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Plaintiffs' Notice of Permanent Withdrawal of All Settlement Offers and Demand for Jury Trial

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: May 1, 2026
Document: Plaintiffs' Notice of Permanent Withdrawal of All Settlement Offers and Demand for Jury Trial
Document Type: Plaintiffs’ notice permanently withdrawing all settlement offers and demanding that the case proceed to a jury trial.

Includes: Explains Plaintiffs’ stated reasons for ending settlement negotiations, including alleged bad-faith defense tactics, insurance-disclosure issues, continuances, unresolved ADA-accommodation and amendment motions, and alleged litigation-related harm. Attaches (1) Plaintiffs’ Supreme Court petition for a writ of mandamus concerning pending circuit-court motions and (2) the South Carolina Supreme Court’s return-request letter in Appellate Case No. 2026-000919.

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NameDescriptionTypeFiledDocket Seq.Documents
James C. McNeil Notice of Permanent Withdraw of All Offers,Demand f/Jury Notice 05/01/2026 P1A49 Official copy
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Executive Summary

Plaintiffs James C. McNeil and Meaghan Poyer, appearing pro se, filed this notice in their Charleston County landlord-tenant and related tort action against SAC 181, LLC, Meridian Residential Group, LLC, the Bayleses, and MRG Investing Company LLC. They irrevocably withdraw all prior settlement offers, demands, and negotiations, and demand placement of the case on the next available jury-trial roster.

The plaintiffs assert that alleged defense bad faith, insurance-disclosure obstruction, improper continuances, litigation-related medical harm, denial of ADA accommodations, and prolonged inaction on pending motions have made settlement futile and require public adjudication. The notice also references their pending South Carolina Supreme Court mandamus matter seeking action on the trial court’s unresolved motions.

Legal Significance

Plaintiffs formally and irrevocably withdraw all prior settlement offers, demands, and negotiation frameworks, and demand that the case be set for a jury trial at the earliest available date. The filing does not itself adjudicate any claim or bind defendants to trial, but it places the parties and court on notice that Plaintiffs no longer seek private negotiated resolution.

It also preserves and reiterates Plaintiffs’ allegations that defense conduct and court delays have obstructed the action, including unresolved insurance-disclosure, amendment, and ADA-accommodation requests.

By attaching the South Carolina Supreme Court’s return request in the related mandamus matter, Plaintiffs document that the state Supreme Court has sought information from the Charleston County Clerk concerning the status of their pending motions.

Document Access

Restored copy: native text with the clerk FILE stamp


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Full text of the filing (9 sections, server-rendered)

Notice of Permanent Withdrawal of All Settlement Offers and Demand for Jury Trial (p. 1-1)

TO THE HONORABLE COURT AND ALL PARTIES OF RECORD:
PLEASE TAKE NOTICE that Plaintiffs James C. McNeil and Meaghan Poyer, appearing pro se, hereby formally and irrevocably withdraw any and all prior settlement offers, demands, frameworks, or negotiations extended to Defendants in this matter, effective Friday, May 1, 2026, at 12:01 PM EDT.

Plaintiffs will not entertain, accept, or engage in any future settlement negotiations, regardless of the amount offered. Plaintiffs formally demand that this matter proceed to a jury trial at the earliest available date.

This irrevocable commitment to trial is necessitated by the following documented conditions of institutional failure and defense lawfare:

1. Bad Faith Defense Tactics (p. 2-2)

1. Bad Faith Defense Tactics: Defendants' retained counsel have engaged in a coordinated pattern of bad faith negotiations - including establishing policy-limits settlement frameworks and then abruptly reversing course to counter with gaslighting nuisance offers framed around the same false narrative of the case that Defendants have used against Plaintiffs throughout this litigation (see items 4 and 5 below). This conduct has intentionally sabotaged any good-faith resolution and is part of the same coordinated gaslighting pattern that produced the medical harm documented in item 4.

2. Intentional Concealment of Insurance Exposure (p. 2-2)

2. Intentional Concealment of Insurance Exposure: Defendants have actively stonewalled mandatory disclosures to prevent any good-faith evaluation of this case. Plaintiffs’ Motion to Compel Insurance Disclosure and for Sanctions has sat on this Court’s docket unopposed and completely unaddressed since September 30, 2025 - over 212 days. This coordinated refusal to disclose basic coverage parameters proves the defense was never operating with an intent to resolve this matter, rendering further negotiation futile.

3. Improper Continuances Enabling Lawfare (p. 2-2)

3. Improper Continuances Enabling Lawfare: Defendants successfully secured two separate continuances under demonstrably false pretenses (including fabricated consent). These procedurally improper delays removed all judicial pressure on the defense to negotiate or face accountability, effectively buying them the dark space needed to execute the exhaustion and gaslighting tactics that broke Plaintiff McNeil's health.

