Defamation and Conspiracy Lawsuit: Bryant v. Mace, et al.
In his counter-claims and Third-Party Complaint, Patrick Bryant alleges that Nancy Mace, along with Melissa Britton and Alexis Berg, defamed him and combined in a civil conspiracy to fabricate a false sexual assault and a false video in order to extort his property and ruin his reputation. Bryant pleads these claims inside the case Berg brought against him, Berg v. Bryant (2025-CP-10-03124). This page lays out the two central claims, defamation and conspiracy, the way the law frames them, using only documents that are on the public record: the pleadings themselves, sworn affidavits and deposition testimony, a recorded call that has been published, and Mace’s own filed Answer. Every box and every line below is sourced. These are allegations in a pending case; all three deny them, and no court has ruled.
How to read this page
Everything here is drawn from public court filings and sworn statements. The defamation and conspiracy claims described below are allegations made by Patrick Bryant in his counter-claims and Third-Party Complaint. Melissa Britton has moved to dismiss, arguing the complaint states no viable claim against her; Berg, too, has moved to dismiss Bryant's counter-claims. Nancy Mace, in her filed Answer, admits some of the underlying acts but maintains Bryant gave her permission to access his phone, denies hacking, and denies any conspiracy. Alexis Berg maintains that she was assaulted. No court has made any finding of fact on any of this; no criminal charges have been filed; the case is unadjudicated and ongoing. Bryant, for his part, denies the assault and voyeurism allegations made against him. The legend marks which statements come from a court filing and which come from an independently sworn source.
What the Lawsuit Pleads
Bryant’s pleading is in two parts: counter-claims against Berg, the woman who sued him, and a third-party complaint that brings in Mace and Britton. Together they plead the counts below. This page maps the two central claims, defamation and civil conspiracy, in full; the remaining counts are listed here for the complete picture. Every count is an allegation Bryant makes. All three deny them, and no court has ruled.
Against Alexis Berg
Bryant’s counter-claims
- Count I, Defamation. The false statements to a co-worker and in her sworn court filings. ¶¶72-82. Mapped in full below.
- Count II, Tortious Interference. Alleges Berg handed ADW’s and Bryant’s sensitive business information to Mace to disrupt his contracts and business relationships. ¶¶83-89.
- Count III, Civil Conspiracy. Alleges Berg furthered Mace and Britton’s plan by spreading the false account to ADW staff. ¶¶90-94. Mapped in full below.
Against Nancy Mace
Bryant’s third-party complaint
- Count I, Defamation. The false statement to political consultant Wesley Donehue. ¶¶98-104. Mapped in full below.
- Count II, Intentional Infliction of Emotional Distress. Alleges Mace accessed the phone, took private data, and threatened to release it unless Bryant transferred the two properties. ¶¶105-112. Documented at The Phone & the Files.
- Count III, Conversion. Alleges Mace wrongfully took and kept Bryant’s phone and extracted and deleted its data. ¶¶113-118. Documented at The Phone & the Files.
- Count IV, Invasion of Privacy. Alleges Mace intruded on the private photos and data on the phone and used them to threaten him. ¶¶119-127. Documented at The Phone & the Files.
- Count V, Civil Conspiracy. With Britton: the agreement to fabricate the assault and the video. ¶¶128-138. Mapped in full below.
Against Melissa Britton
Bryant’s third-party complaint
- Count V, Civil Conspiracy. With Mace: supplying the 2018 "diary email" and joining the agreement. ¶¶128-138. Mapped in full below.
- Count VI, Aiding and Abetting. Alleges Britton concealed the events and the "diary email" for years and disclosed them only after Mace approached her. ¶¶139-145. Mapped in full below.
