When Two Firms Coordinate to Hide Evidence Before a Regulatory Deadline

Document Overview

Executive Summary

There is yet another round of defense conduct triggered escalation in the case that began with a retaliatory eviction August 1 2025 followed by a late deposit return explained with a suspicious looking postmark from PMIC Tara Bayles of Meridian Residential Group, LLC. Through connecting the dots found during litigation discovery, Plaintiffs uncovered what appears to be a unified enterprise between a property owner's LLC, a property management company, a PMIC (Property Manager-in-Charge), and the house-holding LLC including beneficial ownership by a public official serving on the City's affordable housing commission, all seemingly sharing operational control over security deposit funds in violation of South Carolina's trust account requirements.

Then the defense coordinated to block the evidence.

The Obstruction Pattern: Timeline Proves Coordination

December 23, 2025 — Plaintiffs serve subpoenas to four third-party witnesses:

• Synovus Bank (for "SAC 181 OP" operating account records showing commingling)
• AppFolio (property management software used to send the "Ghost" Notice to Vacate, among other functions)
• ShowMojo (syndicated distribution of property ads, including those with images of Plaintiffs, belongings, and their family dog used without consent)
• Matterport (virtual tour whose records show privacy violations)

January 8, 2026 — Resnick & Louis (Meridian's counsel) files Motion to Quash targeting AppFolio, ShowMojo, and Matterport subpoenas.

January 9, 2026 — The same day after filing its quash motion, Meridian directly contacts AppFolio with "formal notice" instructing AppFolio to refuse compliance.

January 12, 2026 — Two escalations occur:

1. AppFolio confirms Meridian's "formal notice" has caused them to withhold responsive documents pending court order
2. Phelps Dunbar (purportedly representing SAC 181 owner Charles Altman) files Motion to Quash the Synovus Bank subpoena—one day after the 19-day objection deadline under SCRCP 45(d)(2)(B), making the motion legally waived

January 12, 2026 (morning) — The same day, counsel Bolyard delays witness Phillips' deposition to February 24—four days AFTER the February 20 LLR investigation deadline.

February 20, 2026 — Statutory deadline for South Carolina Department of Labor, Licensing & Regulation investigation (PMIC investigation initiated September 23, 2025; 150-day deadline expires)

The Smoking Gun

This clustering of actions—all timed to prevent evidence from reaching the LLR investigator before the February 20 deadline—proves bad faith obstruction, not legitimate procedural concerns.

If the service defect were genuine, Defendants would have objected immediately on December 23. Instead, they waited 16-20 days for a narrow window before the regulatory deadline, then coordinated four simultaneous obstruction actions.

The Conflicts: Defense Counsel Protecting Non-Clients' Licenses While Abandoning Their Own Clients

The Bolyard Problem: Irreconcilable Conflict

Attorney Alicia Bolyard (Resnick & Louis) purports to represent three defendants: Meridian Residential Group, LLC, Tara Bayles (individually), and Adam Bayles (individually).

Meridian's Crossclaim (filed October 9, 2025) alleges that SAC 181 LLC bears primary fault while Meridian's liability is "only secondary or passive." To zealously defend this indemnity claim, Bolyard must argue:

• SAC 181 exercised control over security deposit handling
• The "SAC 181 OP" account commingling proves unified enterprise
• Veil-piercing doctrine applies; SAC 181 liable for Meridian's conduct

The Synovus Bank subpoena seeks precisely this evidence: account control, signatory authority, operational commingling.

Yet Bolyard simultaneously seeks to quash the identical Synovus subpoena, characterizing it as an "irrelevant fishing expedition."

Bolyard cannot argue both (A) "Synovus records are essential to prove Meridian's indemnity claim" AND (B) "Synovus records are irrelevant and should be blocked" in the same litigation.

This is unconsentable conflict per se under SC RPC 1.7(b)(3). Disqualification is mandatory.

The Plaintiffs' Opposition recommends striking Bolyard's quash motion as tainted by conflicted representation while preserving Meridian's October 9 Crossclaim (which remains operative judicial admission that SAC 181 bears "primary" fault).

The Phelps Dunbar Problem: Captured Counsel

Phelps Dunbar represents SAC 181 LLC (Charles S. Altman is registered agent). Yet for 32 days after Plaintiffs filed devastating evidence of a "Flash Transfer" scheme - property transferred for $5.00 as liability shield, beneficiary Jonathan Altman serves on City affordable housing commission the property management company Meridian Residential Group, LLC executing displacement tactics - Phelps Dunbar remained silent.

Instead, Phelps Dunbar filed a quash motion mirroring the minimizing Meridian characterization of this eight-count fraud case, describing it as merely "a landlord-tenant dispute involving the rental of the Property and the return of the related security deposit."

A competent defense counsel representing SAC 181 would immediately respond to veil-piercing allegations. Instead, Phelps Dunbar aggressively blocked the Synovus discovery that would prove or disprove corporate separateness—while remaining silent on the Flash Transfer itself.

The Impossible Choice: Phelps Dunbar faces an irreconcilable conflict between:

• SAC 181's interest (defend against veil-piercing by proving corporate separateness)
• (Meridian PMIC/CEO) Tara Bayles' non-client interest (protect PMIC license #83633 from regulatory investigation)

By blocking Synovus records, Phelps Dunbar protects Tara's license from evidence of commingling while abandoning SAC 181's veil-piercing defense. This suggests captured counsel serving non-client Tara Bayles' interests rather than represented client SAC 181.

