by the defense's attrition strategy. Every pending defense motion is noise.
The signal is seven of eight documented violations that have received zero substantive response
in 167 days.

Preliminary Statement: The Role of This Filing and the Plaintiff Who Files It (p. 1-2)

PRELIMINARY STATEMENT: THE ROLE OF THIS FILING AND THE
PLAINTIFF WHO FILES IT
This brief builds directly on the February 9, 2026 hearing brief and is offered in the same spirit as a contribution to judicial efficiency from a systems analyst who entered the housing justice system after seeing the need for systemic change. Studying it this way acknowledges that a system’s effectiveness is equivalent to its resilience and resilience can be determined by how well it treats its most vulnerable member. Given that, like in the show Undercover CEO, McNeil examined the system response from the role of its Most Vulnerable Member, a self-represented tenant who could not afford an attorney. He also utilized the “Study from the Outside In from End Customer Point of View” method from the Vanguard Method in the UK, which was used in the Systems Thinking in Housing Study and achieved profound results. Deliberately, methodologically, and with documented professional expertise, he studied and reported on a failure pattern that has injured Plaintiffs and will continue injuring others until it is made visible and accountable. That positioning matters procedurally. Plaintiff James C. Chris McNeil is a systems thinking consultant, creator of the Strategic Thought Leadership framework, and strategic communications professional with prior expert witness experience in complex technology litigation. He did not intend to remain pro se through 167 days of multi-firm opposition. He crossed the case-complexity threshold for handing off to counsel months ago. The conduct documented in this record, including coordinated misrepresentation, obstruction of a regulatory investigation, and clinical-level psychological harm documented at PCL-5 severity 76–80, is precisely why institutional betrayal (Smith & Freyd, Dangerous Safe Havens, 69 Am. Psychologist 119 (2014)) makes that handoff extraordinarily difficult: it raises the standard of due diligence before responsibly entrusting this case to any firm. That process is underway. This may be the last major pro se filing. The Court may use this brief to orient quickly, act efficiently, and clear a docket that has been deliberately burdened by the defense's attrition strategy. Every pending defense motion is noise. The signal is seven of eight documented violations that have received zero substantive response in 167 days.

Requested judgment (p. 12-12)

• Requested judgment: $7,785 in treble damages plus reasonable attorneys' fees (or pro se equivalent and Plaintiff McNeil bill $375/hour as consultant), costs, and interest.

Counts and Judicial Disposition Table (continued) (p. 3-4)

| Count | Cause of Action | Statutes / Authority | Strongest Judicial Action | Unrefuted Evidence on Record | Effect on Docket |
| --- | --- | --- | --- | --- | --- |
| | | | | | 11/19/25 sanctions) collapse - Plaintiffs' claims judicially validated. |
| III | Breach of Contract | S.C. Code § 27-40-10 et seq.; lease agreement | Full Summary Judgment - No genuine issue of material fact | Second Amended Complaint, 10/24/25, ¶¶ 65–68 (valid lease, performance, breach); Second Amended Complaint, 10/24/25, Ex. F-1, F-2 (deposit withheld beyond 30-day statutory window); Move-Out Statement charges include falsehoods (oven cleaning, itemized Plaintiff move-out cleaning invoice included) and pre-existing conditions (water-damage drywall) without evidentiary support | Enters judgment on liability. Consequential damages calculable. May be fully resolved without jury. |
| IV | Retaliatory Conduct | S.C. Code § 27-40-910 (retaliatory eviction); § 27-40-440 | Partial Summary Judgment on Liability Damages to jury | Second Amended Complaint, 10/24/25, Ex. B (May 23, 2025 safety proposal); Second Amended Complaint, 10/24/25, Ex. A (May 29, 2025 NTV- 6 days later); Second Amended Complaint, 10/24/25, Ex. K (July 17 email: "why don't you want us here anymore?"); Second Amended Complaint, 10/24/25, Ex. C-1 (July 19 rent spiked 128%, listing pulled July 26); Dana DeVoe-Riddick June 4, 2025 email: "owner has decided to do some renovations" - zero renovation evidence produced in discovery | Establishes retaliation as matter of law. Damages phase: relocation, STL platform destruction, emotional distress, punitive - largest damages claims in the original harms of the case. |
| V | Negligence / Habitability Breach | S.C. Code § 27-40-440; implied warranty of habitability | Partial Summary Judgment on Liability Damages consolidated with Count IV | Second Amended Complaint, 10/24/25, Ex. B (safety requests: broken blinds, damaged screens, asbestos testing); Second Amended Complaint, 10/24/25, Ex. N (retaliatory email pattern); Aug. 3, 2022 Roadstead (Meridian predecessor) email: "The owner did not approve replacing the blinds" (standalone exhibit); Broken attic stair throughout tenancy, painted-shut and/or screenless windows documented throughout five-year tenancy -zero defense response | Establishes habitability breach. Damages overlap with Count IV - efficient to consolidate. |
| VI | Alter Ego / Piercing Corporate Veil | Sturkie v. Sifly; Pertuis v. Front Roe Restaurants (S.C. 2019) | Partial Summary Judgment or Deemed Admissions via Rule 36 | Second Amended Complaint, 10/24/25, Ex. G-1 through G-5 (shared address 8310 Rivers Ave, Suite B; SoS discrepancies since 2021; MRG mortgage); Meridian Answer and Crossclaims, 10/9/25, ¶¶ 114–115 (admits "several properties" managed for SAC 181); Second Amended Complaint, 10/24/25, Ex. L (Orangeburg $5.00 insider conveyance, 2021); Plaintiffs' Opposition to Quash, 1/14/26, § VII (SAC 181 OP account: Tara signature, Meridian address, "OP" not trust/escrow designation — four § 40-57-136 violations); Plaintiffs' Memorandum on Probate Records, 12/3/25; Supplemental Memorandum re Flash Transfer, 12/11/25 ($5.00 capitalization, 95% Charles Realty stock devaluation) - 82 days, zero response from any defense firm | Exposes individual Bayles + MRG + Altman family portfolio (including Charles Realty Company Inc.) assets to judgment. Eliminates corporate shields. |
| MfL | Motion for Leave - Second Amended Complaint | SCRCP Rule 15(a) - leave freely given | Grant Leave Immediately + Order 7-Day Answer Deadline | Motion for Leave to File 2AC, 10/24/25 (122 days pending, no substantive opposition filed); adds 21-platform image exploitation counts with specific platform evidence; adds Charles S. Altman individually for negligent retention/supervision, veil-piercing, probate fraud/judicial estoppel | Adds Charles S. Altman individually. Opens 62–72 LLC portfolio discovery, probate records, Jonathan Altman beneficial ownership. Short answer window prevents further attrition delay. |

Section I - The Record at a Glance (p. 2-5)

SECTION I: THE RECORD AT A GLANCE
What Has Been Filed, How Long It Has Sat Unanswered, and What Defense Has Shown/Stated.
The table below is the filing in summary form. The last two column speaks most clearly.

