2021-12-06 Satterfield Amended Complaint (Murdaugh-BOA) With Exhibits and Virzi Affidavit (As Filed-Without Filed Stamp)

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FOR THE FOURTEENTH JUDICIAL CIRCUIT

COUNTY OF HAMPTON ) CIVIL ACTION NO.: 2021-CP-25-00298
Michael “Tony” Satterfield, Individually

)
and in his Capacity as the Personal )
Representative of the Estate of Gloria )
Satterfield and Brian Harriott, )
) SUPPLEMENTAL SUMMONS
Plaintiffs, )
)
vs. )
)
Richard Alexander “Alex” Murdaugh, Sr. )
and Bank of America, N.A., )
)
Defendants. )
) Jury Trial Demanded!
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 BLAND RICHTER, LLP
December 6, 2021 Attorneys for Plaintiffs
s/Ronald L. Richter, Jr.
Ronald L. Richter, Jr. (SC Bar No. 66377)
s/Scott M. Mongillo
Scott M. Mongillo (SC Bar No. 16574)
Peoples Building
18 Broad Street, Mezzanine
Charleston, South Carolina 29401
Telephone 843.573.9900
Facsimile 843.573.0200
ronnie@blandrichter.com
scott@blandrichter.com
s/Eric S. Bland
Eric S. Bland (SC Bar No. 64132)
1500 Calhoun Street
Post Office Box 72
Columbia, South Carolina 29202
Telephone803.256.9664
ericbland@blandrichter.com
1
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FOR THE FOURTEENTH JUDICIAL CIRCUIT
COUNTY OF HAMPTON ) CIVIL ACTION NO.: 2021-CP-25-00298
Michael “Tony” Satterfield, Individually

)
and in his Capacity as the Personal )
Representative of the Estate of Gloria )
Satterfield and Brian Harriott, )
) AMENDED COMPLAINT
Plaintiffs, )
)
vs. )
)
Richard Alexander “Alex” Murdaugh, Sr. )
and Bank of America, N.A., )
)
Defendants. )
) Jury Trial Demanded!
The Plaintiffs, complaining of the conduct of the Defendants herein, allege as follows:
INTRODUCTION
As detailed herein, Bank of America, N.A. (“BOA”) acted as Alex Murdaugh’s
(“Murdaugh”) BANK OF FRAUD. Specifically, BOA aided and abetted Murdaugh’s financial
crimes and money laundering. 1 By flexing their own rules and ignoring banking customs, BOA
helped Murdaugh establish his fake Forge accounts, which Murdaugh funded with stolen money
from the Plaintiffs, as well as other victims and/or PMPED 2 clients. Once he was in possession of
his ill-gotten gain, Murdaugh engaged in other suspicious banking conduct with BOA should have
identified. For example, from one of Murdaugh’s fake BOA accounts, he issued 17 cashier’s
checks to Charles E. Smith (a/k/a Cousin Eddie) totaling $164,748.76. 3 In addition, Murdaugh
1
On November 18, 2021, Murdaugh was issued 27 indictments for financial crimes, nine of which pertain to the
Plaintiff’s money, including counts for money laundering $403,500.00, money laundering $2,961,931.95 and money
laundering $118,000.00.
2
Peters, Murdaugh, Parker, Eltzroth & Detrick, PA
3
These cashiers checks were issued between October 8, 2019 and May 28, 2021 from a fake “Forge” account as is
described herein.
2
transferred huge sums of stolen money from his fake Forge accounts to a personal checking
account which Murdaugh also established at BOA. From one such account, Murdaugh separately
issued 254 personal checks to Cousin Eddie totaling $1,825,560.95.
BOA was the last clear chance to stop Murdaugh’s criminal activities; instead of acting as
a good corporate citizen, BOA chose to cash in on his crimes. To be clear, BOA made significant
fees from Murdaugh’s accounts, presumably loaned money based on his stolen deposits and
collected interest on the same. But what is truly unbelievable is that even after Murdaugh’s fraud
and theft was exposed, BOA failed to terminate Murdaugh as a customer. 4
Through this Amended Complaint, Plaintiffs seek to hold BOA accountable for its
deceptive business practices and its conspiracy with Murdaugh. 5 Murdaugh did not act alone.
BOA is the bank of a money launderer. BOA is a bank of fraud. They are nothing more than a
high-tech laundromat.
PARTIES & JURISDICTION
1. Plaintiff Michael “Tony” Satterfield (“Tony”) is a citizen and resident of Hampton
County, South Carolina, and he brings this action both individually and in his capacity as the
Personal Representative of the Estate of Gloria Satterfield (“Estate”), Hampton County Probate
Court No: 2018-ES-25-0056, on behalf of the Estate.
2. Plaintiff Brian Harriott (“Brian”) is a citizen and resident of Hampton County,
South Carolina and the half-brother of Tony.
4
Upon information and belief, Murdaugh may have been a BOA customer as late as November 23, 2021.
5
See Plaintiffs’ SCUPTA and civil conspiracy claims below.
3
3. Upon information and belief, Defendant Richard Alexander “Alex” Murdaugh, Sr.
(“Murdaugh”) is a citizen and resident of Colleton County, South Carolina and at all times relevant
hereto was a lawyer licensed to practice law in the State of South Carolina. 6
4. Upon information and belief, Bank of America, N.A. (“BOA”) is a Delaware
corporation registered to conduct business in the State of South Carolina as a foreign corporation
and is a federally charted banking institution with its principal place of business located in
Richland County, South Carolina.
5. This court has jurisdiction over the parties to and the subject matter of this litigation.
6. Venue of this action is proper in this court.
FACTUAL BACKGROUND
7. The Murdaughs are a prominent and wealthy family based in Hampton County who
for generations controlled the Hampton County Solicitor’s Office and who remain the preeminent
legal family in the area.
8. Prior to her untimely death on February 26, 2018, Gloria Satterfield (“Gloria”) had
worked for Murdaugh and his family as a housekeeper and nanny for over two decades.
9. Gloria was told she was an extension of the Murdaugh family after helping to raise
the two Murdaugh boys, Buster and Paul, and she believed it to be true, as did her sons who are
the Plaintiffs in this matter.
10. Both Gloria and the Plaintiffs revered Murdaugh and respected his position of
prominence in Hampton County.
11. While Gloria was proud of her association with the Murdaugh family, she was most
proud of her two sons, Tony and Brian.
6
On September 8, 2021 Murdaugh was temporarily suspended from the practice of law by the South Carolina Supreme
Court.
4
12. On February 2, 2018, Gloria fell while working in Murdaugh’s home.
13. According to the Murdaughs and as reported to Gloria’s family and others, Gloria’s
fall down the exterior stairs of the Murdaughs’ Moselle, South Carolina home in Colleton County,
South Carolina was caused accidentally by the Murdaughs’ dogs.
14. On February 26, 2018, Gloria died as a result of injuries sustained in the fall after
spending approximately three (3) weeks in Trident Hospital in Summerville, South Carolina with
traumatic brain injuries.
15. Gloria was fifty-seven (57) years old at the time of her death.
16. Gloria died intestate. Because she died without a Last Will and Testament, in
accordance with the South Carolina statute for intestate succession, Gloria’s sole legal heirs were
Tony and Brian.
17. After Gloria’s death, Murdaugh told Tony and Brian’s uncle and aunt that he was
going to take the boys to see an attorney he “knew” who would represent them in making claims
against Murdaugh because it was his dogs that caused his mother’s death and he was therefore
legally responsible for Gloria’s death.
18. Sometime after their mother’s funeral, Murdaugh personally introduced Tony to
Corey Fleming, Esquire (“Fleming”), who at the time was a partner in of a Beaufort, South
Carolina law firm.
19. Murdaugh sent Tony to meet Fleming at Fleming’s office and encouraged Tony
and his brother to retain Fleming to represent them in bringing legal claims against Murdaugh in
connection with their mother’s death.
20. The Plaintiffs did not otherwise know anything about Fleming, but they didn’t need
to know anything about Fleming– they trusted Murdaugh.
5
21. Unbeknownst to Tony and Brian, Fleming was a former college roommate of
Murdaugh and was his best friend.
22. Also unbeknownst to Tony and Brian, Fleming was the Godfather of Murdaugh’s
son, Paul Murdaugh
23. Upon information and belief, Fleming had been co-counsel or he worked with
Murdaugh on many other cases.
24. Tony met with Fleming and agreed for him to represent Tony and Brian, although
the terms of the engagement were never reduced to writing. Tony trusted him and had no reason
not to trust him.
25. Tony and Brian trusted Fleming because they trusted Murdaugh 7 and because they
continued reasonably to believe that Murdaugh was representing their interests along with
Fleming.
26. In fact, even after Fleming was hired, Tony was encouraged by Murdaugh to
continue to communicate with Murdaugh directly as it related to his mother’s Estate and
periodically about the status of their claims.
27. Additionally, and upon information and belief, the Estate filings that resulted in the
appointment of Tony to serve as the Personal Representative were prepared with the assistance of
Murdaugh.
7
For example, in 2016 Brian used Murdaugh to represent him in probating his for his grandmother’s estate in In The
Matter of Mildred Smith Stanley, Case Number 2016-ES-25-0170 and he even gave Murdaugh his Power of Attorney
in that matter (emphasis supplied and see Exhibit A, attached and incorporated by reference). In addition, Tony
contacted Murdaugh for legal advice about his deceased father’s estate in In The Matter of David Satterfield, Case
Number 2013-ES-25-0146 and Murdaugh advised him about the same. (See Exhibit B attached hereto and
incorporated by reference.) Murdaugh also had represented Brian in connection with an automobile accident to
recover damages for personal injuries.
6
28. As a result of such filings, on March 28, 2018, Tony was appointed to be the
Personal Representative of the Estate as was his statutory right 8. (See Certificate Appointment
attached as Exhibit C and incorporated by reference.)
29. Furthermore, on May 24, 2018, Murdaugh’s office sent a letter to the Records
Custodian for Trident Anesthesia Group seeking Gloria’s medical records and confirmed their
representation of Gloria’s Estate in the letter: “As you know, this office represents Michael
Satterfield as PR for the Estate of Gloria Satterfield …” (See 5/24/18 letter attached as Exhibit D
and incorporated by reference).
30. Murdaugh sent the letter to Trident despite the fact that on March 8, 2018,
Murdaugh had received a letter from Fleming that placed Murdaugh on notice that Fleming was
representing the Estate of Gloria Satterfield for wrongful death claims that the Estate intended to
pursue against Murdaugh. (See March 8, 2018 letter attached hereto as Exhibit E and incorporated
by reference).
31. Despite the bizarre misalignment of Murdaugh serving as legal counsel for the
purpose of pursuing claims against himself, it is clear that Murdaugh represented the Estate of
Gloria Satterfield.
32. It is likewise clear that Murdaugh represented Tony in his capacity as the Personal
Representative of the Estate.
33. Moreover, Murdaugh owed duties to Tony and Brian individually as the sole
statutory heirs of the Estate, and as the legal heirs on whose behalf a wrongful death claim was to
be pursued.
34. Murdaugh never explained the concept of a “conflict of interest” with Tony or
Brian.
8
S.C. Code Ann. § 62-3-203(a).
7
35. A conflict of interest exists when an attorney’s interests make it impossible to
provide zealous and single-minded representation to a client.
36. By undertaking the representation, Murdaugh was effectively pursuing claims
against himself on behalf of the Plaintiffs.
37. Murdaugh undertook his representation despite the presence of an irreconcilable
conflict of interest which would have made his involvement completely impermissible in
accordance with the South Carolina Rules of Professional Conduct.
38. Minimally, Murdaugh was ethically required to disclose the conflict in writing to
Tony and Brian, although the conflict was so profound that it would not have been possible to
obtain Tony and Brian’s informed consent and waivers of the conflicts even with full disclosure.
In any event, the Satterfield boys were told nothing about the existence of a conflict of interest.
39. In the absence of a written fee agreement, the scope of the relationship between
lawyer and client is defined by the reasonable expectations of the client.
40. In this case, Tony and Brian reasonably believed that Fleming was representing
their interests and the Estate’s interests, along with Murdaugh.
41. Because the claims that would be asserted against Murdaugh consisted of a survival
claim and a wrongful death claim, a Personal Representative was required to prosecute the claims
beneficially for the Estate and for Tony and Brian in accordance with South Carolina statutory
law.
42. During Tony’s tenure as Personal Representative and without his knowledge or
involvement, claims were made against Murdaugh for Gloria’s death, which claims were then
reported to the various insurance carriers who provided coverage for Murdaugh’s Mosselle home.
43. Although Tony had been appointed to serve and was fully capable of continuing to
serve as the Personal Representative of his mother’s Estate, in or around October, 2018, Murdaugh
8
and Fleming decided that it would be beneficial and more “convenient to them” to replace Tony
with a successor Personal Representative.
44. Upon further information and belief, the decision to replace Tony was made out of
a concern that Tony would ask too many questions.
45. Murdaugh and Fleming desired instead a Personal Representative who would not
ask questions.
46. Furthermore, as the attorney client relationship in these setting is made technically
between the lawyers and the Personal Representative, the appointment of a substitute Personal
Representative would create a mechanism through which the attorneys would technically not have
to communicate directly with Tony or Brian any longer.
47. In the fall of 2018, Tony and Brian were told that they would be better served if
Tony ceased his role as Personal Representative of his mother’s estate and that the role should be
entrusted to Palmetto through its Vice President, Chad Westendorf (“Westendorf”), as there would
be “business issues” arising as the matter proceeded that were beyond Tony’s experience.
48. Tony and Brian were not told, however, that an initial settlement in the amount of
$505,000.00 had already been made with one of the insurance companies that insured the
Murdaugh home, Lloyd’s of London, and that a check in the same amount had already issued on
December 4, 2018.
49. Tony and Brian were not told that the lawyers had decided to “slow walk” the initial
settlement until a new Personal Representative could been appointed to replace Tony.
50. Tony and Brian were also not told that in accordance with S.C. Code Ann. §62-3-
203, other Satterfield family members had statutory priority to serve as the Successor Personal
Representative of the Estate over Westendorf.
9
51. Even though there were suitable family member candidates to serve as the Personal
Representative of Gloria’s estate, Murdaugh instead engaged Westendorf, as an officer of
Palmetto, to be the Successor Personal Representative for the Estate.
52. Tony agreed to step aside as the PR because he trusted the lawyers and because he
was impressed that the Vice President of Palmetto would be serving in his stead and that the Vice
President of Palmetto would indeed have greater business expertise than himself.
53. At the time Tony agreed to step aside, he knew nothing of the $505,000.00
settlement that was reached and that the check was actually received by December 6, 2018.
54. Upon information and belief, the appointment to serve as personal representative
for the Estate of Gloria Satterfield was Westendorf’s first engagement as a personal representative.
55. In order for Westendorf to be appointed as the Successor Personal Representative
of the Estate, Tony had to resign as the original Personal Representative and Brian had to renounce
his right to serve.
56. On October 31, 2018, Brian signed a second “Renunciation of Right to
Administration and/or Nomination and/or Waiver of Bond” at Murdaugh’s office. (See a screen
shot of Kristi Jarrell’s LinkedIn profile attached as Exhibit F and the 10-31-18 “Renunciation of
Right to Administration and/or Nomination and/or Waiver of Bond” attached as Exhibit G and
both are incorporated by reference.)
57. On November 16, 2018, Tony signed his “Renunciation of Right to Administration
and/or Nomination and/or Waiver of Bond” at Murdaugh’s office. (See the 11-16-18
“Renunciation of Right to Administration and/or Nomination and/or Waiver attached as Exhibit
H and incorporated by reference.)
10
58. The Renunciation of Right to Administer signed by both Brian and Tony indicated
that they were not simply renouncing their right to serve, but that they were renouncing their right
to serve in favor of Westendorf.
59. It is through these Renunciations of Right to Administer that Westendorf was
appointed Successor Personal Representative of the Estate.
60. After his appointment, Westendorf never communicated with Tony or Brian, never
opened an Estate Bank Account, never obtained a FEIN number for the Estate, never
communicated in writing with the Hampton County Probate Court and never provided periodic
inventories or status reports to the Hampton County Probate Court nor advised it of any settlements
of wrongful death or survival.
61. After Tony and Brian executed their Renunciations of Right to Administer,
Westendorf did not automatically become the Successor Personal Representative. A formal court
order appointing him would be required.
62. While waiting on his appointment, the Lloyds of London settlement check in the
amount of $505,000.00 was delivered to Fleming on December 6, 2018. Tony was still the acting
Personal Representative.
63. Neither Tony, nor Brian, participated in the settlement negotiations.
64. Neither Tony, nor Brian, signed any settlement agreements.
65. Neither Tony, nor Brian were told that money was recovered for them or that there
was a settlement.
66. Importantly, wrongful death and survival claims must be approved by court order
in South Carolina. 9
9
S.C. Code Ann. §15-51-42.
11
67. Wrongful death and survival claims are approved based upon a petition filed by the
Personal Representative, who must attest to the Court that they have been fully informed of the
terms of the settlement and of the fees and costs involved and that they believe the settlement is in
the best interests of the estate and the heirs.
68. No one advised Tony of the $505,000.00 settlement or of the need to file such a
petition.
69. Instead, even though they had check in hand since December 4, 2018, Fleming and
Murdaugh waited on Westendorf’s appointment so that Westendorf could be the petitioner and so
that Westendorf could appear at a future hearing on the petition seeking approval – and not Tony.
(See the December 4, 2018 check in the amount of $505,000.00 attached as Exhibit I).
70. On December 18, 2018, Westendorf was appointed Successor Personal
Representative of the Estate of Gloria Satterfield by court Order.
71. On December 19, 2018, Westendorf, petitioned the Court to approve the
$505,000.00 settlement that he had no involvement in procuring. The Petition was filed in the
Hampton County Court of Common Pleas and was assigned action number: Civil Action
No.:2018-CP-25-0505. (See the Petition attached hereto as Exhibit J and incorporated by
reference).
72. In the Petition, Tony and Brian are identified as the sole “statutory” and “intestate
heirs.” The Petition asks the Court to approve a “partial settlement” apportioned as follows:
"$475,000.00 for wrongful death and $25,000.00 for survival action and $5,000.00 for med pay.”
73. The $25,000.00 of survival funds would be part of Gloria’s estate that would have
to go through probate before being distributed to the Plaintiffs.
12
74. In accordance with South Carolina law, the $475,000.00 wrongful death settlement
was a direct claim Tony and Brian to compensate them for the grief, sorrow and mourning
associated with the loss of their mother and did not have to pass through the Estate.
75. Upon receipt, the net proceeds of the $475,000.00 wrongful death payment were to
be paid immediately to Tony and Brian.
76. Although court approval of wrongful death settlements is required by South
Carolina statutory law, no signed order approving the settlement appears on the Court docket.
77. Nevertheless, upon information and belief, a hearing of some kind may have taken
place on December 19, 2018, based upon a later email between Westendorf and Fleming in which
Westendorf requests a copy of a document signed by a Judge. (See unsigned and unfiled “Order
Approving Wrongful Death and Survival Settlement” without a complete civil action number
attached as Exhibit K as well as an email from Westendorf to Fleming dated January 14, 2019
attached hereto as Exhibit L).
78. Attached hereto as Exhibit K is an unsigned “Order Approving Wrongful Death
and Survival Settlement” describing the December 19, 2018 hearing which was apparently
prepared for the signature of the Honorable Carmen Mullen, but it does not contain the proper case
number and was never filed as of record. Plaintiffs do not know whether this is the document that
Westendorf sought from Fleming in his January 14th email.
79. On January 7, 2019, in direct contravention of the filed Petition and at the direction
of Murdaugh, Fleming sent a check #24817 to an account called “Forge” care of a post office box
in Hampton, South Carolina in the amount of $403,500.00 and did so without a cover letter
enclosing the check. (See a copy of said check attached as Exhibit M and incorporated by
reference).
13
80. Of course, having obtained the $403,500.00 through a breach of trust and a breach
of his fiduciary duties, Murdaugh needed a place to deposit the funds and needed a bank to help
him launder the money – otherwise, he just has a check made to a fake company that he could not
negotiate.
81. As early as 2015, Murdaugh set up two bank accounts with BOA using a version
of the name “Forge” for the purpose of creating the illusion that these accounts were actually
accounts of the structured settlement firm known as Forge Consulting, LLC, with offices in
Columbia, South Carolina.
82. The Murdaugh fake “Forge” accounts were owned and controlled exclusively by
Murdaugh.
83. “Forge” conducts no legitimate business.
84. “Forge” is in the business of stealing money.
85. Upon information and belief, the fake “Forge” accounts became a vehicle through
which Murdaugh began laundering millions of dollars as early as 2015.
86. Murdaugh was able to establish the fake “Forge” accounts with BOA.
87. The two fake “Forge” BOA accounts are:
Account ********7391
Opened 9/22/2015
Name of Sole Proprietorship: Richard A. Murdaugh Sole Prop, DBA Forge
(See BOA “Opening and Maintaining Deposit Account and Services” attached as
Exhibit N and incorporated by reference.)
Account ********7625
Opened 8/21/2018
Name of Business: FORGE
Business Type: Sole Proprietor
Murdaugh signed as “Owner”
(See BOA “Opening and Maintaining Deposit Account and Services” attached as
Exhibit O and incorporated by reference.)
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88. Upon information and belief, BOA violated its own policies and procedures in
permitting the fake “Forge” accounts to be established.
89. Upon information and belief, BOA violated customary banking practices in
permitting the fake “Forge” accounts to be established.
90. For example, according to BOA policies and procedures, Murdaugh was required
to provide a business name filing document or a business license showing the establishment of
“Forge” as a legitimate business. Upon information and belief, no such documentation was
provided.
91. In addition, according to BOA policies and procedures, in order to open a “d/b/a
account” (doing business as), Murdaugh was required to provide a fictitious name certificate,
certificate of trade name, assumed name certificate and/or DBA certificate. Upon information and
belief, no such documentation was provided.
92. According to BOA policies and procedures, in order to open the “Forge” account,
Murdaugh was required to provide a federal tax id number (“TIN”). Instead, BOA never verified
that Murdaugh actually provided a fake TIN which was nothing more than his social security
number with a hyphen after the first two digits making it appear in format as a legitimate TIN. Of
course, BOA knew Murdaugh’s social security number and a simple check of the TIN would have
shown it to be fictitious.
93. Upon information and belief, the account opening forms were executed at a BOA
branch and a BOA employee aided Murdaugh in filing out the forms and in using Murdaugh’s
SSN in order to fabricate a fake TIN.
94. This fake TIN is an example of an extraordinary and specific fact which should
have alerted BOA to the possibility of fraud especially since it was the same exact identification
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number used by Murdaugh’s fist fake BOA account opened 3 years prior (Account
********7391).
95. BOA had a duty to the Plaintiffs to investigate this fake TIN and if it had, the
Plaintiffs’ funds would not have been deposited into Murdaugh’s second fake BOA Forge account
in 2019.
96. Upon information and belief, an as of yet unknown BOA employee or employees
(aka John or Jane Doe(s)) knew of and assisted Murdaugh in creating the fake Forge accounts.
97. While customary banking practices would have required BOA to “know its
customer” and to understand the nature of its business, BOA did nothing to come to know the
nature of Alex Murdaugh’s “Forge” business.
98. Upon information and belief, BOA knew that Alex Murdaugh was an attorney
licensed in the State of South Carolina.
99. Upon information and belief, BOA knew of the existence of a legitimate business
known as Forge Consulting, LLC, a firm that specializes in assisting attorneys and their clients
with structuring settlement funds on behalf of victims who receive money through legal claims.
100. If BOA had been paying attention at all, it should have known that Alex Murdaugh
sought to leverage the name and reputation of the real Forge Consulting, LLC in the establishment
of his fake “Forge” business. Of course, BOA was at all times just one question away from finding
out the truth had they simply asked, “what is the nature of ‘Forge’s’ business,” as was their duty
to do.
101. Upon information and belief, BOA knew that as an attorney licensed to practice
law in South Carolina, Alex Murdaugh would periodically have access to money that belonged to
his clients, which money he had a duty to safeguard on behalf of his clients. As such, BOA knew
that Alex Murdaugh acted in the role of a fiduciary in the safekeeping of money entrusted to him.
16
102. As BOA did literally nothing to learn the nature of Alex Murdaugh’s “Forge”
business, BOA logically concluded or should have concluded that it was an extension of Alex
Murdaugh’s law practice and, correspondingly, an extension of his role as fiduciary.
103. After having allowed the fake accounts to be established, BOA thereafter did not
properly supervise these fake accounts or monitor these accounts in accordance with the applicable
banking statutes, rules, regulations, and, upon information and belief, its own internal policies and
procedures including but not limited to deposits and endorsements on checks.
104. Through its lack of oversight, BOA allowed the fake “Forge” accounts to be used
to launder millions of dollars through deposits of stolen checks, transfers to other accounts and/or
the issuance of many cashier’s checks.
105. Murdaugh was seasoned in his money laundering by the time he received the
Satterfield money in 2018.
106. Murdaugh received the first of his Satterfield money in the form of a check issued
to “Forge” on January 7, 2019, in the amount of $403,500.00.
107. Murdaugh deposited the $403,500.00 into one of his fake “Forge” accounts with
BOA on January 9, 2019.
108. On February 27, 2019, the $403,500.00 deposit was comingled with another deposit
in the amount of $279,850.65, the source of which is unknown, but is presumed also to be ill-
gotten gain as Forge conducted no legitimate business.
109. In March 2019, Murdaugh then made four bank transfers from the BOA fake
“Forge” account to a personal account controlled by Murdaugh ending in 6779, which transfers
totaled $665,700.00, leaving only $1,735.11 in the fake “Forge” account. As set forth herein, this
pattern would continue with the other stolen Satterfield money as well. Also, as set forth herein,
Murdaugh made many
17
110. After the initial settlement of $505,000.00, additional recoveries were pursued from
additional insurance policies. As a result of a mediation in March 2019, an additional settlement
in the amount of $3,800,000.00 from Nautilus Insurance Company was obtained.
111. Once again, neither Tony, nor Brian, signed any settlement agreements.
112. Once again, neither Tony, nor Brian were told that money was recovered for them,
nor did they receive any of the settlement funds.
113. Following the settlement, a new petition under a different and unapproved caption
of “In RE: Gloria Satterfield” was prepared with no reference to a court term or case number and
it was never filed. (Hereinafter the “Unfiled Petition” a copy of which is attached hereto as Exhibit
P and incorporated by reference).
114. South Carolina law requires that the wrongful death and survival settlements be
made a part of the public record through the filing of a petition and the entry of an order granting
the petition. 10
115. At the settlement hearing, which purportedly occurred on May 13, 2019, the same
date of the unfiled petition to approve the $4,300,000.00 of settlements, the Honorable Judge
Carmen Mullen was presented with a “Settlement Statement” indicating the exact sums recovered
and the sources of recovery. More importantly, the Settlement Statement indicated exactly how
the proceeds were to be distributed, including a distribution of “$2,765,000.00” to the
“Beneficiaries.” (See Settlement Statement attached as Exhibit Q and incorporated by reference).
116. On or about May 13, 2019, Judge Mullen was presented with a proposed Order
Approving Settlement. (See the Order which is attached hereto as Exhibit R and incorporated by
reference).
10
S.C. Code Ann. §15-51-41 and 42.
18
117. Upon information and belief, Judge Mullen trusted that the attorneys and
Westendorf who assembled before her would distribute the funds in accordance with the
Distribution Sheet 11 that she approved and trusted that the attorneys would file her order with the
Hampton County Clerk of Court.
118. Judge Mullen was misled by Fleming, Murdaugh and Westendorf as follows:
a. Failing to advise Judge Mullen that she had previously approved the $505,000.00
Lloyds’ settlement and that the signed order could not be located;
b. Representing to Judge Mullen that the Beneficiaries of the Estate were fully
informed as to the terms of the settlements;
c. Representing to Judge Mullen that after the in chambers hearing, the attorneys
would ensure that the Unfiled Petition and Order were filed of record;
d. Representing that the settlement funds would be paid directly to Westendorf as the
Personal Representative;
e. Representing to Judge Mullen that the sum of $2,765,000.00 would be paid to the
beneficiaries;
f. Failing to advise Judge Mullen that there were no written fee agreements for
attorneys’ fees and/or misrepresenting to Judge Mullen that such agreements
existed; and
g. Representing to Judge Mullen that the disbursements would paid only as approved
by the Court on the Disbursement Sheet.
119. Upon information and belief, Judge Mullen signed the Order and gave the original
Unfiled Petition and Order to the attorneys for the purpose of filing in the court docket.
120. The Order approved “payment of the amounts set forth” in the Unfiled Petition and
on the Settlement Statement.
121. The Order did not approve any other payments.
11
In addition, Plaintiffs question the $105,000.00 of “prosecution expenses” that were not properly itemized on the
Disbursement Sheet, especially given the fact that the claim was in its infancy and that no known expenses were
incurred other than de-minimus filing fees.
19
122. Having received the Order, the authority under the Order was limited to making the
payments exactly as set forth in the Settlement Statement without deviation. If there was to be any
deviation, an additional modified court order would be required.
123. The Beneficiaries were not paid the sum of $2,765,000.00 – they were not paid a
dime ever.
124. Rather, Westendorf permitted Fleming to send a check #24909 on May 13, 2019 in
the amount of $2,961,931.95 to one of the fake Forge accounts described above in direct
contravention to Judge Mullen’s order. (See a copy of this Forge check attached as Exhibit S and
incorporated by reference).
125. On May 15, 2019, BOA accepted the $2,961,931.95 check for deposit into one of
the fake Forge accounts without question.
126. Within days thereafter, Murdaugh made transfers to his BOA personal account
ending in 6779 in the amounts of $350,000.00, $400,000.00 and $125,000.00.
127. Over time, all of the money from the $2,961,931.95 was stolen and laundered with
the help of BOA by way of transfers to other accounts in the control of Murdaugh and/or through
the issuance of cashiers checks, often in amounts just below $10,000.00.
128. Nearly two years after the initial partial settlement, October 6, 2020, Fleming filed
a Stipulation of Dismissal purportedly ending the Estate’s claims against Murdaugh. Murdaugh
also signed this stipulation. (See the Dismissal attached as Exhibit T and incorporated by
reference.)
129. It is highly unusual that this Dismissal is signed by Murdaugh, as a named party
and not be an attorney engaged by his insurer on his behalf.
20
130. Neither Tony, nor Brian, were consulted about the Dismissal, nor were they told of
what, if any, additional actions had been taken on their behalf in the years following the partial
settlement.
131. On the very same day the Dismissal was filed, October 6, 2020, Westendorf
permitted Fleming to send a third and final check in the amount of $118,000.00 to one of the fake
Forge accounts. (See a copy of this Forge check attached as Exhibit U and incorporated by
reference).
132. On October 6, 2020, BOA accepted the check for $118,000.00 for deposit into the
fake Forge account without any question.
133. By the end of October, 2020, Murdaugh withdrew or transferred to his account
ending in 6779 amounts totaling $117,200.94, leaving just $839.42 of the $118,000.00 in
Satterfield money that had been deposited on October 6, 2020.
134. The Plaintiffs first learned that money had been recovered from the death of Gloria
when it was reported in the press in late 2020.
135. Since that time and through the litigation process, the Plaintiffs have learned of
some of the uses that Alex Murdaugh has made of their money with the assistance of BOA.
136. Between October 8, 2019 and May 28, 2021, Murdaugh used his fake BOA Forge
account to issue 17 cashier’s checks to Charles E. Smith (a/k/a Cousin Eddie) totaling $164,748.76.
137. From his personal account and through transfers of money from his fake Forge
accounts, Alex Murdaugh separately issued 254 personal checks to Cousin Eddie totaling
$1,825,560.95.
138. The individual breaches of the parties herein singularly or collectively proximately
caused Plaintiffs’ damages.
21
139. BOA should have been a backstop for one Murdaugh’s misconduct, but its breaches
of duty served only to become the vehicle through which Murdaugh was able to operate his
fraudulent scheme.
140. Even if others acted complicitly with Murdaugh, BOA should have easily prevented
the misappropriation of $4,305,000.00 through the simple discharge of their duties. BOA was
literally one question away from preventing these losses:
a. BOA: What is the TIN for Forge?
141. On November 18, 2021, Murdaugh was issued 27 indictments for financial crimes,
nine of which pertain to the Plaintiffs’ money, including counts for money laundering $403,500.00,
money laundering $2,961,931.95 and money laundering $118,000.00.
142. BOA is the bank of the money launderer.
143. The money laundering would not have been possible without BOA.
144. BOA is Murdaugh’s bank of fraud.
FOR A FIRST CAUSE OF ACTION AS TO DEFENDANT MURDAUGH

