Plyler Complaint

ELECTRONICALLY FILED - 2022 Aug 24 4:13 PM - HAMPTON - COMMON PLEAS - CASE#2022CP2500241
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

) THE FOURTEENTH JUDICIAL CIRCUIT
COUNTY OF HAMPTON ) CIVIL ACTION NO.:2022-CP-25-______
Hannah Plyler and Alania Spohn, )

)
Plaintiffs, ) SUMMONS
)
vs. )
)
Russell Lucius Laffitte and )
Palmetto State Bank, )
)
Defendants. )
)
TO THE DEFENDANTS ABOVE-NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which
is herewith served upon you, and to serve a copy of your answer to this Complaint upon the subscriber, at
the address shown below, within thirty (30) days after service hereof, exclusive of the day of such service,
and if you fail to answer the Complaint, judgment by default will be rendered against you for the relief
demanded in the complaint.
Charleston, South Carolina

August 24, 2022
BLAND RICHTER, LLP
Attorneys for Plaintiffs
s/Eric S. Bland
Eric S. Bland (SC Bar No. 64132)
1500 Calhoun Street
Post Office Box 72
Columbia, South Carolina 29202
t: 803.256.9664 | f: 803.256.3056
ericbland@blandrichter.com
s/Ronald L. Richter, Jr.

Ronald L. Richter, Jr. (SC Bar No. 66377)
s/Scott M. Mongillo
Scott M. Mongillo (SC Bar No. 16574)
18 Broad Street, Mezzanine
Charleston, South Carolina 29401
t: 843.573.9900 | f: 843.573.0200
ronnie@blandrichter.com
scott@blandrichter.com
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) THE FOURTEENTH JUDICIAL CIRCUIT
COUNTY OF HAMPTON ) CIVIL ACTION NO.:2022-CP-25-______
Hannah Plyler and Alania Spohn, )

