Atlantic Wave Holdings LLC, Secure Community LLC and Strikepoint Consulting LLC v. Cyberlux Corporation and Mark D. Schmidt, Complaint, No. 37-2023-00055306-CU-MC-CTL (Cal. Super. Ct., San Diego Cnty., filed 18 December 2023)

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.13 Page 1 of 33 EXHIBIT A

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.17 Page 5 of 33 13. The true names and capacities, whether individual, corporate, associate, or otherwise, 2 of defendants, DOES 1 through 50, inclusive, are unknown to Plaintiffs, who therefore sue these 3 defendants by their fictitious names. Plaintiffs are informed and believe, and based upon this 4 information and belief alleges, that each of the defendants designated herein as a fictitiously named 5 defendant is in some manner responsible for the events and happenings herein referred to, either contractually or tortuously, and caused damage to Plaintiffs as herein alleged. When Plaintiffs 7 ascertain the true names and capacities of DOES 1 through 50, inclusive, it will ask leave of this Court to amend its Complaint by setting forth the same. 9 14. Plaintiff is informed and believes, and based upon this information and belief alleges, 10 that at all times herein mentioned, each of the defendants was and is the agent, servant, and employee of each of the other defendants, and all of the things alleged to have been done by each 12 defendant were done in the capacity of and as agent of the other defendants. 13 BACKGROUND 14 15. On August 24, 2022, Plaintiffs filed a complaint for Breach of Contract, 15 Contractual/Equitable Audit, and Quantum Meruit in the Circuit Court of the City of Richmond 16 Virginia against Defendants in the civil action titled, Atlantic Wave Holdings, L.LC; and Secure 17 Community, LLC v. Cyberlux Corporation and Mark D. Schmidt (Case No. CL22-3882) (the - 18 "Underlying Lawsuit"). 19 16. During the Underlying Lawsuit Defendants Cyberlux and Mark D. Schmidt engaged 20 in evasive tactics, such as withholding documents and relevant information, and even went as far 21 as defying a court order. On March 28, 2023, the trial court in the Underlying Lawsuit sanctioned 22 Defendants twice and entered a default judgment against Defendants. A true and correct copy of 23 the Default Judgement in the Underlying Lawsuit is attached hereto as Exhibit "A", and 24 incorporated by this reference, as though set forth in full. 25 26 27 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.26 Page 14 of 33 1 WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, as follows: 2 1. For an order that the Collateral, specifically Datron World Communications, Inc., be foreclosed on, sold, and the proceeds of the sale be applied towards satisfaction and payment of 4 the expenses of sale, the total outstanding sum due and owing to Plaintiff in the amount of 5 $1,126,858.15, plus court-ordered interest, and Plaintiffs' attorneys fees and costs incurred herein; 2. For Defendants, and each of them, to be temporarily and permanently enjoined from selling, transferring, pledging, hypothecating, encumbering, or in any other way impairing the security value of Collateral, specifically Datron World Communications, Inc., described in the 9 UCC Financial Statement. 10 3. For judgment that the Collateral, specifically Datron World Communications, Inc. be 11 foreclosed upon, and for possession of the Collateral by Plaintiffs and/or sale or liquidation of the 12 Collateral, in accordance with the Commercial Code, with the proceeds of the sale to be applied 13 to the monies due and owing to Plaintiff; for a determination by the Court that Defendants are 14 liable for the sums secured by the Final Judgment, and for an Order that a deficiency judgment be 15 entered pursuant to the proceeding prescribed by law; and that Plaintiff or any other party to this 16 action may become a purchaser at the foreclosure sale by public or private sale; 17 4. This Court to enter its Order directing Defendants to provide any and all documents 18 relevant Defendant Cyberlux's Drone sales to Plaintiffs within ten (10) days of the Court's Order 19 5. This Court to enter an Order directing Defendants to provide all documents related to 20 the acquisition of Datron World Communications, Inc. to Plaintiff within ten (10) days of the 21 Court's Order. 22 6. This Court to enter an Order directing Defendants to provide all current Cyberlux 23 Corporation financial statements to Plaintiffs. 24 7. That a Receiver be appointed to obtain possession, custody, and control over the 25 Collateral and be given the power to preserve the Collateral, specifically Datron World 26 Communications, Inc. 27 8. For attorney's fees pursuant to contract and Judgment; 28 9. For Plaintiffs costs of suit herein; COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.19 Page 7 of 33 21. On October 20, 2023, Defendants filed an Acknowledgment of Lien with the California 2 Secretary of State, acknowledging the Plaintiffs' secured lien on various assets of Defendant 3 Cyberlux. A true and correct copy of the Acknowledgment of Lien is attached hereto as Exhibit 4 "E" and incorporated herein by this reference, as though set forth in full. 5 22. Hereinafter, Defendants' obligations to Plaintiffs under the Settlement Agreement and Final Judgement shall sometimes be referred to collectively as the "Obligations." 7 23. Paragraph 21 of the Settlement Agreement outlines, among other things, Plaintiffằ remedies for Defendants' breach and default on the Final Judgment. ("Default Terms"). 9 24. Plaintiffs contend that Defendants are in breach of the Settlement Agreement, 10 paragraphs 4(b), 4(c), 8, 10 and ultimately have Defaulted on the Final Judgement. 11 25. On or about July 1, 2023, payments were made by Defendants to Plaintiff AWH and 12 SC in the amount of $16,102.25; and to Plaintiff Strikepoint in the amount of $4,513.89. 13 26. On August 1, 2023, Defendants failed to pay the owed and ordered installment payment 14 to each of the Plaintiffs. 15 27. Shortly after the missed installment, Plaintiffs contacted Defendants, requesting the 16 status of payment, to which they did not receive a response. At this time, Defendants were in 17 breach of the Settlement Agreement and in Default of the Final Judgement. 18 28. In or about September 2023, Defendants made a miraculous late payment of $575,000 19 to Plaintiffs AWH and SC; and a payment of $50,000 to Plaintiff Strikepoint. This was merely a 20 lump sum drone sale made by Defendants which they attempted to characterize as "pre-payment" 21 after they were already in Default. Plaintiffs made it clear that they were already in arrears on 22 payment and this did not change the fact that Defendants were in Default. 23 29. On October 1, 2023, Defendants, again, failed to make their monthly installment 24 payment to Plaintiffs, bringing Defendants into Default. 25 30. Plaintiffs reached out to Defendants on multiple occasions over the course of the 26 months to inquire into the status of payment and requested information but received no response. 27 Again, Defendants were in Default. 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.13 Page 1 of 33 EXHIBIT A

