Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
observationobservation
EDVA Document 197-15; declaration executed and filed 22 April 2026.
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
observationobservation
Paragraph 7: P000043846; paragraph 8: P000043836.
Read the anchor · page 2
manufacturing, assemblage, headquarters, origination and all other documents referred to in the
Memorandum.
7. The government issued a stop work order on the HII P000043846 Subcontract
with CYBL on December 22, 2023.
8. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
9. I have reviewed all corporate Over the Counter Markets (OTC) filings for CYBL
between 2022 and the current date.
10. OTC filings are required quarterly and are made under oath by an authorized
corporate officer.
11. Fairwinds, ARG and the WeShield parties are not designated as debt holders of
CYBL for any quarter(s) prior to the present Interpleader action.
12. The same corporate filings do not reflect commissions owed or contracts entered
with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only
after the Inter-Pleader action commenced.
I declare the foregoing is true and accurate to the best of my knowledge under penalty of
perjury.
Executed on April 22, 2026 BY:_______________________________________
William Welter
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 2 of 2 PageID# 4358[Visual signature verification: a visible signature reading William Welter appears on the execution line, above the printed name; dated April 22, 2026.]
claimallegation
William Welter’s second declaration on behalf of Atlantic Wave Holdings and Secure Community is filed as EDVA 3:25-cv-00483-JAG Document 197
William Welter’s second declaration on behalf of Atlantic Wave Holdings and Secure Community is filed as EDVA 3:25-cv-00483-JAG Document 197-15 on 22 April 2026. He declares under penalty of perjury and a visible William Welter signature appears above the printed name; native extraction alone omits the signature.
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
claimallegation
Welter states he is over 21, competent, managing director of both creditor entities, familiar with Cyberlux through litigation since 2022, a
Welter states he is over 21, competent, managing director of both creditor entities, familiar with Cyberlux through litigation since 2022, and leads their enforcement in Texas, California and Virginia. This identifies an interested enforcement role, not an independent witness to every underlying transaction.
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
claimallegation
He reports three unsuccessful removal actions remanded to state court, a defeated mandamus petition, appeal and appellate motions, numerous
He reports three unsuccessful removal actions remanded to state court, a defeated mandamus petition, appeal and appellate motions, numerous unsuccessful trial motions, and more than four sanctions granted against Cyberlux. The declaration does not identify every case/order or attach those rulings; it is his summary, not an independently counted docket audit.
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
claimallegation
Paragraph 6 says the summary-judgment memorandum’s factual representations are accurate insofar as he participated in producing or reviewed
Paragraph 6 says the summary-judgment memorandum’s factual representations are accurate insofar as he participated in producing or reviewed them during litigation, including Catalyst acquisition, OTC filings, agreements, UCC filings, orders and locations. This combines participation and document review rather than claiming personal observation of every event.
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
claimallegation
Paragraph 7 states the government issued a stop-work order on HII subcontract P000043846 on 22 December 2023. Paragraph 8 states HII termina
Paragraph 7 states the government issued a stop-work order on HII subcontract P000043846 on 22 December 2023. Paragraph 8 states HII terminated P000043836 on 17 May 2024. The printed numbers differ by one digit; the declaration alone does not establish whether paragraph 8 is a typographical error or a different identifier.
Read the anchor · page 2
manufacturing, assemblage, headquarters, origination and all other documents referred to in the
Memorandum.
7. The government issued a stop work order on the HII P000043846 Subcontract
with CYBL on December 22, 2023.
8. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
9. I have reviewed all corporate Over the Counter Markets (OTC) filings for CYBL
between 2022 and the current date.
10. OTC filings are required quarterly and are made under oath by an authorized
corporate officer.
11. Fairwinds, ARG and the WeShield parties are not designated as debt holders of
CYBL for any quarter(s) prior to the present Interpleader action.
12. The same corporate filings do not reflect commissions owed or contracts entered
with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only
after the Inter-Pleader action commenced.
I declare the foregoing is true and accurate to the best of my knowledge under penalty of
perjury.
Executed on April 22, 2026 BY:_______________________________________
William Welter
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 2 of 2 PageID# 4358[Visual signature verification: a visible signature reading William Welter appears on the execution line, above the printed name; dated April 22, 2026.]
claimallegation
Welter says he reviewed all Cyberlux OTC filings from 2022 to the declaration date and describes quarterly filings as sworn corporate-office
Welter says he reviewed all Cyberlux OTC filings from 2022 to the declaration date and describes quarterly filings as sworn corporate-officer submissions. He asserts Fairwinds, ARG and WeShield parties were not designated debt holders in quarters before this interpleader; the underlying reports and quarter-by-quarter search results are absent.
Read the anchor · page 2
manufacturing, assemblage, headquarters, origination and all other documents referred to in the
Memorandum.
