Scannergate

I.A. Court Already Is Concerned for Plaintiffs' Safety (p. 1-1)

Plaintiff James C. (“Chris”) McNeil’s consulting work helps clients understand and positively impact complex systems by surfacing up front events at the patterns, structures, and core mental models behind them in this role. It wheels this lens as a diagnostic tool on the judicial clarity that is needed due to a more urgent concern: the physical and psychological safety of the McNeil-Poyer family. Models that explain these high-risk system conditions are discussed later.

He is not alone in this concern. Following the nervous breakdown precipitated by harassment and gaslighting by defense, Plaintiff McNeil sought the assistance of a narcissistic abuse recovery specialist, having recognized the hallmarks of this pattern in defense behavior.

That counselor has stated, on multiple occasions, that he is concerned for the safety of both Plaintiff McNeil and his wife, Plaintiff Poyer.

I.A - Counselor Is Concerned for Plaintiffs' Safety, p. 1 (p. 1-1)

A. Counselor Is Concerned for Plaintiffs' Safety Plaintiff James C. ("Chris") McNeil’s consulting work helps clients understand and positive impact complex systems by chunking up from events to the patterns, structure, and core mental models behind them. In this role, he submits this brief as a diagnostic tool for the judicial clarity that is needed due to an urgent concern: the physical and psychological safety of the McNeil- Poyer family. Models that explain these high-risk system conditions are discussed later. He is not alone in this concern. Following the nervous breakdown precipitated by harassment and gaslighting by defense, Plaintiff McNeil sought the assistance of a narcissistic abuse recovery specialist, having recognized the fingerprints of the pattern in defense behavior. That counselor has stated, on multiple occasions, that he is concerned for the safety of both Plaintiff McNeil and his wife, Plaintiff Poyer.

I.B. Immediate Leave for Second Amended Complaint and April 2 Answer Deadline (p. 1-2)

No Defendant has filed opposition. Under SCRCP Rule 15(a), leave "shall be freely given when justice so requires," and the opposing party bears the burden of showing prejudice. Tanner v. Florence County Treasurer, 336 S.C. 552, 558 (1999).
No Defendant has attempted to carry that burden. The motion is ripe, and granting it now enables the Court to align all claims for the April 3 hearing - the single most effective action available to reduce Plaintiffs' escalating exposure to harm.
Plaintiffs also request that the Court set the answer deadline for the 2AC as April 2, 2026 - one day before the scheduled hearing - rather than the standard 30-day period. This shortened period is appropriate under SCRCP Rule 6(b), which permits the Court to set response periods for cause shown, for the following reasons:
1. The 2AC adds Charles S. Altman as an individual defendant. These are not new facts to Altman. The probate valuation discrepancies, the CRC ownership structure, and the individual conduct supporting veil-piercing have been documented in filings on this docket since December 2025 - including the Memorandum on Probate Valuations, the Supplemental Memorandum, and the Case Clarity Brief of February 24, 2026. The 2AC consolidates existing evidence into the operative pleading.
2. The 2AC adds the critical image counts. The counts associated with the mass syndicated private images and virtual tour published without plaintiff consent are added. These are critical allegations and the images were discovered by Plaintiffs after the Amended Complaint was filed and after they had been live for over 10 weeks, including a month when Plaintiffs still lived at 181 Gordon Street.
3. 147 days of silence is itself the answer. The Motion for Leave has been unopposed since October 24, 2025. During that period, Defendants have filed motions to dismiss, motions to quash subpoenas, motions regarding AI usage, and other procedural filings - demonstrating active engagement with the docket. Their silence on the 2AC is a strategic choice, not a lack of notice. SCRCP Rule 15 envisions prejudice as "a lack of notice that the new issue is going to be tried, and a lack of opportunity to refute it." Tanner, 336 S.C. at 558. Neither condition exists here.
4. The April 3 hearing is a critical safety inflection point. As documented in Section V and [Exhibit B], the hearing represents a threshold event after which Plaintiffs' exposure to defense volatility increases materially. Consolidating all claims into the operative pleading before that hearing - rather than leaving them pending for an additional 30 days
- directly serves the safety objective that is this brief's primary concern.
Granting the 2AC with an April 2 answer deadline aligns all counts for disposition at the April 3 hearing, enabling the Court to hear the Omnibus Motion (Section IV.3), apply the March 6 Systems Analysis Brief (Section IV.4), and resolve the maximum number of claims in a single proceeding - reducing both docket congestion and Plaintiffs' ongoing exposure to a system that escalates harm in proportion to the duration it is permitted to operate.

Counselor Is Concerned for Plaintiffs' Safety, p. 1 (p. 1-1)

I. PLAINTIFFS' SAFETY REQUIRES COURT ACTION NOW
A. Counselor Is Concerned for Plaintiffs' Safety Plaintiff James C. ("Chris") McNeil’s consulting work helps clients understand and positive impact complex systems by chunking up from events to the patterns, structure, and core mental models behind them. In this role, he submits this brief as a diagnostic tool for the judicial clarity that is needed due to an urgent concern: the physical and psychological safety of the McNeil-Poyer family. Models that explain these high-risk system conditions are discussed later. He is not alone in this concern. Following the nervous breakdown precipitated by harassment and gaslighting by defense, Plaintiff McNeil sought the assistance of a narcissistic abuse recovery specialist, having recognized the fingerprints of the pattern in defense behavior. That counselor has stated, on multiple occasions, that he is concerned for the safety of both Plaintiff McNeil and his wife, Plaintiff Poyer.

I.B - Request for leave to file second amended complaint and shortened answer period, pp. 1-2 (p. 1-2)

B. The Court Must Immediately Grant Leave for the Second Amended Complaint and Amend the Answer Period to End April 2, 2026 That safety requires docket clearing that removes much of the exposure, and that requires immediately granting Plaintiffs' unopposed Motion for Leave to File the Second Amended Complaint. That motion has sat on the docket for 147 days since October 24, 2025. No Defendant has filed opposition. Under SCRCP Rule 15(a), leave "shall be freely given when justice so requires," and the opposing party bears the burden of showing prejudice. Tanner v. Florence County Treasurer, 336 S.C. 552, 558 (1999). No Defendant has attempted to carry that burden. The motion is ripe, and granting it now enables the Court to align all claims for the April 3 hearing - the single most effective action available to reduce Plaintiffs' escalating exposure to harm. Plaintiffs also request that the Court set the answer deadline for the 2AC as April 2, 2026 - one day before the scheduled hearing - rather than the standard 30-day period. This shortened period is appropriate under SCRCP Rule 6(b), which permits the Court to set response periods for cause shown, for the following reasons:
1. The 2AC adds Charles S. Altman as an individual defendant. These are not new facts
to Altman. The probate valuation discrepancies, the CRC ownership structure, and the individual conduct supporting veil-piercing have been documented in filings on this docket since December 2025 - including the Memorandum on Probate Valuations, the Supplemental Memorandum, and the Case Clarity Brief of February 24, 2026. The 2AC consolidates existing evidence into the operative pleading.
2. The 2AC adds the critical image counts. The counts associated with the mass syndicated
private images and virtual tour published without plaintiff consent are added. These are critical allegations and the images were discovered by Plaintiffs after the Amended Complaint was filed and after they had been live for over 10 weeks, including a month when Plaintiffs still lived at 181 Gordon Street.
3. 147 days of silence is itself the answer. The Motion for Leave has been unopposed since
October 24, 2025. During that period, Defendants have filed motions to dismiss, motions to quash subpoenas, motions regarding AI usage, and other procedural filings - demonstrating active engagement with the docket. Their silence on the 2AC is a strategic choice, not a lack of notice. SCRCP Rule 15 envisions prejudice as "a lack of notice that the new issue is going to be tried, and a lack of opportunity to refute it." Tanner, 336 S.C. at 558. Neither condition exists here.
4. The April 3 hearing is a critical safety inflection point. As documented in Section V
and [Exhibit B], the hearing represents a threshold event after which Plaintiffs' exposure to defense volatility increases materially. Consolidating all claims into the operative pleading before that hearing - rather than leaving them pending for an additional 30 days
- directly serves the safety objective that is this brief's primary concern.
Granting the 2AC with an April 2 answer deadline aligns all counts for disposition at the April 3 hearing, enabling the Court to hear the Omnibus Motion (Section IV.3), apply the March 6 Systems Analysis Brief (Section IV.4), and resolve the maximum number of claims in a single proceeding - reducing both docket congestion and Plaintiffs' ongoing exposure to a system that escalates harm in proportion to the duration it is permitted to operate.

Immediate leave for Second Amended Complaint and April 2 answer deadline, pp. 1-2 (p. 1-2)

B. The Court Must Immediately Grant Leave for the Second Amended Complaint and Amend the Answer Period to End April 2, 2026 That safety requires docket clearing that removes much of the exposure, and that requires immediately granting Plaintiffs' unopposed Motion for Leave to File the Second Amended Complaint. That motion has sat on the docket for 147 days since October 24, 2025. No Defendant has filed opposition. Under SCRCP Rule 15(a), leave "shall be freely given when justice so requires," and the opposing party bears the burden of showing prejudice. Tanner v. Florence County Treasurer, 336 S.C. 552, 558 (1999). No Defendant has attempted to carry that burden. The motion is ripe, and granting it now enables the Court to align all claims for the April 3 hearing - the single most effective action available to reduce Plaintiffs' escalating exposure to harm. Plaintiffs also request that the Court set the answer deadline for the 2AC as April 2, 2026 - one day before the scheduled hearing - rather than the standard 30-day period. This shortened period is appropriate under SCRCP Rule 6(b), which permits the Court to set response periods for cause shown, for the following reasons:
1. The 2AC adds Charles S. Altman as an individual defendant. These are not new facts to Altman. The probate valuation discrepancies, the CRC ownership structure, and the individual conduct supporting veil-piercing have been documented in filings on this docket since December 2025 - including the Memorandum on Probate Valuations, the Supplemental Memorandum, and the Case Clarity Brief of February 24, 2026. The 2AC consolidates existing evidence into the operative pleading.
2. The 2AC adds the critical image counts. The counts associated with the mass syndicated private images and virtual tour published without plaintiff consent are added. These are critical allegations and the images were discovered by Plaintiffs after the Amended Complaint was filed and after they had been live for over 10 weeks, including a month when Plaintiffs still lived at 181 Gordon Street.
3. 147 days of silence is itself the answer. The Motion for Leave has been unopposed since October 24, 2025. During that period, Defendants have filed motions to dismiss, motions to quash subpoenas, motions regarding AI usage, and other procedural filings - demonstrating active engagement with the docket. Their silence on the 2AC is a strategic choice, not a lack of notice. SCRCP Rule 15 envisions prejudice as "a lack of notice that the new issue is going to be tried, and a lack of opportunity to refute it." Tanner, 336 S.C. at 558. Neither condition exists here.
4. The April 3 hearing is a critical safety inflection point. As documented in Section V and [Exhibit B], the hearing represents a threshold event after which Plaintiffs' exposure to defense volatility increases materially. Consolidating all claims into the operative pleading before that hearing - rather than leaving them pending for an additional 30 days - directly serves the safety objective that is this brief's primary concern.
Granting the 2AC with an April 2 answer deadline aligns all counts for disposition at the April 3 hearing, enabling the Court to hear the Omnibus Motion (Section IV.3), apply the March 6 Systems Analysis Brief (Section IV.4), and resolve the maximum number of claims in a single proceeding - reducing both docket congestion and Plaintiffs' ongoing exposure to a system that escalates harm in proportion to the duration it is permitted to operate.

I.C. The Scope of Documented Malfeasance (p. 2-3)

To orient the Court to the scale of what the April 3 hearing must address, Plaintiffs attach as
[Exhibit C] the Comprehensive Enforcement Matrix - a single document mapping every
documented violation across all twelve identified actors (five named defendants, three individual
attorneys, two law firms, and the insurer/adjuster) against the criminal, civil, and regulatory
enforcement pathways each violation implicates.
The matrix documents infractions spanning felony forgery (SC § 16-13-10), federal witness
tampering (18 USC § 1512(b)(3)), PMIC trust account violations (SC § 40-57-136), obstruction
of a state regulatory investigation (SC § 40-57-3403), attorney conflicts of interest (SC RPC
1.7(b)(3)), insurance bad faith, and litigation gaslighting producing clinical-severity PTSD (PCL-
5: 76/80) - across twelve defendants and potential defendants.
The matrix makes the scale of harm visible at a glance: the documented conduct spans criminal,
civil, and regulatory domains, involves coordinated action across multiple firms and entities, and
has produced documented harm at every level. The eight relief items in Section III are designed
to collapse as much of this complexity as possible into a manageable number of dispositive
rulings. The matrix is the fuller map; the relief table is the fast route to a safer point.

I.C - Scope of documented malfeasance, pp. 2-3 (p. 2-3)

C. The Scope of Documented Malfeasance To orient the Court to the scale of what the April 3 hearing must address, Plaintiffs attach as [Exhibit C] the Comprehensive Enforcement Matrix - a single document mapping every documented violation across all twelve identified actors (five named defendants, three individual attorneys, two law firms, and the insurer/adjuster) against the criminal, civil, and regulatory enforcement pathways each violation implicates. The matrix documents infractions spanning felony forgery (SC § 16-13-10), federal witness tampering (18 USC § 1512(b)(3)), PMIC trust account violations (SC § 40-57-136), obstruction of a state regulatory investigation (SC § 40-57-3403), attorney conflicts of interest (SC RPC
1.7(b)(3)), insurance bad faith, and litigation gaslighting producing clinical-severity PTSD (PCL-
5: 76/80) - across twelve defendants and potential defendants. The matrix makes the scale of harm visible at a glance: the documented conduct spans criminal, civil, and regulatory domains, involves coordinated action across multiple firms and entities, and has produced documented harm at every level. The eight relief items in Section III are designed to collapse as much of this complexity as possible into a manageable number of dispositive rulings. The matrix is the fuller map; the relief table is the fast route to a safer point.

I.B. Grant Leave and Set Answer Deadline (continued) (p. 2-2)

Defendant has filed opposition. Under SCRCP Rule 15(a), leave "shall be freely given when
justice so requires," and the opposing party bears the burden of showing prejudice. Tanner v.
Florence County Treasurer, 336 S.C. 552, 558 (1999).
No Defendant has attempted to carry that burden. The motion is ripe, and granting it now enables
the Court to align all claims for the April 3 hearing - the single most effective action available to
reduce Plaintiffs' escalating exposure to harm.
Plaintiffs also request that the Court set the answer deadline for the 2AC as April 2, 2026 - one
day before the scheduled hearing - rather than the standard 30-day period. This shortened period
is appropriate under SCRCP Rule 6(b), which permits the Court to set response periods for cause
shown, for the following reasons:
1. The 2AC adds Charles S. Altman as an individual defendant. These are not new facts
to Altman. The probate valuation discrepancies, the CRC ownership structure, and the
individual conduct supporting veil-piercing have been documented in filings on this
docket since December 2025 - including the Memorandum on Probate Valuations, the
Supplemental Memorandum, and the Case Clarity Brief of February 24, 2026. The 2AC
consolidates existing evidence into the operative pleading.
2. The 2AC adds the critical image counts. The counts associated with the mass syndicated
private images and virtual tour published without plaintiff consent are added. These are
critical allegations and the images were discovered by Plaintiffs after the Amended
Complaint was filed and after they had been live for over 10 weeks, including a month
when Plaintiffs still lived at 181 Gordon Street.
3. 147 days of silence is itself the answer. The Motion for Leave has been unopposed since
October 24, 2025. During that period, Defendants have filed motions to dismiss, motions
to quash subpoenas, motions regarding AI usage, and other procedural filings -
demonstrating active engagement with the docket. Their silence on the 2AC is a strategic
choice, not a lack of notice. SCRCP Rule 15 envisions prejudice as "a lack of notice that
the new issue is going to be tried, and a lack of opportunity to refute it." Tanner, 336 S.C.
at 558. Neither condition exists here.
4. The April 3 hearing is a critical safety inflection point. As documented in Section V
and [Exhibit B], the hearing represents a threshold event after which Plaintiffs' exposure to
defense volatility increases materially. Consolidating all claims into the operative
pleading before that hearing - rather than leaving them pending for an additional 30 days
- directly serves the safety objective that is this brief's primary concern.
Granting the 2AC with an April 2 answer deadline aligns all counts for disposition at the April 3
hearing, enabling the Court to hear the Omnibus Motion (Section IV.3), apply the March 6
Systems Analysis Brief (Section IV.4), and resolve the maximum number of claims in a single
proceeding - reducing both docket congestion and Plaintiffs' ongoing exposure to a system that
escalates harm in proportion to the duration it is permitted to operate.

Scope of Documented Malfeasance, p. 3 (p. 3-3)

C. The Scope of Documented Malfeasance To orient the Court to the scale of what the April 3 hearing must address, Plaintiffs attach as [Exhibit C] the Comprehensive Enforcement Matrix - a single document mapping every documented violation across all twelve identified actors (five named defendants, three individual attorneys, two law firms, and the insurer/adjuster) against the criminal, civil, and regulatory enforcement pathways each violation implicates. The matrix documents infractions spanning felony forgery (SC § 16-13-10), federal witness tampering (18 USC § 1512(b)(3)), PMIC trust account violations (SC § 40-57-136), obstruction of a state regulatory investigation (SC § 40-57-3403), attorney conflicts of interest (SC RPC 1.7(b)(3)), insurance bad faith, and litigation gaslighting producing clinical-severity PTSD (PCL-5: 76/80) - across twelve defendants and potential defendants. The matrix makes the scale of harm visible at a glance: the documented conduct spans criminal, civil, and regulatory domains, involves coordinated action across multiple firms and entities, and has produced documented harm at every level. The eight relief items in Section III are designed to collapse as much of this complexity as possible into a manageable number of dispositive rulings. The matrix is the fuller map; the relief table is the fast route to a safer point.

