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Discovery Is Not a Word Game: Motion to Determine Sufficiency of Defendants’ RFA Response

When “vague and ambiguous” becomes a strategy, Requests for Admission stop narrowing issues and start hiding them. Motion seeks court intervention after defendants deployed coordinated "vague and ambiguous" boilerplate to avoid clean admissions.

Document Overview

Charleston County Court of Common Pleas Case number: 2025-CP-10-05095
Filing Date: December 23, 2025
Document filed: Plaintiffs’ Motion to Determine Sufficiency of Answers/Objections to Requests for Admission; Deemed Admissions; Compel Clean Responses (and related relief)
Core Theme:-Plaintiffs contend defendants’ “transparent hypertechnical evasion warrants this Court’s intervention.

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Executive Summary

Requests for Admission exist to narrow issues and establish uncontested facts efficiently, but Plaintiffs contend Defendants responded with coordinated boilerplate objections designed to prevent clean admissions.

Plaintiffs argue that despite being represented by two separate law firms, the responding defendants used “virtually identical boilerplate objections,” reflecting “coordinated evasion” rather than good-faith compliance with Rule 36.

Plaintiffs ask the Court to strike insufficient objections, order amended “clean Admit or Deny” responses within 10 days, deem certain matters admitted if evasion continues, and award reasonable expenses under Rule 37.

Key Evidence (RFA table)

Defendant	RFA No.	What was requested (short)	Response pattern (short)	Plaintiffs’ commentary from filing (short)
SAC 181	1	Admit 181 Gordon is sole real property asset (material times)	“Vague/ambiguous” then denies but “admits” in 2025 only property is 181 Gordon	Plaintiffs argue the phrase “sole real property asset” is ordinary English and SAC 181 proved it understood by immediately giving the exact information sought; objection is “pretextual” and hedge-building.
SAC 181	2	Admit SAC authorized Meridian to act as agent for leasing/management/tenant relations	Objects “compound,” “vague” then denies but admits management agreement exists	Plaintiffs argue every management agreement creates agency; SAC’s hedge is “evasion wrapped in legal sophistry” to avoid admitting the relationship it created.
SAC 181	3	Admit did not review or object to public advertising materials displaying Plaintiffs/property	Objects “disjunctive,” “vague” (“public advertising materials,” “rental listing websites”)	Plaintiffs argue the request is about common rental platforms and SAC either reviewed the listings or didn’t; if SAC claims it didn’t, it should say so cleanly under oath (or the matter should be deemed admitted).
SAC 181	6	Admit showings occurred while Plaintiffs still occupied in July 2025	Objects to meaning of “showings” and “occupied,” then denies but admits tour on July 15 and Plaintiffs were tenants in July	Plaintiffs treat this as classic “deny, but admit” hedging; the requested admission can be made cleanly based on SAC’s own partial admissions.
Meridian	1	Admit Meridian had operational responsibility over 181 Gordon during 2025	“Vague,” “legal conclusion,” “year not over,” directs to management agreement, denies	Plaintiffs argue “operational responsibility” means day-to-day control (leasing/maintenance/tenant relations) and directing Plaintiffs to the management agreement while refusing to answer “proves” deliberate evasion.