Count I
Security Deposit Violation
S.C. Code § 27-40-410 (mandatory treble damages)
Full Summary Judgment: Liability + treble damages as matter of law
Second Amended Complaint, 10/24/25, Ex. F-1 (MeridianScanner20250905161321.pdf - filename proves Sept. 5 creation); Second Amended Complaint, 10/24/25, Ex. F-2 (actual USPS envelope, Columbia SC postmark Sept. 8–10); Tara Bayles Sept. 5, 2025 email to Plaintiffs ("checks were mailed on August 28, 2025"); Tara Bayles RFA Responses (now admits "EMAILED 8/28/2025" was internal office notation, not USPS postmark)
Enters judgment: $7,785 treble + fees. Eliminates "deposit dispute" defense framing. MTD becomes moot.

Count II
Fraudulent Misrepresentation (Falsified Postal Evidence)
S.C. common law fraud; S.C. Code § 16-13-10 (forgery); 18 U.S.C. § 1343 (wire fraud)
Partial Summary Judgment on Liability: Damages to jury
Tara Bayles Sept. 5, 2025 email transmitting envelope image as "postage-marked" proof of Aug. 28 mailing; Second Amended Complaint, 10/24/25, Ex. F-1 (filename metadata: Sept. 5, 4:13 PM); Tara Bayles RFA Responses (retreat to "internal office stamp"directly contradicting Sept. 5 representation); Zero defense affidavit or alternative explanation in 167 days
Establishes fraud liability. Jury determines compensatory + punitive. Defense sanctions motions (11/10/25 AI motion; 11/19/25 sanctions) collapse - Plaintiffs' claims judicially validated.

Count III
Breach of Contract
S.C. Code § 27-40-10 et seq.; lease agreement
Full Summary Judgment - No genuine issue of material fact
Second Amended Complaint, 10/24/25, ¶¶ 65–68 (valid lease, performance, breach); Second Amended Complaint, 10/24/25, Ex. F-1, F-2 (deposit withheld beyond 30-day statutory window); Move-Out Statement charges include falsehoods (oven cleaning, itemized Plaintiff move-out cleaning invoice included) and pre-existing conditions (water-damage drywall) without evidentiary support
Enters judgment on liability. Consequential damages calculable. May be fully resolved without jury.

Count IV
Retaliatory Conduct
S.C. Code § 27-40-910 (retaliatory eviction); § 27-40-440
Partial Summary Judgment on Liability Damages to jury
Second Amended Complaint, 10/24/25, Ex. B (May 23, 2025 safety proposal); Second Amended Complaint, 10/24/25, Ex. A (May 29, 2025 NTV- 6 days later); Second Amended Complaint, 10/24/25, Ex. K (July 17 email: "why don't you want us here anymore?"); Second Amended Complaint, 10/24/25, Ex. C-1 (July 19 rent spiked 128%, listing pulled July 26); Dana DeVoe-Riddick June 4, 2025 email: "owner has decided to do some renovations" - zero renovation evidence produced in discovery
Establishes retaliation as matter of law. Damages phase: relocation, STL platform destruction, emotional distress, punitive -largest damages claims in the original harms of the case.

Count V
Negligence / Habitability Breach
S.C. Code § 27-40-440; implied warranty of habitability
Partial Summary Judgment on Liability Damages consolidated with Count IV
Second Amended Complaint, 10/24/25, Ex. B (safety requests: broken blinds, damaged screens, asbestos testing); Second Amended Complaint, 10/24/25, Ex. N (retaliatory email pattern); Aug. 3, 2022 Roadstead (Meridian predecessor) email: "The owner did not approve replacing the blinds" (standalone exhibit); Broken attic stair throughout tenancy, painted-shut and/or screenless windows documented throughout five-year tenancy -zero defense response
Establishes habitability breach. Damages overlap with Count IV - efficient to consolidate.

Count VI
Alter Ego / Piercing Corporate Veil
Sturkie v. Sifly; Pertuis v. Front Roe Restaurants (S.C. 2019)
Partial Summary Judgment or Deemed Admissions via Rule 36
Second Amended Complaint, 10/24/25, Ex. G-1 through G-5 (shared address 8310 Rivers Ave, Suite B; SoS discrepancies since 2021; MRG mortgage); Meridian Answer and Crossclaims, 10/9/25, ¶¶ 114–115 (admits "several properties" managed for SAC 181); Second Amended Complaint, 10/24/25, Ex. L (Orangeburg $5.00 insider conveyance, 2021); Plaintiffs' Opposition to Quash, 1/14/26, § VII (SAC 181 OP account: Tara signature, Meridian address, "OP" not trust/escrow designation — four § 40-57-136 violations); Plaintiffs' Memorandum on Probate Records, 12/3/25; Supplemental Memorandum re Flash Transfer, 12/11/25 ($5.00 capitalization, 95% Charles Realty stock devaluation) - 82 days, zero response from any defense firm
Exposes individual Bayles + MRG + Altman family portfolio (including Charles Realty Company Inc.) assets to judgment. Eliminates corporate shields.

MfL
Motion for Leave - Second Amended Complaint
SCRCP Rule 15(a) - leave freely given
Grant Leave Immediately + Order 7-Day Answer Deadline
Motion for Leave to File 2AC, 10/24/25 (122 days pending, no substantive opposition filed); adds 21-platform image exploitation counts with specific platform evidence; adds Charles S. Altman individually for negligent retention/supervision, veil-piercing, probate fraud/judicial estoppel
Adds Charles S. Altman individually. Opens 62–72 LLC portfolio discovery, probate records, Jonathan Altman beneficial ownership. Short answer window prevents further attrition delay.

What This Table Shows: On seven of eight substantive matters, the defense has produced zero
substantive engagement in 82 to 167 days. The one partial acknowledgement. Tara Bayles' RFA
admission that the stamp was an internal office notation, not a USPS postmark does not function
as a defense. It establishes the falsity element of Count II as a matter of record.
Every obstruction motion on the docket (Motions to Quash, Jan. 8 & 12; SAC 181 Protective
Order re Deposition, Jan. 26; Motion to Stay, Jan. 27–28) is an effort to prevent
the evidence from being examined, not a substantive challenge to the claims. Under the
established adverse inference principle, a party who obstructs the production of evidence it
characterizes as irrelevant demonstrates consciousness of its materiality.
The February 9, 2026 scheduling conference signaled that this Court will not accept defense
characterizations at face value. Plaintiffs submit this streamlined guide to assist the Court in
making decisive orders that resolve what can be resolved now, protecting judicial resources
while preserving Plaintiffs' safety and case integrity.

7. Partial Summary Judgment on Count II (Fraudulent Misrepresentation), Liability Only. (p. 12-12)

7. Partial Summary Judgment on Count II (Fraudulent Misrepresentation), Liability Only.

• Falsified postal evidence transmitted via interstate email on Sept. 5, 2025. Document metadata proves Sept. 5 creation. Tara Bayles' RFA responses retreat to "internal office stamp," directly contradicting the Sept. 5 email representation. No defense affidavit or alternative explanation has been offered in 167 days.

