Document Overview
SC 9th Circuit Common Pleas Case number: 2025-CP-10-05095Filing Date: October 29, 2025
Document: Emergency Motion for Rule 11 Sanctions and to Strike Defective Answer Pursuant to SCRCР 11(b)(3) and 12(f)
Document Type: Emergency Motion for Rule 11 Sanctions and to Strike Defendants’ Answer, seeking sanctions for alleged unsupported denials and defective affirmative defenses
Includes: Requests that the court strike the Answer’s responses and affirmative defenses while preserving the crossclaim, deem certain allegations admitted, award sanctions and fees, and expedite a hearing. Includes 7 exhibits concerning emails, scanned mailing materials, public and corporate records, a management-transition notice, a USPS envelope, Secretary of State filing history, and an October 16 attorney correspondence.
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| Name | Description | Type | Filed | Docket Seq. | Documents |
|---|
| James C. McNeil |
Emergency Motion/Rule 11 Sanctions & Strike Defective Answer |
Motion |
10/29/2025 |
P1A11 |
Official copy
Restored copy
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1-bit bitonal image encodingRestoredfiled
Executive Summary
James C. McNeil, proceeding pro se with co-plaintiff Meaghan Poyer, filed an emergency motion in Charleston County Court of Common Pleas seeking Rule 11 sanctions and to strike much of the defendants’ answer to the amended complaint.
The motion alleges that SAC 181, Meridian Residential Group, the Bayleses, and MRG Investing Company made unsupported boilerplate denials of facts within their control, including their own emails, records, lease documents, mailing information, and corporate filings. Plaintiffs ask the court to strike the answer’s responses and affirmative defenses while preserving the crossclaim against SAC 181, deem improperly denied allegations admitted, award monetary or other sanctions, and expedite a hearing.
Legal Significance
Plaintiffs seek emergency Rule 11 sanctions and striking of defendants’ Answer and affirmative defenses, alleging that the denials lack evidentiary support, contradict defendants’ own records, and were asserted without reasonable inquiry. The motion asks the court to deem the amended complaint’s well-pleaded factual allegations admitted under Rule 8(b)/(d), which, if granted, would materially limit defendants’ ability to contest liability-related facts while leaving their crossclaim against SAC 181 intact.
It also places at issue the propriety of defense counsel’s pleading practices and communications, including alleged boilerplate denials, inconsistent lease positions, and purported efforts to obstruct service on an LLC. Plaintiffs request monetary or other deterrent sanctions, citing over 50 hours of claimed lost work valued at $18,750, and expedited consideration due to their pro se status.
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7706b94f9b7748f238214802d65cf4f9abf4789c4013bf455529ef932bd250f3- Native source
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Parties in this Record
- James C. McNeil (Filed by)
- Adam Bayles (Defendant)
- Alicia Bolyard (Counsel)
- Meridian Residential Group, LLC (Defendant)
- Tara Bayles (Defendant)