ACCOUNTING
145. The paragraphs enumerated above are incorporated herein as if alleged and restated
in full herein.
146. Plaintiffs are entitled to an accounting of any and all funds recovered as a result of
Civil Action No.:2018-CP-25-0505 and/or any other claim, action or settlement involving the
death of their mother or the Estate.
147. Murdaugh owes a duty to provide Plaintiffs with such an accounting.
148. Plaintiffs have never received an accurate accounting.
149. Therefore, Plaintiffs hereby demand from Defendant Murdaugh an immediate, full,
complete, and accurate accounting of any and all funds, costs, and expenses from Civil Action
22
No.:2018-CP-25-0505 and/or from any other claim, action or settlement involving the death of
their mother or the Estate, as well as all supporting documentation for the same.
FOR A SECOND CAUSE OF ACTION AS TO MURDAUGH AND BOA

CIVIL CONSPIRACY
150. Paragraphs enumerated above are incorporated herein as if alleged and restated in
full herein.
151. Defendants, and perhaps other unnamed third-parties, combined together for the
purpose of injuring Plaintiffs.
152. Plaintiffs have suffered special damage in that they have been forced to incur legal
expense in an effort to stop these unlawful actions and Plaintiffs’ damages are different and unique
as compared to their other causes of action listed herein.
153. Plaintiffs are entitled to and pray for an award of damages against the Defendants
and perhaps other unnamed third parties for all losses suffered herein, including special damages,
as well as an award of punitive damages in an amount deemed sufficient by a jury to impress upon
these Defendants the seriousness of their conduct and to deter such similar conduct in the future.
FOR AN THIRD CAUSE OF ACTION AS TO BOA

AIDING AND ABETTING BREACH OF FIDUCIARY DUTY
full herein.
155. BOA is required to follow customary and usual banking practices in the conduct of
its business, especially as it pertains to the establishment of accounts, and particularly small
business or DBA account.
156. BOA had a duty to obtain, verify, and record information that identifies each
person/entity who opens an account.
23
157. In general, all banks, such as BOA, are required to have a written Customer
Identification Program (“CIP”) that includes specific requirements appropriate for individuals and
businesses opening accounts.
158. The CIP must be incorporated into the bank’s overall Anti-Money Laundering / Bank
Secrecy Act (“AML/BSA”) processes and subject to approval by the bank’s board of directors.
159. With regards to opening a business account, BOA was required to know the
business name, business physical street address, as well as additional identification information.
160. For example for a “doing business as account” (“DBA”) such as Account
********7391 “Richard A. Murdaugh Sole Prop, DBA Forge” and/or Account ********7625
“FORGE” BOA should have required an Affidavit of Certificate of Doing Business Under an
Assumed Name or some similar type document but, upon information and belief, did not.
161. BOA is required to utilize “Know Their Customers” type protocols as well as conduct
risk assessments of their client’s database using tools like RISK ID, Efund, and/or “OFAC checks,”
etc. and, upon information and belief, BOA failed to do so with the two fake Murdaugh “Forge”
accounts described herein.
162. BOA is required to have in place “Anti-Money Laundering” policies and
procedures in order to assist in complying with such laws as USA Patriot Act or Uniting and
Strengthening America by Providing Appropriate Tools to Restrict, Intercept and Obstruct
Terrorism Act of 2001 and, upon information and belief, did not do so for the two fake Murdaugh
“Forge” accounts described herein.
163. BOA is required to have in place policies and procedures to comply with the Bank
Secrecy Act in order to assist in investigation criminal activities such as tax evasion and money
launderings, and, upon information and belief, did not do so for the two fake Murdaugh “Forge”
accounts described herein.
24
164. Upon information and belief, BOA did not conduct annual independent testing on
the two fake Murdaugh “Forge” accounts described herein or have their Board approved Ban Secrecy
Officer inspect or monitor these accounts.
165. Upon information and belief, BOA knew that Alex Murdaugh was a lawyer.
166. Upon information and belief, BOA knew that the Forge deposits represented money
that Alex Murdaugh received in his capacity as a fiduciary and/or if BOA failed to know this, it failed
only through its willful blindness and reckless disregard.
167. Upon information and belief, BOA knew that Murdaugh’s transfers of the Satterfield
deposits were made in breach of his fiduciary duties, and/or if BOA failed to know this, it failed only
through its willful blindness and reckless disregard.
168. Through its failures to follow its own policies and procedures, banking laws and
regulations and/or customary banking practices including endorsement and deposit procedures,
BOA aided and abetting Murdaugh in breaching his fiduciary duties to the Plaintiffs.
169. Plaintiffs are entitled to and pray for judgment against BOA, both actual, in a sum
not less than $4,305,000.00, and punitive, in an amount deemed sufficient to impress upon BOA
the seriousness of their conduct and to deter such similar conduct in the future.
FOR A FOURTH CAUSE OF ACTION AS TO BOA

AIDING AND ABETTING FRAUD
full herein.
171. As is described in detail above, Murdaugh engaged in fraudulent behavior by
obtaining money through false pretenses and then by using his fake BOA Forge accounts to launder
his ill-gotten gain.
172. BOA had actual knowledge of Murdaugh’s fraudulent behavior, if BOA failed to
know, it failed only as a result of its willful blindness or reckless disregard.

