Executive Summary
Plaintiffs James C. McNeil and Meaghan Poyer, proceeding pro se, filed this motion to compel defendants to disclose insurance information and to seek sanctions or other relief ensuring future cooperation. They assert that defendants ignored four informal written requests for carrier identities, policy numbers, limits, coverage positions, punitive-damages coverage, and claims-adjuster information, while SAC 181’s insurer indicated that other defendants have their own insurers.
The motion argues that insurance information is discoverable under South Carolina Rule 26 and necessary for case management and settlement evaluation. Plaintiffs ask the court to order each defendant to provide the requested insurance disclosures within five business days and grant any further appropriate relief.
Legal Significance
Plaintiffs seek an order requiring all defendants to disclose insurance carriers, policy numbers and limits, coverage positions, punitive-damages coverage, and adjuster contacts within five business days. The motion puts at issue whether defendants’ failure to answer four informal, pre-answer insurance requests warrants court intervention or sanctions, despite plaintiffs acknowledging that formal discovery may not yet have commenced.
It relies on Rule 26’s insurance-discovery provision and the court’s case-management authority, asserting that an insurer’s statement indicates the remaining defendants have separate coverage. If granted, the motion would accelerate disclosure of coverage information and potentially facilitate coordinated defense, settlement evaluation, and future discovery.
Full text of the filing (14 sections, server-rendered)
Caption and Motion Title, p 1 (p. 1-1)
STATE OF SOUTH CAROLINA )
) IN THE COURT OF COMMON PLEAS
COUNTY OF CHARLESTON ) NINTH JUDICIAL CIRCUIT
) James C. (“Chris”) McNeil and ) Civil Action No.: 2025-CP-10-05095 Meaghan Poyer, ) ) Plaintiffs, ) ) v. ) )
SAC 181, LLC, )
Meridian Residential Group, LLC, ) Adam W. Bayles, individually, ) Tara Bayles, individually, and ) MRG Investing Company LLC, ) Defendants. ) _____________________________________ )
MOTION TO COMPEL INSURANCE DISCLOSURE AND FOR SANCTIONS
TO THE HONORABLE COURT:
Plaintiffs James C. McNeil and Meaghan Poyer, appearing pro se, respectfully move this Court to compel Defendants to provide mandatory insurance disclosures and for such sanctions as the Court deems appropriate to ensure future cooperation.
I. Procedural Background, pp 1-2 (p. 1-2)
I. PROCEDURAL BACKGROUND
1. On September 10, 2025, Defendants were served with the Complaint.
2. On September 15, 2025, Plaintiffs filed an Amended Complaint.
3. Plaintiffs have made FOUR separate requests for insurance disclosure, all ignored:
a. September 17, 2025 (48-hour deadline): Email to Mr. Pettis requesting insurance carriers and policy numbers "to facilitate efficient resolution. " True copy attached as Exhibit A. b. September 22, 2025: Email transmitting Enhanced Jury Risk Analysis V3, again requesting insurance information. True copy attached as Exhibit B. c. September 25, 2025 (48-hour deadline expiring 9/27): Email explicitly requesting insurance coverage information with clear deadline. True copy attached as Exhibit C. d. September 29, 2025: Email transmitting Jury Risk Analysis V4, noting "Insurance information (outstanding)" as a housekeeping item requiring response. True copy attached as Exhibit D.
4. Mr. Pettis has not responded to any of these requests.
5. Only SAC 181's insurer (IPG) has voluntarily engaged, confirming coverage for SAC
181 only and requesting answer extension.
II. Legal Standard, p 2 (p. 2-2)
II. LEGAL STANDARD
Rule 26(b)(2), S.C.R.C.P ., makes insurance information discoverable: "A party may obtain discovery... regarding... the existence and contents of any insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment... " While formal discovery typically commences after responsive pleadings, Plaintiffs made reasonable informal requests for information that defendants could voluntarily provide to facilitate case management and settlement discussions. Courts encourage such voluntary exchanges to promote efficient resolution. Rule 37(d) authorizes sanctions when parties fail to respond to proper discovery requests. While these requests were informal and pre-answer, defendants' complete non- responsiveness over four separate requests spanning thirteen days demonstrates an obstructive approach requiring judicial intervention.