II - Housing Justice Audit, pp. 3-5 (p. 3-5)

I.C. Scope of Documented Malfeasance (p. 2-3)

C. The Scope of Documented Malfeasance
To orient the Court to the scale of what the April 3 hearing must address, Plaintiffs attach as
[Exhibit C] the Comprehensive Enforcement Matrix - a single document mapping every
documented violation across all twelve identified actors (five named defendants, three individual
attorneys, two law firms, and the insurer/adjuster) against the criminal, civil, and regulatory
enforcement pathways each violation implicates.
The matrix documents infractions spanning felony forgery (SC § 16-13-10), federal witness
tampering (18 USC § 1512(b)(3)), PMIC trust account violations (SC § 40-57-136), obstruction
of a state regulatory investigation (SC § 40-57-3403), attorney conflicts of interest (SC RPC
1.7(b)(3)), insurance bad faith, and litigation gaslighting producing clinical-severity PTSD (PCL-
5: 76/80) - across twelve defendants and potential defendants.
The matrix makes the scale of harm visible at a glance: the documented conduct spans criminal,
civil, and regulatory domains, involves coordinated action across multiple firms and entities, and
has produced documented harm at every level. The eight relief items in Section III are designed
to collapse as much of this complexity as possible into a manageable number of dispositive
rulings. The matrix is the fuller map; the relief table is the fast route to a safer point.

Housing Justice Audit purpose and mitigation theory, pp. 3-4 (p. 3-4)

II. THE HOUSING JUSTICE AUDIT (HJA)
The Housing Justice Audit ("HJA") is an application of Plaintiff McNeil's Strategic Thought Leadership (STL) Schema Platform, which had just found product-market fit when the forced move flattened its velocity, which was kept flat by defense exhaustion tactics. The social media graphs documenting the flatlining from August 2025 forward are in evidence. A. Reason for the HJA: Mitigate Damages and Prove Value of Flattened Platform. S.C. Code § 27-40-50(a) imposes an affirmative duty: "The aggrieved party has a duty to mitigate damages." Rather than claiming speculative lost profits from a platform disrupted at its July 2025 growth inflection, Plaintiffs rebuilt the STL platform using the case as a study of response by the Charleston, SC Housing Justice System to a pull for justice from its most vulnerable member or MVM, then designing a system intervention based on its findings. This is now being soft-launched at HousingJusticeAudit.com after a pre-publication draft was released in February. This creates an opportunity for direct experience of merit by a jury for the purpose of determining punitive damages for destroying a platform of value at a critical time.

III - Relief requested, pp. 5-8 (p. 5-8)

III. RELIEF REQUESTED: EIGHT HIGH-LEVERAGE
MITIGATION ACTIONS
The Ask–Harm Loop documented in Section II operates through a specific mechanism: each unresolved motion generates a new cycle of adversarial filings, mischaracterizations, and deadline pressure that compounds Plaintiff McNeil's clinical PTSD (PCL-5: 76/80) and reduces his functional capacity - currently estimated at approximately 30%. Deemed admissions and summary judgments structurally eliminate the motion cycles through which the harm is delivered. Every count resolved on April 3 is a count that cannot generate another round of discovery obstruction, another sanctions threat, another mischaracterization to court staff, another DARVO escalation. The attrition strategy functions only as long as liability remains contestable; once it is judicially fixed, the engine that converts "ask for justice" into "harm to the person asking" loses its fuel Each action below is a leverage point: resolving it removes a structural condition that sustains the Ask–Harm Loop, collapses defense attrition capacity, or both. The Court can treat this table as a checklist for the April 3 hearing - every item has been briefed, every evidentiary basis has been filed, and zero items have received a substantive defense response on the merits. Disqualifying conflicted counsel (#7–8) removes the human actors operating that engine. Granting veil-piercing discovery (#5) and applying unclean hands (#6) activate the Altmans' rational self-interest - the one force documented in the Statement of Systemic Risk as powerful enough to override every other condition in the system, but which captured counsel has kept dormant by filtering information under a "these harms did not happen" absence of narrative. The Court can treat this table as a checklist for the April 3 hearing: every item has been briefed, every evidentiary basis has been filed, and zero items have received a substantive defense response on the merits.

II. Housing Justice Audit (p. 3-3)

II. THE HOUSING JUSTICE AUDIT (HJA)
The Housing Justice Audit ("HJA") is an application of Plaintiff McNeil's Strategic Thought
Leadership (STL) Schema Platform, which had just found product-market fit when the forced
move flattened its velocity, which was kept flat by defense exhaustion tactics. The social media
graphs documenting the flatlining from August 2025 forward are in evidence.

HJA diagnostic framework and Conscious Co-Stewardship, pp. 3-4 (p. 3-4)

III - Third Amended Complaint notice, p. 8 (p. 8-8)

Third Amended Complaint Plaintiffs also place the Court and all parties on notice that they plan to file a Motion for Leave to File a Third Amended Complaint that will add additional entities and individuals as defendants and is based on conduct that includes but is not necessarily limited to that which arose during this litigation. Plaintiffs plan to file filing this motion concurrently with a law firm litigation partner officially entering the case. This notice is provided now so the Court can weigh the full trajectory of the case when evaluating the eight relief items above.

II.A. Reason for HJA (p. 3-3)

A. Reason for the HJA: Mitigate Damages and Prove Value of Flattened Platform.
S.C. Code § 27-40-50(a) imposes an affirmative duty: "The aggrieved party has a duty to
mitigate damages." Rather than claiming speculative lost profits from a platform disrupted at its
July 2025 growth inflection, Plaintiffs rebuilt the STL platform using the case as a study of
response by the Charleston, SC Housing Justice System to a pull for justice from its most
vulnerable member or MVM, then designing a system intervention based on its findings. This is
now being soft-launched at HousingJusticeAudit.com after a pre-publication draft was released
in February.
This creates an opportunity for direct experience of merit by a jury for the purpose of
determining punitive damages for destroying a platform of value at a critical time.

HJA risk amplification and jury psychology, pp. 4-5 (p. 4-5)

C. The HJA Unintentionally Elevates Risk Substantially Since this has set up a viscous cycle of escalating harm as the harm requires more sophisticated asks for justice, which triggers more harm, it is concerning to consider the escalation of harm that could be triggered by the “Ask” of the Housing Justice Audit and the full impact it will have. The same instrument that gives the Court clarity gives a jury purpose, and this is what elevates Defendants' exposure into the range that triggers the safety conditions documented in [Exhibit B]. Peer-reviewed jury psychology research confirms what the HJA's trial function means for verdict range: Sunstein, Hastie & Payne (Punitive Damages: How Juries Decide, 2002): deliberation produces a "severity shift toward ever-higher awards," and jurors specifically penalize calculated institutional indifference. Hans (What's It Worth?, Wm. & Mary L. Rev., 2014): damage awards function as "powerful political actions by the civil jury" that "serve to check or endorse private power". Gabriel & Shaw (Law360, 2024): "juror activism" occurs "where a jury believes that its verdict should have a social message above the actual evidence" — and perceived institutional resistance escalates this impulse. Every amplifying condition is present. Charleston jurors in 2026 are in a housing market where rents have risen 51% while wages rose 31%. They will experience a platform built to change how housing treats its most vulnerable participants. The resulting credible verdict range creates an existential threat to the Altman's entire portfolio, as documented in the sealed [Exhibit A]

IV - Judicial path to clearing the docket, pp. 8-11 (p. 8-11)

IV . JUDICIAL PATH TO CLEARING THE DOCKET
The Court possesses full authority under existing South Carolina procedural rules and inherent judicial power to act on all eight relief items at the April 3, 2026 hearing. No extraordinary procedure is required. Each action maps to established authority the Court exercises routinely: Each rests on rules and precedents the Court applies in ordinary civil practice. The thing that current stands out about this case is the duration of defense silence on the merits. And the procedural rules exist precisely to address that condition. This is how these impact the four motions currently noticed for the April 3, 2026 hearing before Judge McCoy. MQUASH — Motion to Quash Deposition Defense
(LLR
subpoena) Plaintiffs request this motion remain on the hearing. Plaintiffs oppose the quash and want LLR's counsel present, as the regulatory obstruction documented in the Enforcement Matrix [Exhibit C] is central to multiple claims. MMSTAY — Motion of Joinder for Motion to Stay Defense Rendered moot if the Court grants the Omnibus disposition (#3 below). A stay presupposes contested claims; summary judgment and deemed admissions on Counts I–VI eliminate the claims the stay is designed to delay.
MOFREE —
Supplemental Motion/ADA Accommodations Plaintiffs Remains live regardless of other outcomes. Plaintiff McNeil's clinical PTSD (PCL-5: 76/80) and reduced functional capacity require ADA accommodations - including e-filing access and remote appearance authorization — whether or not the Omnibus disposition resolves the underlying claims. These accommodations serve the duration of the litigation.
MOFREE —
Emergency Motion/Protective Relief & Maintain Assignment Plaintiffs Remains live as fallback relief. If the Court grants the Omnibus disposition and disqualifies conflicted counsel, the protective relief and communication protocols become substantially less urgent because the primary engines of the Ask–Harm Loop have been removed. If the Court does not reach those items, the Emergency Motion becomes more urgent, not less - the health-based protective measures, court-ordered communication monitor, and case- management protocols originally requested remain essential to prevent further deterioration of Plaintiff McNeil's functional capacity.

II.B. HJA as Key to Fast Clarity (p. 3-4)

V - Defendants' exposure and settlement window, pp. 11-14 (p. 11-14)

V . DEFENDANTS' EXPOSURE AND THE SETTLEMENT
WINDOW
Three sealed exhibits accompany this filing, each modeling Defendants' financial exposure from a distinct analytical starting point. Together they form a progression from floor to ceiling to catastrophe: • Exhibit A1: The HJA as Instrument of Systemic Impact. This model accounts for the behavioral reality documented in peer-reviewed jury psychology research: when jurors perceive their verdict as an instrument of systemic change, they write numbers that function as policy rather than compensation. The model stacks comparable verdicts and applies the aggravating differential present in this case across every comparable dimension, including three novel categories with no known ceiling. Under SC § 15-32- 530, punitive damages are uncapped for intentional conduct. • Exhibit A2: Conservative Verdict Modeling with Judicial Estoppel & Collection Analysis. This model excludes the HJA's amplifying effect on jury behavior entirely and calculates a floor based on documented, largely uncontested compensatory categories with a conservative punitive multiplier below the range typical in comparable SC cases. It then maps what judicial estoppel does to even that modest number when collected against Defendants' own sworn probate valuations. • Exhibit A3: Worst-Case Combined Exposure -High Verdict + Estoppel Collection. This is where the two models converge into a defense catastrophe. The collection analysis demonstrates what happens when a jury award informed by systemic- change psychology is collected against assets priced at Defendants' own sworn probate figures. The estoppel trap permits no favorable resolution: accepting sworn values means asset loss at pennies on the dollar; rejecting sworn values constitutes an admission of material misrepresentation in probate proceedings, opening perjury exposure, probate fraud referral, and tax liability. Specific modeling figures are contained in the sealed exhibits and are not reproduced here. What the Court needs to know for purposes of this public filing is the structural dynamic: Plaintiffs will make a settlement offer available to the property ownership group with the April 3 hearing as the deadline. If the April 3 hearing happens, that means the settlement window did not produce a result and Plaintiffs are operating in high-risk systems conditions. The System Conditions That Make This Urgent The Statement of Systemic Risk [Exhibit B] documents twelve interlocking conditions - seven currently operating, five predicted to activate at the April 3 threshold. The critical dynamic: the Altman family may be operating in Pre-Shock Latency (Condition 7)
- they likely have not yet processed the full scope of their collection exposure because captured
counsel has been filtering information under the false narrative that this is "just a deposit dispute". The April 3 hearing is the bifurcation point where that false narrative becomes unsustainable. When deemed admissions, partial summary judgments, or the veil-piercing discovery order converts liability from speculative to fixed, Prospect Theory (Kahneman & Tversky, 1979) predicts the result: when all outcomes are perceived as losses, the system shifts to extreme risk- seeking. The marginal cost of further escalation drops to zero. The system is no longer fighting for a result - it is fighting for existence.

Eight high-leverage mitigation actions—overview, pp. 5-6 (p. 5-6)

III. RELIEF REQUESTED: EIGHT HIGH-LEVERAGE
MITIGATION ACTIONS
The Ask–Harm Loop documented in Section II operates through a specific mechanism: each unresolved motion generates a new cycle of adversarial filings, mischaracterizations, and deadline pressure that compounds Plaintiff McNeil's clinical PTSD (PCL-5: 76/80) and reduces his functional capacity - currently estimated at approximately 30%. Deemed admissions and summary judgments structurally eliminate the motion cycles through which the harm is delivered. Every count resolved on April 3 is a count that cannot generate another round of discovery obstruction, another sanctions threat, another mischaracterization to court staff, another DARVO escalation. The attrition strategy functions only as long as liability remains contestable; once it is judicially fixed, the engine that converts "ask for justice" into "harm to the person asking" loses its fuel Each action below is a leverage point: resolving it removes a structural condition that sustains the Ask–Harm Loop, collapses defense attrition capacity, or both. The Court can treat this table as a checklist for the April 3 hearing - every item has been briefed, every evidentiary basis has been filed, and zero items have received a substantive defense response on the merits. Disqualifying conflicted counsel (#7–8) removes the human actors operating that engine. Granting veil-piercing discovery (#5) and applying unclean hands (#6) activate the Altmans' rational self-interest - the one force documented in the Statement of Systemic Risk as powerful enough to override every other condition in the system, but which captured counsel has kept dormant by filtering information under a "these harms did not happen" absence of narrative. The Court can treat this table as a checklist for the April 3 hearing: every item has been briefed, every evidentiary basis has been filed, and zero items have received a substantive defense response on the merits.

II.C. HJA Elevates Risk (p. 4-5)

C. The HJA Unintentionally Elevates Risk Substantially
Since this has set up a viscous cycle of escalating harm as the harm requires more sophisticated
asks for justice, which triggers more harm, it is concerning to consider the escalation of harm
that could be triggered by the “Ask” of the Housing Justice Audit and the full impact it will have.
The same instrument that gives the Court clarity gives a jury purpose, and this is what elevates
Defendants' exposure into the range that triggers the safety conditions documented in [Exhibit
B].
Peer-reviewed jury psychology research confirms what the HJA's trial function means for verdict
range:
Sunstein, Hastie & Payne (Punitive Damages: How Juries Decide, 2002): deliberation produces a
"severity shift toward ever-higher awards," and jurors specifically penalize calculated
institutional indifference.
Hans (What's It Worth?, Wm. & Mary L. Rev., 2014): damage awards function as "powerful
political actions by the civil jury" that "serve to check or endorse private power".
Gabriel & Shaw (Law360, 2024): "juror activism" occurs "where a jury believes that its verdict
should have a social message above the actual evidence" — and perceived institutional resistance
escalates this impulse.
Every amplifying condition is present. Charleston jurors in 2026 are in a housing market where
rents have risen 51% while wages rose 31%. They will experience a platform built to change
how housing treats its most vulnerable participants. The resulting credible verdict range creates
an existential threat to the Altman's entire portfolio, as documented in the sealed [Exhibit A]

VI - Public filing and transparency rationale, p. 14 (p. 14-14)

VI. WHY DELAY INCREASES RISK AND WHY THIS FILING IS
PUBLIC
The Statement of Systemic Risk [Exhibit B] documents five post-threshold system conditions predicted to activate when the April 3 hearing converts liability from speculative to fixed. Each is supported by a recognized academic model and documented in the case record: These conditions are sequential and compounding. Activated condition creates the input that triggers the next. The April 3 hearing is a potential trigger event. This filing is on the public record because transparency is the primary protective mechanism available. A system that knows it is being watched behaves differently than one operating in shadows. Respectfully submitted this 20 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

Eight requested rulings and supporting filings, pp. 6-8 (p. 6-8)

1 Grant Leave to File Second Amended Complaint Pending 148+ days with no opposition; adds 21 image-exploitation counts, adds Charles S. Altman individually for negligent retention/supervision and veil-piercing; SCRCP 15(a) mandates leave "freely given when justice so requires." Motion for Leave, 10/24/25 2 Order April 2 2026 Answer Deadline on 2AC Case is 11 months old; Defendants have had notice of all underlying facts since October 2025; a short deadline prevents the 2AC from becoming a new attrition vehicle and forecloses further delay. This aligns the images counts with the April 3 hearing and enables the below: Omnibus Request ¶12, 2/24/26 3 Rule on Omnibus Motion (Counts I–
VI)
Seven of eight substantive matters have received zero defense engagement on the merits in 167+ days; full summary judgment on Counts I (treble deposit) and III (breach), partial summary judgment on liability for Counts II (fraud), IV (retaliation), V (habitability), and VI (veil-piercing) per SCRCP 56; deemed admissions per SCRCP 36 where RFA Sufficiency Motion of 12/23/25 remains unanswered. Omnibus Brief,
2/24/26; RFA
Sufficiency Motion, 12/23/25 4 Adopt March 6 Systems Analysis Brief as Judicial Framework The Brief demonstrates defense has no counter-narrative - only procedural friction (noise) and silence; provides the Court a single-read path to disposition without extended adversarial proceedings. Systems Analysis Brief, 3/6/26 5 Order Veil- Piercing Discovery into CRC Portfolio Flash Transfer of 181 Gordon for $5.00 on the same day as estate distribution (2/21/07); 95% Charles Realty stock devaluation ($30K/share → $1,392/share) during Charleston's historic real estate boom; SAC 181 OP account bearing Meridian's address with Tara's signature - 82+ days with zero response from any defense firm. Probate Memo, 12/3/25; Supplemental Memo (Flash Transfer), 12/11/25 6 Apply Unclean Hands and Judicial Estoppel Jonathan S. Altman swore to Probate Court that SAC 181's asset was worth $251K while the property generates $63K/year in rent (cap- rate value: $1.27M) and adjacent 182 Gordon sold for $1.1M - Defendants cannot assert contradictory valuations in two courts.; Public hypocrisy of him simultaneously serving on Charleston's Homeownership Initiative Commission while being beneficial owner of a property at the center of an exploitation lawsuit - enables the Unclean Hands doctrine. Probate Memo, 12/3/25; Supplemental Memo, 12/11/25 7 Disqualify Resnick & Louis (Bolyard) Unconsentable conflict under SC RPC
1.7(b)(3): Meridian's own crossclaim (Answer
¶¶114–125) requires proving SAC 181's operational control and commingling, yet Bolyard simultaneously quashes the Synovus subpoena that would prove it - logically irreconcilable positions for the same counsel in the same proceeding; compounded by witness tampering (Meridian's 1/9/26 contact with AppFolio instructing non-compliance). Cross-Motion to Disqualify, 1/14/26 8 Disqualify Phelps Dunbar (Tate/O'Brien) Quash motion filed one day after SCRCP 45(d)(2)(B) deadline (waived under Ex parte Smith); 32 days of silence on Flash Transfer allegations while minimizing eight-count fraud as "deposit dispute"; captured-counsel dynamic - blocking Synovus discovery that would prove their own client's corporate separateness defense, sacrificing SAC 181's veil-piercing defense to protect non-client Tara Bayles' PMIC license. Cross-Motion to Disqualify, 1/14/26; Omnibus Brief, 2/24/26