• Damages (compensatory and punitive) to be determined by jury.

What This Table Shows (p. 5-5)

What This Table Shows: On seven of eight substantive matters, the defense has produced zero substantive engagement in 82 to 167 days. The one partial acknowledgement. Tara Bayles' RFA admission that the stamp was an internal office notation, not a USPS postmark does not function as a defense. It establishes the falsity element of Count II as a matter of record.

Every obstruction motion on the docket (Motions to Quash, Jan. 8 & 12; SAC 181 Protective Order re Deposition, Jan. 26; Motion to Stay, Jan. 27–28) is an effort to prevent the evidence from being examined, not a substantive challenge to the claims. Under the established adverse inference principle, a party who obstructs the production of evidence it characterizes as irrelevant demonstrates consciousness of its materiality.

The February 9, 2026 scheduling conference signaled that this Court will not accept defense characterizations at face value. Plaintiffs submit this streamlined guide to assist the Court in making decisive orders that resolve what can be resolved now, protecting judicial resources while preserving Plaintiffs' safety and case integrity.

Since February 9:

• SAC 181 failed to appear for its own February 2 deposition • LLR investigator Kasey Williams refused February 9 appearance; findings sealed despite February 20 statutory deadline • Defense obstruction continues unabated despite Court's positioning • Plaintiff McNeil remains at low functional capacity (PCL-5: 76 out of 80; gaslighting severity: 79 out of 80)

What Plaintiffs seek: Safety-driven case management that stops the Ask for Justice-Harm Loop documented below.

Developments Since February 9 (p. 5-5)

Since February 9:
• SAC 181 failed to appear for its own February 2 deposition
• LLR investigator Kasey Williams refused February 9 appearance; findings sealed despite
February 20 statutory deadline
• Defense obstruction continues unabated despite Court's positioning
• Plaintiff McNeil remains at low functional capacity (PCL-5: 76 out of 80; gaslighting
severity: 79 out of 80)
What Plaintiffs seek: Safety-driven case management that stops the Ask for Justice-Harm
Loop documented below.

8. Full Summary Judgment on Count III (Breach of Contract). (p. 12-12)

8. Full Summary Judgment on Count III (Breach of Contract).

• Valid lease admitted. Plaintiffs performed all obligations. Defendants failed to return deposit within 30 days and provided false itemization (charges for pre-existing conditions without evidentiary support). No genuine issue of material fact.

The Compounding Harm Architecture (p. 5-5)

Section II - The Compounding Harm Architecture (p. 5-7)

9. Partial Summary Judgment on Count IV (Retaliatory Conduct, S.C. Code § 27-40-910), Liability Only. (p. 12-12)

9. Partial Summary Judgment on Count IV (Retaliatory Conduct, S.C. Code § 27-40-910), Liability Only.

• Documentary timeline is unrefuted by any defense filing: April 2-3 and May 8, 2025 Plaintiff rights assertions in response to legal misrepresentations; May 23 safety proposal; May 29 NTV (six days); July 17 motive inquiry ("why don't you want us here anymore?"); July 19 rent spiked 128% ($3,050 to $5,276); July 26 listing pulled. "Owner has decided to do some renovations" contradicted by zero renovation evidence in discovery and the pre-renovation Matterport tour of the occupied home.

• Damages to jury: relocation costs, increased housing costs, STL platform destruction, emotional distress, punitive damages.

Compounding Layers Summary Table (p. 6-7)

Compounding Layers Summary Table

| Layer | Harm Type | Primary Actors | Legal Nexus | Why It Compounds |
| --- | --- | --- | --- | --- |
| 1 | Security deposit theft + falsified USPS postmark | Tara Bayles / Meridian / SAC 181 | SC § 27-40-410 (treble); SC 16-13-10 (felony forgery); 18 USC 1343 (wire fraud) | Foundation fraud. Defense posture appears configured largely to conceal these first three events |
| 2 | Retaliatory eviction (heat-wave displacement) | SAC 181 / Meridian | SC 27-40-910; NTV 6 days after safety proposal | Destroyed home environment configured for Rocket's blindness; launched litigation triggering all subsequent layers |
| 3 | Privacy violations (21+ platforms) | Meridian / Bayles | SC invasion of privacy; SC § 39-5-20 (unfair trade) | False endorsement of Chris's STL brand by abuser's platform; dignitary harm + commercial exploitation; retaliatory motive suggested by response to rights assertions and safety requests + no other Meridian property ads depicted tenants or their belongings. |
| 4 | STL platform destruction | SAC 181 / Meridian (via eviction) | SC § 27-40-910 consequential damages | Growth vector obliterated; reborn platform (Rockets Fight, Housing Justice Audit) now demonstrates value through direct experience of merit |
| 5 | Lawfare including gaslighting | Phelps Dunbar / Resnick Louis / IPG | SCRCP Rule 11; SC § 16-3-1700 (harassment); SC ODC RPC 8.4 | Exhaustion tactic: each frivolous motion forces response while withholding discovery needed to respond; Emotional warfare via gaslighting and disrespect. |
| 6 | DARVO pattern (institutional betrayal) | Phelps Dunbar and Resnick & Louis, coordinated | SC § 16-3-1700 (emotional distress); Freyd institutional betrayal doctrine | Direct cause of PCL-5 76 out of 80 PTSD crisis; reduces Plaintiff capacity to ~20%; self-reinforcing |
| 7 | Public figure hypocrisy / probate fraud | Jonathan S. Altman (beneficial owner, executor) | Judicial estoppel; SC estate/tax fraud; unclean hands | Policy-Profit Feedback Loop: affordable housing commissioner benefits from income from house managed with destabilizing practices he's sworn to prevent |
| 8 | LLR investigation obstruction | Meridian / Bayles / defense counsel | SC § 40-57-3403; 18 USC 1512(b)(3) (witness tampering) | Regulatory protection neutralized - if Big Law can quash PMIC investigations, licensing oversight becomes decorative |
| 9 | CCSO victim advocate obstruction | CCSO (status - stifling) | CCSO Policy 14-02; institutional betrayal doctrine | Victim advocacy system that should buffer power asymmetry instead compounds it |
| 10 | Discovery stonewalling | SAC 181 / Phelps Dunbar | SCRCP Rules 30, 37 | Each stonewalling act forces another motion cycle, multiplying PTSD triggers while defense exploits attrition asymmetry |
| 11 | Rocket's injury (demonstrative evidence) | SAC 181 / Meridian | Emotional distress evidence | Elderly blind dog stuck under couch 2 hours whimpering - jury-facing evidence of human cost of displacement |
| 12 | Insurance bad faith (misrepresentation) | IPG / Gladys Lambert | SC bad faith insurance law; excess judgment exposure | IPG's "deposit dispute" framing enabled defense exhaustion strategy while apparently misrepresenting scope to client/regulator |

Cascade Effect and Docket-Clearing Disposition (p. 7-8)

Cascade Effect: Why This Sequence Clears the Docket

Count I (Full Summary Judgment). Enters $7,785 judgment. The "deposit dispute" framing
defense has maintained for 167 days is judicially recognized as false. Motion to Dismiss
becomes moot.

