Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
claimallegation
Brian Stout’s declaration was executed and filed 15 April 2026 as EDVA175-1 in3:25-cv-00483-JAG for Legalist’s summary-judgment motion. He i
Brian Stout’s declaration was executed and filed 15 April 2026 as EDVA175-1 in3:25-cv-00483-JAG for Legalist’s summary-judgment motion. He identifies himself as Investment Lead of Government Receivables sinceFebruary 2024 and claims personal knowledge; his signed declaration is a lender-side evidentiary assertion, not a judgment.
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Case 3:25-cv-00483-JAG Document 175-1 Filed 04/15/26 Page 1 of 4 PagelD# 2691
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Civil Action No. 3:25-cv-483-JAG
CYBERLUX CORPORATION, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF BRIAN STOUT IN SUPPORT OF
LEGALIST SPV III, L.P.'S MOTION FOR SUMMARY JUDGMENT
I, Brian Stout, pursuant to the provisions of 28 U.S.C. § 1746, declare:
I am over 18 years old and of sound mind. The following information is based on
my personal knowledge and I am competent to testify on the matters herein.
2.
I work for Legalist SPV III, L.P. ("Legalist), as Investment Lead of Government
Receivables. I have held this position since February 2024.
Legalist is in the business of providing revolving lines of credit to fund business
operations, with a focus on legal assets, including government receivables lending.
4. On March 27, 2024, Legalist entered into a Government Purchase Order Financing
Agreement with Cyberlux, whereby Legalist would provide a line of credit for Legalist to fund
operational expenses. A true and correct copy of the Government Purchase Order Financing
Agreement is attached as Exhibit 1.
5. On July 14, 2024, Legalist and Cyberlux entered into an Amended and Restated
Government Purchase Order Financing Agreement which raised the limit on the line of credit and
claimallegation
The declaration identifies Exhibits 1–7, but the supplied PDF ends with the page 4 signature. Those referenced financing agreements, UCCs, r
The declaration identifies Exhibits 1–7, but the supplied PDF ends with the page 4 signature. Those referenced financing agreements, UCCs, requests, wire receipt and payoff statement cannot be counted as fully read attachments within this source.
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Civil Action No. 3:25-cv-483-JAG
CYBERLUX CORPORATION, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF BRIAN STOUT IN SUPPORT OF
LEGALIST SPV III, L.P.'S MOTION FOR SUMMARY JUDGMENT
I, Brian Stout, pursuant to the provisions of 28 U.S.C. § 1746, declare:
I am over 18 years old and of sound mind. The following information is based on
my personal knowledge and I am competent to testify on the matters herein.
2.
I work for Legalist SPV III, L.P. ("Legalist), as Investment Lead of Government
Receivables. I have held this position since February 2024.
Legalist is in the business of providing revolving lines of credit to fund business
operations, with a focus on legal assets, including government receivables lending.
4. On March 27, 2024, Legalist entered into a Government Purchase Order Financing
Agreement with Cyberlux, whereby Legalist would provide a line of credit for Legalist to fund
operational expenses. A true and correct copy of the Government Purchase Order Financing
Agreement is attached as Exhibit 1.
5. On July 14, 2024, Legalist and Cyberlux entered into an Amended and Restated
Government Purchase Order Financing Agreement which raised the limit on the line of credit and
claimallegation
Stout describes 27 March 2024 financing,14 July 2024 amended/restated terms raising the line, and 29 April 2025 second amended terms acknowl
Stout describes 27 March 2024 financing,14 July 2024 amended/restated terms raising the line, and 29 April 2025 second amended terms acknowledging default and adding compensation/protections. The referenced agreementsExhibits 1–3 are not included in this four-page file; its apparent original sentence says the line was for Legalist to fund operational expenses and should not be silently rewritten as contract text.
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Civil Action No. 3:25-cv-483-JAG
CYBERLUX CORPORATION, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF BRIAN STOUT IN SUPPORT OF
LEGALIST SPV III, L.P.'S MOTION FOR SUMMARY JUDGMENT
I, Brian Stout, pursuant to the provisions of 28 U.S.C. § 1746, declare:
I am over 18 years old and of sound mind. The following information is based on
my personal knowledge and I am competent to testify on the matters herein.
2.
I work for Legalist SPV III, L.P. ("Legalist), as Investment Lead of Government
Receivables. I have held this position since February 2024.
Legalist is in the business of providing revolving lines of credit to fund business
operations, with a focus on legal assets, including government receivables lending.
4. On March 27, 2024, Legalist entered into a Government Purchase Order Financing
Agreement with Cyberlux, whereby Legalist would provide a line of credit for Legalist to fund
operational expenses. A true and correct copy of the Government Purchase Order Financing
Agreement is attached as Exhibit 1.
5. On July 14, 2024, Legalist and Cyberlux entered into an Amended and Restated
Government Purchase Order Financing Agreement which raised the limit on the line of credit and
claimallegation
Stout quotes an all-assets/receivables security grant and reports 1 April 2024 Nevada/NC UCC filings. These assertions support Legalist’s cl
Stout quotes an all-assets/receivables security grant and reports 1 April 2024 Nevada/NC UCC filings. These assertions support Legalist’s claimed collateral position; they do not adjudicate priority over another creditor.
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required various warranties from Cyberlux. A true and correct copy of the Amended and Restated
Government Purchase Order Financing Agreement is attached as Exhibit 2.