7. The government issued a stop work order on the HII P000043846 Subcontract
with CYBL on December 22, 2023.
8. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
9. I have reviewed all corporate Over the Counter Markets (OTC) filings for CYBL
between 2022 and the current date.
10. OTC filings are required quarterly and are made under oath by an authorized
corporate officer.
11. Fairwinds, ARG and the WeShield parties are not designated as debt holders of
CYBL for any quarter(s) prior to the present Interpleader action.
12. The same corporate filings do not reflect commissions owed or contracts entered
with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only
after the Inter-Pleader action commenced.
I declare the foregoing is true and accurate to the best of my knowledge under penalty of
perjury.
Executed on April 22, 2026 BY:_______________________________________
William Welter
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 2 of 2 PageID# 4358[Visual signature verification: a visible signature reading William Welter appears on the execution line, above the printed name; dated April 22, 2026.]
claimallegation
He further says those filings do not reflect commissions owed or contracts entered with Fairwinds or ARG, and WeShield parties were mentione
He further says those filings do not reflect commissions owed or contracts entered with Fairwinds or ARG, and WeShield parties were mentioned only after interpleader commenced. This is a claimed absence from reviewed disclosures, not proof that no underlying agreement, obligation or equitable claim existed.
Read the anchor · page 2
manufacturing, assemblage, headquarters, origination and all other documents referred to in the
Memorandum.
7. The government issued a stop work order on the HII P000043846 Subcontract
with CYBL on December 22, 2023.
8. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
9. I have reviewed all corporate Over the Counter Markets (OTC) filings for CYBL
between 2022 and the current date.
10. OTC filings are required quarterly and are made under oath by an authorized
corporate officer.
11. Fairwinds, ARG and the WeShield parties are not designated as debt holders of
CYBL for any quarter(s) prior to the present Interpleader action.
12. The same corporate filings do not reflect commissions owed or contracts entered
with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only
after the Inter-Pleader action commenced.
I declare the foregoing is true and accurate to the best of my knowledge under penalty of
perjury.
Executed on April 22, 2026 BY:_______________________________________
William Welter
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 2 of 2 PageID# 4358[Visual signature verification: a visible signature reading William Welter appears on the execution line, above the printed name; dated April 22, 2026.]
entityobservation
William Welter
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
entityobservation
Atlantic Wave Holdings, LLC
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
entityobservation
Secure Community, LLC
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
entityobservation
Cyberlux Corporation
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
entityobservation
Catalyst Machineworks, LLC
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
entityobservation
Fairwinds
Read the anchor · page 2
manufacturing, assemblage, headquarters, origination and all other documents referred to in the
Memorandum.
7. The government issued a stop work order on the HII P000043846 Subcontract
with CYBL on December 22, 2023.
8. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
9. I have reviewed all corporate Over the Counter Markets (OTC) filings for CYBL
between 2022 and the current date.
10. OTC filings are required quarterly and are made under oath by an authorized
corporate officer.
11. Fairwinds, ARG and the WeShield parties are not designated as debt holders of
CYBL for any quarter(s) prior to the present Interpleader action.
12. The same corporate filings do not reflect commissions owed or contracts entered
with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only
after the Inter-Pleader action commenced.
I declare the foregoing is true and accurate to the best of my knowledge under penalty of
perjury.
Executed on April 22, 2026 BY:_______________________________________
William Welter
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 2 of 2 PageID# 4358[Visual signature verification: a visible signature reading William Welter appears on the execution line, above the printed name; dated April 22, 2026.]
entityobservation
ARG
Read the anchor · page 2
manufacturing, assemblage, headquarters, origination and all other documents referred to in the
Memorandum.
7. The government issued a stop work order on the HII P000043846 Subcontract
with CYBL on December 22, 2023.
8. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
9. I have reviewed all corporate Over the Counter Markets (OTC) filings for CYBL
between 2022 and the current date.
10. OTC filings are required quarterly and are made under oath by an authorized
corporate officer.
11. Fairwinds, ARG and the WeShield parties are not designated as debt holders of
CYBL for any quarter(s) prior to the present Interpleader action.
12. The same corporate filings do not reflect commissions owed or contracts entered
with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only
after the Inter-Pleader action commenced.
I declare the foregoing is true and accurate to the best of my knowledge under penalty of
perjury.
Executed on April 22, 2026 BY:_______________________________________
William Welter
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 2 of 2 PageID# 4358[Visual signature verification: a visible signature reading William Welter appears on the execution line, above the printed name; dated April 22, 2026.]
eventattribution
Welter signs second declaration and it is filed in the interpleader.