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.21 Page 9 of 33 37. Defendants' default and their ongoing failure and refusal to cure such default is in direct 2 violation of the Final Judgment. It is also in breach of the Settlement Agreement terms which 3 outline the various Defaults and contain specifics related to Plaintiffs' security interests in the 4 Collateral. As such, Plaintiffs have no other option but to foreclose on the Collateral pursuant to 5 the Settlement Agreement, the Final Judgment, and the UCC Financing Statement, all of which are personally agreed to by Defendants via the Acknowledgment of Lien, which was filed with the 7 California Secretary of State. 38. In addition to repayment of debts and obligations owed in the Underlying Lawsuit, by 9 the terms of the Settlement Agreement and Final Judgment, Defendants agreed to pay attorneys' 10 fees and costs incurred by Plaintiffs in any action required for Plaintiffs to enforce the Settlement 11 Agreement and Final Judgement and satisfy Defendants' debt. Plaintiffs have been required to 12 retain legal counsel and incur other expenses. Indeed, Plaintiffs' counsel has attempted to settle 13 this dispute and recoup the amount owed in the Final Judgment providing Defendants notice of 14 the Default and requesting payment pursuant to the Final Judgment. This was unsuccessful. 15 39. Plaintiffs performed all the promises, covenants, and conditions it agreed to perform in 16 accordance with the terms of the Settlement Agreement and Final Judgement, except for those 17 promises, covenants, and conditions excused by the acts or omissions of said Defendants. 18 40. Pursuant to the Settlement Agreement and given the threatened decline of the secured 19 assets, time is of the essence. 20 FIRST CAUSE OF ACTION 21 (Judicial Foreclosure of Collateral Against All Defendants, and Does 1 through 50, 22 inclusive) 23 41. Plaintiffs repeat and reallege the allegations contained above, and incorporates them 24 herein by reference, as though set forth in full. 25 26 27 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.24 Page 12 of 33 55. As a further, direct, and proximate result of DefendantẾrongful conduct, Plaintiff 2 has incurred and will incur expenses to foreclose on the Collateral and recoup monies owned to 3 them including reasonable attorney's fees and legal expenses all to its further damage in an amount 4 according to proof at trial. 5 THIRD CAUSE OF ACTION (Appointment of a Receiver against All Defendants) 7 56. Plaintiff requests that the Court appoint a Receiver and enter its Order providing the Receiver with the appropriate power to oversee the sale of the Collateral and distribute funds 9 pursuant to further Orders of this Court. 10 57. Defendants have a history of mishandling funds and/or claiming that their assets are 11 worthless. 12 58. In the Underlying Lawsuit, Plaintiffs reviewed certified business records from 13 TowneBank and CitiBank, after entry of Sanction Order, that revealed Defendant Schmidt used 14 Cyberlux funds to pay the following credit card balances: (a) February - $21,264.53; (b) March - 15 $28,951.15; (c) April - $24,654.91; and (d) May - $17,843.30. Most of the credit card expenses 16 are not for any valid business purpose, but rather purely personal expenditures by Schmidt. 17 59. The Underlying Lawsuit also revealed that Defendant Schmidt reimbursed himself for 18 personal expenses, such as groceries, gasoline, household expenses, extravagant dinners, and 19 luxury items. For example, Schmidt spent and then reimbursed himself for over $2,700 spent at 20 Tumi (purses, luggage). Cyberlux paid for a meal at a restaurant near Schmidt's home in North 21 Carolina with a bill of $4,799.22. Also, Cyberlux paid for Schmidt's wife to make at least three 22 trips to Manhattan, in the first-class cabin before paying all her restaurant, hotel, and shopping 23 charges. Cyberlux, through Schmidt, even paid for Schmidt's son's alumni association 24 contribution, as well as travel for his daughter and her friends. These examples are only from one 25 credit card that was paid by Cyberlux, and it does not even address the tens of thousands of dollars 26 in cash withdrawals made by Defendant Schmidt. 27 60. Further, as mentioned above, Plaintiffs have proof that Defendants have sold numerous 28 drones, and have misrepresented such information in an effort to avoid their Obligations. COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.26 Page 14 of 33 1 WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, as follows: 2 1. For an order that the Collateral, specifically Datron World Communications, Inc., be foreclosed on, sold, and the proceeds of the sale be applied towards satisfaction and payment of 4 the expenses of sale, the total outstanding sum due and owing to Plaintiff in the amount of 5 $1,126,858.15, plus court-ordered interest, and Plaintiffs' attorneys fees and costs incurred herein; 2. For Defendants, and each of them, to be temporarily and permanently enjoined from selling, transferring, pledging, hypothecating, encumbering, or in any other way impairing the security value of Collateral, specifically Datron World Communications, Inc., described in the 9 UCC Financial Statement. 10 3. For judgment that the Collateral, specifically Datron World Communications, Inc. be 11 foreclosed upon, and for possession of the Collateral by Plaintiffs and/or sale or liquidation of the 12 Collateral, in accordance with the Commercial Code, with the proceeds of the sale to be applied 13 to the monies due and owing to Plaintiff; for a determination by the Court that Defendants are 14 liable for the sums secured by the Final Judgment, and for an Order that a deficiency judgment be 15 entered pursuant to the proceeding prescribed by law; and that Plaintiff or any other party to this 16 action may become a purchaser at the foreclosure sale by public or private sale; 17 4. This Court to enter its Order directing Defendants to provide any and all documents 18 relevant Defendant Cyberlux's Drone sales to Plaintiffs within ten (10) days of the Court's Order 19 5. This Court to enter an Order directing Defendants to provide all documents related to 20 the acquisition of Datron World Communications, Inc. to Plaintiff within ten (10) days of the 21 Court's Order. 22 6. This Court to enter an Order directing Defendants to provide all current Cyberlux 23 Corporation financial statements to Plaintiffs. 24 7. That a Receiver be appointed to obtain possession, custody, and control over the 25 Collateral and be given the power to preserve the Collateral, specifically Datron World 26 Communications, Inc. 27 8. For attorney's fees pursuant to contract and Judgment; 28 9. For Plaintiffs costs of suit herein; COMPLAINT

