CYBERLUX CORPORATION nvbke-26-50721 0043.0

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 to make payroll, near -100% financing, and withheld government orders. Nor does the Answer identify which debts Cyberlux is paying, when the wage claimants were paid, or the factual basis for treating every claim as disputed. The Answer also admits that Cyberlux has more than twelve creditors. Answer ¶ 5. That admission materially undermines reliance on the Virginia settlement as a comprehensive substitute for bankruptcy. The interpleader concerns a single res and excludes cred itors who attempted to participate; Cyberlux itself now confirms that its creditor body extends beyond the limited participants in the settlement. At the May 27, 2026 summary -judgment hearing in the Virginia interpleader (a certified copy of the transcript of which is attached hereto as Exhibit 1 and cited as “Tr.”), Senior United States District Judge John A. Gibney, Jr. repeatedly questioned why th e dispute was not in bankruptcy. Tr. 35:21 –22; 35:25 –36:1; 36:20 –22. Counsel for Fairwinds Technologies LLC likewise told that court that a receiver could “put it into the bankruptcy court where everybody agrees it should be,” that bankruptcy is “a federal forum that does this every single day,” and that bankruptcy “cuts through” the parties’ priority dispute. Tr. 46:3 –6; 47:25–48:1; 51:23–25. Those statements materially undermine the Motion’s assertion that this case serves no valid bankruptcy purpose. The automatic stay is self-executing and applies to acts to obtain possession of or exercise control over property of the estate. 11 U.S.C. § 362(a)(3). Mr. Maadarani does not ask this Court to accept as established Cyberlux’s asserted entitlement to the residual fund. Cyberlux opposes the involuntary petition, but that opposition does not determine whether Cyberlux held a legal or equitable interest in the res on the petition date. The relevant point is narrower: the fund derives from Cyberlux’s subcontract rights; HII allegedly held the receipts with the intent to pay Cyberlux, subject to disputed contractual conditions; Cyberlux asserted a claim to the res before the petition; and no final judgment has extinguished that asserted interest. The Court need not resolve Cyberlux’s ultimate entitlement in order to resolve this Motion. Whatever the eventual extent of the estate’s interest, no portion of the res may be transferred before that interest is adjudicated, and the requested “comfort orde r” would permit exactly that. As set Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 3 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10 c) any unresolved allocation remain in the Virginia registry pending further order of this Court; d) no settlement release impair estate causes of action or the rights of nonparties; and e) all avoidance, subordination, claim-objection, and turnover rights remain preserved. This approach respects the Virginia court’s work while avoiding a potentially void transfer. See Schwartz v. United States (In re Schwartz) , 954 F.2d 569, 571 (9th Cir. 1992); 40235 Washington Street Corp. v. Lusardi, 329 F.3d 1076, 1080 (9th Cir. 2003). B. Cyberlux’s Answer Does Not Establish That § 305 Abstention Better Serves Cyberlux and All Creditors Section 305(a)(1) permits dismissal or suspension only if “the interests of creditors and the debtor would be better served.” The standard is conjunctive. Abstention in a properly filed case is an extraordinary remedy, and dismissal is appropriate only whe n both the debtor and creditors would affirmatively be better served. Eastman v. Eastman (In re Eastman), 188 B.R. 621, 624–25 (9th Cir. BAP 1995). Because appellate review is restricted, dismissal under § 305 must remain narrow. Wechsler v. Macke International Trade, Inc. (In re Macke International Trade, Inc.), 370 B.R. 236, 247 (9th Cir. BAP 2007). Cyberlux asserts in its Answer that this Court should abstain. Answer, Affirmative Defense ¶ 8. The Answer, however, states only the conclusion; it does not explain how abstention better serves Cyberlux and every creditor, identify a comprehensive alternat ive insolvency proceeding, or reconcile abstention with Cyberlux’s earlier sworn financial record. Cyberlux’s opposition is relevant, but management’s preference does not by itself establish that dismissal objectively better serves Cyberlux under § 305. Cyberlux’s own sworn record describes an enterprise facing an inability to meet payroll, inability to obtain ordinary financing, and inability to fulfill substantial customer orders because of financial instability. Mr. Maadarani does not purport to decide whether continued operations, sale, or liquidation is preferable. An independent fiduciary should evaluate those alternatives, investigate Cyberlux’s financial affairs, and determine how value can be preserved for all creditors. Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 10 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 to make payroll, near -100% financing, and withheld government orders. Nor does the Answer identify which debts Cyberlux is paying, when the wage claimants were paid, or the factual basis for treating every claim as disputed. The Answer also admits that Cyberlux has more than twelve creditors. Answer ¶ 5. That admission materially undermines reliance on the Virginia settlement as a comprehensive substitute for bankruptcy. The interpleader concerns a single res and excludes cred itors who attempted to participate; Cyberlux itself now confirms that its creditor body extends beyond the limited participants in the settlement. At the May 27, 2026 summary -judgment hearing in the Virginia interpleader (a certified copy of the transcript of which is attached hereto as Exhibit 1 and cited as “Tr.”), Senior United States District Judge John A. Gibney, Jr. repeatedly questioned why th e dispute was not in bankruptcy. Tr. 35:21 –22; 35:25 –36:1; 36:20 –22. Counsel for Fairwinds Technologies LLC likewise told that court that a receiver could “put it into the bankruptcy court where everybody agrees it should be,” that bankruptcy is “a federal forum that does this every single day,” and that bankruptcy “cuts through” the parties’ priority dispute. Tr. 46:3 –6; 47:25–48:1; 51:23–25. Those statements materially undermine the Motion’s assertion that this case serves no valid bankruptcy purpose. The automatic stay is self-executing and applies to acts to obtain possession of or exercise control over property of the estate. 11 U.S.C. § 362(a)(3). Mr. Maadarani does not ask this Court to accept as established Cyberlux’s asserted entitlement to the residual fund. Cyberlux opposes the involuntary petition, but that opposition does not determine whether Cyberlux held a legal or equitable interest in the res on the petition date. The relevant point is narrower: the fund derives from Cyberlux’s subcontract rights; HII allegedly held the receipts with the intent to pay Cyberlux, subject to disputed contractual conditions; Cyberlux asserted a claim to the res before the petition; and no final judgment has extinguished that asserted interest. The Court need not resolve Cyberlux’s ultimate entitlement in order to resolve this Motion. Whatever the eventual extent of the estate’s interest, no portion of the res may be transferred before that interest is adjudicated, and the requested “comfort orde r” would permit exactly that. As set Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 3 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14 D. Fairwinds Is Judicially Estopped from Asserting That This Case Serves No Bankruptcy Purpose At the May 27 hearing, counsel for Fairwinds, Mark A. Mintz, Esq. — the same attorney who signed the Motion now before this Court and appears pro hac vice to prosecute it [ECF Nos. 16, 25] — proposed appointment of a federal receiver with authority to operate Cyberlux and place it into bankruptcy, stating that the receiver could “put it into the bankruptcy court where everybody agrees it should be.” Tr. 45:21–25; 46:3–6. Counsel further stated that bankruptcy supplies “a federal system” for priority disputes, is “a federal forum that does this every single day,” and would “cut[] through” the unsecured-creditor issues. Tr. 47:17 –18; 47:25 –48:1; 51:23 –52:1. Counsel explained that the absence of an involuntary petition reflected the risks imposed on petitioning creditors, not the absence of a bankruptcy purpose. Tr. 45:8–18. Judicial estoppel “precludes a party from gaining an advantage by asserting one position, and then later seeking an advantage by taking a clearly inconsistent position,” and protects “against a litigant playing fast and loose with the courts.” Hamilton v. State Farm Fire & Casualty Co., 270 F.3d 778, 782 (9th Cir. 2001) (citing Russell v. Rolfs, 893 F.2d 1033, 1037 (9th Cir. 1990)). Each consideration identified in New Hampshire v. Maine, 532 U.S. 742, 750–51 (2001), is present. The positions are clearly inconsistent: “put it into the bankruptcy court where everybody agrees it should be” cannot be reconciled with a motion asserting that bankruptcy serves no valid purpose. The district court accepted the earlier position — as Fairwinds’ counsel himself announced: “Your Honor has expressed that it should be there.” Tr. 46:10. And the advantage sought is concrete: in bankruptcy, Fairwinds — an unsecured claimant asserting a $2,348,542 teaming -fee claim [ECF No. 1, Attach. A] — stands behind the wage priorities of 11 U.S.C. § 507(a)(4) –(5) and takes no post-petition interest, 11 U.S.C. § 502(b)(2); under the settlement negotiated after the wage claimants were excluded, it stands to take more. Fairwinds is judicially estopped, and the Motion should be denied as to Fairwinds on that ground alone. The client is the same; the lawyer is the same; the case is the same. Mr. Mintz told Judge Gibney that this case belonged in bankruptcy, and Mr. Mintz signed the Motion telling this Court that it does not. Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 14 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 As to the remaining Movants, the Court need not determine that every element of judicial estoppel is satisfied. Fairwinds may contend that it advocated a receiver -authorized filing rather than this involuntary petition, or that the Virginia court did not f ormally adopt its position. Even if those distinctions were credited, the prior advocacy remains fatal to the Motion’s credibility concerning creditor interests, the adequacy of the alternative forum, and the legitimacy of this case’s purpose. The Movants told the district court that this case belonged in bankruptcy. It is here. They should be held to their word. E. If Deference to Virginia Is Appropriate, Suspension and Preservation —not Dismissal—Are the Proper Alternatives Section 305(a) authorizes suspension as well as dismissal. In In re EB Holdings II, Inc. , 589 B.R. 704, 727 –28 (Bankr. D. Nev. 2017), this District suspended an involuntary case while prepetition litigation resolved underlying nonbankruptcy disputes rather than extinguishing the bankruptcy proceeding. If the Court concludes that any temporary deference to the Virginia litigation is nonetheless warranted, suspension would preserve the bankruptcy forum and the rights of excluded creditors while avoiding inconsistent rulings. The Court could suspend furthe r adjudication of the involuntary petition for a defined period, require status reports, and retain jurisdiction to protect the fund and determine whether an order for relief remains necessary. Any suspension should be conditioned on preservation of the res. No disputed funds should be distributed absent further order of this Court or relief under § 362(d). Any amount determined to belong to Cyberlux should remain protected for transfer to a trus tee or other authorized estate representative if an order for relief is entered. All avoidance, subordination, turnover, and claim - objection rights should remain expressly reserved. F. Dismissal “With Prejudice” Is Unsupported The Motion requests dismissal “with prejudice” under § 305(a)(1), but does not identify the statutory basis for a prospective filing bar, the proposed duration, the persons or claims it would bind, or the findings necessary to impose it. Section 305 authorizes dismissal or suspension; it does not automatically create a bar against future bankruptcy relief. Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 15 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 forth below, the forum in which the Movants propose to complete the remaining determinations is itself weeks from losing its presiding judge. The disputed funds should remain in the registry, undisturbed, absent further order of this Court or relief from stay under 11 U.S.C. § 362(d). Dismissal under § 305 is an extraordinary remedy available only when the interests of both the debtor and the creditor body would be better served. Cyberlux’s request for abstention in its Answer is relevant, but management’s preference is not dispositive of Cyberlux’s objective interests or those of all creditors. The Virginia interpleader does not administer all Cyberlux assets and liabilities and cannot provide the investigation, avoidance, claims-administration, priority, and collective-distribution mechanisms available in bankruptcy. If temporary deference is warranted, suspension—not dismissal, and certainly not dismissal “with prejudice” —is the appropriate alternative. II. JURISDICTION This Court has jurisdiction under 28 U.S.C. §§ 157 and 1334. This is a core proceeding under 28 U.S.C. § 157(b)(2)(A), (B), (G), and (O). Venue is proper under 28 U.S.C. § 1408. The relevant statutory predicates include 11 U.S.C. §§ 105(a), 303, 305, 362, 501, 502, 507, 541, 542, 543, and 726, and Federal Rules of Bankruptcy Procedure 1003, 1013, and 9014. Pursuant to LR 7008, the Petitioning Creditors and Mr. Maadarani consent to entry of final orders and judgment by this Court on the Motion and this Opposition. III. FACTUAL AND PROCEDURAL BACKGROUND A. The Unpaid Employees and the Involuntary Petition On July 17, 2026, Christopher Spangler, Phillip R. Tucker, and Neill Whiteley commenced this case by filing an involuntary petition under chapter 7 [ECF No. 1]. Their asserted claims aggregate $1,425,417.67 for unpaid wages and employment-contract compensation and are alleged to be noncontingent and not subject to a bona fide dispute as to liability or amount. 11 U.S.C. § 303(b)(1). Seven additional creditors joined the petition under 11 U.S.C. § 303(c) and Federal Rule of Bankruptcy Procedure 1003(b): Mr. Maadarani [ECF No. 9], Wael Ali [ECF No. 10], Leila Ali [ECF No. 11], Yaroslav Yakymov [ECF No. 13], Nghiem Ba Hoang [ECF No. 23], Hau Sze Poon Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 4 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 16 The Motion does not establish bad faith sufficient to support extraordinary prospective relief. Cyberlux’s Answer alleges bad faith and improper purpose but pleads no supporting facts. Answer, Affirmative Defense ¶ 4. Filing after exclusion from the Virginia interpleader and shortly before distribution does not itself demonstrate bad faith where creditors seek a collective remedy unavailable to them in the interpleader. Nor do the Motion or Answer distinguish § 305’s best - interests inquiry from the separate requirements governing relief under § 303(i). If the Court dismisses under § 305, the order should be without prejudice, should make clear that it does not adjudicate the validity or priority of any creditor’s claim, and should not impair future relief based on changed circumstances. G. The Orderly Path Forward The Court should deny the Motion, preserve the status quo, and confirm that the automatic stay prevents distribution of any portion of the interpleaded funds necessary to protect a legal or equitable interest Cyberlux may hold pending adjudication. The Cou rt should then proceed promptly to adjudication of the involuntary petition. See Fed. R. Bankr. P. 1013(a). Upon entry of an order for relief and an appropriate determination of the estate’s interest, a trustee may seek turnover or transfer of property determined to belong to the estate under 11 U.S.C. §§ 542, 543, and 105(a). The trustee and this Court can then determine claims and priorities under §§ 502, 506, 507, and 726. If a temporary pause is