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
inferenceinference
Welter’s source foundation combines his enforcement participation with review of documents; his organisational interest and derivative basis
Welter’s source foundation combines his enforcement participation with review of documents; his organisational interest and derivative basis should remain visible when weighing the assertions.
inferenceinference
A claimed failure to disclose a debt or contract does not by itself disprove its existence. The precise disclosure obligations, report dates
A claimed failure to disclose a debt or contract does not by itself disprove its existence. The precise disclosure obligations, report dates and underlying instruments are separate tests.
otherattribution
Complete supplied 2-page source reviewed at SHA-256 1476294ff7c9f9f51d21bf31a38c9312a6dd9a2b9d10a35fb0befe34121c22d6. Source assertions, ori
Complete supplied 2-page source reviewed at SHA-256 1476294ff7c9f9f51d21bf31a38c9312a6dd9a2b9d10a35fb0befe34121c22d6. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Both native-text pages and own images fully read. Signature visibly present on page 2, despite absent native extraction. Printed subcontract identifiers and negative-disclosure scope preserved exactly.
Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
v. Case Number: 3:25cv483
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC
WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1. My name is William Welter and I am over the age of 21 years and competent.
2. I am the Managing Director of Atlantic Wave Holdings, LLC (“AWH”) and
Secure Community, LLC (“SC”).
3. I am familiar with Cyberlux Corporation (“CYBL”) having been in litigation with
CYBL since 2022.
4. I lead the enforcement of AWH’s and SC’s rights against Cyberlux in Texas,
California and Virginia. In Texas and California, Atlantic Wave defended three attempted
unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one
Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were
all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5. In total, AW sought and was granted more than four sanctions against Cyberlux
by the various courts.
6. I am personally familiar with all of the factual representations asserted in the
Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I
either participated in their production or reviewed them as part of my litigation efforts. This
would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL,
the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
Case 3:25-cv-00483-JAG Document 197-15 Filed 04/22/26 Page 1 of 2 PageID# 4357
questionquestion
Which stop-work and termination instruments support the two dates and resolve P000043846 versus P000043836?
questionquestion
Which specific OTC filings, disclosure fields and underlying agreements support or qualify the negative-disclosure conclusions?
questionquestion
Does the declaration alone disprove other claimants’ contracts or establish the termination identifier?
claimallegation
No commissions or contracts reflected for Fairwinds or ARG
Corporate OTC filings do not reflect commissions owed or contracts entered with Fairwinds entity or ARG entity.
Read the anchor · page 2
The same corporate filings do not reflect commissions owed or contracts entered with any of the Fairwinds entity, or the ARG entity.
allegation
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
fairwinds arg and weshield parties are not designated as debt holders of cyberlux for any quarter s prior to the present interpleader actionrelates to{"chapter":28,"exposure_lens":"The acquisition-chain inquiry locates the official owner of each technical, financial and contractual decision before drawing any conclusion from institutional involvement.","responsibility":"Requirement, contract vehicle, delegated authority, contracting decisions and settlement review.","sequence":328,"unit_key":"CH28"}
The controlling book database maps this allegation into Part II; the book's explicit control-to-exposure crosswalk places that responsibility in Part III, Chapter 28. This is an identifier-based publication link, not a name match.
corporate otc filings do not reflect commissions owed or contracts entered with fairwinds entity or arg entityrelates to{"chapter":28,"exposure_lens":"The acquisition-chain inquiry locates the official owner of each technical, financial and contractual decision before drawing any conclusion from institutional involvement.","responsibility":"Requirement, contract vehicle, delegated authority, contracting decisions and settlement review.","sequence":328,"unit_key":"CH28"}
The controlling book database maps this allegation into Part II; the book's explicit control-to-exposure crosswalk places that responsibility in Part III, Chapter 28. This is an identifier-based publication link, not a name match.
Corporate OTC filings do not reflect commissions owed or contracts entered with Fairwinds entity or ARG entity.supportscorporate otc filings do not reflect commissions owed or contracts entered with fairwinds entity or arg entity
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
Fairwinds, ARG and WeShield parties are not designated as debt holders of Cyberlux for any quarter(s) prior to the present interpleader action.supportsfairwinds arg and weshield parties are not designated as debt holders of cyberlux for any quarter s prior to the present interpleader action
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
Paragraph 7 states the government issued a stop-work order on HII subcontract P000043846 on 22 December 2023. Paragraph 8 states HII terminated P000043836 on 17 May 2024. The printed numbers differ by one digit; the declaration alone does not establish whether paragraph 8 is a typographical error or a different identifier.supportsWhich stop-work and termination instruments support the two dates and resolve P000043846 versus P000043836?
Specifically named source propositions support the bounded distinction or question.