)
Plaintiffs, ) COMPLAINT
) (Jury Trial Demanded!)
vs. )
)
Russell Lucius Laffitte and )
Palmetto State Bank, )
)
Defendants. )
)
The Plaintiffs, complaining of the conduct of the Defendants herein, alleges as follows:
INTRODUCTION
A crash. Two deaths. Two children. On July 16, 2005, Alania Plyler (12 years old) and
Hannah Plyler (8 years old) were in the backseat of their family’s Ford Explorer when it left I-95
in Hampton County, South Carolina, and struck a stand of pine trees. Alania and Hannah witnessed
the deaths of their mother, Angela, and their brother, Justin. Two men would come into their lives
purportedly to help them: a lawyer, Alec Murdaugh, and a banker, Russell Laffitte (“Laffite”).
While millions of dollars were recovered for the girls and while huge fees were paid to the lawyer
and the banker, opportunity abounded when the money hit the table. Although Laffitte was duty
bound as a fiduciary for the girls to protect them and to protect their property, they were just
children who did not (and could not) understand the complex finances following the deaths of their
mother and brother. And besides, who would notice if a little money was “borrowed” here and
there as long as it was put back in the right place before the girls celebrated their 18th birthdays
and assumed control of their own finances.
So, Laffitte helped himself to hundreds of thousands of dollars of “loans” from the girls
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and graced himself with sweetheart interest rates as low as 1.5%. He extended the same courtesies
to his good buddy, Alec Murdaugh, who needed a helping hand to deal with a financial and legal
morass he had created for himself. While Laffitte properly petitioned the Court for permission to
spend $150.00 of the girl’s money for school clothing, Christmas gifts and the like, he never asked
the Court for permission to make over a dozen loans to himself or to his good friend, loans ranging
from $10,000.00 to $225,000.00 at a time. In the final act and as the girls approached their 18th
birthdays, Laffitte found himself a little short on his sweetheart loans – approximately $260,000.00
short. To “cure” the problem, Laffitte simply took money from other accounts which he had been
entrusted to protect on behalf of other clients sent to him by his good friend Murdaugh. So, all’s
well that ends well, right? Not exactly. Fiduciaries who self-deal and use the people they are
charged to protect as financial opportunities are not allowed to profit by their conduct. Alania and
Hannah Plyler were not just Laffitte’s next dollar. Laffitte and his bank that aided and abetted his
conduct now need to answer to the Plylers to account for every dollar of benefit they enjoyed at
the Plylers’ expense.
PARTIES AND JURISDICTION
1. Plaintiff Hannah Plyler (“Hannah”) is, and was at all times relevant herein, a
citizen and resident of Richland County, South Carolina.
2. Plaintiff Alania Spohn (“Alania”) is, and was at all times relevant herein, a citizen
and resident of Richland County, South Carolina and is Hannah’ sister.
3. Defendant Russell Laffitte (“Laffitte”) is, and was at all times relevant herein, a
citizen and resident of Hampton County, South Carolina.
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4. Defendant Palmetto State Bank (“PSB”) is a corporation organized and existing
under the laws of the State of South Carolina with its principal place of business located in
Hampton County.
FACTUAL BACKGROUND
5. During the late afternoon hours of July 16, 2005, Alania Plyler (then 12 years old)
had an argument with her brother, Justin (who was 14 years old).
6. They fought over who would have the right to ride shotgun from Hardeeville to
Columbia, South Carolina.
7. As she had on many prior occasions, the children’s mother, Angela Plyler, laid
down the law.
8. Justin was the oldest, and Justin had the right.
9. So, with the disagreement settled, Alania and her sister Hannah (then 8 years) old,
took their rightful places in the backseat of the family’s 1999 Ford Explorer for an evening drive
to Columbia.
10. Angela had recently separated from her husband and the children’s father, Richard
“Rickie” Plyler, and the trip was necessary to return a television that belonged to the kids’ father.
Also, while in Columbia, Angela was going to make a little extra money for her family selling and
delivering The State newspapers, a job which she had worked prior to her relocation to Hardeeville.
11. As the family traveled the section of I-95 that traversed Hampton County, Justin
and Hannah had fallen asleep and Alania was contently listening to an Usher CD on her
headphones when she was interrupted by her mother in the front seat.
12. “Alania, are you asleep?”
13. Alania took off her headphones and had the last conversation she would ever have
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with her best friend.
14. As Alania spoke to her mother, she heard a loud POP, followed by a scream.
15. She noticed her mother’s hands shaking on the steering wheel as Angela tried to
maintain control.
16. The car left the roadway.
17. The car struck a stand of pine trees.
18. Alania vividly recalls the smell of pine and smoke.
19. She was pinned in the backseat behind her brother Justin, whose seat had collapsed
into Alania’s lap.
20. Justin was not moving. The site of his obvious head wound was disorienting.
21. Alania saw her mother in the front seat. Red blood tinted her beautiful blond hair.
She too was motionless.
22. Hannah, who was only 8 years old, was forced to mature instantly.
23. Alania was pinned. Hannah was able to exit the destroyed vehicle. She climbed
the embankment to the roadside, and at 8 years old, Hannah Plyler flagged down a passing truck
driver for help.
24. In full sight of the girls, first responders eventually made it to the scene and began
a frenzied effort to extract Angela and Justin from the vehicle.
25. In full sight of Alania, Angela and Justin were placed into body bags.
26. Setting aside their appreciable physical injuries, Hannah and Alania Plyler suffered
wounds that day which will follow them for the rest of their lives.
27. It was later discovered that the Ford Explorer had been equipped with Firestone
tires, the same deadly Ford/Firestone combination that had resulted in many other tire-failure,
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rollover accidents.
28. When the Firestone tire failed, the Ford Explorer was uncontrollable and left the
roadway leading to the deaths of Angela and Justin Plyler.
29. In 2005, in Hampton County, South Carolina, there was but one place to go for
justice arising out of an accident of this nature – Peters, Murdaugh, Parker, Eltzroth and Detrick
(“PMPED”).
30. For nearly 100 years, the Murdaugh family reigned over a legal dynasty in Hampton
County.
31. For nearly 100 years, railroads, trucking companies, manufacturers and other
institutions had been hauled into Hampton County to face civil suits brought by the Murdaughs
and to be handed massive jury trial verdicts.
32. Under the reign of the Murdaugh dynasty, Hampton County had earned the
reputation as the third worst “judicial hellhole” in America by 2004, according to a report
published by the watchdog group the American Tort Reform Foundation.
33. In 2005, the latest generation of Murdaughs was represented by Richard Alexander
“Alec” Murdaugh.
34. After graduating from law school in 1994, Alec Murdaugh took his rightful seat at
the PMPED table and began to practice law with the firm.
35. Like his father (Randolph Murdaugh, III), grandfather (Randolph “Buster”
Murdaugh, Jr.) and great-grandfather (Randolph Murdaugh, Sr.), Alec Murdaugh also ascended to
occupy a seat at the 14th Judicial Circuit’s Solicitor’s Office which the Murdaugh family had
controlled since 1910.
36. By 2005, when the Plyler girls were brought to PMPED and to Alec Murdaugh for
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legal representation, Alec had garnered his own reputation as the latest Murdaugh lawyer who
would carry the name of the firm forward and who had the ability to wield the Murdaugh influence
in Hampton County.
37. In total, PMPED undertook to represent the Plyler family in four separate lawsuits
against Ford Motor Company, Bridgestone Corporation and others, one for each of the victims
involved in the accident:
a. A wrongful death suit for Angela Plyler, which became known as Action
No. 05-CP-25-456;
b. A wrongful death suit for Justin Plyler, which became known as Action No.
05-CP-25-531;
c. A personal injury action on behalf of Alania Plyler, which became known
as Action No. 05-CP-25-532; and
d. A personal injury action on behalf of Hannah Plyler, which became known
as Action No. 05-CP-25-533.
38. In order to bring the aforementioned actions, however, the wrongful death suits
could only be brought in the name of the Personal Representative of the Estate of the deceased and
the actions for Alania and Hannah needed to be brought by a parent or someone else serving as a
Guardian ad Litem or Conservator on their behalf.
39. Because Angela and Justin died intestate, their nearest next of kin was entitled to
serve in the role of Personal Representative in accordance with South Carolina statutory law.
40. Likewise, because Alania and Hannah were minors, their surviving parent (Rickie)
had the statutory right to pursue lawsuits on their behalf.
41. Upon information and belief, however, Alec Murdaugh suggested to the family that
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it would be preferable to appoint someone independent to serve as the Personal Representative of
the Estates of Angela and Justin, and that it would be preferable to have someone appointed as
Conservator for Alania and Hannah and to prosecute their actions for their benefit.
42. The “someone” Alec had in mind was Russell Laffitte, who was then the Vice
President of Palmetto State Bank (“PSB”).
43. The selection of Laffitte and PSB was a continuation of a symbiotic relationship
that existed between PMPED and PSB. In this symbiotic relationship, PMPED sent its clients to
PSB for high interest rate paying “litigation loans” through which PMPED clients would either
receive an advance against their future case recovery and/or money to help pay expenses during
litigation and PSB would charge the clients interest rates ranging from 18% to 25%. In addition,
through the settlements PMPED achieved, it created large depository accounts for PSB which
reflected well on the balance sheets of the bank. Finally, PMPED created fee opportunities for the