U230074215520 REAL OF TH STATE OF CALIFORNIA For Office Use Only Office of the Secretary of State UCC FINANCING STATEMENT (UCC 1) -FILED- California Secretary of State 1500 11th Street File No.: U230074215520 LIFORNI Sacramento, California 95814 (916) 653-3516 Date Filed: 10/20/2023 Submitter Information: Contact Name Eric M. Lemmer, Esq. Organization Name Arlington Law Group Phone Number (703) 842-3025šŚź Email Address elemmer@arlingtonlawgroup.com Address 1739 CLARENDON BOULEVARD ARLINGTON, VA 22209 Debtor Information: B2192-3038 10/20/2023 6:59 AM Received by California Secretary of State Debtor Name Mailing Address Mark D. Schmidt 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Cyberlux Corporation 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Secured Party Information: Secured Party Name Mailing Address Atlantic Wave Holdings, LLC 11 S. 12th Street Richmond, VA 23219 Secure Community, LLC 11 S. 12th Street Richmond, VA 23219 Indicate how documentation of Collateral is provided: Entered as Text Description: All of each Debtor's right, title and interest, whether now owned or hereafter acquired, in all of such Debtor's assets, including without limitation (i) any and all inventory (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), equipment, accounts, chattel paper, contractual rights, instruments, letter-of-credit rights, letters of credit, documents, deposit accounts, money, intellectual property (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), general intangibles, accounts receivable and other rights to payment and performance, (ii) any and all furniture, fixtures, attachments, accessions, accessories, fittings, tools, parts, supplies and commingled goods relating to any of the foregoing property, (ill) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, (iv) any and all insurance proceeds relating to any of the foregoing property, (v) any and all goodwill relating to any of the foregoing property, and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Datron World Communications, Inc. Indicate if Collateral is held in a Trust or is being administered by a Decedent's Personal Representative: Not Applicable Select an alternate Financing Statement type: Not Applicable Select an additional alternate Financing Statement type: Not Applicable Page 1 of 2