25
173. BOA provided substantial assistance in the conduct of Murdaugh’s fraud by
providing for Murdaugh the vehicle through which he was able to launder millions and millions
of dollars, including millions of dollars of the Satterfields’ money.
174. Plaintiffs are entitled to and pray for judgment against BOA, both actual, in a sum
sufficient not less than $4,305,000.00, and punitive, in an amount deemed sufficient to impress
upon BOA the seriousness of their conduct and to deter such similar conduct in the future.
FOR A FIFTH CAUSE OF ACTION AS TO BOA

NEGLIGENCE / GROSS NEGLIGENCE
full herein.
176. At all times relevant hereto, BOA owed a duty of reasonable care in the operation
of its business, including specifically a duty of reasonable care hire, train and supervise its
employees in order to ensure its employees complied with all applicable laws, rules, regulations,
policies and customary banking practices.
177. BOA did not properly supervise its employees, which resulted in the establishment
of the two fake Murdaugh “Forge” accounts described herein, as well as in the use of the accounts to
launder millions of dollars from the Plaintiffs.
178. BOA breached its duty of care and otherwise acted in a negligent, grossly negligent,
willful, wanton and reckless manner in a number of particulars, including but not limited to some
or all of the following:
a. Failing to adopt and / or enforce adequate policies and procedures regarding its
accounts such as a CIP, AML/BSA, DBA protocols, Know Their Customers, and
Anti-Money Laundering;
b. Failing to adequately and properly hire, train and supervise its employees to
perform their duties;
c. Permitting the establishment of the two fake “Forge” accounts;
26
d. Accepting a fake TIN in order to establish one of the fake “Forge” accounts;
e. Failing to require Murdaugh to present a business license;
f. Failing to require Murdaugh to present a fictitious name certificate;
g. Permitting the checks described herein to be deposited in the fake “Forge”

accounts;
h. Permitting checks made payable to “Forge Consultants, LLC” with a Lady Street
address in Columbia, South Carolina to be deposited into the fake “Forge” accounts
(See check attached hereto as Exhibit V and incorporated by reference.);
i. Permitting check #1725 dated 3/15/21 endorsed by “Maggie B. Murdaugh” to be

deposited in BOA. (See check #1725 attached hereto as Exhibit W and
incorporated by reference.);
j. Failing to identify fraudulent account activity, including the issuance of numerous

cashier’s checks and/or other checks for amounts just under $10,000.00;
k. Failing to identify suspicious account activity, including the issuance of numerous

cashier’s checks and/or other checks to C.E. Smith mostly for amounts just under
$10,000.00 as summarized in Exhibit X; and
l. Other particulars as the evidence in the case may demonstrate.
179. Accompanying these breaches were other extraordinary circumstances, including
but not limited to:
a. The existence of suspicious identification documents used to open the fake Forge
accounts such as a fake TIN that was created with the assistance of a BOA
employee;
b. BOA’s lack of any knowledge regarding the business of Forge;
c. BOA’s knowledge of a legitimate company known as Forge Consulting, LLC;
d. BOA accepting for deposit into the fake Forge accounts at least 17 checks totaling
$2,726,449.82 which were made out to Forge or Forge Consulting, LLC with the
address 1122 Lady Street, Ste 705, Columbia, SC, which is the correct address for
27
Forge Consulting, LLC (and not the address provided for the establishment of the
fake Forge accounts);
e. A large volume of cashier’s checks issued on the accounts;
f. A large volume of inter-account transfers; and
g. 254 checks issued to a single individual totaling more than $1.8 Million.
180. The two fake Murdaugh “Forge” accounts authorized by BOA were run amok without
adequate control or supervision, as a result of which BOA permitted the money that was intended for
Tony and Brian from their mother’s death to be stolen.
181. But for the conduct of BOA as described herein, the Plaintiffs would have received
the settlement funds following the death of their mother.
182. As a direct and proximate result of the conduct of BOA as described herein, the
Plaintiffs have suffered significant economic harm.
183. The Plaintiffs are entitled to and pray for separate awards of damages against BOA,
both actual, in a sum sufficient to compensate the Plaintiffs for their damages but not less than
$4,305,000.00, as well as punitive damages in an amount sufficient to impress upon BOA the
seriousness of its conduct and to deter such similar conduct in the future.
FOR A SIXTH CAUSE OF ACTION AS TO BOA

SCUTPA
full herein.
185. As set forth herein above, BOA engaged in unfair or deceptive acts in the course of
commerce in the State of South Carolina.
186. The acts of BOA are capable of repetition and have in fact been repeated, certainly
as to the Plaintiffs herein, and upon information and belief, the same acts have been committed to
other Murdaugh victims through the use of his fake BOA Forge accounts.
28
187. The conduct of BOA impacts the public interest in that the integrity of the banking
system is central and integral to consumer confidence and to the health of the United States
economy itself.
188. The Plaintiffs are entitled to damages against BOA in a sum sufficient to
compensate the Plaintiffs for their damages, but not less than $4,305,000.00.
189. Because the conduct of BOA in this case is willful, the Plaintiffs are entitled to
treble damages, as well as an award of attorneys’ fees.
FOR A SEVENTH CAUSE OF ACTION AS TO BOA

Caldwell v. K-Mart NEGLIGENCE PER-SE
full herein.
191. BOA’s internal policies and procedures are designed and implemented to protect
itself and its customers from fraud.
192. In addition, Plaintiffs are intended third party beneficiaries of BOA’s internal
policies and procedures and self-imposed rules.
193. As is described in greater detail above, BOA repeatedly violated their own internal
policies and procedures in dealing with Murdaugh’s BOA accounts (the two fake FORGE accounts
as well as his personal BOA account) including, but not limited to, the following:
a. Failing to require proper account opening documents for the Murdaugh accounts;
b. Allowing numerous cashiers checks to issue from Murduagh’s fake Forge account;
c. Allowing withdrawals to evade currency transaction reporting requirements;
d. Allowing fraudulent deposits;
e. Accepting checks made out to different payees;
f. Improper transfers from business accounts to an individual account;
29
g. Accepting improper endorsements; and,
h. Other such actions as discovery may demonstrate.
194. BOA’s actions regarding Murdaugh’s BOA accounts were not reasonable.
195. BOA’s failure to abide by their own internal policies demonstrate its failure to
exercise reasonable care concerning the Murdaugh accounts and since BOA actions were not
reasonable BOA has committed negligence per se.
196. Absent BOA’s negligence per se Murdaugh would not have been able to
economically harm the Plaintiffs.
197. BOA breached its duties to the Plaintiffs as intended third party beneficiaries of
BOA’s internal policies and procedures.
198. The Plaintiffs are entitled to and pray for separate awards of damages against BOA,
both actual, in a sum sufficient to compensate the Plaintiffs for their damages but not less than
$4,305,000.00, as well as punitive damages in an amount sufficient to impress upon BOA the
seriousness of its conduct in failing to bide by their own internal policies and self-imposed rules
and to deter such similar conduct in the future.
FOR AN EIGHTH CAUSE OF ACTION AS TO MURDAUGH

LEGAL MALPRACTICE / BREACH OF FIDUCIARY DUTY
full herein.
200. At all times relevant hereto, Murdaugh and Plaintiffs were in an attorney-client
relationship by virtue of which the Murdaugh and PMPED owed duties to the Estate and duties to
Tony and Brian as the sole heirs and beneficiaries of the Estate.
201. The duties owed by Murdaugh to the Plaintiffs include, but are not limited to, the
duty to possess and to exercise the same degree of care, skill and learning as would be expected of
30
a reasonable and competent attorney under the same or similar circumstances and to act in a
diligent manner when representing a client and the duty to act at all times as a fiduciary to the
Plaintiffs and to pursue their interests as a fiduciary and to protect their property as a fiduciary.
202. Murdaugh breached their duties to Plaintiffs and otherwise acted in a negligent,
grossly negligent, willful, wanton and reckless manner in a number of particulars, including but
not limited to the following:
a. In violating the South Carolina Rules of Professional Conduct including, but not
limited to, Rule 1.7, Rule 8.3, and Rule 8.4;
b. In undertaking to represent the Plaintiffs despite an irreconcilable conflict of

interest that would have made such representation improper and impermissible;
c. In failing to have a written fee agreement for a contingency matter in violation of

Rule 1.5 of the South Carolina Rules of Professional Conduct;
d. In failing to provide competent representation;
e. In failing to keep the Plaintiffs reasonably informed about the status of their legal
matters;
f. In excluding the Plaintiffs from settlement discussions regarding their claims;
g. In settling the Plaintiffs’ claims without the knowledge or consent;
h. In failing to adequately monitor the actions of Westendorf, Palmetto, Fleming, and

MKF;
i. In failing to protect clients’ property;
j. In misappropriating clients’ property; and
k. In such other particulars as the evidence in the case may demonstrate.
203. As a direct and proximate result of the conduct of Murdaugh, Plaintiffs’ have been
denied the monies rightfully owed to them as a result of the death of their mother, Gloria. The
Plaintiffs are entitled to damages, both actual, in an amount determined by a jury to be sufficient
to compensate them fully for the harm they suffered but not less than $4,305,000.00, and punitive
31
in an amount to impress upon Murdaugh the seriousness of his conduct and to deter such similar
conduct in the future.
WHEREFORE, the Plaintiffs pray for an award of damages against the Defendants
herein, for actual damages, in a sum sufficient to compensate them for their losses herein, as well
as an award of special damages, pre-judgment interest, and a disgorgement of the attorneys’ fees
and costs paid in relation to the claims made by the Estate of Gloria Satterfield, an award of
punitive damages in an amount necessary to impress upon the Defendants the seriousness of their
conduct and to deter such similar conduct in the future, as well as an award of treble damages and
attorneys’ fees against BOA, together with such further relief as the court deems just and proper.
Charleston, South Carolina BLAND RICHTER, LLP

December 6, 2021 Attorneys for Plaintiffs
s/Ronald L. Richter, Jr.
Ronald L. Richter, Jr. (SC Bar No. 66377)
s/Scott M. Mongillo
Scott M. Mongillo (SC Bar No. 16574)
Peoples Building
18 Broad Street, Mezzanine
Charleston, South Carolina 29401
Telephone 843.573.9900
ronnie@blandrichter.com
scott@blandrichter.com
s/Eric S. Bland
Eric S. Bland (SC Bar No. 64132)
1500 Calhoun Street
Post Office Box 72
Columbia, South Carolina 29202
Telephone803.256.9664
ericbland@blandrichter.com
32
Exhibit
A

STATE OF SOUTH CAROLINA, )
) POW ER OF ATTORNEY
COUNTY OF HAMPTON )
KNOW ALL MEN BY THESE PRESENTS, that I, BRIAN HARRIOTT, a
citizen of Hampton County, South Carolina do hereby constitute and appoint R.
ALEXANDER MURDAUGH my true and lawful attorney for me and in my name,
place and stead:
To lease, let, take possession, bargain, sell, assign, convey, pledge, mortgage
and encumber, repair, insure and generally manage, any and all property, both real
and personal, which I own, or may hereafter acquire from any source; to sign,
execute and deliver any and all legal documents in connection therewith, and in all
ways and in every way to deal with all property real and personal which I may at
any time hereafter own, and with all rights or interest at any time owned or
possessed by me with respect to any such property, and with all or any part of such
property rights and interest in any and all lawful ways in which I could myself deal
with such property, rights and interest, and each part thereof. To convey, waive,
release and relinquish all and every dower rights, all and every h01nestcad estates,
and all and every rights under and by virtue of the homestead exemption laws. To
deposit any monies received from any source whatever for me, and in my name with
any bank, and to draw and deliver checks in my name against said monies and other
monies to be deposited in my name or to my credit; to endorse, discount, sell, assign,
negotiate and extend upon such terms as my attorney may deem be,st, aGlpl:lchecks,
l'nge l of 5 Pages
Po1ver of Attorney
& - .-· f l/;~' .
Brinn Harriot/ -
PMPED HARMON-000020
drafts, notes, bills of exchange, trade and bankers' acceptances, and other
negotiable or nonnegotiable papers, payable to me or to my order; and to accept
and pay any note, draft, check, trade acceptances or bills of exchange drawn upon
me in relation to said matters; to sell, transfer, and assign all and any stock, or
certificates thereof, standing in my name, and to collect all dividends, coupons and
interest on any stock, bonds, or other securities now or hereafter owned by me; to
ask, demand, sue for, recover, collect, settle, compound, compromise and adjust, by
payment or otherwise, any and all debts, claims or demands due or to become due to
me or against me, and to make, give and execute full release, acquittance or other
discharge for the same, whether under seal or otherwise; to execute vouchers in my
behalf for any and all allowances and reimbursements properly payable to me by
the United States; to take possession and order the removal and shipment of any
property from any post, warehouse, depot, dock or other place of storage or
safekeeping, government or private; to execute any forms which may be necessary
to effect any allotment of or deduction from any pay and allowances; to execute any
form which I may be required to execute in connection with obtaining dependence
allowances under any authority statutory or otherwise; to do all things necessary
concerning any insurance policies, including the right to change bene.f iciary.
I do hereby give full power to perform all and every act and thing whatsoever
including but not limited to decisions regarding my health and hefalt;,,car

i o ~~,9?
c,./ f ·site
Page 2 of 5 Pages
Power of Attorney /~~
_ ~ t Jf/ / /
13()
CJA0~ G n,,,,, """'"'
PMPED HARMON-000021
and necessary to be done in and about my affairs as full to all intents and purposes
as I might or could do if personally present at the doing thereof, with full power of
substitution or revocation, hereby ratifying and confirming all that my said attorney
substitute shall lawfully do or cause to be done by virtue hereof. However, nothing
herein shall be construed to allow my attorney in fact or any other person from
entering into any agreement that can affect my right to a jury trial.
I HEREBY DECLARE, that any act or thing lawfully done hereunder by my
said attorney, shall be binding on myself and my heirs, assigns, legal and personal
representatives. I hereby ratify all that my attorney may do in the premise by virtue
of this Power of Attorney, which shall remain in full force and effect until written
notice of its revocation, signed by me, shall have been received by the grantee
herein.
No person who may act in reliance upon the representations of my Attorney-
in-Fact for the scope of authority granted to the Attorney-in Fact shall incur any
liability as to me or my estate as a result of permitting the Attorney-in-Fact to
exercise this authority, nor is any such person who deals with my Attorney-in-Fact
responsible to determine or ensure the proper application of funds or property.
IT IS MY FURTHER INTENTION, that this Power of Attorney shall not be
affected by physical disability or mental incompetence of the principal, which
renders the principal incapable of managing@her) own estate.
Pnge 3 of5 Pnge.v

Power ofAttomey
Bria111/arriot/ fl -
PMPED HARMON-000022
IT IS MY FURTHER INTENTION, that all express words and terms, used
herein granting powers and rights, be construed in their broadest sense to include
all synonymous terms and implied powers thereunder.
My attorney in fact/power of attorney does not have the right, power, or
authority to enter into any agreement, contract or any other document that
removes, restricts or effects my right to a jury trial for any matter.
I, (Principal's Name), the principal, sign my name to this instrument this
~ day of[ : c.::: :---- , 2018, and being first duly sworn, do hereby declare to the
undersigned authority that I sign and execute this instrument as my Power of
Attorney and that I sign it willingly, that I execute it as my free and voluntary act
for the purposes therein expressed, and I am eighteen years of age or older, of sound
mind, and under no constraint or undue influence.
~
,: ?
BRIAN HARRIOTT
--
-
;
/
·w./
,,
/<14c-?. -~~
I
,//
., , ..
We, and 7)f.J V\)) \,\) ,_(:t;\);t0/;~the witnesses,

sign our names o this the undersigned authority that t he Principal signs and
executes this instrument as and for (his/her) Power of Attorney and that (he/she)
signs it willingly, and that each of us, in the presence and hearing of the Principal
and in the presence and hearing of each other, hereby signs this Power of Attorney
as witness to the Principal's signing, and that to the best of our knowledge the
Principal is eighteen years of age or older, of sound mind, and under no constraint
or undue influence.
C~{J(_ ~ Address_,...._.~--t------"-~~Lfc
'_c9,.q~tj 21/:.,.....__
1
,._ / _,__ --'----,....,,,,
I; ~_ :..,... /!d""""L~l_J.,,_c\~ /- - --'C.: . .i, "'--~ID~f-~ ...:.,---:~=-·----==
- -Add ress~-fJ~l()"rM. ? _Cf.;__
, l_/1/·_· --+--
f /
Page 4 of 5 Pages
Power of Aftomey
Bria11 Harrioll
PMPED HARMON-000023
State of South Carolina )
County of HAMPTON )
PERSONALLY appeared before me the undersigned witness and made oath
that (s)he saw the within named, Principal, sign, seal and as (his/her) act and deed,
deliver the within written Power of Attorney, and (s)he with
witnessed the execution thereof.
~ 0.' 0/lcJ?ffeV
SWORN to before me this
?\ day of __,(~ _-\_- _. , 2018.
Page 5 of 5 Pages
Power of Atto1'11ey
Brian 1-larrintt
-a
. CJJf
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1ye,'/1.,.,..
.
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PMPED HARMON-000024
Exhibit
B