6. On April 29, 2025, Legalist and Cyberlux entered into a Second Amended and
Restated Government Purchase Order Financing Agreement ('Financing Agreement"), which
acknowledged that Cyberlux had defaulted, temporarily raised the credit limit, and provided
Legalist additional compensation and protections based on Cyberlux's default. A true and correct
copy of the Second Amended and Restated Government Purchase Order Financing Agreement is
attached as Exhibit 3.
The Financing Agreement provided Legalist "a continuing lien on and security
interest in all [Cyberlux's] assets ... including its now existing and hereafter arising rights and
interests in ... contract rights or rights to payment of money... [and] accounts receivable." Ex.
3, 10.
On April 1, 2024, Legalist filed UCC financing statements in the office of the
Secretary of State for Nevada and North Carolina identifying its lien on Cyberlux's assets,
including its accounts receivable (the "UCC Statements"). True and correct copies of the UCC
Statements are attached as Exhibit 4.
9. As part of the underwriting process for the Financing Agreement, Legalist
requested that Cyberlux provide a copy of any contracts currently awarded for which operational
expenses would be financed under the Financing Agreement. Cyberlux provided a copy
Subcontract No. P000043846 between Cyberlux and HII Mission Technologies Corp. ("HIT)
which I understand is the source of the funds at issue in this litigation ("the HII Contract').
10. Cyberlux also informed Legalist that the HII Contract was the only current contract
they anticipated the Financing Agreement would support.
2
claimallegation
He says Cyberlux supplied HII subcontractP000043846 during underwriting and represented that it was the only current contract expected to be
He says Cyberlux supplied HII subcontractP000043846 during underwriting and represented that it was the only current contract expected to be supported. This is the declarant’s report of Cyberlux’s representation, not proof every advance was actually spent on that contract.
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required various warranties from Cyberlux. A true and correct copy of the Amended and Restated
Government Purchase Order Financing Agreement is attached as Exhibit 2.
6. On April 29, 2025, Legalist and Cyberlux entered into a Second Amended and
Restated Government Purchase Order Financing Agreement ('Financing Agreement"), which
acknowledged that Cyberlux had defaulted, temporarily raised the credit limit, and provided
Legalist additional compensation and protections based on Cyberlux's default. A true and correct
copy of the Second Amended and Restated Government Purchase Order Financing Agreement is
attached as Exhibit 3.
The Financing Agreement provided Legalist "a continuing lien on and security
interest in all [Cyberlux's] assets ... including its now existing and hereafter arising rights and
interests in ... contract rights or rights to payment of money... [and] accounts receivable." Ex.
3, 10.
On April 1, 2024, Legalist filed UCC financing statements in the office of the
Secretary of State for Nevada and North Carolina identifying its lien on Cyberlux's assets,
including its accounts receivable (the "UCC Statements"). True and correct copies of the UCC
Statements are attached as Exhibit 4.
9. As part of the underwriting process for the Financing Agreement, Legalist
requested that Cyberlux provide a copy of any contracts currently awarded for which operational
expenses would be financed under the Financing Agreement. Cyberlux provided a copy
Subcontract No. P000043846 between Cyberlux and HII Mission Technologies Corp. ("HIT)
which I understand is the source of the funds at issue in this litigation ("the HII Contract').
10. Cyberlux also informed Legalist that the HII Contract was the only current contract
they anticipated the Financing Agreement would support.
2
claimallegation
The ten-row schedule states advances:9 April 2024$1.8m;19 April$500k;2 May$500k;26 June$142k;5 July$53k;16 July$2.5m;2 August$650k;27 August
The ten-row schedule states advances:9 April 2024$1.8m;19 April$500k;2 May$500k;26 June$142k;5 July$53k;16 July$2.5m;2 August$650k;27 August$535k;3 October$150k and$120k. These sum$6,950,000. The tenth request-date cell explicitly says[blank]; request dates differ from payment dates. Requests and bank evidence are referenced but absent.
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11.
To receive a capital advance under the Financing Agreement, Cyberlux had to
submit a completed Request for Disbursement, which was attached as Exhibit B to each of the
financing agreements. See Exs. 1-3, at 8 & Ex. B.
12.
Between April and October 2024, Cyberlux requested and Legalist advanced
$6,950,000 in capital pursuant to the Financing Agreement, as shown in the chart below. True and
correct copies of the ten Requests for Disbursement submitted by Cyberlux are attached as Exhibit
5.
RFD No.
RFD Date
Advance Date Amount
1
3.29.2024
4.9.2024
$1,800,000.00
2
3.29.2024
4.19.2024
$500,000.00
4.26.2024
5.2.2024
$500,000.00
4
6.14.2024
6.26.2024
$142,000.00
7.1.2024
7.5.2024
$53,000.00
7.11.2024
7.16.2024
$2,500,000.00
7.29.2024
8.2.2024
$650,000.00
8.14.2024
8.27.2024
$535,000.00
8.27.2024
10.3.2024
$150,000.00
10
[blank]
10.3.2024
$120,000.00
13.
After it was filed on July 30, 2024, Cyberlux made Legalist aware of a judgment
enforcement action brought by Atlantic Wave Holdings, LLC and Secure Community, LLO
(collectively, "Atlantic Wave") against Cyberlux in Harris County, Texas (Cause No. 2024-48085)
(the "Texas Action').
