Full text of the filing (26 sections, server-rendered)
Caption and Notice 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, ) NOTICE OF PRIOR SERVICE
) AND COMPUTED DEADLINES
v. ) )
SAC 181, LLC, )
Meridian Residential Group, LLC, ) Adam W. Bayles, individually, ) Tara Bayles, individually, and ) MRG Investing Company LLC, ) ) Defendants. ) _____________________________________ )
Notice Introduction (p. 1-1)
Plaintiffs give notice to the Court and all parties of the following:
Notice Introduction and Paragraph 1, p 1 (p. 1-1)
Plaintiffs give notice to the Court and all parties of the following:
1. On October 3, 2025 at 5:17 PM, Plaintiffs served First Interrogatories and First Requests for
Production on Meridian Residential Group, LLC; SAC 181, LLC; Adam W. Bayles; and Tara R. Bayles through then-counsel Eric Pettis. See Exhibits A–B (service transmittal screenshot and full email with four discovery PDFs).
Paragraph 1 - October 3 Discovery Service (p. 1-1)
1. On October 3, 2025 at 5:17 PM, Plaintiffs served First Interrogatories and First Requests for
Production on Meridian Residential Group, LLC; SAC 181, LLC; Adam W. Bayles; and Tara R. Bayles through then-counsel Eric Pettis. See Exhibits A–B (service transmittal screenshot and full email with four discovery PDFs).
Paragraph 2 – Requests for Admission Service, p 1 (p. 1-1)
2. On October 31, 2025, Plaintiffs served their First Requests for Admission on counsel of record.
See Exhibit D (Certificates of Service).
Paragraph 2 - October 31 Requests for Admission Service (p. 1-1)
2. On October 31, 2025, Plaintiffs served their First Requests for Admission on counsel of record.
See Exhibit D (Certificates of Service).
Paragraph 3 – Courtesy Notice and Representation Confirmation, p 1 (p. 1-1)
3. Plaintiffs also provided courtesy notice to SAC 181’s insurer the evening of October 3, 2025. See
Exhibit C. Mr. Pettis had previously confirmed on September 10, 2025 that he represented both management and ownership (including SAC 181, LLC) and would accept service for those entities. See Exhibit E.
Paragraph 3 - Courtesy Notice and Representation Confirmation (p. 1-1)
3. Plaintiffs also provided courtesy notice to SAC 181’s insurer the evening of October 3, 2025. See
Exhibit C. Mr. Pettis had previously confirmed on September 10, 2025 that he represented both management and ownership (including SAC 181, LLC) and would accept service for those entities. See Exhibit E.
Paragraph 4 – Computed Response Deadlines, p 1 (p. 1-1)
4. Based on the above service dates—and Defendants’ stated position that email service is computed
with the Rule 6(e) five-day add-on—the following response deadlines apply: • Interrogatories and Requests for Production served October 3, 2025: Due Friday, November 7, 2025. • Requests for Admission served October 31, 2025: Due Friday, December 5, 2025.
Paragraph 4 - Computed Response Deadlines (p. 1-1)
4. Based on the above service dates—and Defendants’ stated position that email service is computed
with the Rule 6(e) five-day add-on—the following response deadlines apply: • Interrogatories and Requests for Production served October 3, 2025: Due Friday, November 7, 2025. • Requests for Admission served October 31, 2025: Due Friday, December 5, 2025.
Notice Closing and Signature, pp 1-2 (p. 1-2)
This Notice seeks no relief and is submitted to maintain a clear record and avoid further confusion regarding running deadlines. Plaintiffs will proceed on the dates above absent an agreed extension or Court order.
Dated: November 5, 2025 Respectfully submitted,
______________________________ James C. (Chris) McNeil, Plaintiff Pro Se (on behalf of Plaintiffs) P.O. Box 30386, Charleston, SC 29417 chris@thaut.io | (843) 818-3495
Purpose of Notice (p. 1-1)
This Notice seeks no relief and is submitted to maintain a clear record and avoid further confusion regarding running deadlines. Plaintiffs will proceed on the dates above absent an agreed extension or Court order.
