Document Overview
SC 9th Circuit Common Pleas Case number: 2025-CP-10-05095Filing Date: November 13, 2025
Document: Plaintiffs' Amended Response in Opposition to Defendant SAC 181 LLC's Motion for a Case Management Order Regarding the Use of "AI" and Incorporated Memorandum of Law
Document Type: Plaintiffs’ amended response opposing SAC 181 LLC’s motion for an AI-related case-management order, seeking denial, sanctions, pro se fees, and immediate discovery compliance.
Includes: Legal memorandum arguing that South Carolina’s Interim AI Policy creates no litigant disclosure or certification duty, Rule 11 already governs filing accuracy, and compelled disclosure of research tools would invade work product. Includes 7 exhibits: a litigation-and-alleged-obstruction timeline; two AI/marketing publications; the South Carolina Interim AI Policy; social-media activity charts; defense-counsel communications; and a pre-AI 2021 opposition filing offered to demonstrate Plaintiff’s prior litigation capability.
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| Name | Description | Type | Filed | Docket Seq. | Documents |
|---|
| James C. McNeil |
Amended Response in Opposition to Motion/Case Management Ord |
Notice |
11/13/2025 |
P1A20 |
Official copy
Restored copy
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1-bit bitonal image encodingRestoredfiled
Executive Summary
Plaintiffs James C. McNeil and Meaghan Poyer, proceeding pro se, filed an amended opposition to defendant SAC 181 LLC’s motion for a case-management order concerning use of AI. They argue that South Carolina’s Interim AI Policy applies primarily to judicial personnel and imposes no AI-use disclosure or certification duty on litigants beyond existing Rule 11 obligations to ensure accuracy and protect confidentiality.
Plaintiffs assert that SAC 181’s requested disclosure of research tools, prompts, and drafting methods would improperly invade protected work product and is a frivolous delay tactic intended to distract from overdue discovery responses.
They ask the court to deny SAC 181’s motion, impose sanctions and pro se-equivalent fees under S.C. Code § 15-36-10, and order SAC 181 to immediately comply with outstanding discovery.
Legal Significance
Plaintiffs oppose SAC 181’s request for a case-management order requiring disclosure or certification of AI use, arguing that South Carolina’s Interim AI Policy regulates judicial personnel rather than litigants and adds no duties beyond Rule 11’s existing accuracy certification. They assert that compelled disclosure of AI tools, prompts, research methods, and drafting workflows would invade protected work product and has no demonstrated connection to any inaccurate filing or substantive defense.
The response also puts at issue SAC 181’s discovery compliance and characterizes its AI motion as a delay and harassment tactic warranting sanctions under S.C. Code § 15-36-10, pro se fees, and an immediate order compelling overdue discovery.
Plaintiffs support their position with claimed
prior pre-AI litigation competence and evidence they contend shows a broader defense pattern of obstruction, intimidation, and efforts to discredit their pro se advocacy.
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Parties in this Record
- James C. McNeil (Filed by)
- Charles S. Altman (ProposedDefendant)
- Jonathan S. Altman (PotentialDefendant)
- Kevin O'Brien (Counsel)
- Meridian Residential Group, LLC (Defendant)
- Phelps Dunbar LLP (Law Firm)
- Resnick & Louis, P.C. (Law Firm)
- SAC 181, LLC (Defendant)