III. Relief Requested (p. 5-8)

III. RELIEF REQUESTED: EIGHT HIGH-LEVERAGE
MITIGATION ACTIONS
The Ask–Harm Loop documented in Section II operates through a specific mechanism: each
unresolved motion generates a new cycle of adversarial filings, mischaracterizations, and
deadline pressure that compounds Plaintiff McNeil's clinical PTSD (PCL-5: 76/80) and reduces
his functional capacity - currently estimated at approximately 30%.
Deemed admissions and summary judgments structurally eliminate the motion cycles through
which the harm is delivered. Every count resolved on April 3 is a count that cannot generate
another round of discovery obstruction, another sanctions threat, another mischaracterization to
court staff, another DARVO escalation. The attrition strategy functions only as long as liability
remains contestable; once it is judicially fixed, the engine that converts "ask for justice" into
"harm to the person asking" loses its fuel
Each action below is a leverage point: resolving it removes a structural condition that sustains
the Ask–Harm Loop, collapses defense attrition capacity, or both. The Court can treat this table
as a checklist for the April 3 hearing - every item has been briefed, every evidentiary basis has
been filed, and zero items have received a substantive defense response on the merits.
Disqualifying conflicted counsel (#7–8) removes the human actors operating that engine.
Granting veil-piercing discovery (#5) and applying unclean hands (#6) activate the Altmans'
rational self-interest - the one force documented in the Statement of Systemic Risk as powerful
enough to override every other condition in the system, but which captured counsel has kept
dormant by filtering information under a "these harms did not happen" absence of narrative.
The Court can treat this table as a checklist for the April 3 hearing: every item has been briefed,
every evidentiary basis has been filed, and zero items have received a substantive defense
response on the merits.
# Relief Requested One-Sentence Basis
Filed / Supported
By
1
Grant Leave to
File Second
Amended
Complaint
Pending 148+ days with no opposition; adds
21 image-exploitation counts, adds Charles S.
Altman individually for negligent
retention/supervision and veil-piercing;
SCRCP 15(a) mandates leave "freely given
when justice so requires."
Motion for Leave,
10/24/25
2
Order April 2
2026 Answer
Deadline on 2AC
Case is 11 months old; Defendants have had
notice of all underlying facts since October
2025; a short deadline prevents the 2AC from
becoming a new attrition vehicle and
forecloses further delay. This aligns the
images counts with the April 3 hearing and
enables the below:
Omnibus Request
¶12, 2/24/26
3
Rule on Omnibus
Motion (Counts I–
VI)
Seven of eight substantive matters have
received zero defense engagement on the
merits in 167+ days; full summary judgment
on Counts I (treble deposit) and III (breach),
partial summary judgment on liability for
Counts II (fraud), IV (retaliation), V
(habitability), and VI (veil-piercing) per
SCRCP 56; deemed admissions per SCRCP 36
where RFA Sufficiency Motion of 12/23/25
remains unanswered.
Omnibus Brief,
2/24/26; RFA
Sufficiency
Motion, 12/23/25
4
Adopt March 6
Systems Analysis
Brief as Judicial
Framework
The Brief demonstrates defense has no
counter-narrative - only procedural friction
(noise) and silence; provides the Court a
Systems Analysis
Brief, 3/6/26
# Relief Requested One-Sentence Basis
Filed / Supported
By
single-read path to disposition without
extended adversarial proceedings.
5
Order Veil-
Piercing Discovery
into CRC
Portfolio
Flash Transfer of 181 Gordon for $5.00 on the
same day as estate distribution (2/21/07); 95%
Charles Realty stock devaluation ($30K/share
→ $1,392/share) during Charleston's historic
real estate boom; SAC 181 OP account bearing
Meridian's address with Tara's signature - 82+
days with zero response from any defense firm.
Probate Memo,
12/3/25;
Supplemental
Memo (Flash
Transfer),
12/11/25
6
Apply Unclean
Hands and
Judicial Estoppel
Jonathan S. Altman swore to Probate Court
that SAC 181's asset was worth $251K while
the property generates $63K/year in rent (cap-
rate value: $1.27M) and adjacent 182 Gordon
sold for $1.1M - Defendants cannot assert
contradictory valuations in two courts.; Public
hypocrisy of him simultaneously serving on
Charleston's Homeownership Initiative
Commission while being beneficial owner of a
property at the center of an exploitation
lawsuit - enables the Unclean Hands doctrine.
Probate Memo,
12/3/25;
Supplemental
Memo, 12/11/25
7
Disqualify Resnick
& Louis (Bolyard)
Unconsentable conflict under SC RPC
1.7(b)(3): Meridian's own crossclaim (Answer
¶¶114–125) requires proving SAC 181's
operational control and commingling, yet
Bolyard simultaneously quashes the Synovus
subpoena that would prove it - logically
irreconcilable positions for the same counsel
in the same proceeding; compounded by
witness tampering (Meridian's 1/9/26 contact
with AppFolio instructing non-compliance).
Cross-Motion to
Disqualify,
1/14/26
8
Disqualify Phelps
Dunbar
(Tate/O'Brien)
Quash motion filed one day after SCRCP
45(d)(2)(B) deadline (waived under Ex parte
Smith); 32 days of silence on Flash Transfer
allegations while minimizing eight-count fraud
as "deposit dispute"; captured-counsel
dynamic - blocking Synovus discovery that
would prove their own client's corporate
separateness defense, sacrificing SAC 181's
Cross-Motion to
Disqualify,
1/14/26; Omnibus
Brief, 2/24/26
veil-piercing defense to protect non-client Tara
Bayles' PMIC license.
Why These Eight and Why Now
These eight independent requests form a cascade.
• Granting #1 (2AC leave) and #2 (short answer deadline) adds Charles S. Altman and the
image counts, closing the entity gap.
• Ruling on #3 (Omnibus) enters liability on the counts where defense silence has
functioned as concession.
• Adopting #4 (March 6 Brief) gives the Court the framework to do so efficiently.
• Ordering #5 (CRC discovery) exposes the portfolio assets that make judgment
collectible.
• Applying #6 (unclean hands/estoppel) locks Defendants to their own sworn valuations -
they cannot claim $251K in Probate Court and $1.27M in this Court.
• And disqualifying the conflicted firms (#7–8) removes the two engines of the coordinated
obstruction that has driven every motion to quash, every deposition delay, every
mischaracterization to court staff, and every "deposit dispute" narrative that obscures
what is actually an eight-count fraud, retaliation, and privacy case with veil-piercing and
probate-fraud dimensions.

Exhibits A1-A3 sealed-exhibit notice, p. 15 (p. 15-15)

EXHIBIT A1
The HJA as Instrument of Systemic Impact.

EXHIBIT A2
Conservative Verdict Modeling with Judicial Estoppel & Collection Analysis

EXHIBIT A3
Worst-Case Combined Exposure -High Verdict + Estoppel Collection

Exhibits A1–A3 are filed under seal pursuant to SCRCP Rule 41.1 and the accompanying Motion to Seal. Originals submitted separately for in camera review.

Why These Eight and Why Now; planned Third Amended Complaint, p. 8 (p. 8-8)

Why These Eight and Why Now These eight independent requests form a cascade. • Granting #1 (2AC leave) and #2 (short answer deadline) adds Charles S. Altman and the image counts, closing the entity gap. • Ruling on #3 (Omnibus) enters liability on the counts where defense silence has functioned as concession. • Adopting #4 (March 6 Brief) gives the Court the framework to do so efficiently. • Ordering #5 (CRC discovery) exposes the portfolio assets that make judgment collectible. • Applying #6 (unclean hands/estoppel) locks Defendants to their own sworn valuations - they cannot claim $251K in Probate Court and $1.27M in this Court. • And disqualifying the conflicted firms (#7–8) removes the two engines of the coordinated obstruction that has driven every motion to quash, every deposition delay, every mischaracterization to court staff, and every "deposit dispute" narrative that obscures what is actually an eight-count fraud, retaliation, and privacy case with veil-piercing and probate-fraud dimensions. Third Amended Complaint Plaintiffs also place the Court and all parties on notice that they plan to file a Motion for Leave to File a Third Amended Complaint that will add additional entities and individuals as defendants and is based on conduct that includes but is not necessarily limited to that which arose during this litigation. Plaintiffs plan to file filing this motion concurrently with a law firm litigation partner officially entering the case. This notice is provided now so the Court can weigh the full trajectory of the case when evaluating the eight relief items above.

Third Amended Complaint Notice (p. 8-8)

Third Amended Complaint
Plaintiffs also place the Court and all parties on notice that they plan to file a Motion for Leave
to File a Third Amended Complaint that will add additional entities and individuals as
defendants and is based on conduct that includes but is not necessarily limited to that which
arose during this litigation. Plaintiffs plan to file filing this motion concurrently with a law firm
litigation partner officially entering the case.
This notice is provided now so the Court can weigh the full trajectory of the case when
evaluating the eight relief items above.

Exhibit B - Statement of Systemic Risk and Behavioral Volatility, pp. 16-29 (p. 16-29)

EXHIBIT B
Statement of Systemic Risk and Behavioral Volatility Purpose Plaintiffs submit this analysis to identify, for the Court’s awareness,
1. A set of interlocking system conditions that are currently generating escalating risk to
Plaintiffs’ safety and impacting their well-being, and
2. A second set of conditions that will be triggered by the April 3, 2026 hearing as a
threshold event. The analysis draws on established behavioral economics, forensic psychology, and organizational systems research to explain why the defense system is operating as it is, and why the hearing will predictably intensify the threat. These are documented behavioral patterns with peer-reviewed predictive models. Plaintiffs present them transparently to the Court because observation is itself a dampening mechanism for the volatility described. Implication for Plaintiffs’ Safety Plaintiffs’ counselor has expressed deep concern for the McNeil-Poyer family’s safety after reviewing the high-stakes dynamics of this case alongside the documented pattern of systemic dehumanization. That concern is grounded in the following convergence: • A system already operating under Stage 1 CAS with documented escalation after notice • Captured counsel filtering information from the principals who could intervene • Regulatory and law enforcement bodies that have failed to provide protection • A threshold event (April 3) that creates conditions favoring converting managed risk to existential panic • An exposed target family that includes a Plaintiff with clinical PTSD (PCL-5: 76/80) and a documented history of being told by victim services: “We don’t help people like you” • Defendants with established capacity for dehumanization (“Trick residents so company can make more money”) and escalation (two law firms deployed for lawfare against pro se plaintiffs) Plaintiffs ask the Court to observe that established behavioral models - Prospect Theory, narcissistic collapse literature, institutional DARVO research, and systems dynamics - converge on the same prediction: that the April 3 hearing sets up conditions that historically trigger a measurable increase in volatility, and that transparency and judicial awareness are the primary mechanisms available to dampen that volatility before it produces irreversible harm. This analysis is filed on the public record because observation is itself a protective measure. A system that knows it is being watched behaves differently than one that operates in shadow.

Judicial authority and path to clearing the docket, pp. 8-10 (p. 8-10)

IV . JUDICIAL PATH TO CLEARING THE DOCKET
The Court possesses full authority under existing South Carolina procedural rules and inherent judicial power to act on all eight relief items at the April 3, 2026 hearing. No extraordinary procedure is required. Each action maps to established authority the Court exercises routinely: #1 – Grant Leave (2AC) SCRCP Rule 15(a) "Leave shall be freely given when justice so requires." 148+ days pending, no opposition filed. Unopposed motions for leave are granted as a matter of course. #2 – 7-Day Answer Deadline SCRCP Rule 12(a); Chambers v. NASCO, Inc., 501 U.S. 32 (1991) Court's inherent case-management authority to set deadlines that prevent attrition abuse. Defendants have had notice of all underlying facts since 10/24/25. #3 – Omnibus Disposition (Counts I–VI) SCRCP Rule 56 (summary judgment); SCRCP Rule 36(a) (deemed admissions); SCRCP Rule 37 (discovery sanctions) Rule 56: judgment as a matter of law where no genuine issue of material fact exists - 167+ days of zero substantive defense on core documentary evidence satisfies this standard. Rule 36(a): evasive or insufficient RFA responses deemed admitted upon motion - RFA Sufficiency Motion of 12/23/25 pending 88+ days without response. Rule 37: failure to comply with discovery obligations supports sanctions up to adverse inference, striking of pleadings, or default. #4 – Adopt March 6 Brief as Framework Chambers v. NASCO,
501 U.S. 32 (1991);
inherent judicial authority Courts possess inherent authority to manage complex litigation, organize the record, and adopt analytical frameworks that promote judicial economy.
#5 – CRC
Portfolio Discovery SCRCP Rule 26(b)(1); SCRCP Rule 37(a) Rule 26(b)(1): discovery of any matter relevant to the subject matter - probate records, Charles Realty holdings, and SAC 181 capitalization are directly relevant to veil-piercing (Count VI). Rule 37(a): motion to compel where 82+ days of zero response constitutes failure to respond. #6 – Unclean Hands / Judicial Estoppel SC equitable doctrine; Hayne Federal Credit Union v. Bailey, 327 S.C. 242 (Ct. App. 1997) (judicial estoppel); inherent equitable authority Judicial estoppel bars a party from asserting a position in one court inconsistent with a position successfully maintained in another. Jonathan Altman's sworn $251K probate valuation vs. $1.27M cap-rate value is the textbook application. Unclean hands bars equitable relief for a party whose own conduct is inequitable in the matter at issue. #7 – Disqualify Resnick & Louis SC RPC 1.7(b)(3); Matter of Unnamed Member of S.C. Bar, 313 S.C. 229 (1993); Burdette v. Burdette, 296 S.C. 297 (Ct. App. 1988) Disqualification is mandatory where dual representation requires logically contradictory positions in the same proceeding. Bolyard's simultaneous advocacy for Meridian's indemnity crossclaim and against the Synovus subpoena that would prove it is the definition of unconsentable conflict. #8 – Disqualify Phelps Dunbar SCRCP Rule 45(d)(2)(B) (waiver — untimely quash); Ex parte Smith,
407 S.C. 422 (2014); SC
RPC 1.4(a)(3); inherent authority Quash motion filed Day 20, one day after the 19- day deadline - waived under Ex parte Smith without further analysis. Captured-counsel conduct (blocking evidence that would support own client's defense) independently warrants disqualification under inherent authority to protect proceedings integrity. Each rests on rules and precedents the Court applies in ordinary civil practice. The thing that current stands out about this case is the duration of defense silence on the merits. And the procedural rules exist precisely to address that condition.