The Witness Tampering Allegation

On January 9, 2026—one day after filing its quash motion—Meridian directly contacted AppFolio with "formal notice" instructing AppFolio to refuse compliance with Plaintiffs' subpoena.

AppFolio's January 12 email confirms:

"We have received formal notice from our customer, Meridian Residential Group, LLC, that they have filed an objection and/or Motion to Quash the third-party subpoena. We will await resolution of our customer's objection or a court order directing compliance before releasing their associated records."

Plaintiffs contend this satisfies all elements of S.C. Code § 16-9-340 (Obstruction of Law Enforcement):

1. Knowing conduct: Meridian sent "formal notice" with specific content about court filings
2. Willful obstruction: Meridian's January 12 escalation (after Plaintiffs' legal challenge) proves intentional obstruction
3. Hinders authorized official: LLR investigators conducting statutory PMIC investigation with 150-day deadline
4. In discharge of official duty: Investigation is authorized under S.C. Code § 40-57-720

The Plaintiffs' Opposition recommends:

• Criminal referral to Charleston County Solicitor for § 16-9-340 felony obstruction
• Federal criminal referral to FBI Charleston for 18 U.S.C. § 1512(b)(3) witness tampering
• Licensing referral to LLR for S.C. Code § 40-57-340(3) PMIC obstruction of investigation

The Evidence Defendants Are Trying to Hide

The "SAC 181 OP" Account: Four Alleged Statutory Violations in One Configuration

Security deposit refund checks (#1027, #1028) were issued from the "SAC 181 OP" account (Synovus Bank) with what Plaintiffs characterize as three damning characteristics:

1. Signed by Tara Bayles — Meridian CEO and PMIC #83633, not a SAC 181 representative
2. Bearing Meridian's office address — 8310 Rivers Ave Suite B, North Charleston, not SAC 181's address
3. Designated "OP" (Operating Account) — violating S.C. Code § 40-57-136(A)(1) requirement for "trust" or "escrow" designation

Plaintiffs allege this configuration violates four separate statutory requirements:

• § 40-57-136(A)(1): Account must include "trust" or "escrow" in title. "SAC 181 OP" satisfies neither.
• § 40-57-136(A)(5): Checks must reflect account designation. No trust/escrow designation shown.
• § 40-57-136(B)(3): PMICs "may not commingle trust funds with operating money." Operating accounts by definition commingle.
• § 40-57-136(B)(1): PMIC must maintain "accurate and complete records." No evidence of segregated accounting exists.

Under § 40-57-136(B)(5), a PMIC who violates trust account requirements "is considered to have demonstrated incompetence to act as a broker-in-charge or property manager-in-charge."

This evidence triggers licensing discipline by the LLR and veil-piercing liability in civil litigation.

What Defendants' Coordination Reveals

When four separate law firms file simultaneous obstruction motions timed to a regulatory deadline, despite representing clients with divergent interests (Meridian with indemnity crossclaim against SAC 181, yet blocking evidence needed for that crossclaim), the pattern proves:

1. Unified control of litigation strategy — Despite separate representation, all firms coordinated timing around February 20 LLR deadline
2. Consciousness of guilt — Clustering of motions and witness tampering reveals Defendants recognize evidence is material and damaging
3. Regulatory exposure — The coordination targets prevention of evidence reaching the LLR investigator, proving Defendants fear licensing discipline
4. Systemic pattern — This is not isolated misconduct but coordinated scheme involving four firms and multiple defendants

The Regulatory Significance: February 20, 2026

The PMIC Investigation of Tara Bayles (File #2025-566, initiated September 23, 2025) has a statutory 150-day deadline: February 20, 2026.

Labor Licensing & Regulation Investigators will receive:

1. Subpoena to LLR (filed January 14, 2026) seeking Meridian's complaint file and investigation history
2. This Opposition Brief (filed January 14, 2026) documenting the coordinated obstruction designed to prevent evidence from reaching the investigator
3. RocketsRight.org platform as searchable evidence repository enabling rapid access to supporting documentation

The LLR investigator will now understand:

• Why Defendants coordinated quash motions within 42 days of the deadline
• Why Meridian directly contacted AppFolio to block compliance
• Why Bolyard delayed witness deposition to February 24 (4 days past deadline)
• Why minimizing an 8-count case that includes fraud, retaliation, privacy violations, and veil-piercing as a 'deposit dispute' serves obstruction

The Civil Litigation Significance

The Opposition establishes three dispositive defects:

1. Counsel Bolyard's mandatory disqualification — Unconsentable conflicts under SC RPC 1.7(b)(3)
2. Phelps Dunbar's waived motion — Filed one day late; no reconsideration without permission
3. Meridian's witness tampering — Direct violation of § 16-9-340, warranting criminal referral

The Court can now:

• Strike Bolyard's quash motion as tainted by conflicted representation
• Deny Phelps Dunbar's motion as untimely waived
• Order re-service of clerk-issued subpoenas (curing procedural defects)
• Refer Meridian to Charleston County Solicitor and FBI for criminal investigation
• Refer Tara Bayles to LLR for licensing violation under § 40-57-340(3)

Media Inquiries

For press inquiries or housing justice coordination:
Chris McNeil, Pro Se Plaintiff
Email: Click here to email with web form
Case: 2025-CP-10-05095, Charleston County Court of Common Pleas

Document Access

Opposition to Motion to Quash Subpoenas and Cross-Motion to Disqualify Counsel for Unconsentable Conflicts of Interest and for Sanctions

Related Resources