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EXHIBIT A
ELECTRONICALLY FILED - 2018 Dec 19 2:58 PM - HAMPTON - COMMON PLEAS - CASE#2018CP2500505
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ELECTRONICALLY FILED - 2018 Dec 19 2:58 PM - HAMPTON - COMMON PLEAS - CASE#2018CP2500505
ELECTRONICALLY FILED - 2021 Sep 27 10:06 AM - HAMPTON - COMMON PLEAS - CASE#2021CP2500298
ELECTRONICALLY FILED - 2018 Dec 19 2:58 PM - HAMPTON - COMMON PLEAS - CASE#2018CP2500505
ELECTRONICALLY FILED - 2021 Sep 27 10:06 AM - HAMPTON - COMMON PLEAS - CASE#2021CP2500298
 ELECTRONICALLY FILED - 2021 Sep 27 10:06 AM - HAMPTON - COMMON PLEAS - CASE#2021CP2500298
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 and Brian )

Harriott, )
)
Plaintiffs, )
) PRIORITY MATTER WITH
vs. ) ORAL ARGUMENT AND TESTIMONY
) UNDER OATH REQUESTED
Richard Alexander “Alex” Murdaugh, )
Chad Westendorf, Palmetto State Bank, )
Corey Fleming, and Moss, Kuhn & )
Fleming, P.A., )
)
Defendants. )

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

) CIVIL ACTION NUMBER: 2018-CP-25-0505
COUNTY OF HAMPTON )

Chad Westendorf, as Personal )

Representative of the Estate of Gloria )
Satterfield, )
)
Plaintiff, )
)
v. )
)
Richard A. Murdaugh, )
)
Defendant. )

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

)
COUNTY OF HAMPTON ) Docket Number:

In RE: Gloria Satterfield, )

)

Notice of Motion and Motion for

Civil Detention Pursuant to S.C. Code Ann. §15-17-20

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PLEASE TAKE NOTICE that Michael “Tony” Satterfield (“Tony”) and Brian Harriott

(“Brian”), by and through their undersigned counsel, hereby move before the Honorable Carmen

Mullen and/or such other Judge as may be assigned to hear this matter, for an Order requiring the

arrest and detention of Defendant Richard Alexander “Alex” Murdaugh in accordance with South

Carolina Code Section 15-17-20 1, until such time as the Defendant returns to the Petitioners the

property that he has fraudulently embezzled from them. THIS IS A PRIORITY MATTER AND

ORAL ARGUMENT AND TESTIMONY UNDER OATH IS REQUESTED. This motion is

based upon the following grounds, as well as upon such additional testimony, evidence and/or

argument as may be offered at the time of hearing:

1. Gloria Satterfield died on February 26, 2018, following a fall in the home of Alex

Murdaugh (“Murdaugh”).

2. After Gloria’s funeral, Murdaugh told the Satterfield family, and specifically

Gloria’s sons, Tony and Brian, that Gloria’s fall was his fault and that he would take Gloria’s sons

to an attorney for the purpose of making a legal claim against Murdaugh.

3. Gloria Satterfield had worked in the Murdaugh family home for over twenty (20)

years.

4. Gloria Satterfield and her family viewed themselves as an extension of the

Murdaugh family.

5. Tony and Brian trusted Murdaugh – and had no reason not to trust Murdaugh.

1
§ 15-17-20. ARREST IN CIVIL ACTIONS PERMITTED IN CERTAIN CASES.
The defendant may be arrested, as prescribed in this article, in the following cases:
(1) In an action for money received or property embezzled or fraudulently misapplied by a public officer, an
attorney, solicitor or counsellor, an officer or agent of a corporation or banking association in the course of
his employment as such or a factor, agent, broker or other person in a fiduciary capacity or in an action for
any misconduct or neglect in office or in a professional employment;

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6. Murdaugh introduced Tony and Brian to attorney Corey Fleming (“Fleming”),

whose job it would be to bring a claim against Murdaugh.

7. Murdaugh did not tell Tony and Brian that Fleming was Murdaugh’s former college

roommate, had previously worked with Fleming when he was a young attorney and/or that he was

the godfather of Murdaugh’s son, Paul.