IV. Judicial Path to Clearing the Docket (p. 8-11)

IV . JUDICIAL PATH TO CLEARING THE DOCKET
The Court possesses full authority under existing South Carolina procedural rules and inherent
judicial power to act on all eight relief items at the April 3, 2026 hearing. No extraordinary
procedure is required. Each action maps to established authority the Court exercises routinely:
Relief Item Governing Authority Application
#1 – Grant
Leave (2AC)
SCRCP Rule 15(a)
"Leave shall be freely given when justice so
requires." 148+ days pending, no opposition
filed. Unopposed motions for leave are granted
as a matter of course.
#2 – 7-Day
Answer
Deadline
SCRCP Rule 12(a);
Chambers v. NASCO,
Inc., 501 U.S. 32 (1991)
Court's inherent case-management authority to
set deadlines that prevent attrition abuse.
Defendants have had notice of all underlying
facts since 10/24/25.
#3 – Omnibus
Disposition
(Counts I–VI)
SCRCP Rule 56
(summary judgment);
SCRCP Rule 36(a)
(deemed admissions);
SCRCP Rule 37
(discovery sanctions)
Rule 56: judgment as a matter of law where no
genuine issue of material fact exists - 167+
days of zero substantive defense on core
documentary evidence satisfies this standard.
Rule 36(a): evasive or insufficient RFA
responses deemed admitted upon motion -
RFA Sufficiency Motion of 12/23/25 pending
88+ days without response. Rule 37: failure to
comply with discovery obligations supports
sanctions up to adverse inference, striking of
pleadings, or default.
#4 – Adopt
March 6 Brief
as Framework
Chambers v. NASCO,
501 U.S. 32 (1991);
inherent judicial authority
Courts possess inherent authority to manage
complex litigation, organize the record, and
adopt analytical frameworks that promote
judicial economy.
#5 – CRC
Portfolio
Discovery
SCRCP Rule 26(b)(1);
SCRCP Rule 37(a)
Rule 26(b)(1): discovery of any matter relevant
to the subject matter - probate records, Charles
Realty holdings, and SAC 181 capitalization are
directly relevant to veil-piercing (Count VI).
Rule 37(a): motion to compel where 82+ days of
zero response constitutes failure to respond.
#6 – Unclean
Hands /
Judicial
Estoppel
SC equitable doctrine;
Hayne Federal Credit
Union v. Bailey, 327 S.C.
242 (Ct. App. 1997)
(judicial estoppel);
inherent equitable
authority
Judicial estoppel bars a party from asserting a
position in one court inconsistent with a position
successfully maintained in another. Jonathan
Altman's sworn $251K probate valuation vs.
$1.27M cap-rate value is the textbook
application. Unclean hands bars equitable relief
for a party whose own conduct is inequitable in
the matter at issue.
Relief Item Governing Authority Application
#7 –
Disqualify
Resnick &
Louis
SC RPC 1.7(b)(3);
Matter of Unnamed
Member of S.C. Bar, 313
S.C. 229 (1993); Burdette
v. Burdette, 296 S.C. 297
(Ct. App. 1988)
Disqualification is mandatory where dual
representation requires logically contradictory
positions in the same proceeding. Bolyard's
simultaneous advocacy for Meridian's indemnity
crossclaim and against the Synovus subpoena
that would prove it is the definition of
unconsentable conflict.
#8 –
Disqualify
Phelps
Dunbar
SCRCP Rule 45(d)(2)(B)
(waiver — untimely
quash); Ex parte Smith,
407 S.C. 422 (2014); SC
RPC 1.4(a)(3); inherent
authority
Quash motion filed Day 20, one day after the 19-
day deadline - waived under Ex parte Smith
without further analysis. Captured-counsel
conduct (blocking evidence that would support
own client's defense) independently warrants
disqualification under inherent authority to
protect proceedings integrity.
Each rests on rules and precedents the Court applies in ordinary civil practice. The thing that
current stands out about this case is the duration of defense silence on the merits. And the
procedural rules exist precisely to address that condition.
This is how these impact the four motions currently noticed for the April 3, 2026 hearing before
Judge McCoy.
Noticed Motion Filed By Status Under This Brief
MQUASH — Motion to
Quash Deposition
Defense
(LLR
subpoena)
Plaintiffs request this motion remain on the
hearing. Plaintiffs oppose the quash and want LLR's
counsel present, as the regulatory obstruction
documented in the Enforcement Matrix [Exhibit C]
is central to multiple claims.
MMSTAY — Motion of
Joinder for Motion to
Stay
Defense
Rendered moot if the Court grants the Omnibus
disposition (#3 below). A stay presupposes
contested claims; summary judgment and deemed
admissions on Counts I–VI eliminate the claims the
stay is designed to delay.
MOFREE —
Supplemental
Motion/ADA
Accommodations
Plaintiffs
Remains live regardless of other outcomes.
Plaintiff McNeil's clinical PTSD (PCL-5: 76/80) and
reduced functional capacity require ADA
accommodations - including e-filing access and
remote appearance authorization — whether or not
the Omnibus disposition resolves the underlying
Noticed Motion Filed By Status Under This Brief
claims. These accommodations serve the duration of
the litigation.
MOFREE —
Emergency
Motion/Protective
Relief & Maintain
Assignment
Plaintiffs
Remains live as fallback relief. If the Court grants
the Omnibus disposition and disqualifies conflicted
counsel, the protective relief and communication
protocols become substantially less urgent because
the primary engines of the Ask–Harm Loop have
been removed. If the Court does not reach those
items, the Emergency Motion becomes more urgent,
not less - the health-based protective measures,
court-ordered communication monitor, and case-
management protocols originally requested remain
essential to prevent further deterioration of Plaintiff
McNeil's functional capacity.

Effect on motions noticed for April 3 hearing, pp. 10-11 (p. 10-11)

This is how these impact the four motions currently noticed for the April 3, 2026 hearing before Judge McCoy. MQUASH — Motion to Quash Deposition Defense
(LLR
subpoena) Plaintiffs request this motion remain on the hearing. Plaintiffs oppose the quash and want LLR's counsel present, as the regulatory obstruction documented in the Enforcement Matrix [Exhibit C] is central to multiple claims. MMSTAY — Motion of Joinder for Motion to Stay Defense Rendered moot if the Court grants the Omnibus disposition (#3 below). A stay presupposes contested claims; summary judgment and deemed admissions on Counts I–VI eliminate the claims the stay is designed to delay.
MOFREE —
Supplemental Motion/ADA Accommodations Plaintiffs Remains live regardless of other outcomes. Plaintiff McNeil's clinical PTSD (PCL-5: 76/80) and reduced functional capacity require ADA accommodations - including e-filing access and remote appearance authorization — whether or not the Omnibus disposition resolves the underlying claims. These accommodations serve the duration of the litigation.
MOFREE —
Emergency Motion/Protective Relief & Maintain Assignment Plaintiffs Remains live as fallback relief. If the Court grants the Omnibus disposition and disqualifies conflicted counsel, the protective relief and communication protocols become substantially less urgent because the primary engines of the Ask–Harm Loop have been removed. If the Court does not reach those items, the Emergency Motion becomes more urgent, not less - the health-based protective measures, court-ordered communication monitor, and case- management protocols originally requested remain essential to prevent further deterioration of Plaintiff McNeil's functional capacity.

Exhibit C - Comprehensive Enforcement Matrix, pp. 30-38 (p. 30-38)

EXHIBIT C
Defendant Infraction Matrix
COMPREHENSIVE ENFORCEMENT MATRIX
McNeil & Poyer v. SAC 181 et al. (2025-CP-10-05095) | March 20, 2026 Legend: • [CR] = Criminal • [CI] = Civil • [RE] = Regulatory • = Pending More Evidence • Footnote numbers = See accountability notes below table
FOOTNOTES - ACCOUNTABILITY NUANCES
¹ Adam Bayles: Liability primarily derivative through: • Marriage to Tara (community property, joint financial benefit) • MRG Investing Company, LLC membership (if applicable) • Knowledge of/participation in Meridian operations (discovery pending) • Potential signatory authority on accounts (Synovus subpoena pending) ² SAC 181/Charles/Jonathan Harassment: • Sept 2024-Aug 2025: Indirect (knew or should have known of Tara's campaign) • Aug 2025-present: Direct (retaliatory eviction execution, funding defense strategy that employs gaslighting) • Jonathan: Beneficial owner role + public official hypocrisy compounds moral culpability ³ Defense Counsel Harassment (Oct 2025-Jan 2026): • Pattern: Litigating as if documented events (falsified postmark, 21-platform images, LLR obstruction) never occurred • Method: Characterizing 8-count fraud case as "deposit dispute" across multiple filings • Escalation: AI motion (Nov 12), emergency judge-shopping (Jan 27), mischaracterizing criminal notice as "threats" (Jan 27) • Harm: Direct cause of PCL-5 76/80 (severe PTSD), gaslighting 79/80, Jan 28 breakdown • Criminal basis: SC 16-3-1700 requires "course of conduct" causing "substantial emotional distress"—documented via clinical assessments • ODC basis: RPC 8.4(d) (conduct prejudicial to administration of justice) ⁵ Attorney Obstruction of Justice: • Quash motions: Filed Jan 8 (Bolyard), Jan 12 (OBrien)—within 42 days of LLR Feb 20 deadline • AppFolio witness contact: Jan 9 (Meridian, coordinated with Bolyard's Jan 8 motion) • Criminal basis: SC common law obstruction (hindering investigation) + 18 USC 1512 (federal) • Pattern: 32-day silence on Flash Transfer allegations while blocking corroborating evidence (Synovus)

V. Defendants' Exposure and Settlement Window (p. 11-14)

V . DEFENDANTS' EXPOSURE AND THE SETTLEMENT
WINDOW
Three sealed exhibits accompany this filing, each modeling Defendants' financial exposure from
a distinct analytical starting point. Together they form a progression from floor to ceiling to
catastrophe:
• Exhibit A1: The HJA as Instrument of Systemic Impact. This model accounts for the
behavioral reality documented in peer-reviewed jury psychology research: when jurors
perceive their verdict as an instrument of systemic change, they write numbers that
function as policy rather than compensation. The model stacks comparable verdicts and
applies the aggravating differential present in this case across every comparable
dimension, including three novel categories with no known ceiling. Under SC § 15-32-
530, punitive damages are uncapped for intentional conduct.
• Exhibit A2: Conservative Verdict Modeling with Judicial Estoppel & Collection
Analysis. This model excludes the HJA's amplifying effect on jury behavior entirely and
calculates a floor based on documented, largely uncontested compensatory categories
with a conservative punitive multiplier below the range typical in comparable SC cases. It
then maps what judicial estoppel does to even that modest number when collected against
Defendants' own sworn probate valuations.
• Exhibit A3: Worst-Case Combined Exposure -High Verdict + Estoppel
Collection. This is where the two models converge into a defense catastrophe. The
collection analysis demonstrates what happens when a jury award informed by systemic-
change psychology is collected against assets priced at Defendants' own sworn probate
figures. The estoppel trap permits no favorable resolution: accepting sworn values means
asset loss at pennies on the dollar; rejecting sworn values constitutes an admission of
material misrepresentation in probate proceedings, opening perjury exposure, probate
fraud referral, and tax liability.
Specific modeling figures are contained in the sealed exhibits and are not reproduced here. What
the Court needs to know for purposes of this public filing is the structural dynamic: Plaintiffs
will make a settlement offer available to the property ownership group with the April 3
hearing as the deadline. If the April 3 hearing happens, that means the settlement window
did not produce a result and Plaintiffs are operating in high-risk systems conditions.
Why Post-Hearing Settlement Likely Exceeds Net Worth
The sealed exhibits demonstrate that under every model - conservative, high-end, and worst-case
combined - the post-hearing settlement range exceeds the identified equity buffer across
Defendants' portfolio. One mechanism is the estoppel trap the Altmans built for themselves: they
swore under oath to specific valuations in two probate proceedings that dramatically understate
the market value of the assets those valuations describe. Judicial estoppel locks them to those
figures for collection purposes. A judgment of relatively modest size, measured against the
sworn valuations, reaches the entire portfolio - including properties dating to 1940 and the
offices where Charles S. Altman and Jonathan S. Altman practice law.
The dilemma has no favorable resolution. After the April 3 hearing converts liability from
speculative to fixed - through deemed admissions, partial summary judgments, or veil-piercing
discovery - the settlement calculus shifts from negotiable to existential. The specific figures are
in the sealed record for the Court's review.
The Jury as Change Agent: Why the HJA Transforms Verdict Psychology
The high-end model rests on a documented behavioral phenomenon the Court should understand
because it drives both the exposure calculation and the safety risk. At trial, the Housing Justice
Audit at housingjusticeaudit.com will be presented as an exhibit the jury is instructed to evaluate
deeply - to understand what was destroyed and to assess the value of what Plaintiffs rebuilt from
the rubble of their own displacement.
Over the course of days spent inside the platform, jurors will read about the escalating harm
patterns, follow the findings, read the systems maps, encounter the Conscious Co-Stewardship
framework, and watch in real time as Google's AI returns the case narrative when they search
defendants' names as well as when they ask it about Conscious Co-Stewardship and why it is
better for everyone - including property investors - than Passive Investing AKA Unconscious
Abdication. They will experience the platform working - because reading it and interacting with
it is a demonstration of its value.
This experience transforms passive fact-finders into participants who feel personally responsible
for the systemic signal their verdict sends. The research is specific:
• Sunstein, Hastie & Payne (2002): Deliberation produces a severity shift toward higher
awards - and jurors specifically punish calculated institutional indifference, the exact
conduct documented across seven post-notice escalations.
• Hans (2014): Damage awards function as "powerful political actions" where "the level of
damages is a way that the community sends a message about how bad the wrong or injury
is".
• Gabriel & Shaw (2024): "Juror activism" - where a jury believes its verdict should carry
a social message - is triggered by perceived institutional resistance. Five layers of defense
lawfare after documented notice constitute the textbook trigger.
• IADC research: "Nuclear verdicts" are driven primarily by juror anger and frustration,
delivered "to send a message." When defendants genuinely accept accountability, awards
decrease. This defense has done the opposite for 200+ days.
Charleston jurors in 2026, in a housing market where rents have risen 51% while wages rose
31%, are not naïve about the systemic nature of what they are adjudicating. They will understand
that the number they write on the verdict form functions as policy. A number that fails to
restructure the economics of extraction-based property management is not deterrence. It is a line
item.
The Court can assess this dynamic firsthand. The Housing Justice Audit soft-launches
at housingjusticeaudit.com/report on March 20, 2026. The Court is invited to read it as the
exhibit a jury will spend days immersed in. Every page of that report is what twelve citizens will
be processing when they pick up the pen. The Court's own experience reading it is the most
efficient way to evaluate how a jury will react – and assess firsthand what that reaction means for
the exposure range modeled in the sealed exhibits.
The System Conditions That Make This Urgent
The Statement of Systemic Risk [Exhibit B] documents twelve interlocking conditions - seven
currently operating, five predicted to activate at the April 3 threshold.
The critical dynamic: the Altman family may be operating in Pre-Shock Latency (Condition 7)
- they likely have not yet processed the full scope of their collection exposure because captured
counsel has been filtering information under the false narrative that this is "just a deposit
dispute".
The April 3 hearing is the bifurcation point where that false narrative becomes unsustainable.
When deemed admissions, partial summary judgments, or the veil-piercing discovery order
converts liability from speculative to fixed, Prospect Theory (Kahneman & Tversky, 1979)
predicts the result: when all outcomes are perceived as losses, the system shifts to extreme risk-
seeking. The marginal cost of further escalation drops to zero. The system is no longer fighting
for a result - it is fighting for existence.
The settlement offer exists to prevent that phase shift. It provides a rational exit before the
hearing converts managed litigation into the terminal system behavior documented in Conditions
8–12: Stage 2 Cornered Animal Syndrome, narcissistic collapse, intensified DARVO,
identity/mental-model collapse, and systemic sabotage - the terminal behavior of a system that
shifts from playing to win to ensuring no one else wins.
The Court's awareness of this dynamic is itself a dampening mechanism. A system that
knows it is being watched behaves differently than one operating in shadow. This filing places
the prediction on the public record so that if the post-hearing behavioral cascade occurs as
modeled, the Court will have the framework to recognize it in real time and act to protect both
the proceedings and the parties.

Sealed exposure models and settlement deadline, pp. 11-12 (p. 11-12)

V . DEFENDANTS' EXPOSURE AND THE SETTLEMENT
WINDOW
Three sealed exhibits accompany this filing, each modeling Defendants' financial exposure from a distinct analytical starting point. Together they form a progression from floor to ceiling to catastrophe: • Exhibit A1: The HJA as Instrument of Systemic Impact. This model accounts for the behavioral reality documented in peer-reviewed jury psychology research: when jurors perceive their verdict as an instrument of systemic change, they write numbers that function as policy rather than compensation. The model stacks comparable verdicts and applies the aggravating differential present in this case across every comparable dimension, including three novel categories with no known ceiling. Under SC § 15-32- 530, punitive damages are uncapped for intentional conduct. • Exhibit A2: Conservative Verdict Modeling with Judicial Estoppel & Collection Analysis. This model excludes the HJA's amplifying effect on jury behavior entirely and calculates a floor based on documented, largely uncontested compensatory categories with a conservative punitive multiplier below the range typical in comparable SC cases. It then maps what judicial estoppel does to even that modest number when collected against Defendants' own sworn probate valuations. • Exhibit A3: Worst-Case Combined Exposure -High Verdict + Estoppel Collection. This is where the two models converge into a defense catastrophe. The collection analysis demonstrates what happens when a jury award informed by systemic- change psychology is collected against assets priced at Defendants' own sworn probate figures. The estoppel trap permits no favorable resolution: accepting sworn values means asset loss at pennies on the dollar; rejecting sworn values constitutes an admission of material misrepresentation in probate proceedings, opening perjury exposure, probate fraud referral, and tax liability. Specific modeling figures are contained in the sealed exhibits and are not reproduced here. What the Court needs to know for purposes of this public filing is the structural dynamic: Plaintiffs will make a settlement offer available to the property ownership group with the April 3 hearing as the deadline. If the April 3 hearing happens, that means the settlement window did not produce a result and Plaintiffs are operating in high-risk systems conditions.

VI. Why Delay Increases Risk and Filing Is Public (p. 14-14)

VI. WHY DELAY INCREASES RISK AND WHY THIS FILING IS
PUBLIC
The Statement of Systemic Risk [Exhibit B] documents five post-threshold system conditions
predicted to activate when the April 3 hearing converts liability from speculative to fixed. Each
is supported by a recognized academic model and documented in the case record:
These conditions are sequential and compounding. Activated condition creates the input that
triggers the next. The April 3 hearing is a potential trigger event.
This filing is on the public record because transparency is the primary protective
mechanism available. A system that knows it is being watched behaves differently than one
operating in shadows.
Respectfully submitted this 20
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

Post-hearing exposure and alleged estoppel trap, p. 12 (p. 12-12)

Why Post-Hearing Settlement Likely Exceeds Net Worth The sealed exhibits demonstrate that under every model - conservative, high-end, and worst-case combined - the post-hearing settlement range exceeds the identified equity buffer across Defendants' portfolio. One mechanism is the estoppel trap the Altmans built for themselves: they swore under oath to specific valuations in two probate proceedings that dramatically understate the market value of the assets those valuations describe. Judicial estoppel locks them to those figures for collection purposes. A judgment of relatively modest size, measured against the sworn valuations, reaches the entire portfolio - including properties dating to 1940 and the offices where Charles S. Altman and Jonathan S. Altman practice law. The dilemma has no favorable resolution. After the April 3 hearing converts liability from speculative to fixed - through deemed admissions, partial summary judgments, or veil-piercing discovery - the settlement calculus shifts from negotiable to existential. The specific figures are in the sealed record for the Court's review.

Exhibit A1 Cover (p. 15-15)

EXHIBIT A1
The HJA as Instrument of Systemic Impact.