Count II (Partial Summary Judgment on Liability). Falsified postal evidence judicially
recognized. Defense sanctions motions (SAC 181 Partial MTD, 10/29/25; AI Motion, 11/10/25;
Sanctions Motion, 11/19/25) become baseless. Criminal referral basis enters the record.

Count III (Full Summary Judgment). Breach of contract liability entered. Straightforward;
may resolve fully without jury.

Count IV (Partial Summary Judgment on Liability). Retaliatory eviction established as
matter of law. Narrows remaining litigation to damages only.

Count V (Partial Summary Judgment on Liability). Habitability breach established.
Consolidates with Count IV damages phase.

Count VI (Partial Summary Judgment or Deemed Admissions). Corporate veil pierced.
Individual assets of Bayles, MRG, and Altman exposed to collection.

Motion for Leave Granted (7-day answer deadline). Charles S. Altman added individually.
Opens discovery into 62 to 72 LLC portfolio, probate records, and Jonathan Altman beneficial
ownership. Third Amended Complaint pathway (law firms, IPG, agents as defendants) becomes
viable.

10. Partial Summary Judgment on Count V (Negligence / Habitability Breach), Liability Only. (p. 12-12)

10. Partial Summary Judgment on Count V (Negligence / Habitability Breach), Liability Only.

• Broken attic stairs, most windows painted shut, all with no screens installed throughout five-year tenancy. Aug. 3, 2022 email confirms owner refused blinds replacement. Safety conditions documented in the May 23 proposal that triggered the retaliatory NTV . Zero defense response.

• Damages to consolidate with Count IV damages phase.

Cascade Effect and Legal Authority for Docket-Clearing Disposition (p. 7-8)

Cascade Effect: Why This Sequence Clears the Docket

Count I (Full Summary Judgment). Enters $7,785 judgment. The "deposit dispute" framing defense has maintained for 167 days is judicially recognized as false. Motion to Dismiss becomes moot.

Count II (Partial Summary Judgment on Liability). Falsified postal evidence judicially recognized. Defense sanctions motions (SAC 181 Partial MTD, 10/29/25; AI Motion, 11/10/25; Sanctions Motion, 11/19/25) become baseless. Criminal referral basis enters the record.

Count III (Full Summary Judgment). Breach of contract liability entered. Straightforward; may resolve fully without jury.

Count IV (Partial Summary Judgment on Liability). Retaliatory eviction established as matter of law. Narrows remaining litigation to damages only.

Count V (Partial Summary Judgment on Liability). Habitability breach established. Consolidates with Count IV damages phase.

Count VI (Partial Summary Judgment or Deemed Admissions). Corporate veil pierced. Individual assets of Bayles, MRG, and Altman exposed to collection.

Motion for Leave Granted (7-day answer deadline). Charles S. Altman added individually. Opens discovery into 62 to 72 LLC portfolio, probate records, and Jonathan Altman beneficial ownership. Third Amended Complaint pathway (law firms, IPG, agents as defendants) becomes viable.

Legal Authority for Docket-Clearing Disposition

SCRCP Rule 56. Summary judgment appropriate where no genuine issue of material fact exists and movant is entitled to judgment as a matter of law. 167 days of zero substantive defense on core documentary evidence satisfies this standard.

SCRCP Rule 36(a). Evasive or insufficient RFA responses may be deemed admitted upon motion. Plaintiffs' RFA Sufficiency Motion of Dec. 23, 2025 has been pending 62 days without response.

SCRCP Rule 37. Failure to comply with discovery obligations (47+ days zero substantive responses; SAC 181 deposition no-show on Feb. 2, 2025) supports sanctions up to and including adverse inference instructions, striking of pleadings, or default judgment.

SCRCP Rule 15(a). Leave to amend "shall be freely given when justice so requires." 122-day pendency with no opposition is itself grounds for granting.

Chambers v. NASCO, Inc., 501 U.S. 32 (1991). Inherent judicial authority to manage litigation, sanction bad-faith conduct, and protect the integrity of proceedings.

Legal Authority for Docket-Clearing Disposition (p. 8-8)

Legal Authority for Docket-Clearing Disposition

SCRCP Rule 56. Summary judgment appropriate where no genuine issue of material fact exists
and movant is entitled to judgment as a matter of law. 167 days of zero substantive defense on
core documentary evidence satisfies this standard.

SCRCP Rule 36(a). Evasive or insufficient RFA responses may be deemed admitted upon
motion. Plaintiffs' RFA Sufficiency Motion of Dec. 23, 2025 has been pending 62 days without
response.

SCRCP Rule 37. Failure to comply with discovery obligations (47+ days zero substantive
responses; SAC 181 deposition no-show on Feb. 2, 2025) supports sanctions up to and including
adverse inference instructions, striking of pleadings, or default judgment.

SCRCP Rule 15(a). Leave to amend "shall be freely given when justice so requires." 122-day
pendency with no opposition is itself grounds for granting.

Chambers v. NASCO, Inc., 501 U.S. 32 (1991). Inherent judicial authority to manage litigation,
sanction bad-faith conduct, and protect the integrity of proceedings.

11. Partial Summary Judgment or Deemed Admissions on Count VI (Corporate Veil Piercing / Alter Ego). (p. 12-13)

11. Partial Summary Judgment or Deemed Admissions on Count VI (Corporate Veil Piercing / Alter Ego).

• Same address (8310 Rivers Ave, Suite B) for Meridian and MRG. Adam Bayles controls both. SAC 181 OP account bears Meridian address with Tara's signature (commingling). False registered office since 2021. $5.00 Orangeburg insider conveyance (2021). Flash Transfer $5.00 capitalization (Feb. 21, 2007). Meridian Crossclaims of 10/9/25, ¶¶ 114 to 115 admit "several properties" managed for SAC 181. (Altman family Charles Realty Company owns 2 other properties on Gordon Street -171 and 177); Plaintiffs' Memorandum on Probate Records (12/3/25) and Supplemental Memorandum re Flash Transfer (12/11/25) have received zero response from any defense firm in 82 days.

• Alternatively, deem Plaintiffs' RFAs on unity-of-interest elements admitted under Rule 36, as the RFA Sufficiency Motion of 12/23/25 has been pending 62 days without response.