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.45 Page 33 of 33 Secretary of State Business Programs Division 1500 11th Street, Sacramento, CA 95814 CALIFORNI ARLINGTON LAW GROUP October 20, 2023 7:02 AM ERIC M. LEMMER, ESQ. File No.: U230074215520 1739 CLARENDON BOULEVARD ARLINGTON, VA 22209 Lien Acknowledgment This acknowledges the filing of the attached Lien document relavant to the information below. To access free copies of filed UCC documents, enter the File No. above in the Search module on the UCC Online web portal at bizfileonline.sos.ca.gov/search/ucc. DEBTOR INFORMATION Debtor Name: MARK D. SCHMIDT Debtor Address: 800 PARK OFFICES DRIVE SUITE 3209 RESEARCH TRIANGLE PARK, NC 27709 Debtor Name: CYBERLUX CORPORATION Debtor Address: 800 PARK OFFICES DRIVE SUITE 3209 RESEARCH TRIANGLE PARK, NC 27709 SECURED PARTY INFORMATION Secured Party Name: ATLANTIC WAVE HOLDINGS, LLC Secured Party Address: 11 S. 12TH STREET RICHMOND, VA 23219 Secured Party Name: SECURE COMMUNITY, LLC Secured Party Address: 11 S. 12TH STREET RICHMOND, VA 23219 FILING INFORMATION Lien Type: Ucc Lien File No.: U230074215520 File Date: 10/20/2023 6:58 AM Lapse Date: 10/20/2028 11:59 PM Page 1 of 1

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.16 Page 4 of 33 8. On June 15, 2023, Plaintiffs and Defendants executed a settlement agreement 2 (hereinafter the "Settlement Agreement") which acted as a security agreement between the parties 3 by creating a secured interest in various Cyberlux assets situated in the State of California, County 4 of San Diego. 5 9. On June 28, 2023, a Final Order and Judgement (hereafter "Final Judgement') in the underlying action was entered by a judge in the Commonwealth of Virginia memorializing the 7 Settlement Agreement into a formal judgment. The Final Judgment expressly provides for PlaintiffẾsecured interest in Cyberlux assets held in the County of San Diego. Pursuant to Article 9 IV, Section 1 of the United States Constitution, judgments from one state are generally recognized 10 and enforceable in other states under the Full Faith and Credit Clause. 11 10. On October 20, 2023, Plaintiffs filed a Uniform Commercial Code Financing Statement 12 ("UCC Financing Statement) with the California Secretary of State as agreed to in the parties' 13 Settlement Agreement and further ordered in the Final Judgment. The UCC Financing Statement 14 identifies, with specificity, the assets of Defendants subject to a secured interest by Plaintiffs 15 specifically categorizing collateral for debts owed to Plaintiffs and set forth in both the Settlement 16 Agreement and Final Judgement in the event Defendants defaulted on their obligations. 17 11. On October 20, 2023, Defendants filed a Lien Acknowledgment with the California 18 Secretary of State acknowledging the specific secured assets created by the Settlement Agreement, 19 Final Judgement, and UCC Financing Statement. 20 12. The Settlement Agreement, Final Judgement, UCC Financing Statement, and 21 Acknowledgment of Lien each individually and also collectively entitle Plaintiffs to secured 22 interest in Defendants' property located in California and more specifically in San Diego County, 23 which is within the judicial boundaries of the above-entitled Court. The Settlement Agreement, 24 Final Judgement, UCC Financing Statement, and Acknowledgment of Lien each provide that both 25 Defendants, individually and also jointly and severally, agreed to submit to the jurisdiction of the 26 courts in San Diego County in the event additional action was needed. The above Court is the 27 proper Court for the trial of this action. 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.35 Page 23 of 33 2 8 10 XHIBIT B 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COMPLAINT 16

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.29 Page 17 of 33 Dirginia: In the Circuit Court of the City of Richmond, John Marshall Courts Buibing ATLANTIC WAVE HOLDINGS, LLC, & SECURE COMMUNITY, LLC, Plaintiffs, Case No. CL22-3882 CYBERLUX CORPORATION, & MARK D. SCHMIDT, Defendants. ORDER On January 26, 2023 came the Plaintiffs, by counsel, to be heard on the Plaintiff Atlantic Wave Holdings, LLC's ("AWH") Motion for Sanctions against Defendant Cyberlux Corp. ("Cyberlux) filed in this Court on January 9, 2023. Counsel for the Defendants were relieved by the Court pursuant to Rule of Professional Conduct 1.16(c)' prior to the arguments on the Plaintiff AWH's motion. The Plaintiff AWH Noticed the January 26 hearing on January 12, 2023? The Court took the matter under advisement. Having reviewed the filings in this matter and heard the arguments of the Plaintiff AWH, the Court makes the findings and determinations outlined below. BACKGROUND The Plaintiffs filed a Complaint in this matter on August 24, 2022, alleging two claims of Breach of Contract, Contractual/Equitable Audit, and Quantum Meruit. On October 11, 2022, the Defendants filed responsive pleadings - an Answer and a Motion Motion to Withdraw as counsel having been filed with the Court on 12/27/22. 2 While the Notice was properly served on counsel, who have since withdrawn, counsel for the Defendants represented, as officers of the Court, that they had provided the Defendants with the Notice of Hearing and underlying Motion for Sanctions. CL22-3882 Page 1|6