Exhibit A – Screenshot of Service Email, p 3 (p. 3-4)
EXHIBIT A
Screenshot of Service email to Pettis 10/3/2025
Signature Block (p. 2-2)
Dated: November 5, 2025 Respectfully submitted,
______________________________ James C. (Chris) McNeil, Plaintiff Pro Se (on behalf of Plaintiffs) P.O. Box 30386, Charleston, SC 29417 chris@thaut.io | (843) 818-3495
Exhibit B – PDF of Service Email, p 5 (p. 5-5)
EXHIBIT B
PDF of Service email to Pettis 10/3/2025
Exhibit A - Screenshot of Service Email (p. 3-4)
EXHIBIT A
Screenshot of Service email to Pettis 10/3/2025
Exhibit B – October 3, 2025 Service Email to Pettis, pp 6-7 (p. 6-7)
From: chris thaut.io To: epettis@bwpf-law.com Cc: Desja Wilder; C&M McNeil; Charlie Altman Subject: Service of Discovery - McNeil & Poyer v. SAC 181, LLC, et al. (2025-CP-10-05095) Date: Friday, October 3, 2025 5:17:00 PM Attachments: Discovery_Meridian_Residential_Group.pdf Discovery_Adam_Bayles.pdf Discovery_Tara_Bayles.pdf Discovery_SAC_181_LLC.pdf Importance: High Sensitivity: Confidential Mr. Pettis,
Pursuant to Rules 33 and 34 of the South Carolina Rules of Civil Procedure, Plaintiffs hereby serve the attached First Set of Interrogatories and Requests for Production of Documents upon the following defendants:
1. Meridian Residential Group, LLC
2. Tara R. Bayles, individually
3. Adam W. Bayles, individually
4. SAC 181, LLC
5. MRG Investing Company, LLC
Responses to the attached discovery are due within thirty (30) days of service, on or before November 3, 2025, regardless of any pending answer deadlines.
Pending Deadlines: October 15, 2025: Answer to Amended Complaint due for Adam Bayles, Tara Bayles, and Meridian Residential Group, LLC October 29, 2025: Answer to Amended Complaint due for SAC 181, LLC (per courtesy extension)
Important Notes:
1. Evidence Preservation: This discovery is served in coordination with Plaintiffs’
October 2, 2025 Evidence Preservation Demand. Defendants remain under continuing obligation to preserve all potentially responsive materials, including but not limited to: Native digital files with metadata intact AppFolio system logs and syndication data The file "Meridian_Scanner_20250905_161321.pdf" with complete forensic metadata All versions of documents, including those in backup systems
2. ESI Production Requirements: Electronic documents must be produced in native
format with all metadata preserved as specified in the discovery requests.
3. Privilege Logs: Any documents withheld on privilege grounds require a privilege
log per Rule 26(b)(5), SCRCP, within the 30-day response period.
4. Representation Status: Please confirm whether you continue to represent all
named defendants in this matter, or whether separate counsel has been or will be retained for any party.
Please acknowledge receipt of this email and the attached discovery requests.
Respectfully,
James C. McNeil & Meaghan Poyer Plaintiffs Pro Se PO Box 30386 Charleston, SC 29417 Email: chris@thaut.io; mcneilandpoyer@gmail.com Telephone: (843) 818-3495
CC (Courtesy Copy Only - No Response Required): Charles Altman as RA of SAC 181, LLC (caltman@caltmanlaw.com)
Note to CC Recipient: This email is being provided as a courtesy copy only to ensure you are informed of discovery served upon the defendants in this matter. All responses must be directed through counsel of record (Eric R. Pettis). We are not soliciting direct communication with represented parties with this email.
