Mark Tinsley — Direct (Recall)

COURT CLERK: Please have a seat in the witness stand. State your name again for the record and spell your last name.

MARK TINSLEY: My name is Mark Tinsley, T-i-n-s-l-e-y.

MARK TINSLEY: Good.

MARK TINSLEY: Sure. As I said, my name is Mark Tinsley. I'm a lawyer; I practice in Allendale. I've been there since about 2000. I'm originally from --

MARK TINSLEY: The mic is short and my knees apparently are long because this is the most uncomfortable place to sit.

MARK TINSLEY: Yeah. I'm from Anderson originally. I went to Clemson. I carried an orange book bag when I was at Carolina; I went to law school there. I graduated in '98. I worked in Columbia for a couple of years doing primarily insurance defense work. You've heard a lot of plaintiffs lawyers, so I would have been one of the lawyers representing an insurance company that was hired to -- or had the coverage on somebody who was getting sued, or I would have dealt with coverage, the specific loss covered or something. So, that's primarily what I did for the first two years. One of my good friends was originally from Barnwell. I made my way to Allendale in 2000, and I've been there ever since.

MARK TINSLEY: I have. I practiced with Gooding and Gooding. You know, when you live in a small town, you do all kinds of things. I have the luxury of having a successful practice and being able to go to different places and handle cases. I try cases. I try truck wrecks. I try highway defect cases where there's something wrong with the way that the contractor had not really designed the roads but maintained the road and somebody gets catastrophically injured. I tried bad faith cases where an insurance company has coverage, but for some reason or another they don't do what they were supposed to do under the contract and their insured gets harmed as a result or suffers a loss. And so, you know, I pick and choose, but when you're in a small town you help people, and so I end up doing all kinds of things. There's no case that's too small, no case that's too big. If I can help you, I try and help you.

MARK TINSLEY: I have. You know, there's only 17 miles basically between Allendale and Hampton, small bars. At one time I think we really only had four or maybe five lawyers in Allendale and about twice -- maybe it ultimately gets up to three or four times that many in Hampton, but it's a small bar. And I had the occasion to work with -- you saw Ronnie Crosby, I think, yesterday. I've handled a number of cases with Ronnie Crosby. You've heard Lee Cope's name mentioned. I've had cases with Lee Cope. But I knew everybody.

MARK TINSLEY: It does.

MARK TINSLEY: You know, it's hard -- I heard Chris Wilson this morning. I don't remember exactly. I came in 2000. I always remember him being there, so sometime shortly after I came to practice in the 14th Circuit.

MARK TINSLEY: Sure. He's immediately to the right of Mr. Harpootlian.

MARK TINSLEY: You know, I hate to be a lawyer. I had a case where a defendant was in default and Alex was a special referee, meaning -- you may remember Chris Wilson said in that Mack Truck case one of the defendants didn't answer, and so if you get sued and you don't respond at the right time, then you're in default and so the other side by default wins generally. And Alex was my special referee, meaning this guy had been accused of selling some property under a lien and he was arrested at his job, and we sued the company called Southern Finance that incidentally went into bankruptcy. It's a long, complicated story, but we got reversed and so I didn't do that again, and then --

MARK TINSLEY: Well, yeah, but I didn't handle cases with Alex, unlike, say, Ronnie or Lee Cope, and we just didn't have that sort of relationship. You know, I guess he and I did so much of the same thing it just -- I don't recall a time over the last twenty years where we worked on a case together.

MARK TINSLEY: Oh, absolutely. I mean, it's a small bar and you go to the roster meetings, you know what everybody is doing and you see what cases they have, yeah, absolutely. You know if they have a success, a big case, or a failure.

MARK TINSLEY: Yes, probably a couple of times. There was -- he tried a case in Allendale. It was the first case -- I think it was '98 that the Allendale courthouse burned. The story was is that Judge Peeples from Barnwell was going to sentence some guy for a drug offense, and Judge Peeples was very strict on drug offenses, and so the guys who were going to be sentenced on Monday decided Sunday would be a good day to burn the courthouse, so they burned the courthouse. And so many months later I think Judge Peeples --

MARK TINSLEY: At any rate, they rebuilt the courthouse, and so the first case that was tried in 2005 Alex tried, and I was there when he made his closing arguments.

MARK TINSLEY: I was.

MARK TINSLEY: He cried.

MARK TINSLEY: '5. It was March of 2005. It was --

MARK TINSLEY: I think so.

