Scannergate

Caption and title (p. 1-1)

STATE OF SOUTH CAROLINA )
COUNTY OF CHARLESTON ) IN THE COURT OF COMMON
) PLEAS
) NINTH JUDICIAL CIRCUIT
James C. ("Chris") McNeil and ) Meaghan Poyer, ) Civil Action No. 2025-CP-W-05095 ) Plaintiffs, ) SYSTEMS ANALYSIS
) BRIEF IN AID
) OF JUDICIAL
v.
) EFFICIENCY
SAC 181, LLC, )
Meridian Residential Group, LLC, Adam W. Bayles, individually, ) Tara Bayles, individually, and ) MRG Investing Company LLC ) ) Defendants. )

Executive Summary (p. 1-1)

I. EXECUTIVE SUMMARY IN 2 TABLES
This filing serves the Court as a systems analysis, offered to accelerate judicial comprehension.
Complex cases become clear when viewed through the system dynamics that generate recurring
patterns. Plaintiff McNeil discovered these patterns by studying how Charleston's Housing Justice
System responds when its Most Vulnerable Member, the unrepresented tenant, asks for accountability ..
For expediency, you can see the general dynamics of the case with 2 tables.

Executive Summary in 2 Tables (p. 1-2)

I. EXECUTIVE SUMMARY IN 2 TABLES
This filing serves the Court as a systems analysis, offered to accelerate judicial comprehension. Complex cases become clear when viewed through the system dynamics that generate recurring patterns. Plaintiff McNeil discovered these patterns by studying how Charleston's Housing Justice System responds when its Most Vulnerable Member, the unrepresented tenant, asks for accountability .. For expediency, you can see the general dynamics of the case with 2 tables.
TABLE 1: DEFENSE RECENT FILINGS ANALYSIS
As Table 2 supports, you will find this pattern throughout defense filings. Defense Filing Word Count Words Acknowledging Core Evidence/Harms Signal/Noise Feb 9, 2026: SAC 181 Supplemental Addendum 2,967 0 0% Jan 20, 2026: MRG Motion to Stay Discovery 691 0 0%
TABLE 2: COORDINATED SILENCE ON DOCUMENTED
VIOLATIONS
This table is a summary subset; the pattern holds for every infraction. Defense counsel's coordinated, trauma-erasing framing reduces documented harms such as retaliatory eviction in a heat wave, and mass-syndicated intimate images without consent to silence. Zero acknowledgment..

Executive Summary in 2 Tables, pp. 1-2 (p. 1-2)

I. EXECUTIVE SUMMARY IN 2 TABLES
This filing serves the Court as a systems analysis, offered to accelerate judicial comprehension. Complex cases become clear when viewed through the system dynamics that generate recurring patterns. Plaintiff McNeil discovered these patterns by studying how Charleston's Housing Justice System responds when its Most Vulnerable Member, the unrepresented tenant, asks for accountability .. For expediency, you can see the general dynamics of the case with 2 tables.
TABLE 1: DEFENSE RECENT FILINGS ANALYSIS
As Table 2 supports, you will find this pattern throughout defense filings. Defense Filing Word Count Words Acknowledging Core Evidence/Harms Signal/Noise Feb 9, 2026: SAC 181 Supplemental Addendum 2,967 0 0% Jan 20, 2026: MRG Motion to Stay Discovery 691 0 0%
TABLE 2: COORDINATED SILENCE ON DOCUMENTED
VIOLATIONS
This table is a summary subset; the pattern holds for every infraction. Defense counsel's coordinated, trauma-erasing framing reduces documented harms such as retaliatory eviction in a heat wave, and mass-syndicated intimate images without consent to silence. Zero acknowledgment.. Infraction Evidence Exhibit(s) Originally Filed With Instances of Defense Engagement Days on Docket Postal Fraud / Forgery Exhibit F Series: F-1 (MeridianScanner20250905161321.pdf); F-2 (actual USPS envelope, Columbia postmark Sept 8–10) Motion for Leave to File 2AC (Oct 24, 2025) 0 163 Retaliatory Eviction Exhibit A (May 29 NTV); Exhibit B (May 23 safety proposal); Exhibit K (July 17 "why don't you want us here?"); Exhibit N (April–May legal misrepresentations) Complaint (Sept 9, 2025); Amended Complaint (Sept 15, 2025) 0 179 Privacy Violations — Stills & Matterport Exhibit C Series: 15–16 private still images syndicated across platforms under "inspection" pretext 3D interior tour showing disabled dog in diapers, plaintiff, business branding; "AI will remove the tenants" fraudulent inducement Motion for Leave (Oct 24, 2025) 0 133 Trust Account Violations Exhibit G Series: SAC 181 "OP" account (Meridian address, Tara signature, no trust/escrow designation); 4 violations SC § 40-57-136 Motion for Leave (Oct 24, 2025) 0 133 Witness Tampering /
LLR
Obstruction Exhibit L (AppFolio emails: Meridian instructed non-compliance with subpoena); Exhibit P (LLR File #2025-566 deadline Feb 20); Coordinated Quash Motions filed 42 days before deadline Plaintiffs' Opposition to Quash / Cross- Motion to Disqualify (Jan 14, 2026) 0 53 Institutional Gaslighting /
DARVO
Exhibit Q (Table of False Narrative Coordination: "single, simple claim regarding security deposit"); Exhibit H (Jan 27–29 DARVO: criminal notice mischaracterized as "threats"); Exhibit I (Clinical injury: PCL-5 76/80, gaslighting severity 79/80) Plaintiffs' Hearing Brief (Feb 9, 2026); Omnibus Brief (Feb 24, 2026) 0 26

Defense Recent Filings Analysis (p. 1-1)

TABLE 1: DEFENSE RECENT FILINGS ANALYSIS
As Table 2 supports, you will find this pattern throughout defense filings.
Defense Filing
Word
Count
Words Acknowledging Core
Evidence/Harms
Signal/Noise
Feb 9, 2026: SAC 181
Supplemental Addendum
2,967
0 0%
Jan 20, 2026: MRG Motion to
Stay Discovery
691
0 0%

Coordinated Silence on Documented Violations (p. 2-2)

Postal Fraud / Forgery Exhibit F Series: F-1 (MeridianScanner20250905161321.pdf); F-2 (actual USPS envelope, Columbia postmark Sept 8–10) Motion for Leave to File 2AC (Oct 24, 2025) 0 163 Retaliatory Eviction Exhibit A (May 29 NTV); Exhibit B (May 23 safety proposal); Exhibit K (July 17 "why don't you want us here?"); Exhibit N (April–May legal misrepresentations) Complaint (Sept 9, 2025); Amended Complaint (Sept 15, 2025) 0 179 Privacy Violations — Stills & Matterport Exhibit C Series: 15–16 private still images syndicated across platforms under "inspection" pretext 3D interior tour showing disabled dog in diapers, plaintiff, business branding; "AI will remove the tenants" fraudulent inducement Motion for Leave (Oct 24, 2025) 0 133 Trust Account Violations Exhibit G Series: SAC 181 "OP" account (Meridian address, Tara signature, no trust/escrow designation); 4 violations SC § 40-57-136 Motion for Leave (Oct 24, 2025) 0 133 Witness Tampering /
LLR
Obstruction Exhibit L (AppFolio emails: Meridian instructed non-compliance with subpoena); Exhibit P (LLR File #2025-566 deadline Feb 20); Coordinated Quash Motions filed 42 days before deadline Plaintiffs' Opposition to Quash / Cross- Motion to Disqualify (Jan 14, 2026) 0 53 Institutional Gaslighting /
DARVO
Exhibit Q (Table of False Narrative Coordination: "single, simple claim regarding security deposit"); Exhibit H (Jan 27–29 DARVO: criminal notice mischaracterized as "threats"); Exhibit I (Clinical injury: PCL-5 76/80, gaslighting severity 79/80) Plaintiffs' Hearing Brief (Feb 9, 2026); Omnibus Brief (Feb 24, 2026) 0 26

Court Supportive Stance, Consultant Frame, p. 3 (p. 3-3)

A. Court Supportive Stance, Consultant Frame As acknowledged in the Plaintiffs’ Brief in Advance of February 9, 2026 Scheduling Conference (filed Feb 10 2026), Plaintiff Chris McNeil’s intention is to honor the principles of justice and equity at the heart of the court and the legal profession as a supportive professional in adjacent and litigation-relevant fields. He has experience as an expert witness in high-tech communications cases as well as the skillset of a systems thinking and strategic communication-based litigation consultant. He began the case pro se as a system study and positive system intervention opportunity, intending to transition to a firm should the case grow past a certain complexity level. The case surpassed that complexity threshold months ago, and the transition to a values-aligned firm is actively underway.

Coordinated Silence on Documented Violations (p. 2-2)

TABLE 2: COORDINATED SILENCE ON DOCUMENTED
VIOLATIONS
This table is a summary subset; the pattern holds for every infraction. Defense counsel's coordinated,
trauma-erasing framing reduces documented harms such as retaliatory eviction in a heat wave, and
mass-syndicated intimate images without consent to silence. Zero acknowledgment..

Infraction Evidence Exhibit(s)
Originally
Filed With
Instances of
Defense
Engagement
Days
on
Docket

Postal Fraud
/ Forgery
Exhibit F Series: F-1
(MeridianScanner20250905161321.pdf); F-2
(actual USPS envelope, Columbia postmark
Sept 8–10)
Motion for
Leave to File
2AC (Oct 24,
2025)
0 163

Retaliatory
Eviction
Exhibit A (May 29 NTV); Exhibit B (May 23
safety proposal); Exhibit K (July 17 "why don't
you want us here?"); Exhibit N (April–May
legal misrepresentations)
Complaint
(Sept 9, 2025);
Amended
Complaint
(Sept 15,
2025)
0 179

Privacy
Violations —
Stills &
Matterport
Exhibit C Series: 15–16 private still images
syndicated across platforms under "inspection"
pretext 3D interior tour showing disabled dog
in diapers, plaintiff, business branding; "AI
will remove the tenants" fraudulent
inducement
Motion for
Leave (Oct 24,
2025)
0 133

Trust
Account
Violations
Exhibit G Series: SAC 181 "OP" account
(Meridian address, Tara signature, no
trust/escrow designation); 4 violations SC §
40-57-136
Motion for
Leave (Oct 24,
2025)
0 133

Witness
Tampering /
LLR
Obstruction
Exhibit L (AppFolio emails: Meridian
instructed non-compliance with subpoena);
Exhibit P (LLR File #2025-566 deadline Feb
20); Coordinated Quash Motions filed 42 days
before deadline
Plaintiffs'
Opposition to
Quash / Cross-
Motion to
Disqualify (Jan
14, 2026)
0 53

Institutional
Gaslighting /
DARVO
Exhibit Q (Table of False Narrative
Coordination: "single, simple claim regarding
security deposit"); Exhibit H (Jan 27–29
DARVO: criminal notice mischaracterized as
"threats"); Exhibit I (Clinical injury: PCL-5
76/80, gaslighting severity 79/80)
Plaintiffs'
Hearing
Brief (Feb
9, 2026);
Omnibus
Brief (Feb
24, 2026)
0 26

Court Supportive Stance, Consultant Frame (p. 3-3)

A. Court Supportive Stance, Consultant Frame As acknowledged in the Plaintiffs’ Brief in Advance of February 9, 2026 Scheduling Conference (filed Feb 10 2026), Plaintiff Chris McNeil’s intention is to honor the principles of justice and equity at the heart of the court and the legal profession as a supportive professional in adjacent and litigation-relevant fields. He has experience as an expert witness in high-tech communications cases as well as the skillset of a systems thinking and strategic communication-based litigation consultant. He began the case pro se as a system study and positive system intervention opportunity, intending to transition to a firm should the case grow past a certain complexity level. The case surpassed that complexity threshold months ago, and the transition to a values-aligned firm is actively underway.

Tragedy of the Common and Study Methodology, p. 3 (p. 3-3)

B. The Tragedy of the Common in Charleston, SC Common Pleas The institutional pattern we discovered of lawyers wasting system resources to abuse pro se plaintiffs models the same "Tragedy of the Commons" systems structure that set up the New England overfishing situation depicted in the movie "The Perfect Storm". The Perfect Storm was set up by the desperation created when a common stock is depleted by individual actors putting their interests ahead of the integrity of the whole system. Such as the court system. C. Study Methodology The data populating each level was gathered using:
1. The outside-in methodology of John Seddon's Vanguard Method, which studies systems from
the point of end-user demand. When applied to UK social housing in a study sponsored by the Office of the Deputy Prime Minister, this methodology produced documented efficiency gains, improved service performance, and higher tenant satisfaction across three pilot housing organizations (Davis & Bretherton, "Evaluating Systems Thinking in Housing," Journal of the Operational Research Society 58(12), 2007).
2. The aforementioned Most Vulnerable Member method popularized by shows like Undercover
Boss and effectively utilized by First Amendment Advocate Jeff Gray of Honor Your Oath.
3. The Audience Attunement “Listening” method of the Thaut Process of Strategic Thought
Leadership framework developed by Plaintiff Chris McNeil. This analyses language patterns in authentic conversations on a topic by the target audience. Audience analyzed included investors, property managers, and tenants. This method identifies unmet values and related stale mental models ripe for improvement.

Court Supportive Stance, Consultant Frame (p. 3-3)

A. Court Supportive Stance, Consultant Frame
As acknowledged in the Plaintiffs’ Brief in Advance of February 9, 2026 Scheduling Conference (filed
Feb 10 2026), Plaintiff Chris McNeil’s intention is to honor the principles of justice and equity at the
heart of the court and the legal profession as a supportive professional in adjacent and litigation-relevant
fields. He has experience as an expert witness in high-tech communications cases as well as the skillset
of a systems thinking and strategic communication-based litigation consultant.
He began the case pro se as a system study and positive system intervention opportunity, intending to
transition to a firm should the case grow past a certain complexity level. The case surpassed that
complexity threshold months ago, and the transition to a values-aligned firm is actively underway.