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l-rorn : lo,^tl sq$c? f',e\ J
- Gs\ s \^vr','.\ $rov* VqnJttL'\Ir no! suY€

lf f- trreJ \r i; or",yh*l with i r r u'\af rl
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my lhone i s &3-?qZ'-)Lo\..l ;+ )ot hcnv e om y
clues |lcl e { -fh*^ V-s

Exhibit
C
STATE OF SOUTH CAROLINA IN THE PROBATE COURT
COUNTY OF: HAMPTON

CERTIFICATE OF APPOINTMENT
IN THE MATTER OF:
GLORIA ANN SATTERFIELD CASE NUMBER: 201 8ES250056
(Decedent)
This is to certify that
MICHAEL ANTHONY SATTERFIELD,
is the duly qualified
PERSONAL REPRESENTATIVE
SUCCESSOR PERSONAL REPRESENTATIVE
SPECIAL ADMINISTRATOR
in the above matter and that this appointment, having been executed on the 28th day of March, 2018, is
in fullforce and effect.
RESTRICTIONS
NONE
Executed this 28th day of March, 2018.
SHEI B. ODO Probate Court Judge
Do not accept a copy of this certificate without

the raised seal of the Probate Court.
FORM #141ES (112014l,

62-1 -305, 62-3-1 03
Exhibit
D
Exhibit
E
(Page 1 of 1)
MW~
MOSS,ltUHN«'~ JA
~ .....
ft.llm)lW8llfj'J&
tawrt~
Mardl:B~JGll
Mt.ltfcbataA. M ~
4141 Moselle Raad ·
~SCl9929
~=~~~ ..~ ·
P~l,Jct;~\.,.f~b,~·(Jf(l~:J~ld~W.e•~•
,a wreilpll ·a.th claim ,on beWJ· e£ the. estate. Please forward :Ns; eo~m.m to the
~fio, ;._..C!f_n-·.n~- Ac;...~ .,.,.t,,..,i ..t..... ~'"-• Aiwif'D'-
,~J'"P~r~,~~~'~·L'~~;~.. '~Kl,:.atUijU 'Ulfl:\iWBfrl '"'f'""J~,,..~,, -,J1r4·1i~
mv Qi!a.,.,.. :mniliii,lill-efv·
~~~~. · ,I;':.,.
With~ r.eprds, t s
V:f#t~I'~
M&G000203
Exhibit
F
Exhibit
G
STATE OF SOUTH CAROLINA IN ROBATE COURT
COUNTY OF
RENUNCIATION OF RIGHT TO ADMINISTRATION
AND/OR NOMINATION AND/OR WAIVER OF BOND
IN THE MATTER OF:
CASE NUMBER:
(Decedent)
By renouncing my rfght to seNe as Personal Representative, I am informing the Court that I do not want to be the Personal
Representative to administe· the estate. I am not giving up any interest in the estate or inheritance rights by signing
this document.
The undersigned hereby (check all that apply):
D renounces his/her right to seNe as Personal Representative of the above-captioned estate.
59 renounces his/her right to seNe as Personal Representative of the above-captioned estate so long as the
following nominee seNes as Personal Representative:
Name: C ~ \.Se.~ftl,\. Jo.rf - £..,ee.~~svr Pfi.

Address:
D agrees to waive bond for the person(s) nominated above.
I understand this is effectfve only to the extent the law allows for nomination and waiver of bond.
Executed this
SWORN to .b,efore me this __3_L day of

3l
day of lt\., 2015~-
Signature: G)
'- .#~
--->,,,...-,C'-------"-=--"-"'-'-----,F--1---------
{!k.!, 20_/_c; Print Name: - - - - - - - - - - - 1 1 ' - - - - - - - - - -
A ddress:
--------------------
Telephone (Work): _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
(Home): -------------------
(Cell): _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Email: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Relationship to Decedent/Estate: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
FORM #302ES (1/2014)

62-3-203, 62-3-603
Exhibit
H
STATE OF SOUTH CAROLINA ) INT.PROBATE COURT
)
COUNTY OF. )
) RENUNCIATION OF RIGHT TO ADMINISTRATION
) AND/OR NOMINATION AND/OR WAIVER OF BOND
IN THE MATTER OF: i- )
) CASE NUMBER:
(Decedent) )
By renouncing my right to serve as Personal Representative, I am informing the Court that I do not want to be the Personal
Representative to administer the estate. I am not giving up any interest in the estate or inheritance rights by signing
this document.
The undersigned hereby (check all that apply):
D renounces his/her right to serve as Personal Representative of the above-captioned estate.
~ renounces his/her right to serve as Personal Representative of the above-captioned estate so long as the
following nominee serves as Personal Representative:
Name: C~J we~~ f) r ~ ' r.., C c.e S.J"vr LP ~.

Address:
D agrees to waive bond for the person(s) nominated above.
I understand this is effective only to the extent the law allows for nomination and waiver of bond.
Executed this J(.p day of /\hi .. 20 1f5 .
SWORN to before me this _1__b_ day of Signature:~Qb~ ~~

Print Name: Toi~fu:e\ ~£-.\3:e \cl
Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
~.o~-~~Q
o t ~ s O c ~ j-Z...02.-"3
My commission expires: Telephone (Work): _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
(Home): _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
(Cell): _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Email:
--------------------
Re Iations hip to Decedent/Estate: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
FORM #302ES (1/2014)

62-3-203, 62-3-603
Exhibit
I
Exhibit
J
ELECTRONICALLY FILED - 2018 Dec 19 2:58 PM - HAMPTON - COMMON PLEAS - CASE#2018CP2500505
Exhibit
K
STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
COUNTY OF HAMPTON Civil Action No. 2018-CP-25-00
Chad Westendorf, as Personal

Representative of the Estate of Gloria
Satterfield,
PETITIONER(S), Order Approving Wrongful Death and

Survival Settlement
v.
Richard A. Murdaugh,
RESPONDENT(S).
This matter came before the Court for hearing on December 19, 2018, pursuant to
S.C. Code Ann. §§ 15-51-41, 15-51-42, and 62-3-715(24), and upon the Verified Petition for
Wrongful Death and Survival Settlement of Chad Westendorf, as Personal Representative of
the Estate of Gloria Satterfield. Present at the hearing was Chad Westendorf, as Personal
Representative of the Estate of Gloria Satterfield, and Cory H. Fleming, counsel for the
Petitioner. Testimony was provided by Chad Westendorf.
After due consideration and inquiry into the circumstances surrounding the proposed
settlement of these claims, I make the following findings of fact:
1. The Petitioner, Chad Westendorf, has been duly appointed as the Personal
Representative of the Estate of Gloria Satterfield by the Probate Court for Hampton
County, South Carolina.
2. The Petitioner is duly authorized to seek approval of this matter.
3. This compromise settlement, concerning this insurance policy only, between
the Petitioner and the Respondent, Richard A. Murdaugh, as recited in the Petition, has been
-1-
CHF_00404
reached.
4. All interested parties to this action or their representatives were duly notified
and have been duly informed of the matters set forth in the Petition.
5. The Petitioner testified and affirmed all matters contained in the Petition.
6. There exists between the Petitioner and the Respondent a legitimate contest
and controversy, and this agreement for compromise is just, reasonable, and adequate under
all of the circumstances of this case, and is in the best interests of those persons represented
by the Personal Representative of the Estate.
7. I find this settlement to have been reached in good faith.
8. The Petitioner has asked that I hear testimony and review evidence and
allocate the proceeds between the wrongful death action and the survival action.
9. The Court heard in-person testimony from Chad Westendorf, as to the losses
sustained by the decedent, her heirs, beneficiaries, and estate.
10. It is undisputed that the Decedent’s sons: Brian Harriott and Michael Anthony
Satterfield are the sole beneficiaries of the survival action.
11. Based upon the testimony heard and evidence reviewed, I am of the opinion
and so find, that the settlement set forth in the Petition should be approved and confirmed
as provided in S.C. Code Ann. §§ 15-51-41, 15-51-42, and 62-3-715(24).
12. After a careful review of the testimony and evidence, I find that the settlement
should be allocated as $475,000.00 for Wrongful Death and $25,000.00 for Survival and
$5,000.00 for med pay.
The Petitioner stated, and I so find, that he understood all matters raised at the
hearing and had no questions or concerns about any matter.

-2-
CHF_00405
IT IS THEREFORE ORDERED:
A. That the said compromise as recited in the Petition be and hereby is approved
as a fair, just, and reasonable settlement of the contest and controversy existing as to this
insurance policy only between the Estate of Gloria Satterfield and the Respondent.
B. That the Petitioner, Chad Westendorf as Personal Representative of the Estate
of Gloria Satterfield is hereby directed, empowered, and authorized to execute such
documents as may be required to fully effectuate the compromise or settlement agreement
approved by this Court arising out of the events of February 26, 2018, which gave rise to this
claim.
C. The settlement is allocated as $475,000.00 for Wrongful Death and $25,000.00
for Survival and $5,000.00 for med pay.
D. The net settlement proceeds are to be distributed by the Petitioner Chad
Westendorf as Personal Representative of the Estate of Gloria Satterfield, in connection
with the wrongful death and survival actions as provided for under the governing law.
E. The Petitioner, Chad Westendorf, as Personal Representative of the Estate of
Gloria Satterfield, shall notify the Probate Court of the settlement of this portion of the
survival action against the Respondents within ten (10) days of the filing of this Order.
Judge Carmen T. Mullen

Presiding Fourteenth Circuit Court Judge
Hampton, South Carolina

___________ ____, 2018
-3-
CHF_00406
Exhibit
L
Cory Fleming
From: Cory Fleming

Sent: Tuesday, January 15, 2019 2:00 PM
To: Chad Westendorf
Subject: RE: Satterfield
Attachments: satterfield petition for approval wd settlement.pdf; signed disbursement sheet.pdf
Here it is.
Thank you,
Cory Fleming
Moss, Kuhn & Fleming, PA
PO Box 507
Beaufort, SC 29901
(843) 524-3373
Confidentiality Note:
This message is intended exclusively for the individual or which it is addressed. This communication may contain
information that is proprietary , privileged, confidential or otherwise legally exempt from disclosure. If you are not the
named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If
you have received this message in error, please notify the sender immediately either by phone (843) 524-3373 or reply
to this e-mail and delete all copies of this message.
From: Chad Westendorf [mailto:cwestendorf@palmettostatebank.com]

Sent: Monday, January 14, 2019 10:07 AM
To: Cory Fleming
Subject: Satterfield
Good Morning, Cory
Hope all is well.
Could you please send me a copy of the document that we signed with the judge the other day just want to keep a copy.
I know you had to file it so whenever you get a chance.
Thanks and talk with you soon,
Chad
Chad F. Westendorf
Vice President
Palmetto State Bank
601 First Street W.
Hampton, SC 29924
(803) 943-7695 Direct
(803) 943-2671 Work
1
CHF_00288
Exhibit
M
Exhibit
N
Dale: 9/22/2015 Time: ,t: 10:58. Pt1I (US Centcal Ticne) Scanned From I": I 0.46.36.9
BankofAmerica ~
Sole Proprietorship Authorization -·Opening and
llANK OF AMERJC.~. NA. (THE "BANK") Maintaining Deposit Accounts and Servict,>s
Account Number, 2230ll959739i

------------------
Name of Sok Propnetorsh1p R!CllARD A MURDAUGH SOLE PROP
DBA FORGE
I. the undersigned, hereby certify to _B_A_N_K_O_l_'_A_~_1E_:R_._'C_A_,_N_'_A_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
that DBAPORGE
havmg 1ts pnnc1pal place of busmcss m the St;_,te of ~ (the ..Propnetors.1-up") is the name and styie: under
which I conduct an unmcorporatcd bu;;mess a~ a sok proprietoi: and ffos.t no other person, fim1 or c-0rpor.auon has any right, title ~x mterest m ~1d Propnetorship.
Further, l hereby destgnate ..!'!.'.::!:'.~-~!F AMERICA, N A (the "Bank")
as a depo..,awry of said Propnetorsh1p and hereby dccfo.re that deposn accounts and!or time: dcpos:ts (CDs} be opened and rnamtamed m the name of th1&
Prnpnetorshtp with Bank m accordance wnh the renns of the Bank's. Depo:.it Agreemenl .and D1sdosure;; and the applicable rules and regulauons for :;ut:h act.:ounts
Furthermore. I Hereby Certify, Agree And Direct As 1''ollows:

I. That any one oftlic follo.,1ng aulhonzcd rcpr<sentauves oftlus l'ropnetorsh,p
'Rrcha.rrl
Name Name
Name
1. . . . . . . . . . . . . . . . . . . . . . .-.. . _ Name
is hereby authorized, on behalf of this Proprietors.hip and m Wi name, to execute an<l sign any apphcatmn, deposit agreement. ::agnaturc: card and any other
docurnental:on required by Bank to open :.atd accounts; to sign check5, drafl.s, notes, biUs of exchange. actept.ances, tune deposits {CDs) or ether orders for payment
of money; to endorse check5. draft.:::, notes. biHs. hme deposits (CDs) or othe-r mstruments- O\Vned or held by this Propnetorship for deposit w1th Bank or for
colle,tion or discount by Bank, to alccept, drafts, acceptances. and other msu1:rnents payable at Bank. to place order:,. wtth Rank for !he purchase and sale of foreign
currencies on behalf of this Proprietorsh1p; to execute and deliver an electronic fund transfer agreement and to make transfers or withdrawals by electronic trans.fer
on behalf of the Propnetorship; to obtain an acces.5 device (mduding but not limsted to a card, code, er other means of acces:, to the Propnetnrsh1p':; accnunts) that
may he U!-.ed fo1 the purpose ofimtmtmg elc:ctromc fund mmr.fers [Propnetorsh1p agrees and acknowledges that nc1ther the Electromc Funds Transfer Act (l 5 U S.C
1693 et seq) nor Regulation E. (12 C.F R Part 205) are apphcable to any such access device]; to establish and mamtam a mght deposit r,lauonship; to execute and
ddrver a wire transfer ngreement and to request, or to appoint und delegate from nme to time such persons who may request, Wifes of funds~ w ente-.r mto any
agreemenL:; wHh the Bank for the provision by Bank of various Treasury Management services to this Propnetorship as such Aurhonzed Rc:prescntattve may
determine, m h1s or her sole d1scretwn, and lo sign any and all documents and take alI actions required by Bank relative to .mch Treasury Management serv.;.ces or
the perfomiance of the Prnpnelorsh1p's. obhgations thereunder, and tha( any such Trea'iury Management agreement(s} shall remam m fuU force and effect until
wntlen nouce to tennmat(' g1veri m al:cordance wtth the terms of any such agreement shaH have b:c:en received by Bank and that such termrnalion shaH not affect any
anwn taken by the Bank prior to such tenninatwn; to rent or lease a safe depoMt box from Bank, to e.xet:ute the rental agrei:-mcnt or lease, to take whatever other
.iCtwns or enter mm whatever other agreements relating to the accounts or mvestment cf funds in such accounts with Bank and to execute, amend . .supplement and
debver to Bank such agreements on behalf of the Propnemrsh1p upon such terms and condiucns as such Authonzed Representative may deetn. appropnate and to