8. Fleming was thereafter engaged for the purpose of representing the Estate of Gloria

Satterfield in making civil claims against Murdaugh.

9. Tony and Brian are the sole heirs of Gloria Satterfield and were to be the sole

beneficiaries of any proceeds of her Estate.

10. Tony was originally appointed to be the Personal Representative of the Estate of

Gloria Satterfield as was his statutory right. Brian had equal right to serve as Personal

Representative, but renounced his right to serve in favor of his brother, Tony.

11. By law, only the Personal Representative of an Estate in South Carolina has

standing to pursue wrongful death and/or survival claims.

12. In the fall of 2018, Fleming advised Tony and Brian that they would be better served

if Tony ceased his role as Personal Representative of his mother’s Estate and if that role were

entrusted to the Vice President of Palmetto State Bank, Chad Westendorf (“Westendorf”), as there

would be “business issues” arising that were beyond Tony’s experience.

13. Tony and Brian trusted Fleming and agreed to renounce their right to serve as

Personal Representative in favor of Westendorf.

14. At the time, Tony was not told of any meaningful developments in connection with

the claim, nor was Tony told of any settlement discussions let alone a settlement being reached.

15. Tony and Brian trusted Westendorf and Palmetto State Bank.

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16. On December 18, 2018, Westendorf was appointed by the Hampton County Probate

Court as the Personal Representative of the Estate of Gloria Satterfield and Tony was replaced.

17. One day later, on December 19, 2018, Fleming filed a Petition to Approved

Settlement in a matter captioned as Chad Westendorf, As Personal Representative of the Estate of

Gloria Satterfield, Plaintiff, v. Richard A. Murdaugh, Defendant, Action Number 2018-CP-25-

0505 (hereinafter the “Filed Petition” attached hereto as Exhibit A) 2.

18. In the Filed Petition, Fleming and Westendorf sought court permission to access a

“partial” settlement of the claims against Murdaugh in the sum of $505,000.00, while reserving

the right to pursue “additional insurance coverage that is applicable to this matter.”

19. Given that Westendorf was appointed on December 18 and the Filed Petition was

filed on December 19, it is reasonable to deduce that the “partial” settlement was achieved PRIOR

to Westendorf’s appointment and that the Filed Petition was held until AFTER his appointment.

20. Neither Tony, nor Brian, were told anything about the partial settlement.

21. Rather than ask the Court to hear the Filed Petition, Fleming did in fact continue to

pursue additional insurance policies, and through a mediation in March, 2019, was able to secure

an additional settlement in the amount of $3,800,000.00.

22. As neither Tony, nor Brian, served as the Personal Representative of his mother’s

estate, Tony, they did not participate in the mediation and were not informed of the final settlement.

23. All wrongful death settlements in South Carolina are contingent upon Court

approval.

2
In this entire sordid matter, this is the only filing with the court in connection with Gloria’s death other than a curious
dismissal that was filed in October 2020 which was signed by Fleming and Murdaugh. Additionally, this is the only
caption and court term that any settlement reached in connection with Gloria’s death could be used for a request of
the court to approve any settlements.
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24. No wrongful death settlement in South Carolina may be achieved without Court

approval.

25. As a result, parties to a wrongful death settlement agree conditionally to the terms

of settlement and thereafter petition the Court for permission to allow the Personal Representative

to accept the settlement.

26. In connection with the mediated settlement in this case, Westendorf conditionally

signed a Release on April 11, 2019, wherein it was agreed that the settlement payments would be

paid directly to Westerndorf. See Exhibit B attached hereto.

27. Upon information and belief, Fleming then prepared a new petition which he did

not file under the caption “In RE: Gloria Satterfield.” (hereinafter the “Unfiled Petition” a copy

of which is attached hereto as Exhibit C). 3

28. Further, the new petition did not have a case number assigned to it.

29. Neither Tony nor Brian were told anything about the settlements or the Unfiled

Petition.

30. While court orders are required to settle wrongful death claims in South Carolina,

it is not unusual that the attorneys involved in such cases call the clerks of the resident Judges to

coordinate convenient times to hear such matters.