Exhibit B - October 3 Service Email to Pettis (p. 5-7)
EXHIBIT B
PDF of Service email to Pettis 10/3/2025
From: chris thaut.io To: epettis@bwpf-law.com Cc: Desja Wilder; C&M McNeil; Charlie Altman Subject: Service of Discovery - McNeil & Poyer v. SAC 181, LLC, et al. (2025-CP-10-05095) Date: Friday, October 3, 2025 5:17:00 PM Attachments: Discovery_Meridian_Residential_Group.pdf Discovery_Adam_Bayles.pdf Discovery_Tara_Bayles.pdf Discovery_SAC_181_LLC.pdf Importance: High Sensitivity: Confidential Mr. Pettis,
Pursuant to Rules 33 and 34 of the South Carolina Rules of Civil Procedure, Plaintiffs hereby serve the attached First Set of Interrogatories and Requests for Production of Documents upon the following defendants:
1. Meridian Residential Group, LLC
2. Tara R. Bayles, individually
3. Adam W. Bayles, individually
4. SAC 181, LLC
5. MRG Investing Company, LLC
Responses to the attached discovery are due within thirty (30) days of service, on or before November 3, 2025, regardless of any pending answer deadlines.
Pending Deadlines: October 15, 2025: Answer to Amended Complaint due for Adam Bayles, Tara Bayles, and Meridian Residential Group, LLC October 29, 2025: Answer to Amended Complaint due for SAC 181, LLC (per courtesy extension)
Important Notes:
1. Evidence Preservation: This discovery is served in coordination with Plaintiffs’
October 2, 2025 Evidence Preservation Demand. Defendants remain under continuing obligation to preserve all potentially responsive materials, including but not limited to: Native digital files with metadata intact AppFolio system logs and syndication data The file "Meridian_Scanner_20250905_161321.pdf" with complete forensic metadata All versions of documents, including those in backup systems
2. ESI Production Requirements: Electronic documents must be produced in native
format with all metadata preserved as specified in the discovery requests.
3. Privilege Logs: Any documents withheld on privilege grounds require a privilege
log per Rule 26(b)(5), SCRCP, within the 30-day response period.
4. Representation Status: Please confirm whether you continue to represent all
named defendants in this matter, or whether separate counsel has been or will be retained for any party.
Please acknowledge receipt of this email and the attached discovery requests.
Respectfully,
James C. McNeil & Meaghan Poyer Plaintiffs Pro Se PO Box 30386 Charleston, SC 29417 Email: chris@thaut.io; mcneilandpoyer@gmail.com Telephone: (843) 818-3495
CC (Courtesy Copy Only - No Response Required): Charles Altman as RA of SAC 181, LLC (caltman@caltmanlaw.com)
Note to CC Recipient: This email is being provided as a courtesy copy only to ensure you are informed of discovery served upon the defendants in this matter. All responses must be directed through counsel of record (Eric R. Pettis). We are not soliciting direct communication with represented parties with this email.
Exhibit C – PDF of Reply Email from Gladys Lambert, p 8 (p. 8-8)
EXHIBIT C
PDF of Reply Email from Gladys Lambert 10/3/2025
Exhibit C - October 3 IPG Reply and Prior Coverage Emails (p. 8-11)
EXHIBIT C
PDF of Reply Email from Gladys Lambert 10/3/2025
From: Gladys Lambert To: chris thaut.io; "mcneilandpoyer@gmail.com" Subject: RE: Update - Discovery Served in McNeil v. SAC 181, LLC Date: Friday, October 3, 2025 6:40:04 PM Thank you for the notice.
IPG Logo Gladys Lambert, MBA, CPCU, AIC, AINS, CA License 6003996 (IPG) Senior Claims Examiner gladys.lambert@ipgclaims.com Direct Toll Free : : 501-725-3425 (Phone/Text/Fax) 800 ‑684 ‑9157 x4095 International Programs Group – ipgclaims.com P.O. Box 45058, Little Rock, AR 72214 This email communication is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged information. Any use of this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the email and all copies (electronic or otherwise) immediately. From: chris thaut.io Sent: Friday, October 3, 2025 4:27 PM To: Gladys Lambert ; 'mcneilandpoyer@gmail.com' Subject: Update - Discovery Served in McNeil v. SAC 181, LLC
CAUTION - EXTERNAL EMAIL | ATTENTION - COURRIEL EXTERNE
Ms. Lambert,
Thank you for your prior communication regarding the extension for SAC 181, LLC to retain separate counsel.