14. In May 2025, Cyberlux approached Legalist through counsel about paying the
judgment and fees requested in the Texas Action. Legalist had authority to do so under the power
of attorney granted in Paragraph 20 of the Financing Agreement, which appoints Legalist as
Cyberlux's attorney in fact to take various actions, including to "(iv) discharge past due taxes,
assessments, charges, fees, or liens on the Collateral; ... and (xii) do all other acts and things
3
claimallegation
Stout says Cyberlux informed Legalist of the Texas judgment-enforcement action after its 30 July 2024filing and approached it through counse
Stout says Cyberlux informed Legalist of the Texas judgment-enforcement action after its 30 July 2024filing and approached it through counsel in May 2025 about funding judgment and fees. He relies on financing-agreement paragraph 20 power of attorney; the full instrument is not here.
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Case 3:25-cv-00483-JAG Document 175-1 Filed 04/15/26 Page 3 of 4 PagelD# 2693
11.
To receive a capital advance under the Financing Agreement, Cyberlux had to
submit a completed Request for Disbursement, which was attached as Exhibit B to each of the
financing agreements. See Exs. 1-3, at 8 & Ex. B.
12.
Between April and October 2024, Cyberlux requested and Legalist advanced
$6,950,000 in capital pursuant to the Financing Agreement, as shown in the chart below. True and
correct copies of the ten Requests for Disbursement submitted by Cyberlux are attached as Exhibit
5.
RFD No.
RFD Date
Advance Date Amount
1
3.29.2024
4.9.2024
$1,800,000.00
2
3.29.2024
4.19.2024
$500,000.00
4.26.2024
5.2.2024
$500,000.00
4
6.14.2024
6.26.2024
$142,000.00
7.1.2024
7.5.2024
$53,000.00
7.11.2024
7.16.2024
$2,500,000.00
7.29.2024
8.2.2024
$650,000.00
8.14.2024
8.27.2024
$535,000.00
8.27.2024
10.3.2024
$150,000.00
10
[blank]
10.3.2024
$120,000.00
13.
After it was filed on July 30, 2024, Cyberlux made Legalist aware of a judgment
enforcement action brought by Atlantic Wave Holdings, LLC and Secure Community, LLO
(collectively, "Atlantic Wave") against Cyberlux in Harris County, Texas (Cause No. 2024-48085)
(the "Texas Action').
14. In May 2025, Cyberlux approached Legalist through counsel about paying the
judgment and fees requested in the Texas Action. Legalist had authority to do so under the power
of attorney granted in Paragraph 20 of the Financing Agreement, which appoints Legalist as
Cyberlux's attorney in fact to take various actions, including to "(iv) discharge past due taxes,
assessments, charges, fees, or liens on the Collateral; ... and (xii) do all other acts and things
3
claimallegation
He reports being informed through counsel that the receiver said at a 9 June 2025hearing that receipt of the full claimed amount would end t
He reports being informed through counsel that the receiver said at a 9 June 2025hearing that receipt of the full claimed amount would end the receivership. This is a relayed conditional representation, not the hearing transcript or an entered termination order.
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Case 3:25-cv-00483-JAG Document 175-1 Filed 04/15/26 Page 4 of 4 PagelD# 2694
reasonably necessary to carry out the terms of this Agreement and to preserve, protect, or enforce
Lender's rights with respect to the Collateral."
15.
Legalist was informed through counsel that at a hearing in the Texas Action on June
9, 2025, the Receiver represented that the receivership would terminate if the Receiver received
the full amount of the claimed judgment, interest, costs, and fees, which totaled just under $3.1
million.
16.
On or about June 11, 2025, through counsel, Legalist wired the sum of
$3,083,639.75 to the Receiver in the Texas Action on behalf of Cyberlux to satisfy the underlying
judgment, then-accrued interest, and certain costs and fees claimed by the Receiver. A true and
correct copy of the receipt for this wire transfer is attached as Exhibit 6.
17. As of April 15, 2026, Cyberlux's total indebtedness to Legalist is $13,608,702.73,
comprising of:
a. $10,033,639.75 in principal;
b. $2,900,646.70 in unpaid interest;
c. $112,500.00 for a commitment fee;
d. $53,000.00 for a forbearance fee;
e. $312,959.85 in paid legal fees and costs; and
f. $195,956.43 in unpaid legal fees and costs.
A true and correct copy of a Payoff Statement identifying Cyberlux's total indebtedness to Legalist
as of April 15th, 2026, is attached as Exhibit 7.
I declare under the penalty of perjury that the foregoing is true and correct.
- Signed by:
Brian Stout
Executed on April 15, 2026.
By:
- 3F53FA174222434.
Brian Stout
4
claimallegation
Stout says Legalist wired$3,083,639.75 through counsel on/about 11 June 2025 to the receiver for Cyberlux’s judgment,interest,costs/fees. Re
Stout says Legalist wired$3,083,639.75 through counsel on/about 11 June 2025 to the receiver for Cyberlux’s judgment,interest,costs/fees. Referenced wire receipt Exhibit 6 is absent from this file. $6,950,000 advances plus this claimed payment equals stated principal$10,033,639.75.
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reasonably necessary to carry out the terms of this Agreement and to preserve, protect, or enforce
Lender's rights with respect to the Collateral."
15.