The phone-based counts (conversion, invasion of privacy, and emotional distress) are documented at The Phone & the Files · Berg v. Bryant docket
The Defamation Claim
Bryant alleges two people defamed him: Berg, who repeated the accusations to a co-worker and swore them into her court filings, and Mace, who made the accusation to her political consultant. South Carolina defines defamation by a six-part test, and Bryant’s own filing recites it. Below is that test, who he says defamed him and to whom, and the two counts word for word. Read every line as "Bryant alleges." Berg maintains she was assaulted; Mace denies; Bryant denies the underlying accusations.
The Elements of Defamation, and How the Complaint Pleads Each
South Carolina defamation, under the standard Bryant’s own Memorandum in Support of Motion to Dismiss recites (citing Parker v. Evening Post Publishing Co.), has six parts. The top of each card is the legal element, quoted from that public filing. The bottom is how Bryant’s pleading alleges the element is met. The mapping is Bryant’s allegation, not a finding. As his filing puts it, "a communication is defamatory only if it is false and tends to impeach the plaintiff’s reputation."
- 1
The statement had a defamatory meaning.
Bryant alleges Berg and Mace branded him a rapist and a voyeur who secretly filmed women; the complaint pleads this is "defamation per se because she accused Bryant of... committing a crime."
Counter-Claims ¶¶73, 77; Third-Party Complaint ¶99
- 2
It was published with actual or implied malice.
Bryant alleges the statements were made "with a reckless disregard for the truth," and as to Mace "with the knowledge that her statements were false."
Counter-Claims ¶¶73, 80; Third-Party Complaint ¶101
- 3
It was false.
Bryant alleges there is no video and no assault took place, and that Berg spoke "without personal knowledge" while admitting she had "no memory."
Counter-Claims ¶¶5, 55, 73; Third-Party Complaint ¶101
- 4
It was published by the defendant.
Bryant alleges Berg published to an ADW co-worker and in her sworn court filings, and that Mace published to her political consultant, Wesley Donehue.
Counter-Claims ¶¶74-75, 78; Third-Party Complaint ¶99
- 5
It concerned the plaintiff.
Bryant alleges every statement named him or plainly identified him as the man who filmed and enabled the alleged assault.
Counter-Claims ¶73; Third-Party Complaint ¶99
- 6
It resulted in presumed or special damages.
Bryant alleges harm to his reputation, humiliation, emotional distress, and loss of personal and professional standing; a per se claim carries presumed damages.
Counter-Claims ¶¶77, 81; Third-Party Complaint ¶104
Who Bryant Says Defamed Him, and to Whom
Defamation needs a false statement, published to someone else. These are the two people Bryant’s pleading accuses, the specific statements he attributes to each, the third party each allegedly published to, and the public source for each. Read every row as "Bryant alleges." Both deny wrongdoing.
Alexis Berg
Alleged to have defamed Bryant to a co-worker and in her sworn court filings.
- On a February 2025 call to ADW employee Erin Gunther, Berg said Bryant filmed her being assaulted while unconscious, that he "is a really scary person who records women without them knowing," and is "a professional at hiding cameras" with "terabytes of other women," while admitting she had no memory and no firsthand knowledge.Counter-Claims ¶¶53-57, 78
- Repeated the assault-and-filming allegations in her sworn Jane Doe complaint and amended complaint, which placed them on the public record and, Bryant alleges, amplified the harm.Counter-Claims ¶¶74-75
- Bryant pleads this is defamation per se, because it accuses him of committing a crime.Counter-Claims ¶77
Nancy Mace
Alleged to have defamed Bryant to her political consultant, off the clock.
- Told political consultant Wesley Donehue that Bryant "recorded women without their consent and possessed illicit materials."Third-Party Complaint ¶99
- Donehue testified Mace showed him images she said came from Bryant’s phone and told him Bryant had "filmed women without their consent," the same statement the defamation count is built on.Donehue deposition
- Bryant pleads Mace made the statement "without privilege" and outside the scope of her office, before she had introduced any legislation on the subject or reported anything to law enforcement.Third-Party Complaint ¶¶100-103
How the Complaint Pleads It
Defamation is pleaded twice: once against Berg in Bryant’s counter-claims and once against Mace in his third-party complaint. Each is quoted verbatim below, and the stamped pages are reproduced beneath. The full filing is hosted at the end of the page.