I wanted to inform you that today we served comprehensive discovery requests on all defendants, including SAC 181, LLC. Responses are due November 3, 2025, shortly after the October 29 answer deadline.
The discovery addresses: Charles Altman's personal involvement in decisions regarding our tenancy SAC 181's financial condition and assets Knowledge of the 2020-2021 litigation and its influence on 2025 actions Insurance coverage information
All formal communications should continue through Mr. Eric Pettis at Brownlee Whitlow and Praet, who, to our knowledge, currently represents all defendants, excepting MRG Investing Company, LLC, who remains unrepresented to our knowledge, or through separate counsel once retained by SAC 181, LLC.
Given the compressed timeline (October 29 answer + November 3 discovery responses), we wanted to ensure you were aware of these deadlines as you coordinate SAC 181's separate representation.
Respectfully, James C. McNeil and Meaghan Poyer Plaintiffs Pro Se PO Box 30386 • Charleston, SC 29417 chris@thaut.io | mcneilandpoyer@gmail.com • (843) 818-3495
From: chris thaut.io Sent: Wednesday, October 1, 2025 12:03 PM To: Gladys Lambert ; mcneilandpoyer@gmail.com Subject: RE: Concerning claim 147434 - SAC 181 LLC (63522-91095) (Enhanced Jury Risk Analysis V4 - Extension Conditions for SAC 181, LLC )
Ms. Lambert,
Thank you for the coverage information.
Plaintiffs consent to extending SAC 181, LLC's answer deadline to October 29, 2025. Please provide defense counsel's contact information once assigned.
Note: We filed two motions yesterday regarding the other defendants. Your voluntary disclosure resolved SAC 181's portion of the insurance disclosure motion.
Respectfully, James C. McNeil and Meaghan Poyer Plaintiffs Pro Se PO Box 30386 • Charleston, SC 29417 chris@thaut.io | mcneilandpoyer@gmail.com • (843) 818-3495
From: Gladys Lambert Sent: Wednesday, October 1, 2025 9:51 AM To: chris thaut.io ; mcneilandpoyer@gmail.com Subject: RE: Concerning claim 147434 - SAC 181 LLC (63522-91095) (Enhanced Jury Risk Analysis V4 - Extension Conditions for SAC 181, LLC )
Good morning,
1. Confirmation of defense counsel assignment and contact information: Defense is
being provided and counsel will be assigned
2. Insurance policy limits for relevant coverage $500,000 policy limits
3. Coverage position (accepted, denied, or under reservation of rights) Defense
under reservation of rights
4. Whether coverage extends to punitive damages No coverage for punitive damages
Regards, IPG Logo Gladys Lambert, MBA, CPCU, AIC, AINS, CA License 6003996 (IPG) Senior Claims Examiner gladys.lambert@ipgclaims.com Direct Toll Free : : 501-725-3425 (Phone/Text/Fax) 800 ‑684 ‑9157 x4095 International Programs Group – ipgclaims.com P.O. Box 45058, Little Rock, AR 72214 This email communication is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged information. Any use of this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the email and all copies (electronic or otherwise) immediately. From: chris thaut.io Sent: Monday, September 29, 2025 11:45 AM To: Gladys Lambert ; mcneilandpoyer@gmail.com Subject: RE: Concerning claim 147434 - SAC 181 LLC (63522-91095) (Enhanced Jury Risk Analysis V4 - Extension Conditions for SAC 181, LLC )
CAUTION - EXTERNAL EMAIL | ATTENTION - COURRIEL EXTERNE
Ms. Lambert,
Thank you for clarifying IPG's coverage scope (SAC 181 only).