Pending Motions & Evidence Never Addressed - Deemed Admission Pathway (p. 8-9)

III. PENDING MOTIONS & EVIDENCE NEVER
ADDRESSED - DEEMED ADMISSION PATHWAY

Defense has never substantively addressed the core documented events spanning 5 months:

Core Documented Events Defense Treats As Non-Existent:

• Falsified USPS postmark (datetime encoded in filename = metadata: MeridianScanner20250905161321.pdf - created Sept. 5, presented as Aug. 28) • 25-platform (at minimum) privacy syndication (June 29–Sept. 23, 2025; Meridian watermarks on all still images) • Retaliatory eviction timeline (May 23 safety proposal → May 29 NTV → July 17 "why don't you want us here?" → July 19 rent spike 128% → July 26 listing pulled) • LLR obstruction (quash motions 42 days before Feb. 20 deadline; AppFolio witness tampering Jan. 9; sealed findings) • Jonathan Altman probate fraud (SAC 181 valued $83K in 2021 probate; actual value $620K–$1.27M; Charles Realty stock 95% devaluation 2006–2020)

Motions Pending Without Substantive Defense Response (47+ days):

1. Plaintiffs' Cross - Motion to Disqualify Resnick Louis (Jan. 14, 2026) - unconsentable conflict SC RPC 1.7(b)(3)
2. Motion for Leave to File Second Amended Complaint (Oct. 24, 2025) - adding image counts + Charles S. Altman individually
3. Motion to Compel Discovery (Nov. 10, 2025) - 47+ days zero substantive responses
4. Motion re: RFA Sufficiency (Dec. 23, 2025) - evasive boilerplate objections to basic facts

Why Timing Is Right for Deemed Admissions / Partial Summary Judgment:

Resolving Counts II (Fraud), III (Breach of Contract), IV (Retaliatory Conduct) by partial summary judgment based on unrefuted documentary evidence collapses the entire defense attrition strategy in one stroke:

• MTD becomes moot (core liability established) • Sanctions motions become baseless (Plaintiffs' claims validated by deemed admissions) • Discovery narrows to damages only • Introduces 3AC pathway (law firms, IPG, agents as defendants for lawfare conduct) • Supports criminal referral request (obstruction, witness tampering now judicially recognized)

Section III - Pending Motions and Evidence Never Addressed (p. 8-9)

III. PENDING MOTIONS & EVIDENCE NEVER
ADDRESSED - DEEMED ADMISSION PATHWAY
Defense has never substantively addressed the core documented events spanning 5 months:
Core Documented Events Defense Treats As Non-Existent:
• Falsified USPS postmark (datetime encoded in filename = metadata:
MeridianScanner20250905161321.pdf - created Sept. 5, presented as Aug. 28)
• 25-platform (at minimum) privacy syndication (June 29–Sept. 23, 2025; Meridian
watermarks on all still images)
• Retaliatory eviction timeline (May 23 safety proposal → May 29 NTV → July 17 "why
don't you want us here?" → July 19 rent spike 128% → July 26 listing pulled)
• LLR obstruction (quash motions 42 days before Feb. 20 deadline; AppFolio witness
tampering Jan. 9; sealed findings)
• Jonathan Altman probate fraud (SAC 181 valued $83K in 2021 probate; actual value
$620K–$1.27M; Charles Realty stock 95% devaluation 2006–2020)
Motions Pending Without Substantive Defense Response (47+ days):
1. Plaintiffs' Cross - Motion to Disqualify Resnick Louis (Jan. 14, 2026) - unconsentable
conflict SC RPC 1.7(b)(3)
2. Motion for Leave to File Second Amended Complaint (Oct. 24, 2025) - adding image
counts + Charles S. Altman individually
3. Motion to Compel Discovery (Nov. 10, 2025) - 47+ days zero substantive responses
4. Motion re: RFA Sufficiency (Dec. 23, 2025) - evasive boilerplate objections to basic
facts
Why Timing Is Right for Deemed Admissions / Partial Summary Judgment:
Resolving Counts II (Fraud), III (Breach of Contract), IV (Retaliatory Conduct) by partial
summary judgment based on unrefuted documentary evidence collapses the entire defense
attrition strategy in one stroke:
• MTD becomes moot (core liability established)
• Sanctions motions become baseless (Plaintiffs' claims validated by deemed admissions)
• Discovery narrows to damages only
• Introduces 3AC pathway (law firms, IPG, agents as defendants for lawfare conduct)
• Supports criminal referral request (obstruction, witness tampering now judicially
recognized)

Recommended Relief - Immediate Orders (p. 10-10)

IV. RECOMMENDED RELIEF

Plaintiffs request the following relief, organized to maximize judicial economy while protecting Plaintiff safety.

A. Immediate Orders (Within 7 Days)

1. ADA Accommodations (Title II, 42 U.S.C. § 12132), Effective Immediately.

• Primary: E-filing access for disabled Plaintiff McNeil, with joint use by co-Plaintiff Poyer. • Secondary (if e-filing is delayed): Interim order treating signed PDFs emailed to the Clerk as filed upon receipt, timestamped on transmission. • Remote appearance: All non-evidentiary hearings via WebEx, Zoom or equivalent without requiring opposing counsel consent.

2. Interim Health-Based Protective Window (Rule 26(c), SCRCP), 7 Days.

• Restrict non-essential adversarial communications to allow Plaintiff McNeil to complete mental health evaluation. The Feb. 4, 2026 provider cancelled due to billing incompatibilities; rescheduling is underway through State Health Plan behavioral health channels.

12. Order Granting Motion for Leave to File Second Amended Complaint (filed Oct. 24, 2025, pending 122 days, no opposition). (p. 13-13)

12. Order Granting Motion for Leave to File Second Amended Complaint (filed Oct. 24, 2025, pending 122 days, no opposition).

• Adds 21-platform image exploitation counts with specific platform evidence.

• Adds Charles S. Altman individually for negligent retention and supervision of Meridian and veil-piercing (inadequate capitalization and operational commingling).

• Short answer deadline of seven (7) days. This case is now eight months old. Defendants have had ample notice of all underlying facts through the Oct. 24, 2025 filing.

Relief 1 - ADA Accommodations (p. 10-10)

IV. RECOMMENDED RELIEF

Plaintiffs request the following relief, organized to maximize judicial economy while protecting
Plaintiff safety.
A. Immediate Orders (Within 7 Days)
1. ADA Accommodations (Title II, 42 U.S.C. § 12132), Effective Immediately.
• Primary: E-filing access for disabled Plaintiff McNeil, with joint use by co-Plaintiff Poyer.
• Secondary (if e-filing is delayed): Interim order treating signed PDFs emailed to the Clerk
as filed upon receipt, timestamped on transmission.
• Remote appearance: All non-evidentiary hearings via WebEx, Zoom or equivalent without
requiring opposing counsel consent.

Expedited Hearing on Cross-Motion to Disqualify Resnick & Louis (p. 10-10)

B. Expedited Case Management (Within 14 Days)

3. Expedited Hearing on Plaintiffs' Cross-Motion to Disqualify Resnick & Louis (filed Jan. 14, 2026).

• Grounds: Unconsentable conflict under SCRPC 1.7(b)(3). Bolyard simultaneously represents Meridian (whose indemnity crossclaim against SAC 181 requires evidence of commingled operations) and Tara Bayles (whose personal liability defense requires suppression of that same evidence). • Witness tampering: On or before Jan. 9, 2026, which was one day after filing the Motion to Quash, Meridian directly contacted AppFolio instructing non-compliance with Plaintiffs' subpoena. • LLR obstruction: Coordinated quash motions plus unilateral delay of Tara Bayles' deposition to Feb. 24 (four days past the Feb. 20 LLR statutory deadline). • This is a safety measure. Removing conflicted counsel who have facilitated witness tampering and participated with Phelps Dunbar in coordinated gaslighting is a direct way to protect Plaintiff McNeil's health.