Legalist was informed through counsel that at a hearing in the Texas Action on June
9, 2025, the Receiver represented that the receivership would terminate if the Receiver received
the full amount of the claimed judgment, interest, costs, and fees, which totaled just under $3.1
million.
16.
On or about June 11, 2025, through counsel, Legalist wired the sum of
$3,083,639.75 to the Receiver in the Texas Action on behalf of Cyberlux to satisfy the underlying
judgment, then-accrued interest, and certain costs and fees claimed by the Receiver. A true and
correct copy of the receipt for this wire transfer is attached as Exhibit 6.
17. As of April 15, 2026, Cyberlux's total indebtedness to Legalist is $13,608,702.73,
comprising of:
a. $10,033,639.75 in principal;
b. $2,900,646.70 in unpaid interest;
c. $112,500.00 for a commitment fee;
d. $53,000.00 for a forbearance fee;
e. $312,959.85 in paid legal fees and costs; and
f. $195,956.43 in unpaid legal fees and costs.
A true and correct copy of a Payoff Statement identifying Cyberlux's total indebtedness to Legalist
as of April 15th, 2026, is attached as Exhibit 7.
I declare under the penalty of perjury that the foregoing is true and correct.
- Signed by:
Brian Stout
Executed on April 15, 2026.
By:
- 3F53FA174222434.
Brian Stout
4
claimallegation
The 15 April 2026 payoff assertion totals$13,608,702.73:principal$10,033,639.75,interest$2,900,646.70,commitment fee$112,500,forbearance fee
The 15 April 2026 payoff assertion totals$13,608,702.73:principal$10,033,639.75,interest$2,900,646.70,commitment fee$112,500,forbearance fee$53,000,paid legal costs$312,959.85 andunpaid legal costs$195,956.43. Components reconcile exactly; contractual entitlement, fee reasonableness and actual current payoff are not resolved by arithmetic. Exhibit 7 payoff statement is absent.
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reasonably necessary to carry out the terms of this Agreement and to preserve, protect, or enforce
Lender's rights with respect to the Collateral."
15.
Legalist was informed through counsel that at a hearing in the Texas Action on June
9, 2025, the Receiver represented that the receivership would terminate if the Receiver received
the full amount of the claimed judgment, interest, costs, and fees, which totaled just under $3.1
million.
16.
On or about June 11, 2025, through counsel, Legalist wired the sum of
$3,083,639.75 to the Receiver in the Texas Action on behalf of Cyberlux to satisfy the underlying
judgment, then-accrued interest, and certain costs and fees claimed by the Receiver. A true and
correct copy of the receipt for this wire transfer is attached as Exhibit 6.
17. As of April 15, 2026, Cyberlux's total indebtedness to Legalist is $13,608,702.73,
comprising of:
a. $10,033,639.75 in principal;
b. $2,900,646.70 in unpaid interest;
c. $112,500.00 for a commitment fee;
d. $53,000.00 for a forbearance fee;
e. $312,959.85 in paid legal fees and costs; and
f. $195,956.43 in unpaid legal fees and costs.
A true and correct copy of a Payoff Statement identifying Cyberlux's total indebtedness to Legalist
as of April 15th, 2026, is attached as Exhibit 7.
I declare under the penalty of perjury that the foregoing is true and correct.
- Signed by:
Brian Stout
Executed on April 15, 2026.
By:
- 3F53FA174222434.
Brian Stout
4
entityobservation
Brian Stout
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Case 3:25-cv-00483-JAG Document 175-1 Filed 04/15/26 Page 1 of 4 PagelD# 2691
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Civil Action No. 3:25-cv-483-JAG
CYBERLUX CORPORATION, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF BRIAN STOUT IN SUPPORT OF
LEGALIST SPV III, L.P.'S MOTION FOR SUMMARY JUDGMENT
I, Brian Stout, pursuant to the provisions of 28 U.S.C. § 1746, declare:
I am over 18 years old and of sound mind. The following information is based on
my personal knowledge and I am competent to testify on the matters herein.
2.
I work for Legalist SPV III, L.P. ("Legalist), as Investment Lead of Government
Receivables. I have held this position since February 2024.
Legalist is in the business of providing revolving lines of credit to fund business
operations, with a focus on legal assets, including government receivables lending.
4. On March 27, 2024, Legalist entered into a Government Purchase Order Financing
Agreement with Cyberlux, whereby Legalist would provide a line of credit for Legalist to fund
operational expenses. A true and correct copy of the Government Purchase Order Financing
Agreement is attached as Exhibit 1.
5. On July 14, 2024, Legalist and Cyberlux entered into an Amended and Restated
Government Purchase Order Financing Agreement which raised the limit on the line of credit and
entityobservation
Legalist SPV III, L.P.
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Case 3:25-cv-00483-JAG Document 175-1 Filed 04/15/26 Page 1 of 4 PagelD# 2691
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Civil Action No. 3:25-cv-483-JAG
CYBERLUX CORPORATION, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF BRIAN STOUT IN SUPPORT OF
LEGALIST SPV III, L.P.'S MOTION FOR SUMMARY JUDGMENT
I, Brian Stout, pursuant to the provisions of 28 U.S.C. § 1746, declare:
I am over 18 years old and of sound mind. The following information is based on
my personal knowledge and I am competent to testify on the matters herein.
2.
I work for Legalist SPV III, L.P. ("Legalist), as Investment Lead of Government
Receivables. I have held this position since February 2024.