Attached is Enhanced Jury Risk Analysis V4, reflecting evidence developments since JRA
V3.
Regarding your extension request: I can agree to October 29, 2025 for SAC 181's answer deadline, conditioned upon receiving the following information within 10
Exhibit C – October 3, 2025 IPG Email Thread, pp 9-11 (p. 9-11)
From: Gladys Lambert To: chris thaut.io; "mcneilandpoyer@gmail.com" Subject: RE: Update - Discovery Served in McNeil v. SAC 181, LLC Date: Friday, October 3, 2025 6:40:04 PM Thank you for the notice.
IPG Logo Gladys Lambert, MBA, CPCU, AIC, AINS, CA License 6003996 (IPG) Senior Claims Examiner gladys.lambert@ipgclaims.com Direct Toll Free : : 501-725-3425 (Phone/Text/Fax) 800 ‑684 ‑9157 x4095 International Programs Group – ipgclaims.com P.O. Box 45058, Little Rock, AR 72214 This email communication is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged information. Any use of this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the email and all copies (electronic or otherwise) immediately. From: chris thaut.io Sent: Friday, October 3, 2025 4:27 PM To: Gladys Lambert ; 'mcneilandpoyer@gmail.com' Subject: Update - Discovery Served in McNeil v. SAC 181, LLC
CAUTION - EXTERNAL EMAIL | ATTENTION - COURRIEL EXTERNE
Ms. Lambert,
Thank you for your prior communication regarding the extension for SAC 181, LLC to retain separate counsel.
I wanted to inform you that today we served comprehensive discovery requests on all defendants, including SAC 181, LLC. Responses are due November 3, 2025, shortly after the October 29 answer deadline.
The discovery addresses: Charles Altman's personal involvement in decisions regarding our tenancy SAC 181's financial condition and assets Knowledge of the 2020-2021 litigation and its influence on 2025 actions Insurance coverage information
All formal communications should continue through Mr. Eric Pettis at Brownlee Whitlow and Praet, who, to our knowledge, currently represents all defendants, excepting MRG Investing Company, LLC, who remains unrepresented to our knowledge, or through separate counsel once retained by SAC 181, LLC.
Given the compressed timeline (October 29 answer + November 3 discovery responses), we wanted to ensure you were aware of these deadlines as you coordinate SAC 181's separate representation.
Respectfully, James C. McNeil and Meaghan Poyer Plaintiffs Pro Se PO Box 30386 • Charleston, SC 29417 chris@thaut.io | mcneilandpoyer@gmail.com • (843) 818-3495
From: chris thaut.io Sent: Wednesday, October 1, 2025 12:03 PM To: Gladys Lambert ; mcneilandpoyer@gmail.com Subject: RE: Concerning claim 147434 - SAC 181 LLC (63522-91095) (Enhanced Jury Risk Analysis V4 - Extension Conditions for SAC 181, LLC )
Ms. Lambert,
Thank you for the coverage information.
Plaintiffs consent to extending SAC 181, LLC's answer deadline to October 29, 2025. Please provide defense counsel's contact information once assigned.
Note: We filed two motions yesterday regarding the other defendants. Your voluntary disclosure resolved SAC 181's portion of the insurance disclosure motion.