Berg made false and defamatory statements regarding Bryant by falsely and with a reckless disregard for the truth, stating without personal knowledge that Bryant recorded women without their permission and by affirming Mace’s false and defamatory claims that Bryant and others committed rape and took nonconsensual photos of women, including underage girls... Berg’s statements constitute defamation per se because she accused Bryant of, among other things, committing a crime.
Amended Counter-Claims ¶¶73, 77
Mace made false and defamatory statements about Bryant to Donehue, claiming that Bryant recorded women without their consent and possessed illicit materials... Mace made these statements without privilege and with the knowledge that her statements were false and/or with a reckless disregard for the truth.
Third-Party Complaint ¶¶99, 101
The Conspiracy Claim
The second central claim is civil conspiracy: that Mace, Britton, and Berg combined to fabricate the assault and the video that the defamation above repeated. The rest of this page lays that claim out, the way the law frames it, from the same public record.
The Four Elements, and How the Complaint Pleads Each
South Carolina civil conspiracy, under the standard the parties brief in this case (Paradis v. Charleston County School District), requires four things. The top of each card is the legal element, quoted from the parties’ own memoranda. The bottom is how Bryant’s Third-Party Complaint alleges that element is met. The mapping is Bryant’s allegation, not a finding.
- 1
The combination or agreement of two or more persons.
Bryant alleges Mace and Britton agreed, after Mace first tried and failed with others, then drew in Berg.
Third-Party Complaint ¶¶2, 47-49, 133
- 2
To commit an unlawful act, or a lawful act by unlawful means.
Bryant alleges the object was to fabricate a false assault and a false video to extort property and ruin him.
Third-Party Complaint ¶¶4, 133-134
- 3
Together with the commission of an overt act in furtherance of the agreement.
Bryant alleges the overt acts included falsely communicating the 2018 events to Berg and recruiting her to sue.
Third-Party Complaint ¶¶135-137
- 4
And damages proximately resulting to the plaintiff.
Bryant alleges personal and professional damage from being branded a rapist and voyeur.
Third-Party Complaint ¶¶7, 138
Who Bryant Says Did What
A civil conspiracy needs two or more people acting together. These are the three roles Bryant’s complaint assigns, with the key acts he alleges for each and the public source for each act. Read every row as "Bryant alleges." All three deny these allegations.
Nancy Mace
Alleged to have initiated and directed the scheme.
- Bryant alleges Mace accessed his phone and extracted data, then sought to use it as leverage to obtain two jointly owned properties.TPC ¶¶26-30, 130
- Donehue testified Mace told him, "I’m going to use this information to get my houses," and that she declined to report it.Donehue deposition
- On the recorded April 6, 2024 call, Mace told Berg a "video" showed her being assaulted and steered her toward a lawsuit.April 6, 2024 call
Melissa Britton
Alleged to have supplied the foundational story and joined the agreement.
- Concealed a 2018 "diary email" for more than five years, disclosing it only after Mace approached her in early 2024.TPC ¶¶44, 47, 144
- Alleged to have met and "conspired to frame and defraud Bryant, Bowman, and Osborne" relating to the 2018 events.TPC ¶¶48, 133-134
- Is the sole trustee of Pommer Group LLC, which owns the home where the 2018 gathering occurred.TPC ¶43
Alexis Berg
Alleged to have furthered the scheme and filed the suit.
- Alleged to have "had no independent memory" of the events Mace described to her on the April 6, 2024 call.TPC ¶51
- Alleged to have told an ADW employee, Erin Gunther, of an assault while admitting she had no firsthand knowledge and that Mace was her only source.TPC ¶¶53-62
- Filed the underlying lawsuit on June 10, 2025.Public docket
Timeline of the Acts on the Record
The chronology Bryant lays out, every step tied to a public document. A navy tag marks a court filing; a red tag marks an independently sworn statement or a published recording. Dates and characterizations from the complaint are Bryant’s allegations.
