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Supplemental Memorandum in Support of Plaintiffs' Opposition to Defendants' Motions and in Further Support of Systemic Valuation Anomalies

McNeil & Poyer v. SAC 181, LLC et al. — 2025-CP-10-05095

Document Overview

SC 9th Circuit Common Pleas Case number: 2025-CP-10-05095
Filing Date: December 11, 2025
Document: Supplemental Memorandum in Support of Plaintiffs' Opposition to Defendants' Motions and in Further Support of Systemic Valuation Anomalies
Document Type: Supplemental memorandum supporting Plaintiffs’ opposition to Defendants’ motions and seeking veil-piercing, judicial estoppel, and related relief based on alleged systemic valuation anomalies.
What's here: Argues that probate filings undervalued Charles Realty Company stock, that 181 Gordon Street was transferred to SAC 181, LLC in a same-day “flash transfer,” and that SAC 181 and Meridian allegedly commingled operations. Seeks to estop Defendants from valuing 181 Gordon Street above $251,000 and to apply unclean-hands principles.
Exhibits: 9 exhibits, including Altman estate inventories, deeds concerning 181 Gordon Street, Charles Realty property records, SAC 181 operating-account checks, Bees Ferry Shopping Center records, City Homeownership Initiative Commission records, and a probate settlement application.

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NameDescriptionTypeFiledDocket Seq.Documents
James C. McNeil Supplemental Memo in Support of Ptlff Opposition to Deft Mot Notice 12/11/2025 P1A30 Official copy
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Executive Summary

James C. McNeil and Meaghan Poyer, proceeding pro se, filed this supplemental memorandum supporting their opposition to defendants’ motions in their Charleston County Court of Common Pleas action against SAC 181, LLC, Meridian Residential Group, LLC, the Bayles defendants, and MRG Investing Company LLC. The plaintiffs assert newly discovered records show systemic asset undervaluation by the Altman family enterprise, including a roughly 95% decline in reported Charles Realty Company stock value between probate filings, allegedly to reduce taxes. They further contend that the same-day 2007 transfer of 181 Gordon Street to SAC 181, LLC for nominal consideration, and SAC 181 LLC operating account checks bearing Meridian’s address, show SAC 181 is an inadequately capitalized alter ego whose veil should be pierced. They ask the court to estop defendants from valuing 181 Gordon Street above $251,000, apply unclean-hands doctrine to bar equitable defenses, and grant other appropriate relief.

Legal Significance

This supplemental memorandum adds plaintiffs’ newly cited probate, deed, banking, and corporate records to support their opposition to defendants’ motions and to reinforce allegations of a unified Altman/Meridian enterprise. Plaintiffs contend that sharply inconsistent probate valuations of Charles Realty Company stock, together with the same-day 2007 transfer of 181 Gordon Street to SAC 181, LLC for nominal consideration, show asset undervaluation, sham capitalization, and use of SAC 181 as an alter ego or liability shield. It further puts at issue alleged operational commingling between SAC 181 and Meridian through checks bearing Meridian’s address, which plaintiffs argue supports veil piercing under Sturkie and defeats defendants’ claimed arm’s-length relationship. The filing seeks to judicially estop defendants from valuing 181 Gordon above $251,000, bar equitable defenses through unclean hands, and preserve a basis for reaching affiliated persons or entities beyond SAC 181.

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pending

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The official docket copy of this filing was stored by the clerk's scanner as 1-bit bitonal image encoding. Search engines, assistive technology and AI systems read that shelf. This page carries the filing as the author submitted it, the clerk's FILE stamp as an independent overlay, and the cryptographic tether that lets any reader confirm the two files are the same filing.

Parties in this Record

  • James C. McNeil (Filed by)
  • Charles S. Altman (ProposedDefendant)
  • Jonathan S. Altman (ProposedDefendant)
  • Kevin O'Brien (Counsel)
  • Phelps Dunbar LLP (Law Firm)
  • SAC 181, LLC (Defendant)