31. Likewise, it is not uncommon that Judges entertain such requests either on formal

court record, in chambers or even remotely as an accommodation to the attorneys and to the

families of those who have lost a loved one.

32. These matters are routinely handled as a matter of mutual trust and respect between

the bench and the members the bar.

3
Upon information and belief Murdaugh requested that the attorneys take his name off the caption because he had
just been sued by the estate of Mallory Beach a couple months before and he didn’t want the Plaintiff’s counsel in that
case to know the insurance carriers that Murdaugh had.
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33. By whatever means the hearing is conducted, however, it is required that the matter

be made a part of the public record through the filing of a petition and the entry of an order granting

the petition.

34. Upon information and belief, Fleming’s office contacted Judge Mullen’s office to

report that a death settlement had been achieved and to request an in-chambers hearing to approve

the settlement.

35. Upon information and belief, Judge Mullen knew Fleming, knew Murdaugh, knew

their law firms, knew the defense attorneys who represented Murdaugh for his primary and excess

insurance policies and knew that they all enjoyed reputations (at least at that time) as excellent and

ethical lawyers.

36. Upon information and belief, Judge Mullen trusted the lawyers who were to appear

before her and had no reason not to trust them.

37. Upon information and belief, an in-chambers settlement hearing was held before

the Honorable Carmen Mullen on May 13, 2019.

38. Upon information and belief, present at the hearing were Fleming, Westendorf,

Murdaugh and the attorneys representing Murdaugh and/or his insurance carriers.

39. Tony was not present, was not told and was not invited.

40. Brian was not present, was not told and was not invited.

41. Upon information and belief, Judge Mullen was presented with the Unfiled Petition

for her consideration.

42. Upon information belief, Judge Mullen was not told material facts about the

proposed settlement and/or the Estate and was misled to believe that the beneficiaries of the Estate

were fully informed.

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43. In addition to the Unfiled Petition, Judge Mullen was presented with a “Settlement

Statement” and a Distribution Sheet, 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.”

44. Upon information and belief, on May 13, 2019, Judge Mullen was presented with

a proposed Order Approving Settlement for her consideration (“Order” a copy of which is attached

hereto as Exhibit D).

45. Upon information and belief, Judge Mullen trusted that the attorneys who

assembled before her would distribute the funds in accordance with the Distribution Sheet that she

was presented with and approved. 4

46. Upon information and believe, Judge Mullen’s trust was informed in part by the

South Carolina Rules of Professional Conduct which impose upon attorneys an absolute duty of

candor to the Court.

47. Upon information and belief, Judge Mullen was misled by:

a. Failing to advise Judge Mullen of the pending Filed Petition for $505,000.00;

b. Representing to Judge Mullen that the beneficiaries of the Estate of Gloria

Satterfield 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 Westerndorf

as the Personal Representative, and thereafter to the Beneficiaries.

4
At a later time, the undersigned will be questioning the $105,000.00 of “prosecution expenses” that were not properly
itemized and the failure to seek Court approval of a personal representative fee.

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48. 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 it in the court docket.

49. The Order approved “payment of the amounts set forth” in the Unfiled Petition and

on the Settlement Statement and allocated $50,000.00 to the survival claim, with the remaining

amount being the wrongful death settlement amount. 5

50. The Order did not approve any other payments.

51. 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 were to be

any deviation, an additional modified court order would have been required.

52. Upon information and belief, and in direct contravention of the Order, payments

were not made as set forth in the Petition and Settlement Statement.

53. The Beneficiaries were not paid the sum of $2,765,000.00.

54. The Beneficiaries were not paid a dime.

55. Upon information and belief, Murdaugh set up a bank account using the name

“Forge” for the purpose of creating the illusion that it was actually the structured settlement firm

known as Forge Consulting, LLC out of Atlanta, Georgia.

56. Upon information and belief, the Murdaugh “Forge” account was owned and

controlled exclusively by Murdaugh.

57. Upon information and belief, Murdaugh instructed Fleming to issue the check for

$2,765,000.00 that was otherwise to be paid to Tony and Brian as the beneficiaries of Gloria

Satterfield to “Forge” instead.