Tragedy of the Commons in Charleston Common Pleas (p. 3-3)

B. The Tragedy of the Common in Charleston, SC Common Pleas The institutional pattern we discovered of lawyers wasting system resources to abuse pro se plaintiffs models the same "Tragedy of the Commons" systems structure that set up the New England overfishing situation depicted in the movie "The Perfect Storm". The Perfect Storm was set up by the desperation created when a common stock is depleted by individual actors putting their interests ahead of the integrity of the whole system. Such as the court system.

Iceberg Model Analysis, pp. 4-5 (p. 4-5)

D. Iceberg Model Analysis This analysis employs the Iceberg Model (Meadows, Donella Meadows Project, Systems Thinking Resources) to move from the visible events of this case: each individual harm - downward through recurring patterns, enabling structures, and root mental models.
TABLE 3: THE ICEBERG MODEL OF HOUSING JUSTICE PER
SYSTEM STUDY OF MCNEIL V SAC 181, LLC
Iceberg Level How it Shows Up for this Case Events (Alleged) Institutionalized Bullying, Gaslighting, Misrepresentation, Exhaustion Tactics, Retaliation, Financial Exploitation, Dignity harm escalating to health harm. Patterns Escalation of harm in response to perceived vulnerable member (unrepresented tenant) asking for fairness, then justice. The higher-level the ask, the more the harm escalates. Willful blindness by the owners who fund the system. Harm via agents of a bad actor. Misuse of shared resources (court, insurance pool). Regulatory capture protects from accountability, further lowering standard of performance to the public Structures Hierarchical design where money flows down from owner to central agent, but tenant well-being feedback does not flow back up. Central agent funded by enabling owner delegates through additional agents. Such agents utilize the backed up state of the court system to evade judicial accountability long enough to further pollute it with frivolous filings designed to prevent the vulnerable from accessing justice. Opaque entity structures to make it difficult to identify owners and hold them accountable, closed-system management of such entities. In general, the system is designed to harm the powerless who ask it for fairness or justice, apparently to prevent them from accessing resources. Mental Models Core Mental Model Behind This: Passive Investing. The hidden assumption behind it: What most people really mean by that is Unconscious Abdication. As per Donella Meadows’ Places to Intervene in a System, paradigms are the highest level of system intervention. [Meadows, D. (1999). Leverage Points: Places to Intervene in a System. Hartland, VT: The Sustainability Institute] Changing policy, rules, feedback design, or even system purpose are lower-level interventions that cannot fully succeed if they are undermined by a faulty paradigm. And housing is undermined by such a faulty paradigm: The Core Pattern: Ask for Justice → Receive Escalating Harm The System Structure: "Tragedy of the Commons" applied to the court system itself The Root Cause: A mental model called "Unconscious Abdication" (passive investing without oversight) that treats housing as a mechanical extraction system rather than a social system where shelter anchors human life stories. In "On the Mismatch Between Systems and Their Models." Ackoff and Gharajedaghi formally classify systems into four types:
1. deterministic,
2. ecological,
3. animate, and
4. social systemic,
and argue explicitly that treating social systems (whose parts are choice-making people) with mechanical/deterministic models produces system failures. [Ackoff, R.L. & Gharajedaghi, J. (1996). "On the Mismatch Between Systems and Their Models." Systems Dynamics Review] Why This Matters to Judicial Efficiency: Understanding the system structure reveals why traditional case management approaches will likely fall short. Defense strategy exploits systemic brittleness. Each procedural motion compounds plaintiff harm while consuming Court resources.

The Tragedy of the Common in Charleston, SC Common Pleas (p. 3-3)

B. The Tragedy of the Common in Charleston, SC Common Pleas
The institutional pattern we discovered of lawyers wasting system resources to abuse pro se plaintiffs
models the same "Tragedy of the Commons" systems structure that set up the New England overfishing
situation depicted in the movie "The Perfect Storm".
The Perfect Storm was set up by the desperation created when a common stock is depleted by individual
actors putting their interests ahead of the integrity of the whole system. Such as the court system.

Study Methodology (p. 3-3)

C. Study Methodology The data populating each level was gathered using:
1. The outside-in methodology of John Seddon's Vanguard Method, which studies systems from
the point of end-user demand. When applied to UK social housing in a study sponsored by the Office of the Deputy Prime Minister, this methodology produced documented efficiency gains, improved service performance, and higher tenant satisfaction across three pilot housing organizations (Davis & Bretherton, "Evaluating Systems Thinking in Housing," Journal of the Operational Research Society 58(12), 2007).
2. The aforementioned Most Vulnerable Member method popularized by shows like Undercover
Boss and effectively utilized by First Amendment Advocate Jeff Gray of Honor Your Oath.
3. The Audience Attunement “Listening” method of the Thaut Process of Strategic Thought
Leadership framework developed by Plaintiff Chris McNeil. This analyses language patterns in authentic conversations on a topic by the target audience. Audience analyzed included investors, property managers, and tenants. This method identifies unmet values and related stale mental models ripe for improvement.

Master Index of Key Evidence—Part I, pp. 5-6 (p. 5-6)

III. MASTER INDEX OF KEY EVIDENCE
EXHIBITS
PART I: THE ORIGINS (Retaliatory Eviction, Privacy Invasion & Forgery) EXHIBIT A: Retaliatory Notice to Vacate (NTV) / Termination • May 29, 2025: Unprovoked "ghost" email containing NTV. • June 4, 2025: Email claiming false "owner renovations" pretext. • Attached: ntv_non_renewal_meaghan_poyer_052925.pdf EXHIBIT B: Safety/Lease Renewal (Protected Activity) • May 23, 2025: Good-faith Lease Renewal Proposal submitted by Plaintiffs (Triggers statutory retaliation protections). EXHIBIT C SERIES: Mass Privacy Invasion (Listings, Images, Matterport) • C-1: Initial public listing screenshots displaying occupied interior. • C-2: July 14, 2025: Transcribed call of agent "Addy" inducing consent via fraudulent "AI removal" promise. • C-3: Affidavit of Meaghan Poyer affirming lack of consent and misrepresentation. • C-4: Screenshots of the published intimate stills and Matterport virtual tour. EXHIBIT D: Evidence Preservation Demand • September 21, 2025: Formal Evidence Preservation Notice and Takedown Demand. EXHIBIT E: Consciousness of Guilt (Platform Swaps) • Evidence of subjects suddenly replacing unauthorized images with "COMING SOON" graphics and 404 errors shortly after receiving the Exhibit D Takedown Notice. EXHIBIT F SERIES: Deposit Forgery & Property Management Transition • F-1: "Meridian Scanner_20250905_161321.pdf" showing the falsified internal "EMAILED" stamp passed off as a USPS postmark. • F-2: Actual physical USPS envelope and checks showing the true, late September 8 postmark. • F-3: January 5, 2024 email regarding Property Management transition.

Study Methodology (p. 3-3)

C. Study Methodology
The data populating each level was gathered using:
1. The outside-in methodology of John Seddon's Vanguard Method, which studies systems from
the point of end-user demand. When applied to UK social housing in a study sponsored by the
Office of the Deputy Prime Minister, this methodology produced documented efficiency gains,
improved service performance, and higher tenant satisfaction across three pilot housing
organizations (Davis & Bretherton, "Evaluating Systems Thinking in Housing," Journal of the
Operational Research Society 58(12), 2007).
2. The aforementioned Most Vulnerable Member method popularized by shows like Undercover
Boss and effectively utilized by First Amendment Advocate Jeff Gray of Honor Your Oath.
3. The Audience Attunement “Listening” method of the Thaut Process of Strategic Thought
Leadership framework developed by Plaintiff Chris McNeil. This analyses language patterns in
authentic conversations on a topic by the target audience. Audience analyzed included investors,
property managers, and tenants. This method identifies unmet values and related stale mental
models ripe for improvement.

Iceberg Model Analysis (p. 4-5)

D. Iceberg Model Analysis This analysis employs the Iceberg Model (Meadows, Donella Meadows Project, Systems Thinking Resources) to move from the visible events of this case: each individual harm - downward through recurring patterns, enabling structures, and root mental models.
TABLE 3: THE ICEBERG MODEL OF HOUSING JUSTICE PER
SYSTEM STUDY OF MCNEIL V SAC 181, LLC
Iceberg Level How it Shows Up for this Case Events (Alleged) Institutionalized Bullying, Gaslighting, Misrepresentation, Exhaustion Tactics, Retaliation, Financial Exploitation, Dignity harm escalating to health harm. Patterns Escalation of harm in response to perceived vulnerable member (unrepresented tenant) asking for fairness, then justice. The higher-level the ask, the more the harm escalates. Willful blindness by the owners who fund the system. Harm via agents of a bad actor. Misuse of shared resources (court, insurance pool). Regulatory capture protects from accountability, further lowering standard of performance to the public Structures Hierarchical design where money flows down from owner to central agent, but tenant well-being feedback does not flow back up. Central agent funded by enabling owner delegates through additional agents. Such agents utilize the backed up state of the court system to evade judicial accountability long enough to further pollute it with frivolous filings designed to prevent the vulnerable from accessing justice. Opaque entity structures to make it difficult to identify owners and hold them accountable, closed-system management of such entities. In general, the system is designed to harm the powerless who ask it for fairness or justice, apparently to prevent them from accessing resources. Mental Models Core Mental Model Behind This: Passive Investing. The hidden assumption behind it: What most people really mean by that is Unconscious Abdication.

Master Index of Key Evidence—Part II, pp. 6-7 (p. 6-7)

PART II: THE ESCALATION (Harassment, Tampering, & Obstruction) EXHIBIT G: The Genesis of Gaslighting (Fraudulent Misrepresentation) • September 6, 2024: Email from PMIC Tara Bayles falsely claiming Co- Owner/Registered Agent Adam Bayles is merely in the "maintenance department," establishing the baseline strategy of reality-denial. EXHIBIT H: Coordinated DARVO & Lawfare (Harassment) • January 27-29, 2026: Coordinated emails from defense counsel (O'Brien, Bolyard, Tate) to court staff, deliberately misrepresenting a standard "Courtesy Notice" as a physical threat to inflict distress and exhaust the complainant. EXHIBIT I SERIES: The Psychological Injury (Criminal Harm) • I-1 & I-2: Affidavits of Meaghan Poyer (Nov 25, 2025 & Jan 29, 2026) detailing the severe disruption to daily life, business, and physical health. • I-3: The PCL-5 Clinical Score (76/80) documenting Severe PTSD resulting from the coordinated institutional gaslighting campaign. EXHIBIT J: Pattern Evidence • Public reviews detailing a historical pattern of similar predatory behavior by the subjects against other tenants. EXHIBIT K: Exposing the Pretext • July 17, 2025: Complainant's email asking "Why don’t you want us here?", directly challenging the fraudulent "renovations" excuse. EXHIBIT L: Witness Tampering & Obstruction (S.C. Code § 16-9-340) • January 9 & 12, 2026: Emails from AppFolio Legal compliance confirming Meridian formally instructed them to withhold subpoenaed evidence that was relevant to an active LLR regulatory investigation. EXHIBIT M SERIES: Corporate Shielding & Agency Admission • M-1: Alicia Bolyard’s October 16, 2025 email improperly attempting to block statutory communication with Registered Agent Adam Bayles. • M-2: Meridian's October 9, 2025 Answer/Crossclaim admitting agency and pointing fault at SAC 181 (an admission they suddenly dropped on January 15, 2026, to coordinate a cover-up). EXHIBIT N: Retaliation Narrative (Supporting Emails) • Chronology of low-level harassment and misrepresentations by agents (e.g., rigid inspection scheduling, legal misrepresentations regarding the lease by Stephanie Phillips, and failure to clarify suspicious documents). EXHIBIT O: Text Message Logs • SMS thread between complainant and Meridian Residential Group, LLC agents. EXHIBIT P SERIES: The Catalyst for Obstruction (LLR PMIC Investigation) • P-1: September 23, 2025: Formal LLR Complaint filed against Tara Bayles’ PMIC License for forgery, retaliation, and privacy violations. • P-2: October 2, 2025: LLR Investigator Assignment Letter confirming an active state investigation with a strict 150-day deadline (February 20, 2026), providing the direct motive for the extreme obstruction and DARVO tactics. EXHIBIT Q: Table of Evidence (False Narrative Coordination) • A chronological table demonstrating how legally adverse defense counsel (Bolyard, O'Brien, Tate) synchronously adopted identical false narratives across multiple filings. This proves a coordinated, institutional effort to minimize an 8-count fraud and privacy case to shield Tara Bayles from the LLR investigation.

Iceberg Model Analysis (p. 4-5)

D. Iceberg Model Analysis
This analysis employs the Iceberg Model (Meadows, Donella Meadows Project, Systems Thinking
Resources) to move from the visible events of this case: each individual harm - downward through
recurring patterns, enabling structures, and root mental models.