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.15 Page 3 of 33 GENERAL ALLEGATIONS 2 1. This honorable Court is the appropriate venue for the instant action because the 3 secured assets to be foreclosed on which are the subject of this action are physically situated in 4 San Diego County, California. 5 2. At all times herein mentioned, Plaintiff AWH, has been a Virginia limited liability company, and at all times herein is permitted to conduct business in the State of California. 3. Plaintiffs are informed and believes and thereupon alleges that defendant Cyberlux Corporation ("Cyberlux"), was and is a corporation, formed under the laws of the State 9 Nevada and permitted to conduct business in the State of California. 10 4. Plaintiffs are informed and believe and thereupon allege that defendant Strikepoint, LLC, a Virginia limited liability company, is permitted to conduct business in the 12 State of California. 13 5. Plaintiffs are informed and believe and based thereon allege that Defendant 14 Cyberlux Corporation is a corporation owning physical assets and subsidiary businesses situated 15 in the State of California and County of San Diego. 16 6. Plaintiff is informed and believes and thereupon alleges that defendant Mark D. Schmidt, 17 president of defendant Cyberlux Corporation, is an individual residing in North Carolina 18 (Hereinafter, Cyberlux, and Mark D. Schmidt shall collectively be referred to as "Defendants.") 19 Defendant Schmidt is a named party to the settlement agreement, final judgment, UCC financing 20 statement, and acknowledgment of the lien described more fully herein. 21 7. Plaintiff is informed and believes and thereupon alleges that the property to be foreclosed 22 on, including but not limited to Datron World Communication, Inc., a corporation formed under 23 the laws of the State of California and a subsidiary of Cyberlux, is located within the judicial 24 boundaries of this Court. Datron World Communications is located at 995 Joshua Way Suite A, 25 Vista, CA 92081. 26 I!! 27 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.17 Page 5 of 33 13. The true names and capacities, whether individual, corporate, associate, or otherwise, 2 of defendants, DOES 1 through 50, inclusive, are unknown to Plaintiffs, who therefore sue these 3 defendants by their fictitious names. Plaintiffs are informed and believe, and based upon this 4 information and belief alleges, that each of the defendants designated herein as a fictitiously named 5 defendant is in some manner responsible for the events and happenings herein referred to, either contractually or tortuously, and caused damage to Plaintiffs as herein alleged. When Plaintiffs 7 ascertain the true names and capacities of DOES 1 through 50, inclusive, it will ask leave of this Court to amend its Complaint by setting forth the same. 9 14. Plaintiff is informed and believes, and based upon this information and belief alleges, 10 that at all times herein mentioned, each of the defendants was and is the agent, servant, and employee of each of the other defendants, and all of the things alleged to have been done by each 12 defendant were done in the capacity of and as agent of the other defendants. 13 BACKGROUND 14 15. On August 24, 2022, Plaintiffs filed a complaint for Breach of Contract, 15 Contractual/Equitable Audit, and Quantum Meruit in the Circuit Court of the City of Richmond 16 Virginia against Defendants in the civil action titled, Atlantic Wave Holdings, L.LC; and Secure 17 Community, LLC v. Cyberlux Corporation and Mark D. Schmidt (Case No. CL22-3882) (the - 18 "Underlying Lawsuit"). 19 16. During the Underlying Lawsuit Defendants Cyberlux and Mark D. Schmidt engaged 20 in evasive tactics, such as withholding documents and relevant information, and even went as far 21 as defying a court order. On March 28, 2023, the trial court in the Underlying Lawsuit sanctioned 22 Defendants twice and entered a default judgment against Defendants. A true and correct copy of 23 the Default Judgement in the Underlying Lawsuit is attached hereto as Exhibit "A", and 24 incorporated by this reference, as though set forth in full. 25 26 27 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.29 Page 17 of 33 Dirginia: In the Circuit Court of the City of Richmond, John Marshall Courts Buibing ATLANTIC WAVE HOLDINGS, LLC, & SECURE COMMUNITY, LLC, Plaintiffs, Case No. CL22-3882 CYBERLUX CORPORATION, & MARK D. SCHMIDT, Defendants. ORDER On January 26, 2023 came the Plaintiffs, by counsel, to be heard on the Plaintiff Atlantic Wave Holdings, LLC's ("AWH") Motion for Sanctions against Defendant Cyberlux Corp. ("Cyberlux) filed in this Court on January 9, 2023. Counsel for the Defendants were relieved by the Court pursuant to Rule of Professional Conduct 1.16(c)' prior to the arguments on the Plaintiff AWH's motion. The Plaintiff AWH Noticed the January 26 hearing on January 12, 2023? The Court took the matter under advisement. Having reviewed the filings in this matter and heard the arguments of the Plaintiff AWH, the Court makes the findings and determinations outlined below. BACKGROUND The Plaintiffs filed a Complaint in this matter on August 24, 2022, alleging two claims of Breach of Contract, Contractual/Equitable Audit, and Quantum Meruit. On October 11, 2022, the Defendants filed responsive pleadings - an Answer and a Motion Motion to Withdraw as counsel having been filed with the Court on 12/27/22. 2 While the Notice was properly served on counsel, who have since withdrawn, counsel for the Defendants represented, as officers of the Court, that they had provided the Defendants with the Notice of Hearing and underlying Motion for Sanctions. CL22-3882 Page 1|6