MARK TINSLEY: Well, I mean, it is a roster. It is a list of cases. Generally a case comes up for trial -- in civil cases I'm talking about, supposed to be about a year old. It's usually longer than that, but they go on this list. And so come Monday morning all the lawyers would show up. There's 100 cases, and so you see what's coming up, who has what cases. In Hampton in particular, Alex usually had, it seemed, like a majority of the cases on the Hampton roster. His name would be on them anyway.

MARK TINSLEY: Sure. Lawyers are the biggest gossips in the world; I mean, everybody knew what everybody was doing.

MARK TINSLEY: No. I mean, it indicates they were settled. But often times when you go through the roster, there's actually a notation the case is settled. The judge will sign what's called a form order, which just administratively disposes of it; it takes it off the roster so it doesn't stay on that list.

MARK TINSLEY: Well, it's a lot like sitting in here. I mean, it's easier to pay attention than just sit there bored, so yeah, you pay attention to it.

MARK TINSLEY: I am very familiar. I represent the Beach family, and so I filed the boat case.

MARK TINSLEY: The family of Mallory Beach, that's right.

MARK TINSLEY: She did.

MARK TINSLEY: It was the early morning hours of February 24, 2019.

MARK TINSLEY: I was. Shortly after the wreck, there was an incident on the causeway. So, this crash happens. There's a bridge called -- you go over Archers Creek. Archers Creek is a creek that separates Parris Island, the Marine installation, from -- I guess that's Port Royal, and the boat crash happened at that bridge. There's a road -- if you can imagine the causeway, there's an old road that goes down to the base of the bridge, and after the boat cash they -- law enforcement had cordoned off, had a rope up or yellow flag, yellow tape up. And so Ms. Beach wanted to go down and see where her daughter had died, and she wasn't allowed --

MARK TINSLEY: She wasn't allowed to go down to the bridge. She was --

MARK TINSLEY: She was not. She was told it was a crime scene and she couldn't go down there.

MARK TINSLEY: Almost immediately thereafter --

MARK TINSLEY: Almost immediately thereafter, a car pulled up driven by Alex's father. His wife was in the front seat. Alex's wife, Maggie, was in the front seat. They were waved down to the bridge, and that caused her a great amount of distress.

MARK TINSLEY: That day I got involved.

MARK TINSLEY: I did. I started to investigate, but I started to try to put pressure on law enforcement, which is -- you know, I'm drawing the distinction there almost immediately because the concern was that it was going to get covered up -- by the Beach family -- and they didn't want that to happen.

MARK TINSLEY: I did.

MARK TINSLEY: I did. Well, I talked to a number of the partners, but after I began --

MARK TINSLEY: Yes, I'm sorry. But eventually I came to know that Danny Henderson was appointed as Alex's personal counsel, who was one of the partners. You may remember there was a video with Alex in the front seat of the law enforcement car, and the arm that reaches up and squeezes his shoulder while he's crying, that's Danny Henderson.

MARK TINSLEY: He brought me all of the insurance policies for all of the insurance that Alex had in place at the time of the boat crash.

MARK TINSLEY: Well, when you do what I do, we can't turn back the hands; we can't undo what has happened. And so, you know, the best that you can hope -- when you get a case like this, this kind of loss, nobody gets what their case is worth, if that means anything. I mean, nobody would willingly trade place with these people for money, but that's all that you can do in a civil case is recover money, and so some things are covered by insurance, some things are not. And so many times when we are drafting lawsuits, we want to know what insurance there was so that we try not to destroy the ability for the insurance to apply in the beginning. So, that would have been the reason I was looking at the insurance.

MARK TINSLEY: It seems like it was a week or ten days after the boat crash.

MARK TINSLEY: I did.

MARK TINSLEY: It did not appear to me that he had any coverage other than there was a policy with Progressive, a watercraft policy, that applied to the boat. It was $500,000, and it was offered by Progressive immediately. When you have a catastrophic loss, it's not unusual that an insurance company will say here, here is our money. Take it, please, because they have an obligation to protect their insured if they can. The other policies that he had didn't provide coverage except for a for-hire hunting operation, which this didn't arise out of, and so --

MARK TINSLEY: Philadelphia Insurance.

MARK TINSLEY: The occurrence, the accident, if you will, had to arise out of a hunting operation, a business operation. And if it -- even if there was some way to say that this boat ride this night did that, there were very specific watercraft exclusions that -- and excluded the coverage. So, accidents are covered, but then you have all of these exclusions that takes the coverage away, so there was no coverage.