He further says those filings do not reflect commissions owed or contracts entered with Fairwinds or ARG, and WeShield parties were mentioned only after interpleader commenced. This is a claimed absence from reviewed disclosures, not proof that no underlying agreement, obligation or equitable claim existed.supportsWhich specific OTC filings, disclosure fields and underlying agreements support or qualify the negative-disclosure conclusions?
Specifically named source propositions support the bounded distinction or question.
Paragraph 6 says the summary-judgment memorandum’s factual representations are accurate insofar as he participated in producing or reviewed them during litigation, including Catalyst acquisition, OTC filings, agreements, UCC filings, orders and locations. This combines participation and document review rather than claiming personal observation of every event.supportsWelter’s source foundation combines his enforcement participation with review of documents; his organisational interest and derivative basis should remain visible when weighing the assertions.
Specifically named source propositions support the bounded distinction or question.
Welter says he reviewed all Cyberlux OTC filings from 2022 to the declaration date and describes quarterly filings as sworn corporate-officer submissions. He asserts Fairwinds, ARG and WeShield parties were not designated debt holders in quarters before this interpleader; the underlying reports and quarter-by-quarter search results are absent.supportsDoes the declaration alone disprove other claimants’ contracts or establish the termination identifier?
Specifically named source propositions support the bounded distinction or question.
Welter says he reviewed all Cyberlux OTC filings from 2022 to the declaration date and describes quarterly filings as sworn corporate-officer submissions. He asserts Fairwinds, ARG and WeShield parties were not designated debt holders in quarters before this interpleader; the underlying reports and quarter-by-quarter search results are absent.supportsWhich specific OTC filings, disclosure fields and underlying agreements support or qualify the negative-disclosure conclusions?
Specifically named source propositions support the bounded distinction or question.
He further says those filings do not reflect commissions owed or contracts entered with Fairwinds or ARG, and WeShield parties were mentioned only after interpleader commenced. This is a claimed absence from reviewed disclosures, not proof that no underlying agreement, obligation or equitable claim existed.supportsDoes the declaration alone disprove other claimants’ contracts or establish the termination identifier?
Specifically named source propositions support the bounded distinction or question.
Paragraph 7 states the government issued a stop-work order on HII subcontract P000043846 on 22 December 2023. Paragraph 8 states HII terminated P000043836 on 17 May 2024. The printed numbers differ by one digit; the declaration alone does not establish whether paragraph 8 is a typographical error or a different identifier.supportsDoes the declaration alone disprove other claimants’ contracts or establish the termination identifier?
Specifically named source propositions support the bounded distinction or question.
Welter states he is over 21, competent, managing director of both creditor entities, familiar with Cyberlux through litigation since 2022, and leads their enforcement in Texas, California and Virginia. This identifies an interested enforcement role, not an independent witness to every underlying transaction.supportsWelter’s source foundation combines his enforcement participation with review of documents; his organisational interest and derivative basis should remain visible when weighing the assertions.
Specifically named source propositions support the bounded distinction or question.
Paragraph 6 says the summary-judgment memorandum’s factual representations are accurate insofar as he participated in producing or reviewed them during litigation, including Catalyst acquisition, OTC filings, agreements, UCC filings, orders and locations. This combines participation and document review rather than claiming personal observation of every event.supportsDoes the declaration alone disprove other claimants’ contracts or establish the termination identifier?
Specifically named source propositions support the bounded distinction or question.
Welter says he reviewed all Cyberlux OTC filings from 2022 to the declaration date and describes quarterly filings as sworn corporate-officer submissions. He asserts Fairwinds, ARG and WeShield parties were not designated debt holders in quarters before this interpleader; the underlying reports and quarter-by-quarter search results are absent.supportsA claimed failure to disclose a debt or contract does not by itself disprove its existence. The precise disclosure obligations, report dates and underlying instruments are separate tests.
Specifically named source propositions support the bounded distinction or question.
He further says those filings do not reflect commissions owed or contracts entered with Fairwinds or ARG, and WeShield parties were mentioned only after interpleader commenced. This is a claimed absence from reviewed disclosures, not proof that no underlying agreement, obligation or equitable claim existed.supportsA claimed failure to disclose a debt or contract does not by itself disprove its existence. The precise disclosure obligations, report dates and underlying instruments are separate tests.
Specifically named source propositions support the bounded distinction or question.
He reports three unsuccessful removal actions remanded to state court, a defeated mandamus petition, appeal and appellate motions, numerous unsuccessful trial motions, and more than four sanctions granted against Cyberlux. The declaration does not identify every case/order or attach those rulings; it is his summary, not an independently counted docket audit.supportsWelter’s source foundation combines his enforcement participation with review of documents; his organisational interest and derivative basis should remain visible when weighing the assertions.
Specifically named source propositions support the bounded distinction or question.
WEIGH
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No published WEIGH run
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