TABLE 3: THE ICEBERG MODEL OF HOUSING JUSTICE PER
SYSTEM STUDY OF MCNEIL V SAC 181, LLC

Iceberg
Level
How it Shows Up for this Case
Events
(Alleged) Institutionalized Bullying, Gaslighting, Misrepresentation, Exhaustion Tactics, Retaliation,
Financial Exploitation, Dignity harm escalating to health harm.
Patterns
Escalation of harm in response to perceived vulnerable member (unrepresented tenant) asking for
fairness, then justice. The higher-level the ask, the more the harm escalates. Willful blindness by the
owners who fund the system. Harm via agents of a bad actor. Misuse of shared resources (court,
insurance pool). Regulatory capture protects from accountability, further lowering standard of
performance to the public
Structures
Hierarchical design where money flows down from owner to central agent, but tenant well-being
feedback does not flow back up. Central agent funded by enabling owner delegates through
additional agents. Such agents utilize the backed up state of the court system to evade judicial
accountability long enough to further pollute it with frivolous filings designed to prevent the
vulnerable from accessing justice. Opaque entity structures to make it difficult to identify owners
and hold them accountable, closed-system management of such entities. In general, the system is
designed to harm the powerless who ask it for fairness or justice, apparently to prevent them
from accessing resources.
Mental
Models
Core Mental Model Behind This: Passive Investing.
The hidden assumption behind it: What most people really mean by that is Unconscious Abdication.
As per Donella Meadows’ Places to Intervene in a System, paradigms are the highest level of system
intervention. [Meadows, D. (1999). Leverage Points: Places to Intervene in a System. Hartland, VT:
The Sustainability Institute]
Changing policy, rules, feedback design, or even system purpose are lower-level interventions that
cannot fully succeed if they are undermined by a faulty paradigm.
And housing is undermined by such a faulty paradigm:
The Core Pattern: Ask for Justice → Receive Escalating Harm
The System Structure: "Tragedy of the Commons" applied to the court system itself
The Root Cause: A mental model called "Unconscious Abdication" (passive investing without
oversight) that treats housing as a mechanical extraction system rather than a social system where shelter
anchors human life stories.
In "On the Mismatch Between Systems and Their Models." Ackoff and Gharajedaghi formally classify
systems into four types:
1. deterministic,
2. ecological,
3. animate, and
4. social systemic,
and argue explicitly that treating social systems (whose parts are choice-making people) with
mechanical/deterministic models produces system failures. [Ackoff, R.L. & Gharajedaghi, J.
(1996). "On the Mismatch Between Systems and Their Models." Systems Dynamics Review]
Why This Matters to Judicial Efficiency: Understanding the system structure reveals why traditional
case management approaches will likely fall short. Defense strategy exploits systemic brittleness. Each
procedural motion compounds plaintiff harm while consuming Court resources.

Root Cause and Judicial-Efficiency Significance (p. 5-5)

The Root Cause: A mental model called "Unconscious Abdication" (passive investing without oversight) that treats housing as a mechanical extraction system rather than a social system where shelter anchors human life stories. In "On the Mismatch Between Systems and Their Models." Ackoff and Gharajedaghi formally classify systems into four types:
1. deterministic,
2. ecological,
3. animate, and
4. social systemic,
and argue explicitly that treating social systems (whose parts are choice-making people) with mechanical/deterministic models produces system failures. [Ackoff, R.L. & Gharajedaghi, J. (1996). "On the Mismatch Between Systems and Their Models." Systems Dynamics Review] Why This Matters to Judicial Efficiency: Understanding the system structure reveals why traditional case management approaches will likely fall short. Defense strategy exploits systemic brittleness. Each procedural motion compounds plaintiff harm while consuming Court resources.

Exhibit A—Notice to Vacate and Renovations Email, pp. 9-15 (p. 9-15)

EXHIBIT A
NTV / Termination

 NTV - Non-Renewal.pdf (May 29 “ghost” email with no message body or identifiable sender)  Re_ Lease Status and Rent Confirmation.pdf (Jun 4 email with “owner renovations” claim)  ntv_non_renewal_meaghan_poyer_052925.pdf (identical attachment from both of above emails) From: Meridian Residential Group To: chris thaut.io; mcneilandpoyer@gmail.com Subject: NTV - Non-Renewal Date: Thursday, May 29, 2025 9:15:34 AM Attachments: ntv_non_renewal_meaghan_poyer_052925.pdf No content. From: Assistant Manager To: chris thaut.io; Meridian Manager Cc: C&M McNeil Subject: Re: Lease Status and Rent Confirmation Date: Wednesday, June 4, 2025 3:29:29 PM Attachments: ntv_non_renewal_meaghan_poyer_052925.pdf Importance: High Good afternoon, Per the email sent on 5/29/2025 (shows it was opened), a Notice to Vacate 181 Gordon St by July 31, 2025 at 11:59pm. The owner has decided to do some renovations and you are asked to vacate the property at 181 Gordon St. Thank you for your time and attention to this matter. Please see attached Notice to Vacate. Dana DeVoe-Riddick Assistant Manager Meridian Residential Group 8310 Rivers Ave. Suite B North Charleston, SC 29406 Phone 834-996-4987 05/29/2025 Meaghan Poyer, James McNeil 181 Gordon St Charleston, SC 29403
NOTICE TO VACATE
To: Meaghan Poyer, James McNeil, and all others in possession. The purpose of this notice is to terminate your tenancy of the below-described premises on July 31, 2025, at 11:59 p.m. Per the terms of your lease agreement. The premises are situated in Charleston, County of Charleston County, state of South Carolina, designated by the number and street as: 181 Gordon St Charleston, 29403 If you fail to perform or otherwise comply, the owner/landlord will institute legal proceedings to recover rent, charges/fees, damages, and possession of said premises, which could result in a judgment against you, including costs and necessary disbursements together, with damages as allowed by law for such unlawful detention. If you fail to fulfill the terms of your obligations, the Landlord and/or Landlord's Agent can submit a negative credit report reflecting your credit to a credit report agency. Please note: you are required to pay rent for the entire notice period, even if vacating earlier than the required date. You are not to re-rent the property; refer all potential tenants to Meridian Residential Group _____________________________________ Agent: Tara Bayles Date: 05/29/2025 Meridian Residential Group 8310 Rivers Ave. Suite B North Charleston, SC 29406 Phone (843) 996-4987 www.meridianresidentialgroup.com

Exhibit B—Lease Renewal Proposal and Safety Requests, pp. 16-18 (p. 16-18)

EXHIBIT B
Safety/Lease Renewal (Protected Activity)

Good faith Lease Renewal Proposal from plaintiffs. From: chris thaut.io To: Meridian Manager; Assistant Manager Cc: C&M McNeil Subject: Lease Renewal Proposal and Term Adjustment Request Date: Friday, May 23, 2025 5:22:00 PM Dear Stephanie,

Thank you again for sharing the lease renewal options. We appreciate the opportunity to continue living at 181 Gordon Street and would like to renew under terms that reflect both the history of our tenancy and the condition of the property. We’ve outlined below a few important adjustments that would make the lease more workable and sustainable for us — grouped by category to simplify review.

Health & Safety Considerations AC/Heating duct cleaning: We ask that the ducts be professionally cleaned, as they have not been serviced during our tenancy and doing so would help ensure good air quality. Insulation safety: If not already done in the past, we would appreciate confirmation that the insulation has been checked for asbestos, given the age of the home. Windows and screens: Many of the windows are painted shut, and none currently have screens, which makes fresh air circulation difficult and limits safe ventilation. We ask that functional windows with screens be made available in each room.

Deferred or Previously Discussed Improvements Venetian blinds replacement: Many blinds remain broken or missing. We were told they would be replaced early in our tenancy, but that was postponed due to COVID and other circumstances. We request that blinds in disrepair be replaced for privacy and usability. Fence installation option: We’d like to retain the option to install a fence (at our expense) with prior written approval. This was discussed and verbally approved when we moved in, but never followed up on due to unexpected events.

Lease Term Flexibility 12-month lease with renewal or month-to-month conversion: We propose that the lease include a clause allowing us either to:
1. Renew for another year at the same terms, or
2. Automatically convert to month-to-month status under the same terms, unless either
party gives 60 days’ notice of change. Buyout option: We appreciate that the lease includes a buyout clause. We’d like to request that the fee be reduced to the equivalent of one month’s rent rather than two, as a reflection of our long-term tenancy and good payment history.

Pet Fee Fairness We paid a $400 pet fee upon move-in for two pets. We’ve remained at or below that number and ask that the original arrangement remain in effect. If a pet rent policy is being applied, we propose a balanced structure: $20/month only for additional pets beyond two, and only for pets over 5 pounds. This avoids applying charges to animals with minimal or no impact on the property. Otherwise, if we got an ant farm, that could run in the thousands per month.

Utilities The current lease includes landlord-paid water and sewer, and we request that this continue. However, we’re open to further discussion on this point as part of an overall agreement.

We’ve enjoyed living here and want to continue our tenancy with a few reasonable updates that reflect safety, fairness, and livability. Thank you for your time and consideration — we look forward to your response and continuing the conversation toward a positive resolution. Warm regards, Chris McNeil & Meaghan Poyer

Master Index of Key Evidence — Part I (p. 5-6)

III. MASTER INDEX OF KEY EVIDENCE
EXHIBITS
PART I: THE ORIGINS (Retaliatory Eviction, Privacy Invasion & Forgery)
EXHIBIT A: Retaliatory Notice to Vacate (NTV) / Termination
• May 29, 2025: Unprovoked "ghost" email containing NTV.
• June 4, 2025: Email claiming false "owner renovations" pretext.
• Attached: ntv_non_renewal_meaghan_poyer_052925.pdf
EXHIBIT B: Safety/Lease Renewal (Protected Activity)
• May 23, 2025: Good-faith Lease Renewal Proposal submitted by Plaintiffs (Triggers
statutory retaliation protections).
EXHIBIT C SERIES: Mass Privacy Invasion (Listings, Images, Matterport)
• C-1: Initial public listing screenshots displaying occupied interior.
• C-2: July 14, 2025: Transcribed call of agent "Addy" inducing consent via fraudulent
"AI removal" promise.
• C-3: Affidavit of Meaghan Poyer affirming lack of consent and misrepresentation.
• C-4: Screenshots of the published intimate stills and Matterport virtual tour.
EXHIBIT D: Evidence Preservation Demand
• September 21, 2025: Formal Evidence Preservation Notice and Takedown Demand.
EXHIBIT E: Consciousness of Guilt (Platform Swaps)
• Evidence of subjects suddenly replacing unauthorized images with "COMING
SOON" graphics and 404 errors shortly after receiving the Exhibit D Takedown
Notice.
EXHIBIT F SERIES: Deposit Forgery & Property Management Transition
• F-1: "Meridian Scanner_20250905_161321.pdf" showing the falsified internal
"EMAILED" stamp passed off as a USPS postmark.
• F-2: Actual physical USPS envelope and checks showing the true, late September 8
postmark.
• F-3: January 5, 2024 email regarding Property Management transition.

Master Index of Key Evidence (p. 5-8)

III. MASTER INDEX OF KEY EVIDENCE
EXHIBITS
PART I: THE ORIGINS (Retaliatory Eviction, Privacy Invasion & Forgery) EXHIBIT A: Retaliatory Notice to Vacate (NTV) / Termination • May 29, 2025: Unprovoked "ghost" email containing NTV. • June 4, 2025: Email claiming false "owner renovations" pretext. • Attached: ntv_non_renewal_meaghan_poyer_052925.pdf EXHIBIT B: Safety/Lease Renewal (Protected Activity) • May 23, 2025: Good-faith Lease Renewal Proposal submitted by Plaintiffs (Triggers statutory retaliation protections). EXHIBIT C SERIES: Mass Privacy Invasion (Listings, Images, Matterport) • C-1: Initial public listing screenshots displaying occupied interior. • C-2: July 14, 2025: Transcribed call of agent "Addy" inducing consent via fraudulent "AI removal" promise. • C-3: Affidavit of Meaghan Poyer affirming lack of consent and misrepresentation. • C-4: Screenshots of the published intimate stills and Matterport virtual tour. EXHIBIT D: Evidence Preservation Demand • September 21, 2025: Formal Evidence Preservation Notice and Takedown Demand. EXHIBIT E: Consciousness of Guilt (Platform Swaps) • Evidence of subjects suddenly replacing unauthorized images with "COMING SOON" graphics and 404 errors shortly after receiving the Exhibit D Takedown Notice. EXHIBIT F SERIES: Deposit Forgery & Property Management Transition • F-1: "Meridian Scanner_20250905_161321.pdf" showing the falsified internal "EMAILED" stamp passed off as a USPS postmark. • F-2: Actual physical USPS envelope and checks showing the true, late September 8 postmark. • F-3: January 5, 2024 email regarding Property Management transition. PART II: THE ESCALATION (Harassment, Tampering, & Obstruction) EXHIBIT G: The Genesis of Gaslighting (Fraudulent Misrepresentation) • September 6, 2024: Email from PMIC Tara Bayles falsely claiming Co- Owner/Registered Agent Adam Bayles is merely in the "maintenance department," establishing the baseline strategy of reality-denial. EXHIBIT H: Coordinated DARVO & Lawfare (Harassment) • January 27-29, 2026: Coordinated emails from defense counsel (O'Brien, Bolyard, Tate) to court staff, deliberately misrepresenting a standard "Courtesy Notice" as a physical threat to inflict distress and exhaust the complainant. EXHIBIT I SERIES: The Psychological Injury (Criminal Harm) • I-1 & I-2: Affidavits of Meaghan Poyer (Nov 25, 2025 & Jan 29, 2026) detailing the severe disruption to daily life, business, and physical health. • I-3: The PCL-5 Clinical Score (76/80) documenting Severe PTSD resulting from the coordinated institutional gaslighting campaign. EXHIBIT J: Pattern Evidence • Public reviews detailing a historical pattern of similar predatory behavior by the subjects against other tenants. EXHIBIT K: Exposing the Pretext • July 17, 2025: Complainant's email asking "Why don’t you want us here?", directly challenging the fraudulent "renovations" excuse. EXHIBIT L: Witness Tampering & Obstruction (S.C. Code § 16-9-340) • January 9 & 12, 2026: Emails from AppFolio Legal compliance confirming Meridian formally instructed them to withhold subpoenaed evidence that was relevant to an active LLR regulatory investigation. EXHIBIT M SERIES: Corporate Shielding & Agency Admission • M-1: Alicia Bolyard’s October 16, 2025 email improperly attempting to block statutory communication with Registered Agent Adam Bayles. • M-2: Meridian's October 9, 2025 Answer/Crossclaim admitting agency and pointing fault at SAC 181 (an admission they suddenly dropped on January 15, 2026, to coordinate a cover-up). EXHIBIT N: Retaliation Narrative (Supporting Emails) • Chronology of low-level harassment and misrepresentations by agents (e.g., rigid inspection scheduling, legal misrepresentations regarding the lease by Stephanie Phillips, and failure to clarify suspicious documents). EXHIBIT O: Text Message Logs • SMS thread between complainant and Meridian Residential Group, LLC agents. EXHIBIT P SERIES: The Catalyst for Obstruction (LLR PMIC Investigation) • P-1: September 23, 2025: Formal LLR Complaint filed against Tara Bayles’ PMIC License for forgery, retaliation, and privacy violations. • P-2: October 2, 2025: LLR Investigator Assignment Letter confirming an active state investigation with a strict 150-day deadline (February 20, 2026), providing the direct motive for the extreme obstruction and DARVO tactics. EXHIBIT Q: Table of Evidence (False Narrative Coordination) • A chronological table demonstrating how legally adverse defense counsel (Bolyard, O'Brien, Tate) synchronously adopted identical false narratives across multiple filings. This proves a coordinated, institutional effort to minimize an 8-count fraud and privacy case to shield Tara Bayles from the LLR investigation.