Meridian	3	Admit Meridian/agents involved in causing or permitting images to be published without consent	Objects “vague” and “legal conclusion,” then denies	Plaintiffs argue publishing images is a factual act (uploading/activating syndication) distinct from whether it violated rights; objection improperly conflates conduct with liability.
Meridian	5	Admit filename MeridianScanner20250905161321.pdf encodes timestamp (scan time/date)	Objects to “encoded” as vague	Plaintiffs call this “absurd,” noting YYYYMMDDHHMMSS is a standard timestamp format and “encoded” means embedded/contained; objection is “performative ignorance.”
Meridian	6	Admit Meridian lacked written, signed consent for publication when listing/Matterport published	Objects “legal conclusion,” denies	Plaintiffs argue possession of a signed consent document is a binary factual question: either it exists in Meridian’s files or it doesn’t; legal effect is separate.
Meridian	8	Admit used AppFolio/ShowMojo or similar to “syndicate” listing to third-party sites	Objects “syndicate” as vague; admits only uses “third-party websites”	Plaintiffs argue “syndicate” is standard property-management usage and Meridian is avoiding naming platforms/software that would reveal distribution scope and records.
Tara Bayles	1	Admit possessed or had access to photos of Plaintiff/belongings during/after tenancy	Objects “possessed/had access” as vague; denies	Plaintiffs argue timeframe is explicitly stated and Tara sent the photos and created the scan file, so the “vague” objection is pretextual.
Tara Bayles	2	Admit sent/caused to be sent the email with attached PDF bearing “disputed postmark”	Objects; asserts “never a postmark”; describes “E‑MAILED 8/28/2025” stamp; then denies	Plaintiffs argue this is “a confession masquerading as an objection” because it admits key mechanics (stamp added, internal documentation) while still denying the send/causation question.
Tara Bayles	5	Admit deposit refund checks drawn on “SAC 181 OP” account and bore Meridian office address	Admit	Plaintiffs highlight this as the clean admission—and also highly significant—because it supports commingling/enterprise themes and shows other “vague” objections are selective and pretextual.
Tara Bayles	6	Admit communications with Adam re June/July 2025 listing/images	Invokes marital privilege; denies	Plaintiffs argue marital privilege does not shield business communications made in corporate capacity (CEO/PMIC + co-owner) and the objection is baseless.
Adam Bayles	1	Admit decision-making authority as principal/managing member for Meridian in 2025	Objects “decision-making authority” vague; admits authority to make “some decisions”	Plaintiffs argue this is semantic hairsplitting; admitting authority to make decisions is effectively admitting decision-making authority.
Adam Bayles	2	Admit did not object to publication of images	Denies; claims unaware; claims unable to admit/deny	Plaintiffs argue the response is internally contradictory (deny + unaware + unable) and reflects evasion rather than confusion.
Adam Bayles	4	Admit personally benefited from management/rental proceeds of 181 Gordon	Objects “personally benefited” vague; admits benefit from owning Meridian but claims can’t identify portion tied to 181 Gordon	Plaintiffs argue Meridian’s accounting records should permit identifying management fee streams by property, so the “no way to identify” position is implausible.
Adam Bayles	5–6	Admit communications/directives re listing/images; admit no takedown directive before 9/21/2025	Invokes marital privilege; denies	Plaintiffs argue these are business/operational issues and the marital privilege assertion mirrors Tara’s objection pattern.