Respectfully, James C. McNeil and Meaghan Poyer Plaintiffs Pro Se PO Box 30386 • Charleston, SC 29417 chris@thaut.io | mcneilandpoyer@gmail.com • (843) 818-3495
From: Gladys Lambert Sent: Wednesday, October 1, 2025 9:51 AM To: chris thaut.io ; mcneilandpoyer@gmail.com Subject: RE: Concerning claim 147434 - SAC 181 LLC (63522-91095) (Enhanced Jury Risk Analysis V4 - Extension Conditions for SAC 181, LLC )
Good morning,
1. Confirmation of defense counsel assignment and contact information: Defense is
being provided and counsel will be assigned
2. Insurance policy limits for relevant coverage $500,000 policy limits
3. Coverage position (accepted, denied, or under reservation of rights) Defense
under reservation of rights
4. Whether coverage extends to punitive damages No coverage for punitive damages
Regards, IPG Logo Gladys Lambert, MBA, CPCU, AIC, AINS, CA License 6003996 (IPG) Senior Claims Examiner gladys.lambert@ipgclaims.com Direct Toll Free : : 501-725-3425 (Phone/Text/Fax) 800 ‑684 ‑9157 x4095 International Programs Group – ipgclaims.com P.O. Box 45058, Little Rock, AR 72214 This email communication is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged information. Any use of this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the email and all copies (electronic or otherwise) immediately. From: chris thaut.io Sent: Monday, September 29, 2025 11:45 AM To: Gladys Lambert ; mcneilandpoyer@gmail.com Subject: RE: Concerning claim 147434 - SAC 181 LLC (63522-91095) (Enhanced Jury Risk Analysis V4 - Extension Conditions for SAC 181, LLC )
CAUTION - EXTERNAL EMAIL | ATTENTION - COURRIEL EXTERNE
Ms. Lambert,
Thank you for clarifying IPG's coverage scope (SAC 181 only).
Attached is Enhanced Jury Risk Analysis V4, reflecting evidence developments since JRA
V3.
Regarding your extension request: I can agree to October 29, 2025 for SAC 181's answer deadline, conditioned upon receiving the following information within 10
Exhibit D - Certificates of Service (p. 12-14)
EXHIBIT D
Two Certificates of Service for Discover y Served
Exhibit D – Two Certificates of Service for Discovery, pp 12-14 (p. 12-14)
EXHIBIT D
Two Certificates of Service for Discover y Served
Exhibit E - September 10 Representation Confirmation (p. 15-18)
EXHIBIT E
September 10, 2025 email from Pettis confirming he represents both Meridian Residential Group, LLC and
SAC 181, LLC
From: Eric Pettis To: chris thaut.io; mcneilandpoyer@gmail.com Cc: Desja Wilder Subject: RE: Notice of Representation- Meridian Residential Group, LLC - Demand Letters Date: Wednesday, September 10, 2025 9:41:08 AM Attachments: image001.png Sensitivity: Confidential Greetings Chris, Yes, I represent both management and ownership (SAC 181, LLC). Thank you. With sincere appreciation, Eric Pettis | Associate Licensed in PA and SC Mailing Address: P.O. Box 62975, N. Charleston, South Carolina 29419 Physical Address: 4000 Faber Place Drive, Suite 100, N. Charleston, South Carolina 29405 Firm: (843) 628-7120 | Direct Phone/Fax: (843) 213-6835 Email: epettis@bwpf-law.com Web: BWPF-Law.com The information in this email message is attorney privileged and confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this message is strictly prohibited. If you have received this message in error, please immediately notify the sender by email or by contacting our firm at the numbers listed above. The typewritten signature included with this email is not an electronic signature within the meaning of Electronic Signatures in the Global and National Commerce Act or any other law of similar import, including without limitation, the Uniform Electronic Transactions Act, as the same may be enacted in any State. Consumer Debt Collection Warning: To the extent any portion of this email relates to a consumer debt, please be advised that this email message is an attempt to collect a debt and any information provided may be used for that purpose. From: chris thaut.io Sent: Wednesday, September 10, 2025 9:29 AM To: Eric Pettis ; mcneilandpoyer@gmail.com Cc: Desja Wilder Subject: RE: Notice of Representation- Meridian Residential Group, LLC - Demand Letters Importance: High Sensitivity: Confidential Mr. Pettis, Thank you for your response regarding representation of Meridian Residential Group,
LLC.