necessary, the Court should suspend rather than dismiss this case, preserve the disputed res, retain jurisdiction, and require periodic status reports. PRAYER WHEREFORE, the petitioning creditors and Mr. Maadarani respectfully request that the Court: 1. Deny the Motion to the extent it seeks a blanket determination that the automatic stay does not apply to the interpleaded funds or their distribution; 2. Confirm that 11 U.S.C. § 362(a) applies to any act to obtain, distribute, or exercise control over any portion of the interpleaded funds necessary to protect a legal or equitable interest Cyberlux may hold pending adjudication; Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 16 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 I. PRELIMINARY STATEMENT The Motion asks this Court to permit distribution of $23,736,937.56 derived from Cyberlux Corporation’s contract receivable and held in the registry of the United States District Court for the Eastern District of Virginia. The proposed distribution arises from a settlement negotiated among only a portion of the claimants to the fund. Mr. Maadarani and other wage claimants were not permitted to participate in that settlement, and the Motion does not establish that their claims— or the interests of Cyberlux’s complete creditor body—will be protected if the fund is distributed. The stakes are concrete. In the Texas receivership, Cyberlux’s President and Chief Executive Officer, Mark D. Schmidt, stated under penalty of perjury that Cyberlux “will be unable to meet payroll by the end of March,” which would “directly impact more tha n 60 families who depend on Cyberlux for their income.” Ex. 2 (Schmidt Decl. ¶ 4.a) (a true and correct copy of Cyberlux’s March 18, 2026 emergency motion and the supporting Schmidt Declaration is attached hereto as Exhibit 2). Ten wage claimants are now before this Court. The Motion does not establish that those employees have been paid or identify a mechanism by which the Virginia settlement will pay them. The district court has already characterized the conduct underlying these claims. At the May 27, 2026 hearing, Judge Gibney likened Cyberlux’s business practices to the cartoon character Wimpy: “What Whimpy would always say, ‘For a hamburger today I will p ay you on Tuesday.’ So Whimpy would get the hamburger, but he never had the money on Tuesday. And that is essentially what you want.” Tr. 26:16–20. Asked what becomes of the unpaid counterparty, the court supplied the answer: “isn’t the hamburger salesman just a general creditor?” Tr. 27:6–7. Claims of $47,172,175.50 are asserted against a fund of $23.7 million, Mot. at 14–15; the order of distribution therefore determines which creditors are paid at all, and the Bankruptcy Code — not a settlement among a portion of the claimants — supplies that order. 11 U.S.C. §§ 507, 726. Cyberlux’s Answer to Involuntary Petition and All Joinders Thereto [ECF No. 34] (the “Answer”) now denies that Cyberlux is generally not paying its debts as they become due and asserts that every petitioning and joining creditor’s claim is subject to a bona fide dispute. Answer ¶¶ 3–4, 6. Those denials do not erase Cyberlux’s earlier sworn statements concerning its inability Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 2 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 forth below, the forum in which the Movants propose to complete the remaining determinations is itself weeks from losing its presiding judge. The disputed funds should remain in the registry, undisturbed, absent further order of this Court or relief from stay under 11 U.S.C. § 362(d). Dismissal under § 305 is an extraordinary remedy available only when the interests of both the debtor and the creditor body would be better served. Cyberlux’s request for abstention in its Answer is relevant, but management’s preference is not dispositive of Cyberlux’s objective interests or those of all creditors. The Virginia interpleader does not administer all Cyberlux assets and liabilities and cannot provide the investigation, avoidance, claims-administration, priority, and collective-distribution mechanisms available in bankruptcy. If temporary deference is warranted, suspension—not dismissal, and certainly not dismissal “with prejudice” —is the appropriate alternative. II. JURISDICTION This Court has jurisdiction under 28 U.S.C. §§ 157 and 1334. This is a core proceeding under 28 U.S.C. § 157(b)(2)(A), (B), (G), and (O). Venue is proper under 28 U.S.C. § 1408. The relevant statutory predicates include 11 U.S.C. §§ 105(a), 303, 305, 362, 501, 502, 507, 541, 542, 543, and 726, and Federal Rules of Bankruptcy Procedure 1003, 1013, and 9014. Pursuant to LR 7008, the Petitioning Creditors and Mr. Maadarani consent to entry of final orders and judgment by this Court on the Motion and this Opposition. III. FACTUAL AND PROCEDURAL BACKGROUND A. The Unpaid Employees and the Involuntary Petition On July 17, 2026, Christopher Spangler, Phillip R. Tucker, and Neill Whiteley commenced this case by filing an involuntary petition under chapter 7 [ECF No. 1]. Their asserted claims aggregate $1,425,417.67 for unpaid wages and employment-contract compensation and are alleged to be noncontingent and not subject to a bona fide dispute as to liability or amount. 11 U.S.C. § 303(b)(1). Seven additional creditors joined the petition under 11 U.S.C. § 303(c) and Federal Rule of Bankruptcy Procedure 1003(b): Mr. Maadarani [ECF No. 9], Wael Ali [ECF No. 10], Leila Ali [ECF No. 11], Yaroslav Yakymov [ECF No. 13], Nghiem Ba Hoang [ECF No. 23], Hau Sze Poon Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 4 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 I. PRELIMINARY STATEMENT The Motion asks this Court to permit distribution of $23,736,937.56 derived from Cyberlux Corporation’s contract receivable and held in the registry of the United States District Court for the Eastern District of Virginia. The proposed distribution arises from a settlement negotiated among only a portion of the claimants to the fund. Mr. Maadarani and other wage claimants were not permitted to participate in that settlement, and the Motion does not establish that their claims— or the interests of Cyberlux’s complete creditor body—will be protected if the fund is distributed. The stakes are concrete. In the Texas receivership, Cyberlux’s President and Chief Executive Officer, Mark D. Schmidt, stated under penalty of perjury that Cyberlux “will be unable to meet payroll by the end of March,” which would “directly impact more tha n 60 families who depend on Cyberlux for their income.” Ex. 2 (Schmidt Decl. ¶ 4.a) (a true and correct copy of Cyberlux’s March 18, 2026 emergency motion and the supporting Schmidt Declaration is attached hereto as Exhibit 2). Ten wage claimants are now before this Court. The Motion does not establish that those employees have been paid or identify a mechanism by which the Virginia settlement will pay them. The district court has already characterized the conduct underlying these claims. At the May 27, 2026 hearing, Judge Gibney likened Cyberlux’s business practices to the cartoon character Wimpy: “What Whimpy would always say, ‘For a hamburger today I will p ay you on Tuesday.’ So Whimpy would get the hamburger, but he never had the money on Tuesday. And that is essentially what you want.” Tr. 26:16–20. Asked what becomes of the unpaid counterparty, the court supplied the answer: “isn’t the hamburger salesman just a general creditor?” Tr. 27:6–7. Claims of $47,172,175.50 are asserted against a fund of $23.7 million, Mot. at 14–15; the order of distribution therefore determines which creditors are paid at all, and the Bankruptcy Code — not a settlement among a portion of the claimants — supplies that order. 