The Conspiracy Claim
In his Third-Party Complaint, Patrick Bryant alleges that Nancy Mace, Melissa Britton, and Alexis Berg combined to fabricate a false sexual assault and a false video in order to extort his property and ruin his reputation. This page lays out that claim the way the law frames it, using only documents that are on the public record: the complaint itself, 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 conspiracy described below is an allegation made by Patrick Bryant in his Third-Party Complaint. Melissa Britton has moved to dismiss it, arguing it states no viable claim against her. 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.
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.
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.
- 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