Please clarify your representation scope: Do you represent only Meridian Residential Group, LLC, or do you also represent SAC 181, LLC (the property owner)? Ms. Bayles indicated your firm represents both entities. If you do not represent SAC 181, LLC, are you aware of their separate legal representation?
As you review the case materials, you'll recognize this extends beyond a routine deposit dispute. The documented conduct - falsified postal markings, systematic corporate violations, and disregard for statutory tenant protections - reflects a pattern.
I want to be clear that this case is fundamentally about principle..
Property managers wield significant power over vulnerable families' ability to maintain stable housing. When that responsibility is violated through deliberate and reckless misconduct, accountability serves essential community interests. While I harbor no ill will toward your client, meaningful consequences are necessary to protect tenants in general from such conduct.
The multiple areas of exposure favor early resolution, and I'm prepared to settle promptly. However, the resolution must reflect real accountability that serves the broader principle of protecting families from property management abuse.
Please confirm representation scope within 48 hours so we may proceed with appropriate service protocols.
Respectfully,
Chris McNeil & Meaghan Poyer Pro Se Plaintiffs Case No. 2025CP1005095 480A Parkdale Dr. Charleston, SC 29414 | 843-818-3495 (Chris mobile) Chris@thaut.io mcneilandpoyer@gmail.com
From: Eric Pettis Sent: Tuesday, September 9, 2025 10:17 PM To: chris thaut.io ; mcneilandpoyer@gmail.com Cc: Desja Wilder Subject: Notice of Representation- Meridian Residential Group, LLC - Demand Letters
Greetings Chris and Meaghan,
Please take notice that I am legal counsel for MERIDIAN RESIDENTIAL GROUP, LLC and have been retained to represent them in connection with your previous demands and allegations asserted against them. If you have in fact filed a civil action against my Client, I will accept service on their behalf upon receipt of the filed documents. Once I have reviewed this matter and any filings you have made, I will issue a response or file responsive pleadings as appropriate. Thank you. With sincere appreciation, Eric Pettis | Associate Licensed in PA and SC Mailing Address: P.O. Box 62975, N. Charleston, South Carolina 29419 Physical Address: 4000 Faber Place Drive, Suite 100, N. Charleston, South Carolina 29405 Firm: (843) 628-7120 | Direct Phone/Fax: (843) 213-6835 Email: epettis@bwpf-law.com Web: BWPF-Law.com The information in this email message is attorney privileged and confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this message is strictly prohibited. If you have received this message in error, please immediately notify the sender by email or by contacting our firm at the numbers listed above. The typewritten signature included with this email is not an electronic signature within the meaning of Electronic Signatures in the Global and National Commerce Act or any other law of similar import, including without limitation, the Uniform Electronic Transactions Act, as the same may be enacted in any State. Consumer Debt Collection Warning: To the extent any portion of this email relates to a consumer debt, please be advised that this email message is an attempt to collect a debt and any information provided may be used for that purpose.
Exhibit E – September 10, 2025 Representation Confirmation, p 15 (p. 15-15)
EXHIBIT E
September 10, 2025 email from Pettis confirming he represents both Meridian Residential Group, LLC and
SAC 181, LLC
Exhibit E – September 9-10, 2025 Pettis Representation Email Thread, pp 16-18 (p. 16-18)
From: Eric Pettis To: chris thaut.io; mcneilandpoyer@gmail.com Cc: Desja Wilder Subject: RE: Notice of Representation- Meridian Residential Group, LLC - Demand Letters Date: Wednesday, September 10, 2025 9:41:08 AM Attachments: image001.png Sensitivity: Confidential Greetings Chris, Yes, I represent both management and ownership (SAC 181, LLC). Thank you. With sincere appreciation, Eric Pettis | Associate Licensed in PA and SC Mailing Address: P.O. Box 62975, N. Charleston, South Carolina 29419 Physical Address: 4000 Faber Place Drive, Suite 100, N. Charleston, South Carolina 29405 Firm: (843) 628-7120 | Direct Phone/Fax: (843) 213-6835 Email: epettis@bwpf-law.com Web: BWPF-Law.com The information in this email message is attorney privileged and confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this message is strictly prohibited. If you have received this message in error, please immediately notify the sender by email or by contacting our firm at the numbers listed above. The typewritten signature included with this email is not an electronic signature within the meaning of Electronic Signatures in the Global and National Commerce Act or any other law of similar import, including without limitation, the Uniform Electronic Transactions Act, as the same may be enacted in any State. Consumer Debt Collection Warning: To the extent any portion of this email relates to a consumer debt, please be advised that this email message is an attempt to collect a debt and any information provided may be used for that purpose. From: chris thaut.io Sent: Wednesday, September 10, 2025 9:29 AM To: Eric Pettis ; mcneilandpoyer@gmail.com Cc: Desja Wilder Subject: RE: Notice of Representation- Meridian Residential Group, LLC - Demand Letters Importance: High Sensitivity: Confidential Mr. Pettis, Thank you for your response regarding representation of Meridian Residential Group,
LLC.