Legalist is in the business of providing revolving lines of credit to fund business
operations, with a focus on legal assets, including government receivables lending.
4. On March 27, 2024, Legalist entered into a Government Purchase Order Financing
Agreement with Cyberlux, whereby Legalist would provide a line of credit for Legalist to fund
operational expenses. A true and correct copy of the Government Purchase Order Financing
Agreement is attached as Exhibit 1.
5. On July 14, 2024, Legalist and Cyberlux entered into an Amended and Restated
Government Purchase Order Financing Agreement which raised the limit on the line of credit and
inferenceinference
Stout provides a dated lender-side reconciliation linking operating advances and the receiver payment to claimed principal, but the use of f
Stout provides a dated lender-side reconciliation linking operating advances and the receiver payment to claimed principal, but the use of funds and enforceable payoff require the referenced records.
inferenceinference
The only-contract underwriting representation and the later actual destination of funds are different questions; this declaration supplies t
The only-contract underwriting representation and the later actual destination of funds are different questions; this declaration supplies the former and selected advance totals, not a complete expenditure trace.
omissiongap
ReferencedExhibits 1–7 are absent from this declaration-only file, preventing direct verification here of instruments and payment records.
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Civil Action No. 3:25-cv-483-JAG
CYBERLUX CORPORATION, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF BRIAN STOUT IN SUPPORT OF
LEGALIST SPV III, L.P.'S MOTION FOR SUMMARY JUDGMENT
I, Brian Stout, pursuant to the provisions of 28 U.S.C. § 1746, declare:
I am over 18 years old and of sound mind. The following information is based on
my personal knowledge and I am competent to testify on the matters herein.
2.
I work for Legalist SPV III, L.P. ("Legalist), as Investment Lead of Government
Receivables. I have held this position since February 2024.
Legalist is in the business of providing revolving lines of credit to fund business
operations, with a focus on legal assets, including government receivables lending.
4. On March 27, 2024, Legalist entered into a Government Purchase Order Financing
Agreement with Cyberlux, whereby Legalist would provide a line of credit for Legalist to fund
operational expenses. A true and correct copy of the Government Purchase Order Financing
Agreement is attached as Exhibit 1.
5. On July 14, 2024, Legalist and Cyberlux entered into an Amended and Restated
Government Purchase Order Financing Agreement which raised the limit on the line of credit and
otherattribution
Complete supplied 4-page source reviewed at SHA-256 5794dbaca549b3c3c1f3447efcf7f81f790e85061bfd0d188ac989c68d0f4af1. Source assertions, ori
Complete supplied 4-page source reviewed at SHA-256 5794dbaca549b3c3c1f3447efcf7f81f790e85061bfd0d188ac989c68d0f4af1. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Full 4-page reading and visual QA of registered version version_34d9b492fb814d8d84b896f70407a4fe, exactSHA256 5794dbaca549b3c3c1f3447efcf7f81f790e85061bfd0d188ac989c68d0f4af1; no source replacement or live-docket update.
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Civil Action No. 3:25-cv-483-JAG
CYBERLUX CORPORATION, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF BRIAN STOUT IN SUPPORT OF
LEGALIST SPV III, L.P.'S MOTION FOR SUMMARY JUDGMENT
I, Brian Stout, pursuant to the provisions of 28 U.S.C. § 1746, declare:
I am over 18 years old and of sound mind. The following information is based on
my personal knowledge and I am competent to testify on the matters herein.
2.
I work for Legalist SPV III, L.P. ("Legalist), as Investment Lead of Government
Receivables. I have held this position since February 2024.
Legalist is in the business of providing revolving lines of credit to fund business
operations, with a focus on legal assets, including government receivables lending.
4. On March 27, 2024, Legalist entered into a Government Purchase Order Financing
Agreement with Cyberlux, whereby Legalist would provide a line of credit for Legalist to fund
operational expenses. A true and correct copy of the Government Purchase Order Financing
Agreement is attached as Exhibit 1.
5. On July 14, 2024, Legalist and Cyberlux entered into an Amended and Restated
Government Purchase Order Financing Agreement which raised the limit on the line of credit and
questionquestion
Do the ten requests, bank traces and full financing amendments confirm advance purpose, principal credits and each payoff component?
questionquestion
What hearing transcript and entered orders establish the terms and legal effect of the receiver’s reported termination representation?
questionquestion
Does the declared$13.608million balance independently prove the debt and every fee is enforceable?
claimallegation
HII contract supplied for underwriting
Stout states that Legalist requested current contracts for underwriting and Cyberlux supplied Subcontract P000043846 with HII.
Read the anchor · page 2
its lien on Cyberlux's assets,
including its accounts receivable (the "UCC Statements"). True and correct copies of the UCC
Statements are attached as Exhibit 4.
9. As part of the underwriting process for the Financing Agreement, Legalist
requested that Cyberlux provide a copy of any contracts currently awarded for which operational
expenses would be financed under the Financing Agreement. Cyberlux provided a copy
Subcontract No. P000043846 between Cyberlux and HII Mission Technologies Corp. ("HIP)
which I understand is the source of the funds at issue in this litigation ("the HII Contract").
10. Cyberlux also informed Legalist that the FIT Contract was the only current contract
they anticipated the Financing Agreement would support.
2
claimallegation
Legalist advances
Stout states that Legalist advanced $6,950,000 from April through October 2024.