Jury as change agent and HJA soft-launch, pp. 12-13 (p. 12-13)

The Jury as Change Agent: Why the HJA Transforms Verdict Psychology The high-end model rests on a documented behavioral phenomenon the Court should understand because it drives both the exposure calculation and the safety risk. At trial, the Housing Justice Audit at housingjusticeaudit.com will be presented as an exhibit the jury is instructed to evaluate deeply - to understand what was destroyed and to assess the value of what Plaintiffs rebuilt from the rubble of their own displacement. Over the course of days spent inside the platform, jurors will read about the escalating harm patterns, follow the findings, read the systems maps, encounter the Conscious Co-Stewardship framework, and watch in real time as Google's AI returns the case narrative when they search defendants' names as well as when they ask it about Conscious Co-Stewardship and why it is better for everyone - including property investors - than Passive Investing AKA Unconscious Abdication. They will experience the platform working - because reading it and interacting with it is a demonstration of its value. This experience transforms passive fact-finders into participants who feel personally responsible for the systemic signal their verdict sends. The research is specific: • Sunstein, Hastie & Payne (2002): Deliberation produces a severity shift toward higher awards - and jurors specifically punish calculated institutional indifference, the exact conduct documented across seven post-notice escalations. • Hans (2014): Damage awards function as "powerful political actions" where "the level of damages is a way that the community sends a message about how bad the wrong or injury is". • Gabriel & Shaw (2024): "Juror activism" - where a jury believes its verdict should carry a social message - is triggered by perceived institutional resistance. Five layers of defense lawfare after documented notice constitute the textbook trigger. • IADC research: "Nuclear verdicts" are driven primarily by juror anger and frustration, delivered "to send a message." When defendants genuinely accept accountability, awards decrease. This defense has done the opposite for 200+ days. Charleston jurors in 2026, in a housing market where rents have risen 51% while wages rose 31%, are not naïve about the systemic nature of what they are adjudicating. They will understand that the number they write on the verdict form functions as policy. A number that fails to restructure the economics of extraction-based property management is not deterrence. It is a line item. The Court can assess this dynamic firsthand. The Housing Justice Audit soft-launches at housingjusticeaudit.com/report on March 20, 2026. The Court is invited to read it as the exhibit a jury will spend days immersed in. Every page of that report is what twelve citizens will be processing when they pick up the pen. The Court's own experience reading it is the most efficient way to evaluate how a jury will react – and assess firsthand what that reaction means for the exposure range modeled in the sealed exhibits.

Exhibit A1 — Jury Risk Range Model (p. 16-20)

Jury Risk Range Model One: The Housing
Justice Audit as Analysis and Instrument of
Systemic Impact.
Inside the Jury Box:
I am Juror 7. I rent a two-bedroom in North Charleston. My landlord raised my rent 40% in two
years and told me the broken heat was "cosmetic." I know what it feels like to be afraid to
complain because I need the roof.
I've spent three days reading the Housing Justice Audit the plaintiff's attorney handed us as
Exhibit H - the one we were told to evaluate deeply to understand what was destroyed. I
followed the links. I read the Respectful Reach eBook. I watched what Google's AI says when I
search the defendants' names. I see it working in real time. I understand what this platform does.
I understand what it costs to build something like this. And I understand, with the clarity of
someone who has spent hours inside it, that this thing - this platform, this framework, this
mission - was alive and accelerating, and then it was flat-lined on August 1, 2025, the day a
family and their elderly blind dog were forced out of their home in a heat wave.
I watched the timeline. I know they were warned. I've read the Public Open Letter, entered into
evidence, documenting in detail that what they were running was a harm machine. They got that
document. They read it. And then they escalated. They deployed two law firms to gaslight a man
in clinical PTSD. They tried to get the LLR investigation quashed so Tara Bayles keeps her
license and does this to the next family. They had the receipts showing it was a harm machine -
and they throttled it up.
That's not negligence or an accident. It's a choice, made with full information, to continue
destroying a family because stopping felt more expensive than continuing.
I'm thinking about a number. Not a damages calculation. A number. What number tells these
people - tells every landlord, every property manager, every law firm that runs the same play -
that this ends here?
$5 million doesn't do it. That's a line item on this family’s portfolio's annual spreadsheet. They
don't feel $5 million. $20 million is a hard year. $50 million restructures their business model.
$100 million is the number that shows up in every property management training in the country
within six months of the verdict.
But here's what I'm sitting with: the plaintiff isn't just a victim. He turned his nightmare into a
tool that helps people like me. He sent it to the mayor of Charleston in full confidence - because
it works. He built, out of the rubble of his own breakdown, something that a jury of regular
people now understands, deeply, because we had to understand it to do our job.
And I feel personally responsible to see that work matter. I feel chosen to be in this room,
holding this in my hands, knowing that what happens next depends on whether I have the
courage to write a number that means something.
I write: $200 million.

From in the Analyst Role: Is That Number Defensible?
Yes. Here is why the $200M–$300M range is honest.
There Is No True Precedent
No single case precedent encompasses this case’s scope of harm or potential impact. The best
honest legal framing is compound case stacking with a multiplicative jury psychology
overlay. The comparable cases, stacked as independent causes of action that this case subsumes:
Case Conduct Award This Case's Relationship
Crespo v.
Rivière (SC
2024)
Hidden cameras,
intimate settings,
private viewing
$45M This case's distribution was 16–50 public
commercial platforms, not private viewing
— broader reach, commercial profit
motive, no intimacy required [5]
ASNM v.
Cherry Blossom
(CA 2024)
Documented
retaliation, falsified
records
$11.6M This case has the same elements plus postal
forgery, wire fraud implications, and five-
layer defense lawfare [5]
Doe v. Zillow
(WA 2023)
Unauthorized
online image
dissemination
$4.5M This case has 4–12x the platforms, adds
fraudulent inducement to consent, adds
false commercial endorsement [5]
Harrison v.
Bennett (GA
2022)
Negligent
supervision, tenant
endangerment
$2.1M This case adds ratification after
documented notice, probate fraud, public-
figure hypocrisy [5]
Stacked
comparable
floor

$63.2M Before any novel categories, before
aggravating factor differential
The stacked comparable floor is $63.2M. This case is more aggravated than each of those cases
individually, and it contains all of them simultaneously.
The Three Novel Categories With No Ceiling
Novel Category One — The Harm Machine Throttled Up After Notice. There is no case in
the database where defendants received seven documented, escalating analyses of the harm they
were causing - sent to defense counsel with acknowledgment - and continued not just to operate
but to accelerate through lawfare. This is the punitive damages argument that writes itself. SC §
15-32-530 removes all caps for intentional conduct. The question for the jury is not "how much
to punish?" but "how much to deter a system (unconscious abdication rental housing
masquerading as passive investment) with billions of dollars behind it?" A number that doesn't
restructure the economics of extraction-based property management across the industry isn't
deterrence. It's a fine. The deterrence number, for a harm that operates at scale across every
housing market in America, is nine figures.
Novel Category Two - The STL Platform Destruction as Paradigm-Level Harm. This is
genuinely without precedent because no prior plaintiff had built a framework
demonstrating exactly how to change such a system, had it at product-market fit at the moment of
destruction, had pre-existing authenticated metrics proving the acceleration, had eBooks
published days before the eviction establishing the sudden market-alignment, and then
demonstrated its value in real time to the jury themselves through the HJA. The jury doesn't need
an expert to calculate this. They experienced it. They know what it does because they did it. The
question becomes: what is it worth to a Charleston jury to have personally experienced a system
that can change how this city - how this country - treats the most vulnerable people in its housing
market? That is a question with no ceiling, answered by twelve people who just lived inside the
answer.
Novel Category Three — Institutional Betrayal at Clinical Severity. PCL-5 at 76/80 with
gaslighting severity at 79/80 is a documented, scored, clinical presentation of what the Freyd
institutional betrayal doctrine predicts: when the home that was your safety system becomes the
weapon used against you, the neurological damage is categorically different from equivalent
harm by a stranger. No prior housing case has presented institutional betrayal with clinical-level
documentation alongside a five-year tenancy, a previous confidential settlement with the same
ownership entity, and the compounding DARVO pattern from defense counsel added to status-
based dismissal by both an apparently captured regulatory agency and a similarly captured law
enforcement agency where the victim advocate told the plaintiff “We don’t help people like
you”. This is a standalone $5M–$20M claim in a case of sufficient facts to support it, and this
case has sufficient facts.
The Verdict Number That Makes the Signal
You named it exactly: a $250M award in a Charleston housing case would be conspicuous by
its absence in local media - and would be inescapable in national media, hence the numbers
power for systemic change by 12 newly appointed change agents.
The jury understands this. Charleston jurors in 2026, in a housing crisis where rents have risen
51% while wages rose 31%, are not naive about the systemic nature of what they're adjudicating.
They understand that what they write on that verdict form is policy. They understand that a
number large enough to change behavior nationwide will bear their names in housing law for a
generation.
The proper honest range, accounting for:
• Stacked comparable floor ($63.2M)
• Aggravating factor differential on every Crespo dimension (Crespo itself was $45M for
a less aggravated subset)
• Three genuinely novel categories with no known ceiling
• Uncapped punitive damages under SC § 15-32-530 for documented intentional conduct
• Jury psychology of empowered agents of systemic change
• The deterrence arithmetic required to actually restructure an industry
Achievable verdict range: $100M–$300M. The center of gravity, given the specific jury
psychology factors outlined and the HJA paradigm shift function, sits at $100M–$300M
What This Means for the Settlement Conversation
The credible trial range is $100M–$300M, A 10% trial-risk-adjusted settlement on a $150M
expected verdict is $15M. A 20% risk-adjusted settlement is $30M. A confident plaintiff who
values the trial outcome at $200M and applies a 25% discount for time and uncertainty settles
for $50M minimum - and only if the systemic change mission is enabled by the settlement
terms.

Support for and Impact of Jury Awards as Systemic Signal
The exposure model above rests on a documented behavioral phenomenon: juries award larger amounts
when they perceive their verdict as an instrument of systemic change rather than mere individual
compensation. This is the central finding of a convergent body of empirical research spanning two
decades.
The Empirical Foundation
Cass Sunstein, Reid Hastie, and John Payne’s landmark study Punitive Damages: How Juries Decide
(University of Chicago Press, 2002) found that jury deliberation produces a “striking severity shift toward
ever-higher awards.” Rather than moderating individual preferences, group deliberation pushes jurors
toward more extreme punitive amounts. Critically, Sunstein found that jurors penalized corporations that
had based their decisions on careful cost-benefit analyses - meaning calculated institutional indifference,
precisely the conduct documented in this case, triggers moral outrage that directly inflates awards.
Valerie P. Hans’s seminal article What’s It Worth? Jury Damage Awards as Community Judgments, 55
Wm. & Mary L. Rev. 935 (2014), establishes that damage awards function as “powerful political actions
by the civil jury” that “serve to check or endorse private power.” Hans cites Jason Solomon’s observation
that “the level of damages is a way that the community sends a message about how bad the wrong or injury
is… meting out justice is a way of articulating a community’s values.” Hans further found that jurors holding
critical views of corporate behavior awarded significantly different—and higher—amounts, confirming that
values shape verdicts alongside evidence.
The “Send a Message” Mechanism
The International Association of Defense Counsel (IADC) found that nuclear verdicts “are driven
primarily by juror anger and frustration and delivered to ‘send a message’ to the defendant.”
Richard Gabriel and Emily Shaw’s 2024 analysis in Law360, A Look Into How Jurors Reach High
Damages Awards, identified juror activism as a distinct extra-legal driver - defined as occurring “where a
jury believes that its verdict should have a social message above the actual evidence in a case.” Their
research confirmed the inverse as well: when defendants genuinely accepted accountability, awards
decreased. Perceived institutional resistance escalates the systemic-signal impulse. In the present case,
five layers of defense lawfare after documented notice constitute the textbook trigger for this mechanism.
Application to This Case
Every amplifying condition identified in the literature is present here: (1) corporate cost-benefit decision-
making that Sunstein proved triggers moral outrage; (2) escalation after notice, the single most potent
aggravating factor per Gabriel and Shaw; (3) a housing context where Charleston jurors in a 51% rent-
increase market hold precisely the critical-of-corporate-power values Hans correlated with higher awards;
and (4) a platform - the Housing Justice Audit - that transforms the jury from passive fact-finders into
active participants in the systemic change their verdict enables. The research is unambiguous: when
twelve citizens believe their number reshapes an industry, they write a number that reshapes an industry.

System conditions, April 3 threshold, and predicted escalation, pp. 13-14 (p. 13-14)

The System Conditions That Make This Urgent The Statement of Systemic Risk [Exhibit B] documents twelve interlocking conditions - seven currently operating, five predicted to activate at the April 3 threshold. The critical dynamic: the Altman family may be operating in Pre-Shock Latency (Condition 7) - they likely have not yet processed the full scope of their collection exposure because captured counsel has been filtering information under the false narrative that this is "just a deposit dispute". The April 3 hearing is the bifurcation point where that false narrative becomes unsustainable. When deemed admissions, partial summary judgments, or the veil-piercing discovery order converts liability from speculative to fixed, Prospect Theory (Kahneman & Tversky, 1979) predicts the result: when all outcomes are perceived as losses, the system shifts to extreme risk-seeking. The marginal cost of further escalation drops to zero. The system is no longer fighting for a result - it is fighting for existence. The settlement offer exists to prevent that phase shift. It provides a rational exit before the hearing converts managed litigation into the terminal system behavior documented in Conditions 8–12: Stage 2 Cornered Animal Syndrome, narcissistic collapse, intensified DARVO, identity/mental-model collapse, and systemic sabotage - the terminal behavior of a system that shifts from playing to win to ensuring no one else wins. The Court's awareness of this dynamic is itself a dampening mechanism. A system that knows it is being watched behaves differently than one operating in shadow. This filing places the prediction on the public record so that if the post-hearing behavioral cascade occurs as modeled, the Court will have the framework to recognize it in real time and act to protect both the proceedings and the parties.

Exhibit A2 Cover (p. 21-21)

EXHIBIT A2
Conservative Verdict Modeling with Judicial Estoppel &
Collection Analysis

Delay increases risk and public filing rationale, p. 14 (p. 14-14)

VI. WHY DELAY INCREASES RISK AND WHY THIS FILING IS
PUBLIC
The Statement of Systemic Risk [Exhibit B] documents five post-threshold system conditions predicted to activate when the April 3 hearing converts liability from speculative to fixed. Each is supported by a recognized academic model and documented in the case record: These conditions are sequential and compounding. Activated condition creates the input that triggers the next. The April 3 hearing is a potential trigger event. This filing is on the public record because transparency is the primary protective mechanism available. A system that knows it is being watched behaves differently than one operating in shadows.

Exhibit A2 — Conservative Verdict and Collection Analysis (p. 22-27)