III.A. Informal Requests Were Reasonable and Proper, pp 2-3 (p. 2-3)
III. ARGUMENT
A. Informal Requests Were Reasonable and Proper Plaintiffs made four clear written requests for basic insurance information to facilitate: • Efficient case management with multiple defendants • Coordination of defense counsel assignment • Evaluation of settlement possibilities • Understanding of coverage positions This information is routinely exchanged informally in the interest of judicial economy.
III.B. SAC 181's Insurer Confirms Other Defendants Have Insurance, p 3 (p. 3-3)
B. SAC 181's Insurer Confirms Other Defendants Have Insurance IPG's voluntary engagement proves insurance information exists and is readily accessible. More significantly, IPG's claims examiner Gladys Lambert stated in her September 29, 2025 email: "I understand the other defendants have their own insurance carriers. " True copy attached as Exhibit E. This statement confirms:
1. The other defendants have insurance coverage
2. This information is known to parties in the case
3. There is no legitimate reason for continued refusal to disclose
Despite this confirmation that insurance exists, defendants Meridian Residential Group, LLC; Adam W. Bayles; Tara Bayles; and MRG Investing Company LLC continue to withhold basic carrier and policy information necessary for case management.
III.C. Complete Non-Response Justifies Court Intervention, p 3 (p. 3-3)
C. Complete Non-Response Justifies Court Intervention While defendants have no formal obligation to respond to pre-answer informal requests, their complete silence across four attempts over thirteen days suggests an intent to obstruct rather than cooperate in case management.
III.D. Insurance Information Is Prerequisite to Settlement Discussions, pp 3-4 (p. 3-4)
D. Insurance Information Is Prerequisite to Settlement Discussions SAC 181's insurer stated in her September 29, 2025 email: "It is premature to discuss settlement, I am unable to commit to settlement negotiations at this stage. " This confirms that settlement discussions cannot proceed without basic insurance information from all defendants. The Court and parties cannot evaluate reasonable settlement parameters when: • Four defendants refuse to disclose insurance carriers or policy limits • Coverage positions are unknown • Coordination among multiple insurers is impossible Defendants' refusal to provide insurance information creates a circular problem: settlement is "premature" because they won't provide the information necessary to make settlement discussions possible.
III.E. Court Has Authority to Order Disclosure, p 4 (p. 4-4)
E. Court Has Authority to Order Disclosure Under its inherent case management authority and Rule 26(c), this Court may order early disclosure of insurance information to promote efficient case resolution, particularly where: • Multiple defendants require coordination • Insurance coverage will determine defense strategy • Informal requests have been repeatedly ignored • Information is readily available but being withheld
IV. Requested Relief, pp 4-5 (p. 4-5)
IV. REQUESTED RELIEF
WHEREFORE, Plaintiffs respectfully request: A. ORDER compelling each Defendant to disclose within five (5) business days:
1. Identity of all insurance carriers providing coverage for claims alleged
2. Policy numbers
3. Policy limits
4. Coverage position (accepted, denied, or reservation of rights)
5. Whether coverage extends to punitive damages
6. Identity and contact information for assigned claims adjusters
B. SUCH OTHER RELIEF as the Court deems appropriate to ensure cooperation with case management. Respectfully submitted this 30th day of September, 2025.
_________________________________ James C. (“Chris”) McNeil, Pro Se Plaintiff
_________________________________ Meaghan Poyer, Pro Se Plaintiff P.O. Box 30386 Charleston, SC 29417 chris@thaut.io | mcneilandpoyer@gmail.com
Exhibit A, p 6 (p. 6-6)
EXHIBIT A
September 17 email to Pettis screenshot
Exhibit B, p 7 (p. 7-7)
EXHIBIT B
September 22 email to Pettis screenshot
Exhibit C, p 8 (p. 8-8)
EXHIBIT C
September 25 email to Pettis screenshot
Exhibit D, p 9 (p. 9-9)
EXHIBIT D
September 29 email to Pettis screenshot
Exhibit E, p 10 (p. 10-10)
EXHIBIT E
September 29 email from Lambert screenshot