Exhibit C Series—Listings, Images, and Matterport, pp. 19-38 (p. 19-38)

EXHIBIT C Series Listings, Images, Matterport, Syndication

• Ex. C-1 — Initial public listing while occupied • Ex. C-2 - July 14 call between “Addy” and Meaghan on Matterport • Ex. C-3 - Affidavit of Meaghan Poyer (no consent for image use, misrepresentation) • Ex. C-4 - Screenshots and images of some of the published stills and the virtual tour Ex. C-3 - Affidavit of Meaghan Poyer

Describes misrepresentation of Matterport Tour by Addison Bayles: “AI will be used to remove you and your belongings” and lack of consent any images of Plaintiffs and their belongings to be posted online, including the still imagers from the earlier shoot by Meridian predecessor Roadstead that was done under the premise of an “inspection” . 3 images of Meaghan on Zillow (1 in mirror) https://www.zillow.com/homedetails/181-Gordon-St-Charleston-SC-29403/10909318_zpid/

Listing Realtor.com – used same Meridian watermarked images https://www.realtor.com/rentals/details/181-Gordon-St_Charleston_SC_29403_M59688-00267 Matterport Virtual tour https://discover.matterport.com/space/AiTQuLgqRQF They show Chris McNeil and Plaintiffs’ dog, Rocket in diapers in a “virtual tour” and “Presented by Meridian Residential Group”. Plaintiff’s company name is prominent on a sign. (time/date bottom right in first image)

Rocket is also seen in the hall 9/22/25 Sites with images and time/date stamps Matterport with timestamp 9/22/25, day before removal

Trulia 9/22/25 Ex. C-5 - Comparator listings (Meridian ads that do not show tenants). All other Meridian listings examined only show empty units or with staged furnishings. No other listings appear “lived in”.

Master Index of Key Evidence — Part II (p. 6-7)

PART II: THE ESCALATION (Harassment, Tampering, & Obstruction)
EXHIBIT G: The Genesis of Gaslighting (Fraudulent Misrepresentation)
• September 6, 2024: Email from PMIC Tara Bayles falsely claiming Co-
Owner/Registered Agent Adam Bayles is merely in the "maintenance department,"
establishing the baseline strategy of reality-denial.
EXHIBIT H: Coordinated DARVO & Lawfare (Harassment)
• January 27-29, 2026: Coordinated emails from defense counsel (O'Brien, Bolyard,
Tate) to court staff, deliberately misrepresenting a standard "Courtesy Notice" as a
physical threat to inflict distress and exhaust the complainant.
EXHIBIT I SERIES: The Psychological Injury (Criminal Harm)
• I-1 & I-2: Affidavits of Meaghan Poyer (Nov 25, 2025 & Jan 29, 2026) detailing the
severe disruption to daily life, business, and physical health.
• I-3: The PCL-5 Clinical Score (76/80) documenting Severe PTSD resulting from the
coordinated institutional gaslighting campaign.
EXHIBIT J: Pattern Evidence
• Public reviews detailing a historical pattern of similar predatory behavior by the
subjects against other tenants.
EXHIBIT K: Exposing the Pretext
• July 17, 2025: Complainant's email asking "Why don’t you want us here?", directly
challenging the fraudulent "renovations" excuse.
EXHIBIT L: Witness Tampering & Obstruction (S.C. Code § 16-9-340)
• January 9 & 12, 2026: Emails from AppFolio Legal compliance confirming Meridian
formally instructed them to withhold subpoenaed evidence that was relevant to an
active LLR regulatory investigation.
EXHIBIT M SERIES: Corporate Shielding & Agency Admission
• M-1: Alicia Bolyard’s October 16, 2025 email improperly attempting to block
statutory communication with Registered Agent Adam Bayles.
• M-2: Meridian's October 9, 2025 Answer/Crossclaim admitting agency and pointing
fault at SAC 181 (an admission they suddenly dropped on January 15, 2026, to
coordinate a cover-up).
EXHIBIT N: Retaliation Narrative (Supporting Emails)
• Chronology of low-level harassment and misrepresentations by agents (e.g., rigid
inspection scheduling, legal misrepresentations regarding the lease by Stephanie
Phillips, and failure to clarify suspicious documents).
EXHIBIT O: Text Message Logs
• SMS thread between complainant and Meridian Residential Group, LLC agents.
EXHIBIT P SERIES: The Catalyst for Obstruction (LLR PMIC Investigation)
• P-1: September 23, 2025: Formal LLR Complaint filed against Tara Bayles’ PMIC
License for forgery, retaliation, and privacy violations.
• P-2: October 2, 2025: LLR Investigator Assignment Letter confirming an active state
investigation with a strict 150-day deadline (February 20, 2026), providing the direct
motive for the extreme obstruction and DARVO tactics.
EXHIBIT Q: Table of Evidence (False Narrative Coordination)
• A chronological table demonstrating how legally adverse defense counsel (Bolyard,
O'Brien, Tate) synchronously adopted identical false narratives across multiple filings.
This proves a coordinated, institutional effort to minimize an 8-count fraud and
privacy case to shield Tara Bayles from the LLR investigation.

Signature Block (p. 8-8)

Respectfully submitted this 6 th day of March, 2026. James C. (“Chris”) McNeil, Pro Se P.O. Box 30386, Charleston, SC 29417 chris@thaut.io Meaghan Poyer, Pro Se P.O. Box 30386, Charleston, SC 29417 mcneilandpoyer@gmail.com

Exhibit D—Evidence Preservation Notice, pp. 41-45 (p. 41-45)

From: chris thaut.io To: Eric Pettis; mcneilandpoyer@gmail.com Cc: Desja Wilder Subject: URGENT - Evidence Preservation Notice - McNeil & Poyer v. SAC 181, LLC, et al. (Case No. 2025-CP-10-05095) Date: Sunday, September 21, 2025 11:14:00 AM Importance: High Sensitivity: Confidential Mr. Pettis,

This constitutes formal notice of your clients' duty to preserve evidence under South Carolina Rules of Civil Procedure in connection with systematic privacy violations, fraudulent conduct, and newly discovered safety endangerment arising from unauthorized commercial exploitation of our family's images and personal information.

JUSTIFICATION FOR WEEKEND NOTICE
This notice is sent on Sunday due to:

Ongoing Privacy Violations: Images of my family remain published across multiple commercial platforms without consent, causing continuing damages each day Safety Concerns: Unauthorized publication of our residential address and personal images creates ongoing security risks as Plaintiffs have documented harassment history from family members requiring restraining orders and no-contact protocols. Public court documents now create searchable connections between the published address and our current location, potentially enabling continued harassment and requiring court-ordered address protection measures. Evidence Destruction Risk: Delay until business hours provides opportunity for coordinated evidence destruction or modification False Endorsement/Personal Defamation: Meridian watermarks and 'Presented by Meridian Residential Group' branding falsely associate Plaintiffs with a company they are actively suing for systematic misconduct. This creates the damaging impression that Plaintiffs endorse or affiliate with an organization documented for tenant exploitation and fraudulent practices, directly harming their personal character, integrity, and reputation. The forced association causes ongoing personal and professional damage. Duty to Mitigate: Plaintiffs have a legal obligation to mitigate ongoing damages by taking immediate action to preserve evidence and halt continuing violations

PRESERVATION REQUIREMENTS
This includes all photographs, video, and Matterport imagery originally obtained or generated by Roadstead Residential Property Management prior to Meridian’s acquisition of that portfolio, as well as any files carried over, imported, or repurposed by Meridian or its affiliates. Defendants remain responsible for preserving those materials to the extent they assumed control or benefited from them.

Your clients must immediately preserve all documents, communications, electronic files, and physical materials related to:

1. Photography and Image Usage (2020-Present)
All photographs, videos, and virtual tours of 181 Gordon Street All versions of images containing Plaintiffs, their belongings, pets, or business signage Metadata and EXIF data for all images Original source files (RAW, JPEG, TIFF, Matterport cloud data), not merely exported copies Matterport dashboard access, accounts, and administrative controls All contracts with photographers, marketing vendors, or platform services

2. Platform Publications and Marketing
All accounts, credentials, and administrative access for: Zillow, Realtor.com, Trulia, Matterport, ApartmentHomeLiving, and any other real estate or rental platforms All communications with platform representatives regarding image uploads, modifications, or takedown requests All marketing materials, brochures, or advertisements featuring the property

3. Internal Communications
All emails, text messages, phone records, and internal communications between Meridian, SAC 181, MRG Investing, the Bayleses, and any third parties regarding: Photography or marketing of 181 Gordon Street Tenant privacy or consent for image usage Platform management or image publication This litigation or the underlying tenant relationship

4. Corporate Documentation
All documents evidencing corporate relationships, shared operations, or unified management between defendants All financial records showing asset transfers, shared expenses, or commingled funds All professional licenses, insurance policies, and regulatory filings

ESCALATION CONSEQUENCES
Injunctive Relief: Failure to immediately cease unauthorized image usage will result in emergency motion for temporary restraining order and preliminary injunction, with defendants bearing all associated costs. Regulatory Exposure: Continued violations may trigger complaints to the South Carolina Real Estate Commission regarding systematic tenant exploitation and professional misconduct. Expanded Liability: This preservation notice covers initial evidence categories. Additional preservation requirements will follow as our investigation expands into the full scope of defendants' business practices.

IMMEDIATE ACTION REQUIRED
1. Document Retention: Issue litigation hold notices to all employees, contractors, and
affiliates
2. Platform Preservation: Secure all online accounts and prevent any modifications or
deletions
3. Third-Party Notice: Notify all vendors, photographers, and service providers of
preservation duties
4. Compliance Confirmation: Provide written confirmation of preservation measures by
Monday, September 22, 2025, 5:00 PM

TAKEDOWN NOTICE COORDINATION
Plaintiffs will be submitting takedown notices to all identified platforms today and tomorrow citing privacy violations and lack of consent. Your clients should coordinate with these platforms to ensure preservation of all materials before any removal occurs.

SPOLIATION CONSEQUENCES
Failure to preserve evidence may result in: Adverse inference instructions to the jury Sanctions under SCRCP Rule 37 Independent claims for obstruction of justice under S.C. Code § 16-9-340 Enhanced punitive damages for destruction of evidence Violation of Rule 37(b) (failure to comply with court order) and Rule 37(e) (ESI destruction)

ONGOING DAMAGES
Resolution Path: Immediate compliance with preservation duties and cessation of unauthorized image usage represents the most efficient path to resolution. All other paths lead to expanded litigation, regulatory scrutiny, and increased liability.

Plaintiffs will be actively monitoring all platforms and preservation compliance. Any modifications, deletions, or access restrictions will be immediately detected and reported to the court.

Please confirm receipt of this notice and your clients' compliance measures within 24 hours.

Respectfully,

James C. ("Chris") McNeil and Meaghan Poyer Pro Se Plaintiffs

Exhibit A - NTV / Termination (p. 9-15)

EXHIBIT A
NTV / Termination

 NTV - Non-Renewal.pdf (May 29 “ghost” email with no message body or identifiable sender)  Re_ Lease Status and Rent Confirmation.pdf (Jun 4 email with “owner renovations” claim)  ntv_non_renewal_meaghan_poyer_052925.pdf (identical attachment from both of above emails)

Notice to Vacate and Renovations Email (p. 10-15)

From: Meridian Residential Group
To: chris thaut.io; mcneilandpoyer@gmail.com
Subject: NTV - Non-Renewal
Date: Thursday, May 29, 2025 9:15:34 AM
Attachments: ntv_non_renewal_meaghan_poyer_052925.pdf
No content.