11 U.S.C. §§ 507, 726. Cyberlux’s Answer to Involuntary Petition and All Joinders Thereto [ECF No. 34] (the “Answer”) now denies that Cyberlux is generally not paying its debts as they become due and asserts that every petitioning and joining creditor’s claim is subject to a bona fide dispute. Answer ¶¶ 3–4, 6. Those denials do not erase Cyberlux’s earlier sworn statements concerning its inability Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 2 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 I. PRELIMINARY STATEMENT The Motion asks this Court to permit distribution of $23,736,937.56 derived from Cyberlux Corporation’s contract receivable and held in the registry of the United States District Court for the Eastern District of Virginia. The proposed distribution arises from a settlement negotiated among only a portion of the claimants to the fund. Mr. Maadarani and other wage claimants were not permitted to participate in that settlement, and the Motion does not establish that their claims— or the interests of Cyberlux’s complete creditor body—will be protected if the fund is distributed. The stakes are concrete. In the Texas receivership, Cyberlux’s President and Chief Executive Officer, Mark D. Schmidt, stated under penalty of perjury that Cyberlux “will be unable to meet payroll by the end of March,” which would “directly impact more tha n 60 families who depend on Cyberlux for their income.” Ex. 2 (Schmidt Decl. ¶ 4.a) (a true and correct copy of Cyberlux’s March 18, 2026 emergency motion and the supporting Schmidt Declaration is attached hereto as Exhibit 2). Ten wage claimants are now before this Court. The Motion does not establish that those employees have been paid or identify a mechanism by which the Virginia settlement will pay them. The district court has already characterized the conduct underlying these claims. At the May 27, 2026 hearing, Judge Gibney likened Cyberlux’s business practices to the cartoon character Wimpy: “What Whimpy would always say, ‘For a hamburger today I will p ay you on Tuesday.’ So Whimpy would get the hamburger, but he never had the money on Tuesday. And that is essentially what you want.” Tr. 26:16–20. Asked what becomes of the unpaid counterparty, the court supplied the answer: “isn’t the hamburger salesman just a general creditor?” Tr. 27:6–7. Claims of $47,172,175.50 are asserted against a fund of $23.7 million, Mot. at 14–15; the order of distribution therefore determines which creditors are paid at all, and the Bankruptcy Code — not a settlement among a portion of the claimants — supplies that order. 11 U.S.C. §§ 507, 726. Cyberlux’s Answer to Involuntary Petition and All Joinders Thereto [ECF No. 34] (the “Answer”) now denies that Cyberlux is generally not paying its debts as they become due and asserts that every petitioning and joining creditor’s claim is subject to a bona fide dispute. Answer ¶¶ 3–4, 6. Those denials do not erase Cyberlux’s earlier sworn statements concerning its inability Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 2 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 to make payroll, near -100% financing, and withheld government orders. Nor does the Answer identify which debts Cyberlux is paying, when the wage claimants were paid, or the factual basis for treating every claim as disputed. The Answer also admits that Cyberlux has more than twelve creditors. Answer ¶ 5. That admission materially undermines reliance on the Virginia settlement as a comprehensive substitute for bankruptcy. The interpleader concerns a single res and excludes cred itors who attempted to participate; Cyberlux itself now confirms that its creditor body extends beyond the limited participants in the settlement. At the May 27, 2026 summary -judgment hearing in the Virginia interpleader (a certified copy of the transcript of which is attached hereto as Exhibit 1 and cited as “Tr.”), Senior United States District Judge John A. Gibney, Jr. repeatedly questioned why th e dispute was not in bankruptcy. Tr. 35:21 –22; 35:25 –36:1; 36:20 –22. Counsel for Fairwinds Technologies LLC likewise told that court that a receiver could “put it into the bankruptcy court where everybody agrees it should be,” that bankruptcy is “a federal forum that does this every single day,” and that bankruptcy “cuts through” the parties’ priority dispute. Tr. 46:3 –6; 47:25–48:1; 51:23–25. Those statements materially undermine the Motion’s assertion that this case serves no valid bankruptcy purpose. The automatic stay is self-executing and applies to acts to obtain possession of or exercise control over property of the estate. 11 U.S.C. § 362(a)(3). Mr. Maadarani does not ask this Court to accept as established Cyberlux’s asserted entitlement to the residual fund. Cyberlux opposes the involuntary petition, but that opposition does not determine whether Cyberlux held a legal or equitable interest in the res on the petition date. The relevant point is narrower: the fund derives from Cyberlux’s subcontract rights; HII allegedly held the receipts with the intent to pay Cyberlux, subject to disputed contractual conditions; Cyberlux asserted a claim to the res before the petition; and no final judgment has extinguished that asserted interest. The Court need not resolve Cyberlux’s ultimate entitlement in order to resolve this Motion. Whatever the eventual extent of the estate’s interest, no portion of the res may be transferred before that interest is adjudicated, and the requested “comfort orde r” would permit exactly that. As set Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 3 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7 liens, acknowledged that claims remained to be resolved, and did not issue a final summary - judgment ruling. Tr. 22:16–18; 24:10–11; 58:12–15. D. The Answer Confirms That the Virginia Settlement Does Not Encompass the Full Creditor Body Cyberlux admits that it has more than twelve creditors. Answer ¶ 5. The admission is significant because § 305 requires consideration of creditors as a body, not merely the claimants who remained in the Virginia interpleader and negotiated the settlement. Mr. Maadarani moved to intervene in the Virginia action on April 9, 2026. The district court denied intervention as untimely on April 20, 2026, rather than adjudicating the merits of his wage claim. Mot. at 8. The court similarly directed that materials su bmitted by Tucker and Whiteley be docketed to preserve and complete the record but ordered that they not be added as interpleader defendants. Id. The remaining interpleader participants reached a settlement on June 24, 2026 and moved for distribution. Mot. at 9. The involuntary petition followed on July 17, 2026. The timing does not, standing alone, establish bad faith. It is consistent with an effo rt by excluded creditors to preserve a finite fund before distribution under a settlement to which they were not parties. E. The Gap Period On July 20, 2026, this Court denied the petitioning creditors’ motion for appointment of an interim trustee under 11 U.S.C. § 303(g) [ECF Nos. 4, 7]. Cyberlux’s incumbent management therefore retains the authority provided by § 303(f) during the gap period. The stay is presently the principal statutory protection against transfer or dissipation of any estate interest in the registry fund before adjudication of the petition. IV. ARGUMENT AND AUTHORITIES A. The Stay Applies to Distribution of Any Portion of the Fund Necessary to Protect an Interest Cyberlux May Hold The automatic stay arose by operation of law upon filing of the petition. It is self-executing and “sweeps broadly.” Gruntz v. County of Los Angeles (In re Gruntz) , 202 F.3d 1074, 1081 –82 (9th Cir. 2000) (en banc). The stay protects the debtor and creditors as a class by preventing Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 7 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7 liens, acknowledged that claims remained to be resolved, and did not issue a final summary - judgment ruling. Tr. 22:16–18; 24:10–11; 58:12–15. D. The Answer Confirms That the Virginia Settlement Does Not Encompass the Full Creditor Body Cyberlux admits that it has more than twelve creditors. Answer ¶ 5. The admission is significant because § 305 requires consideration of creditors as a body, not merely the claimants who remained in the Virginia interpleader and negotiated the settlement. Mr. Maadarani moved to intervene in the Virginia action on April 9, 2026. The district court denied intervention as untimely on April 20, 2026, rather than adjudicating the merits of his wage claim. Mot. at 8. The court similarly directed that materials su bmitted by