Media Inquiries

For questions about this motion and the discovery record it addresses, contact
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

Motion to Determine Sufficiency of RFA Responses

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Systems View

Iceberg systems thinking model This filing is not merely about one disputed sentence or one objection; it’s about whether discovery functions as truth-seeking or devolves into “blindman’s bluff,” requiring court intervention to restore the process.

Plaintiffs contend the repeating pattern—ordinary terms labeled “vague,” factual questions labeled “legal conclusions,” and two firms deploying near-identical boilerplate—signals an improper purpose: delay, cost imposition, and avoidance of clean admissions. The intervention requested is a classic systems leverage move: force clean yes/no answers (or deemed admissions) so the case can converge on real disputed issues rather than semantic fog.

The key point, systemically, is that compelling “clean admit/deny” responses is a real intervention—but it is not the highest leverage move. It is closer to a rule-enforcement / structural correction that treats symptoms; the highest leverage is at the mental model level: what the court and counsel assume about:

truth,
status, and
pro se competence.

Iceberg Level	Current State in This Case	Target State (Truth-Seeking Model)
Events	Motion required because RFAs were met with recurring boilerplate objections, partial admissions embedded in denials, and “cannot admit/deny” posture on facts within Defendants’ control.	RFAs operate as designed: clean admissions narrow issues, clean denials clarify disputes, and “reasonable inquiry” explanations are specific and accountable.
Patterns	Repeating pattern: ordinary terms labeled “vague,” factual acts reframed as “legal conclusions,” and mirrored language across multiple parties—suggesting a coordinated evasion template rather than individualized, good-faith answering.	Pattern of disclosure integrity: answers track ordinary meaning; objections are rare, specific, and actually supported; parties either admit/deny or identify exactly what record/inquiry would resolve uncertainty.
Structure	Incentives reward “fog”: cost imposition, delay, and asymmetric burden-shifting—especially against pro se litigants, where opponents may expect skepticism toward competence and higher tolerance for gamesmanship.	Structures reward clarity: court expectations and case-management norms treat evasiveness as noncompliance; discovery is evaluated by functional truth-seeking output (clarity, verification, narrowing issues), not by credential-driven performance theater.
Mental Models	*ABP (Status/Gatekeeper model): If a perceived “higher-status” party conflicts with a lower-status party, then credibility follows rank, meaning truth is licensed, not verified. ABP* (Pro se suspicion model): If a pro se litigant produces sophisticated work, then it must be “improper,” meaning competence is treated as evidence of cheating. ABP* (Discovery-as-combat model):** If discovery can be turned into semantic fog, then that is “effective defense,” meaning truth-seeking is secondary to attrition.	*TLP (Merit-based integrity model): If status is treated as noise and argument strength as signal, then the stronger position wins, meaning court integrity and fairness prevail over hierarchy. TLP* (Pro se respect model): If a pro se litigant produces sophisticated work, then they may be autodidactic and innovating, meaning competence deserves engagement—not suspicion. TLP* (Discovery-as-convergence model):** If discovery is designed to converge the case on real disputes, then gamesmanship is treated as system waste, meaning clarity is the win.

Iceberg Level

Current State in This Case

Target State (Truth-Seeking Model)

Events

Motion required because RFAs were met with recurring boilerplate objections, partial admissions embedded in denials, and “cannot admit/deny” posture on facts within Defendants’ control.

RFAs operate as designed: clean admissions narrow issues, clean denials clarify disputes, and “reasonable inquiry” explanations are specific and accountable.

Patterns

Repeating pattern: ordinary terms labeled “vague,” factual acts reframed as “legal conclusions,” and mirrored language across multiple parties—suggesting a coordinated evasion template rather than individualized, good-faith answering.

Pattern of disclosure integrity: answers track ordinary meaning; objections are rare, specific, and actually supported; parties either admit/deny or identify exactly what record/inquiry would resolve uncertainty.

Structure

Incentives reward “fog”: cost imposition, delay, and asymmetric burden-shifting—especially against pro se litigants, where opponents may expect skepticism toward competence and higher tolerance for gamesmanship.

Structures reward clarity: court expectations and case-management norms treat evasiveness as noncompliance; discovery is evaluated by functional truth-seeking output (clarity, verification, narrowing issues), not by credential-driven performance theater.

Mental Models

ABP* (Status/Gatekeeper model): If a perceived “higher-status” party conflicts with a lower-status party, then credibility follows rank, meaning truth is licensed, not verified.
ABP* (Pro se suspicion model): If a pro se litigant produces sophisticated work, then it must be “improper,” meaning competence is treated as evidence of cheating.
ABP* (Discovery-as-combat model): If discovery can be turned into semantic fog, then that is “effective defense,” meaning truth-seeking is secondary to attrition.

TLP* (Merit-based integrity model): If status is treated as noise and argument strength as signal, then the stronger position wins, meaning court integrity and fairness prevail over hierarchy.
TLP* (Pro se respect model): If a pro se litigant produces sophisticated work, then they may be autodidactic and innovating, meaning competence deserves engagement—not suspicion.
TLP* (Discovery-as-convergence model): If discovery is designed to converge the case on real disputes, then gamesmanship is treated as system waste, meaning clarity is the win.

* ABP = Audience Baseline Position, TLP = Thought Leadership Position

Leverage ladder

Ordered clean admit/deny answers (and deemed admissions where warranted) are best framed as a mid-level leverage intervention: it reduces fog and forces convergence. Higher leverage is achieved when the Court explicitly signals the mental-model standard: credibility is grounded in verification, pro se status is not a proxy for incompetence, and discovery tactics are evaluated by whether they help the Court reach accurate resolution efficiently

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