From: Assistant Manager
To: chris thaut.io; Meridian Manager
Cc: C&M McNeil
Subject: Re: Lease Status and Rent Confirmation
Date: Wednesday, June 4, 2025 3:29:29 PM
Attachments: ntv_non_renewal_meaghan_poyer_052925.pdf
Importance: High
Good afternoon,
Per the email sent on 5/29/2025 (shows it was opened), a Notice to Vacate 181 Gordon
St by July 31, 2025 at 11:59pm.
The owner has decided to do some renovations and you are asked to vacate the property
at 181 Gordon St.
Thank you for your time and attention to this matter. Please see attached Notice to
Vacate.
Dana DeVoe-Riddick
Assistant Manager
Meridian Residential Group
8310 Rivers Ave. Suite B
North Charleston, SC 29406
Phone 834-996-4987

05/29/2025
Meaghan Poyer, James McNeil
181 Gordon St
Charleston, SC 29403
NOTICE TO VACATE
To: Meaghan Poyer, James McNeil, and all others in possession.
The purpose of this notice is to terminate your tenancy of the below-described premises on
July 31, 2025, at 11:59 p.m. Per the terms of your lease agreement.
The premises are situated in Charleston, County of Charleston County, state of South
Carolina, designated by the number and street as:
181 Gordon St Charleston, 29403
If you fail to perform or otherwise comply, the owner/landlord will institute legal proceedings to
recover rent, charges/fees, damages, and possession of said premises, which could result in a
judgment against you, including costs and necessary disbursements together, with damages as
allowed by law for such unlawful detention. If you fail to fulfill the terms of your obligations, the
Landlord and/or Landlord's Agent can submit a negative credit report reflecting your credit to a
credit report agency.
Please note: you are required to pay rent for the entire notice period, even if vacating earlier
than the required date. You are not to re-rent the property; refer all potential tenants to Meridian
Residential Group
_____________________________________
Agent: Tara Bayles
Date: 05/29/2025
Meridian Residential Group
8310 Rivers Ave. Suite B
North Charleston, SC 29406
Phone (843) 996-4987
www.meridianresidentialgroup.com

June 4, 2025 renovations email (p. 11-11)

From: Assistant Manager To: chris thaut.io; Meridian Manager Cc: C&M McNeil Subject: Re: Lease Status and Rent Confirmation Date: Wednesday, June 4, 2025 3:29:29 PM Attachments: ntv_non_renewal_meaghan_poyer_052925.pdf Importance: High Good afternoon, Per the email sent on 5/29/2025 (shows it was opened), a Notice to Vacate 181 Gordon St by July 31, 2025 at 11:59pm. The owner has decided to do some renovations and you are asked to vacate the property at 181 Gordon St. Thank you for your time and attention to this matter. Please see attached Notice to Vacate. Dana DeVoe-Riddick Assistant Manager Meridian Residential Group 8310 Rivers Ave. Suite B North Charleston, SC 29406 Phone 834-996-4987

Exhibit E—Platform Swaps, Overlays, and Removals, pp. 55-60 (p. 55-60)

EXHIBIT E
Platform swaps/overlays/removals (e.g., “COMING SOON,” 404 on tour) Timestamped screenshots taken on 9/26/25, after discovering more sites with the same ad. padhopper

Zumper (1) Zumper (2)

Rent.com Clemsonoffcampus.com

Apartmenthomeliving.com Forrent.com

Showmojo.com

For the sake of brevity, not including all sites or all screenshots in exhibit Matterport (virtual tour removed)

15 Sites found with the 181 Gordon St. ad as of October 5, 2025 + 1 Virtual Tour (Matterport) = 16 sites so-far identified*
*And there are likely more, given AppFolio/ShowMojo syndication fingerprints and
ShowMojo’s claim of distribution over 50+ sites Sites identified with ~16 still images (with Meaghan, belongings, bathroom, bedroom) or identified with replacement ad after original ad removal zillow, trulia, realtor.com, apartments.com, apartmentfinder.com, forrent.com, rent.com, clemsonoffcampus.com, PadMapper, Zumper, meridianresidentialgroup.com, showmetherent.com, HotPads.com, RentalSource.com, Showmojo.com

Matterport Virtual Tour (with Chris, Rocket in diapers, Thaut Thought Leadership sign) Matterport & everywhere the virtual tour was embedded or downloaded

Exhibit B - Safety/Lease Renewal (p. 16-18)

EXHIBIT B
Safety/Lease Renewal (Protected Activity)

Good faith Lease Renewal Proposal from plaintiffs.

Safety and Lease Renewal Proposal (p. 17-18)

From: chris thaut.io
To: Meridian Manager; Assistant Manager
Cc: C&M McNeil
Subject: Lease Renewal Proposal and Term Adjustment Request
Date: Friday, May 23, 2025 5:22:00 PM
Dear Stephanie,

Thank you again for sharing the lease renewal options.
We appreciate the opportunity to continue living at 181 Gordon Street and would like to renew
under terms that reflect both the history of our tenancy and the condition of the property.
We’ve outlined below a few important adjustments that would make the lease more workable and
sustainable for us — grouped by category to simplify review.

Health & Safety Considerations
AC/Heating duct cleaning: We ask that the ducts be professionally cleaned, as they have not
been serviced during our tenancy and doing so would help ensure good air quality.
Insulation safety: If not already done in the past, we would appreciate confirmation that the
insulation has been checked for asbestos, given the age of the home.
Windows and screens: Many of the windows are painted shut, and none currently have
screens, which makes fresh air circulation difficult and limits safe ventilation. We ask that
functional windows with screens be made available in each room.

Deferred or Previously Discussed Improvements
Venetian blinds replacement: Many blinds remain broken or missing. We were told they
would be replaced early in our tenancy, but that was postponed due to COVID and other
circumstances. We request that blinds in disrepair be replaced for privacy and usability.
Fence installation option: We’d like to retain the option to install a fence (at our expense)
with prior written approval. This was discussed and verbally approved when we moved in, but
never followed up on due to unexpected events.

Lease Term Flexibility
12-month lease with renewal or month-to-month conversion: We propose that the lease
include a clause allowing us either to:
1. Renew for another year at the same terms, or
2. Automatically convert to month-to-month status under the same terms, unless either
party gives 60 days’ notice of change.
Buyout option: We appreciate that the lease includes a buyout clause. We’d like to request
that the fee be reduced to the equivalent of one month’s rent rather than two, as a reflection
of our long-term tenancy and good payment history.

Pet Fee Fairness
We paid a $400 pet fee upon move-in for two pets. We’ve remained at or below that number
and ask that the original arrangement remain in effect.
If a pet rent policy is being applied, we propose a balanced structure: $20/month only for
additional pets beyond two, and only for pets over 5 pounds. This avoids applying charges
to animals with minimal or no impact on the property. Otherwise, if we got an ant farm, that
could run in the thousands per month.

Utilities
The current lease includes landlord-paid water and sewer, and we request that this continue.
However, we’re open to further discussion on this point as part of an overall agreement.

We’ve enjoyed living here and want to continue our tenancy with a few reasonable updates that
reflect safety, fairness, and livability. Thank you for your time and consideration — we look forward
to your response and continuing the conversation toward a positive resolution.
Warm regards,
Chris McNeil & Meaghan Poyer

Exhibit F Series—Deposit/Postmark and Management Transition, pp. 61-68 (p. 61-68)

EXHIBIT F Series Deposit / Postmark / Property Management Company Change

• Ex. F-1 - Meridian scanner PDF image • Ex. F-2 - Actual USPS envelope + checks showing 9/8 postmark • Ex. F-3 - Jan 5, 2024 Property Management transition email (“owner is fully aware… effective Dec 27, 2023”) Ex. F-1 - Meridian scanner PDF image

• September 5, 2025 email from Tara Bayles, attached “Meridian Scanner_20250905_161321.pdf”, • file name evidencing scan time of 4:13:21 PM on September 5, 2025 (using military time,
“16” = “4PM”)
• Irreconcilable difference between the scanner’s date and the mailing narrative • Meridian Scanner_20250905_161321.pdf following Ex. F-2 - Actual USPS envelope + checks showing 9/8 postmark Actual USPS Envelope and Checks Received September 10
- Shows legitimate September 8 postmark, contrast with “emailed” “postmark” in F-1
- Same check numbers as Exhibit F-1 - Proves timeline impossibility
Ex. F-3 - Jan 5, 2024 Property Management transition email (“owner is fully aware… effective Dec 27, 2023”) 01/05/2024 Meaghan Poyer, James McNeil 181 Gordon St Charleston, SC 29403 RE: New Management Dear Meaghan, James, This is to inform you that management for your residence has transferred from Roadstead Management due to an acquisi�on of the management company. The property owner is fully aware of this change and became e ffec�ve December 27, 2023.

Listings, Images, Matterport and Syndication (p. 19-38)

EXHIBIT C Series
Listings, Images, Matterport, Syndication

• Ex. C-1 — Initial public listing while occupied
• Ex. C-2 - July 14 call between “Addy” and Meaghan on Matterport
• Ex. C-3 - Affidavit of Meaghan Poyer (no consent for image use, misrepresentation)
• Ex. C-4 - Screenshots and images of some of the published stills and the virtual tour

Ex. C-3 - Affidavit of Meaghan Poyer

Describes misrepresentation of Matterport Tour by Addison Bayles: “AI will be used to remove
you and your belongings” and lack of consent any images of Plaintiffs and their belongings to be
posted online, including the still imagers from the earlier shoot by Meridian predecessor
Roadstead that was done under the premise of an “inspection” .

Ex. C-4 - Screenshots and images of some of the published stills and the virtual tour

3 images of Meaghan on Zillow (1 in mirror)
https://www.zillow.com/homedetails/181-Gordon-St-Charleston-SC-29403/10909318_zpid/

Realtor.com – used same Meridian watermarked images
https://www.realtor.com/rentals/details/181-Gordon-St_Charleston_SC_29403_M59688-00267

Matterport Virtual tour
https://discover.matterport.com/space/AiTQuLgqRQF
They show Chris McNeil and Plaintiffs’ dog, Rocket in diapers in a “virtual tour” and “Presented
by Meridian Residential Group”. Plaintiff’s company name is prominent on a sign. (time/date
bottom right in first image)

Rocket is also seen in the hall

9/22/25 Sites with images and time/date stamps
Matterport with timestamp 9/22/25, day before removal

Ex. C-5 - Comparator listings (Meridian ads that do not show tenants).

All other Meridian listings examined only show empty units or with staged furnishings. No other
listings appear “lived in”.

Exhibit C Series - Listings, Images, Matterport, Syndication (p. 19-38)

EXHIBIT C Series Listings, Images, Matterport, Syndication

• Ex. C-1 — Initial public listing while occupied • Ex. C-2 - July 14 call between “Addy” and Meaghan on Matterport • Ex. C-3 - Affidavit of Meaghan Poyer (no consent for image use, misrepresentation) • Ex. C-4 - Screenshots and images of some of the published stills and the virtual tour

Exhibit G—Adam Bayles Role Obfuscation, pp. 69-73 (p. 69-73)

EXHIBIT G
Baseline Intent to Deceive through Fraudulent Misrepresentation 9/6/2024 Adam Bayles Role Obfuscation Document: Email from Tara Bayles to Chris McNeil, dated September 6, 2024, alongside corroborating public records (Meridian website bio and LinkedIn profile).

The Deception: In the following email, Property Manager Tara Bayles explicitly instructs the complainant not to contact Adam Bayles regarding lease or account issues, falsely claiming: "Adam works in our maintenance department."

The Reality: Adam Bayles is not a maintenance worker. As proven by Meridian's own website and his professional profiles, Adam Bayles is the Co-Owner of Meridian Residential Group, leads business development, and serves as the statutorily designated Registered Agent for the affiliated ownership entity (MRG Investing Company, LLC).

Investigative Significance (Why This Matters): In criminal harassment (S.C. Code 16-3-1700), investigators must establish intent. This document serves as the genesis point for the subjects' pattern of psychological abuse. It proves that the subjects did not just make administrative errors; they operated from a calculated baseline of reality-denial.

By actively falsifying the corporate structure and the identities of the company's owners to disempower a tenant, the subjects established a deliberate strategy of gaslighting and misrepresentation that would later escalate into retaliatory eviction, postal forgery, and mass privacy violations. Adam Bayles is the co-owner of Meridian Residential Group, where he leads business development and operational management with a focus on growth and efficiency. Originally from North Carolina, Adam has called Charleston home for over a decade, embracing the city’s vibrant culture and community. After a four-year service in the U.S. Army, Adam pursued a bachelor’s degree in political science from Texas A&M University. He went on to build a successful 15-year career with Ecolab, where he gained extensive experience in sales and management. In his current role at Meridian, Adam channels his entrepreneurial spirit and passion for real estate into purchasing and rehabilitating investment properties. He’s also earned his real estate license, further solidifying his commitment to the industry. With a blend of military discipline, business acumen, and a love for Charleston’s architecture, Adam continues to drive success and innovation at Meridian Residential Group.

Matterport Virtual Tour Description (p. 35-35)

Matterport Virtual tour https://discover.matterport.com/space/AiTQuLgqRQF They show Chris McNeil and Plaintiffs’ dog, Rocket in diapers in a “virtual tour” and “Presented by Meridian Residential Group”. Plaintiff’s company name is prominent on a sign. (time/date bottom right in first image)

Rocket is also seen in the hall

Evidence Preservation Notice and Takedown Demands (p. 42-54)

From: chris thaut.io
To: Eric Pettis; mcneilandpoyer@gmail.com
Cc: Desja Wilder
Subject: URGENT - Evidence Preservation Notice - McNeil & Poyer v. SAC 181, LLC, et al. (Case No. 2025-CP-10-05095)
Date: Sunday, September 21, 2025 11:14:00 AM
Importance: High
Sensitivity: Confidential
Mr. Pettis,

This constitutes formal notice of your clients' duty to preserve evidence under South Carolina
Rules of Civil Procedure in connection with systematic privacy violations, fraudulent
conduct, and newly discovered safety endangerment arising from unauthorized
commercial exploitation of our family's images and personal information.

JUSTIFICATION FOR WEEKEND NOTICE
This notice is sent on Sunday due to:

Ongoing Privacy Violations: Images of my family remain published across multiple
commercial platforms without consent, causing continuing damages each day
Safety Concerns: Unauthorized publication of our residential address and personal
images creates ongoing security risks as Plaintiffs have documented harassment history
from family members requiring restraining orders and no-contact protocols. Public court
documents now create searchable connections between the published address and our
current location, potentially enabling continued harassment and requiring court-ordered
address protection measures.
Evidence Destruction Risk: Delay until business hours provides opportunity for
coordinated evidence destruction or modification
False Endorsement/Personal Defamation: Meridian watermarks and 'Presented by
Meridian Residential Group' branding falsely associate Plaintiffs with a company they are
actively suing for systematic misconduct. This creates the damaging impression that
Plaintiffs endorse or affiliate with an organization documented for tenant exploitation
and fraudulent practices, directly harming their personal character, integrity, and
reputation. The forced association causes ongoing personal and professional damage.
Duty to Mitigate: Plaintiffs have a legal obligation to mitigate ongoing damages by
taking immediate action to preserve evidence and halt continuing violations

PRESERVATION REQUIREMENTS
This includes all photographs, video, and Matterport imagery originally obtained or generated
by Roadstead Residential Property Management prior to Meridian’s acquisition of that
portfolio, as well as any files carried over, imported, or repurposed by Meridian or its affiliates.
Defendants remain responsible for preserving those materials to the extent they assumed
control or benefited from them.