- Aug. 2023
Mace places an AirTag on Bryant’s car for one day (she admits this in her Answer).
Mace Answer - Sept. 7, 2023
Mace asks Eric Bowman whether he "knew someone who could hack into a phone," then hours later says she has "taken care of it."
Bowman affidavit ¶¶3, 5 - Nov. 7-9, 2023
Per Donehue’s deposition, Mace showed him images she said came from the phone and said she would "use this information to get my houses"; he says he urged her to call police and she declined.
Donehue deposition - Nov. 13, 2023
Bryant alleges Mace used a data-recovery app ("Mr. Fone") on his phone; the same day, Mace’s attorneys send a preservation letter citing criminal voyeurism and warning of "disastrous financial consequences." In her Answer, Mace says she accessed hidden folders with a four-digit safe code Bryant gave her, and denies hacking.
TPC ¶¶27, 38; Answer - Jan. 8, 2024
At pre-suit mediation over the properties, Bryant alleges Mace used a folder of photos from his phone to pressure him to transfer ownership.
TPC ¶41 - Early 2024
Bryant alleges Mace and Britton met and that Britton, after five years of silence, disclosed her "diary email"; Bryant alleges the conspiracy was formed at this point.
TPC ¶¶47-48, 144 - Early April 2024
Per Berg’s complaint, Mace "contacted someone she thought might know" Berg and asked him to reach out; that go-between called Berg and asked if she would speak with Mace about Bryant. Berg’s public complaint identifies him only as "someone" and "he," and does not name him.
Berg complaint ¶¶100-101 - Apr. 6, 2024
Mace calls Berg, tells her a "video" on Bryant’s phone shows Berg being "gang raped" in 2018, and steers her toward a civil suit and damages. Mace’s 2024 campaign manager, John Mason Long, swears he witnessed the call.
April 6, 2024 call; Long affidavit - Aug. 2024
In separate meetings at The Dime on Daniel Island, Mace meets two of Bryant’s former girlfriends, Neely Kelleher and Ashleigh Messervy. Both swear in affidavits that Mace urged them to come forward as possible victims, and both say her claims were untrue (Messervy: Bryant "is not an abuser"; Kelleher: Mace told her Bryant "had HIV... None of it was true").
Kelleher & Messervy affidavits - Feb. 2025
Berg calls ADW employee Erin Gunther and repeats the accusations while, per Bryant, admitting she has no memory of any assault and that Mace is her only source.
TPC ¶¶53-62 - Early May 2025
Mace approaches Bryant’s former housekeeper, Vicki Pittman, at the Charleston airport and, per her sworn affidavit, presses her to corroborate hidden-camera claims; Pittman swears Mace was acting in a personal capacity and that she feared retaliation.
Pittman affidavit - May 9, 2025
Mace texts Kris Furniss, the ex-husband of Bryant’s girlfriend: "He is being investigated for potential wrongdoing and crimes committed against me and other women. I stand by every word in my floor speech February 10th... I would never allow my children or any other child or woman or girl around him. Period. End of story." The text is quoted as Exhibit X in the public Musgrave v. Mace federal opposition.
Musgrave opp. (Section 13) - May 17, 2025
Mace emails attorney Marybeth Mullaney: "I’d like to ask your thoughts about me also filing a suit against Patrick Bryant. After Ali files hers." (reproduced as an exhibit to Mace’s own later brief).
Mace brief, Ex. A - May 20, 2025
Chairing a House Oversight subcommittee hearing, Mace announces a congressional tip line for anyone "victimized by Patrick Bryant and any of his business partners" and reads the number, (843) 212-7048, into the official record.
May 20, 2025 House hearing - June 10, 2025
Berg files the underlying lawsuit (initially as "Jane Doe").
Public docket - Nov. 6 / Dec. 9, 2025
Bryant files, then amends, his Third-Party Complaint, naming Mace, Britton, and Berg and pleading civil conspiracy.