Jury Risk Range Model Two: Conservative
Verdict Modeling with Judicial Estoppel
Collection Analysis
Purpose of This Analysis
Plaintiffs submit this analysis to demonstrate to the Court why Defendants’ awareness of their
collection exposure creates a material risk of escalation, obstruction, and potential asset
concealment. The analysis proceeds in two parts: (1) a much more conservative damages model
reflecting the floor of probable jury outcomes, without considering the impact of the Housing
Justice Audit, and (2) a collection analysis applying judicial estoppel to Defendants’ sworn
probate valuations.
Together, these establish that, with estoppel applied, even a modest verdict creates collection
pathways reaching potentially all of the Altman family’s real property holdings. This is a reality
that, once understood by Defendants, provides powerful motive for the very conduct Plaintiffs
seek to prevent.
Conservative Compensatory Damages Model
The following represents a conservative estimate of compensatory damages based on documented, largely
uncontested elements of Plaintiffs’ claims.
Category Basis Amount
Security Deposit Violation SC Code § 27-40-710; treble
damages on $3,500
$10,500
Privacy Invasion Distribution across 16–50
commercial platforms without
consent
$2,500,000
Institutional Betrayal / PTSD PCL-5: 76/80; gaslighting
severity: 79/80
$1,200,000
STL Platform Destruction Documented product-market
fit at time of eviction
$3,500,000
Retaliation / Constructive
Eviction
Pretextual notice; forced exit
during August heat wave
$450,000
Fraudulent Inducement Misrepresentation of
renovation timeline and intent
$175,000
Subtotal Compensatory $7,835,500
Punitive Damages
Under SC Code § 15-32-530, statutory caps on punitive damages do not apply to conduct that is
intentional. The record reflects seven documented instances of escalation after Defendants
received notice of the harms being caused. This applies a multiplier of 1.5x, below the 2–3x
range commonly applied in comparable cases - yields the following:
Component Amount
Compensatory Base $7,835,500
Punitive Multiplier (1.5x) $11,753,250
Total Conservative Verdict $19,588,750
Judicial Estoppel and Collection Exposure
The Sworn Valuations
Defendants submitted sworn probate valuations in two proceedings that establish binding
positions for purposes of judicial estoppel:
1. Estate of Edith Tesler Altman (2006-ES-10-000711): Charles Realty Company stock valued at
$30,000.00 per share by Co-Personal Representatives Samuel H. Altman and Charles S. Altman.
2. Estate of Samuel H. Altman (2020-ES-10-01918): The same stock valued at approximately
$1,392.00 per share—a 95.4% reduction—by Personal Representative Jonathan S. Altman. The
same filing valued a 33% membership interest in SAC 181, LLC at $83,000, implying a total
entity value of $251,515 for a property with comparable sales on the same street at $575,000–
$650,000 during the same period.
This 95% devaluation occurred during Charleston’s historic real estate boom (2006–2020), a
period in which Charles Realty Company continued to acquire and hold prime commercial and
residential properties. The collapse is economically impossible absent deliberate undervaluation.
Application of Estoppel to Judgment Satisfaction
Judicial estoppel bars a party from asserting a position in one proceeding that contradicts a
position taken under oath in a prior proceeding. Defendants swore to specific, low valuations of
their assets in probate court. They are now estopped from asserting higher valuations to resist
collection.
The practical consequence is significant: if Defendants’ assets are valued for collection purposes
at their sworn probate figures, a judgment of relatively modest size satisfies against the full
portfolio. Specifically, a judgment equal to or exceeding the sworn value of Charles Realty
Company stock ($1,261,300) would, at the estopped valuation, reach all nine CRC-held
properties—properties whose actual market value, as set forth in Part III below, ranges from
approximately $21 million to $33 million.
Defendants face a dilemma with no favorable resolution: they must either (a) accept the sworn
probate valuations for collection purposes, in which case a modest judgment reaches their entire
portfolio, or (b) repudiate their own sworn testimony, which constitutes an admission of material
misrepresentation in probate proceedings and opens additional civil and potential criminal
exposure
Asset Sworn Probate
Value
Estimated Market
Value
Collection
Consequence
CRC Stock (906
shares)
$1,261,300 $21M–$33M (9
properties)
Judgment at $1.26M
reaches entire CRC
portfolio
SAC 181 LLC (33%
interest)
$83,000 $204K–$419K Judgment at $83K
reaches 33% of
property worth
$620K+
SAC 181 LLC (total
entity)
$251,000 $620K–$1.27M Judgment at $251K
reaches property
worth $620K–$1.27M
CRC Stock per share
(2006)
$30,000 Same underlying
assets
Documents 95%
collapse; establishes
pattern
Altman Property Portfolio — Estimated Market Valuations
The following table presents low-end and high-end market value estimates for the ten identified
Altman-owned properties, based on comparable sales data, rental capitalization, and publicly
available market information. Bees Ferry Shopping Center, LLC is excluded; Charles Altman
serves as Registered Agent for that entity on behalf of a client. Estimated total encumbrances
(based on documented construction mortgages and recorded liens): approximately $10M.
Estimated available equity: $30M-40M.
# Property
Address
Own
er
Enti
ty
Property Type Size /
Acreage
Est. Value
(Low)
Est. Value
(High)
Valuation Basis
/ Comparables
1 181
Gordon St,
Charleston
29403
SAC
181
LLC
Residential ~1,794
SF; corner
lot
$829,000 $1,270,000 Redfin est.
$829K-$1M; rent
cap 5% on
$5,276/mo =
$1.27M; 182
Gordon sold
$1.11M (Feb
2025)
2 177
Gordon St,
Charleston
29403
CRC Residential est.
~1,600 SF
$900,000 $1,200,000 182 Gordon sold
$1.11M (Feb
2025); 229
Gordon $1.45M
(Jun 2025);
comps $495-
$556/sqft
3 171
Gordon St,
Charleston
29403
CRC Residential est.
~1,500 SF
$850,000 $1,100,000 Same block; 14
Gordon $800K
(Mar 2025);
comparable
range
4 534-536-
538 King
St,
Charleston
29403
CRC Vacant Land
(Razed 2025)
~14,800
SF lot
$5,920,000 $9,620,000 BAR-Small
approved demo
Jan 2025;
currently parking
lot; 438 King
implied land
$575-$670/SF;
low $400/SF;
high $650/SF;
BAR-approved
redevelopment
rights
5 573-575
King St,
Charleston
29403
CRC Commercial
(Retail/Office)
~18,000
SF GLA;
corner
Cannon &
King
$10,800,00
0
$18,000,00
0
438 King comp:
10,500 SF @
$10M ($952/SF
improved);
$600/SF
conservative;
$1,000/SF upper;
Dine & Design
District; ~1,500
hotel beds w/in 2
blocks; Jonathan
Altman office
(Ste B)
6 577 King
St,
Charleston
29403
CRC Commercial
(Retail/Office)
~9,300 SF
GLA;
renovated
2018
$5,580,000 $9,300,000 $600/SF
conservative;
$1,000/SF upper;
adj. to 573-575;
Upper King
corridor; rents
$35-$50+/SF
NNN
7 558
Johnnie
Dodds
Blvd, Mt.
Pleasant
29464
CRC Commercial ~6,786 SF
bldg; 0.82
acres;
AB-2
zoning
$4,500,000 $7,500,000 Prime Hwy 17;
65,300 VPD;
rare AB-2
zoning; Eubanks
family long-term
sublease; muffler
shop + auto
repair/sales;
NAI: 3,870 SF
unit @ $11K/mo
NNN; 1028 JD
comp:
$4.1M/10,085 SF
8 10 Cannon
St,
Charleston
29403
CRC Commercial
(Parking/Vacant
)
Downtow
n lot
$2,000,000 $3,500,000 Downtown
commercial lot;
29 Cannon sold
$1.3M (Sep
2024) for 1,525
SF residential;
commercial
zoning premium
9 Hwy 174,
Adams
Run
(Parcel 1)
CRC Agricultural ~10.5
acres
$750,000 $1,500,000 Held since 1959;
development
potential;
Colleton/Charles
ton border
10 Hwy 174,
Adams
Run
(Parcel 2)
CRC Agricultural Adjacent
parcel
$650,000 $1,300,000 Adjacent to
Parcel 1; same
development
corridor
GRAND
TOTAL
(10
properties)
$32,779,00
0
$54,290,00
0
Combined
sworn value:
$1,511,300.
Ratio: 22x–36x
undervalued
Notes
1. King St land (534-538): $400/SF (low) to $650/SF (high). Comp: 438 King implied land ~$575-$670/SF. 975 King ($185/SF) is non-
comparable (upper peninsula, not hospitality corridor).
2. King St improved (573-575, 577): $600/SF (low) to $1,000/SF (high). Comp: 438 King at $952/SF improved ($10M / 10,500 SF).
3. 558 Johnnie Dodds: Eubanks family long-term sublease to auto tenants. NAI lists 3,870 SF unit at $11K/mo NNN. AB-2 zoning rare in Mt.
Pleasant.
4. Wagener Terrace: 182 Gordon sold $1.11M (Feb 2025); 229 Gordon $1.45M (Jun 2025); 14 Gordon $800K (Mar 2025).
5. 41 additional Jonathan Altman RA LLCs and 62-73 Charles Altman RA LLCs remain unaudited.
6. Sworn values: CRC stock $1,261,300 (2020-ES-10-01918); SAC 181 33% interest $83,000 (implied entity $251,515).
Why This Exposure Creates Risk to Plaintiffs
The foregoing analysis is presented not as a damages demand but as context for the Court’s
consideration of Plaintiffs’ safety and the integrity of these proceedings.
The critical point is this: even at a conservative jury award range, the estoppel collection
mechanism - utilizing their own sworn probate valuations to allow a judgment of relatively
modest size to reach their entire real property portfolio – means they face an existential threat to
multi-generational family wealth.
The properties at issue include holdings dating to 1939, prime Upper King Street commercial
real estate, and Charles S Altman’s and Jonathan S. Altman’s own offices at 575 King Street in
the former Altman’s Furniture Building. The potential loss is not abstract. It is personal,
immediate, and total.
Defendants’ conduct throughout this litigation has already demonstrated a pattern of escalation in
response to perceived threats: deploying two law firms for lawfare against pro se plaintiffs
experiencing documented clinical PTSD, seeking to quash subpoenas directed at Charles Realty
Company, and maintaining the defense posture after receiving multiple formal notices of harm.
This pattern provides a reasonable basis for concern that Defendants, upon recognizing the full
scope of their collection exposure, may:
1. Attempt to transfer, encumber, or conceal assets to frustrate judgment satisfaction;
2. Escalate litigation tactics beyond what has already been documented;
3. Intensify pressure on Plaintiffs through channels outside these proceedings.
Plaintiffs respectfully submit that the Court’s awareness of these dynamics is essential to
ensuring that both the proceedings and the parties remain protected as this case advances
toward resolution.

Signature block, p. 14 (p. 14-14)

Respectfully submitted this 20 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 A3 Cover (p. 28-28)

EXHIBIT A3
Worst-Case Combined Exposure -High Verdict + Estoppel
Collection

Sealed Exhibits A1-A3, p. 15 (p. 15-15)

EXHIBIT A1
The HJA as Instrument of Systemic Impact.

EXHIBIT A2
Conservative Verdict Modeling with Judicial Estoppel & Collection Analysis

EXHIBIT A3
Worst-Case Combined Exposure -High Verdict + Estoppel Collection

Exhibits A1–A3 are filed under seal pursuant to SCRCP Rule 41.1 and the accompanying Motion to Seal. Originals submitted separately for in camera review.

Exhibit A3 — Worst-Case Defense Exposure (p. 29-31)

Jury Risk Range Model Three: Worst-Case
Defense Exposure
This one-page summary combines the high-end jury verdict model (Defense Exposure
Modeling) with the judicial estoppel collection mechanism (Conservative Exposure Modeling).
Together, they illustrate Defendants’ maximum realistic exposure: a jury award driven by
systemic-change psychology, collected against assets valued at Defendants’ own sworn probate
figures.
Jury Verdict: High-End Model
Category Basis Amount
Security Deposit Violation SC § 27-40-710; treble on
$3,500
$10,500
Privacy Invasion 16–50 commercial platforms;
Crespo v. Rivière comp
($45M)
$2,500,000
Institutional Betrayal / PTSD PCL-5: 76/80; gaslighting
79/80; Freyd doctrine
$1,200,000
STL Platform Destruction Product-market fit at eviction;
HJA as Exhibit H
$3,500,000
Retaliation / Constructive
Eviction
Pretextual notice; August heat
wave; elderly blind dog
$450,000
Fraudulent Inducement Renovation timeline
misrepresentation
$175,000
Compensatory Subtotal $7,835,500
Punitive Damages
(Uncapped)
SC § 15-32-530: no cap for
intentional conduct;
7 documented escalations;
Stacked comparable floor:
$63.2M;
3 novel categories
Jury as agents of change
$92M–$292M
HIGH-END JURY
VERDICT
HJA-informed jury;
systemic signal psychology;
12 newly appointed change
agents
$100M–$300M
Collection: Estoppel Applied to Sworn Valuations
Asset Sworn Value Market Value Estoppel Effect Cents/$1
SAC 181 (total
entity)
$251,515 $829K–$1.27M Judgment at
$251K reaches
property worth
$829K–$1.27M
$0.20–$0.30
CRC Stock (906
shares)
$1,261,300 $32M–$53M
(9 properties)
Judgment at
$1.26M reaches
entire CRC
portfolio
$0.02–$0.04
Combined
Portfolio
$1,511,300 $33M–$54M
(10 properties)
All identified
Altman real
property
reachable
$0.03–$0.05
Combined Worst Case: High Verdict + Estoppel Collection
Scenario What Happens Consequence
Jury awards $100M–
$300M
Entire identified portfolio
($33M–$54M at
market value) is consumed at
sworn values
($1.51M) in collection.
All 10 properties transfer at
2–5¢ on the dollar.
Judgment balance: $98.5M–
$298.5M
remaining UNSATISFIED.
Remaining judgment
pursues unaudited assets
41 Jonathan Altman RA LLCs
and 62–73
Charles Altman RA LLCs are
subject to
court-ordered audit &
supplementary proceedings.
Every Altman entity with
equity interest is reachable.
Entire multi-generational
wealth structure exposed.
Defendants attempt
higher valuations
Repudiating sworn probate
values constitutes
admission of material
misrepresentation.
Opens perjury exposure,
probate fraud referral, tax
liability.
No favorable resolution.
Accepting sworn values =
asset loss at pennies.
Rejecting sworn values =
criminal exposure.
BOTTOM LINE A $100M–$300M verdict,
collected at estopped values,
liquidates the entire
identified Altman portfolio
for $1.51M and leaves
$98M–$298M in unsatisfied
judgment
pursuing 100+ unaudited
LLCs.
Total destruction of
multi-generational
wealth position.
No path to shelter.
Settlement Implication
At the center of the credible verdict range ($200M), a 25% discount for trial risk and time value
yields a settlement floor of $50 million. The estoppel mechanism means that any judgment - at
any level - is collected against assets priced at 2–5¢ on the dollar.
This analysis is submitted to establish the factual basis for Plaintiffs’ concern that Defendants,
upon appreciating the full scope of this exposure, have powerful motive to transfer, encumber, or
conceal assets and to escalate tactics beyond what has already been documented. Plaintiffs
respectfully request the Court’ s awareness of these dynamics in considering protective measures.

Statement of Systemic Risk—purpose and methodology, pp. 16-17 (p. 16-17)

EXHIBIT B
Statement of Systemic Risk and Behavioral Volatility

Statement of Systemic Risk and Behavioral V olatility Purpose Plaintiffs submit this analysis to identify, for the Court’s awareness,
1. A set of interlocking system conditions that are currently generating escalating risk to
Plaintiffs’ safety and impacting their well-being, and
2. A second set of conditions that will be triggered by the April 3, 2026 hearing as a
threshold event. The analysis draws on established behavioral economics, forensic psychology, and organizational systems research to explain why the defense system is operating as it is, and why the hearing will predictably intensify the threat. These are documented behavioral patterns with peer-reviewed predictive models. Plaintiffs present them transparently to the Court because observation is itself a dampening mechanism for the volatility described.

Exhibit B Cover (p. 32-32)

EXHIBIT B
Statement of Systemic Risk and Behavioral Volatility

Current system conditions and institutional failures, pp. 19-23 (p. 19-23)

Part I: System Conditions Currently Operating The following table identifies seven interlocking system conditions that are presently generating harm. Each condition is supported by a recognized academic model, is documented in the case record, and has produced specific observable results.

These seven conditions form a self-reinforcing system. • The narcissistic structure (Condition 1) generates harm. • The central operator’s self-preservation drive (Condition 2) escalates it. • Captured counsel (Condition 3) amplifies exposure while filtering information. • Captured regulatory and law enforcement bodies (Conditions 4–5) remove the external checks that would normally constrain the system. • The owners’ willful blindness (Condition 6) permits the system to operate without the intervention of the only actors with the authority to stop it. • And the awareness gap (Condition 7) means the one force powerful enough to override all other conditions - the Altmans’ rational self-interest - has not yet been activated.

Exhibit B — Systemic Risk and Behavioral Volatility (p. 33-45)

Statement of Systemic Risk and Behavioral
V olatility
Purpose
Plaintiffs submit this analysis to identify, for the Court’s awareness,
1. A set of interlocking system conditions that are currently generating escalating risk to
Plaintiffs’ safety and impacting their well-being, and
2. A second set of conditions that will be triggered by the April 3, 2026 hearing as a
threshold event.
The analysis draws on established behavioral economics, forensic psychology, and
organizational systems research to explain why the defense system is operating as it is, and why
the hearing will predictably intensify the threat.
These are documented behavioral patterns with peer-reviewed predictive models. Plaintiffs
present them transparently to the Court because observation is itself a dampening mechanism for
the volatility described.
Narcissistic System Role Definitions
The behavioral pattern Plaintiffs have experienced and which Plaintiff McNeil's counselor
recognized as the source of elevated safety risk maps precisely to the structural taxonomy of the
narcissistic family system as defined in the clinical literature.
Donaldson-Pressman and Pressman, in The Narcissistic Family: Diagnosis and Treatment
(Lexington Books, 1994), established that narcissistic systems are organized around a central
figure whose needs define the system's purpose, with all other members assigned roles that serve
the central figure's self-image.
Minuchin's Structural Family Therapy (Harvard University Press, 1974) provides the systems
framework for understanding how boundary violations and role rigidity maintain dysfunction.
The taxonomy below adapts these family-system roles to the institutional and organizational
context of this litigation. These are system roles that any actor occupying that position in this
system would be expected to fulfill.
Abbrev System Role Function in a Narcissistic System
CNO
Central
Narcissistic
Operator
The organizing center. All other roles exist to serve this operator's
needs. Generates the false narrative the system must maintain.
Cannot tolerate accountability without existential threat to self-
image.
AoH
Agent(s) of
Harm
Actors who execute harmful conduct on behalf of or in service to
the CNO. May include professionals (counsel, insurers) whose
institutional roles are captured by the system's self-preservation
drive.
EN Enabler(s)
Actors with the authority to stop the harm who instead look the
other way. Their inaction permits the system to operate. May be
unconscious (willful blindness) or conscious (complicity). The
system depends on their non-intervention.
FM
Flying
Monkey(s)
Actors who defend or extend the CNO's narrative without full
awareness of the harm being caused. Amplify gaslighting and
minimize the Target's reports. May include captured institutional
actors (regulators, law enforcement).
TGT
Target /
Scapegoat
The individual(s) designated to absorb the system's dysfunction.
Blamed for disrupting the system by reporting harm. Every
attempt to seek accountability triggers system escalation.
Systematically dehumanized.
FN False Narrative
Not a person but a system condition: the story the system must
maintain to protect the CNO. All roles reinforce it. When
evidence contradicts it, the system escalates rather than
integrates.
Part I: System Conditions Currently Operating
The following table identifies seven interlocking system conditions that are presently generating
harm. Each condition is supported by a recognized academic model, is documented in the case
record, and has produced specific observable results.
# System Condition Academic Model Evidence in Record Current Result
1 Narcissistic
System Structure
Hotchkiss, Why Is It
Always About Y ou?
(2003); Freyd,
Institutional
Betrayal (2014)

System roles: Central
Operator,
Agents of Harm,
Enablers,
Scapegoat/Target
Central operator:
Property Manager;
Agents of harm:
Attorneys and
Insurance Agents,
CCSO Victim
Advocate
Enablers: Property
Owners (unconscious
abdication)
Scapegoat/Target:
Plaintiffs
System adopts
false narrative
(“deposit dispute”)
to protect
central operator.
Mirrors DARVO:
Deny harms,
Attack reporter,
Reverse roles.
“Trick residents so
company can
make more
money” (2018
review).
“Adam is
maintenance”
(Bayles
email Sep 6,
2024).
2 Stage 1 Cornered
Animal
Syndrome (CAS)

Threat to PMIC
License
Kahneman &
Tversky, Prospect
Theory (1979): risk-
seeking
behavior under
perceived sure
loss.

Seddon, Vanguard
Method:
failure demand
spiral.
LLR investigation of
PMIC
license initiated by
Plaintiffs.
Defense sought to
quash subpoenas
directed at records.
Seven documented
escalations after
notice of harm.
No substantial
remediation
attempted.
Escalation of harm
with no attempt
to remedy. “Win at
all costs”
to preserve image.
Each escalation
generates further
“ask for justice”
requiring more
aggressive harm
response.
Marginal cost of
further bad
behavior perceived
as zero.
3 Captured
Counsel

(SAC 181 / Phelps
Dunbar)
Freyd, Institutional
DARVO
(2024); Agency
conflict
literature
(Eisenhardt, 1989)
Phelps Dunbar
represents SAC 181
(Altman entity) but
defense posture
protects Bayles’
interests, not
Altmans’.
IPG Insurance’s client
(Altmans)
exposure driven up by
counsel’s
tactics.
Conflict documented
in Plaintiffs’
Opposition to Quash
(Jan 2026).
Altmans’ financial
exposure
dramatically
increased by
counsel acting in
Bayles’
interest.
Harm to plaintiffs
compounded.
Altmans receive
filtered
information (“just
a deposit
dispute”).
4 (Apparent)
Captured
Regulatory
Agency

(SC LLR)
Stigler, Theory of
Regulatory
Capture (1971);
Heffernan, Willful
Blindness
(2011)
LLR stonewalled
McNeil when he
contacted them to
provide additional
evidence.
Plaintiff forced to
email evidence page
and record read
receipt to
ensure accountability.