Read the anchor · page 3
ncing Agreement, Cyberlux had to
submit a completed Request for Disbursement, which was attached as Exhibit B to each of the
financing agreements. See Exs. 1-3, at 18 & Ex. B.
12. Between April and October 2024, Cyberlux requested and Legalist advanced
$6,950,000 in capital pursuant to the Financing Agreement, as shown in the chart below. True and
correct copies of the ten Requests for Disbursement submitted by Cyberlux are attached as Exhibit
5.
RFD No. RFD Date
Advance Date Amount
3.29.2024
4.9.2024
$1,800,000.00
2
3.29.2024
4.19.2024
$500,000.00
4.26.2024
5.2.2024
$500,000.00
4
6.14.2024
6.26.2024
$142,000.00
1.1.2024
7.5.2024
$33,000.00
6
7.11.2024
7.16.2024
$2,500,000.0
claimallegation
Only anticipated supported contract
Stout states that Cyberlux told Legalist the HII contract was the only current contract it expected the financing agreement to support.
Read the anchor · page 2
JAG Document 175-1 Filed 04/15/26 Page 2 of 4 PagelD# 2692
required various warranties from Cyberlux. A true and correct copy of the Amended and Restated
Government Purchase Order Financing Agreement is attached as Exhibit 2.
6. On April 29, 2025, Legalist and Cyberlux entered into a Second Amended and
Restated Government Purchase Order Financing Agreement ("Financing Agreement), which
acknowledged that Cyberlux had defaulted, temporarily raised the credit limit, and provided
Legalist additional compensation and protections based on Cyberlux's default. A true and correct
copy of the Second Amended and Restated Government Purchase Order Financing Agreement is
attached as Exhibit 3.
The Financing Agreement provided Legalist "a continuing lien on and security
interest in all [Cyberlux's] assets... including its now existing and hereafter arising rights and
interests in ... contract rights or rights to payment of money... [and] accounts receivable." Ex.
3, 10.
On April 1, 2024, Legalist filed UCC financing statements in the office of the
Secretary of State for Nevada and North Carolina identifying its lien on Cyberlux's assets,
including its accounts receivable (the "UCC Statements"). True and correct copies of the UCC
Statements are attached as Exhibit 4.
9. As part of the underwriting process for the Financing Agreement, Legalist
requested that Cyberlux provide a copy of any contracts currently awarded for which operational
expenses would be financed under the Financing Agreement. Cyberlux provided a copy
Subcontract No. P000043846 between Cyberlux and HII Mission Technologies Corp. ("HIP)
which I understand is the source of the funds at issue in this litigation ("the HII Contract").
10. Cyberlux also informed Legalist that the FIT Contract was the only current contract
they anticipated the Financing Agreement would support.
2
eventattribution
Original financing agreement
Brian Stout states that Legalist and Cyberlux entered the original financing agreement on 27 March 2024.
Read the anchor · page 1
THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff,
V.
Civil Action No. 3:25-cv-483-JAG
CYBERLUX CORPORATION, et al.,
Interpleader Defendants/Claimants.
DECLARATION OF BRIAN STOUT IN SUPPORT OF
LEGALIST SPV III, L.P.'S MOTION FOR SUMMARY JUDGMENT
1, Brian Stout, pursuant to the provisions of 28 U.S.C. § 1746, declare:
I am over 18 years old and of sound mind. The following information is based on
my personal knowledge and I am competent to testify on the matters herein.
2. I work for Legalist SPV III, L.P. (*Legalist), as Investment Lead of Government
Receivables. I have held this position since February 2024.
Legalist is in the business of providing revolving lines of credit to fund business
operations, with a focus on legal assets, including government receivables lending.
4. On March 27, 2024, Legalist entered into a Government Purchase Order Financing
Agreement with Cyberlux, whereby Legalist would provide a line of credit for Legalist to fund
operational expenses. A true and correct copy of the Government Purchase Order Financing
Agreement is attached as Exhibit 1.
5. On July 14, 2024, Legalist and Cyberlux entered into an Amended and Restated
Government Purchase Order Financing Agreement which raised the limit on the l
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.
Brian Stout states that Legalist and Cyberlux entered the original financing agreement on 27 March 2024.supports{"timeline_thread":"money","timeline_thread_label":"Money movement"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
Stout states that the second amended agreement was executed on 29 April 2025 and acknowledged Cyberlux's default.supports{"timeline_thread":"money","timeline_thread_label":"Money movement"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
Legalist advanced $6,950,000 to Cyberlux between April and October 2024.relates to{"chapter":31,"exposure_lens":"Money movement identifies a transaction. Exposure remains separate for each lender, bank, creditor and recipient and depends on its own authority, knowledge, benefit and defences.","responsibility":"Financing, account control, payment processing, creditor entitlement, value and recipient knowledge where legally relevant.","sequence":331,"unit_key":"CH31"}
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 31. This is an identifier-based publication link, not a name match.
Stout states that Cyberlux told Legalist the HII contract was the only current contract it expected the financing agreement to support.relates to{"chapter":31,"exposure_lens":"Money movement identifies a transaction. Exposure remains separate for each lender, bank, creditor and recipient and depends on its own authority, knowledge, benefit and defences.","responsibility":"Financing, account control, payment processing, creditor entitlement, value and recipient knowledge where legally relevant.","sequence":331,"unit_key":"CH31"}
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 31. This is an identifier-based publication link, not a name match.