4. Documented Medical Harm Caused by Defense Conduct (p. 2-3)

4. Documented Medical Harm Caused by Defense Conduct: Plaintiff McNeil had no PTSD diagnosis and no PTSD symptoms prior to encountering Defendants. Defendants' deliberate attrition tactics, gaslighting about case scope, and discovery obstruction directly caused Plaintiff McNeil to suffer a documented nervous breakdown (PCL-5 score of 76/80, indicating extreme/severe PTSD). The disability described in this litigation is an injury Defendants inflicted during this litigation.

5. Denial of ADA Accommodations for That Defense-Inflicted Disability (p. 3-3)

5. Denial of ADA Accommodations for That Defense-Inflicted Disability: Plaintiffs filed formal ADA accommodation requests beginning January 30, 2026, detailing the Defendant-caused medical crisis described in item 4 and seeking a set of accommodations necessary for meaningful pro se participation - including Webex remote-appearance access. This Court has allowed 91 days to pass without ruling on those requests. During that same interval, when defense counsel subsequently asked in a court staff thread for Webex remote-appearance access - one of the accommodations already pending in Plaintiffs' request - the Court granted that to defense within days. The disabled pro se litigant whose disability Defendants inflicted continues to wait 91 days and counting; opposing counsel received the same accommodation, by reference to the same technology, within days of asking.

6. Systemic Obstruction (p. 3-4)

6. Systemic Obstruction: Plaintiffs' Motion for Leave to File the Second Amended Complaint, filed October 24, 2025, remains pending before this Court as of the filing of this Notice - 189 days later, without hearing and without ruling - despite Rule 15(a), SCRCP, directing that such leave "shall be freely given when justice so requires." The proposed pleading introduces causes of action arising from the mass-syndicated publication of private images of Plaintiffs' lives - discovered September 18, 2025 after approximately ten weeks of undisclosed public exposure - and names Charles S. Altman, a Charleston legal and real estate insider, as an individual defendant.

The 189-day denial of access to justice persists as of this filing. For 179 of those 189 days, no Defendant filed any written opposition to the Motion. Defendant SAC 181, LLC finally filed its Memorandum of Law in Opposition on April 21, 2026 - 179 days late, and on the same day Defendants were provided a pre-filing courtesy copy of this Notice. That Opposition engages none of the evidentiary record supporting the proposed pleading. It does not address the mass-syndicated image publication, the retaliatory-eviction pattern, the documented PMIC regulatory violations, the falsified postal evidence, the SAC 181_OP commingling, or the factual allegations supporting piercing the corporate veil. It argues only that the proposed pleading is "futile" and "dilatory" - 179 days after sitting silent on a motion the Rules direct this Court to grant freely.

The 189-day denial of access to justice persists as of this filing. On April 28, 2026, the Supreme Court of South Carolina docketed Plaintiffs' request for original-jurisdiction relief as Appellate Case No. 2026-000919 and directed the Charleston County Clerk of Court to serve and file a return within ten days addressing the current status of Plaintiffs' pending motions. The pattern that persisted for 189 days is now under the active review of the Supreme Court. It is no longer merely a local administrative failure; it is a matter of record at the highest court in this State.

[True and correct copies of (a) Plaintiffs' Petition for Writ of Mandamus in Appellate Case No. 2026-000919 and (b) the Supreme Court of South Carolina's April 28, 2026 return-request letter are attached as Exhibits A and B, respectively.]

Defendants' escalating exposure remains shielded from judicial review. The pattern is not neutral; it is structural.

Basis for Trial Commitment (p. 4-5)

Because the local judicial apparatus has proven either unable or unwilling to protect a disabled pro se litigant from coordinated defense lawfare or rule on basic administrative motions, Plaintiffs are forced to seek the transparency and "sunshine" of national investigative press and the equalizing power of a jury of peers.

Partnering with national media to expose the systemic failures documented in the Housing Justice Audit requires an absolute, legally binding commitment that Plaintiffs will not accept a confidential financial settlement to quietly dismiss the case.

Request for Jury Trial Roster (p. 5-5)

This Notice serves as that binding commitment. The time for private resolution has permanently closed. Plaintiffs respectfully request that the Court place this matter on the next available roster for a jury trial.

Machine-readable record

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Official copy
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Native source
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Restored copy
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Normalized text
pending

Parties in this Record

  • James C. McNeil (Filed by)
  • James C. McNeil (Filed by)
  • Adam Bayles (Actor)
  • Charles S. Altman (Actor)
  • Charleston County Court of Common Pleas (Court)
  • Meaghan Poyer (Actor)
  • Meridian Residential Group, LLC (Actor)
  • SAC 181, LLC (Actor)
  • Tara Bayles (Actor)
  • U.S. Court of Appeals, Fourth Circuit (Actor)
  • U.S. District Court, District of South Carolina (Actor)