Your clients must immediately preserve all documents, communications, electronic files, and
physical materials related to:

1. Photography and Image Usage (2020-Present)
All photographs, videos, and virtual tours of 181 Gordon Street
All versions of images containing Plaintiffs, their belongings, pets, or business signage
Metadata and EXIF data for all images
Original source files (RAW, JPEG, TIFF, Matterport cloud data), not merely exported
copies
Matterport dashboard access, accounts, and administrative controls
All contracts with photographers, marketing vendors, or platform services

2. Platform Publications and Marketing
All accounts, credentials, and administrative access for: Zillow, Realtor.com, Trulia,
Matterport, ApartmentHomeLiving, and any other real estate or rental platforms
All communications with platform representatives regarding image uploads,
modifications, or takedown requests
All marketing materials, brochures, or advertisements featuring the property

3. Internal Communications
All emails, text messages, phone records, and internal communications between
Meridian, SAC 181, MRG Investing, the Bayleses, and any third parties regarding:
Photography or marketing of 181 Gordon Street
Tenant privacy or consent for image usage
Platform management or image publication
This litigation or the underlying tenant relationship

4. Corporate Documentation
All documents evidencing corporate relationships, shared operations, or unified
management between defendants
All financial records showing asset transfers, shared expenses, or commingled funds
All professional licenses, insurance policies, and regulatory filings

IMMEDIATE ACTION REQUIRED
1. Document Retention: Issue litigation hold notices to all employees, contractors, and
affiliates
2. Platform Preservation: Secure all online accounts and prevent any modifications or
deletions
3. Third-Party Notice: Notify all vendors, photographers, and service providers of
preservation duties
4. Compliance Confirmation: Provide written confirmation of preservation measures by
Monday, September 22, 2025, 5:00 PM

TAKEDOWN NOTICE COORDINATION
Plaintiffs will be submitting takedown notices to all identified platforms today and tomorrow
citing privacy violations and lack of consent. Your clients should coordinate with these
platforms to ensure preservation of all materials before any removal occurs.

SPOLIATION CONSEQUENCES
Failure to preserve evidence may result in:
Adverse inference instructions to the jury
Sanctions under SCRCP Rule 37
Independent claims for obstruction of justice under S.C. Code § 16-9-340
Enhanced punitive damages for destruction of evidence
Violation of Rule 37(b) (failure to comply with court order) and Rule 37(e) (ESI
destruction)

Please confirm receipt of this notice and your clients' compliance measures within 24 hours.

Respectfully,

James C. ("Chris") McNeil and Meaghan Poyer
Pro Se Plaintiffs
480A Parkdale Dr.
Charleston, SC 29414
chris@thaut.io | mcneilandpoyer@gmail.com
Case No. 2025-CP-10-05095

Exhibit H—Coordinated DARVO by Attorneys, pp. 74-86 (p. 74-86)

Exhibit L—AppFolio Subpoena Communications, pp. 111-115 (p. 111-115)

EXHIBIT L
Witness Tampering & Obstruction (S.C. Code § 16-9-340) Overview: AppFolio Emails (Jan 9 & Jan 12, 2026) proving Meridian actively instructed third parties to withhold evidence that was simultaneously being sought by the LLR regulatory investigation. From: Kristin Williams To: chris thaut.io; mcneilandpoyer@gmail.com Subject: Subpoena: McNeil and Poyer v. Meridian Residential Group, LLC - Civil Action No. 2025-CP-10-05095 Date: Friday, January 9, 2026 7:48:12 PM Hello, We are writing to confirm receipt of the subpoena in the aforementioned matter. Please be advised that we have received notice from our customer that they intend to object to this subpoena, if they have not already done so. Therefore, we will not be providing any responsive documents until otherwise notified. Thank you, Kristin Williams Paralegal, Legal & Compliance kristin.williams@appfolio.com From: Kristin Williams To: chris thaut.io Cc: Take Legal In Subject: Re: URGENT: Subpoena Compliance Inquiry + Evidence Preservation — McNeil v. Meridian (Case No. 2025-CP- 10-05095) Date: Monday, January 12, 2026 6:09:01 PM  - privacy@appfolio.com, support@appfolio.com Dear Mr. McNeil and Ms. Poyer, I am writing to acknowledge receipt of your email of January 11, 2026, regarding the subpoena McNeil & Poyer v. Meridian Residential Group, LLC. AppFolio’s position remains that production of documents is currently stayed because we have received formal notice from our customer, Meridian Residential Group, LLC, that they have filed an objection and/or Motion to Quash the third-party subpoena. We will await resolution of our customer's objection or a court order directing compliance before releasing their associated records. Please be advised that AppFolio has implemented a comprehensive legal hold and all potentially responsive documents, as described in the October 1, 2025 notice and the December 23, 2025 Subpoena Duces Tecum, are being preserved. Regards,

Kristin Williams Paralegal, Legal & Compliance kristin.williams@appfolio.com

Exhibit D - Evidence Preservation and Takedown Notices (p. 41-54)

EXHIBIT D
Sept 21, 2025 Evidence Preservation Notice Email and Takedown Notices. (CoStar, Zillow, etc.)

 Takedown Notice/Image Preservation email to Eric Pettis September 21, 2025  (move.com – realtor.com) Unauthorized Image Takedown & Preservation Request – Privacy Violation & Active Litigation (Case No. 2025-CP-10-05095).pdf  (Zillowgroup)Unauthorized Image Takedown & Preservation Request – Privacy Violation & Active Litigation (Case No. 2025-CP-10-05095).pdf  (Matterport)Unauthorized Image Takedown & Preservation Request – Privacy Violation & Active Litigation (Case No. 2025-CP-10-05095).pdf  (costargroup)Unauthorized Image Takedown & Cache Elimination Required – Privacy Violation & Active Litigation (Case No. 2025-CP-10-05095).pdf

Platform Swaps, Overlays and Removals (p. 55-60)

EXHIBIT E
Platform swaps/overlays/removals
(e.g., “COMING SOON,” 404 on tour)

Timestamped screenshots taken on 9/26/25, after discovering more sites with the same ad.

For the sake of brevity, not including all sites or all screenshots in exhibit

Matterport (virtual tour removed)

15 Sites found with the 181 Gordon St. ad as of October 5, 2025
+ 1 Virtual Tour (Matterport) = 16 sites so-far identified*
*And there are likely more, given AppFolio/ShowMojo syndication fingerprints and
ShowMojo’s claim of distribution over 50+ sites
Sites identified with ~16 still images (with Meaghan, belongings, bathroom, bedroom) or
identified with replacement ad after original ad removal
zillow, trulia, realtor.com, apartments.com, apartmentfinder.com, forrent.com, rent.com,
clemsonoffcampus.com, PadMapper, Zumper, meridianresidentialgroup.com,
showmetherent.com, HotPads.com, RentalSource.com, Showmojo.com

Matterport Virtual Tour (with Chris, Rocket in diapers, Thaut Thought Leadership sign)
Matterport
& everywhere the virtual tour was embedded or downloaded

Exhibit M—Meridian Answer and Crossclaim, pp. 122-126 (p. 122-126)

115. SAC hired Defendant Meridian as the property manager at several properties
including 181 Gordon Street, Charleston, SC (“Subject Property”).
116. SAC and Meridian entered into a management agreement where Meridian was
authorized to lease and manage on behalf of SAC, the owner of the subject property.
121. Pursuant to the Defendants’ contract, Defendant SAC owes a duty to Meridian to
indemnify, defend, and hold harmless Meridian from all claims and suits.
122. Pursuant to the Defendants’ contract, Defendant SAC agreed to cover without limit
attorneys’ fees and costs for Meridian.
123. To the extent, if any, that Meridian is held liable to Plaintiffs in this action, such
liability would be a direct and proximate result of the wrongful acts, omissions, and negligence of Defendant SAC, which has damaged Meridian because it has been subjected to liability and has incurred consequential damages by having to expend attorneys’ fees and costs in defending this action.
124. Defendant Meridian is entitled to indemnification from Defendant SAC for any
liability Meridian is found to have to Plaintiffs in accordance with the parties’ contract, and in such a case, Meridian would be entitled to recover from Defendant SAC for the fees, costs, and other expenses incurred in defending this action and any money in which Meridian may be held liable to the Plaintiffs.
125. To the extent, if any, Defendant Meridian is liable to Plaintiffs, Meridian is entitled
to contractual and equitable indemnity from Defendant SAC for any judgment or settlement amount, including reasonable attorney’s fees. Further, to the extent liability or damages are imposed against Defendant Meridian, Meridian alleges its liability to Plaintiffs, if any, is only secondary or passive and Plaintiffs’ damages, if any, were solely and proximately caused by the active or primary fault of Defendant SAC. Therefore, Meridian pleads the right of contractual and equitable indemnity exists in its favor against Defendant SAC because Meridian is exposed to liability in this case, if at all, because of the primary wrongful acts or omissions of SAC.

Exhibit E - Platform Swaps, Overlays, and Removals (p. 55-60)

EXHIBIT E
Platform swaps/overlays/removals (e.g., “COMING SOON,” 404 on tour)

Deposit, Postmark and Property Management Transition (p. 61-68)

EXHIBIT F Series
Deposit / Postmark / Property Management Company
Change

• Ex. F-1 - Meridian scanner PDF image
• Ex. F-2 - Actual USPS envelope + checks showing 9/8 postmark
• Ex. F-3 - Jan 5, 2024 Property Management transition email (“owner is fully
aware… effective Dec 27, 2023”)

Ex. F-1 - Meridian scanner PDF image

• September 5, 2025 email from Tara Bayles, attached “Meridian
Scanner_20250905_161321.pdf”,
• file name evidencing scan time of 4:13:21 PM on September 5, 2025 (using military time,
“16” = “4PM”)
• Irreconcilable difference between the scanner’s date and the mailing narrative
• Meridian Scanner_20250905_161321.pdf following

Ex. F-2 - Actual USPS envelope + checks showing 9/8 postmark
Actual USPS Envelope and Checks Received September 10

- Shows legitimate September 8 postmark, contrast with “emailed” “postmark” in F-1
- Same check numbers as Exhibit F-1 - Proves timeline impossibility

Ex. F-3 - Jan 5, 2024 Property Management transition email (“owner is fully aware…
effective Dec 27, 2023”)

01/05/2024
Meaghan Poyer, James McNeil
181 Gordon St
Charleston, SC 29403
RE: New Management
Dear Meaghan, James,
This is to inform you that management for your residence has transferred from Roadstead Management due to an
acquisition of the management company. The property owner is fully aware of this change and became effective
December 27, 2023.
Payments:
Please note that all payments made from December 27 - January 5, 2024, are in the process of being uploaded
into our system.
• If you received a notice from Meridian that your payment has not been received, and you have confirmation
from Roadstaed that a payment was processed, please disregard the Meridian notice.
• Therefore, any payments made after today, January 5, 2024, and all future rental payments will need to be
made through Meridian Residential Group. Your current rental agreement remains in effect.

Sincerely,
Tara D. Bayles, PMIC
Meridian Residential Group

Exhibit N—Retaliation Timeline, pp. 131-132 (p. 131-132)

Retaliation Timeline - Pattern of Legal Misrepresentation & Escalation

April 2, 2025: Stephanie Phillips attempts to dictate inspection timing without tenant coordination and with less than 24 hours-notice. (following) May 8, 2025: Stephanie misrepresents lease validity, claiming lease invalid due to missing Roadstead signature despite years of honoring terms. Chris McNeil provides comprehensive legal correction with supporting documentation showing de facto lease recognition under contract law principles. (following) May 23, 2025: Good-faith safety-oriented proposal submitted regarding property conditions. (Exhibit B) May 29, 2025: Retaliatory Notice to Vacate issued 6 days after safety proposal - retaliation for pattern of challenging legal misrepresentations and asserting tenant rights. (Exhibit A) July 5, 2025: Suspicious email with potentially fraudulent attachment, likely sent by Stephanie Phillips. When questioned about legitimacy and security concerns, Meridian provides no response or clarification despite professional inquiry. (following) July 14, 2025: Stephanie again misrepresents South Carolina landlord-tenant law regarding "reasonable times" for entry, claiming landlord can dictate timing without tenant coordination. Chris McNeil provides detailed legal correction citing SC Code § 27-40-530. Tara Bayles subsequently acknowledges tenant's legal position is correct, contradicting her employee's misrepresentation. (following) July 17, 2025: Unanswered “Why are we being asked to leave?” email (July 17, 2025) following lawful safety and compliance requests, establishing key evidence for the retaliation timeline. Two days afterwards, On July 19, 2025 as per Redfin, Meridian raised the rent from $3,050/month to $5,276/month. (Exhibit K)

Sites Identified with Listing Images (p. 60-60)

15 Sites found with the 181 Gordon St. ad as of October 5, 2025 + 1 Virtual Tour (Matterport) = 16 sites so-far identified*
*And there are likely more, given AppFolio/ShowMojo syndication fingerprints and
ShowMojo’s claim of distribution over 50+ sites Sites identified with ~16 still images (with Meaghan, belongings, bathroom, bedroom) or identified with replacement ad after original ad removal zillow, trulia, realtor.com, apartments.com, apartmentfinder.com, forrent.com, rent.com, clemsonoffcampus.com, PadMapper, Zumper, meridianresidentialgroup.com, showmetherent.com, HotPads.com, RentalSource.com, Showmojo.com

Matterport Virtual Tour (with Chris, Rocket in diapers, Thaut Thought Leadership sign) Matterport & everywhere the virtual tour was embedded or downloaded

Adam Bayles Role Obfuscation (p. 69-73)

EXHIBIT G
Baseline Intent to Deceive through Fraudulent Misrepresentation
9/6/2024
Adam Bayles Role Obfuscation
Document:
Email from Tara Bayles to Chris McNeil, dated September 6, 2024, alongside corroborating
public records (Meridian website bio and LinkedIn profile).