13. Order to Compel Discovery and Sanctions for Stonewalling. (p. 13-13)

13. Order to Compel Discovery and Sanctions for Stonewalling.

• SAC 181 failed to appear for its own deposition on Feb. 2, 2026.

• Zero substantive discovery responses since Oct. 3, 2025 (143 days).

• Evasive RFA responses requiring Rule 36 sufficiency determination (Motion of 12/23/25, pending 62 days).

• Sanctions warranted under SCRCP Rule 37, including adverse inference instructions at trial.

Relief 2 - Interim Health-Based Protective Window (p. 10-10)

2. Interim Health-Based Protective Window (Rule 26(c), SCRCP), 7 Days.
• Restrict non-essential adversarial communications to allow Plaintiff McNeil to complete
mental health evaluation. The Feb. 4, 2026 provider cancelled due to billing
incompatibilities; rescheduling is underway through State Health Plan behavioral health
channels.

Show-Cause Order re Phelps Dunbar Conduct (p. 10-11)

4. Show-Cause Order re Phelps Dunbar Conduct.

• Waived Motion to Quash: Filed one day after the SCRCP 45(d)(2)(B) deadline; waived under SCRCP Rule 45(d)(2)(B) (14-day deadline for motion to quash +5 per SCSC mail/email extension) • Misrepresentation to Court: Jan. 27 and 28, 2026 emails to court scheduler(s) and Judge Van Slambrook’s staff characterizing a factual criminal-investigation notice as "threats against lawyers and their families." The email contained no threats. Defense counsel had declined to attach it, and likely believed it was Rule 408 protected so Plaintiffs could not attach it either. Although it was written in a similar format to prior Rule 408 protected communications, it contained no settlement numbers and was not, so Plaintiff McNeil immediately attached it in a reply to the thread. • Frivolous AI sanctions motion: Filed Nov. 10, 2025, based on speculation without evidence. • Coordinated obstruction: Serving Tara Bayles' interests rather than own client Charles Altman's interests (the "captured counsel" problem documented in the Jan. 14, 2026 filing). • December 19 continuance: Obtained through misrepresentation of Plaintiff's position by SAC 181, LLC Counsel Justine Tate of Phelps Dunbar and reiterated, as was the by Meridian, Adam Bayles, and Tara Bayles Counsel Alicia Bolyard, who had also reiterated the claim of “threads against lawyers and their families” by SAC 181, LLC Counsel Kevin O’Brien of Phelps Dunbar.

14. Mandatory Mediation at Defendants' Expense (Within 30 Days). (p. 13-13)

14. Mandatory Mediation at Defendants' Expense (Within 30 Days).

• Mediator with experience in landlord-tenant disputes and power-imbalanced litigation.

• Defense has demonstrated no willingness to engage on the merits. Court-ordered process may create conditions for resolution that voluntary negotiation has not.

Relief 3 - Expedited Disqualification Hearing (p. 10-10)

B. Expedited Case Management (Within 14 Days)
3. Expedited Hearing on Plaintiffs' Cross-Motion to Disqualify Resnick & Louis (filed Jan.
14, 2026).
• Grounds: Unconsentable conflict under SCRPC 1.7(b)(3). Bolyard simultaneously
represents Meridian (whose indemnity crossclaim against SAC 181 requires evidence of
commingled operations) and Tara Bayles (whose personal liability defense requires
suppression of that same evidence).
• Witness tampering: On or before Jan. 9, 2026, which was one day after filing the Motion to
Quash, Meridian directly contacted AppFolio instructing non-compliance with Plaintiffs'
subpoena.
• LLR obstruction: Coordinated quash motions plus unilateral delay of Tara Bayles'
deposition to Feb. 24 (four days past the Feb. 20 LLR statutory deadline).
• This is a safety measure. Removing conflicted counsel who have facilitated witness
tampering and participated with Phelps Dunbar in coordinated gaslighting is a direct way
to protect Plaintiff McNeil's health.

Court-Ordered Case Manager or Communication Monitor (p. 11-11)

5. Court-Ordered Case Manager or Communication Monitor (if disqualification hearings cannot be set within 14 days).

• Route all counsel-to-Plaintiff communications through a supervised channel (filed on docket or routed through the case manager) so characterizations can be verified against the actual record in real time. • Prohibit ex parte characterizations of Plaintiff conduct to court staff without attaching the full text of the referenced communication. • This is the minimum structural intervention required to prevent continued psychological harm pending disqualification hearings.

D. Criminal Referral (Affirmative Request) (p. 13-14)

D. Criminal Referral (Affirmative Request)

15. Court Referral to the Charleston County Solicitor's Office and the United States Attorney for the District of South Carolina.

• Plaintiffs independently initiated CCSO Case No. 2026-001263 on Jan. 26, 2026. Multiple agents of CCSO have declined to share case status with Plaintiffs despite their status as complainants and documented victims.

The documented conduct on the civil record before this Court independently supports referral:

• S.C. Code § 16-13-10 (felony forgery): fabricated "EMAILED 8/28/2025" stamp transmitted as postal evidence.

• S.C. Code § 16-13-240 (false pretenses): deposit represented as timely mailed when mailing occurred 38 days late.

• 18 U.S.C. § 1343 (wire fraud): falsified postal image transmitted via interstate email on Sept. 5, 2025.

• 18 U.S.C. § 1512(b)(3) (witness tampering): Meridian's Jan. 9, 2026 contact with AppFolio instructing non-compliance with lawful subpoena.

• S.C. Code § 40-57-3403 (PMIC obstruction): coordinated quash motions and witness tampering to obstruct LLR Investigation No. 2025-566 into Tara Bayles.

• S.C. Code § 16-3-1700 (second-degree harassment): pattern of gaslighting communications documented in Consolidated Attorney Toxic Emails exhibit of Nov. 23, 2025 and confirmed by complete absence of any defense acknowledgement whatsoever of nearly all primary harms of Plaintiffs.

• The Court's referral serves judicial economy and integrity of the court: criminal accountability for the underlying fraud set a clear precedent and reduces the likelihood that the same conduct pattern replicates against future tenants and in future proceedings before this Court.