5
It was the duty of Westerndorf, an officer of the Probate Court not only to secure all of the settlement funds, but also
to ensure that the $50,000.00 survival claim was paid into the Probate Court into the estate.
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58. Upon information and belief, Fleming thereafter issued a check to the Murdaugh

“Forge” account in the amount of $2,765,000.00.

59. Through this deception, Murdaugh was able to embezzle and/or fraudulently

misapply the funds that were intended to be paid to Tony and Brian.

60. The present action is in part to recover money that was embezzled or fraudulently

misapplied by Murdaugh.

61. The Petitioners herein are entitled to and petition for an order in accordance with

South Carolina Code Section 15-17-20, directing the arrest and detention of Murdaugh and/or to

require Murdaugh post such bond as may be necessary to protect the Petitioners and to facilitate a

return of their property and/or settlement funds.

62. The Plaintiff requests a public evidentiary hearing into these matters with all

parties, including the defense attorneys in the underlying matter, to appear in court to be

placed under oath for examination.

WHEREFORE, the Plaintiff requests the relief requested herein, along with costs and

attorney’s fees to be awarded as the Court deems just and proper.

Columbia, South Carolina BLAND RICHTER, LLP

September 27 2021 Attorneys for Plaintiffs

s/Eric S. Bland
Eric S. Bland (SC Bar No. 64132)
1500 Calhoun Street
Post Office Box 72
Columbia, South Carolina 29202
Telephone 803.256.9664
Facsimile 803.256.3056
[email protected]

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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
[email protected]
[email protected]

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EXHIBIT C
 ELECTRONICALLY FILED - 2021 Sep 27 10:06 AM - HAMPTON - COMMON PLEAS - CASE#2021CP2500298
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.

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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,

)
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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.

.)
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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
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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

{
)
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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:

(>
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(

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
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EXHIBIT B
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t

I
STATE OF SOU'I'Ij CAROI-INA
IIEI.I}ASE
COUNTY OI.'HAMPI"ON

WIIEI{EAS, GI,ORIA SAT'TIIRFIIIII,D received injuries orr or about l.'ebrsari,

2,2018.
after fbllingdorvri the I'r'ont staix of a Colletorr County. South Carolirra
r.csiclencc or.r,ncclby Richarcl

Alexander MLrrdaugh and Marrgaret Mrrrdaughl

Wl'IEREAS. Cloria Sattetileld sustaincd iniulies in her fhll ancl subscquently

dicd. The
Estate of Cloria Satter{'ield made a clairr for hcr rvrongful death against Richard Alexander

Murdaugh; and

WHERF:AS, Chad Wcstendorf u,as cJul),appoirrtc.d personal Repr.esentative

olrhe hlstate of
Gloria sanerfield irr the Probate cou't lbr Hanrplorr courrtyr and

WHEREA S, Chad Westendorl-has obtained a1:proval of the Court lbr Harrrptol

County to

execute this instrurnent on behatf of the Estate of Gloria Sattcrfield and on

behalf of Decedent,s

statLrtoly bene liciaries; and

WHER[:AS. Certain Undernrritem at l-loyrl'.s, l.,onclon ("Brit Syrrdicates l-td") issucd

to

Richarcl Alcxander Murdar.rgh a honreowners liatiility policy, policy nunrber 883032101.,-5261.

effbctive January 6,20118 to January 6, 2019; and

WHEREAS, Nautilus lnsurance Contpany issuetJ to Iticharrl Alexander MLpdaugh a

personal umbrclla liability policy. policy nulllrel PLJ386804. effcctive. January 6.2018 to.lanuary 6,

20l9,and

NOW, TIJERF.FORE, I(NOW Al,l.. MEN nV f'ltnSn PRES[.':NTS that l, the Lrndersignecl.