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.18 Page 6 of 33 17. On June 15, 2023, Plaintiffs and Defendants negotiated a settlement of the Underlying 2 Lawsuit, memorialized by the parties in the Settlement Agreement, which was intended to 3 concurrently serve as a security agreement, and was ultimately entered as consented and agreed 4 in the Amended Final Order and Judgement in the Underlying Lawsuit. Plaintiff will be moving 5 this Court to file a true and correct copy of the Settlement Agreement under seal and attached hereto as Exhibit "B", and incorporated by this reference, as though set forth in full. 7 18. In connection with the Settlement Agreement, on June 28, 2023, the Court in the Underlying Lawsuit entered an Amended Final Order and Judgment (Final Judgment) in favor 9 of the Plaintiffs for the principal sum of One Million Five Hundred Seventy-Two Thousand and 10 Five Hundred Dollars ($1,572,500), attorney's fees incurred in the Underlying Lawsuit as set forth 11 in the Settlement Agreement, sanctions in the amount of Ten Thousand Seven Hundred Thirty- 12 Seven and Fifty cents ($10,737.50), post-judgment interest of 12% per annum, and security interest 13 ond lien interest in all property held by Defendants if all sums are not paid. A true and correct 14 copy of the Final Judgement is attached hereto as Exhibit "C", and incorporated by this reference, 15 as though set forth in full. 16 19. The Settlement Agreement as memorialized in pertinent part by the Final Judgement, 17 provides that Defendants agree to pay the principal sum of $1,572,500. Under the terms of the 18 Settlement Agreement in paragraph 4(a) Defendants agreed to specific payment terms. 19 20. The Settlement Agreement, which was always intended by the Parties to function as a 20 security agreement, included terms in paragraph 7 - Security Interest and Lien Interest - wherein 21 Defendants agree and grant to Plaintiffs a "full security interest and lien interest" Defendants 22 assets, specifically outlining the types of assets to be secured (Collateral) in the event Defendants 23 breached their Obligation to pay as set forth by the Final Judgement. Plaintiffs duly perfected their 24 security interest in the Collateral by filing a UCC Financing Statement with the California 25 Secretary of State. A true and correct copy of the UCC Financing Statement is attached hereto as 26 Exhibit "D" and incorporated herein by this reference, as though set forth in full. 27 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.40 Page 28 of 33 WE ASK FOR THIS: W. Benjamin Pace (VSB No. 48633) Justin S. Feinman (VSB-No. 87511) WILLIAMS MULLEN, PC 200 South 10th Street, 16th Floor Richmond, Virginia 23219 804.420.6442 wpace@williamsmullen.com jfeinman@williamsmullen.com Counsel for Plaintiffs SEEN and AGREED: Marl D. S Mark D. Schmidt and Cyberlux Corporation 800 Park Offices Drive, Suite 3209 Research Triangle Park, NC 27709 By Mark D. Schmidt, Individually and as President of Cyberlux Corporation Charles Watts, Jr, in his capacity as Special Counsel or Cyberlux Corporation and Mark D. Schmidt 15 [Signature marks present at Plaintiffs counsel, Schmidt, and Watts endorsement lines.]