leadership of PSB by hand picking PSB officers to play the role of Personal Representative or
Conservator for cases and to earn handsome fees in the process.
44. In exchange for the many benefits bestowed upon PSB by PMPED, the bank
likewise reciprocated by extending loans, lines of credit and other courtesies to PMPED and/or its
partners, even going so far as to extend a credit line to Alec Murdaugh himself after his legal woes
following the death of Mallory Beach left him significantly overdrawn on his personal PSB
accounts.
45. Like PMPED, PSB was a generational, familial institution in Hampton County.
PSB prospered under the ownership and control of the Lafitte family. Just as Alec Murdaugh had
ascended to his seat at the PMPED table, on a parallel track, Russell Laffitte was coming into his
power at the PSB table. The two rising lions of their families came together for the prosecution of
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the Plyler cases.
46. In order to have Laffitte appointed as the Personal Representative of the Estates of
Angela and Justin, application needed to be made to the probate court of the county of their
residence at the time of their deaths, which was Richland County. In addition, Murdaugh and
Laffitte would have to secure a renunciation from Rickie Plyler of his right to serve in the capacity
as Personal Representative in favor of Laffitte.
47. Also, in order to be appointed Personal Representative of the Estates of Angela and
Justin Plyler, Russell Laffitte sought and received the express permission of PSB.
48. Petitions for the Appointment of Russell Laffitte in the Estate of Angela Plyler and
in the Estate of Justin Plyler were filed in the Hampton County Probate Court.
49. Russell Laffitte was appointed Personal Representative of the Estates of Angela
and Justin Plyler by Order of the Hampton County Probate Court.
50. What was in it for Laffitte and PSB? In addition to the continuation of the symbiotic
relationship with PMPED, Laffitte stood to earn Personal Representative fees of up to five (5%)
of the monies recovered in each case. PSB stood to become the potential recipient of huge sums
by way of depository accounts upon the settlement of the cases.
51. As for the girls, an additional “obstacle” stood in the way of having Russell Laffitte
appointed as their Conservator for purposes of prosecuting their cases, earning additional fees and
creating yet more depository account opportunities for PSB: Conservatorships are established in
the county of residence of the ward.
52. At the time their mother died, Alania and Hannah remained residents of Richland
County. After Mom died, they first resided with their father for a time, and were later passed
around from family member to family member, but primarily in Lexington County.
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53. Russell Laffitte and PSB were located in Hampton County.
54. This obstacle notwithstanding, Murdaugh prepared Petitions to establish the
Conservatorships of Alania and Hannah Plyler in Hampton County and to do so under the Russell
Laffitte.
55. To overcome the jurisdictional and venue obstacle, the Petition for Appointment of
Alania Plyler and for Hannah Plyler simply misrepresented to the Court that venue was proper
because the girls lived in Hampton County. To be clear, the girls NEVER lived in Hampton
County.
(See two Petitions for Appointment of Conservators and both are attached as Exhibit A and
incorporated by reference.)
56. In advancing Laffitte as the right man for the job, the qualifying credential offered
to the Court was that Russell Laffitte was “Vice President of Palmetto State Bank.” (See Exhibit
A.)
57. On November 16, 2006, Fiduciary Letters issued from the Hampton County
Probate Court for both Alania Plyler and Hannah Plyler appointing Russell Laffitte as their
Conservator. (See two Fiduciary Letters and both are attached as Exhibit B and incorporated by
reference.)
58. The Fiduciary Letters were conditioned by one important restriction: “NO
DISBURSEMENTS TO BE MADE WITHOUT PRIOR APPROVAL OF THE HAMPTON
COUNTY PROBATE COURT.” (See Exhibit B.)
59. With their hand-picked Conservator and Personal Representative, Russell Laffitte
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having been “duly” appointed, Murdaugh and PMPED obtained significant settlements on all four
cases.
60. Of course, in order to finalize the settlements, it was necessary to for Murdaugh to
file Petitions to Approve Settlements in the various actions and to appear in Court seeking orders
permitting the settlements to go forward.
61. So in each of the four separate lawsuits, Petitions to Approve Settlement were
submitted to the Court and hearings were scheduled.
62. At the hearings, Laffitte was required to appear and to attest that he was aware of
the various settlements, that he was aware of the costs and fees involved, that he was pleased with
the services of the lawyers and that he thought the settlements were in the best interests of the
parties involved. (See Laffite’s handwritten hearing notes attached as Exhibit C and incorporated
by refence.)
63. With regard to the wrongful death settlements for Angela and Justin, after the
settlements were approved, the remaining net funds were distributed to the heirs of the two Estates
in accordance with South Carolina law for intestate succession. As such, there was no need for
any continued management of the settlement proceeds.
64. As a fee for his services in the Angela Plyler Estate, Laffitte was paid the sum of
Fifty Thousand ($50,000.00) Dollars.
65. As a fee for his services in the Justin Plyler Estate, Laffitte was paid the sum of
Twenty Five Thousand ($25,000.00) Dollars.
66. Alania’s and Hannah’s situations were different.
67. Alania and Hannah were still minors at the time of their settlements, so decisions
would have to be made regarding the oversight and management of their money.
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68. From the Estate of their deceased mother, each of the girls was to receive the sum
of Eighty Six Thousand One Hundred Thirty and 96/100 ($86,130.96) Dollars.
69. From their own cases, however, each of the girls was slated to receive settlements
net of attorneys’ fees and costs in the millions of dollars.
70. As Conservator, Laffitte was charged with the fiduciary obligation to protect the
girls, to protect their money and to act single-mindedly for what was in their best interests. The
question confronting Laffitte was simple – what was he to do with all of that money?
71. From Alania’s money, Laffitte decided that the most prudent thing to do was to buy
an annuity that would pay Alania a monthly sum for the rest of her life that would more than
exceed any foreseeable need she may have had. Or at least, that is what he would do with “most”
of the money.
72. Laffitte prepared notes and calculations in which he projected that Alania’s needs
would be less than $2,000.00 per month as a minor, and that her annuity would pay her over
$10,000.00 per month (tax free) for the rest of her life. According to Laffitte’s calculations, from
the annuity payments alone, Alania would accumulate over Three Hundred Sixty-One Thousand
($361,000.00) Dollars net of her monthly needs by the time she turned 18 years of age. In addition,
Alania would have the Eighty Six Thousand One Hundred Thirty and 96/100 ($86,130.96) Dollars
from her mother’s estate. (See Laffite’s handwritten notes attached as Exhibit D and incorporated
by reference.)
73. From Hannah’s money, Laffitte likewise decided that the most prudent thing to
do was to buy and annuity that would pay Hannah a monthly sum for the rest of her life that would
more than exceed any foreseeable need she may have had. Or again, that is what he would do with
“most” of the money.
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74. Laffitte prepared notes and calculations in which he projected that Hannah’s needs
would be less than $2,000.00 per month as a minor, and that her annuity would pay her over
$7,040.00 per month (tax free) for the rest of her life. According to Laffitte’s calculations, from
the annuity payments alone, Hannah would accumulate over Three Hundred Forty-Six Thousand
($346,000.00) Dollars net of her monthly needs by the time she turned 18 years of age. In addition,
Hannah would have the Eighty Six Thousand One Hundred Thirty and 96/100 ($86,130.96)
Dollars from her mother’s estate. (See Laffite’s handwritten notes attached as Exhibit E and
incorporated by reference.)
75. Despite the fact that the annuities purchased for the girls would more than address
any possible future need, including college by the time they were old enough to attend, Laffitte
opted to hold back over $800,000.00 between the two girls and to deposit those funds into PSB
accounts which he was “manage.” This money was supplemented by the $86,130.96 that each of
the girls received from the death of their mother.
76. Like the wrongful death suits, settlement hearings were scheduled and Laffitte
appeared in Court to explain that he was aware of the settlements, that he was aware of the costs
and fees incurred, that he was pleased with the lawyers and that he thought the settlements were
in the best interests of the girls. (See two Disbursement Sheets attached as Exhibit F and
incorporated by refence.)
77. The settlements were approved. (See two Orders Approving Minor Settlement
signed by Judge Carmen T. Mullen, both are attached as Exhibit G and incorporated by reference.)
78. The annuities were purchased.
79. Accounts in each of the girls’ names were established at PSB and at other
institutions for the surplus money not used to buy the annuities.
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80. From Alania’s settlement, Laffitte was paid a Conservator Fee in 2009 of One
Hundred Forty Thousand Four Hundred Forty-One and 04/100 ($140,441.04) Dollars. (See
document entitled “Alania Plyler 2009 Accounting” attached as Exhibit H and incorporated by
refence.)
81. From Hannah’s settlement, Laffitte was paid a Conservator Fee in 2009 of Ninety-
One Thousand Four Hundred Fifty-Five and 91/100 ($91,455.91) Dollars. (See document entitled
“Hannah Plyler Checking” attached as Exhibit I and incorporated by refence.)
82. Of course, more money was available to be made as Laffitte would continue to
earn Conservator Fees for the following years for each of the girls until they reached their age of
majority. Likewise, PSB would also continue to benefit from its relationship with PMPED and its
partners.