Third-Party Complaint - Dec. 2025 - Jan. 2026
Mace answers, admitting some acts while maintaining permission and denying hacking and conspiracy; Britton moves to dismiss, arguing the complaint "fails to state any viable claim against Ms. Britton."
Answer; Britton motion to dismiss
Other Women Mace Approached
Berg was not the only person Mace approached about Bryant. Three other women, two former girlfriends and a former housekeeper, swore affidavits describing meetings at which Mace urged them to come forward against him. Notably, none of them corroborated her: each swore, in her own filed affidavit, that what Mace told her was untrue or that she felt pressured. Each entry is that woman’s own sworn account; Mace denies wrongdoing and no court has ruled.
Neely Kelleher
Aug. 2024 · The Dime, Daniel Island
- A former girlfriend of Bryant’s. She swears Mace urged her to come forward and told her Bryant "had HIV," adding in her affidavit: "None of it was true."Kelleher affidavit
Ashleigh Messervy
Aug. 28, 2024 · The Dime, Daniel Island
- A journalist and former girlfriend of Bryant’s. She swears Mace said she was "notifying women" in videos on Bryant’s phone and told her, "I hacked into his [Patrick’s] computer and phone." She did not corroborate: "I say with confidence he is not an abuser."Messervy affidavit
Vicki Pittman
Early May 2025 · Charleston airport
- A former housekeeper for Bryant. She swears Mace approached her at the airport and pressed her to corroborate hidden-camera claims, that Mace was acting in a personal capacity, and that she feared retaliation.Pittman affidavit
These affidavits are each affiant’s own sworn statements, filed on the public record. They are reproduced in full, with the source documents, on The Phone & the Files.
The Congressional Tip Line
On May 20, 2025, chairing a House Oversight subcommittee hearing she convened, Mace announced a congressional tip line aimed by name at a single private citizen, on the official record and the congressional video stream. Unlike the rest of this page, this is not an allegation about Mace; it is Mace’s own public statement.
My office has a tip line that remains active for those who believe they may have been recorded, assaulted, or otherwise victimized by Patrick Bryant and any of his business partners. That number is (843) 212-7048.
May 20, 2025 House Oversight Subcommittee hearing (official congressional video)
The number she read out, (843) 212-7048, has stayed published on her official House press releases, including her November 2025 release announcing that "two additional women" had come forward, so the tip line she pointed at Bryant by name remains on the public record today. The Post and Courier reported the line was "flooded with calls." Bryant denies the underlying accusations; no criminal charges have been filed.
Watch the hearing → · Mace’s official press release · Post and Courier coverage
How the Complaint Pleads It
The conspiracy is pleaded in three counts of the public Third-Party Complaint. Each is quoted verbatim below, and the stamped pages are reproduced beneath. The full filing is hosted at the end of the page.
When Donehue refused, Mace turned to Britton and planned to perpetrate several unlawful acts against Bryant, Bowman, and Osborne and to inflict harm on them. They agreed to commit an unlawful act by unlawful means. Mace and Britton plotted to fabricate an alleged assault and the existence of an alleged video and e-mail and falsely representing the events that occurred in October 2018 to Berg.
Third-Party Complaint ¶¶133-134
Mace and Britton plotted to fabricate an alleged assault and the existence of an alleged video and e-mail and falsely representing the events that occurred in October 2018 to Berg. Berg furthered their conspiracy when she communicated with Gunther and other ADW employees.
Third-Party Complaint ¶¶91-93
Britton concealed the events that occurred on October 26, 2018, by not notifying Berg, or law enforcement. She further concealed the existence of an e-mail she allegedly authored the following morning describing the assault. Britton failed to disclose the existence of the e-mail or her first hand-knowledge of the assault until Mace approached her in early 2024, more than five-years later.