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.19 Page 7 of 33 21. On October 20, 2023, Defendants filed an Acknowledgment of Lien with the California 2 Secretary of State, acknowledging the Plaintiffs' secured lien on various assets of Defendant 3 Cyberlux. A true and correct copy of the Acknowledgment of Lien is attached hereto as Exhibit 4 "E" and incorporated herein by this reference, as though set forth in full. 5 22. Hereinafter, Defendants' obligations to Plaintiffs under the Settlement Agreement and Final Judgement shall sometimes be referred to collectively as the "Obligations." 7 23. Paragraph 21 of the Settlement Agreement outlines, among other things, Plaintiffằ remedies for Defendants' breach and default on the Final Judgment. ("Default Terms"). 9 24. Plaintiffs contend that Defendants are in breach of the Settlement Agreement, 10 paragraphs 4(b), 4(c), 8, 10 and ultimately have Defaulted on the Final Judgement. 11 25. On or about July 1, 2023, payments were made by Defendants to Plaintiff AWH and 12 SC in the amount of $16,102.25; and to Plaintiff Strikepoint in the amount of $4,513.89. 13 26. On August 1, 2023, Defendants failed to pay the owed and ordered installment payment 14 to each of the Plaintiffs. 15 27. Shortly after the missed installment, Plaintiffs contacted Defendants, requesting the 16 status of payment, to which they did not receive a response. At this time, Defendants were in 17 breach of the Settlement Agreement and in Default of the Final Judgement. 18 28. In or about September 2023, Defendants made a miraculous late payment of $575,000 19 to Plaintiffs AWH and SC; and a payment of $50,000 to Plaintiff Strikepoint. This was merely a 20 lump sum drone sale made by Defendants which they attempted to characterize as "pre-payment" 21 after they were already in Default. Plaintiffs made it clear that they were already in arrears on 22 payment and this did not change the fact that Defendants were in Default. 23 29. On October 1, 2023, Defendants, again, failed to make their monthly installment 24 payment to Plaintiffs, bringing Defendants into Default. 25 30. Plaintiffs reached out to Defendants on multiple occasions over the course of the 26 months to inquire into the status of payment and requested information but received no response. 27 Again, Defendants were in Default. 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.20 Page 8 of 33 31. On November 1, 2023, Defendants missed another, consecutive installment payment 2 owed to Plaintiffs. 3 32. On November 3, 2023, after Defendants were in Default for 2 months, Plaintiffs 4 exercised their rights under the Settlement Agreement and Final Judgement and requested 5 information and documentation under paragraph 8 of the Settlement Agreement. Defendants failed or refused to provide such information. 7 33. On November 13, 2023, again after no monthly payments had been made and Defendants' continued silence, Plaintiffs again requested further documentation and information 9 about specific financial documents in paragraph 8 of the Settlement Agreement. Defendants 10 provided no documentation to support such claim, despite being required to do so by the Settlement Agreement. Plaintiffs have confirmed through multiple sources that substantial financial 12 information is being withheld, despite Defendants' representations to the contrary which can only 13 be construed as sheer avoidance of Defendants Obligations. 14 34. As of the filing of this Complaint, Defendants have refused to give even the slightest 15 bit of information relevant to financial information as is required under the Settlement Agreement. 16 Defendants are making a specious claim that all details are "classified". 17 35. Despite not providing Plaintiffs with any information on their financials, including 18 drone sales, and claiming all information relevant to the financials were "classified", Defendants 19 made numerous posts on X, formerly Twitter, stating that they had received approximately 20 $78,000,000 for the sale of 2,000 Drones. 21 36. Despite owing Plaintiffs in excess of $1,000,000 as well as the value for Plaintiff's 22 stock, Defendants acquired Datron World Communication, located in San Diego County, paying 23 upon information and belief, a $5,500,000 million down payment. 24 25 26 27 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

U230074215520 REAL OF TH STATE OF CALIFORNIA For Office Use Only Office of the Secretary of State UCC FINANCING STATEMENT (UCC 1) -FILED- California Secretary of State 1500 11th Street File No.: U230074215520 LIFORNI Sacramento, California 95814 (916) 653-3516 Date Filed: 10/20/2023 Submitter Information: Contact Name Eric M. Lemmer, Esq. Organization Name Arlington Law Group Phone Number (703) 842-3025šŚź Email Address elemmer@arlingtonlawgroup.com Address 1739 CLARENDON BOULEVARD ARLINGTON, VA 22209 Debtor Information: B2192-3038 10/20/2023 6:59 AM Received by California Secretary of State Debtor Name Mailing Address Mark D. Schmidt 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Cyberlux Corporation 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Secured Party Information: Secured Party Name Mailing Address Atlantic Wave Holdings, LLC 11 S. 12th Street Richmond, VA 23219 Secure Community, LLC 11 S. 12th Street Richmond, VA 23219 Indicate how documentation of Collateral is provided: Entered as Text Description: All of each Debtor's right, title and interest, whether now owned or hereafter acquired, in all of such Debtor's assets, including without limitation (i) any and all inventory (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), equipment, accounts, chattel paper, contractual rights, instruments, letter-of-credit rights, letters of credit, documents, deposit accounts, money, intellectual property (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), general intangibles, accounts receivable and other rights to payment and performance, (ii) any and all furniture, fixtures, attachments, accessions, accessories, fittings, tools, parts, supplies and commingled goods relating to any of the foregoing property, (ill) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, (iv) any and all insurance proceeds relating to any of the foregoing property, (v) any and all goodwill relating to any of the foregoing property, and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Datron World Communications, Inc. Indicate if Collateral is held in a Trust or is being administered by a Decedent's Personal Representative: Not Applicable Select an alternate Financing Statement type: Not Applicable Select an additional alternate Financing Statement type: Not Applicable Page 1 of 2