83. Having money to “manage,” Laffitte was subject to certain rules and standards
governing conservatorships in South Carolina, including but not limited to the restriction in the
Fiduciary Letters that Laffitte could make “NO DISBURSEMENTS … WITHOUT PRIOR
APPROVAL OF THE HAMPTON COUNTY PROBATE COURT.” (See Exhibit B.)
84. In addition, PSB was at all times aware of Laffitte’s Conservatorships. First, PSB
expressly authorized Laffitte to accept the role of conservator for the Plyler girls. Furthermore,
Laffitte established conservatorship accounts at PSB. In fact, when Alania’s conservatorship
account was created, internal PSB documents reveal that PSB was aware of the account and of the
fact that Laffitte himself had to approve all withdrawals from the account:
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(See PSB record attached as Exhibit J and incorporated by refence.)
85. Following the terrible accident and the loss of their Mother, the Plyler girls found
themselves largely without anyone in their lives to play a parental role. Their relationship with
their father was difficult at best, and the girls spent the years after the accident being passed from
household to household within the broader family.
86. Whether Laffitte appreciated it at the time or not, the girls inevitably began to see
him as a father figure in their lives. He controlled their money. He made decisions on their behalf.
He was the one that the girls had to talk to in requesting money (their money) for allowances,
school supplies, clothing and Christmas gifts.
87. What the girls could not know, and did not know, is that although Laffitte
repeatedly sought court permission for expenditures on the girls’ behalf for nominal sums, he was
helping himself to hundreds of thousands of their dollars without court approval for his own
personal use and was granting hundreds of thousands of dollars in personal loans to his friend,
Alec Murdaugh, again without court approval.
88. For example, on May 7, 2008, Laffitte sought and received approval from the
Hampton County Probate Court for $100.00 for Hannah to participate in a school trip.
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(See Petition for Expenditures attached as Exhibit K and incorporated by refence.)
89. On July 21, 2008, Laffitte sought and received approval from the Hampton County
Probate Court for $250.00 for Hannah to purchase school clothes.
(See Petition for Expenditures attached as Exhibit L and incorporated by refence.)
90. On May 7, 2008, Laffitte sought and received approval from the Hampton County
Probate Court for $150.00 for Alania to purchase a dress for school.
(See Petition for Expenditures attached as Exhibit M and incorporated by refence.)
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91. On May 27, 2008, Laffitte sought and received approval from the Hampton
County Probate Court for $1,750.00 for Alania to purchase a 1992 Capri vehicle so she could
travel to and from school and work. Alania did not receive a 1992 Capri, but she was given a 2008
Nissan that Laffitte told her he had purchased at an auction.
(See Petition for Expenditures attached as Exhibit N and incorporated by refence.)
92. On July 21, 2008, Laffitte sought and received approval from the Hampton County
Probate Court for $250.00 for Alania to purchase clothing for school.
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(See Petition for Expenditures attached as Exhibit O and incorporated by refence.)
93. By April, 2009, the process of going back and forth to the Hampton County
Probate Court for such expenditures became too burdensome for Laffitte. As a result, he sought
and obtained permission from the Hampton County Probate Court to make expenditures for
Alania’s benefit up to $2,000.00 per month and to make expenditures for Hannah’s benefit up to
$1,000.00 per month. (See two Orders Allowing Purchases attached as Exhibit P and incorporated
by refence.)
94. In January, 2011, Hannah wanted to go to Disney World with a friend’s family.
She had never been. Of course, Hannah had to ask Laffitte for permission and Laffitte for access
to her money in order to go.
95. Playing the role of the good parent, Laffitte told Hannah that she could go, but
that she had to track her receipts. He also warned her that if he didn’t get the receipts, then she
would not be permitted to do anything at Disney World but the basics.
(See Laffite’s handwritten notes dated 1/12/11 attached as Exhibit Q and incorporated by refence.)
96. Upon information and belief, it was also in 2011 that Laffitte began making loans
using the girls’ money both to himself and to his good friend, Alec Murdaugh.
97. As it relates to the loans to Alec Murdaugh, Laffitte made not less than eight (8)
such loans, and perhaps as many as fourteen (14) loans (the “Murdaugh Loans”).
98. Laffitte did not seek the permission of the Hampton County Probate Court for any
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of the Murdaugh Loans. (See table entitled “Alex Loans” attached as Exhibit R and incorporated
by refence.)
99. Laffitte did not receive the permission of the Hampton County Probate Court for
any of the Murdaugh Loans.
100. None of the Murdaugh Loans were secured by any collateral.
101. None of the Murdaugh Loans were reviewed by any loan committee.
102. Alec Murdaugh was not credit worthy for any of the Murdaugh Loans.
103. PSB was aware of each and every Murdaugh Loan as each and every Murdaugh
Loan involved the transfer of funds from a PSB conservatorship account.
104. Upon information and belief, one or more of the Murdaugh Loans also involved a
transfer from a PSB conservatorship account into an account in the name of Alec Murdaugh.
105. Upon information and belief, at the time of one or more of the Murdaugh Loans,
Alec Murdaugh was overdrawn one or more of his personal accounts at PSB.
106. On April 14, 2011, Russell Laffitte as Conservator for Hannah Plyler, loaned
Ninety Thousand ($90,000.00) Dollars to Alec Murdaugh from the PSB conservatorship account
for Hannah Plyler.
(See Check #1018 attached as Exhibit S and incorporated by reference.)
107. When loaning money to his good friend Alec Murdaugh using the Plyler money,
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Laffitte charged his good buddy the below market rate for an unsecured loan of five (5%) percent
on this particular loan. (See Promissory Note attached as Exhibit T and incorporated by reference.)
108. This stands in stark contrast to the rates that PSB charged the girls for “litigation
loans” during the time that their cases were being prosecuted:
a. On April 19, 2007, Russell Laffitte as Conservator for Hannah Plyler
borrowed $1,750.00 from PSB for use in the litigation and PSB charged
Hannah Plyler 21.371% interest; (See PSB loan documents attached as
Exhibit U and incorporated by reference.)
b. On April 19, 2007, Russell Laffitte as Conservator for Alania Plyler
Alania Plyler 21.371% interest; (See PSB loan document attached as
Exhibit V and incorporated by reference.)
c. On November 25, 2008, Russell Laffitte as Conservator for Alania Plyler
Alania Plyler 20.950% interest; and, (See PSB loan document attached as
Exhibit W and incorporated by reference.)
d. On February 19, 2009, Russell Laffitte as Conservator for Alania Plyler
borrowed $31,036.94 from PSB in order for Alania to purchase a car and
PSB charged Alania Plyler 18.190% interest (of course, there was more than
enough of Alania’s money available for her to purchase a car with her own
money – wasn’t there?). (See PSB loan documents attached as Exhibit X
and incorporated by reference.)
109. On December 21, 2011, Russell Laffitte as Conservator for Hannah Plyler, loaned
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Fifty Thousand ($50,000.00) Dollars to Alec Murdaugh from the PSB conservatorship account for
Hannah Plyler at the below market rate for unsecured loans of 4.5% interest. (See Promissory Note
attached as Exhibit Y and incorporated by reference.)
110. On September 11, 2012, Russell Laffitte as Conservator for Hannah Plyler, loaned
One Hundred Thousand ($100,000.00) Dollars to Alec Murdaugh from the PSB conservatorship
account for Hannah Plyler at the below market rate for unsecured loans of 3.0% interest. (See
Exhibit R at Loan 91112 (the date of the loan) and the Promissory Note attached as Exhibit Z
111. On October 23, 2012, Russell Laffitte as Conservator for Hannah Plyler, loaned
Hannah Plyler at the below market rate for unsecured loans of 3.0% interest. (See Exhibit R at
Loan 91112 at date 10/23/2012 and the Promissory Note attached as Exhibit AA and incorporated
by reference.)
112. On February 12, 2013, Russell Laffitte as Conservator for Hannah Plyler, loaned
One Hundred Fifty Thousand ($150,000.00) Dollars to Alec Murdaugh from the PSB
conservatorship account for Hannah Plyler at a below market interest rate. (See Exhibit R at Loan
21213 (the date of the loan) and Check #1048 attached as Exhibit BB and incorporated by
reference.)
113. On July 29, 2013, Russell Laffitte as Conservator for Hannah Plyler, loaned One
Hundred Thousand ($100,000.00) Dollars to Alec Murdaugh from the PSB conservatorship
account for Hannah Plyler at a below market interest rate. The loan was documented as having
been accomplished by was of a transfer between accounts – presumably accounts that existed at
PSB. (See Exhibit R Loan 72913 (the date of the loan) and the 2013 statement Bates stamped
20
Hannah000579 attached as Exhibit CC and incorporated by reference.)
114. On September 27, 2013, Russell Laffitte as Conservator for Hannah Plyler, loaned
Forty Thousand ($40,000.00) Dollars to Alec Murdaugh from the PSB conservatorship account
for Hannah Plyler at a below market interest rate. The loan was documented as having been
accomplished by way of a transfer between accounts – presumably accounts that existed at PSB.
(See Exhibit R at Loan 92713 (the date of the loan) and Exhibit CC at 9/27/2013 and 10/18/2013
entries.)
115. On October 23, 2013, Russell Laffitte as Conservator for Hannah Plyler, loaned
Forty Thousand ($70,000.00) Dollars to Alec Murdaugh from the PSB conservatorship account
for Hannah Plyler at a below market interest rate. (See Exhibit R at Loan 102313 (the date of the
loan) and Exhibit CC at 10/23/2013 and 10/28/2013 entries.)
116. The loan was documented as having been accomplished by way of a transfer
between accounts – presumably accounts that existed at PSB and this PSB statement illustrates
PSB knowledge of this scheme and aiding and abetting of the same. (See the PSB statement which
