Document Overview
SC 9th Circuit Common Pleas Case number: 2025-CP-10-05095Filing Date: October 24, 2025
Document: Motion for Leave to File Second Amended Complaint
Document Type: Motion for Leave to File Second Amended Complaint under Rule 15(a), SCRCP, seeking permission to add claims, allegations, and Charles S. Altman as an individual defendant.
What's here: Explains why amendment is timely, in good faith, related to the same occurrence, nonprejudicial, and not futile; requests relation back and 30 days for defendants to respond. Includes a proposed 32-page Second Amended Complaint alleging security-deposit violations, fraud, breach of lease, retaliation, negligence, enterprise/alter-ego liability, SCUTPA violations, privacy torts, and negligent hiring/retention/supervision, plus supporting exhibits concerning listings and image syndication, management communications, deposit records, corporate records, cross-claims, and public reviews.
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Executive Summary
James C. McNeil and Meaghan Poyer, appearing pro se, move for leave under South Carolina Rule 15(a) to file a proposed Second Amended Complaint in their Charleston County action against SAC 181, Meridian Residential Group, the Bayles defendants, MRG Investing, and proposed new defendant Charles S. Altman.
They assert that newly discovered evidence - including widespread publication of images from their occupied home, Meridian’s cross-claim statements about its relationship with SAC, and a management-transition email - supports additional claims and Altman’s individual liability. The proposed complaint adds claims under SCUTPA, common-law privacy theories, and negligent hiring, retention, and supervision, while expanding allegations of retaliatory tenancy termination, deceptive deposit handling, fraud, enterprise/alter-ego liability, and unauthorized commercial use of plaintiffs’ images.
The motion asks the court to grant leave, deem the amended complaint filed as of the order date, rule that the claims relate back under Rule 15(c), and allow all defendants 30 days to respond.
Legal Significance
Plaintiffs seek leave under Rule 15(a) to file a Second Amended Complaint and add Charles S. Altman individually as a defendant. The proposed amendment materially expands the case with SCUTPA, common-law privacy, negligent hiring/retention/supervision, and enhanced enterprise/alter-ego theories, while preserving and restating existing deposit, fraud, contract, retaliation, and negligence claims.
It places at issue alleged deceptive procurement and commercial publication of tenants’ images, retaliatory nonrenewal, late or falsified deposit-mailing documentation, and whether SAC, Meridian, their principals, and affiliated entities operated as a unified enterprise. The motion relies on post-amendment discoveries and defendants’ October 9 crossclaim admissions to argue diligence, lack of prejudice, nonfutility, and relation back under Rule 15(c), and requests thirty days for all defendants, including Altman, to respond if leave is granted.