MARK TINSLEY: And umbrella policy would be if you have a primary policy, say, on your car, the umbrella policy would sort of be the coverage. It could also apply to your house. Generally that coverage is -- the limits are multiples of maybe what your liability limits are, and it could be broader than just your house. It could apply to your house and your car. So, I don't remember. I think all of the coverage was with Philadelphia. I remember reviewing all of the policies. I don't remember if it was exactly what they were referring to this time.

MARK TINSLEY: There was no coverage for this boat crash other than with Progressive on the boat.

MARK TINSLEY: He had coverage. He had the coverage with Lloyds of London and Novice immediately before, which was the coverage that was in effect when Gloria Satterfield fell at his house, and he had an umbrella policy there.

MARK TINSLEY: The policy came up for renewal. Normally they're a year. It comes up for renewal and this claim is still open, and so when it came up for renewal, the insurance company wouldn't renew the policy and they canceled it, which is why he then went and bought this hunting club operation, or hunting for hire operation, whatever that policy was. It didn't really cover anything because he didn't have that kind of business.

MARK TINSLEY: It did not. I told Danny Henderson in November of 2019 that it did not. Philadelphia filed something called a declaratory judgment action where they go and ask the Court to declare their rights, meaning we don't have any coverage. It's clear the policy doesn't apply, judge. Tell in this case, the plaintiff because they sued us, the Beach family, and they sued Alex Murdaugh, too, for a declaration there was no coverage. I refused to participate. I said I would just be bound by whatever the result was because I knew what the result was going to be.

MARK TINSLEY: Well -- so, I believed that he was making lots of money. I told you that he had most of the cases, so if that's 50 percent or 60 percent of the cases that are actively resolving, he's actively making money. Money is coming in. Now, whether -- I knew that -- how the law firm worked in terms of they would get their money at the end of the year, that's not uncommon, but it doesn't really change the fact that he's making lots of money. And that didn't really change in the time that I knew him, but certainly it hadn't changed in the years immediately preceding the boat crash, and so the last three to five years.

MARK TINSLEY: The Progressive boat policy.

MARK TINSLEY: 500,000.

MARK TINSLEY: No, it wasn't. There were six people on the boat including Alex's son, Paul. So, there was one girl whose hand was pretty severely injured; she had about $130,000 in medical bills, a couple surgeries. You had one boy who was thrown into the console and had a broken jaw.

MARK TINSLEY: And his medical bills exceeded 100,000. So you've got a death, you've got two people with substantial medical bills, and there was just no way there was enough coverage at 500.

MARK TINSLEY: I don't know if it's as easy to answer that. But as I began to realize there was no coverage, it was clear that -- and often times when you have someone who is very affluent, who has a lot of money, it's not uncommon for those people to pay in addition to what they have in insurance, and so Alex was going to have to pay out of his own pocket to settle the cases.

MARK TINSLEY: I filed suit, I think, about a month after the boat crash. I filed suit before the criminal charges were bought.

MARK TINSLEY: Paul, I'm sorry.

MARK TINSLEY: I believe so.

MARK TINSLEY: I did.

MARK TINSLEY: So in the very beginning, if there was any chance at coverage, the allegations were that he knew that his son, Buster, his older son, Buster, who was twenty-one years old, had obtained a duplicate license, and that Paul was using that license to buy alcohol. And so it was -- it's sort of a -- Alex's lawyers from time to time characterized it as negligent parenting, but it's -- in the law you have this idea that there's this thing called negligent entrustment. You know that somebody drinks, you know that he has a propensity to drink in excess, get drunk, you give him your vehicle, you've created a hazardous situation, and so that's the liability against Alex. And so what I did in the very beginning in the first lawsuit was I drafted it to try to see if there could be coverage, even though I didn't think it was going to be successful.

MARK TINSLEY: He was.

MARK TINSLEY: Multiple times and very clearly.

MARK TINSLEY: Yes.

MARK TINSLEY: There is.