states “xfer to Alex for loan” attached as Exhibit DD and incorporated by refence.)
117. With regard to the $70,000.00 Murdaugh loan, Alec Murdaugh was overdrawn on
his PSB accounts and PSB had demanded that Murdaugh make a deposit in order to cure the
overdraw.
118. On October 22, 2013 at 8:40 a.m., Russell Laffitte emailed Murdaugh from his
PSB email address and told Murdaugh: “Need a deposit. Thought you were coming in yesterday.”
(See email attached as Exhibit EE and incorporated by refence.)
119. At 3:09 p.m. the same day, Murdaugh replied from his PMPED email address:
“Sorry I forgot. Can u make a loan from Hannah and I will pay it as we discussed.” (See Exhibit
21
EE.)
120. At 9:05 a.m. the following morning, Laffitte confirmed for his friend Murdaugh
that “I transferred the 70l this morning.” Problem solved. Without Court approval, Laffitte simply
took $70,000.00 from the Hannah Plyler account to cure Alec Murdaugh’s overdrawn account at
PSB. (See Exhibit EE.)
121. On November 5, 2013, Russell Laffitte as Conservator for Hannah Plyler, loaned
Hannah Plyler at a below market interest rate. The loan was documented as having been
accomplished by way of a transfer between accounts – presumably accounts that existed at PSB.
(See Exhibit R at Loan 110513 (the date of the loan).)
122. On December 6, 2013, Russell Laffitte as Conservator for Hannah Plyler, loaned
One Hundred Thousand ($100,000.00) Dollars to Alec Murdaugh from the PSB conservatorship
account for Hannah Plyler at a below market interest rate. (See Exhibit R at the last loan that is
cut off the page.)
123. On May 6, 2014, Russell Laffitte as Conservator for Hannah Plyler, loaned Fifty
Thousand ($50,000.00) Dollars to Alec Murdaugh from the PSB conservatorship account for
Hannah Plyler at a below market interest rate. (See Exhibit R at Loan 50614 (the date of the loan).)
124. As it relates to the loans that Laffitte made to himself, Laffitte made not less than
six (6) such loans, and perhaps as many as eight (8) loans (the “Laffitte Loans”). (See table entitled
“Russell Loans” attached as Exhibit FF and incorporated by refence.)
125. Laffitte did not seek the permission of the Hampton County Probate Court for any
of the Laffitte Loans.
126. Laffitte did not receive the permission of the Hampton County Probate Court for
22
any of the Laffitte Loans.
127. Several of the Laffitte Loans were secured by Laffitte’s 2,471 shares in PSB.
128. None of the Laffitte Loans were reviewed by any loan committee.
129. PSB was aware of each and every Laffitte Loan as each and every Laffitte Loan
involved the transfer of funds from a PSB conservatorship account.
130. On July 15, 2011, Russell Laffitte as Conservator for Hannah Plyler, loaned Two
Hundred Twenty Five Thousand ($225,000.00) Dollars to himself from the PSB conservatorship
account for Hannah Plyler. While a Promissory Note Laffitte prepared for his own signature
indicates that the interest rate for the loan was at the below market interest rate of 3.25%, a Laffitte
internal tracking document shows that he actually charged himself 1.5% interest. Upon
information and belief, the loan was accomplished by way of a transfer to an account in Russell
Laffitte’s name at PSB. (See Exhibit FF at Loan 71811 and the 7/15/11 Promissory Note attached
as Exhibit GG incorporated by reference.)
131. On January 4, 2012, following a partial pay down on the Laffitte Loan for Two
Hundred Twenty Five Thousand ($225,000.00) Dollars, Laffitte “renewed” the loan via a new
Promissory Note in the amount of One Hundred Seventy Five Thousand ($175,000.00) Dollars.
While the Promissory Note indicates a below market interest rate of 2.25%, a Laffitte internal
tracking document shows that he actually charged himself 1.5% interest. Upon information and
belief, the loan was accomplished through the use of accounts in Russell Laffitte’s name at PSB.
(See Exhibit FF at Loan 71811 at date 1/4/2012 and the Promissory Note attached as Exhibit HH
and information on Loan #071511 attached as Exhibit II and incorporated by reference).
132. On September 28, 2012, Russell Laffitte as Conservator for Hannah Plyler, issued
a check to himself from the PSB conservatorship account for Hannah Plyler in the amount of Fifty
23
Thousand ($50,000.00) Dollars. (See Exhibit FF at Loan 92812 (the date of the loan) and check
#1043 attached as Exhibit JJ and incorporated by reference).
133. On the same date, Russell Laffitte executed a Promissory Note promising to repay
Hannah Plyler the sum of Fifty Thousand and 00/100 ($50,000.00) Dollars. While the Promissory
Note Laffitte prepared for his own signature indicates that the interest rate for the loan was at the
below market rate of 2.50%, a Laffitte internal tracking document shows that he actually charged
himself 1.5% interest. Upon information and belief, the loan was accomplished by way of a transfer
to an account in Russell Laffitte’s name at PSB. (See the 9/28/12 Promissory Note attached as
Exhibit KK and incorporated by reference.)
134. On November 21, 2012, following a partial pay down on the Laffitte Loan for
Fifty Thousand ($50,000.00) Dollars, Laffitte “renewed” the loan via a new Promissory Note in
the amount of Forty Thousand One Hundred Ninety Eight and 65/100 Dollars ($40,198.65). (See
the 11/21/12 Promissory Note attached as Exhibit LL and incorporated by reference.)
135. On November 15, 2012, Russell Laffitte as Conservator for Hannah Plyler, loaned
Twenty Five Thousand ($25,000.00) Dollars to himself from the PSB conservatorship account for
Hannah Plyler. A Promissory Note Laffitte prepared for his own signature indicates that the
interest rate for the loan was at the below market interest rate of 2.5%. Upon information and
belief, the loan was accomplished by way of a transfer to an account in Russell Laffitte’s name at
PSB. (See Exhibit FF at Loan 111612 and the Promissory Note attached as Exhibit MM and
incorporated by reference).
136. On May 28, 2013, Russell Laffitte as Conservator for Hannah Plyler, loaned
himself Ten Thousand ($10,000.00) Dollars by issuing a check made payable to cash (check
#1050). Upon information and belief, he cashed the check at PSB. (See Exhibit FF at Loan52813
24
(the date of the loan) and the 2013 5/28/2013 entry showing “RLL loan” attached as Exhibit NN
137. On June 14, 2013, Laffitte loaned himself Twenty Thousand ($20,000.00) Dollars
from the Hannah Plyler Conservatorship account at PSB. While the loan is not documented by a
Promissory Note, a Laffitte internal tracking document shows that he charged himself 2.25%
interest. (See Exhibit FF at Loan 61413 (the date of the loan).)
138. On December 27, 2013, Laffitte loaned himself Twenty Five Thousand
($25,000.00) Dollars from the Hannah Plyler Conservatorship account at PSB by transferring the
money to a savings account that Laffitte also maintained at PSB. While the loan is not documented
by a Promissory Note, a Laffitte internal tracking document shows that he charged himself 1.5%
interest. (See Exhibit FF at Loan 122713 (the date of the loan) and the 2013 12/27/2013 entry
showing “New loan 122713 RL” attached as Exhibit OO and incorporated by reference.)
139. As Hannah Plyler approached her eighteenth birthday, Laffitte had a problem – he
didn’t have the money to repay all of the loans.
140. By his own calculations, Laffitte determined that he was short by the sum of Two
Hundred Sixty Four Thousand Five Hundred Thirty Seven and 27/100 ($264,537.27) Dollars. (See
Exhibit FF at Laffitte’s handwritten $264,537.27 at top center of page.)
141. If he was going to fix the mess he had created, Russell was going to have to hustle.
142. Upon information and belief, in order to “cure” his problem, Laffitte simply
accessed other accounts that had been placed in his management for other clients that had been
sent his way by Murdaugh and PMPED.
143. Upon information and belief, Laffitte transferred the sum of One Hundred Fifty
One Thousand Seven Hundred Twenty Six and 05/100 ($151,726.05) Dollars from an account in
25
the name of PMPED client, Arthur Badger.
144. Upon further information and belief, more money came from other PMPED client
accounts at PSB, and perhaps from an account in the name of Hakeem Pinckney’s estate.
145. Upon further information and belief, the balance of the shortfall came from a
credit from Russell Laffitte for a portion of his conservatorship fees – fees that he was not legally
entitled to charge or to retain given his profound breaches of the fiduciary duties he owed the Plyler
girls.
146. On April 20, 2015, Russell Laffitte met Hannah Plyler at a Starbucks coffee shop
in Columbia, South Carolina. He brought with him a file of various materials related to his time as
conservator, presented the file to Hannah, told her “Good luck” and walked out of her life.
147. So, all’s well that ends well? Laffitte was able to steal enough money from other
people to make good the money that he took from the girls - But not so fast.
148. Over the passage of time that Laffitte served as Conservator for the Plyler girls,
he paid himself approximately $260,000.00 in conservator fees, none of which he is entitled to
retain given his profound acts of self-dealing and breaches of fiduciary duty. These funds do not
include the sizable fees Laffitte also “earned” on the deaths of Angela and Justin Plyler.
149. Over the passage of time that Laffitte served as Conservator for the Plyler girls,
he reaped the benefit of low interest rate loans for his personal pursuits, while at the same time he
served up the girls to pay exorbitant interest rates for litigation loans to PSB.
150. For each and every one of the Murdaugh Loans that Laffitte issued, he received a
benefit which he is not entitled to retain. Whether the benefit was money or the further ingratiation
of the relationship between himself and PSB with Murdaugh and PMPED, a real and tangible
benefit was realized about which the Plaintiffs are entitled to know completely.
26
151. For each and every one of the Laffitte Loans, Laffitte realized a benefit not only
through the artificially low interest rates, but also through the use and application of the money
itself. The Plaintiffs are entitled to know of any benefit realized through the use of the money and
to have that benefit delivered to them.
152. PSB has realized benefits from Laffitte’s conduct through the establishment of
depositor accounts at the bank, the issuance of high rate litigation loans and the further cementing
of the relationship that it enjoys with PMPED.
FOR A FIRST CAUSE OF ACTION AGAINST DEFENDANT LAFFITTE