Tucker and Whiteley be docketed to preserve and complete the record but ordered that they not be added as interpleader defendants. Id. The remaining interpleader participants reached a settlement on June 24, 2026 and moved for distribution. Mot. at 9. The involuntary petition followed on July 17, 2026. The timing does not, standing alone, establish bad faith. It is consistent with an effo rt by excluded creditors to preserve a finite fund before distribution under a settlement to which they were not parties. E. The Gap Period On July 20, 2026, this Court denied the petitioning creditors’ motion for appointment of an interim trustee under 11 U.S.C. § 303(g) [ECF Nos. 4, 7]. Cyberlux’s incumbent management therefore retains the authority provided by § 303(f) during the gap period. The stay is presently the principal statutory protection against transfer or dissipation of any estate interest in the registry fund before adjudication of the petition. IV. ARGUMENT AND AUTHORITIES A. The Stay Applies to Distribution of Any Portion of the Fund Necessary to Protect an Interest Cyberlux May Hold The automatic stay arose by operation of law upon filing of the petition. It is self-executing and “sweeps broadly.” Gruntz v. County of Los Angeles (In re Gruntz) , 202 F.3d 1074, 1081 –82 (9th Cir. 2000) (en banc). The stay protects the debtor and creditors as a class by preventing Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 7 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7 liens, acknowledged that claims remained to be resolved, and did not issue a final summary - judgment ruling. Tr. 22:16–18; 24:10–11; 58:12–15. D. The Answer Confirms That the Virginia Settlement Does Not Encompass the Full Creditor Body Cyberlux admits that it has more than twelve creditors. Answer ¶ 5. The admission is significant because § 305 requires consideration of creditors as a body, not merely the claimants who remained in the Virginia interpleader and negotiated the settlement. Mr. Maadarani moved to intervene in the Virginia action on April 9, 2026. The district court denied intervention as untimely on April 20, 2026, rather than adjudicating the merits of his wage claim. Mot. at 8. The court similarly directed that materials su bmitted by Tucker and Whiteley be docketed to preserve and complete the record but ordered that they not be added as interpleader defendants. Id. The remaining interpleader participants reached a settlement on June 24, 2026 and moved for distribution. Mot. at 9. The involuntary petition followed on July 17, 2026. The timing does not, standing alone, establish bad faith. It is consistent with an effo rt by excluded creditors to preserve a finite fund before distribution under a settlement to which they were not parties. E. The Gap Period On July 20, 2026, this Court denied the petitioning creditors’ motion for appointment of an interim trustee under 11 U.S.C. § 303(g) [ECF Nos. 4, 7]. Cyberlux’s incumbent management therefore retains the authority provided by § 303(f) during the gap period. The stay is presently the principal statutory protection against transfer or dissipation of any estate interest in the registry fund before adjudication of the petition. IV. ARGUMENT AND AUTHORITIES A. The Stay Applies to Distribution of Any Portion of the Fund Necessary to Protect an Interest Cyberlux May Hold The automatic stay arose by operation of law upon filing of the petition. It is self-executing and “sweeps broadly.” Gruntz v. County of Los Angeles (In re Gruntz) , 202 F.3d 1074, 1081 –82 (9th Cir. 2000) (en banc). The stay protects the debtor and creditors as a class by preventing Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 7 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 to make payroll, near -100% financing, and withheld government orders. Nor does the Answer identify which debts Cyberlux is paying, when the wage claimants were paid, or the factual basis for treating every claim as disputed. The Answer also admits that Cyberlux has more than twelve creditors. Answer ¶ 5. That admission materially undermines reliance on the Virginia settlement as a comprehensive substitute for bankruptcy. The interpleader concerns a single res and excludes cred itors who attempted to participate; Cyberlux itself now confirms that its creditor body extends beyond the limited participants in the settlement. At the May 27, 2026 summary -judgment hearing in the Virginia interpleader (a certified copy of the transcript of which is attached hereto as Exhibit 1 and cited as “Tr.”), Senior United States District Judge John A. Gibney, Jr. repeatedly questioned why th e dispute was not in bankruptcy. Tr. 35:21 –22; 35:25 –36:1; 36:20 –22. Counsel for Fairwinds Technologies LLC likewise told that court that a receiver could “put it into the bankruptcy court where everybody agrees it should be,” that bankruptcy is “a federal forum that does this every single day,” and that bankruptcy “cuts through” the parties’ priority dispute. Tr. 46:3 –6; 47:25–48:1; 51:23–25. Those statements materially undermine the Motion’s assertion that this case serves no valid bankruptcy purpose. The automatic stay is self-executing and applies to acts to obtain possession of or exercise control over property of the estate. 11 U.S.C. § 362(a)(3). Mr. Maadarani does not ask this Court to accept as established Cyberlux’s asserted entitlement to the residual fund. Cyberlux opposes the involuntary petition, but that opposition does not determine whether Cyberlux held a legal or equitable interest in the res on the petition date. The relevant point is narrower: the fund derives from Cyberlux’s subcontract rights; HII allegedly held the receipts with the intent to pay Cyberlux, subject to disputed contractual conditions; Cyberlux asserted a claim to the res before the petition; and no final judgment has extinguished that asserted interest. The Court need not resolve Cyberlux’s ultimate entitlement in order to resolve this Motion. Whatever the eventual extent of the estate’s interest, no portion of the res may be transferred before that interest is adjudicated, and the requested “comfort orde r” would permit exactly that. As set Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 3 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 to make payroll, near -100% financing, and withheld government orders. Nor does the Answer identify which debts Cyberlux is paying, when the wage claimants were paid, or the factual basis for treating every claim as disputed. The Answer also admits that Cyberlux has more than twelve creditors. Answer ¶ 5. That admission materially undermines reliance on the Virginia settlement as a comprehensive substitute for bankruptcy. The interpleader concerns a single res and excludes cred itors who attempted to participate; Cyberlux itself now confirms that its creditor body extends beyond the limited participants in the settlement. At the May 27, 2026 summary -judgment hearing in the Virginia interpleader (a certified copy of the transcript of which is attached hereto as Exhibit 1 and cited as “Tr.”), Senior United States District Judge John A. Gibney, Jr. repeatedly questioned why th e dispute was not in bankruptcy. Tr. 35:21 –22; 35:25 –36:1; 36:20 –22. Counsel for Fairwinds Technologies LLC likewise told that court that a receiver could “put it into the bankruptcy court where everybody agrees it should be,” that bankruptcy is “a federal forum that does this every single day,” and that bankruptcy “cuts through” the parties’ priority dispute. Tr. 46:3 –6; 47:25–48:1; 51:23–25. Those statements materially undermine the Motion’s assertion that this case serves no valid bankruptcy purpose. The automatic stay is self-executing and applies to acts to obtain possession of or exercise control over property of the estate. 