MARK TINSLEY: It started -- you first see the references back in -- I think it was the 40's and 50's, and it was is a way that if you're from out of state and you get sued in South Carolina, you have a right -- rather than being in state court like we have now, you could have it -- that case against you taken to federal court. And so often times what people would do to keep the out-of-state person from taking it to federal court and rather keep it in the county where they knew everybody is you would also sue someone in state, and so that was -- it was a venue defendant. Now -- and that kept the federal court from having what's called diversity. But in civil cases in state court, sometimes you do that. I mean, if there were two people driving a car -- driving two cars, two people involved in the wreck, you know, the passenger didn't cause the wreck, so you could sue both and let the jury sort out who it was, even though you believed that probably 99 percent of the liability is on one person, or maybe all of it's on one person. Juries do crazy things sometimes.

MARK TINSLEY: From the beginning and very clearly.

MARK TINSLEY: He was always going to have to pay, and pay a lot of money.

MARK TINSLEY: We do. Michael Gunn mentioned it. I think he called SCAG or -- I don't know, so I call it the trial lawyers conference. It was at the Westin at Hilton Head every year.

MARK TINSLEY: It's usually the first weekend of August. So, if that's 1st, 2nd, and 3rd or 4th, 5th, and 6th, but it's usually that first week of August.

MARK TINSLEY: I did.

MARK TINSLEY: I did.

MARK TINSLEY: Normally different law firms have dinners, and groups of lawyers -- because it's marketing, too, right? I mean, you go and you have dinners and you take other lawyers out who may send you cases or get you involved in cases. And so after dinner everybody sort of comes back to the hotel, and there at the Westin there's a gathering area. And I think it was a fundraiser either for Mr. Harpootlian or for Lindsey Graham, but there was a whole room of lawyers and he saw me. And this is the first sort of gathering, this little tension, I think, generally in the room about it, and then he beelines across the room and gets about this close.

MARK TINSLEY: Hey, Bo, what's this I've been hearing about what you've been saying? I thought we were friends.

MARK TINSLEY: I did. I told him that we were friends, that if he didn't think that I was going to do everything I needed to do to help my clients, that he was wrong and he needed to settle the case.

MARK TINSLEY: That's -- when he said what's this about what I've been hearing, I thought we were friends, that's what he was talking about. He didn't like the fact that I was saying he was going to have to come out of his pocket and pay.

MARK TINSLEY: The next year. So, that was August of '19. We don't have the mediation until September of '20.

MARK TINSLEY: We are. Which is you go and put witnesses under oath and you take their deposition and you examine them and you collect documents and those sorts of things. But we were taking depositions primarily of law enforcement, the people at the emergency room, that sort of thing.

MARK TINSLEY: Well, Covid began to shut the courts down. We continued to take some depositions, but ultimately I think it was probably April or May then we were sort of confined to our offices by then. So, in March we're still taking deposition of law enforcement, and it sort of slows down.

MARK TINSLEY: We -- we did.

MARK TINSLEY: I did. You know, one of -- there was a number of things that we knew existed that had not been collected by law enforcement and didn't appear to exist as far as law enforcement was concerned. And so, you know, for instance, I subpoenaed from the Department of Defense, I believe, and ultimately got all of the federal government's documents of affidavits and things of witnesses that were out there from Parris Island and --

MARK TINSLEY: It did.

MARK TINSLEY: Well, you know, they're sitting in the room. They may not know it until I bring it out, you know. The first lawyer asks questions and then the person may or may not be completely truthful and then you bring out the document, and so they're seeing it happen, and that's mainly with law enforcement. There were a number law enforcement depositions where that happened.

MARK TINSLEY: I did in this case.

MARK TINSLEY: Yes, and I was specifically interested in Beaufort County, and I can explain that if you want.

MARK TINSLEY: So, the alcohol was sold by a convenience store, Parker's Convenient Store, and Parker's lawyer at times would seem to act like Paul wasn't the driver, and at other times --

MARK TINSLEY: At other times he would go after law enforcement, specifically about that particular officer's connection with Alex Murdaugh or the Murdaughs in general. And so you really can't have it both ways, right? If Paul is not the driver, you don't really worry about the alcohol that was sold, then the connection with law enforcement sort of becomes irrelevant. So, he -- and it was clear what they were doing was they were trying to try a case that looked at all of the bad things. Don't let him get away with this because a verdict against Parker's. And so I was interested in if we went to Beaufort -- because I'm being told by Alex's lawyer that a Hampton jury won't return a verdict against him. And so what I'm trying to determine is if we go to Beaufort, is the evidence that I have uncovered so overwhelming that a jury ignores the clear breaches by Parker's company.

MARK TINSLEY: Absolutely.