(Accounting)
153. The Paragraphs listed above are restated herein as if realleged and restated in full
verbatim.
154. At all times relevant hereto, Laffitte operated as the Court appointed conservator
for Alania and Hannah Plyler.
155. As Conservator, Laffitte had a duty to safe keep the property of those he was tasked
to serve and to refrain from any acts of self-dealing.
156. Both Alania and Hannah Plyler are entitled to and pray for a full and complete
accounting from Russell Laffitte, including, but not limited to:
a. An accounting of each and every dollar of theirs that was entrusted to his
management;
b. An accounting of every expenditure made using their money;
c. An accounting of how the money that was loaned to Alec Murdaugh was
used and an accounting of any benefit realized by Alec Murdaugh, Russell
Laffitte and/or others through the use of their money; and,
d. An accounting of how the money that Russell Laffitte loaned to himself was
27
used and an accounting of any benefit realized by Russell Laffitte and/or
others through the use of their money.
FOR A SECOND CAUSE OF ACTION AGAINST DEFENDANT LAFFITTE

(Breach of Fiduciary Duty)
verbatim.
158. At all times relevant hereto, Russell Laffitte owed fiduciary duties to both Alania
and Hannah Plyler, including the duty of loyalty, the duty to refrain from acts of self-dealing and
the duty to act single-mindedly in their best interests.
159. Russell Laffitte repeatedly breached his fiduciary duties to the Plyler girls in a
number of particulars, including but not limited to the following particulars:
a. In causing them to enter into high interest rate loans with PSB for litigation
expenses which he should have insisted that PMPED simply advance on
behalf of their clients;
b. In causing Alania Plyler to borrow money from PSB for a car at outrageous
interest rates, when there was more than enough money in Alania’s account
to pay for the car herself;
c. In failing to seek or obtain Court permission to make loans from the
conservatorship accounts he was sworn to protect;
d. In loaning money to his friend, Alec Murdaugh, using the conservatorship
account he was sworn to protect;
e. In loaning money to his friend, Alec Murdaugh, unsecured and at below
market interest rates;
f. In loaning money to his friend, Alec Murdaugh, without loan committee
28
review;
g. In loaning money to his friend, Alec Murdaugh, when he knew that
Murdaugh was a credit risk;
h. In loaning money to his friend, Alec Murdaugh, when he knew that
Murdaugh’s other accounts at PSB were overdrawn;
i. In making loans to himself at below market interest rates;
j. In making loans to himself without proper collateral;
k. In making loans to himself for the purpose of pursuing personal financial
opportunities; and
l. In such other particulars as the evidence in the case may demonstrate.
160. By virtue of his many breaches of fiduciary duty, Defendant Laffitte benefited in
many ways. He benefited through the receipt of conservatorship fees. He benefited through access
to money at below market interest rates. He benefited through rewarding and/or protecting his
friend, Alec Murdaugh, and through advancing his bank’s relationship with PMPED. He benefited
from the use of the conservatorship funds for the pursuit of personal opportunities.
161. The Plaintiffs are entitled to and pray for an award of damages, including a
complete disgorgement of any and all fees paid to Russell Laffitte, a complete disgorgement of
any and all benefits that Laffitte realized through the improper use of the conservatorship accounts,
interest on the “loans” at the same rates as they had been charged by PSB at the hands of Laffitte,
and other relief that will be revealed through the light of discovery, along with an award of punitive
damages in a sum determined by a jury to be sufficient to impress upon the Defendant the
seriousness of his conduct and to deter such similar conduct in the future.
FOR A THIRD CAUSE OF ACTION AGAINST DEFENDANT PSB