Stout states that Legalist requested current contracts for underwriting and Cyberlux supplied Subcontract P000043846 with HII.relates to{"chapter":31,"exposure_lens":"Money movement identifies a transaction. Exposure remains separate for each lender, bank, creditor and recipient and depends on its own authority, knowledge, benefit and defences.","responsibility":"Financing, account control, payment processing, creditor entitlement, value and recipient knowledge where legally relevant.","sequence":331,"unit_key":"CH31"}
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 31. This is an identifier-based publication link, not a name match.
Stout states that Legalist requested current contracts for underwriting and Cyberlux supplied Subcontract P000043846 with HII.supportsStout states that Legalist requested current contracts for underwriting and Cyberlux supplied Subcontract P000043846 with HII.
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
Stout states that Legalist advanced $6,950,000 from April through October 2024.supportsLegalist advanced $6,950,000 to Cyberlux between April and October 2024.
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
Stout states that Cyberlux told Legalist the HII contract was the only current contract it expected the financing agreement to support.supportsStout states that Cyberlux told Legalist the HII contract was the only current contract it expected the financing agreement to support.
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
{"timeline_thread":"money","timeline_thread_label":"Money movement"}relates to{"chapter":31,"exposure_lens":"Money movement identifies a transaction. Exposure remains separate for each lender, bank, creditor and recipient and depends on its own authority, knowledge, benefit and defences.","responsibility":"Financing, account control, payment processing, creditor entitlement, value and recipient knowledge where legally relevant.","sequence":331,"unit_key":"CH31"}
The controlling book publication map connects this dated event to Part III, Chapter 31. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"money","timeline_thread_label":"Money movement"}relates to{"chapter":31,"exposure_lens":"Money movement identifies a transaction. Exposure remains separate for each lender, bank, creditor and recipient and depends on its own authority, knowledge, benefit and defences.","responsibility":"Financing, account control, payment processing, creditor entitlement, value and recipient knowledge where legally relevant.","sequence":331,"unit_key":"CH31"}
The controlling book publication map connects this dated event to Part III, Chapter 31. The connection follows stored event/source and publication identifiers.
The 15 April 2026 payoff assertion totals$13,608,702.73:principal$10,033,639.75,interest$2,900,646.70,commitment fee$112,500,forbearance fee$53,000,paid legal costs$312,959.85 andunpaid legal costs$195,956.43. Components reconcile exactly; contractual entitlement, fee reasonableness and actual current payoff are not resolved by arithmetic. Exhibit 7 payoff statement is absent.supportsDoes the declared$13.608million balance independently prove the debt and every fee is enforceable?
Specifically named source propositions support the bounded distinction or question.
The 15 April 2026 payoff assertion totals$13,608,702.73:principal$10,033,639.75,interest$2,900,646.70,commitment fee$112,500,forbearance fee$53,000,paid legal costs$312,959.85 andunpaid legal costs$195,956.43. Components reconcile exactly; contractual entitlement, fee reasonableness and actual current payoff are not resolved by arithmetic. Exhibit 7 payoff statement is absent.supportsDo the ten requests, bank traces and full financing amendments confirm advance purpose, principal credits and each payoff component?
Specifically named source propositions support the bounded distinction or question.
The declaration identifies Exhibits 1–7, but the supplied PDF ends with the page 4 signature. Those referenced financing agreements, UCCs, requests, wire receipt and payoff statement cannot be counted as fully read attachments within this source.supportsStout provides a dated lender-side reconciliation linking operating advances and the receiver payment to claimed principal, but the use of funds and enforceable payoff require the referenced records.
Specifically named source propositions support the bounded distinction or question.
The declaration identifies Exhibits 1–7, but the supplied PDF ends with the page 4 signature. Those referenced financing agreements, UCCs, requests, wire receipt and payoff statement cannot be counted as fully read attachments within this source.supportsDo the ten requests, bank traces and full financing amendments confirm advance purpose, principal credits and each payoff component?
Specifically named source propositions support the bounded distinction or question.
The ten-row schedule states advances:9 April 2024$1.8m;19 April$500k;2 May$500k;26 June$142k;5 July$53k;16 July$2.5m;2 August$650k;27 August$535k;3 October$150k and$120k. These sum$6,950,000. The tenth request-date cell explicitly says[blank]; request dates differ from payment dates. Requests and bank evidence are referenced but absent.supportsThe only-contract underwriting representation and the later actual destination of funds are different questions; this declaration supplies the former and selected advance totals, not a complete expenditure trace.
Specifically named source propositions support the bounded distinction or question.
The declaration identifies Exhibits 1–7, but the supplied PDF ends with the page 4 signature. Those referenced financing agreements, UCCs, requests, wire receipt and payoff statement cannot be counted as fully read attachments within this source.supportsReferencedExhibits 1–7 are absent from this declaration-only file, preventing direct verification here of instruments and payment records.
Specifically named source propositions support the bounded distinction or question.
The 15 April 2026 payoff assertion totals$13,608,702.73:principal$10,033,639.75,interest$2,900,646.70,commitment fee$112,500,forbearance fee$53,000,paid legal costs$312,959.85 andunpaid legal costs$195,956.43. Components reconcile exactly; contractual entitlement, fee reasonableness and actual current payoff are not resolved by arithmetic. Exhibit 7 payoff statement is absent.supportsStout provides a dated lender-side reconciliation linking operating advances and the receiver payment to claimed principal, but the use of funds and enforceable payoff require the referenced records.