No penalty issued so
far for PMIC who:
• Falsified postal
evidence
• Distributed private
images
• Retaliated against
reporting tenant
• Misrepresented
material facts
If LLR permits
Bayles to retain
license, the
message to every
PMIC in SC is:
there is no
consequence for
tenant abuse.

Vulnerable people
placed at
continuing risk.
Plaintiffs deprived
of regulatory
protection they are
entitled to.
5 (Apparent)
Captured
Law Enforcement

(CCSO)
Freyd, Betrayal
Blindness
(1996): suppression
of
awareness of betrayal
by
trusted institutions.
Institutional betrayal
literature.
CCSO Victim
Advocate “Dierra”
told Plaintiff McNeil:
“We don’t
help people like
you.”
Investigation
stonewalled and
dropped despite clear
evidence provided.

Forced Plaintiffs to
consider SLED
referral.
Status-based
exclusion from
victim protection
services.

Plaintiffs denied
the LE protection
available
to other citizens.
Compounds
institutional
betrayal
and clinical PTSD
(PCL-5: 76/80).
6 Willful Blindness

(Altman Family)
Heffernan, Willful
Blindness:
Why We Ignore the
Obvious at
Our Peril (2011).

Senge, The Fifth
Discipline:
mental models as
invisible
assumptions that
constrain
action.
Altmans operate
under “Unconscious
Abdication” mental
model: delegation of
all property
management with no
oversight, enabling
bad actor behavior.
May have accepted
Bayles’ narrative
about Plaintiffs .
No direct engagement
with Plaintiffs despite
documented
harm.
Owners remain
shielded from
reality of what is
being done in their
name.
Counsel’s
information
filtering
reinforces
blindness.
Blindness enables
continuation
of harm.

Does not excuse
liability.
7 Pre-Shock
Latency

(Altman
Awareness Gap)
Kübler-Ross, On
Death and Dying
(1969): denial as first
response to
catastrophic
information.

Meadows, Thinking
in Systems: delay
between stimulus and
response as system
vulnerability.
Altmans likely have
not yet processed full
scope of collection
exposure
(Entire portfolio
reachable
at 2–5¢ on the dollar
via estoppel).
April 3 hearing is
threshold event
where this
information becomes
unavoidable and even
without estoppel
entire portfolio will
not likely cover fair
settlement rage.
Current behavioral
mode:
Corporate Logic
(managed
litigation).
Post-hearing
behavioral mode:
system conditions
favorable for shift
to Cornered
Animal Syndrome
Stage 2.
These seven conditions form a self-reinforcing system.
• The narcissistic structure (Condition 1) generates harm.
• The central operator’s self-preservation drive (Condition 2) escalates it.
• Captured counsel (Condition 3) amplifies exposure while filtering information.
• Captured regulatory and law enforcement bodies (Conditions 4–5) remove the external
checks that would normally constrain the system.
• The owners’ willful blindness (Condition 6) permits the system to operate without the
intervention of the only actors with the authority to stop it.
• And the awareness gap (Condition 7) means the one force powerful enough to override
all other conditions - the Altmans’ rational self-interest - has not yet been activated.
Part II: Post-Threshold Conditions (Triggered by April 3 Hearing)
The April 3, 2026 hearing is a bifurcation point. If the Court grants deemed admissions, partial summary judgments,
or summary judgments on any substantial claims, the settlement range moves from negotiable to existential. The
following conditions are predicted to activate at that threshold, compounding the risks identified in Part I.
# Triggered
Condition
Academic Model Predicted Trigger
Mechanism
Predicted
Behavioral
Result
8 Stage 2
Cornered
Animal
Syndrome

(Altman Family
Activation)
Kahneman &
Tversky, Prospect
Theory (1979):
extreme risk-
seeking when all
outcomes
perceived as losses.

Meadows: system
behavior
when negative
feedback loops
are overwhelmed.
Deemed
admissions
convert
liability from
speculative to
fixed. Settlement
range ($19.6M
conservative;
$100M–$300M
high-end)
approaches or
exceeds
$40M equity
buffer.

Path narrowing:
“best case”
settlement
becomes
indistinguishable
from “worst
case” total loss.
Risk inversion:
high-risk legal
gambles become
“cheaper” than
certain
bankruptcy.
Scorched-earth
tactics: delay,
retaliatory
filings, asset
transfers,
extreme
gaslighting.
Marginal cost of
further
escalation = zero.
Loss of
proportionality:
“already losing
$40M” removes
deterrent against
further harm.
9 Narcissistic
Collapse
and Rage

(Bayles +
System)
Kohut, The Analysis
of the
Self (1971):
narcissistic rage
as protection of
grandiose self.

Kernberg, Borderline
Conditions
and Pathological
Narcissism
(1975).

Hotchkiss: five
phases of
narcissistic collapse.
Deemed
admissions
establish
as fact: falsified
evidence,
privacy invasion,
retaliation,
fraudulent
inducement.

Bayles’
professional
identity
(“competent
PMIC”) and
Altmans’
Phase 1:
Narcissistic
injury
(identity crack).
Phase 2: Rage
and retaliation
—smear
campaigns,
reputation
attacks, victim-
playing, threats.
“How dare you
stop feeding my
ego?”
Phase 3:
Collapse—
# Triggered
Condition
Academic Model Predicted Trigger
Mechanism
Predicted
Behavioral
Result
social identity
(“respected
community leaders
/ Housing
Board Chair”)
simultaneously
threatened with
public
dissolution.
psychological
freefall when
tactics fail.

Key risk: rage is
not emotional
release but
control
restoration.
When rage fails,
ESCALATION.
10 Dual
Narcissistic
Collapse

(CNO + EN
Simultaneous
Failure)
Hotchkiss, Why Is It
Always About
You? (2003):
collapse when
grandiose self-image
meets undeniable
contradiction.

Kernberg, Borderline
Conditions and
Pathological
Narcissism (1975):
rage as primitive
defense against
annihilation anxiety.

Shaw &
Webber, Narcissistic
Abuse
Recovery (2017):
systemic collapse
when both central
operator and
enablers lose
narrative control
simultaneously.
CNO (property
manager)
collapse: LLR
findings + deemed
admissions destroy
professional
identity and PMIC
license viability.
Cannot maintain
"competent
professional"
narrative.

EN (property
owners)
collapse: Discover
(a) entire portfolio
at existential risk,
(b) counsel
protected CNO not
them, (c) their
sworn probate
values are the
weapon, (d)
"deposit dispute"
narrative was
false.

Convergence
event: Both CNO
and EN realize
their interests
CNO loses
incentive to
protect EN: If
PMIC license
lost regardless,
no reason to
minimize EN
exposure. May
escalate to "take
them down with
me."

EN panic
without
guardrails:
Suddenly aware
they've been
misled into
existential
exposure, but
past the point
where
withdrawal is
possible. Classic
"betrayed
betrayer" rage.

System
fragmentation
risk: When CNO
and EN interests
diverge under
# Triggered
Condition
Academic Model Predicted Trigger
Mechanism
Predicted
Behavioral
Result
diverge — but EN
discover this
AFTER exposure
is locked in. CNO
loses control of
EN narrative; EN
lose ability to exit
cleanly.
existential threat,
coordination
breaks down.
Each actor may
pursue
independent
survival
strategies —
increasing
unpredictability
and danger to
TGT.

Highest
volatility state:
Two
simultaneous
collapses + loss
of mutual
narrative =
compounding
rage with no
systemic brake.
11 DARVO
Intensification

(System-Wide)
Freyd, DARVO
(1997):
Deny, Attack,
Reverse Victim
and Offender.

Freyd, Institutional
DARVO
(2024): when
organizations
commit DARVO
with institutional
complicity.
As facts are
judicially
established, denial
becomes
unsustainable.
System must
either
acknowledge
harm or intensify
the attack
on the reporter.
Predicted pivot:
Plaintiffs
reframed as
aggressors
(“extortion,”
“vexatious
litigant”) to justify
escalation.
Institutional
DARVO at scale:
Defendants
position
themselves
as victims of
litigation.
Plaintiffs’
documented
harms
recast as
“attacks.”
Three-stage
pattern: Deny
through policy
→ Scrutinize
the individual →
Organization
as victim.
# Triggered
Condition
Academic Model Predicted Trigger
Mechanism
Predicted
Behavioral
Result
Exploits betrayal
blindness.
12 Identity /
Mental Model
Collapse

(Altman
Family)
Senge, Mental
Models (1990):
invisible
assumptions that
constrain action.

Kübler-Ross grief
stages
applied to status loss.

Cognitive
Dissonance
(Festinger, 1957).
Altmans discover
simultaneously:
(a) Counsel has
been protecting
Bayles, not them;
(b) Their portfolio
is reachable
at 2–5¢ on the
dollar;
(c) Their sworn
probate values
constitute the
weapon;
(d) The “deposit
dispute” is a
$20M–$300M
existential event.
Shock → Denial
→ Anger
→ Bargaining
(too late)
→ System
conditions
favorable for
externalized
aggression.

The “cognitive
snap”:
when the
distance between
believed
narrative and
reality
is too great, the
system
defaults to
aggression rather
than integration.

“Rather burn the
system down
than admit the
paradigm
is broken.”
13 Systemic
Sabotage

(Terminal CAS
Behavior)
Meadows, Thinking
in Systems:
“Playing to ensure
no one
else wins.”

Game theory: spite
strategies
when utility function
inverts.
When total
liability exceeds
total net worth,
rational
cooperation
incentive vanishes.
The system is no
longer
fighting for a
result; it is
fighting for
existence.
Asset transfers,
fraudulent
conveyances,
creation of new
entities.
Witness
intimidation or
tampering.
Extra-legal
pressure on
Plaintiffs.
Deliberate
destruction of
# Triggered
Condition
Academic Model Predicted Trigger
Mechanism
Predicted
Behavioral
Result
No dignified exit
visible.
evidence.
Not “playing to
win” but
“playing to
ensure no one
else wins.”
The post-threshold conditions represent a phase shift from managed litigation to existential
combat.
• Stage 2 CAS (Condition 8) removes the rational incentive to settle.
• Narcissistic collapse (Condition 9) replaces calculation with rage.
• Intensified DARVO (Condition 10) reframes Plaintiffs as aggressors to justify escalation.
• Mental model collapse (Condition 11) overwhelms the Altmans’ capacity for rational
response.
• And systemic sabotage (Condition 12) describes the terminal behavior of a system that
perceives total destruction as inevitable and shifts from fighting to win to ensuring no one
else wins.
The critical insight is that these are not independent risks. They are sequential and
compounding. Each triggered condition activates the next. The April 3 hearing is the
ignition event for the entire cascade.
Implication for Plaintiffs’ Safety
Plaintiffs’ counselor has expressed deep concern for the McNeil-Poyer family’s safety after
reviewing the high-stakes dynamics of this case alongside the documented pattern of systemic
dehumanization. That concern is grounded in the following convergence:
• A system already operating under Stage 1 CAS with documented escalation after notice
• Captured counsel filtering information from the principals who could intervene
• Regulatory and law enforcement bodies that have failed to provide protection
• A threshold event (April 3) that creates conditions favoring converting managed risk to
existential panic
• An exposed target family that includes a Plaintiff with clinical PTSD (PCL-5: 76/80) and a
documented history of being told by victim services: “We don’t help people like you”
• Defendants with established capacity for dehumanization (“Trick residents so company can
make more money”) and escalation (two law firms deployed for lawfare against pro se plaintiffs)
Plaintiffs ask the Court to observe that established behavioral models - Prospect Theory,
narcissistic collapse literature, institutional DARVO research, and systems dynamics -
converge on the same prediction: that the April 3 hearing sets up conditions that
historically trigger a measurable increase in volatility, and that transparency and judicial
awareness are the primary mechanisms available to dampen that volatility before it
produces irreversible harm.
Condition 10 represents the highest-risk state predicted by the model: the moment when
both the Central Narcissistic Operator and the Enablers experience simultaneous collapse
and discover their interests have diverged - but only after both are locked into existential
exposure. In a system where the property manager (CNO) loses professional identity and PMIC
license viability, the incentive to protect the property owners (EN) vanishes. In a system where
the property owners discover they have been misled by both their property manager and their
own counsel into liquidation level exposure, conditions favor the "betrayed betrayer" dynamic
that produces rage that has no systemic outlet.
The convergence of these two collapses – for which the ideal conditions are predicted to occur in
the days immediately following the April 3 hearing as information assimilation completes –
would remove the last coordination mechanism holding the defense system together.
At that point, conditions favor each actor pursuing independent survival strategies, with
Plaintiffs in a system where conditions favor them becoming exposed to fragmented,
uncoordinated aggression from multiple directions simultaneously.
This analysis is filed on the public record because observation is itself a protective measure. A
system that knows it is being watched behaves differently than one that operates in shadow.

Post-threshold phase shift and safety implications, pp. 24-29 (p. 24-29)

Part II: Post-Threshold Conditions (Triggered by April 3 Hearing) The April 3, 2026 hearing is a bifurcation point. If the Court grants deemed admissions, partial summary judgments, or summary judgments on any substantial claims, the settlement range moves from negotiable to existential. The following conditions are predicted to activate at that threshold, compounding the risks identified in Part I.

The post-threshold conditions represent a phase shift from managed litigation to existential combat. • Stage 2 CAS (Condition 8) removes the rational incentive to settle. • Narcissistic collapse (Condition 9) replaces calculation with rage. • Intensified DARVO (Condition 10) reframes Plaintiffs as aggressors to justify escalation. • Mental model collapse (Condition 11) overwhelms the Altmans’ capacity for rational response. • And systemic sabotage (Condition 12) describes the terminal behavior of a system that perceives total destruction as inevitable and shifts from fighting to win to ensuring no one else wins. The critical insight is that these are not independent risks. They are sequential and compounding. Each triggered condition activates the next. The April 3 hearing is the ignition event for the entire cascade. Implication for Plaintiffs’ Safety Plaintiffs’ counselor has expressed deep concern for the McNeil-Poyer family’s safety after reviewing the high-stakes dynamics of this case alongside the documented pattern of systemic dehumanization. That concern is grounded in the following convergence: • A system already operating under Stage 1 CAS with documented escalation after notice • Captured counsel filtering information from the principals who could intervene • Regulatory and law enforcement bodies that have failed to provide protection • A threshold event (April 3) that creates conditions favoring converting managed risk to existential panic • An exposed target family that includes a Plaintiff with clinical PTSD (PCL-5: 76/80) and a documented history of being told by victim services: “We don’t help people like you” • Defendants with established capacity for dehumanization (“Trick residents so company can make more money”) and escalation (two law firms deployed for lawfare against pro se plaintiffs) Plaintiffs ask the Court to observe that established behavioral models - Prospect Theory, narcissistic collapse literature, institutional DARVO research, and systems dynamics - converge on the same prediction: that the April 3 hearing sets up conditions that historically trigger a measurable increase in volatility, and that transparency and judicial awareness are the primary mechanisms available to dampen that volatility before it produces irreversible harm. Condition 10 represents the highest-risk state predicted by the model: the moment when both the Central Narcissistic Operator and the Enablers experience simultaneous collapse and discover their interests have diverged - but only after both are locked into existential exposure. In a system where the property manager (CNO) loses professional identity and PMIC license viability, the incentive to protect the property owners (EN) vanishes. In a system where the property owners discover they have been misled by both their property manager and their own counsel into liquidation level exposure, conditions favor the "betrayed betrayer" dynamic that produces rage that has no systemic outlet. The convergence of these two collapses – for which the ideal conditions are predicted to occur in the days immediately following the April 3 hearing as information assimilation completes – would remove the last coordination mechanism holding the defense system together. At that point, conditions favor each actor pursuing independent survival strategies, with Plaintiffs in a system where conditions favor them becoming exposed to fragmented, uncoordinated aggression from multiple directions simultaneously. This analysis is filed on the public record because observation is itself a protective measure. A system that knows it is being watched behaves differently than one that operates in shadow.