(Aiding and Abetting the Breach of Fiduciary Duty)
29
verbatim.
163. As set forth herein above, Russell Laffitte owed fiduciary duties to the Plaintiffs
and breached those fiduciary duties.
164. PSB knowingly participated in Russell Laffitte’s breaches of fiduciary duty, in a
number of particulars, including but not limited to the following:
a. PSB expressly authorized Russell Laffitte to serve as conservator for the
Plyler girls;
b. PSB understood the nature of a conservatorship account and the fact that it
was to be managed under the auspices of the probate court for the exclusive
benefit of the account ward;
c. PSB desired to further its symbiotic relationship with PMPED by having its
Vice President serve as the conservator of the Plyler girls;
d. PSB established the conservatorship accounts which were utilized by
Russell Laffitte in order to breach his fiduciary duties;
e. During Russell Laffitte’s oversight of the conservatorship accounts at PSB,
PSB knew that the accounts were repeatedly overdrawn and PSB repeatedly
charged overdraft fees against the account;
f. PSB knew that many of the improper loans issued by Russell Laffitte to
Alec Murdaugh were accomplished by intra-bank transfers;
g. PSB knew that Alec Murdaugh was overdrawn on its accounts and knew
his overdraw was cured by a transfer of money into his account from the
Hannah Plyler conservatorship account; and
30
h. In such other particulars as the light of discovery may reveal.
165. By virtue of the many breaches of fiduciary duty by Defendant Laffitte in which
Defendant PSB aided and abetted, Defendant Laffitte benefited in many ways. He benefited
through the receipt of conservatorship fees. He benefited through access to money at below market
interest rates. He benefited through rewarding and/or protecting his friend, Alec Murdaugh, and
through advancing his bank’s relationship with PMPED. He benefited from the use of the
conservatorship funds for the pursuit of personal opportunities. PSB benefited as well by
advancing its relationship with PMPED, by having clients of PMPED continue to establish large
depository accounts at the bank and by having access to PMPED clients for the purpose of issued
high interest rate litigation loans.
166. The Plaintiffs are entitled to and pray for an award of damages, including a
complete disgorgement of any and all fees paid to Russell Laffitte, a complete disgorgement of
any and all benefits that Laffitte realized through the improper use of the conservatorship accounts,
interest on the “loans” at the same rates as they had been charged by PSB at the hands of Laffitte,
a disgorgement of any and all benefit separately realized by PSB Bank, and other relief that will
be revealed through the light of discovery, along with an award of punitive damages in a sum
determined by a jury to be sufficient to impress upon Defendant PSB the seriousness of its conduct
and to deter such similar conduct in the future.
WHEREFORE, the Plaintiffs pray for judgment against the Defendants for actual damages
in a sum sufficient to compensate them fully for all losses occasioned herein, whether past, present
or future, disgorgement, and punitive damages in a sum determined by a jury to impress upon the
Defendants the seriousness of their conduct and to deter such similar conduct in the future, as well
as attorney’s fees and costs, and any other relief granted by this Court.
31
Charleston, South Carolina
August 24, 2022
BLAND RICHTER, LLP