11 U.S.C. § 362(a)(3). Mr. Maadarani does not ask this Court to accept as established Cyberlux’s asserted entitlement to the residual fund. Cyberlux opposes the involuntary petition, but that opposition does not determine whether Cyberlux held a legal or equitable interest in the res on the petition date. The relevant point is narrower: the fund derives from Cyberlux’s subcontract rights; HII allegedly held the receipts with the intent to pay Cyberlux, subject to disputed contractual conditions; Cyberlux asserted a claim to the res before the petition; and no final judgment has extinguished that asserted interest. The Court need not resolve Cyberlux’s ultimate entitlement in order to resolve this Motion. Whatever the eventual extent of the estate’s interest, no portion of the res may be transferred before that interest is adjudicated, and the requested “comfort orde r” would permit exactly that. As set Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 3 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14 D. Fairwinds Is Judicially Estopped from Asserting That This Case Serves No Bankruptcy Purpose At the May 27 hearing, counsel for Fairwinds, Mark A. Mintz, Esq. — the same attorney who signed the Motion now before this Court and appears pro hac vice to prosecute it [ECF Nos. 16, 25] — proposed appointment of a federal receiver with authority to operate Cyberlux and place it into bankruptcy, stating that the receiver could “put it into the bankruptcy court where everybody agrees it should be.” Tr. 45:21–25; 46:3–6. Counsel further stated that bankruptcy supplies “a federal system” for priority disputes, is “a federal forum that does this every single day,” and would “cut[] through” the unsecured-creditor issues. Tr. 47:17 –18; 47:25 –48:1; 51:23 –52:1. Counsel explained that the absence of an involuntary petition reflected the risks imposed on petitioning creditors, not the absence of a bankruptcy purpose. Tr. 45:8–18. Judicial estoppel “precludes a party from gaining an advantage by asserting one position, and then later seeking an advantage by taking a clearly inconsistent position,” and protects “against a litigant playing fast and loose with the courts.” Hamilton v. State Farm Fire & Casualty Co., 270 F.3d 778, 782 (9th Cir. 2001) (citing Russell v. Rolfs, 893 F.2d 1033, 1037 (9th Cir. 1990)). Each consideration identified in New Hampshire v. Maine, 532 U.S. 742, 750–51 (2001), is present. The positions are clearly inconsistent: “put it into the bankruptcy court where everybody agrees it should be” cannot be reconciled with a motion asserting that bankruptcy serves no valid purpose. The district court accepted the earlier position — as Fairwinds’ counsel himself announced: “Your Honor has expressed that it should be there.” Tr. 46:10. And the advantage sought is concrete: in bankruptcy, Fairwinds — an unsecured claimant asserting a $2,348,542 teaming -fee claim [ECF No. 1, Attach. A] — stands behind the wage priorities of 11 U.S.C. § 507(a)(4) –(5) and takes no post-petition interest, 11 U.S.C. § 502(b)(2); under the settlement negotiated after the wage claimants were excluded, it stands to take more. Fairwinds is judicially estopped, and the Motion should be denied as to Fairwinds on that ground alone. The client is the same; the lawyer is the same; the case is the same. Mr. Mintz told Judge Gibney that this case belonged in bankruptcy, and Mr. Mintz signed the Motion telling this Court that it does not. Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 14 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6 already in the federal registry, when Cyberlux stated that it could not meet payroll. That chronology is evidence that the interpleader alone did not protect employees or comprehensively remedy Cyberlux’s financial distress. The Answer also denies every petitioning and joining creditor’s claim in a single categorical formulation. Answer ¶¶ 3–4, 6. It identifies no claim-specific factual or legal basis for those disputes. The Court need not resolve petition eligibility on this Motion, but the blanket denial does not establish that each claim is subject to a bona fide dispute and does not support releasing the finite fund before the petition and claims can be adjudicated. C. The Contractual Origin and Unresolved Status of the Interpleaded Funds The res consists of funds HII Mission Technologies Corp. received from the government in connection with Cyberlux’s subcontract performance and allegedly held with the intent to pay Cyberlux, subject to disputed contractual conditions and procedures. Mot. at 6. On March 6, 2026, HII deposited $23,736,937.56 into the registry of the Eastern District of Virginia in HII Mission Technologies Corp. v. Cyberlux Corp., et al. , No. 3:25 -cv-483 (E.D. Va.). Mot. at 7. The contractual source of the fund does not establish Cyberlux’s ultimate entitlement, but it prevents the res from being treated as indisputably unrelated to Cyberlux’s property rights. Before the involuntary petition, Cyberlux asserted an interest in the res. Its counsel told Judge Gibney that Cyberlux was the “number one person who should take from the res” and that, after payment of Legalist’s secured interest, “the rest of the funds should come back to Cyberlux.” Tr. 22:3–5; 23:13–14. Mr. Maadarani does not adopt that proposed allocation and does not contend that Cyberlux’s advocacy proves ownership. Those statements show only that a genuine ownership dispute existed and that the fund cannot be deemed entirely non -estate property without adjudication. Cyberlux’s opposition to the involuntary petition does not negate or waive whatever contract or property rights it held on the petition date. Whether Cyberlux has an interest in the res and whether an order for relief should be entered over its opposition are distinct questions. The summary-judgment hearing did not finally resolve the first question. The district court questioned whether asserted interests were secured, expressed concern regarding undisclosed or unperfected Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 6 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 to make payroll, near -100% financing, and withheld government orders. Nor does the Answer identify which debts Cyberlux is paying, when the wage claimants were paid, or the factual basis for treating every claim as disputed. The Answer also admits that Cyberlux has more than twelve creditors. Answer ¶ 5. That admission materially undermines reliance on the Virginia settlement as a comprehensive substitute for bankruptcy. The interpleader concerns a single res and excludes cred itors who attempted to participate; Cyberlux itself now confirms that its creditor body extends beyond the limited participants in the settlement. At the May 27, 2026 summary -judgment hearing in the Virginia interpleader (a certified copy of the transcript of which is attached hereto as Exhibit 1 and cited as “Tr.”), Senior United States District Judge John A. Gibney, Jr. repeatedly questioned why th e dispute was not in bankruptcy. Tr. 35:21 –22; 35:25 –36:1; 36:20 –22. Counsel for Fairwinds Technologies LLC likewise told that court that a receiver could “put it into the bankruptcy court where everybody agrees it should be,” that bankruptcy is “a federal forum that does this every single day,” and that bankruptcy “cuts through” the parties’ priority dispute. Tr. 46:3 –6; 47:25–48:1; 51:23–25. Those statements materially undermine the Motion’s assertion that this case serves no valid bankruptcy purpose. The automatic stay is self-executing and applies to acts to obtain possession of or exercise control over property of the estate. 