The Deception:
In the following email, Property Manager Tara Bayles explicitly instructs the complainant not to
contact Adam Bayles regarding lease or account issues, falsely claiming: "Adam works in our
maintenance department."

The Reality:
Adam Bayles is not a maintenance worker. As proven by Meridian's own website and his
professional profiles, Adam Bayles is the Co-Owner of Meridian Residential Group, leads
business development, and serves as the statutorily designated Registered Agent for the affiliated
ownership entity (MRG Investing Company, LLC).

Investigative Significance (Why This Matters):
In criminal harassment (S.C. Code 16-3-1700), investigators must establish intent. This
document serves as the genesis point for the subjects' pattern of psychological abuse. It proves
that the subjects did not just make administrative errors; they operated from a calculated baseline
of reality-denial.

By actively falsifying the corporate structure and the identities of the company's owners to
disempower a tenant, the subjects established a deliberate strategy of gaslighting and
misrepresentation that would later escalate into retaliatory eviction, postal forgery, and mass
privacy violations.

Adam Bayles is the co-owner of Meridian Residential Group, where he leads business
development and operational management with a focus on growth and efficiency.

Exhibit P—LLR Complaint and Investigation, pp. 157-162 (p. 157-162)

EXHIBIT P
The Catalyst for Obstruction (LLR PMIC Investigation) Overview: This exhibit establishes the active regulatory threat against the primary subject, Tara Bayles, which serves as the primary motive for the subsequent pattern of witness tampering, harassment (DARVO), and coordinated legal gaslighting by the subjects and their agents. P1 - LLR Complaint Against PMIC License (Sept 23, 2025) Document: Formal complaint submitted to the South Carolina Department of Labor, Licensing and Regulation (LLR) against Tara Bayles’ Property Manager-In-Charge (PMIC) License (#83633). The Action: The complaint formally flags Tara Bayles for systemic violations of S.C. Code § 40-57-710, specifically detailing the retaliatory eviction, the mass unauthorized publication of private images, and the dishonest dealing regarding the falsified EMAILED postmark stamp (Forgery). Investigative Significance: This document establishes that the subjects were put on official notice that their deceptive practices were being escalated to state regulators. The threat to Tara Bayles' professional license—which underpins the entire Meridian corporate operation—provides the compelling motive for the subjects to engage in extreme obstruction and cover-up tactics rather than participate in normal legal discovery. P2 - LLR Investigator Assignment & Deadline (Oct 2, 2025) Document: Official Acknowledgment Letter from LLR Lead Investigator J. Watson Wharton III, assigning the case to Investigator Kasey Williams (File #2025-566). The Action: This letter confirms an active state investigation into Tara Bayles and establishes a statutory 150-day deadline for the investigation to conclude: February 20, 2026. Investigative Significance (The "Ticking Clock"): This document proves the existence of a hard regulatory deadline. Knowing that LLR investigators had until February 20, 2026, to finalize their findings, the subjects and their legal proxies orchestrated a cluster of obstruction tactics specifically timed to run out this clock. This active state investigation directly explains:
1. Witness Tampering (Exhibit L): Why Meridian formally instructed third-
party software vendors (AppFolio) not to comply with subpoenas in January
2026.
2. Coordinated Minimization (Table A): Why defense attorneys for supposedly
opposing parties adopted identical false narratives, repeatedly characterizing an 8-count fraud and privacy case as a "simple deposit dispute" to minimize the scope of the case before the LLR investigator could review the full evidence.
3. Escalated Harassment (Exhibit H): Why defense counsel resorted to
DARVO tactics against the complainant in late January 2026, desperately trying to reframe the victim as a "threat" just weeks before the LLR deadline.

Exhibit F Series - Deposit, Postmark, and Management Change (p. 61-68)

EXHIBIT F Series Deposit / Postmark / Property Management Company Change

• Ex. F-1 - Meridian scanner PDF image • Ex. F-2 - Actual USPS envelope + checks showing 9/8 postmark • Ex. F-3 - Jan 5, 2024 Property Management transition email (“owner is fully aware… effective Dec 27, 2023”)

January 27-28, 2026 Emergency Status Conference Emails (p. 75-86)

Exhibit Q—False Narrative Coordination, pp. 163-165 (p. 163-165)

EXHIBIT Q
Coordinated Institutional Gaslighting & Unified Enterprise Document: Table of Evidence of False Narrative Coordination (Tracking Court Filings from Oct 2025 to Jan 2026). The Action (What the Evidence Shows): This table tracks the chronological court filings of two supposedly adverse defense camps: SAC 181 (represented by Phelps Dunbar) and Meridian/Tara Bayles (represented by Resnick & Louis). Despite Meridian filing a crossclaim blaming SAC 181 for the damages, the attorneys for both sides continuously, synchronously, and identically characterized an 8-count lawsuit involving retaliatory eviction, forgery, and mass privacy violations as a "single, simple claim regarding whether Plaintiffs' security deposit was timely returned." Investigative Significance (The Criminal Elements):
1. Proof of the Unified Enterprise: Under federal legal standards (Elec. Data
Sys. Corp. v. Steingraber), when supposedly adverse parties independently adopt identical litigation positions, it suggests a common interest and unified enterprise. The synchronous motions to quash (filed Jan 8 and Jan 12) using identical "deposit dispute" characterizations prove both defendants are coordinating to defend the exact same paramount interest: preventing discovery that would expose Tara Bayles to the LLR PMIC investigation.
2. Institutional Betrayal & Harassment: This table proves that the
psychological harm inflicted on the complainant was not caused by a single rogue agent, but by a coordinated system. By formally entering these false narratives into the court record, legal agents deliberately attempted to erase the reality of the victim's forced displacement and privacy violations. As established in psychological literature on "Institutional Betrayal," forcing a victim to continuously fight an institution to prove their traumatic reality actively exacerbates PTSD and constitutes a severe form of psychological harassment (S.C. Code § 16-3-1700).
3. Obstruction Motive: The minimization strategy tracked in this table directly
corresponds with the February 20, 2026, LLR investigation deadline established in Exhibit P. The false narratives were utilized to justify blocking third-party subpoenas that would have yielded evidence for the state regulators. Legal Significance: Under Elec. Data Sys. Corp. v. Steingraber, 403 F.3d 1010 (8th Cir. 2005), independent adoption of identical litigation positions by supposedly adverse parties suggests common interest and unified enterprise. The synchronous quash motions (01/08 and 01/12) using identical "deposit dispute" characterization, despite Meridian's cross-claim against SAC 181, suggests both defendants are defending the same paramount interest: preventing discovery that would threaten Tara Bayles' PMIC license, which is under investigation by the LLR. (Rule 408 Protected): Tate Settlement Communication (December 1, 2025) - "… the only cause of action that SAC sees as potentially viable is the claim regarding the return of the security deposit" [Remainder redacted; cited solely for obstruction exception] This excerpt is offered solely to demonstrate SAC 181’s own case-scope framing in evaluating proportional discovery, not to prove liability or the amount of any claim.

Exhibit G - Adam Bayles Role Obfuscation (p. 69-73)

EXHIBIT G
Baseline Intent to Deceive through Fraudulent Misrepresentation 9/6/2024 Adam Bayles Role Obfuscation Document: Email from Tara Bayles to Chris McNeil, dated September 6, 2024, alongside corroborating public records (Meridian website bio and LinkedIn profile).

The Deception: In the following email, Property Manager Tara Bayles explicitly instructs the complainant not to contact Adam Bayles regarding lease or account issues, falsely claiming: "Adam works in our maintenance department."

The Reality: Adam Bayles is not a maintenance worker. As proven by Meridian's own website and his professional profiles, Adam Bayles is the Co-Owner of Meridian Residential Group, leads business development, and serves as the statutorily designated Registered Agent for the affiliated ownership entity (MRG Investing Company, LLC).

Courtesy Notice — Criminal Investigation and Counsel Conflicts (p. 81-84)

From: chris thaut.io
To: "caltman@caltmanlaw.com"; "jaltman@derfneraltman.com"
Cc: "Kevin O"Brien"; "Justine Tate"; "Alicia Bolyard"; "gladys.lambert@ipgclaims.com"; "C&M McNeil"
Subject: Courtesy Notice – Criminal Investigation & Counsel Conflicts
Date: Monday, January 26, 2026 5:56:00 PM
Importance: High
Mr. Altman, Mr. Altman, Counsel, and Ms. Lambert,
I am sending this as a courtesy notice because I still choose to act from principles of
fairness and transparency, even where your conduct toward me has not done the same.
Some of you will shortly need a new property manager, and this notice may help you
avoid some avoidable crises.

Today I initiated a criminal investigation with the Charleston County Sheriff’s Office,
Case No. 2026 ‑001263, with primary focus on Tara R. Bayles (Meridian Residential
Group, PMIC #30129) and related conduct arising from the 181 Gordon Street matter.
The evidence provided includes the falsified USPS “postmark” (forensic metadata
showing a September 5 creation date for a document represented as August 28),
21‑platform image syndication records, cross ‑firm coordination emails, and timing
analysis of interference with LLR Investigation #2025 ‑566.
From my perspective, the Altman family has funded and continued to rely on a litigation
and insurance machine that has systematically gaslit me about traumatic events (illegal
eviction, document fraud, privacy violations), turning what began as a solvable dispute
into a coordinated harassment and likely smear campaign instead of a good ‑faith effort
to resolve the case.
Counsel – if you recuse yourself from the case, I will consider not filing charges on you.
Before you let your ego make that decision for you, I suggest discussions with your
families. And if you’ve been seeking a way to disentangle from Tara, here is your
opportunity: the perfect excuse.

Evidence preservation
You are hereby instructed to preserve all communications and documents relating to
this matter, including but not limited to emails, texts, internal notes, and messaging with
Ms. Bayles, Meridian, IPG, and co‑counsel.
These are my three cautions:
1. Forensic recoverability. Emails, messages, and deleted files can be retrieved
from cloud servers and third ‑party systems by forensic specialists you do not
control. Attempted cleanup after this notice is rarely successful and is often
obvious in the audit trail.
2. Crime‑fraud and privilege. Use of legal process as a vehicle for harassment,
obstruction, or other criminal conduct pierces the attorney–client privilege;
communications furthering that conduct are not protected and may be subject to
disclosure in both Bar and criminal proceedings.
3. Spoliation and adverse inferences. Any deletion, alteration, or concealment of
relevant evidence following this notice will be treated as spoliation and addressed
accordingly through adverse inferences, sanctions, and, where appropriate,
additional criminal and regulatory referrals.

AppFolio Subpoena Emails (p. 111-115)

EXHIBIT L
Witness Tampering & Obstruction (S.C. Code § 16-9-340)
Overview: AppFolio Emails (Jan 9 & Jan 12, 2026) proving Meridian actively
instructed third parties to withhold evidence that was simultaneously being sought by
the LLR regulatory investigation.

From: Kristin Williams
To: chris thaut.io; mcneilandpoyer@gmail.com
Subject: Subpoena: McNeil and Poyer v. Meridian Residential Group, LLC - Civil Action No. 2025-CP-10-05095
Date: Friday, January 9, 2026 7:48:12 PM
Hello,
We are writing to confirm receipt of the subpoena in the aforementioned matter.
Please be advised that we have received notice from our customer that they intend to
object to this subpoena, if they have not already done so. Therefore, we will not be
providing any responsive documents until otherwise notified.
Thank you,
Kristin Williams
Paralegal, Legal & Compliance
kristin.williams@appfolio.com

From: Kristin Williams
To: chris thaut.io
Cc: Take Legal In
Subject: Re: URGENT: Subpoena Compliance Inquiry + Evidence Preservation — McNeil v. Meridian (Case No. 2025-CP-
10-05095)
Date: Monday, January 12, 2026 6:09:01 PM
Dear Mr. McNeil and Ms. Poyer,
I am writing to acknowledge receipt of your email of January 11, 2026, regarding the
subpoena McNeil & Poyer v. Meridian Residential Group, LLC.
AppFolio’s position remains that production of documents is currently stayed because we have
received formal notice from our customer, Meridian Residential Group, LLC, that they have filed
an objection and/or Motion to Quash the third-party subpoena. We will await resolution of our
customer's objection or a court order directing compliance before releasing their associated
records.
Please be advised that AppFolio has implemented a comprehensive legal hold and all potentially
responsive documents, as described in the October 1, 2025 notice and the December 23, 2025
Subpoena Duces Tecum, are being preserved.

Exhibit H - Coordinated DARVO by Attorneys (p. 74-86)

EXHIBIT H
Coordinated DARVO by Attorneys (Harassment)

The Jan 27-29 DARVO Emails to Court Staff. Emails from O'Brien, Bolyard, and Tate deliberately misrepresenting Complainant’s "Courtesy Notice" as a physical threat to exhaust and intimidate him.

Agency Admission and Crossclaim (p. 123-130)

115. SAC hired Defendant Meridian as the property manager at several properties
including 181 Gordon Street, Charleston, SC (“Subject Property”).
116. SAC and Meridian entered into a management agreement where Meridian was
authorized to lease and manage on behalf of SAC, the owner of the subject property.

121. Pursuant to the Defendants’ contract, Defendant SAC owes a duty to Meridian to
indemnify, defend, and hold harmless Meridian from all claims and suits.
122. Pursuant to the Defendants’ contract, Defendant SAC agreed to cover without limit
attorneys’ fees and costs for Meridian.
123. To the extent, if any, that Meridian is held liable to Plaintiffs in this action, such
liability would be a direct and proximate result of the wrongful acts, omissions, and negligence of
Defendant SAC, which has damaged Meridian because it has been subjected to liability and has
incurred consequential damages by having to expend attorneys’ fees and costs in defending this
action.
124. Defendant Meridian is entitled to indemnification from Defendant SAC for any
liability Meridian is found to have to Plaintiffs in accordance with the parties’ contract, and in such
a case, Meridian would be entitled to recover from Defendant SAC for the fees, costs, and other
expenses incurred in defending this action and any money in which Meridian may be held liable
to the Plaintiffs.
125. To the extent, if any, Defendant Meridian is liable to Plaintiffs, Meridian is entitled
to contractual and equitable indemnity from Defendant SAC for any judgment or settlement
amount, including reasonable attorney’s fees. Further, to the extent liability or damages are
imposed against Defendant Meridian, Meridian alleges its liability to Plaintiffs, if any, is only
secondary or passive and Plaintiffs’ damages, if any, were solely and proximately caused by the
active or primary fault of Defendant SAC. Therefore, Meridian pleads the right of contractual and
equitable indemnity exists in its favor against Defendant SAC because Meridian is exposed to
liability in this case, if at all, because of the primary wrongful acts or omissions of SAC.