appoint and delegate. from tim~ to t1me, such person(s) who may be authorized to enter mto sud1 agyeements and take any other actmns _pursuant m such agreements
m conne:ctwn with said accounts that the Authonzed Repre-sentao.ve deems ne~cessary, and to waive pres.e-nlment, demand, prote5t, and notice of protest or d.ishonor
of any chi:ck, note, b1.Jl. draft, or other mstrument made, drawn or endorsed by th1s Propnemrship; and
2. That the Bank be and is hereby authonze-d to honor, receive. certify, pay or exchange for 1noney orders or other mstruments alJ mstmments signed m .11.:cord.ance
with the foregoing tn:-.tructions ,:·:vet1 though such payment may create an overdra.il or even though such instruments may be drawn or endorsed to the order of any
Authonzed Representative signing lhe same or tendered by such Authorized Representauve or :1 tlnrd party for exchange or rash1ng, or in payrr:r.nt of the mdivtdual
ohbg,:tion of :-.uch Authon,.ed Repre5.entafrve, or for deposit to such Authonzed Rcprcsemattvc's personal account and Bank shall not he ri:quired or be undi:r any
ohl1gat1on to mqmrc: as to the circc.mstances of the 1ssuant:e or l!SC of any instrument signed ln aci.:ordancc mth the foregomg m.structlotlt. or the appltcahon or dlspos1hon
of such instrument or the proceeds thereof; and. further, that the: Bank 1s authonzed to honor any instructions regardm_g withdrawals, orders for payment or transfer of
funds whether oral. by telephone or electronic means if such w1thdrawal~ orders or transief are: in mated by an Authonzed Representative; and
J. That the: Bank be 3.fld is hereby requested. authnrized and directed to hcnor and to treat as authoriz,e.d, checks. drafts or other orders for the payment of money
<lmwn or purportedly dra\Vn m this Propnctorsh1p's name. mcludmg those payable to the mdividual order of any person whose name appears thereon as signer
thereof, when bcarmg or purporting to bear the facsim1le signature: of an Authonzed Representat1ve authonzed m the foregoing mstructJons and the Bank sha1l be
entitled to honor, to treat as authon1..cd. and to charge th1:"< Proprietorship for such check.'i, drafts, or other orders regardless of by whom or by what means the actual
or purported facs1mile sigm.ture thereon may h::.ve been affixed thereto, 1f such mgnature resembles the facsimile specimen duly certified to or filed with the Bank by
any Authorized Representative or if such facst:mle signature resembles any facsimile signature previously affixed to any check. drafr. or other 0rder drawn m the
Propnelorshtp's name, which check, draft, or other order was accepted and paid without tnnely obje.ction hy the Propnetor:slup, therrby ratifymg the use of such
facsirmle signature. and the Propne-torship hereby mde-mnilies and holds the Bflnk hannkss agmnst ;my and aH loss, cost, damage or expense suffered or .1nnmed by
the Bank .a.rtsw.g out of or in any wny rd•Hed to the misuse or unlawful or ur1u-uth0Mzed use by a person of such facs1m1Je .signature, and
NSC
2Db~ ~ .
00-14-9088M I l-2013 . 2-Z?:P tRSS 131/ 1111111111111111111111111 Pagel of 2
S?t~l~
CONFIDENTIAL BOA-20210928-0000001
Date: 9/22/2015 Time: 4: 1Q:58 Ptt1 (US Centrai T,me) Scanned f"corn IP: 1OA6.:36.9
A1:count Number. 223009597391
4. That endorsements. for deposit may be evidenced by the name of the .Prnpnetorslnp bemg written or stamped on the cho:ck or other instrument deposlted.
without designation of the party making the endorsement, and the Bank is au1honzed to supply any endorsement on auy instrument tendered for deposit or
coU,:-r;uon; and
5. That the undenagned shall czrt1fy to Bank the names and sign:ll"ures of persons aufaorized to act on behalf of th1s Propnetorsh1p under the foregomg
mstructrnns and m the event a t~hange occurs m the 1dentlty of the Authonzed Persnn{s), the undersigned shrill tmmedrnteJy report, furnish ,·md certify such changes
to the Bank and shall s.ubmJt to the Bank a new account signature card reflecting such change m order to make such change-• effective and the Bank 1hall be fully
protected m relying on such certrfk:a.tions and ~hall be mdernnifit"d and saved harmless from any claims) dcma...'1:d~, expenses.. losses> or damages resulting from. Hr
growing out of. hononng the stgnature of any Authorized Represemative so certified. or refusing to honor auy signature not so certified. and
6~ That 1f any other pen-on. firm or corporation acquire:< any right, title or mtercst m the Proprietorship or if my relationship thereto as sule O\vner be aiterf'..d m
any way, ,:~r tfsmd busmess shall become mcorporaleti, the undersigned shall nohfy the Bank prompHy; and
7. That the foregomg rnstmct10ns shaH remmn m full force and effect and the authority he-rem given to all of said persons shall remain irrevocable as fat as Bank
is concem~ untll three (3) busmess days after the B,;.mk is notified m wntmg of the re·vocation of such authonty and that receipt of such nouce shaU not affect any
actwn taken by Bank pnor thereto; and
8. That all transactions by the underSlgTI'"Al any Authonzed Represemattve:) or employee of this Propnetorship on its behalf and m its name- with Bank pnor to
de:hvery to Bank ofth1s Propnetorslnp Authonzation are) in aH res~Ct.'i, hereby ratrfied. confinned. approved and adopted; and
9. That m conslder.auor: of your acceptance of the accounts of said Propri,:torship under the foregomg name and style, 1 agree to prote,;t a..,d mdemrnfy Bank
against all loss or iiab1h:ty, mcludmg court cost~ and attorney fees, an.sing from or growing out of the acceptance by said H,mk for payment er credit of checks..
drnft~. notes, bins of exchange, acceptances 1 certificates of deposits or other orders and instruments dra"w11 tn the order of and i..>ndorsed m the name of said
Proprietorshlp; and
10. That the: undersigned has s:gne4 acknowledged and fil.:<l in the proper office of the state of the Propnetorsh1p's pnncipal pi.a.cc of busmcss ;my document(;1,)
wh1ch may be requ~red by the faws of said state to be so filed by a person domg bus.mess undt~r a fictHit.lus or assume:d name) if applicable
In \Vitness Whereof, I have hereto Stgned and subscribed my name this day of
(' l!L---
\-/- (Seal)
Sol• Proprietor
Rank Information
09/22/2015
Date
---------------------------------------.....................................
R,·mking Cent.er Name PLAZA
Asst_icrnte'.s Name Ashlee TI1ompson
Associate's Phone Numbe:r _&_0_3-_6_7_8-_4_2(_lO_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Page 2 of2
11111111111111 lllll III Ill
Exhibit
O
Date: 9/1/2013 rrne: 9:26:58 A01 (US Centrai Time) Scanned From iP:10.47.84.9
Bank of America ....

Business Resolution or Authorization for
Opening and Maintaining Bnnking
Relationship
Name of Business ..t._O_R_G_,_E_____________________________ .........................................
Account Nu tu her 223024167625·----------
State where Organized/Registered/Principal Place of Business _S_'(..c:·_ _ _ _ _ _ _ _ _ _ _ _ __
TIN _2·+-7J77,18:J ________________
Business TyJ>e:
(gJ Sole Proprietor D Coq,oration D Limited Liability Company
D Partnership D Unincorporntcd Association 0 Other
1. Resolved~ that (the "Hank.') 1s h~n:b) ;J(:s1g11<t1cd "'" <1 depo'>Hory of th¢ Bu,mc~s ,wd !ha! ckpos:t :.1c-counts ctndior tnne depostts (CDs) be opened
~in<l nMmtained. Bl the name of this Bu:i1w:\'t \\tlh lhr~ Btmh. rn accmd.mce \VJth the te1m, ofthc Bank's Dcpos:t Agreement and D1sdo.;;ures and lht
,ipphcah!e rule~ ,md n?gulat1on~ fbr such account~., th(H an; one- ot lht:' toHowrng authon.tt:d re-pres.entat1vcs. offfoers. -employees. partners. members.
rr1m1<1g_cr\, as applteable r·Authonn>:d Pe1son ')
N,1me RICHARD A MlJRl'}Al!GH T1tk/Sta1u, _(c..h_v_ncc..··r'----------------

···---··--··················-·---------
T1tk:/Status - - - - - - - - -
Title/Status _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Na:ne _ _ _ _ _ _ __ T1t!e/Statns .........................
i--. hcreb_:, au1honz,.,.".d. on hc:hdlt oftht-:. nu~mc~\ and in 1t, n~1rne. to cxc~uh:' and to sign any apphcanon, .:k~[H.,stt agreemcnt~rdated. signature card and
.:t!l) nthc-1 dntument<ttion n.'quircd hy thr: BJnk. rn open :.--.<!H.l ilccc•ums. to sign che-.:ks, d:afl~. iwk~. hills of t.'Xi..:hange . .acceptances, ume depoo:.1ts
(CD,;'" othe, ender, tor pa_11nent ol nH}fiC). to e11dor,,e d1<:cls,, drat!,, notes, bills, t1rne deposits (CDs) or other mstruments owned or hdd by this
ilu:-.me~'.'.l, tor dcpnsn w1th Bani-.. or for cn!kcoon m dt-.;c-punt bJ lt1~ Banl..., to a-cctpt draHs . .1cceptances. and other mstruments payaMc at the- Bank~ to
pl,tcc o!dcrs wtth the Bank. t01 the purch:1s.e cmd ~J.!c of foreign cwrcnc1cs on hchaH oi ttns Busmess, to execute and dd1v~r an elcctromc fund
ttansfrr.'.--i agn:::i;;m¢nt and to male tr<Hbk! ~ or \qJhd: ,l\\als b) ek~ctromc transfer on behalf ol the Bus mess. to obtam an access d-;;vti.;~ (including but
n0t !lmncJ to a cmd. code, rn other mc,1n,., nf ace¢:-,:-, to tht Busmess\; accounts, that may be ttsed tor the purpose of imtrntmg ek:ctronic fond
tr&n,ter, f l>u,rne>S agrees and ;id,nov, ledge, that ne,1hc1 the Elew0111c Funds Transkr Act { l 5 lJ S C 1693 et sq ) nor Regulation E ( 12 C F R Pa,1
205} are appl:cahh.~ to any such act.:c-.,:; device-], to t"!->Uhl1:-h ,md rnamtain a mght dl.!-posn re!at1rmsh1p. to exe(:ute and deliver a \.\.HC transrer agreen1.ent
and to I equest, or to app0int 01 ddegate frorn tune tu tunt, "m:h person:, ,vho may reque~t w1r(:s of tunds, io enter rnto any agrtcmenH \V!IJ1 th~ Ban~
tnr tht prov1swn Py the Hank ol v.inous ·1 rca . . ur) iv1cm,1gi;?ment -;crv1ces to thts 13.usmess as such Authonzed Person ma) d!i!l.errnme. m bis or her sok
!..11\crelwn. :iTtd to .\tgn an) dnd a{] dtK~un1.ent\ <ind tdke aH aclh.m;; n:ytun:d by B,mk relal!Ye tn such Treasury Management :;~rvtccs or the
p-..':1 lotllMfh::e of1he Basmcss·s ob!1gat10ns thtmunde1. .md that any such T1eas.ury Management ag.reemi::nt(s) shaB rein.am m full fbrcc and effect
uultl \\lllten not1ce to tammatt:" grven m <1.c1;01dan1:t~ '-\Hh the te1nVi of any suc-.h agreement shat! h;ne been received by the Bani-. and that such
tammatwn ,hall not aikct any action talen b; tlK· B,ml-. pnor to such termrnatiOiL to rent or kase a saf('.' dcpo:-.ti box frorn. the Bank to cx,;,::ci.Hc the
1cntdl (1grci~m\!nt 01 lease, to cmcr the safe <lcpn~H box ,md to t'.?nmnate the rental agreement or le,:s¢, tn tah.e \\hatever other actrons ()f enter mto
\\.hclte\.et other agreements rel,1tmg to the ,Kcount:, or mvt'strn~nt ol funds m such accounts \VHh the: Bani<. and to execute, amend. suppkmcnt and
ddtvcr to Bank ~ud1 ,:i.gn:·nnc:nts on bctulfo1 th~~ Blhme~;s upon such terms and condmons as such Attthonzcd Person may deem approprwte and to
<1ppomt ,md 1..kkgJte. trom ume to lane, :.;uch pc1,on{s) who ma) be au!honzed to enter rnto ~uch agreerncnl~ and tale any other -1ctwn$ pur~uant to
\Ut?t°l agreement~ in c.onncct10n \\.Jth s;.ud accounh that tht Authonud Person Jeems necessary. and tn waive presentment demand. pwtt::it, and
notice ot protest or d1\honi}r of any ch::d. note. bt!J di itft, 01 other instrument mude, drawn or endorsed hy this Business. and
2. Further Resolveds that the Bank be ,md 1.;.; he1eh; autlrn::ized to honm, rcc;;1vc. (:Crf1fy. pay or e,changc for an0ther mstrumcnt aU mstruments
. . igned m arcord.:i.nce \.\ tth the toregmng Re,oltHwn m /\uthon?atmn. as appl!cahk:. even though such payment nrny create an nverctran. or ev.:.:11
lhough such :nstrumcnt'; ma; he dra,~n '\1gned 01 endur:;c<l w the <:Jidet of any Authonn';d Person s,gnmg the same or rendered h.) such Au1honzcd
Pcr'>on m a rturd party fi)t exchange or c<t:-ilnng. oi m pa) m::nt of the rnd1vtdual (1bhgat10n of such Aulhonzed Person. or for deposit to such
/\u1hon,:i;d Pcr,;on pc.r-;onal a~count and B<1nl... '-)IM!t not he r~q_uired or be under any nbhgauon to mqwre as to the circrnnstanct::s of the issuan~e or
U'>C: 0t any m,trumcnt signed m accmdaru.x: \\1th the lo11;go1ng Resolutmn or Authonzauon. as appl1c:1b!e, or the application ur <l1spos1t10n of such
m~trument m the rroceed~ rher~nf. J.nd, tu1 thc1, that the Bank 1s authonzeJ to honor any msuuct1on~ regarding \v1thdrawab~ orders for payment or
t: :111..sfcr of funJ<.:; \\herhe; oraL by telephone n1 ck:dH)l1!C mean.;; if ~uch \v1thdrawaL orders or transfer are mttmte<l by a.n Au(hon?.ed Person. and
3. FurthH Resnln,d, thal the Bank k ,lnd is he,dl) 1equc,tcd. authonzd and directed to honor and to treat as authorized, ch~,;hs. dralls or other
orders tor tht: pa) mtnt oi money d1av,n or ru1pP1kdl: dr:l\\n 1n 1h1s Business's name. 1ndud1ng those payable to the individual order of any p~rson
NS(
00.. 14.9120M 09-2017 Pagel of3
1111111111111111111111111111111111111111111111111111111111111
Date: 9/1/2018 Tme: 9:26:58 AM (US Centra, Time) Scanned From ,r>: 10.47.34.9
Annunt Ntintbci 2~3024167625 _ _ _ _ _ _ _ _ __

whosl;' nami;: appears thereon as s1gncr thereof: \vhen bearmg or purporting to bear the facsimile ,1gr:.Jtrn1.: ol ,rn Authonzcd f\~r-;on authon:;ed 1n Hi~
foregoing Rcsolutwn or Au1:hon1.~lt10n. as apphcahle and Bank stiaH be ~nt1tkd 1o honor it) treat <l\ dUtho11zc-d and to chd1g.0 -;:his Bu>m~ss foi ')Ut.h
ch(:ck.s. drafts or other orders regardkss of by \•vhom or by whd! means Htt~ ,1ctual or purpm ted tu. "drni!e ~1gnJ.tme thereon n1.:1) h.1ve been atfi'\.cd
JhertiO d such s1.gn,1ture re~etnblcs th\! facsrn1.1Ie sp~curn:n duly ct:rl!tkd lO or 1ikd with the Ba.nk h\ 1h~ .1ppt0prutt:. AlEhon1.ed Person or 1f ~uch
focs.urnlc signature rt'.:s~mbks any facs1mtle s1.gnJh1n'. prievwus}y affi.~ed 10 r1ny cbe-ck dr.1H or otlw1 (1r'--kl dJ.i\\n :n the Busmt~s·s: naml?. \\lm. h
~hec~ draft or 0H1,~r on.le:? was accepted and p.a1J \VJthout ttmdy obJt~ct!on by tht Bu::.me,._ thcreb,: rdt!t~rng th:: u~c ot r.;uch tav,im!lc <=:.1gn£1tu1e and
the Bu'.:>me,;s hereb; mJe-mrnfics dmi huld~ th:.;: Banh. harmless agam:-,t any dnd all lo...s. CO'>t 1.Lun~1g(: t:w ~,p(:nse ~uikrcd u1 mcurreJ bv 1he B~rnk
art')rng out of or m a.'1y \\:\) related to the misuse or u:iJa..,.vfu} or unauthonzeU use by a per..,on (ii «.m. h t,K'-imnlt: :-,1gnJ.tmc <tnd
4. Further Resolved, that endorsements for dcpos1t n1ay be evidenced by the name ot the Bu,.;1nt:',o:.; !x·.1ng \'ti 111en ot st.:1mped on the t-hed.._OJ othc..'.t
instrument deposited, without dcs1gnat10n of tb~ pdr!)' DM~ mg the endor::,;cment and the B,mk. 1<.. ~i:utho11zi;d to :,upp!y an) endor<:-emeni on <1n)