MARK TINSLEY: I did. Also to Ronnie Crosby, who said that he would talk to Alex and -- I mean, I -- and then they wanted copies of some of the statements by the people that wanted to take everything he had.

MARK TINSLEY: This is May of '20.

MARK TINSLEY: Well, I was getting divorced.

MARK TINSLEY: Yeah. But, yeah. So -- but -- yeah. I think you're -- later in the summer, but --

MARK TINSLEY: Sure. There was a lot of push back about the shock that I would hold Alex personally responsible, make him pay. And then in August of '20, I figured out that I had cancer and -- but we continued to work. And then probably by November I knew how bad it was, and I knew that I was going to be gone, and so I tried to make arrangements to do things because I'm still having to decide -- the case is getting some age on it. We filed it pretty soon. A case that gets about a year old ought to go on the trial roster. We had mandatory mediation. We're going to mediate it in September, and then immediately after that it would be eligible for trial. We didn't settle the case, and in November I sent some requests to admit, which is -- in the law -- in civil cases, you know, it's all of this evidence, it's like I can -- here, you've seen this. You have to bring somebody in here that says I opened the car door, and then you bring the next guy in that says, well, I took the mats out. And if that's not disputed, then we can send something. It's a written question saying admit that it was daylight when this happened. Okay, we'll admit that. So, we don't have to call somebody in. And so it's admitting certain facts to be true, and then those things are taken as true and we don't have to present them. So, I had made up my mind that I was going to send the case to Beaufort after the focus groups, and I was going to try the case in Beaufort. So, I sent requests to admit in November of '19 before I was about to leave to go to Florida for my cancer treatment.

MARK TINSLEY: The sorry, in November of '20. I think it was November the 19th, but --

MARK TINSLEY: Oh, yeah.

MARK TINSLEY: Yeah. And, you know --

MARK TINSLEY: Sure.

MARK TINSLEY: Ultimately I have that conversation. They pushed me for a number. By November I've given them a number, yes.

MARK TINSLEY: That number -- he was going to have to pay 10 million out of his pocket.

MARK TINSLEY: That he might could cobble together a million dollars, that he was broke.

MARK TINSLEY: He was broke.

MARK TINSLEY: Maybe he could get a million.

MARK TINSLEY: No. I didn't believe it at all.

MARK TINSLEY: If you're broke, I'm happy to work out a payment plan; you can make payments. You can convey Moselle. I knew he had Moselle. He had got Moselle right after a big settlement in 2012, so that's 1700 acres. Convey Moselle, convey the beach house, he still had the house in Hampton, and we'll work out a payment plan on the rest.

MARK TINSLEY: He did.

MARK TINSLEY: I did, in October. Almost immediately after the mediation I served some discovery, again it's a written question, and there are two different types. There's interrogatories where you ask a question: tell me where you bank. And then there could be requests for production: give me your bank records. Now, mine didn't say that, but, I did -- I sent discovery to --

MARK TINSLEY: There's no way. I mean, like I said, he has a spicket of money that's running. He's settling cases. He's got big cases; he's got lots of cases. He's got general wealth. There's no way -- he's got 1800 acres in Moselle. He's not broke by anybody's standards.

MARK TINSLEY: I did.

MARK TINSLEY: No.

MARK TINSLEY: It led me to send discovery to get that information.

MARK TINSLEY: Well, it was broad, so it was broader than this. But what I was looking for was the institution, the accounts where he did his banking, because if he was, in fact, broke, if his bank account says zero or $5,000 or $7,000, it was because he was doing -- he was hiding it in my opinion at the time. So, that's what I was looking for.

MARK TINSLEY: I did.

MARK TINSLEY: They objected almost immediately.

MARK TINSLEY: I did. I filed what's called a motion to compel where I asked the judge to compel, or make him give me the information.

MARK TINSLEY: I do. It's the motion to compel that I filed with two -- three exhibits, which are his lawyer's responses, the objection to the questions.

MARK TINSLEY: The motion to compel was filed October the 16th of 2020.

MARK TINSLEY: That's right.

MARK TINSLEY: Correct.

MARK TINSLEY: That's right.

MARK TINSLEY: Yeah. What you see there is the bold -- the answer is, so this is -- Alex's lawyer has retyped the questions that I sent. So, that's the question that I wrote: Number 1, list all checking and/or savings accounts, including credit union accounts, certificates of deposit, 401(k) accounts, SEP accounts, IRA's maintained by you individually and/or jointly with any others, and any other accounts over which you had signature authority. Or maybe it's: Any capacity regardless of whether or not the account or accounts had been closed from February of 2019 to present. And then the answer is what his lawyer said, which is generally an objection: it's overbroad, it's unduly burdensome, it's not relevant, doesn't have anything to do with it.