Relief 4 - Show-Cause Order Regarding Phelps Dunbar (p. 10-11)

4. Show-Cause Order re Phelps Dunbar Conduct.
• Waived Motion to Quash: Filed one day after the SCRCP 45(d)(2)(B) deadline; waived
under SCRCP Rule 45(d)(2)(B) (14-day deadline for motion to quash +5 per SCSC
mail/email extension)
• Misrepresentation to Court: Jan. 27 and 28, 2026 emails to court scheduler(s) and Judge
Van Slambrook’s staff characterizing a factual criminal-investigation notice as "threats
against lawyers and their families." The email contained no threats. Defense counsel had
declined to attach it, and likely believed it was Rule 408 protected so Plaintiffs could not
attach it either. Although it was written in a similar format to prior Rule 408 protected
communications, it contained no settlement numbers and was not, so Plaintiff McNeil
immediately attached it in a reply to the thread.
• Frivolous AI sanctions motion: Filed Nov. 10, 2025, based on speculation without evidence.
• Coordinated obstruction: Serving Tara Bayles' interests rather than own client Charles
Altman's interests (the "captured counsel" problem documented in the Jan. 14, 2026
filing).
• December 19 continuance: Obtained through misrepresentation of Plaintiff's position by
SAC 181, LLC Counsel Justine Tate of Phelps Dunbar and reiterated, as was the by
Meridian, Adam Bayles, and Tara Bayles Counsel Alicia Bolyard, who had also reiterated
the claim of “threads against lawyers and their families” by SAC 181, LLC Counsel
Kevin O’Brien of Phelps Dunbar.

Substantive Disposition - Introduction and Count I (p. 11-11)

C. Substantive Disposition (Within 30 Days)

The following items correspond directly to the Counts and Judicial Disposition table in Section I and are designed to clear the docket in the sequence described in the Cascade Effect analysis.

6. Full Summary Judgment on Count I (Security Deposit Violation, S.C. Code § 27-40-410).

• Deposit of $2,595 withheld beyond the 30-day statutory period. Checks postmarked Sept. 8 to 10, not Aug. 28 as represented. Tara Bayles' own RFA responses now contradict the Aug. 28 mailing claim. Treble damages are mandatory upon finding of willful noncompliance.

E. Future-Filing Leave (Conditional) (p. 14-14)

E. Future-Filing Leave (Conditional)

16. Leave to File Third Amended Complaint Adding Law Firms, IPG, and Agents as Defendants.

• Conditional: if defense lawfare continues after this Court's omnibus ruling.

• Grounds: S.C. Code § 16-3-1700 (harassment via coordinated gaslighting); SCRCP Rule 11 (frivolous filings); SC ODC violations; IPG bad faith (misrepresenting case scope as "deposit dispute" to avoid early settlement and increase excess judgment exposure).

• Clinical harm documentation: PCL-5 score of 76 out of 80; gaslighting severity 79 out of 80; emergency health motions (Jan. 28 to 30, 2026); functional capacity reduced to approximately 20%.

Relief 5 - Court-Ordered Case Manager or Communication Monitor (p. 11-11)

5. Court-Ordered Case Manager or Communication Monitor (if disqualification hearings
cannot be set within 14 days).
• Route all counsel-to-Plaintiff communications through a supervised channel (filed on
docket or routed through the case manager) so characterizations can be verified against
the actual record in real time.
• Prohibit ex parte characterizations of Plaintiff conduct to court staff without attaching the
full text of the referenced communication.
• This is the minimum structural intervention required to prevent continued psychological
harm pending disqualification hearings.

Requested Judgment on Count I (p. 12-12)

• Requested judgment: $7,785 in treble damages plus reasonable attorneys' fees (or pro se equivalent and Plaintiff McNeil bill $375/hour as consultant), costs, and interest.

V. INSTITUTIONAL COURAGE: WHAT THE COURT'S RESPONSE SIGNALS (p. 14-15)

Relief 6 - Full Summary Judgment on Count I (p. 11-12)

C. Substantive Disposition (Within 30 Days)
The following items correspond directly to the Counts and Judicial Disposition table in Section I
and are designed to clear the docket in the sequence described in the Cascade Effect analysis.
6. Full Summary Judgment on Count I (Security Deposit Violation, S.C. Code § 27-40-410).
• Deposit of $2,595 withheld beyond the 30-day statutory period. Checks postmarked Sept. 8
to 10, not Aug. 28 as represented. Tara Bayles' own RFA responses now contradict the
Aug. 28 mailing claim. Treble damages are mandatory upon finding of willful
noncompliance.
• Requested judgment: $7,785 in treble damages plus reasonable attorneys' fees (or pro se
equivalent and Plaintiff McNeil bill $375/hour as consultant), costs, and interest.

Partial Summary Judgment on Count II (p. 12-12)

7. Partial Summary Judgment on Count II (Fraudulent Misrepresentation), Liability Only.

• Falsified postal evidence transmitted via interstate email on Sept. 5, 2025. Document metadata proves Sept. 5 creation. Tara Bayles' RFA responses retreat to "internal office stamp," directly contradicting the Sept. 5 email representation. No defense affidavit or alternative explanation has been offered in 167 days. • Damages (compensatory and punitive) to be determined by jury.

Relief 7 - Partial Summary Judgment on Count II (p. 12-12)

7. Partial Summary Judgment on Count II (Fraudulent Misrepresentation), Liability Only.
• Falsified postal evidence transmitted via interstate email on Sept. 5, 2025. Document
metadata proves Sept. 5 creation. Tara Bayles' RFA responses retreat to "internal office
stamp," directly contradicting the Sept. 5 email representation. No defense affidavit or
alternative explanation has been offered in 167 days.
• Damages (compensatory and punitive) to be determined by jury.

Full Summary Judgment on Count III (p. 12-12)

8. Full Summary Judgment on Count III (Breach of Contract).

• Valid lease admitted. Plaintiffs performed all obligations. Defendants failed to return deposit within 30 days and provided false itemization (charges for pre-existing conditions without evidentiary support). No genuine issue of material fact.

Relief 8 - Full Summary Judgment on Count III (p. 12-12)

8. Full Summary Judgment on Count III (Breach of Contract).
• Valid lease admitted. Plaintiffs performed all obligations. Defendants failed to return
deposit within 30 days and provided false itemization (charges for pre-existing conditions
without evidentiary support). No genuine issue of material fact.

Partial Summary Judgment on Count IV (p. 12-12)

9. Partial Summary Judgment on Count IV (Retaliatory Conduct, S.C. Code § 27-40-910), Liability Only.

• Documentary timeline is unrefuted by any defense filing: April 2-3 and May 8, 2025 Plaintiff rights assertions in response to legal misrepresentations; May 23 safety proposal; May 29 NTV (six days); July 17 motive inquiry ("why don't you want us here anymore?"); July 19 rent spiked 128% ($3,050 to $5,276); July 26 listing pulled. "Owner has decided to do some renovations" contradicted by zero renovation evidence in discovery and the pre-renovation Matterport tour of the occupied home. • Damages to jury: relocation costs, increased housing costs, STL platform destruction, emotional distress, punitive damages.

Relief 9 - Partial Summary Judgment on Count IV (p. 12-12)

9. Partial Summary Judgment on Count IV (Retaliatory Conduct, S.C. Code § 27-40-910),
Liability Only.
• Documentary timeline is unrefuted by any defense filing: April 2-3 and May 8, 2025
Plaintiff rights assertions in response to legal misrepresentations; May 23 safety proposal;
May 29 NTV (six days); July 17 motive inquiry ("why don't you want us here
anymore?"); July 19 rent spiked 128% ($3,050 to $5,276); July 26 listing pulled. "Owner
has decided to do some renovations" contradicted by zero renovation evidence in
discovery and the pre-renovation Matterport tour of the occupied home.
• Damages to jury: relocation costs, increased housing costs, STL platform destruction,
emotional distress, punitive damages.