Jn"itrumcnt t~ndered tor dcp1b1t or 1.;ollecHon. :.md
5. Further Resoh·ed, that tht;: appropriate Authonzed Person oi this Bu~rness sh,.ill ce1t1I) to the ltml-.. name<.; and s1gnatUte') o1 persons autlwnzed tn
act on hehalf of1h1s Bu~aneS;'> unJer the forcgomg: R~solul1on or Autbon1atmn. n~ a.pplH. dble .ind m lh:; t::"Vent a t.hdnge 1.JtU:l~ m tht 1d~ntHJ ot the
Auth,.Jnzc..~.d Per,on . the undersigned shaH 1mmeJrntely re-port. !urmsh and cer!d) such d1dng~.:;. to I·Lu1k. c1nd •;J1<1IJ ~ubm1t to the B.ml-.. ,1 nt':\V accouni
::.1gnat1..1re card rdkc:ing such chnnge(,;;) in order to make such changt!s clkc11v~ 3.rld the Bank. ,;h,11! hi2 tuth prnkdtd m rd) mg ou ,.,uch c-ert1fiLt1lHHh
,mJ <=:.hall be mdcmmtkd dtld ~aved h<1rm!ess from &ny claim~ Jcma11d"i c:-...pcnse,~ Jossco:.; m danup~·, n~'.u!tmg lrorn or grn,\rng ou1 ol honorwg !ht:
~1gnaturr.:' ofan~, AtHhonz~d Person so cerufied. m refusing to honor any ,1gna1un: nol so Ler11fied :md
6. furH,er Resolved thdt the toregomg Re,olutwn or Authonzat,on as appilcable, shall ;emam m lull Joice and dtcct <1nJ the .iutlwnty hc,crn
given to all of ~.aid per,on::-. shall rem<lm 1rrcvo1..ahk a, for as thi.;; Hank. is <...oncerned until th1e:: (3} hu•,ml'.:,.,<., d,1)~ af!~1 B,.H1k p., no11fo,:d m wnt;ng. df
the n!vocaiwri of such authont:, and ihat rei::eipl of such ootlct: .:.:hall not .aHect an; dctwn taken b\ the B,mk. pnor 1hercto ,md
7 Further Rtsolnd, that all transacttnns by the undcrs1p1cd, or any :\uthonzed Pcr;,011 on its beh,ill .im! 1t1 th 11.irnc "tlh \he B<1nf, prwr to the
Jcllvcry 1o Han~ ofa cerofkd i.,Opy ot lh>;;.'.: f'<Hegorng Resolut1on or Aiilhonzatwn ~Vi nppI11.. . <1hk ,m.~ HJ all 1';',;;p~d", hereb) tdtliieJ lonfirmi:d
approved and adoptd, and
8. Further Resolved, that thc..: appropn.1te Authonzed Person be and h~rehy ,~. auihouz,cd ,md dircd<..:.J lo ,.~rtd) the,,~ Re,;;olutions 01 Authonz.1l1un'>
.1s apphcahk to lhe Banl ,md tiut the prov1smn5 hereof ar~ in conformity with the Busme~,., ~ A1ltdes of Irn.rnpc)rat10n 1\rt1dcs ot l\\s.;oc:1r1tion
Article:, ot Organizatwn Chai1er Rules, Agreement Operatrn.g Agri:emcnt (or other Agn.:-emtnt) .md m lh hn\.~ d.S appllca.bk .rnd th.1t 1he
appropriate Authonzi..::d Person be, Qlld hen:b; is, authonzed and .Jm::ded to c~1i1f; tn.Hn iHnt: 10 iHnc..: ht.:1c~1ttc~ the name-., of th;: lwldcr-.; of the Jbi)\t'.
authonzt!d oties ,.rnd their Slgnatt1ri::s on any signature card or other dotum~ntation requu ::d bv -.,~ud Ban~
Sectrnas 9, 1{), I J are applicable only ,f Partnership 1s checked on Page 1
9. Thal the under::.1gncd shall certify to Bank the nmnes and stgnatur(;:S of the Authonzed Pc1~on J.utlwiu.cJ to .id on bchalfofthts Busmes<=:. un(k:1 the
k)rcgorng instructions and nDtv..ithstandmg any mod1ficatwns or termrnauon ofan) of the po\\el ut Jll\ 01· the ab0Vl'.··n,1rned /\u!honzed Pcr::.on, to
r1:;present said Business, whether hy c~:,,;p1ra110n of Hie Par1ners!11p Agreement by death or retirement of an)~ n1 hv the a(:c,;;:ss1on ot on~ or more nt'.'.V,
Pa11ner.si or otht!f\Vt~e, and not\.1..:ith.::tandmg any other nooce 1hereofBan~ may receive thh auihont·, ,ftciH i..Ontmw.: to be hmdmg up{}n .:"ach of the
undersigned tnd1v1dually and upon our legal repres:en1at1ves ,1nd upon ::-.aid Partner'<htp .u1d 1h sucu.~,~01.~ untd \\rJHen notice to the conhdr) -.;lgncd
by one oithe under-;1gned or on his/h~1 behaH by his/her dul) au1ho111.cd agent m reprc,;;cnt.1t1vc. ,;;}Ml! ha\.-~ bt!r:n re(t!IVed b) the Banl prnv1deJ
IH)\.VeYt:'r that the fim:gomg 1nstructwns sh.:i.!l remain tn tull ton..:c and efkct and the auth(WJt\' h::rc..:m given lo aH ot s,wi pi.:tc>(ms ~hali rcmam
1rre.voc,1bk as far as Hant-. 1~ concern<:d until Bank has a rea~onabh.~ tHne tn ad upun .such not1t.r: to the 1...onttcU'\ <tnd :i-111..h reason,1bk tm1c 1...::1111101 he
!;zs;s than three (3) busmess d,l)S after the Bank. 1.s rmt1:tkJ rn ·writing of the r::voc.attnn of ~u(..h authont~ cmJ thct! rcu;1pt of '\UC-h nota:~ s}Ml; not afkt.t
,m:, auwn tak.cn h: !he Bank pnor thereto and
lO. lh&t it an) other per:.,ons betomc mtrrc,;;teJ rn the Partnership a$ a Pann~r or other rnk1este,J pait\ m lhc..: hu\m.:~s dcnlmg~ Df the l\irlncr.,iur nt
1fthere 1s an) change 1n the Partnership that mi.ght ~ha.ngc th.;: ri~lat1ons.h1p ot the Pdnner..::; 01 the ,.Jepth1hH~, rc!&Jmhh1p '"' 1th the B,:1nk or It ,.,,ltd
bu--:rnc;;;;'i -::hall beunne mc0rpornted the undcr"..Jgncd shall nottty the Bank promptly, d:nd
l J. That 1t is e,pre·,;J; understood and agrei;:d 1.hat ea12h Partne,;t is and :,hall be pert-ional)y lldh!e ttn the <1ct1on, taken pursuJnt to authonty g.rttnted
herern and that the rights evidenced by or contained m Hus Busmc~s Re~oluoon or Au1i1011zat1on d:., ~1ppl1e. &bk MC m adJ11H.:m to dnd 1101 tn
1unnution of the nghts mhercnt ma Partner, and
Secuons 12, 13, 14 are applicable only af Sole Proprietor as checked on Page 1
.12. Thdt 1t any other per:.ion. firm or corpornhon acquH-..;;s any nght t1tk or mten.~",t rn the B1J:::.1t1('v-. ot 1i n1) 11:latwn.;;h1p th~n.·to a'> ~ok ov. . n~~r he
alk"red rn any way, or 1ft-ia1d Business shall bccorn~ rncorporate(L 1hc urnkr~1_grnxl :,b.1D nollf) the B:mk p1omptl) and
13. Th..1t m t....ons1d~1.,1tmn of ymu ac..:ceptant..:~ of tht JccounL..:. of ::.u1d Bu\mess undt:r tht ton:gomg naffH~ .ind ,t) h: } t1gree to protect anJ w<lcmnit.)
Bank agarn..:;t ail loss or ltahtbt,: mdudrng court costs and aHorncJ' foes ansmg fiom or grc;\1.-mg out 0f the n<.cf;ptanc~ b) "u1d Bank lot !M) mi:nt of
ucd1t of check:-, dr,tfts, notes. b1Hs ot C\.lh,.mgi:, acceptance·) cs;:rtificdtes o1 tkpu:,1h oi other order-., anJ m<;;tiurncnts dra\.\·n to the order of and
endorsed m m:, n.:une and/or m the name of smd Business. and
NSC
00-14-91201\1 09-2017
IIIIIIIIIIIIIIIIIIIIIII IIII IIIIIIIIIIIIIII IIIIIIIII IIIIII IIll P~gc 2 oi 3
Acco;mt Nnmbs;T _2_2_3_0_2_4_1_6_7_62_·)_-- - - - - - - - - -
I..t. That the undersigned has stgncd. ack.nov, kdJ!J,:.J and filed :n the- proper vffi,,;,.; <Jf the state of tht." Business's r,rincipa! place of hus:ness any
do~tnni:nt{s) \'dw:h may be rcquin.:d bJ the lil\\S o!' ::.aid swte to he filed hy a person doing lmsmes-s under a fict1tious or assmned name. if app!icable.
fn \Vitnes:; \Vhcreof9 f t.":crtit\ that Jam duf; authoruc<l lo c,ccuh"; this Resolution or Authonzatmn. as applicable. on bdialfofthe Buslness. an<l
mtendiug to hmd th:.-; Busrnes.s.. I ha,...c he1eunt0 subscribed my naini.:'. m my capacity to certify the adoption of the Resolution or ,'\uthodz.1tion.
this J.}....... tt. ,"'1).
day of...... .(b ! )('
c+
l,--- __ J w ~ - -
S:gnature of /\t1thon1ed Business fkpresentdt1,·e / Title
Bank lnfornrntio11
Date 0S(Ji;2018
Flai1ncial Center Nmne _Ll:J.~:J..I~l_[:l_:~l; I S(jl!A r_zi_·,.- - - - - - - - - - - · ·-··············································
Adam \V1xrnk
~43-521-607()
Employee's Plwnc Number --------------------
NSC
II0-!4-9120M 09-2017 Page 3 of3
II IIll IIIIIII IIll IIIIII IIII IIIIIIII IIII Ill II lI111111111111111
Exhibit
P
STATE OF SOU]IH CAROI,INA )
) C0UItT 0t C0lvlM0N PLEAS
CJOUN]'Y OIT HAIVIPT'ON )
)
.ln RE:, Glor:ia .Safferfi,bld ) Docltet Numben
)
)
)
) T.'I}TITION FOR API}ITOVA I,
) OF SIII"TLNMJiNT
)
)
)
)
The Petitioner would submil the following:
l. Chad Westbndoi'f is tlre Personal Reprtsentative of the Estate o.f Gloria Satterfield,
laving bee.n so appoinbd by111* Probate Cstut for l{anptpn County; South Carol:ina. CIn
Decernher 29. 201 8,
2,. All per:sons rcqujrcd to bc nQtil'ted.of tliese 1rr:oceeclihgs h:alve he'err notificd,
3. On or about Ifubruagi 2. 20,18. Glolia Satterfield received injuries altel falling dpwn
the ticlnt stails oIa Collelon C]ounbr..sourth Chrrolinil residence o,wtrecl by llicharel Alc'xander
Murdaugh and N4argarct Murdaugh. Desedent Clor:ia Satterlield sub..seclugntly diccl.
4. Chacl Westendsrf. as tlre Fer:sonal Representatirie of the E.state ofGlotia
Sattei'fietd. iras a causg otlaction nndet the suwival staLute. $15-5.90, of the Code o.f l,aws ot;
Souttr Chr'ol.ina, 1976. as amerrcled^ an.cl,a cause o1'Srction flol wrongfirl death under $15-51-
10. Code of l..ar.vs olSouth Ceu'cllina. 1976. a;s anrended.

5. Ccrtain ljirderrvr:iters at l,loycl's" London 1"'t]rit Syndicates l.,tcl") pltv{elecl a
holreowners liabiJi.ty policy to Riahar:el AJexancler Murclaugh. pursuant to policy nun:,her
B83032r 0t,-5261 ,
(r. N.autih.rs Imru:ance Contpany prolided a person:al utnbtella liab'ility policy to Richarel
Ale,xander" Ivlurdaug.h. put:suanl to policy tlumher P{J386804.
7. Brit Syridicaps Ltcl. and Nautilus Insumncs Cqmpany have otfbrcd to pay the,totbl
SUM Of FOUTT MIII,T,ION 'TI{Rti|i.I'[TJNT'RI{T' FIVT.] THOTJSAND ANT' NO/]OO
(54,305;000.00) DOLL.ARSi to the Petititiner: lbr: the benell o{':thc l:jstatc of Gloria
Satterfielcl. and tlre stautoly berreficiarics of the Deced,ent in excltange t'or a lirll and final
Release tbr the liabiliD, g61,erage lvith regald to an,\, and al'l; c,laims ar:isin,g or.rt of the
wrorigfql cleath ancl/ol sulvirrorship of the Decedertt o.r otherwise, lvlrich rniglrt be asserted by
the Fer'.sonal Itepresentative on bellalf o f the Estate o.f Gloria Satter'field or on behalf: o,.f'tlre
statutoly beneficiaries ot'the l)cceclet,rtagaiirst Richald Alexandur Murdairgbl Marga,ret
Mulclaugh: NagtiluS ln$umnee Clompan.vl Mulplrir & (ilantlancl,. F.A,: t}:ii Syndicates I..td.:. qncl
C)a1rcp. .Toltnson. Wiggins.& Assocriates. [nc.l thcir agents. servants. employees. sueeessor.s.
heil's. executp6. administrutcrrs apci.assigns. brcciu-tst'ollthe in-iury to and srtbseqLtent death of
0loria Satterfielcl,
8. Tbe net pr.oCeeds to t:he Petitjonei: ar:e Io be allocateol $4.255.0CI-.00 to the won,gfill'
cieath c.lainr and $5. .000.00 fo the. sr-rrvival a'ction claim.
g. Chad Westendorf" as Persorral Represcntative of the Estate of Gloria Sn$erfield. is
rcpresenteclhy Attorney Cor1, II. Flenring qt'Moss..l(trhn & Fleming. P..A' ol Brvar.rfoft. Sou{h
Carolina,
)
10. l'he statulory beneficiaries o,fthb Decedent are ivlichael Anfhony Satterfield and
Brian Flalr,iott.
I 1. Chad Weslendort'. as the Personal Represerr.tative of the Ustate o'lo Gloria
Satterlislel.lras incurrecl,bills. soists alld cxpenses lbrand oir belrall'ot'the Dcced.ent and thc
blstate. includirr[ attome'y's l'L'es ancl costs as elenoted in thc Disbursernetl! $tatement
piovieled by Counsel lbr: tlrc' Estat'q- which is attachecl hele{o and nrade a pafl hereof as
L".lxllibit A. Chad: Westr-ndorf. as ihe Per.sorr,al Reprcsentative. of tlr,E Esta'te ol'Gloria
Satterfreld, agrees that tlicse bills, oosts aud expenses shall be paicJ fir-orn the proceeds of this
setflenrent.
12. Chad Westendor:f: as tlre Fersernal lteptesentative of the listarte o1'Glori,a
Satter'field. agre:es tl'rat tlie Estate oltGloria Satterfield siiall b€ rc'sponsihle For payirrg 4h1t.4,t6
all additional outstanding bills o'f meclical prclvidem. J'tnreral expensos ol othff pr:oviders ou
liehzrll'oJ"thc Decedent anclior tlre l:statc of (iltxia Satterficlcl. C]had Westendorfi. asthe
Personal ltepiepentative oltlrc Hsterte of Gloria Sdffqrticld. fin'thei'agrees that thc hls.tate rvill
bo solcly responsible l'or satisfyinB an\r anci,all nreclieal. funenal or otller liens held h)' any and
ail thir:d-palty meclical 0r otlrer' piovidels, strorild tirey exist" and that tltesc outtstandirrg bills
a:rd'liens rvill be satisf ied out of tlre proeeeds of'this settlenter:t, and that neither Ri.chaid
Aiexandq ltzl,tri:darrgh; Margalet Mru'dauglt Naurtil.us Insuranqe Cornpltny: Murph'y &
Gr.antland." P,Al Brit Sl,nclicateS L"td.; Cr:anrer..Iohn-son- Wiggins & Associate^s. Iuc,: ncrr tlreil
a.genls. servants. ernplo,vccs. successors. heirs. execrttcrrs, acfinini^stlatols. ol assigns will be
responsible lbr thexc. lrills. eNpenses ol liens.
.)
l:i. Ch,ad Westeudc;rf. as tlre Per,sorral Represcn.tative o,t'the F.b:tate ol:Glor.ia
Sattcrfiekl. has caretj,rlly consiclered tire I'actsauclcir'cunrstaDces hcrei.ir, Clhad Westenclorli. as
the Pct'sonal Rapre.sentalivc oFthe listaleol'Glolia Szrttqrfield. is awtrrie of the uncertainties of
litigatiolt and belicve-s tllat tlre otter:s" u.ncler: tlre sir'curtlstances.", afc fair: ancl cqr:ritable and
shoulai be aecepted without tlre additional delay and expenSe of l'urtlrer litig.arion. 1'herqtbie.
your Pelitioner prays tlrat this Court approve said offer.s and enrpo,r.r,er Chad Westen<iorf as
Personal Representative ofthe listate of Gloria Satterfield a,nd bn behalf ol'tlle statutoryr
beneficiarjes. to e"recutc such cio:eunrents ns may lre necessary to el'fiect a ltrlI encl final
Release in lhrror of .Richarcl Ale;xander'Muiclaugh: Vl.argaret lVJrrdaugh: NaLrtrilus Insuranee
Con:pany: M,urylry & Glarntlturcl.. P,A.t flrit Syndicates lutd,: and Ci'arrrer:. Jolrn.son. Wiggins &
Associates. Inc.: thcir agents. servants. employees. sltcccssor.s. heits. executors, administrators
and assigns" Iironr any and alI clairns, past. p^r'e5ent. ol fiitu'e. adsing out of'or in any way
eonnected with the e6ove-described acci.clent anci the injuries to an.cl,subsequent c.leath ol'
Gloria Shtteifield-
I 4, Chacl Westendoll'. as the Pet'sonal Repleseirtative of the Estate of Glolia
Satterfielc.i, understands tlral.. ilthc proposecl settlenlenf is approvecl. he and the statutory
beneficiar'ies wor;ld tre t'crrcver baned fiorn bringing an action against. br execritjng anlt
.[udgnrent against Ric]rard l\lexanclcr lt4r,rrclar"rglr: Margarct Murdaughl Narrtilus Insnrarce
Conrpart-vl lVlurphy:& Gr:antlarrcl." I).A,1 Llr'it Syneiicates [.tcl.: and, Cmtuet'. Jolrnson. Wiggins &
Associates, Inc.: tlteit agellts..selvants. ernplOyees. suEcsrssols. heiis" execttors. adnrinishal.ots
and assigns,
4
WHEREFOII"II, your P.etiti:onel prai s tha{ this Clour:t.approve the settlenrent as
liereinabove set fbrth antJ autliorize ChacJ Westendorf'. as tlie Peirsonal Represdiitatirre. ot"the
ti5tzrtc ot'Clor:ia Satter:liteld, ts execute any anclall instrunnents'to effeet the lrrll and linal
Release irr favot olithe persons/entities heleinabove nanred,
-/*'
ET.y
Tlris tlre of "
ry--,2019. in .. Sortth Catolina.
Chad. Westenclolll as
ofl the' [..]state of Gloria Satterflie|d arid
reprcsejltative of Miclrdel Anthony SatteffielP*__
Brian r,rarrion {
6",3*/r*/o
{
)
S'l'r\'l'E 0F SOtiTt-rl CAI{OL.INA )
) VERIFICATION
COU.NI]Y OF FIAMPTON )
PIIRSONAI.,I..Y appealed bcf'ore ine. Chad Westendorl'. wlio, heirig duly swor'ri.
clepoises hnd says thzrt, $lro is tlre Petition:er in the'ttrregoing proccedingsi that she has read tlie