Please clarify your representation scope: Do you represent only Meridian Residential Group, LLC, or do you also represent SAC 181, LLC (the property owner)? Ms. Bayles indicated your firm represents both entities. If you do not represent SAC 181, LLC, are you aware of their separate legal representation?
As you review the case materials, you'll recognize this extends beyond a routine deposit dispute. The documented conduct - falsified postal markings, systematic corporate violations, and disregard for statutory tenant protections - reflects a pattern.
I want to be clear that this case is fundamentally about principle..
Property managers wield significant power over vulnerable families' ability to maintain stable housing. When that responsibility is violated through deliberate and reckless misconduct, accountability serves essential community interests. While I harbor no ill will toward your client, meaningful consequences are necessary to protect tenants in general from such conduct.
The multiple areas of exposure favor early resolution, and I'm prepared to settle promptly. However, the resolution must reflect real accountability that serves the broader principle of protecting families from property management abuse.
Please confirm representation scope within 48 hours so we may proceed with appropriate service protocols.
Respectfully,
Chris McNeil & Meaghan Poyer Pro Se Plaintiffs Case No. 2025CP1005095 480A Parkdale Dr. Charleston, SC 29414 | 843-818-3495 (Chris mobile) Chris@thaut.io mcneilandpoyer@gmail.com
From: Eric Pettis Sent: Tuesday, September 9, 2025 10:17 PM To: chris thaut.io ; mcneilandpoyer@gmail.com Cc: Desja Wilder Subject: Notice of Representation- Meridian Residential Group, LLC - Demand Letters
Greetings Chris and Meaghan,
Please take notice that I am legal counsel for MERIDIAN RESIDENTIAL GROUP, LLC and have been retained to represent them in connection with your previous demands and allegations asserted against them. If you have in fact filed a civil action against my Client, I will accept service on their behalf upon receipt of the filed documents. Once I have reviewed this matter and any filings you have made, I will issue a response or file responsive pleadings as appropriate. Thank you. With sincere appreciation, Eric Pettis | Associate Licensed in PA and SC Mailing Address: P.O. Box 62975, N. Charleston, South Carolina 29419 Physical Address: 4000 Faber Place Drive, Suite 100, N. Charleston, South Carolina 29405 Firm: (843) 628-7120 | Direct Phone/Fax: (843) 213-6835 Email: epettis@bwpf-law.com Web: BWPF-Law.com The information in this email message is attorney privileged and confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this message is strictly prohibited. If you have received this message in error, please immediately notify the sender by email or by contacting our firm at the numbers listed above. The typewritten signature included with this email is not an electronic signature within the meaning of Electronic Signatures in the Global and National Commerce Act or any other law of similar import, including without limitation, the Uniform Electronic Transactions Act, as the same may be enacted in any State. Consumer Debt Collection Warning: To the extent any portion of this email relates to a consumer debt, please be advised that this email message is an attempt to collect a debt and any information provided may be used for that purpose.