MARK TINSLEY: That's right.

MARK TINSLEY: So, I knew some information. I would have verified that he was telling me the truth, right? So, I -- some things I'm verifying, but I would have ultimately sent subpoenas to the banks and then I would have begun to subpoena the accounts. I mean, I know he's got a personal account, I know that the law firm has got accounts, but he's got these other entities, these partnerships and things. I didn't know if he had accounts there. So, that would have been what would have happened next.

MARK TINSLEY: I knew about Palmetto State Bank, and I believe that I knew about Bank of America.

MARK TINSLEY: Not a clue.

MARK TINSLEY: Yeah. The subpoena to Bank of America wouldn't have said give me the information for account 102 or whatever the number was. It would have been for all accounts that have his name on it period in any capacity, so it would have been very broad.

MARK TINSLEY: That's exactly what it was, and I was doing it like -- you heard Chris Wilson talk about this, that Mack Truck case that the defendant didn't want this to happen. Well, this is normal in a civil case. There's lots of times that defendants don't want certain things to happen, and so if they don't want it, that's what I want. And so I'm putting pressure where I can put pressure, and this is a place that I can put pressure. At the time I think it's because he's making so much money, he doesn't really want us to know how much money he's making.

MARK TINSLEY: It took awhile. You know, covid wasn't over but the courts weren't really running. There were some courts -- when the Chief Justice began to open the court system back up, they had to have a some kind of Covid plan in place. Hampton wasn't one of them. This case had been specially assigned to a judge from Lancaster, and so there weren't any real opportunities to get the motion heard at that time.

MARK TINSLEY: I first filed the lawsuit in its first draft in Beaufort County.

MARK TINSLEY: By November I've pretty well made up my mind that I'm going to move it back to Beaufort County. And it's not just that I'm moving it back. It's that Parker's was also -- had a motion, so I could consent to its motion to move the case back.

MARK TINSLEY: That's right.

MARK TINSLEY: He was insistent.

MARK TINSLEY: Yes. While I was in Florida, beginning in January Mr. Parker, who owned Parker's Convenience Store, began to do a number of things that I thought would weigh against me going to Beaufort County.

MARK TINSLEY: Not until I got back from my treatment in mid-April.

MARK TINSLEY: You said Hampton and I think you meant Beaufort.

MARK TINSLEY: No, I'm in Hampton. I filed it initially against Luther's, which was a bar after -- so, the kids launched the boat from Alex's family place and it's owned by a family trust, Murdaugh Family Trust. Maybe there are two properties and there's two trusts. I sued Alex's father, I sued the trust because there could have been that alcohol was provided there. It turned out it wasn't, but the kids drank and launched the boat from there, and then they went an oyster roast. I then sued the people who had the oyster roast. From there they went to a bar called Luther's where Paul had two shots, and so I sued Luther's. And I sued Alex. And I'm not 100 percent certain in that first lawsuit whether I sued Buster or not, but I ultimately did sue Buster.

MARK TINSLEY: Yes, I did.

MARK TINSLEY: It was, and the motions were coming up. I mean, it was -- you know, I had been gone for four months or whatever it is, four and a half months, and so the motions are set to be heard, and there are a number of motions. Parker's, as I said, had filed this motion to transfer the case to Beaufort before I left.

MARK TINSLEY: Not -- I think you keep -- you're still getting Beaufort and Hampton mixed up, so not exactly. I was --

MARK TINSLEY: Okay. There was -- there were a number of reasons that I wanted the case in Beaufort. I had substantial evidence. One of the things that we didn't talk about, when you have a seventeen, eighteen, nineteen-year old girl, which I have, she constantly has her phone, she's constantly taking videos. And so one of things that I discovered was is that Paul's girlfriend had tons of videos: videos of alcohol, family trips, videos of Paul drinking in front of his parents, videos of him grossly intoxicated. And so that evidence I shared with Alex's lawyers as well leading up to it. I didn't share it -- they didn't serve the same discovery on me because they didn't want the other defendant, Greg Parker's, to have it at that time because they were so entrenched in that there was some sort of venue friendly lawsuit going on between Alex and myself, but there wasn't.

MARK TINSLEY: So, once I made the --