Partial Summary Judgment on Count V (p. 12-12)

10. Partial Summary Judgment on Count V (Negligence / Habitability Breach), Liability Only.

• Broken attic stairs, most windows painted shut, all with no screens installed throughout five-year tenancy. Aug. 3, 2022 email confirms owner refused blinds replacement. Safety conditions documented in the May 23 proposal that triggered the retaliatory NTV . Zero defense response. • Damages to consolidate with Count IV damages phase.

Relief 10 - Partial Summary Judgment on Count V (p. 12-12)

10. Partial Summary Judgment on Count V (Negligence / Habitability Breach), Liability
Only.
• Broken attic stairs, most windows painted shut, all with no screens installed throughout
five-year tenancy. Aug. 3, 2022 email confirms owner refused blinds replacement. Safety
conditions documented in the May 23 proposal that triggered the retaliatory NTV . Zero
defense response.
• Damages to consolidate with Count IV damages phase.

Partial Summary Judgment or Deemed Admissions on Count VI (p. 12-12)

11. Partial Summary Judgment or Deemed Admissions on Count VI (Corporate Veil Piercing / Alter Ego).

• Same address (8310 Rivers Ave, Suite B) for Meridian and MRG. Adam Bayles controls both. SAC 181 OP account bears Meridian address with Tara's signature (commingling). False registered office since 2021. $5.00 Orangeburg insider conveyance (2021). Flash Transfer $5.00 capitalization (Feb. 21, 2007). Meridian Crossclaims of 10/9/25, ¶¶ 114 to 115 admit "several properties" managed for SAC 181. (Altman family Charles Realty

Relief 11 - Partial Summary Judgment or Deemed Admissions on Count VI (p. 12-13)

11. Partial Summary Judgment or Deemed Admissions on Count VI (Corporate Veil
Piercing / Alter Ego).
• Same address (8310 Rivers Ave, Suite B) for Meridian and MRG. Adam Bayles controls
both. SAC 181 OP account bears Meridian address with Tara's signature (commingling).
False registered office since 2021. $5.00 Orangeburg insider conveyance (2021). Flash
Transfer $5.00 capitalization (Feb. 21, 2007). Meridian Crossclaims of 10/9/25, ¶¶ 114 to
115 admit "several properties" managed for SAC 181. (Altman family Charles Realty
Company owns 2 other properties on Gordon Street -171 and 177); Plaintiffs'
Memorandum on Probate Records (12/3/25) and Supplemental Memorandum re Flash
Transfer (12/11/25) have received zero response from any defense firm in 82 days.
• Alternatively, deem Plaintiffs' RFAs on unity-of-interest elements admitted under Rule 36,
as the RFA Sufficiency Motion of 12/23/25 has been pending 62 days without response.

Relief 12 - Grant Motion for Leave to File Second Amended Complaint (p. 13-13)

12. Order Granting Motion for Leave to File Second Amended Complaint (filed Oct. 24,
2025, pending 122 days, no opposition).
• Adds 21-platform image exploitation counts with specific platform evidence.
• Adds Charles S. Altman individually for negligent retention and supervision of Meridian
and veil-piercing (inadequate capitalization and operational commingling).
• Short answer deadline of seven (7) days. This case is now eight months old. Defendants
have had ample notice of all underlying facts through the Oct. 24, 2025 filing.

Relief 13 - Compel Discovery and Impose Sanctions (p. 13-13)

13. Order to Compel Discovery and Sanctions for Stonewalling.
• SAC 181 failed to appear for its own deposition on Feb. 2, 2026.
• Zero substantive discovery responses since Oct. 3, 2025 (143 days).
• Evasive RFA responses requiring Rule 36 sufficiency determination (Motion of 12/23/25,
pending 62 days).
• Sanctions warranted under SCRCP Rule 37, including adverse inference instructions at
trial.

Relief 14 - Mandatory Mediation (p. 13-13)

14. Mandatory Mediation at Defendants' Expense (Within 30 Days).
• Mediator with experience in landlord-tenant disputes and power-imbalanced litigation.
• Defense has demonstrated no willingness to engage on the merits. Court-ordered process
may create conditions for resolution that voluntary negotiation has not.

Relief 15 - Criminal Referral (p. 13-14)

D. Criminal Referral (Affirmative Request)
15. Court Referral to the Charleston County Solicitor's Office and the United States
Attorney for the District of South Carolina.
• Plaintiffs independently initiated CCSO Case No. 2026-001263 on Jan. 26, 2026. Multiple
agents of CCSO have declined to share case status with Plaintiffs despite their status as
complainants and documented victims.
The documented conduct on the civil record before this Court independently supports referral:
• S.C. Code § 16-13-10 (felony forgery): fabricated "EMAILED 8/28/2025" stamp
transmitted as postal evidence.
• S.C. Code § 16-13-240 (false pretenses): deposit represented as timely mailed when
mailing occurred 38 days late.
• 18 U.S.C. § 1343 (wire fraud): falsified postal image transmitted via interstate email on
Sept. 5, 2025.
• 18 U.S.C. § 1512(b)(3) (witness tampering): Meridian's Jan. 9, 2026 contact with
AppFolio instructing non-compliance with lawful subpoena.
• S.C. Code § 40-57-3403 (PMIC obstruction): coordinated quash motions and witness
tampering to obstruct LLR Investigation No. 2025-566 into Tara Bayles.
• S.C. Code § 16-3-1700 (second-degree harassment): pattern of gaslighting
communications documented in Consolidated Attorney Toxic Emails exhibit of Nov.
23, 2025 and confirmed by complete absence of any defense acknowledgement
whatsoever of nearly all primary harms of Plaintiffs.
• The Court's referral serves judicial economy and integrity of the court: criminal
accountability for the underlying fraud set a clear precedent and reduces the likelihood
that the same conduct pattern replicates against future tenants and in future proceedings
before this Court.

Relief 16 - Conditional Leave to File Third Amended Complaint (p. 14-14)

E. Future-Filing Leave (Conditional)
16. Leave to File Third Amended Complaint Adding Law Firms, IPG, and Agents as
Defendants.
• Conditional: if defense lawfare continues after this Court's omnibus ruling.
• Grounds: S.C. Code § 16-3-1700 (harassment via coordinated gaslighting); SCRCP Rule 11
(frivolous filings); SC ODC violations; IPG bad faith (misrepresenting case scope as
"deposit dispute" to avoid early settlement and increase excess judgment exposure).
• Clinical harm documentation: PCL-5 score of 76 out of 80; gaslighting severity 79 out of
80; emergency health motions (Jan. 28 to 30, 2026); functional capacity reduced to
approximately 20%.

Section V - Institutional Courage (p. 14-15)