Specifically named source propositions support the bounded distinction or question.
Stout says Legalist wired$3,083,639.75 through counsel on/about 11 June 2025 to the receiver for Cyberlux’s judgment,interest,costs/fees. Referenced wire receipt Exhibit 6 is absent from this file. $6,950,000 advances plus this claimed payment equals stated principal$10,033,639.75.supportsWhat hearing transcript and entered orders establish the terms and legal effect of the receiver’s reported termination representation?
Specifically named source propositions support the bounded distinction or question.
The ten-row schedule states advances:9 April 2024$1.8m;19 April$500k;2 May$500k;26 June$142k;5 July$53k;16 July$2.5m;2 August$650k;27 August$535k;3 October$150k and$120k. These sum$6,950,000. The tenth request-date cell explicitly says[blank]; request dates differ from payment dates. Requests and bank evidence are referenced but absent.supportsStout provides a dated lender-side reconciliation linking operating advances and the receiver payment to claimed principal, but the use of funds and enforceable payoff require the referenced records.
Specifically named source propositions support the bounded distinction or question.
He says Cyberlux supplied HII subcontractP000043846 during underwriting and represented that it was the only current contract expected to be supported. This is the declarant’s report of Cyberlux’s representation, not proof every advance was actually spent on that contract.supportsThe only-contract underwriting representation and the later actual destination of funds are different questions; this declaration supplies the former and selected advance totals, not a complete expenditure trace.
Specifically named source propositions support the bounded distinction or question.
Stout says Legalist wired$3,083,639.75 through counsel on/about 11 June 2025 to the receiver for Cyberlux’s judgment,interest,costs/fees. Referenced wire receipt Exhibit 6 is absent from this file. $6,950,000 advances plus this claimed payment equals stated principal$10,033,639.75.supportsDoes the declared$13.608million balance independently prove the debt and every fee is enforceable?
Specifically named source propositions support the bounded distinction or question.
Stout says Legalist wired$3,083,639.75 through counsel on/about 11 June 2025 to the receiver for Cyberlux’s judgment,interest,costs/fees. Referenced wire receipt Exhibit 6 is absent from this file. $6,950,000 advances plus this claimed payment equals stated principal$10,033,639.75.supportsThe only-contract underwriting representation and the later actual destination of funds are different questions; this declaration supplies the former and selected advance totals, not a complete expenditure trace.
Specifically named source propositions support the bounded distinction or question.
Stout says Legalist wired$3,083,639.75 through counsel on/about 11 June 2025 to the receiver for Cyberlux’s judgment,interest,costs/fees. Referenced wire receipt Exhibit 6 is absent from this file. $6,950,000 advances plus this claimed payment equals stated principal$10,033,639.75.supportsStout provides a dated lender-side reconciliation linking operating advances and the receiver payment to claimed principal, but the use of funds and enforceable payoff require the referenced records.
Specifically named source propositions support the bounded distinction or question.
Stout describes 27 March 2024 financing,14 July 2024 amended/restated terms raising the line, and 29 April 2025 second amended terms acknowledging default and adding compensation/protections. The referenced agreementsExhibits 1–3 are not included in this four-page file; its apparent original sentence says the line was for Legalist to fund operational expenses and should not be silently rewritten as contract text.supportsDo the ten requests, bank traces and full financing amendments confirm advance purpose, principal credits and each payoff component?
Specifically named source propositions support the bounded distinction or question.
The ten-row schedule states advances:9 April 2024$1.8m;19 April$500k;2 May$500k;26 June$142k;5 July$53k;16 July$2.5m;2 August$650k;27 August$535k;3 October$150k and$120k. These sum$6,950,000. The tenth request-date cell explicitly says[blank]; request dates differ from payment dates. Requests and bank evidence are referenced but absent.supportsDo the ten requests, bank traces and full financing amendments confirm advance purpose, principal credits and each payoff component?
Specifically named source propositions support the bounded distinction or question.
Stout says Legalist wired$3,083,639.75 through counsel on/about 11 June 2025 to the receiver for Cyberlux’s judgment,interest,costs/fees. Referenced wire receipt Exhibit 6 is absent from this file. $6,950,000 advances plus this claimed payment equals stated principal$10,033,639.75.supportsDo the ten requests, bank traces and full financing amendments confirm advance purpose, principal credits and each payoff component?
Specifically named source propositions support the bounded distinction or question.
He reports being informed through counsel that the receiver said at a 9 June 2025hearing that receipt of the full claimed amount would end the receivership. This is a relayed conditional representation, not the hearing transcript or an entered termination order.supportsWhat hearing transcript and entered orders establish the terms and legal effect of the receiver’s reported termination representation?
Specifically named source propositions support the bounded distinction or question.
The declaration identifies Exhibits 1–7, but the supplied PDF ends with the page 4 signature. Those referenced financing agreements, UCCs, requests, wire receipt and payoff statement cannot be counted as fully read attachments within this source.supportsDoes the declared$13.608million balance independently prove the debt and every fee is enforceable?
Specifically named source propositions support the bounded distinction or question.
WEIGH
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A score appears only when its components and change threshold are published.
No published WEIGH run
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