allcgati<lns sef tbtth in the toregoing Iletition ancl ths sanre are Uue ancl c;orrect ts the best of
her ltnowl eclge. irr flcir:m at i on.. and bel i:e,[.
Westend:orf
Sworn't0 and subscribed befoie nre tlris
thg 13 day of'fT\f,uq.r ,2419,,

( I
(L.S.)
NotE.v, Sorrth
M y. $orr;r nri ssion L)rpirtis:
(>
(
ATTO II NIT Y'S C IiRTI,ITICATE
I hereby'cer:tily that l'anr a menrbcr of t:he South Carolirra ll:ar and. licensed to,pmetice
Jaw in the State ollsouth CarolinA. I lurther certily that. as attolney tbr Cbad Westendorrf* as
Personal Representative.of the Lstate of Gloria $artrer'ficild anel Repr:.esentative o'f Mi:chae'l
.Anthony'Safferfi,el'cj and I}rian Llan'iott" I have considered the pruposed setLlernents set l'olth
lreueinabove and do he.leby applove nrch sqttlemEn{s and reconrrnend that tlrey be ap-ploved lry
this Court.
'lihis the
_$hu, of 19.. in 4^*jr* Sor.rth Carolir:a.
il€
KLrhn & Frle,min.g. P",*.
( '1
Exhibit
Q
SETTLEMENT STATEMENT
Estate of Glor:ia Satterfield v. R. Alexarrder Murdaugh
DA'IE OF INJI.JRY: 02/2812018
Lloyd's Underwriters $505,000.00

Nautilus Ins. Co. 3,800,000.00
-Attorney's Fees (Lloyd's) 168,333.33
-Attomey's fees (Nautilus) r.266.666.67
2,870.000.00
Total Prosecution Expenses $ 105,000.00
Total to Beneficiaries $2,765,000.00
I understand and fully approve the above disbursements; I acknowledge receipt of

the above amount and a copy of this statement. Any hnown or unlcnown medical
bills or expenses, rredical or otherwise, ich are not included above, shall be'paid
by me, the undersigned.
fr
Chad Westendorf, as PR f the Estate o f
Gloria Satterfield
Date: Brl 4,?

Exhibit
R
S:I A fE OF SOUTI-I CAROI"INA )
) couRT oF COMMON,PLEAS
COTJNI"Y OF I{AMPTO}'I )
)
In RE: Glo,ria Salterfield ) Dockct Numbor':'
)
)
)
) ORDIIII. AFPITOVING S,Ii TLEI\4ENT
)
)
)
)
)
TFIIS MATTER cou.ies:before the Cpurt otr the verified Fetition o,f'Chacl
W.estendor:lL as Perconal Represe.ntative oIthe Hstate of Gloria Sattedie{d. lt appears tl.lat on
0r- aboui February 2. 201 8. Glor:ia Salter'lleld received irr.iiu'ios atli{.cl falling d'own the fiont stairs
ola Co.lleton Ctrurry, S.o,utlr Calolina rcsidence ownecl tly Richalcl Alexancier Mtrrd,augh and
Margzu:et Murdaugh. IJeccdent G lqr,i a S,attctfi e ld sulrseq uen tl)' cl i ed.
The Petitiorrer asser{s to have a callse of actiou: undcl tlie survival statute. ss15-5-90.
Code ol [-,aws ol'South Carolina. 1976, as amended. and a caluse of actior:r 'lbr,wrongfitl deat]i
tincler $ 1 5-51-1 0, Code ol'[,aws ol'Soulh Caroljna, 1976,, a$ tlrmended'
Ce*ain Unclerwliter:s at [.loyd's. l.ondon ('!Brit Syndicates L.!c!") pruvicteel a
honreou,ner:s liabi,lity policy to t{icliarcl Alexander Mutclauglr. put'suanl to pol,icy nttnrber
ut33032i 01.',526I .
Naut.i|.m Insurernce Ci:nrparr5, provicleti a pets,otral untrella lia-bil'it1, policy to Richald
A I exandct' M uldaugli. pul sttzt ttl to p<rl ini n unibcr PtJ 3 8 5804.
It is dcnied lly th"e pafiies to bc t'eleased that the inir.rri.es.ancl subscq.uerlt clea,th
suffbred b5r tlre Decedent were the result of airy negiigcnce ot recklcs,sir€ss of a:rry leleasecl
paf$.,
In spite of this denial. nievertheless" and in tlre in:lelest ol'comirromise, Bri.t Syndicates
Ltc,l. and Nautilus'hrsulance Con:pany lrave ol'.fured to pay th:e tolfll sum o,f FOU.R M[[,LION
'I'HREE FIUNDIII]I) IIIVT] TIJQTJSAND AND NOIIOO (S4,3O5,OOO.()O) DOLLARS tO
tlre Petitioner for the benefit of the F;state o{'C.ilor'i,a Satterlield..and th'e s.tartlrtol)l bcneficiarics
of the.l)ecederrt in e;rcharrge, Jior a lrull ancl final Rclease for thc liability covel.age u;,i[l'l rsgsrd
to auy and ali clainrs arising oLlt of the r,l,rongfirl death andlo.r:surtrivorsltip ol'the l)ececlent or
otherwi.se- whieh nrlglrt be asserted. by the Personal Repiesentative.on behalf'of the listate of
Glor:ia Sanerfield ol on behhlf of'the staiutory benel\bi.aties ol'the f)ecedent agairrst llichard
Alexa,nder MurdaLrgh; Mar:ga'et M:ru'datrgh; Nautilus Insurancc Company; Murphy &
Grantlanel,. P.A,: Brit Syndicates L,td.: arrd Cramer. .l'ohrrson. Wiggins & Associates. Lnc..l their
agqnts. se*ant.q. ernplo,rrees. successors. Irc{ils.cxecutcr:'s.adniirristlators and assigns, bec4use ol'
lhe iniur:y to anclsuitrse.q'uerlt deatlr oICIoria SertteLf-leld"
'flre tiet procecds to the Petitioner arc to be allocated as, $4"?55.000.00 to the
wrongfuI death claim and $50"Q00.00 to the sr-rvivdl acti.ot e'lainr'.
l"he Petitioner; Chad Westendort'. as Personal Replesentative of,the Estfie of Glori'a
Satteufielcl.. is represented by Attolney Coly H. ,Flenring of l\zloss. Kuhn & Flerning. P.A. of
Beaufcrrt, South Carolina,
TJre statutor'1,' berrelieiaries of the Decoelcnt are Micl:,ac-l Anthorry Satter{ield and
Br:iair l{an'ion.
s
The Petitioner'. Chacl Westendotl'. as the Fersonal Representative ot'thc Estatc of
Glsr,ia Sattelfield. has iucrrr:red bitls, costs and expcr,nscs f,or and on beltalflof the DeceClent
and tlre Es:tate. irrcludirrg attomey's i'ees and eosts as cleuoted in the Disburlsenrent Statenr'ent
providucl by elounsel lerr the'fistate. lirhich is attachccl, hercto atrd nlacle a paft hereof as,
D,r'lrihit A. Chad Westcrlclor{]. as the Per.sonal Representative of the F,state ti.f Gloria
Satterfield, agfees that these bills. costs and expenses;sliall be rregotiated and resolved fi,om'
the proceecl^s crf this settlement. ChacJ Westendorfl aS the Petsonal Represerttativq of the
Bstate oliGltiiia.satterfield, statecl that the listate slGloria Satterfisld shall be lesponsible for
paying negotiating and resolving any and all additiorral oittstattdingbills of medical
proviciefs. fiineml expeh'.ses or othe:r providersr. Or govenlnlent agenc'ies. on tiehall'of the
Deeeelent aucl/or the llstale o1'Gloria Sauertielcl. I'he Petiticrner'. Chzrd Westendor,J'. llurther
agrecs tliat the [state will be solely lesponsiLrle fbr negoti:atirrg and res0lluin$ any and all
metlic,al, firneral o-r othcr Iicns held by any and.all thiild"palty'nredical or o.tlrer providers,
sho'nld they exist. and tliat thc'se outstanding bills ancl l'iens ivill be satislied orrt oflthe
proceeds of tlris settlenrent. anc{ that nejtlrer Richard A.lexander lVlurdaugh; Malgalet
lV.fulclaugh; Nautilus lnsuranoe Conrpany; Murphy & Grantland., P,A.; Brit Syndicates L,td.;
Cratrrei:. .loirnsoir. Wiggins & As-soeiates. Iirc.; nor tlicil agents-. s'ervant's. shrplo;rees-
succgsgors. heh:s. cxocuto.rs. adrninistt'atol's^ Q[ asrsi$lr-s r'vill hc resporrsitrle flor atiy oirtlrese
bills" experrses or li,ens:.
The Petitioncr. Clracl W.estenclbrf . stated that hE has carelllly coirsicietedthe facts and
'l'h:o
cirgumstai:rces herein. Petitio.ner. Chad Westendorf. stated th,nt he is,arvare of the
uncerta:inties of't'itigation and believes that thc of'f'ers. uncier the circ'tunstances" ale flair: ancl
eeluita:ble ttnd slrould tre accepted r,vfthotrt tlre aclclitio:na'l dela.y and expense of f'urther
litigation.
Upon lirll consiclemti.on of tltis nratter. it ap,pear:s to thc Cout that the. settlenrent
pio:posals outlitred lier,eirrabove hnd in the Petition ars thir a,nd jr-rsl. and ir;r the best interest of
tlie parties. Aceor'dingl'y. it isl
OIIDERED, ADiIUD,GED AND DECREED that the.settlerent ploposals set tbtth
hereinaborre ar:rd in the,ltetitioner's Petitiotl are apploved. and tllat upon payment of tlrc
anroLurt set forth thetein. the Petitioner. Chad Westenclorf, as Personal l{epreseirtative of the.
f:lstate crt'Cjloria Satter'fielcl. is helebri authoriz$d arrcl dilcctecl. to e\ecllte such clocuments a$i
rnilleffl'ct a {trll and linal Rclease i:i lhvor o,lf l;n1ln* Alexandcr lMulciaurgh: Mzu'garct
Murdaugh; Nautihis lnsumircc Conrpany; Murplry & Glarrtland.. P.A..: Brit Syndicates Ltd.t ancl
Cramei'. Johnsoir, Wiggirls & Associates. Inc;; theil agents, s:ervant$.. enrploy-,ees, successors.
hei$. executors. adrnin.istlators and assigns. frorn anlr and all clainrs ol actions wlratsoevet
arisiug out ofthe irrjury to ahd subsqquenl death oiG'loria Satter{ield
AND IT IS S0 ORDERED. this the J-J-. nruil ,1.*.ilLd,--.2019.

-*--*"u***- in
.. .__- Sourth Calolina.
Presiclhrg .ludge
SETTLEMENT STATEMENT
Estate of Glor:ia Satterfield v. R. Alexarrder Murdaugh
DA'IE OF INJI.JRY: 02/2812018
Lloyd's Underwriters $505,000.00

Nautilus Ins. Co. 3,800,000.00
-Attorney's Fees (Lloyd's) 168,333.33
-Attomey's fees (Nautilus) r.266.666.67
2,870.000.00
Total Prosecution Expenses $ 105,000.00
Total to Beneficiaries $2,765,000.00
I understand and fully approve the above disbursements; I acknowledge receipt of

the above amount and a copy of this statement. Any hnown or unlcnown medical
bills or expenses, rredical or otherwise, ich are not included above, shall be'paid
by me, the undersigned.
fr
Chad Westendorf, as PR f the Estate o f
Gloria Satterfield
Date: Brl 4,?

Exhibit
S
Exhibit
T
ELECTRONICALLY FILED - 2020 Oct 06 1:48 PM - HAMPTON - COMMON PLEAS - CASE#2018CP2500505
ELECTRONICALLY FILED - 2020 Oct 06 1:48 PM - HAMPTON - COMMON PLEAS - CASE#2018CP2500505
Exhibit
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Exhibit
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Pay to date amount
C.E. Smith 10/8/2020 8,500.00
C.E. Smith 10/13/2020 9,201.00
C.E. Smith 10/15/2020 8,900.00
C.E. Smith 10/20/2020 9,085.00
C.E. Smith 11/13/2020 9,049.95
C.E. Smith 12/4/2020 9,271.00
C.E. Smith 12/11/2020 4,150.83
C.E. Smith 12/16/2020 8,195.73
C.E. Smith 12/21/2020 8,167.83
C.E. Smith 1/8/2021 9,801.00
C.E. Smith 1/15/2021 9,740.00
C.E. Smith 1/22/2021 9,895.00
C.E. Smith 1/27/2021 9,800.00
C.E. Smith 2/2/2021 9,239.00
C.E. Smith 2/5/2021 9,751.42
C.E. Smith 2/16/2021 9,892.00
C.E. Smith 5/28/2021 22,109.00
TOTAL $164,748.76
Amount: $9,201.00 Sequence Number: 4652141552
Account: Capture Date: 10/13/2020
Bank Number: 11400001 Check Number: 840709702
Cashier's Check No. 0840709702

BANK OF AMERICA~~
BBllk of America, N.A. '

, SAN ANTONIO, TX
11•oa 1.0 'i'O 9 'i'O 211• 1: l, • 1.0000 l, 91:

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9Z/SO
ates )pay'.) 1entJ,O Date: 10/13/20
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SeQ:88012 19/13/28
BAT:195531 CC:0057440788
WT:01 UPS:Atlanta ET
BC:Jean Ribaul Square BC SCl-312
Electronic Endorsements:
Date Sequence Bank j/ Endrs Type TRN RRC Bank Name
10/13/2020 4652141552 11000138 Rtn Loc/BOFD Y Bank of America NA
Noti<.e1ol"urdlulr~ Ultbtflta'ltthal this.dm llloat, .,,~or

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Cashier's Check - CREDIT COPY
ph(lll lO rtpik:cmcnl Th,, dlcct. ah.ould bl: rt,tpe111ed w,sJi1n 90 Oily:t.. No. 0840709702
Void After 90 Days 30-11114-0 Date 10/13/20 03:21:48 PM
JEAN RIBAUT SQUARE NTX
0993 7440700 0233
Pay ¢<>¢<)~~~~l~~·tr;{ ~JJ~~ 1 **$9,201.00**

••Nine Thousand Two Hundred One and 00/JOO Dollars••
To The C.E.SMITH
Order Of
Not-Negotiable
Credit Copy
Remincr (Purchased By): RICHARD A MURDAUGH
Bank of America, N.A.

SAN ANTONIO, TX
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Date Sequence Bank* Endrs Type TRN RRC Bank Name

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SAN ANTONIO, TX
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, I3aiik of America, N .A.
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10/23/2020 3980138952 61000146 Undetermined N Federal Reserve Bank
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0004 7440700 0041
~ B A N K oF,.NrME[ ~ .r::."«,CiS
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••Nine Thousand Forty Nine and 95/100 Dollars••
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Order Of
Not-Negotiable
Credit Copy
Remincr (Purchased By): FORGE

SAN ANTONIO, TX
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Date Sequence Bank Ji Endrs Type TRN RRC Bank Name

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~ • 'Oriler Of .
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11•oa1.,o ?D'i ?aa11• , 1: 1a 1,1.,00001,91:

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Void After 90 Days 30-111140 Date 12/11120 02:46:45 PM
0003 7440700 0122
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••Four Thousand One Hundred Fifty and 83/IOO Dollars••
**$4, 150.83 **
To The C E SMITil
Order Of
Not-Negotiable
Credit Copy
Remitter (Purchased By): FORGE

SAN ANTONIO, TX
, .....,.,.
. )
067473085 Seq: 67
Batch: 751511
Date: 12/11/20
Seij:QQB67 12/11/20
BH:751511 CC:0057440703 Tran 00122 12/11/2020 14:47 NSC
WT: 31 LTPS:At Ianta ET
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Document I osqo709893
Official Ch1;1ck Sale 1 '$4,150.83
DRL SCO******* ' 05/26 06/1B
CRC BM*************** 10/23

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~ R;~incr (Purchased By( F~RG'E
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n•oa 1.,0 70 cia ci :111• ,: i ,, i 1.,0000 i. q1:

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067473085
v11.11w.b 2.n!,cfa m:;r:G2. er.: m
Date Sequence Bank !i Endrs Type TRN RRC Bank Name
12/15/2020 000000029672543 53202596 Rtn Loc/BOFD Y Palmetto State Bank
Amount: $8,167.83 S,sciu,anc,a Numb,ar: 2752842981
Account: Capture Date: 1:/21/2020
NOOCII IO P'ill'dutMr ~ t,, I.hit l'Yffl Wll t.b.:ia did i1 I011. ,.;a;i11(;ed ot Cashier's Check - CREDIT COPY
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No. 1144109642
Void After 90 Days 30-111140 Date 12/21/20 03:54:19 PM
TRENHOLM ROAD NTX
0003 7070500 0295
Pay ~BANKOi•i
~AMERIC =m 1sm8!8
NCTsc1s **$8,167.83**
**Eight Thousand One Hundred Sixty Seven and 83/100 Dollars ..
To The C.E. SMITH
Order Of
Not-Negotiable
Credit Copy
Remillcr (Purchased By): FORGE

SAN ANTONIO, TX
059053522 Seq: 24
Batch: 886147
{ ... ··i 1:,· ·1 [)ate; 12/2.1/2.0
. ! .
S&Q:00024 12/21/20
BAT:8&6147 CC:0057070590
WT:81 LTPS:Atlanta ET Tnn OOc"li 12/21/202(}
BC:Trenholm Road BC SCl-281 15:54 NSC
R!Tlt 540570139 cc 7070500 nr 00001
i+co:.mmt
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llRL SC********* OJ/~b
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Date Sequence Bank# Endrs Type TRN RRC Bank Name
12/'.'l/'.'02 '.'75'.'84'.'981 11000138 Rtn Loc/BOFD Y Bank of America NA
Amount: $8,167.83 SE?CJUE=:ncE=: NumbE=:r: 4392383526
Account: Capture Date: 1:;2:;2020
heck 4 09642
Dank ofAmerica;N.A.: ··
;SAN ANTONIO.TX
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11• 1, 1,1.,1., 2.oc:ifa1., 211• ,•: 2, 2,1.,0000 2,g1:

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059053522
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·:,,··.-· ;,.,,rl''.,2020-12-22
. • ,,., . I, 0528313124