O'Brien Request for Emergency Status Conference (p. 78-80)

We are writing to request an emergency status conference with Judge Van Slambrook. There are many motions pending before the Court. However, the pro se Plaintiffs in this case have recently been taking action and/or sending correspondence, about which we respectfully submit should be brought to the attention of Court and about which we respectfully and humbly request the Court’s intervention. Last night pro se Plaintiff, James C. (“Chris”) McNeil sent an e-mail making threats against lawyers in this case (which we understand to include Ms. Tate and myself) including that he intended to seek criminal charges and he mentioned our families in the e-mail. (We would be happy to share the e- mail with the Court upon Judge Van Slambrook’s request.) Plaintiffs have also been sending to non-parties documents Plaintiffs are purporting to be subpoenas, but which documents were not issued or signed by the Clerk. We have recently filed Motions to Quash two such purported subpoenas to non-parties.

Retaliation Timeline (p. 131-132)

Retaliation Timeline - Pattern of Legal Misrepresentation & Escalation

April 2, 2025: Stephanie Phillips attempts to dictate inspection timing without
tenant coordination and with less than 24 hours-notice. (following)
May 8, 2025: Stephanie misrepresents lease validity, claiming lease invalid due to
missing Roadstead signature despite years of honoring terms. Chris McNeil
provides comprehensive legal correction with supporting documentation showing
de facto lease recognition under contract law principles. (following)
May 23, 2025: Good-faith safety-oriented proposal submitted regarding property
conditions. (Exhibit B)
May 29, 2025: Retaliatory Notice to Vacate issued 6 days after safety proposal -
retaliation for pattern of challenging legal misrepresentations and asserting tenant
rights. (Exhibit A)
July 5, 2025: Suspicious email with potentially fraudulent attachment, likely sent
by Stephanie Phillips. When questioned about legitimacy and security concerns,
Meridian provides no response or clarification despite professional inquiry.
(following)
July 14, 2025: Stephanie again misrepresents South Carolina landlord-tenant law
regarding "reasonable times" for entry, claiming landlord can dictate timing
without tenant coordination. Chris McNeil provides detailed legal correction citing
SC Code § 27-40-530. Tara Bayles subsequently acknowledges tenant's legal
position is correct, contradicting her employee's misrepresentation. (following)
July 17, 2025: Unanswered “Why are we being asked to leave?” email (July 17,
2025) following lawful safety and compliance requests, establishing key evidence
for the retaliation timeline. Two days afterwards, On July 19, 2025 as per Redfin,
Meridian raised the rent from $3,050/month to $5,276/month. (Exhibit K)

Exhibit I - Psychological Injury (p. 87-102)

EXHIBIT I
The Psychological Injury (Criminal Harm for Harassment)

(wife) Meaghan Poyer's A idavits (Nov 25, 2025 & Jan 29, 2026) detailing the severe disruption to daily life.

The PCL-5 Clinical Score (76/80) proving Severe PTSD resulting from the harassment.

LLR Complaint and Investigator Assignment (p. 157-162)

EXHIBIT P
The Catalyst for Obstruction (LLR PMIC Investigation)
Overview: This exhibit establishes the active regulatory threat against the primary
subject, Tara Bayles, which serves as the primary motive for the subsequent pattern of
witness tampering, harassment (DARVO), and coordinated legal gaslighting by the
subjects and their agents.

P1 - LLR Complaint Against PMIC License (Sept 23, 2025)
Document: Formal complaint submitted to the South Carolina Department of Labor,
Licensing and Regulation (LLR) against Tara Bayles’ Property Manager-In-Charge
(PMIC) License (#83633).
The Action: The complaint formally flags Tara Bayles for systemic violations of S.C.
Code § 40-57-710, specifically detailing the retaliatory eviction, the mass
unauthorized publication of private images, and the dishonest dealing regarding the
falsified EMAILED postmark stamp (Forgery).
Investigative Significance: This document establishes that the subjects were put on
official notice that their deceptive practices were being escalated to state regulators.
The threat to Tara Bayles' professional license—which underpins the entire Meridian
corporate operation—provides the compelling motive for the subjects to engage in
extreme obstruction and cover-up tactics rather than participate in normal legal
discovery.

P2 - LLR Investigator Assignment & Deadline (Oct 2, 2025)
Document: Official Acknowledgment Letter from LLR Lead Investigator J. Watson
Wharton III, assigning the case to Investigator Kasey Williams (File #2025-566).
The Action: This letter confirms an active state investigation into Tara Bayles and
establishes a statutory 150-day deadline for the investigation to conclude: February
20, 2026.
Investigative Significance (The "Ticking Clock"): This document proves the
existence of a hard regulatory deadline. Knowing that LLR investigators had until
February 20, 2026, to finalize their findings, the subjects and their legal proxies
orchestrated a cluster of obstruction tactics specifically timed to run out this clock.

False Narrative Coordination (p. 163-165)

EXHIBIT Q
Coordinated Institutional Gaslighting & Unified Enterprise
Document: Table of Evidence of False Narrative Coordination (Tracking Court
Filings from Oct 2025 to Jan 2026).
The Action (What the Evidence Shows): This table tracks the chronological court
filings of two supposedly adverse defense camps: SAC 181 (represented by Phelps
Dunbar) and Meridian/Tara Bayles (represented by Resnick & Louis). Despite
Meridian filing a crossclaim blaming SAC 181 for the damages, the attorneys for both
sides continuously, synchronously, and identically characterized an 8-count lawsuit
involving retaliatory eviction, forgery, and mass privacy violations as a "single,
simple claim regarding whether Plaintiffs' security deposit was timely returned."
Investigative Significance (The Criminal Elements):
1. Proof of the Unified Enterprise: Under federal legal standards (Elec. Data
Sys. Corp. v. Steingraber), when supposedly adverse parties independently
adopt identical litigation positions, it suggests a common interest and unified
enterprise. The synchronous motions to quash (filed Jan 8 and Jan 12) using
identical "deposit dispute" characterizations prove both defendants are
coordinating to defend the exact same paramount interest: preventing discovery
that would expose Tara Bayles to the LLR PMIC investigation.
2. Institutional Betrayal & Harassment: This table proves that the
psychological harm inflicted on the complainant was not caused by a single
rogue agent, but by a coordinated system. By formally entering these false
narratives into the court record, legal agents deliberately attempted to erase the
reality of the victim's forced displacement and privacy violations. As
established in psychological literature on "Institutional Betrayal," forcing a
victim to continuously fight an institution to prove their traumatic reality
actively exacerbates PTSD and constitutes a severe form of psychological
harassment (S.C. Code § 16-3-1700).
3. Obstruction Motive: The minimization strategy tracked in this table directly
corresponds with the February 20, 2026, LLR investigation deadline
established in Exhibit P. The false narratives were utilized to justify blocking
third-party subpoenas that would have yielded evidence for the state regulators.

Exhibit K - July 17 Email (p. 106-110)

Exhibit K – July 17 “Why don’t you want us here?” email

Exhibit L - Witness Tampering and Obstruction (p. 111-115)

EXHIBIT L
Witness Tampering & Obstruction (S.C. Code § 16-9-340) Overview: AppFolio Emails (Jan 9 & Jan 12, 2026) proving Meridian actively instructed third parties to withhold evidence that was simultaneously being sought by the LLR regulatory investigation.

AppFolio January 9 Email (p. 112-113)

From: Kristin Williams To: chris thaut.io; mcneilandpoyer@gmail.com Subject: Subpoena: McNeil and Poyer v. Meridian Residential Group, LLC - Civil Action No. 2025-CP-10-05095 Date: Friday, January 9, 2026 7:48:12 PM Hello, We are writing to confirm receipt of the subpoena in the aforementioned matter. Please be advised that we have received notice from our customer that they intend to object to this subpoena, if they have not already done so. Therefore, we will not be providing any responsive documents until otherwise notified. Thank you, Kristin Williams Paralegal, Legal & Compliance kristin.williams@appfolio.com

Exhibit M - Corporate Shielding and Agency Admission (p. 116-130)

EXHIBIT M
Corporate Shielding, Agency Admission & Coordinated Cover-Up Overview: This exhibit contains two documents that demonstrate how the subjects and their agents actively manipulate corporate structures and legal proceedings to shield individual actors from accountability, establish agency, and then coordinate cover-ups when exposed.

Meridian Agency and Indemnity Allegations (p. 123-125)

114. SAC owned the property that is the subject of this lawsuit.
115. SAC hired Defendant Meridian as the property manager at several properties
including 181 Gordon Street, Charleston, SC (“Subject Property”).
116. SAC and Meridian entered into a management agreement where Meridian was
authorized to lease and manage on behalf of SAC, the owner of the subject property.

Exhibit N - Retaliation Narrative Supporting Emails (p. 131-150)

Exhibit N – Retaliation Narrative Supporting Emails

Included
1. Retaliation timeline
2. April 2-3, 2025 inspection scheduling with less than 24 hours notice and no flexibility
3. May 8, 2025: Legal corrections to Stephanie Phillips' misrepresentations.
4. June 4, 2025
5. July 5, 2025: Suspicious email with potentially fraudulent attachments, Meridian
provides no response or clarification despite professional inquiry.
6. July 14, 2025: Stephanie again misrepresents South Carolina landlord-tenant law

Retaliation Timeline (p. 132-132)

Retaliation Timeline - Pattern of Legal Misrepresentation & Escalation

April 2, 2025: Stephanie Phillips attempts to dictate inspection timing without tenant coordination and with less than 24 hours-notice. (following) May 8, 2025: Stephanie misrepresents lease validity, claiming lease invalid due to missing Roadstead signature despite years of honoring terms. Chris McNeil provides comprehensive legal correction with supporting documentation showing de facto lease recognition under contract law principles. (following) May 23, 2025: Good-faith safety-oriented proposal submitted regarding property conditions. (Exhibit B) May 29, 2025: Retaliatory Notice to Vacate issued 6 days after safety proposal - retaliation for pattern of challenging legal misrepresentations and asserting tenant rights. (Exhibit A) July 5, 2025: Suspicious email with potentially fraudulent attachment, likely sent by Stephanie Phillips. When questioned about legitimacy and security concerns, Meridian provides no response or clarification despite professional inquiry. (following) July 14, 2025: Stephanie again misrepresents South Carolina landlord-tenant law regarding "reasonable times" for entry, claiming landlord can dictate timing without tenant coordination. Chris McNeil provides detailed legal correction citing SC Code § 27-40-530. Tara Bayles subsequently acknowledges tenant's legal position is correct, contradicting her employee's misrepresentation. (following) July 17, 2025: Unanswered “Why are we being asked to leave?” email (July 17, 2025) following lawful safety and compliance requests, establishing key evidence for the retaliation timeline. Two days afterwards, On July 19, 2025 as per Redfin, Meridian raised the rent from $3,050/month to $5,276/month. (Exhibit K)

Exhibit O - Text Message Thread (p. 151-156)

Exhibit O – Text Message Thread with Meridian Residential Group, LLC

Included
1. Table of Date-Time and Topic/Relevance
2. Text thread between Plaintiff McNeil and Meridian number +12058807701

Exhibit P - LLR PMIC Investigation (p. 157-162)

EXHIBIT P
The Catalyst for Obstruction (LLR PMIC Investigation) Overview: This exhibit establishes the active regulatory threat against the primary subject, Tara Bayles, which serves as the primary motive for the subsequent pattern of witness tampering, harassment (DARVO), and coordinated legal gaslighting by the subjects and their agents.

LLR Complaint Against Tara Bayles (p. 158-159)

Tara Bayles, acting as PMIC for Meridian, engaged in misconduct violating SC landlord- tenant and licensing law. She failed to return our deposit within 30 days as required by S.C. Code § 27-40-410, then submitted falsified "postmark" evidence. She issued a retaliatory Notice to Vacate days after we raised safety concerns, a violation of tenant protections. She authorized deceptive image use, exposing us publicly without consent, creating safety risks. This conduct reflects systemic disregard for tenant rights and constitutes grounds for discipline under S.C. Code § 40-57-710.

LLR Investigator Assignment and Deadline (p. 160-162)

P2 - LLR Investigator Assignment & Deadline (Oct 2, 2025) Document: Official Acknowledgment Letter from LLR Lead Investigator J. Watson Wharton III, assigning the case to Investigator Kasey Williams (File #2025-566). The Action: This letter confirms an active state investigation into Tara Bayles and establishes a statutory 150-day deadline for the investigation to conclude: February 20, 2026.

Exhibit Q - False Narrative Coordination (p. 163-165)

EXHIBIT Q
Coordinated Institutional Gaslighting & Unified Enterprise Document: Table of Evidence of False Narrative Coordination (Tracking Court Filings from Oct 2025 to Jan 2026). The Action (What the Evidence Shows): This table tracks the chronological court filings of two supposedly adverse defense camps: SAC 181 (represented by Phelps Dunbar) and Meridian/Tara Bayles (represented by Resnick & Louis). Despite Meridian filing a crossclaim blaming SAC 181 for the damages, the attorneys for both sides continuously, synchronously, and identically characterized an 8-count lawsuit involving retaliatory eviction, forgery, and mass privacy violations as a "single, simple claim regarding whether Plaintiffs' security deposit was timely returned."