Chad Wesrendor{, as Pffsonal RcpresentatiVc o[' the F.state of Gloria Sarted]elcl arrd Cloria

Satterfield's statutor5r beneflcialies, Michael Anthony Sarterflcld and Brian llarriott.

lbr a'd in

consideration of the sLlllr of I'our Million Three Flurrdred Five 'l'housand and 00/100
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(
($4,305,000.00) Dollars, total, including l''ive Ilundled Fivc'l'housand and 00/100 ($505.000.00)

Dollars paid by Brit Syrrdicates l-td, and Three tvlillion E,ight Hundred and 00i100
($3,800.000,00) Dollars paid by NaLrtilus lnsurnnce Conrpeuiy. Lo rne in harrd paid as Pcrsonal

Representative o1'the Estate of Gloria Sattcrt'icld {br thc bcnefit of tlrc staturory bcneficiaries ol

the Decedertt and Lhe Estate of Cloria Satterfield. the rcceipt and suf'ficiency of r,r,liich sunr is

hereby acl<norvledged, cJo hereby rclcasc and folcver clischarge Richarcl AlcxancJc'r Murdaugll

Margat'et Murdaugh; Nautilus lnsurancc Companyi Murphy & Crantland.. lr.A.; Brit Synclicates

Ltd.; and Cmmet, .lohnson, Wiggins & Associates, Inc.; their agents, sel'vants, employees,

successols, heils, executors, administmtors, and assigns; and any and all otlrer.pcr.sous. finrrs and

cot'porations ti'orn any and all actiorrs. causes of action, derrands and/or claims of arry nalure

rvhatsoever, which l, as Personal l{epresentative of the Estate o['Cloria Satterfield, and r,r,lrich thc

Decedent's statutoly beneliciarics may have against Richard Alcxander Murdaugh: Margalct

Muldar.rgh; Nautilurs Insurance Compan;,; MLrrphS, & Clarrtland.. P.A.; lSrit Syndicates l.td.; and

Cratrrer, .lohnson, Wiggins & Associates. Inc,; thcir agents, servants. employees. sLlccessors, hcils,

executors. adntinistlatots. and assigns; prior b and irrclLrcling tlre date hereotl on account oIor in

any way alising oLrt ol'the afbrcsaid accident. Thc consideratiorr cxpressed lrercin corrstituting lirll

paynent lor all danrages, losses arrd irrjuries fbllowing tlre accident albresaid. 'l'he consicleration

expressed herein nrust not be construed to constitute a release of any, person ol entity under any
policy of insumnce other than thc' insurarrce policies refercnccd in this docunrenl..

I further understand arrd agree that any subrogated or'third party intcrcsts including. but not

linrited to, medical charges u,iJl be satisfied in firll l'i'onr the ploceeds of this settlenGnt. and I agrce

to hold hannless and indenrnily Richard Alexarrder Murdaugh. do hcrebl, rcleasc and forever

discharge Richard Alcxander Murc{augh; Margarct MLrrdarrghl Nautilus lnsurancc Conrpanyl

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Murphy & Cruntland.. P'A.l Brit Syndicates l,(cj.tand Cmnrcr'..lohnson. Wiggins
& Associates.
Inc.; their agents. servants, enrployccs, successors. heirs, cxecutors,
administrato6. ancl assigns:

fi'ortt any and all liability or rcsponsibility with lcgarrl to such thircl-party
intercsts or lir..rrs.

J, the undersignecl, expt'essl1' rcllrescnt and warrarrt tlrat I unclerstancl

the cfl'ecr of the things

herein agreed to and that no staten'rcnts or representatioris nracle

by the persons rcleased nor their

agents, or representativcs have inllirenced me or induccd me to execute

and dcliver this Releasc.

It is ftlrther undetstood and agleeci that thE payment of the above said amoLrnts
is nor to be

constl'ued as an adntission of liability on the part o1'the persons r.eleased. Iiability 6eing expressly
derried.

All agreernellts and undcrstandirtgs betu,een tlre palties hercto are enrbodied hcrein and the

ternrs of this Release arc contractual and not a n.lere recital.

I have read the lbregoing l{elease and undcrsrancl it ro be a lirll. final. arrcl bincling

agrcentcnt.

lN WI'INESS WHEREOF, I have hereurito ser nr y hand and sealon this 11.,, i / lday of

20t9

WITl\ESSES
/.*
zr:rax#l$"y'I*FE- d.
Chad Westendorfl as Personal Representative
of thc l:istate ol'Gloria Sancrfield and re;:re.sentativc
ol'Michacl Anthony SatterllcltJ anci Brian l.larriotr
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EXHIBIT D
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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.
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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
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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
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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
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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,?