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l'.'/2'.'/202 00439238-35:6 11101'.'82'.' Pay Bank N Bank of America NA
l'.'/23/202 46.35'.'77697 6100014 Undet.errni_ned N Fede Reserve Bank
12/22/202 000000528313124 53202871 Rtn Loc/BOFD Y Enterprise Bant of
Amount: $8,.500.00 S,sciu,anc,a Numb,ar: 4352330570
tkt~~J.llht,rvf!Mtblll:i:bl1dl«.ki1ln.rnisplaeedlo,
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tGrtpl~I Tiucilod::'lk'luldbtaca,ot1atocl*1Utl•90day:p._ No. 0840709692
Void After 90 Days 30-l/1140 Date 10/08/20 03:07: 15 PM
OOOl 7440700 0061
0
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Eight Thousand Five Hundred and 00/100 Dollars••
**$8,500.00**
To The CE SMITI-l
Order Of
Not-Negotiable
Credit Copy
Rcmitter (Purch=d By): FORGE

SAN ANTONIO, TX
11"081.,0 ?0 1E,!:i 211" 1: 51.,D? so 2.oa,:
Seq: 49
92/£0 *********3S l~u. Batch: 740141
OO'OOS'8$ ar~s >pa43 FPTHO Date: 10/08/20
Z6960l0v80 H +uawnJoa
:iunoJ:•\l
JOOOO JI! OOlOvvl 33 6£tOL~OvS #l/M
3SN 80!\;l OZOUB0/01 19000 UE:Jl
Seq:80049 10108120
BAT: 70141 CC:8857440780 ··•
WT:01 LTPS:Atlanla ET
BC:Jean Ribaul Squart BC SCl-312
Amount: $8,.500.00 SE?CJUE=:ncE=: NumbE=:r: 9294 06

BANK OF AMERICA q ~
Re,~i~er (Purchased By): FORGE

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, · Bank of Americu. N.A. ,

. SAN ANTONIO, TX .
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oo oor;'o $
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BOFD >053202871<
Walterboro
2020-10-08
0227183658
,: ',' _n, ~,
Electr0nic Endorsements:
Dat Sequence Bank# Endrs Type TRN RRC Bank Name
10/ 9/202 3831'.'05671 6100014 Undet.errni_ned N Fede Reserve Bank
Amount: $8,.500.00 S,sciu,anc,a Numb,ar: 4352330570
tkt~~J.llht,rvf!Mtblll:i:bl1dl«.ki1ln.rnisplaeedlo,
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tGrtpl~I Tiucilod::'lk'luldbtaca,ot1atocl*1Utl•90day:p._ No. 0840709692
Void After 90 Days 30-l/1140 Date 10/08/20 03:07: 15 PM
OOOl 7440700 0061
0
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Eight Thousand Five Hundred and 00/100 Dollars••
**$8,500.00**
To The CE SMITI-l
Order Of
Not-Negotiable
Credit Copy
Rcmitter (Purch=d By): FORGE

SAN ANTONIO, TX
11"081.,0 ?0 1E,!:i 211" 1: 51.,D? so 2.oa,:
Seq: 49
92/£0 *********3S l~u. Batch: 740141
OO'OOS'8$ ar~s >pa43 FPTHO Date: 10/08/20
Z6960l0v80 H +uawnJoa
SZ9l9 l ~iO£ZZ :iunoJ:•\l
JOOOO JI! OOlOvvl 33 6£tOL~OvS #l/M
3SN 80!\;l OZOUB0/01 19000 UE:Jl
Seq:80049 10108120
BAT: 70141 CC:8857440780 ··•
BC:Jean Ribaul Squart BC SCl-312
Amount: $8~900.00 Sequence Number: 4692241239
BANK Of AMERICA ..;.-q Cashier's Check No. 0135612030
Dunk of Amcrh::r~ NA
'SAN ANTONIO, T,X
• TH e Ort tG!NAL OOCUMENi HAS A WHIT! fl !!rle'C:JlVf:! WATERMARK C~ iH I! BACK. II HOLD AT AN ANGLE TO VIEW WHEN CHECK!NG THE ENOORSEMEfffS, II
Electronic Endorsements
10/16/2020 000000127317430 53202871 Rtn Loc/BOFD y Enterprise Bank of S
065946007
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10/19/2020 3918239057 61000146 Undeterrni ned N Federal Reserve Bank
N-,o~<e-· In•~- ;;.,.11,,,~ itlolJlt. m,11)1~0f Cashier's Check~ CREDIT COPY

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Void After 90 Days Date 10/! 5/20 02:35:41 PM
PARK PLACE
0002 7180000 0054
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Order Of
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.4,..
Bank of Ammca, N.A.

SAN ANTONIO, TX
065946007 Seq: 3
Batch: 839427
Date: 10/15/20
\• .. .' L.,
'
~ Seq:9&883 11/1&/?9
________________________________:_____________ :;~ ~ t'l1~~: i~ i::: !I g9_9_!___________________________ R/Tlt
BC:Ca:,u, Park Platt BC SC3-2U
Tr1r1 00054 .. _ l0/15/202D _14;36 ____ N$C _____ _
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Doc1JIM'nt # 0135612030
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,
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Ii.Illa\,
Cashier's Check - CREDIT COPY No. 0803110374
pno.- l e » ~ T11111-dl«i:. OIOUJd l!lt Ma,otJlted •lh1n 9IO dlty11.
Void After 90 Days 30-111140 Date 12/04/2001 :20: l OPM
FIVE POINTS NTX
0009 7072200 0114
~BANKOF~:lij'~~ I
00
Pay ~AMERICAti ~Hr.CTSCTS **$9,271.00**
••Nine Thousand Two Hundred Seventy One and 00/100 Dollar..••
To The C E SMJ'lli
Order Of
Not-Negotiable
Credit Copy
Reminer (Purchared By): FORGE

SAN ANTONIO, TX
Q6 8 8 4 9 3
81/'10 'i'USO
~a :JZJ l3Vl.131NI 9WI N
UtUUU:JS l~G
Seq: 31
Batch: 630113
00'1l2'1,t ilTE·S }j:,;,43 Tf·PTMO Date: 12/04/20
bl£0ll£080 H tu;;wn,oa
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60000 JU OOZi.:lOl :J:J .mot~Ot,S Hl/~ ,;,·,,1
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~ 1, • '

BANK OF AMERICA Qq'
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".'"i './,. ,· ·,, ·., , :·(:,'·<'.\'', I ,,,~_
Bruik:of America;NA·:
. SANANTONIO; TX .
. -~. - ·- ..._.,, . ,, . : '
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1111 , THI: ORIGINAL DOCUMENT HAS A WHITE REFLECTIVE WATERMARK ON THE BACK. II L'.HOLD AT AN ANGLE TO VIEW WHEN CHECKING THE ENDORSEMENTS; '; 1111
068849358
www.bani:o'1arnerica.com
0029624729 H"!!W.ban!:o'iarn crica.com
Palmetto State 053202596

Hampton
2020-12-'{)7
0029624729
cofamarica.com wwv-,1.1Janfcok.n11.=1·ica.com
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P"Qf lO ~ Tl\14. (Md: ~ d bf "'fgO(HCed Wlli'wll ,g,Q •rt. No. 1600011842
Void After 90 Days 3().111140 Date 02/02/21 02:33:33 PM
FOLLY ROAD NTX
=:;-
0003 7292900 0136
~BANKO~INE~~~rno
Pay ~AMERIC- §scrs **$9,239.00**
••Nine Thousand Two Hundred Thir1y Nine and 00/100 Dollar..••
To The CE SMITI-1
Order Of
Not-Negotiable
Credit Copy
Rcmitter (Purchased By): FORGE

SAN ANTONIO, TX
11• H,000 1, LB a. 211" 1: 5 L.O? SD l.OB•:
065391693 Seq: 180

Batch: 491591
Date: 02/02/21
Tran 00136 02/02/2021 14:35 HSC

R/TII 540570139 CC 7292900 Tlr 00003
Account
Document ij 1600011842
Official Check Sale $9,239.00
DRL SCUU***** 05/26
ti IHG n!TERACT f2F AUTH
BANK OF AMERICA,,.~
Cashier's Check No. l 6000 l 1842
. . g
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11 THE ORIGINAL DOCUMENT HAS A WHITE REFLECTIVE WATERMARK ON THE BACK. 1111 HOLD AT AN ANGLE TO VIEW WHEN CHECKING THE ENDORSEMENTS. 1111
065391693
0228898 740 2021,02,02

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Date Sequence Bank ii Endrs Type TRN RRC Bank Name
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pnoc co rwpl~t liles.CMC:k. tboukl be lllfl<"lllcel ,.,,ll'un 90datt,, No. 08407 l 0404
Void Aftcr90 Days 30-111140 Datc05/28/21 02:04:51 PM
JEAN RIBAUT SQUARE 1-ITX
0993 7440700 0045
Pay ~~~~l~t";t.JJz~o1:qr9s~
.. Twenty Two Thousand One Hundred Nine and 00/IOO Dollars••
**$22,109.00**
To The C.E. SMITH
Order Of
Not-Negotiable
Credit Copy
Rcmiucr (Purchased By): RICHARD A MURDAUGH

SAN ANTONIO, TX
' ! ' • , ·~' ~

' \ i '.'' . 'f. t,
Q6 97 4 35 Eli~~ :Ji.:! D1Jll31NI !l~I N

Seq: 43
Batch: 702769
auso *********:is ,~a
00 • 601 'zzt a1es )pa4:i TtP,HO Date: 05/28/21
bOtOllObSO I ~uawmoa
~uno:i:iij
£6600 JH OOlObt,l :J::l 61:!0li;OtS Ml/ll
3SH bo:tl · lZDZ/BZ/~O St,000 IAtJl

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"' . c' To The C.E. SMITH '· ~ . ,,,
l OrderOf
~ I
S Remiuer (Purcha.s,:d By): RICHARD A MURDAUGH
I
Bank of America, N.A. I
SAN ANTONIO, TX ,I
11111 me omoou.i. DOC\JYElff HAS A WHl'Tl! REFI..ECTIVE WliTl!!RMAIIK ON THE IACl<.11111 ·' HOU) AT AN ANGLE TO VIEW WMEN CHECKING THE l!NDOftSEMEHTS. ;· . 11111
Q6 9 7 4 3 5 ag~ .mUUU*U:JS l~a

!J';l~31NI 91,11 N Seq: 41
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pnOf lo rqillllelefflll'll. Thi,~ :NI.OIM be neoc,iblted w,lbl111 90 dc1$- No. 0840709893
Void After 90 Days 30-111140 Date 12/11120 02:46:45 PM
0003 7440700 0122
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••Four Thousand One Hundred Fifty and 83/IOO Dollars••
**$4, 150.83 **
To The C E SMITil
Order Of
Not-Negotiable
Credit Copy
Remitter (Purchased By): FORGE

SAN ANTONIO, TX
, .....,.,.
. )
067473085 Seq: 67
Batch: 751511
Date: 12/11/20
Seij:QQB67 12/11/20
BH:751511 CC:0057440703 Tran 00122 12/11/2020 14:47 NSC
WT: 31 LTPS:At Ianta ET
i !, ; .. !"r ; ~ ? :· ~ r ~ !' ~ .. 7 ri ."' I'. ... t 1!" R/T~ 540570139 CC 7440700 Tlr 00003
Account
Document I osqo709893
Official Ch1;1ck Sale 1 '$4,150.83
DRL SCO******* ' 05/26 06/1B
CRC BM*************** 10/23
Amount: $15.00 Sequence Number: 4552069405
Bankof America~~
General Ledger - SC CREDIT
Teller Fees Clearing Account
~ JEAN RmAUT SQUARE
:!,
Cl
:z
j Tran 00122 12/11/2020 14:45
Entity NSC CC 7440700 Tlr 00003
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R/TM 54057013'1
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Seq: 68
Batch: 751511
Date: 12/11/20
Se<1:00068 12/11/20
BAr:151511 cc:e051440100
t!·a1 LTFS At l~nta E~
HOIIG1J:lo~ -.l.al.lletvt"MU'lllll:tlu1chtdttlllosl..111..1:lp1111Xtd.0t
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~or IO fcpllCffll,ffll Thi• i:Mdi: ~ bl Mp)Clltlld ""llfutl 90 ,days No. 1560012040
Void After 90 Days 30-l/ll40 Date 12/16/20 04:03:50 PM
BLUFFTON COMMONS NTX
0001 0025600 0166
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~AMERIC~l@ N
~rb~:!i
-~CTS **$8,195.73**
••Eight Thousand One Hundred Ninety Five and 73/IOO Dollars••
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Order Of
Not-Negotiable
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Rcmilter (Purchased By): FORGE

SAN ANTONIO. TX
Q6 8 Q2 6 35H~nij ;lZ:l !3\/lJ3!Nr S~I N Seq: 61

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----------------------------------111111111111111--------111111111111111
BAN K OF ,:;.q
AM E RIC A Cashier's Check No .. 1560012040
•i .. -. ---_ • - ' - . - -- - . .
BMkof America; N.A.

SANANT01'10, TX
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• HOLD AT AN ANr.::I J: Tn v1~w w~i=N l"&..1cr1r.11.1r- Tu~ ~ ................................ ...
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1
2020-12-11 I
10228236925 ·' ··;i
, W'.11•n.bank::i,11mrmca.c:Drn
Date Sequence Bank -Ii Endrs Type TRN RRC Bank Name
~ro~·'••~Nll1Mscbect1•klet.l'lli~cr Cashier's Check - CREDIT COPY

lffiM. 1 fWfJffi l!Wement Uld. 90-dl'y \l,ISjlJlllg penod w,,JI be ~Nd
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pno, m t-t'pl&eel'l\ffll 1b11 meet i,l!,oullcll be qOll.laU:d willll• 90
No. 11441 09772
Void After 90 Days 30-111140 DateOl/15/21 12:27:05 PM
TRENHOLM ROAD NTX
=Rz'8o RD
0003 7070500 0006
~BANKOF':J.ijE~ [
Pay ~AMERICAl:I CTSCTS **$9,740.00**
••Nine Thousand Seven Hundred Forty and 00/100 Do1tars••
!
"' To TI1e
OrderOf
CE SMITH
Not-Negotiable
~ Credit Copy
Reminer (Purchased By): FORGE

SAN ANTONIO, TX
059053452 Seq: 82
Batch: 241241
Date: 01/15/21
. '
Seq:00082 01/15/21
BAT:241241 CC:0057870530 - .' ~- .
WT:01 LTPS:Atlant~ ET
'
i~an
0000{ : 01/15/2021
BC:Trenholm Road BC SCl-283 12:27 l!SC
R/Ttt 540570139 CC 7070500 Tlr 00003
Ao:01int
Document II 114~109772
Offici.3l Che,:~ Sale $9,740.00
DRL SC********* 05/26
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069743170 Seq: 125

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065391642 Seq: 135

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Document M1600011790
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Document M1600011790
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2021-12-06 Satterfield Amended Complaint (Murdaugh-BOA) With Exhibits and Virzi Affidavit (As Filed-Without Filed Stamp)

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2021-12-06 Satterfield Amended Complaint (Murdaugh-BOA) With Exhibits and Virzi Affidavit (As Filed-Without Filed Stamp)

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STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

) FOR THE FOURTEENTH JUDICIAL CIRCUIT

Michael “Tony” Satterfield, Individually

Michael “Tony” Satterfield, Individually

As detailed herein, Bank of America, N.A. (“BOA”) acted as Alex Murdaugh’s

issued 254 personal checks to Cousin Eddie totaling $1,825,560.95.

and theft was exposed, BOA failed to terminate Murdaugh as a customer. 4

PARTIES & JURISDICTION

1. Plaintiff Michael “Tony” Satterfield (“Tony”) is a citizen and resident of Hampton

Court No: 2018-ES-25-0056, on behalf of the Estate.

2. Plaintiff Brian Harriott (“Brian”) is a citizen and resident of Hampton County,

South Carolina and the half-brother of Tony.

4. Upon information and belief, Bank of America, N.A. (“BOA”) is a Delaware

Richland County, South Carolina.

6. Venue of this action is proper in this court.

legal family in the area.

the Plaintiffs in this matter.

prominence in Hampton County.

proud of her two sons, Tony and Brian.

South Carolina was caused accidentally by the Murdaughs’ dogs.

traumatic brain injuries.

Tony and Brian.

legally responsible for Gloria’s death.

Carolina law firm.

connection with their mother’s death.

to know anything about Fleming– they trusted Murdaugh.

Murdaugh and was his best friend.

son, Paul Murdaugh

Murdaugh on many other cases.

not to trust him.

periodically about the status of their claims.

attached as Exhibit C and incorporated by reference.)

and incorporated by reference).

Representative of the Estate.

provide zealous and single-minded representation to a client.

36. By undertaking the representation, Murdaugh was effectively pursuing claims

against himself on behalf of the Plaintiffs.

37. Murdaugh undertook his representation despite the presence of an irreconcilable

accordance with the South Carolina Rules of Professional Conduct.

lawyer and client is defined by the reasonable expectations of the client.

their interests and the Estate’s interests, along with Murdaugh.

with a successor Personal Representative.

a concern that Tony would ask too many questions.

to communicate directly with Tony or Brian any longer.

Representative of the Estate over Westendorf.

Representative of Gloria’s estate, Murdaugh instead engaged Westendorf, as an officer of

Palmetto, to be the Successor Personal Representative for the Estate.

55. In order for Westendorf to be appointed as the Successor Personal Representative

his right to serve.

56. On October 31, 2018, Brian signed a second “Renunciation of Right to

both are incorporated by reference.)

“Renunciation of Right to Administration and/or Nomination and/or Waiver attached as Exhibit

H and incorporated by reference.)

to serve in favor of Westendorf.

59. It is through these Renunciations of Right to Administer that Westendorf was

appointed Successor Personal Representative of the Estate.

of wrongful death or survival.

order appointing him would be required.