11 U.S.C. § 362(a)(3). Mr. Maadarani does not ask this Court to accept as established Cyberlux’s asserted entitlement to the residual fund. Cyberlux opposes the involuntary petition, but that opposition does not determine whether Cyberlux held a legal or equitable interest in the res on the petition date. The relevant point is narrower: the fund derives from Cyberlux’s subcontract rights; HII allegedly held the receipts with the intent to pay Cyberlux, subject to disputed contractual conditions; Cyberlux asserted a claim to the res before the petition; and no final judgment has extinguished that asserted interest. The Court need not resolve Cyberlux’s ultimate entitlement in order to resolve this Motion. Whatever the eventual extent of the estate’s interest, no portion of the res may be transferred before that interest is adjudicated, and the requested “comfort orde r” would permit exactly that. As set Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 3 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 I. PRELIMINARY STATEMENT The Motion asks this Court to permit distribution of $23,736,937.56 derived from Cyberlux Corporation’s contract receivable and held in the registry of the United States District Court for the Eastern District of Virginia. The proposed distribution arises from a settlement negotiated among only a portion of the claimants to the fund. Mr. Maadarani and other wage claimants were not permitted to participate in that settlement, and the Motion does not establish that their claims— or the interests of Cyberlux’s complete creditor body—will be protected if the fund is distributed. The stakes are concrete. In the Texas receivership, Cyberlux’s President and Chief Executive Officer, Mark D. Schmidt, stated under penalty of perjury that Cyberlux “will be unable to meet payroll by the end of March,” which would “directly impact more tha n 60 families who depend on Cyberlux for their income.” Ex. 2 (Schmidt Decl. ¶ 4.a) (a true and correct copy of Cyberlux’s March 18, 2026 emergency motion and the supporting Schmidt Declaration is attached hereto as Exhibit 2). Ten wage claimants are now before this Court. The Motion does not establish that those employees have been paid or identify a mechanism by which the Virginia settlement will pay them. The district court has already characterized the conduct underlying these claims. At the May 27, 2026 hearing, Judge Gibney likened Cyberlux’s business practices to the cartoon character Wimpy: “What Whimpy would always say, ‘For a hamburger today I will p ay you on Tuesday.’ So Whimpy would get the hamburger, but he never had the money on Tuesday. And that is essentially what you want.” Tr. 26:16–20. Asked what becomes of the unpaid counterparty, the court supplied the answer: “isn’t the hamburger salesman just a general creditor?” Tr. 27:6–7. Claims of $47,172,175.50 are asserted against a fund of $23.7 million, Mot. at 14–15; the order of distribution therefore determines which creditors are paid at all, and the Bankruptcy Code — not a settlement among a portion of the claimants — supplies that order. 11 U.S.C. §§ 507, 726. Cyberlux’s Answer to Involuntary Petition and All Joinders Thereto [ECF No. 34] (the “Answer”) now denies that Cyberlux is generally not paying its debts as they become due and asserts that every petitioning and joining creditor’s claim is subject to a bona fide dispute. Answer ¶¶ 3–4, 6. Those denials do not erase Cyberlux’s earlier sworn statements concerning its inability Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 2 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 I. PRELIMINARY STATEMENT The Motion asks this Court to permit distribution of $23,736,937.56 derived from Cyberlux Corporation’s contract receivable and held in the registry of the United States District Court for the Eastern District of Virginia. The proposed distribution arises from a settlement negotiated among only a portion of the claimants to the fund. Mr. Maadarani and other wage claimants were not permitted to participate in that settlement, and the Motion does not establish that their claims— or the interests of Cyberlux’s complete creditor body—will be protected if the fund is distributed. The stakes are concrete. In the Texas receivership, Cyberlux’s President and Chief Executive Officer, Mark D. Schmidt, stated under penalty of perjury that Cyberlux “will be unable to meet payroll by the end of March,” which would “directly impact more tha n 60 families who depend on Cyberlux for their income.” Ex. 2 (Schmidt Decl. ¶ 4.a) (a true and correct copy of Cyberlux’s March 18, 2026 emergency motion and the supporting Schmidt Declaration is attached hereto as Exhibit 2). Ten wage claimants are now before this Court. The Motion does not establish that those employees have been paid or identify a mechanism by which the Virginia settlement will pay them. The district court has already characterized the conduct underlying these claims. At the May 27, 2026 hearing, Judge Gibney likened Cyberlux’s business practices to the cartoon character Wimpy: “What Whimpy would always say, ‘For a hamburger today I will p ay you on Tuesday.’ So Whimpy would get the hamburger, but he never had the money on Tuesday. And that is essentially what you want.” Tr. 26:16–20. Asked what becomes of the unpaid counterparty, the court supplied the answer: “isn’t the hamburger salesman just a general creditor?” Tr. 27:6–7. Claims of $47,172,175.50 are asserted against a fund of $23.7 million, Mot. at 14–15; the order of distribution therefore determines which creditors are paid at all, and the Bankruptcy Code — not a settlement among a portion of the claimants — supplies that order. 11 U.S.C. §§ 507, 726. Cyberlux’s Answer to Involuntary Petition and All Joinders Thereto [ECF No. 34] (the “Answer”) now denies that Cyberlux is generally not paying its debts as they become due and asserts that every petitioning and joining creditor’s claim is subject to a bona fide dispute. Answer ¶¶ 3–4, 6. Those denials do not erase Cyberlux’s earlier sworn statements concerning its inability Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 2 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6 already in the federal registry, when Cyberlux stated that it could not meet payroll. That chronology is evidence that the interpleader alone did not protect employees or comprehensively remedy Cyberlux’s financial distress. The Answer also denies every petitioning and joining creditor’s claim in a single categorical formulation. Answer ¶¶ 3–4, 6. It identifies no claim-specific factual or legal basis for those disputes. The Court need not resolve petition eligibility on this Motion, but the blanket denial does not establish that each claim is subject to a bona fide dispute and does not support releasing the finite fund before the petition and claims can be adjudicated. C. The Contractual Origin and Unresolved Status of the Interpleaded Funds The res consists of funds HII Mission Technologies Corp. received from the government in connection with Cyberlux’s subcontract performance and allegedly held with the intent to pay Cyberlux, subject to disputed contractual conditions and procedures. Mot. at 6. On March 6, 2026, HII deposited $23,736,937.56 into the registry of the Eastern District of Virginia in HII Mission Technologies Corp. v. Cyberlux Corp., et al. , No. 3:25 -cv-483 (E.D. Va.). Mot. at 7. The contractual source of the fund does not establish Cyberlux’s ultimate entitlement, but it prevents the res from being treated as indisputably unrelated to Cyberlux’s property rights. Before the involuntary petition, Cyberlux asserted an interest in the res. Its counsel told Judge Gibney that Cyberlux was the “number one person who should take from the res” and that, after payment of Legalist’s secured interest, “the rest of the funds should come back to Cyberlux.” Tr. 22:3–5; 23:13–14. Mr. Maadarani does not adopt that proposed allocation and does not contend that Cyberlux’s advocacy proves ownership. Those statements show only that a genuine ownership dispute existed and that the fund cannot be deemed entirely non -estate property without adjudication. Cyberlux’s opposition to the involuntary petition does not negate or waive whatever contract or property rights it held on the petition date. Whether Cyberlux has an interest in the res and whether an order for relief should be entered over its opposition are distinct questions. The summary-judgment hearing did not finally resolve the first question. The district court questioned whether asserted interests were secured, expressed concern regarding undisclosed or unperfected Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 6 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 [ECF No. 24], and Don Robert Hall [ECF No. 36]. Mr. Maadarani asserts a claim of not less than $522,927.63 for unpaid wages, salary, commissions, and expenses. [ECF No. 9]. Ten wage claimants therefore stand before this Court. On August 13, 2026, Cyberlux filed its Answer [ECF No. 34]. Cyberlux denies that the petitioning and joining creditors are eligible petitioners, denies every asserted