Attorneys for Plaintiffs
s/Eric S. Bland
Eric S. Bland (SC Bar No. 64132)
1500 Calhoun Street
Post Office Box 72
Columbia, South Carolina 29202
t: 803.256.9664 | f: 803.256.3056
ericbland@blandrichter.com
s/Ronald L. Richter, Jr.

Ronald L. Richter, Jr. (SC Bar No. 66377)
s/Scott M. Mongillo
Scott M. Mongillo (SC Bar No. 16574)
18 Broad Street, Mezzanine
Charleston, South Carolina 29401
t: 843.573.9900 | f: 843.573.0200
ronnie@blandrichter.com
scott@blandrichter.com
32

Plyler Complaint

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ELECTRONICALLY FILED - 2022 Aug 24 4:13 PM - HAMPTON - COMMON PLEAS - CASE#2022CP2500241

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

Hannah Plyler and Alania Spohn, )

Charleston, South Carolina

s/Ronald L. Richter, Jr.

Hannah Plyler and Alania Spohn, )

and assumed control of their own finances.

the Plylers’ expense.

PARTIES AND JURISDICTION

citizen and resident of Richland County, South Carolina.

and resident of Richland County, South Carolina and is Hannah’ sister.

citizen and resident of Hampton County, South Carolina.

Columbia, South Carolina.

down the law.

8. Justin was the oldest, and Justin had the right.

12. “Alania, are you asleep?”

16. The car left the roadway.

17. The car struck a stand of pine trees.

18. Alania vividly recalls the smell of pine and smoke.

into Alania’s lap.

She too was motionless.

driver for help.

a frenzied effort to extract Angela and Justin from the vehicle.

roadway leading to the deaths of Angela and Justin Plyler.

and to be handed massive jury trial verdicts.

published by the watchdog group the American Tort Reform Foundation.

controlled since 1910.

involved in the accident:

c. A personal injury action on behalf of Alania Plyler, which became known

as Action No. 05-CP-25-532; and

d. A personal injury action on behalf of Hannah Plyler, which became known

as Action No. 05-CP-25-533.

Guardian ad Litem or Conservator on their behalf.

had the statutory right to pursue lawsuits on their behalf.

President of Palmetto State Bank (“PSB”).

Conservator for cases and to earn handsome fees in the process.

as Personal Representative in favor of Laffitte.

and Justin Plyler by Order of the Hampton County Probate Court.

by way of depository accounts upon the settlement of the cases.

the county of residence of the ward.

54. This obstacle notwithstanding, Murdaugh prepared Petitions to establish the

DISBURSEMENTS TO BE MADE WITHOUT PRIOR APPROVAL OF THE HAMPTON

COUNTY PROBATE COURT.” (See Exhibit B.)

permitting the settlements to go forward.

submitted to the Court and hearings were scheduled.

any continued management of the settlement proceeds.

Fifty Thousand ($50,000.00) Dollars.

Twenty Five Thousand ($25,000.00) Dollars.

66. Alania’s and Hannah’s situations were different.

net of attorneys’ fees and costs in the millions of dollars.

“most” of the money.

the girls received from the death of their mother.

78. The annuities were purchased.

“Hannah Plyler Checking” attached as Exhibit I and incorporated by refence.)

APPROVAL OF THE HAMPTON COUNTY PROBATE COURT.” (See Exhibit B.)

Laffitte established conservatorship accounts at PSB. In fact, when Alania’s conservatorship

household to household within the broader family.

school supplies, clothing and Christmas gifts.

Alec Murdaugh, again without court approval.