Exhibit C Cover (p. 46-46)

EXHIBIT C
Defendant Infraction Matrix

Comprehensive Enforcement Matrix—identified violations, pp. 30-37 (p. 30-37)

EXHIBIT C
Defendant Infraction Matrix

COMPREHENSIVE ENFORCEMENT MATRIX
McNeil & Poyer v. SAC 181 et al. (2025-CP-10-05095) | March 20, 2026 Legend: • [CR] = Criminal • [CI] = Civil • [RE] = Regulatory • = Pending More Evidence • Footnote numbers = See accountability notes below table

Felony Forgery [CR]
(SC 16-13-10:
falsified USPS postmark, Sept 5, 2025, $2,000+)

False Pretenses
[CR] (SC 16-
13-240: $2,295 security deposit fraud)

Harassment, 2nd Degree
[CR] (SC 16-3-
1700: Sept 2024-Feb 2026 coordinated campaign, 79/80 gaslighting severity)

Obstruction of Justice [CR] (LLR File 2025-566 interference, Feb 20 deadline)

Witness Tampering
[CR] (18 USC
1512(b)(3): AppFolio contact Jan 9)

PMIC Trust Account Violations
[RE] (SC 40-
57-136: SAC
181 OP
account commingling)

PMIC
Obstruction
[RE] (SC 40-
57-3403: obstructing
LLR
investigation)

Security Deposit Violations
[CI][CR] (SC
27-40-410: late return, treble damages)

Retaliatory Eviction
[CI][CR] (SC
27-40-910: LLR complaint retaliation)

Privacy Violations
[CI][RE] (21-
platform image syndication, July-Sept 2025)

Unfair Trade Practices [CI]
(SC 39-5-20:
systematic tenant exploitation)

Fraudulent Conveyance
[CI][CR]
(Flash Transfer $5, probate undervaluatio n $1.27M →
$251K)

Corporate Veil Piercing
[CI] (SAC 181
OP
operational unity, Tara's singular control)

Tax Fraud [CR] (Estate tax evasion via undervaluatio n, devaluation of Charles Realty stock 95% 2006- 2020)

Attorney Misconduct - Rule 4.3 [RE] (Advising adverse pro se, Oct 16 email)

Attorney Misconduct - Rule 11/37
[CI][RE]
(Frivolous AI motion, discovery obstruction)

Attorney Conflict of Interest [RE]
(RPC 1.7:
Bolyard representing adverse parties in crossclaim)

Litigation Gaslighting /
DARVO [CI]
(Oct 2025-Jan 2026: denying documented evidence, mischaracteri zation, causing PCL-5
76/80 PTSD)

Insurance Bad Faith [CI] (Misrepresenti ng case scope to IPG as "deposit dispute")

Public Official Hypocrisy
[CI][PME]
(Affordable Housing Commission chair while executing Flash Transfer/retali atory eviction)

Exhibit C — Comprehensive Enforcement Matrix (p. 47-54)

COMPREHENSIVE ENFORCEMENT MATRIX
McNeil & Poyer v. SAC 181 et al. (2025-CP-10-05095) | March 20, 2026
Legend:
• [CR] = Criminal
• [CI] = Civil
• [RE] = Regulatory
• = Pending More Evidence
• Footnote numbers = See accountability notes below table
Violation /
Infraction
SAC 181
LLC
Charles
S.
Altman
Jonathan
S. Altman
Meridia
n / Snee
Entities
Tara
Bayles
(PMIC
83633)
Adam
Bayle
s
Phelps
Dunbar
LLP
Kevin
OBrien
Justine
Tate
Resnick
Louis PC
Alicia
Bolyard
IPG /
Gladys
Lambert
Felony
Forgery [CR]
(SC 16-13-10:
falsified USPS
postmark,
Sept 5, 2025,
$2,000+)
CCSO →
Solicitor
→ SC AG
USPS
OIG → US
Attorney
CCSO →
Solicitor
USPS
OIG

Primary
: CCSO
→
Solicitor
→ SC AG
USPS
OIG →
US
Attorney
Primary:
CCSO →
Solicitor
→ SC AG
USPS
OIG → US
Attorney
License:
LLR
emergen
cy
suspensi
on
CCSO
¹

False
Pretenses
[CR] (SC 16-
13-240:
$2,295
security
deposit fraud)
CCSO →
Solicitor
→ SC AG
CCSO →
Solicitor

CCSO →
Solicitor
→ SC AG
Primary:
CCSO →
Solicitor
→ SC AG
LLR (File
2025-
566)
CCSO
¹

Violation /
Infraction
SAC 181
LLC
Charles
S.
Altman
Jonathan
S. Altman
Meridia
n / Snee
Entities
Tara
Bayles
(PMIC
83633)
Adam
Bayle
s
Phelps
Dunbar
LLP
Kevin
OBrien
Justine
Tate
Resnick
Louis PC
Alicia
Bolyard
IPG /
Gladys
Lambert
Harassment,
2nd Degree
[CR] (SC 16-3-
1700: Sept
2024-Feb
2026
coordinated
campaign,
79/80
gaslighting
severity)
CCSO →
Solicitor²
CCSO →
Solicitor²
CCSO →
Solicitor²
[PME]
Primary
: CCSO
→
Solicitor
SC AG
(pattern)
Primary:
CCSO →
Solicitor
LLR
(professi
onal
conduct)
CCSO
¹
Oct-Jan:
CCSO →
Solicitor
SC ODC³
Oct-Jan:
CCSO →
Solicitor
SC ODC³
Oct-Jan:
CCSO →
Solicitor
SC ODC³
Oct-Jan:
CCSO →
Solicitor
SC ODC³
Primary
Oct-Jan:
CCSO →
Solicitor
SC ODC³
Coordina
tion:
CCSO →
Solicitor
Insurance
fraud
investigati
on⁴
Obstruction
of Justice
[CR] (LLR File
2025-566
interference,
Feb 20
deadline)

Primary
: CCSO
→ SC AG
FBI (if
federal
nexus)
Primary:
CCSO →
SC AG
FBI
LLR
emergen
cy action

Discover
y
obstruct
ion:
CCSO →
SC AG⁵
SC ODC
Quash
motion
timing:
CCSO →
SC AG⁵
SC ODC
CCSO⁵
SC ODC
Primary:
CCSO →
SC AG⁵
SC ODC
Coordinat
ed
obstructio
n: CCSO →
SC AG⁵
SC ODC
Strategy
coordinat
ion:
Investigati
on [PME]
Witness
Tampering
[CR] (18 USC
1512(b)(3):
AppFolio
contact Jan 9)

Primary
: FBI →
US
Attorney
CCSO →
Solicitor
Primary:
FBI → US
Attorney
CCSO →
Solicitor
LLR
emergen
cy
suspensi
on

Coordina
tion: FBI →
US
Attorney
SC ODC
Primary
legal
strategy:
FBI → US
Attorney
SC ODC
[PME]
PMIC Trust
Account
Violations
[RE] (SC 40-
57-136: SAC
181 OP
Civil veil-
piercing
Civil
liability

Civil +
regulato
ry
Primary:
LLR (File
2025-
566) →
emergen
cy
Indire
ct via
Meridi
an¹

Violation /
Infraction
SAC 181
LLC
Charles
S.
Altman
Jonathan
S. Altman
Meridia
n / Snee
Entities
Tara
Bayles
(PMIC
83633)
Adam
Bayle
s
Phelps
Dunbar
LLP
Kevin
OBrien
Justine
Tate
Resnick
Louis PC
Alicia
Bolyard
IPG /
Gladys
Lambert
account
commingling)
suspensi
on →
revocatio
n
SC AG
(criminal
referral)
PMIC
Obstruction
[RE] (SC 40-
57-3403:
obstructing
LLR
investigation)

LLR
disciplin
e
Primary:
LLR →
license
revocatio
n
SC AG
(criminal
)
Indire
ct¹
LLR
complai
nt⁶
LLR
complain
t⁶
LLR
complain
t⁶
LLR
complaint
⁶
Primary:
LLR
complaint⁶
[PME]
Security
Deposit
Violations
[CI][CR] (SC
27-40-410:
late return,
treble
damages)
Primary
civil:
Court
treble
damages
SC AG
(pattern)
Court

Court
SC AG
(system
atic)
Primary:
Court +
LLR
SC AG
(pattern)
Court¹

Court
(bad faith
defense)⁴
Retaliatory
Eviction
[CI][CR] (SC
27-40-910:
LLR complaint
retaliation)
Primary:
Court
damages
SC AG
Knowle
dge:
Court
SC AG
Beneficia
l owner:
Court
[PME]
SC AG
[PME]
Primary
: Court
SC AG
Primary:
Court +
LLR
SC AG
Court¹

Privacy
Violations
[CI][RE] (21-
platform
Court
damages
Court

Primary
: Court
FTC
(unfair
Primary:
Court +
LLR
FTC
Court¹

Violation /
Infraction
SAC 181
LLC
Charles
S.
Altman
Jonathan
S. Altman
Meridia
n / Snee
Entities
Tara
Bayles
(PMIC
83633)
Adam
Bayle
s
Phelps
Dunbar
LLP
Kevin
OBrien
Justine
Tate
Resnick
Louis PC
Alicia
Bolyard
IPG /
Gladys
Lambert
image
syndication,
July-Sept
2025)
practice
s)
HUD
OIG
[PME]
HUD OIG
[PME]
Unfair Trade
Practices [CI]
(SC 39-5-20:
systematic
tenant
exploitation)
Primary:
SC AG →
investiga
tion
Court
treble
damages
SC AG
Court
SC AG
[PME]
Court
[PME]
Primary
: SC AG
→
shutdow
n order
FTC (if
interstat
e)
Court
Primary:
SC AG +
LLR
Court
Court¹

SC AG
[PME]⁴
Fraudulent
Conveyance
[CI][CR]
(Flash
Transfer $5,
probate
undervaluatio
n $1.27M →
$251K)
Primary:
Probate
Court
Court
(constru
ctive
trust)
SC AG
(elder
abuse)
[PME]
Primary:
Probate
Court
Court
SC AG
[PME]
Primary
executor:
Probate
Court
Court (lis
pendens
target)
SC AG
(elder
abuse)
[PME]
IRS
(estate
tax) [PME]
Probate
Court

Corporate
Veil Piercing
[CI] (SAC 181
OP
operational
unity, Tara's
Primary
target:
Court →
individua
l liability
Register
ed
agent:
Court →
personal
liability
Beneficia
l owner:
Court →
personal
liability
[PME]
Court
(unified
enterpri
se)
Operatio
nal
control:
Court →
personal
liability
Court¹

Violation /
Infraction
SAC 181
LLC
Charles
S.
Altman
Jonathan
S. Altman
Meridia
n / Snee
Entities
Tara
Bayles
(PMIC
83633)
Adam
Bayle
s
Phelps
Dunbar
LLP
Kevin
OBrien
Justine
Tate
Resnick
Louis PC
Alicia
Bolyard
IPG /
Gladys
Lambert
singular
control)
judgmen
t
Tax Fraud
[CR] (Estate
tax evasion via
undervaluatio
n, devaluation
of Charles
Realty stock
95% 2006-
2020)

Primary:
IRS
Criminal
Investiga
tion
SC DOR
Primary
executor:
IRS
Criminal
Investigati
on
SC DOR
Public
official
angle: FBI
Public
Corruptio
n [PME]

Attorney
Misconduct -
Rule 4.3 [RE]
(Advising
adverse pro
se, Oct 16
email)

Primary:
SC ODC →
sanctions
→
suspensio
n
Primary:
SC ODC →
sanctions
→
suspensio
n

Attorney
Misconduct -
Rule 11/37
[CI][RE]
(Frivolous AI
motion,
discovery
obstruction)

Primary
firm:
Court
sanction
s
SC ODC
Primary
author:
Court
sanctions
+ fees
SC ODC
Court
sanctions
SC ODC
Coordina
ted: Court
sanctions
SC ODC
Coordinat
ed: Court
sanctions
SC ODC

Attorney
Conflict of
Interest [RE]

Beneficia
ry: Court
(if
Primary:
SC ODC →
disqualific
Violation /
Infraction
SAC 181
LLC
Charles
S.
Altman
Jonathan
S. Altman
Meridia
n / Snee
Entities
Tara
Bayles
(PMIC
83633)
Adam
Bayle
s
Phelps
Dunbar
LLP
Kevin
OBrien
Justine
Tate
Resnick
Louis PC
Alicia
Bolyard
IPG /
Gladys
Lambert
(RPC 1.7:
Bolyard
representing
adverse
parties in
crossclaim)
Meridian
settles
poorly)
ation →
malpractic
e exposure
Litigation
Gaslighting /
DARVO [CI]
(Oct 2025-Jan
2026: denying
documented
evidence,
mischaracteri
zation,
causing PCL-5
76/80 PTSD)
Court
(aggravat
ing
damages
)
Court
Court
[PME]
Primary
: Court
(emotio
nal
distress
damage
s)
Primary:
Court
(emotion
al
distress
damages
)
Court¹
Primary
firm
Oct-Jan:
Court
(damage
s)
SC ODC
(fitness
to
practice)
⁷
Primary
Oct-Jan:
Court
(damages
)
SC ODC⁷
Coordina
ted:
Court
SC ODC⁷
Coordina
ted: Court
SC ODC⁷
Primary
Oct-Jan:
Court
(damages)
SC ODC⁷
Strategic
coordinat
ion: Court
[PME]⁴
Insurance
Bad Faith [CI]
(Misrepresenti
ng case scope
to IPG as
"deposit
dispute")
Excess
judgmen
t
exposur
e: IPG
claims →
coverage
litigation

Primary:
IPG
internal
investiga
tion →
malpractic
e claim
SC ODC
Coordina
ted: IPG
→
malpracti
ce
SC ODC
IPG →
malpracti
ce

Primary
adjuster:
State
insurance
regulator
[PME]
Bad faith
litigation
Public
Official
Hypocrisy
[CI][PME]
(Affordable
Housing
Commission
chair while
executing

Primary:
Media
accounta
bility
Charlesto
n County
ethics
inquiry
[PME]

Violation /
Infraction
SAC 181
LLC
Charles
S.
Altman
Jonathan
S. Altman
Meridia
n / Snee
Entities
Tara
Bayles
(PMIC
83633)
Adam
Bayle
s
Phelps
Dunbar
LLP
Kevin
OBrien
Justine
Tate
Resnick
Louis PC
Alicia
Bolyard
IPG /
Gladys
Lambert
Flash
Transfer/retali
atory eviction)
Removal
from
commissi
on [PME]

FOOTNOTES - ACCOUNTABILITY NUANCES
¹ Adam Bayles: Liability primarily derivative through:
• Marriage to Tara (community property, joint financial benefit)
• MRG Investing Company, LLC membership (if applicable)
• Knowledge of/participation in Meridian operations (discovery pending)
• Potential signatory authority on accounts (Synovus subpoena pending)
² SAC 181/Charles/Jonathan Harassment:
• Sept 2024-Aug 2025: Indirect (knew or should have known of Tara's campaign)
• Aug 2025-present: Direct (retaliatory eviction execution, funding defense strategy that employs gaslighting)
• Jonathan: Beneficial owner role + public official hypocrisy compounds moral culpability
³ Defense Counsel Harassment (Oct 2025-Jan 2026):
• Pattern: Litigating as if documented events (falsified postmark, 21-platform images, LLR obstruction) never occurred
• Method: Characterizing 8-count fraud case as "deposit dispute" across multiple filings
• Escalation: AI motion (Nov 12), emergency judge-shopping (Jan 27), mischaracterizing criminal notice as "threats" (Jan 27)
• Harm: Direct cause of PCL-5 76/80 (severe PTSD), gaslighting 79/80, Jan 28 breakdown
• Criminal basis: SC 16-3-1700 requires "course of conduct" causing "substantial emotional distress"—documented via clinical
assessments
• ODC basis: RPC 8.4(d) (conduct prejudicial to administration of justice)
⁴ IPG/Lambert Role:
• Coordination evidence: Discovery responses, settlement posture, defense strategy alignment
• Bad faith theory: Knew or should have known case scope exceeded "deposit dispute" framing
• Pending evidence: IPG claim file (discovery), Lambert communications with defense counsel
⁵ Attorney Obstruction of Justice:
• Quash motions: Filed Jan 8 (Bolyard), Jan 12 (OBrien)—within 42 days of LLR Feb 20 deadline
• AppFolio witness contact: Jan 9 (Meridian, coordinated with Bolyard's Jan 8 motion)
• Criminal basis: SC common law obstruction (hindering investigation) + 18 USC 1512 (federal)
• Pattern: 32-day silence on Flash Transfer allegations while blocking corroborating evidence (Synovus)
⁷ Attorney Fitness to Practice:
• Gaslighting as professional misconduct: Systematic denial of record evidence causing documented psychological harm
• DARVO pattern: Deny (evidence doesn't exist) → Attack → Reverse Victim & Offender (criminal notice becomes "threats")
• SC ODC standard: "Conduct involving dishonesty, fraud, deceit or misrepresentation" (RPC 8.4(c))
• Medical evidence: PCL-5 76/80, gaslighting severity 79/80, emergency health motions Jan 28-30

Enforcement Matrix accountability notes, pp. 37-38 (p. 37-38)

FOOTNOTES - ACCOUNTABILITY NUANCES
¹ Adam Bayles: Liability primarily derivative through: • Marriage to Tara (community property, joint financial benefit) • MRG Investing Company, LLC membership (if applicable) • Knowledge of/participation in Meridian operations (discovery pending) • Potential signatory authority on accounts (Synovus subpoena pending) ² SAC 181/Charles/Jonathan Harassment: • Sept 2024-Aug 2025: Indirect (knew or should have known of Tara's campaign) • Aug 2025-present: Direct (retaliatory eviction execution, funding defense strategy that employs gaslighting) • Jonathan: Beneficial owner role + public official hypocrisy compounds moral culpability ³ Defense Counsel Harassment (Oct 2025-Jan 2026): • Pattern: Litigating as if documented events (falsified postmark, 21-platform images, LLR obstruction) never occurred • Method: Characterizing 8-count fraud case as "deposit dispute" across multiple filings • Escalation: AI motion (Nov 12), emergency judge-shopping (Jan 27), mischaracterizing criminal notice as "threats" (Jan 27) • Harm: Direct cause of PCL-5 76/80 (severe PTSD), gaslighting 79/80, Jan 28 breakdown • Criminal basis: SC 16-3-1700 requires "course of conduct" causing "substantial emotional distress"—documented via clinical assessments • ODC basis: RPC 8.4(d) (conduct prejudicial to administration of justice) ⁴ IPG/Lambert Role: • Coordination evidence: Discovery responses, settlement posture, defense strategy alignment • Bad faith theory: Knew or should have known case scope exceeded "deposit dispute" framing • Pending evidence: IPG claim file (discovery), Lambert communications with defense counsel ⁵ Attorney Obstruction of Justice: • Quash motions: Filed Jan 8 (Bolyard), Jan 12 (OBrien)—within 42 days of LLR Feb 20 deadline • AppFolio witness contact: Jan 9 (Meridian, coordinated with Bolyard's Jan 8 motion) • Criminal basis: SC common law obstruction (hindering investigation) + 18 USC 1512 (federal) • Pattern: 32-day silence on Flash Transfer allegations while blocking corroborating evidence (Synovus) ⁷ Attorney Fitness to Practice: • Gaslighting as professional misconduct: Systematic denial of record evidence causing documented psychological harm • DARVO pattern: Deny (evidence doesn't exist) → Attack → Reverse Victim & Offender (criminal notice becomes "threats") • SC ODC standard: "Conduct involving dishonesty, fraud, deceit or misrepresentation" (RPC 8.4(c)) • Medical evidence: PCL-5 76/80, gaslighting severity 79/80, emergency health motions Jan 28-30