claim, denies that it is generally not paying its debts as they become due, and alleges t hat all claims are subject to a bona fide dispute. Answer ¶¶ 2 –4, 6. Cyberlux also asserts bad faith and improper purpose, requests abstention under § 305, and seeks relief under § 303(i). Answer, Affirmative Defenses ¶¶ 4, 8; Prayer ¶ 3. B. Cyberlux’s Answer Conflicts with Its Earlier Sworn Financial Record On March 18, 2026, Cyberlux filed an emergency motion in Atlantic Wave Holdings, LLC v. Cyberlux Corp., No. 2024-48085 (129th Jud. Dist. Ct., Harris County, Texas), representing that it had been unable to obtain financing, had experienced a steep decline in share value, and would soon be unable to make payroll. Mr. Schmidt stated under penalty of perjury that Cyberlux would be unable to meet payroll by the end of March; that more than 60 families depended on Cyberlux for income; that Cyberlux could access only “payday loan” -type financing at rates approaching 100%; and that an $8.8 million U.S. CECOM order was being withheld until Cyberlux could demonstrate financial stability. Ex. 2 (Schmidt Decl. ¶¶ 4.a, 4.b, 4.e). The Answer’s blanket denial of general nonpayment is in substantial tension with those earlier sworn representations. The March declaration is not merely a creditor’s characterization; it is Cyberlux’s own evidence of an imminent inability to pay payroll and severe financing distress. The Answer does not explain what changed after March, identify financing that cured the stated crisis, allege that the affected payroll was made, or provide facts showing that Cyberlux is now paying its debts as they become due. Nor was the point disputed in open court: when Judge Gibney observed that Cyberlux “couldn’t afford to buy Mr. Robinson a new scarf,” counsel for Fairwinds answered, “I believe that is correct. Make no mistake about it.” Tr. 46:14–17. HII deposited the interpleaded funds on March 6, 2026. Mr. Schmidt executed his declaration twelve days later. The Virginia interpleader was therefore pending, and the fund was Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 5 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 forth below, the forum in which the Movants propose to complete the remaining determinations is itself weeks from losing its presiding judge. The disputed funds should remain in the registry, undisturbed, absent further order of this Court or relief from stay under 11 U.S.C. § 362(d). Dismissal under § 305 is an extraordinary remedy available only when the interests of both the debtor and the creditor body would be better served. Cyberlux’s request for abstention in its Answer is relevant, but management’s preference is not dispositive of Cyberlux’s objective interests or those of all creditors. The Virginia interpleader does not administer all Cyberlux assets and liabilities and cannot provide the investigation, avoidance, claims-administration, priority, and collective-distribution mechanisms available in bankruptcy. If temporary deference is warranted, suspension—not dismissal, and certainly not dismissal “with prejudice” —is the appropriate alternative. II. JURISDICTION This Court has jurisdiction under 28 U.S.C. §§ 157 and 1334. This is a core proceeding under 28 U.S.C. § 157(b)(2)(A), (B), (G), and (O). Venue is proper under 28 U.S.C. § 1408. The relevant statutory predicates include 11 U.S.C. §§ 105(a), 303, 305, 362, 501, 502, 507, 541, 542, 543, and 726, and Federal Rules of Bankruptcy Procedure 1003, 1013, and 9014. Pursuant to LR 7008, the Petitioning Creditors and Mr. Maadarani consent to entry of final orders and judgment by this Court on the Motion and this Opposition. III. FACTUAL AND PROCEDURAL BACKGROUND A. The Unpaid Employees and the Involuntary Petition On July 17, 2026, Christopher Spangler, Phillip R. Tucker, and Neill Whiteley commenced this case by filing an involuntary petition under chapter 7 [ECF No. 1]. Their asserted claims aggregate $1,425,417.67 for unpaid wages and employment-contract compensation and are alleged to be noncontingent and not subject to a bona fide dispute as to liability or amount. 11 U.S.C. § 303(b)(1). Seven additional creditors joined the petition under 11 U.S.C. § 303(c) and Federal Rule of Bankruptcy Procedure 1003(b): Mr. Maadarani [ECF No. 9], Wael Ali [ECF No. 10], Leila Ali [ECF No. 11], Yaroslav Yakymov [ECF No. 13], Nghiem Ba Hoang [ECF No. 23], Hau Sze Poon Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 4 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7 liens, acknowledged that claims remained to be resolved, and did not issue a final summary - judgment ruling. Tr. 22:16–18; 24:10–11; 58:12–15. D. The Answer Confirms That the Virginia Settlement Does Not Encompass the Full Creditor Body Cyberlux admits that it has more than twelve creditors. Answer ¶ 5. The admission is significant because § 305 requires consideration of creditors as a body, not merely the claimants who remained in the Virginia interpleader and negotiated the settlement. Mr. Maadarani moved to intervene in the Virginia action on April 9, 2026. The district court denied intervention as untimely on April 20, 2026, rather than adjudicating the merits of his wage claim. Mot. at 8. The court similarly directed that materials su bmitted by Tucker and Whiteley be docketed to preserve and complete the record but ordered that they not be added as interpleader defendants. Id. The remaining interpleader participants reached a settlement on June 24, 2026 and moved for distribution. Mot. at 9. The involuntary petition followed on July 17, 2026. The timing does not, standing alone, establish bad faith. It is consistent with an effo rt by excluded creditors to preserve a finite fund before distribution under a settlement to which they were not parties. E. The Gap Period On July 20, 2026, this Court denied the petitioning creditors’ motion for appointment of an interim trustee under 11 U.S.C. § 303(g) [ECF Nos. 4, 7]. Cyberlux’s incumbent management therefore retains the authority provided by § 303(f) during the gap period. The stay is presently the principal statutory protection against transfer or dissipation of any estate interest in the registry fund before adjudication of the petition. IV. ARGUMENT AND AUTHORITIES A. The Stay Applies to Distribution of Any Portion of the Fund Necessary to Protect an Interest Cyberlux May Hold The automatic stay arose by operation of law upon filing of the petition. It is self-executing and “sweeps broadly.” Gruntz v. County of Los Angeles (In re Gruntz) , 202 F.3d 1074, 1081 –82 (9th Cir. 2000) (en banc). The stay protects the debtor and creditors as a class by preventing Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 7 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Nathaniel E. Saxe, Esq. Nevada Bar No. 15631 SAXE LAW PLLC 5875 South Rainbow Blvd., Suite 204 Las Vegas, NV 89118 Telephone: (702) 306-1392 Email: nsaxe@saxelegal.com Attorney for Chris Spangler, Neill Whiteley, Rick Tucker, and Bilal Maadarani Mohamad A. Akbik, Esq. Florida Bar No. 116366 (Pro Hac Vice pending, ECF No. 32) 611 S. Fort Harrison Ave., Suite 183 Clearwater, Florida 33756 Tele: 727-223-3005 E-mail: akbiklaw@outlook.com Attorney for Creditor Bilal Maadarani UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CYBERLUX CORPORATION Alleged Debtor Case No.: 26-50721-hlb Involuntary Chapter 7 Judge; Hon. Hilary L. Barnes Hearing Date: August 18, 2026 Hearing Time: 1:30 PM (PDT) OPPOSITION TO MOTION TO CONFIRM INAPPLICABILITY OF THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, MOTION TO ABSTAIN PURSUANT TO 11 U.S.C. § 305 COMES NOW, Bilal Maadarani, (“Mr. Maadarani”), joined by Christopher Spangler, Phillip R. Tucker, and Neill Whiteley (the “Petitioning Creditors”), and by the undersigned counsels, and respectfully files this opposition to the “Interpleader Parties’” Motio n to Confirm Inapplicability of the Automatic Stay or, in the Alternative, Motion to Abstain Pursuant to 11 U.S.C. § 305 [ECF No. 18] (the “Motion”), and states as follows: /// /// Case 26-50721-hlb Doc 43 Entered 08/14/26 10:54:46 Page 1 of 19

On March 6, 2026, HII deposited $23,736,937.56

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