Third-Party Complaint ¶144
Britton’s 2018 "Diary Email"
The whole dispute turns on one document: an email Britton says she wrote to herself the morning after a 2018 pool party, describing an assault. Berg’s public complaint quotes it as the proof of what happened. Bryant’s filings call it concealed for years and, in a public sanctions motion, "a clearly doctored PDF." Both positions are on the public record and both are below. A separate, second diary, Mace’s own account of a January 2024 meeting, exists only inside a privileged text production and is not public, so it is not reproduced here.
The diary email’s authenticity is disputed and unresolved. Both the quotation and the challenge are reproduced from public filings; the site draws no conclusion about which is correct.
The diary email has its own dedicated page: the full text as Berg quotes it, the metadata and "doctored PDF" challenge Bryant raises, the timeline of when it surfaced, and why it sits at the center of the whole case.
The Phone Counts, Documented Elsewhere
Beyond defamation and conspiracy, Bryant’s third-party complaint pleads three more counts against Mace, and all three rest on the same set of facts: that she got into his phone and took its files. Rather than repeat that record here, this page routes it to the section that reproduces it in full, with Mace’s own sworn Answer responding to each of these counts and the affidavits and deposition of the people she spoke to. Each count below is Bryant’s allegation; Mace, in her Answer, admits accessing the phone but maintains it was permitted, denies hacking, and says she gave what she found to law enforcement.
Count III, Conversion
against Mace · Third-Party Complaint ¶¶113-118
- Bryant alleges Mace wrongfully took and kept his phone and "wrongfully extracted and deleted data" from it. In her sworn Amended Answer, Mace admits she accessed the phone and that data was transferred to another device, while maintaining it was permitted and provided to law enforcement.TPC ¶¶113-118
Count IV, Invasion of Privacy
against Mace · Third-Party Complaint ¶¶119-127
- Bryant alleges Mace intruded on the private photos and data on his phone and used them to threaten him into transferring the two properties. Mace’s Answer admits she accessed the phone and obtained photographs and information, and disputes the "without consent" framing.TPC ¶¶119-127
Count II, Emotional Distress
against Mace · Third-Party Complaint ¶¶105-112
- Bryant alleges Mace accessed the phone, obtained private data, and threatened to release it unless he signed over the properties. The count pleads the acts were "solely personal... without relationship to her position as a United States Congresswoman."TPC ¶¶105-112
See all three, with Mace’s own sworn admissions and the witness affidavits: The Phone & the Files → · Case docket
Bryant’s counter-claims also plead one further count against Berg, tortious interference (¶¶83-89), alleging she passed ADW’s and Bryant’s sensitive business information to Mace to damage his business; it is listed in the count map near the top of this page and is pleaded on the public docket. All of these are allegations; all parties deny them and no court has ruled.
Every Source Behind This Page
The documents the timeline and the combined-acts map are built on. Each is public: a filed pleading, a filed affidavit or deposition excerpt, a published recording, or an official report.
- Bryant’s Amended Third-Party Complaint Court filing the spine of this page (Dec. 9, 2025).
- Mace’s Answer to the Third-Party Complaint Court filing her admissions and denials (Dec. 19, 2025).
- The April 6, 2024 Mace-Berg call Sworn the recruitment call, published by FITSNews.
- Watch the clip: the money line, in her own words Sworn "easily all of us can get $150,000 each."
- Wesley Donehue deposition excerpt Sworn "I’m going to use this information to get my houses."
- Eric Bowman affidavit Sworn the "hack into a phone" request.
- John Mason Long affidavit Sworn witness to the April 6, 2024 call.
- Neely Kelleher affidavit, Vicki Pittman affidavit, and Ashleigh Messervy affidavit Sworn the recruitment pattern.
- Bryant’s opposition to the confidentiality order Court filing with the call and the Britton-Berg texts as exhibits.
- Office of Congressional Conduct report Official report the OCC’s report and referral (Mar. 2, 2026).
Related: The Phone & the Files · Berg v. Bryant docket · The federal removal · Melissa Britton