U230074215520 REAL OF TH STATE OF CALIFORNIA For Office Use Only Office of the Secretary of State UCC FINANCING STATEMENT (UCC 1) -FILED- California Secretary of State 1500 11th Street File No.: U230074215520 LIFORNI Sacramento, California 95814 (916) 653-3516 Date Filed: 10/20/2023 Submitter Information: Contact Name Eric M. Lemmer, Esq. Organization Name Arlington Law Group Phone Number (703) 842-3025šŚź Email Address elemmer@arlingtonlawgroup.com Address 1739 CLARENDON BOULEVARD ARLINGTON, VA 22209 Debtor Information: B2192-3038 10/20/2023 6:59 AM Received by California Secretary of State Debtor Name Mailing Address Mark D. Schmidt 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Cyberlux Corporation 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Secured Party Information: Secured Party Name Mailing Address Atlantic Wave Holdings, LLC 11 S. 12th Street Richmond, VA 23219 Secure Community, LLC 11 S. 12th Street Richmond, VA 23219 Indicate how documentation of Collateral is provided: Entered as Text Description: All of each Debtor's right, title and interest, whether now owned or hereafter acquired, in all of such Debtor's assets, including without limitation (i) any and all inventory (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), equipment, accounts, chattel paper, contractual rights, instruments, letter-of-credit rights, letters of credit, documents, deposit accounts, money, intellectual property (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), general intangibles, accounts receivable and other rights to payment and performance, (ii) any and all furniture, fixtures, attachments, accessions, accessories, fittings, tools, parts, supplies and commingled goods relating to any of the foregoing property, (ill) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, (iv) any and all insurance proceeds relating to any of the foregoing property, (v) any and all goodwill relating to any of the foregoing property, and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Datron World Communications, Inc. Indicate if Collateral is held in a Trust or is being administered by a Decedent's Personal Representative: Not Applicable Select an alternate Financing Statement type: Not Applicable Select an additional alternate Financing Statement type: Not Applicable Page 1 of 2

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.34 Page 22 of 33 For the Forgoing reasons, the Court hereby IMPOSES SANCTIONS on Defendant Cyberlux and ORDERS that Defendant Cyberlux pay the attorney's fees and costs of Plaintiff AWH in the amount of $6,842.50 by May 26, 2023. The Court further ORDERS that Defendant Cyberlux's Answer be struck and further ENTERS DEFAULT JUDGEMENT on behalf of Plaintiff AWH against Plaintiff Cyberlux. The Court DIRECTS Plaintiff A WH to follow the docketing procedures of the Court to set a hearing on damages and Notice Defendant Cyberlux of proceedings. It is further ORDERED that the Clerk shall forward a certified copy of this order to both parties. Endorsements are dispensed with by the Court pursuant to Rule 1:13. ENTER: 3/20/2023 Jacqueline S. McClenney, Judge 25 The Court NOTES that Defendant Cyberlux's written objection did not comply with the requirements of Rule 4:9(b)(ii). _ CL22-3882 Page 616 [Judge signature present.]

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.40 Page 28 of 33 WE ASK FOR THIS: W. Benjamin Pace (VSB No. 48633) Justin S. Feinman (VSB-No. 87511) WILLIAMS MULLEN, PC 200 South 10th Street, 16th Floor Richmond, Virginia 23219 804.420.6442 wpace@williamsmullen.com jfeinman@williamsmullen.com Counsel for Plaintiffs SEEN and AGREED: Marl D. S Mark D. Schmidt and Cyberlux Corporation 800 Park Offices Drive, Suite 3209 Research Triangle Park, NC 27709 By Mark D. Schmidt, Individually and as President of Cyberlux Corporation Charles Watts, Jr, in his capacity as Special Counsel or Cyberlux Corporation and Mark D. Schmidt 15 [Signature marks present at Plaintiffs counsel, Schmidt, and Watts endorsement lines.]

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.40 Page 28 of 33 WE ASK FOR THIS: W. Benjamin Pace (VSB No. 48633) Justin S. Feinman (VSB-No. 87511) WILLIAMS MULLEN, PC 200 South 10th Street, 16th Floor Richmond, Virginia 23219 804.420.6442 wpace@williamsmullen.com jfeinman@williamsmullen.com Counsel for Plaintiffs SEEN and AGREED: Marl D. S Mark D. Schmidt and Cyberlux Corporation 800 Park Offices Drive, Suite 3209 Research Triangle Park, NC 27709 By Mark D. Schmidt, Individually and as President of Cyberlux Corporation Charles Watts, Jr, in his capacity as Special Counsel or Cyberlux Corporation and Mark D. Schmidt 15 [Signature marks present at Plaintiffs counsel, Schmidt, and Watts endorsement lines.]

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.40 Page 28 of 33 WE ASK FOR THIS: W. Benjamin Pace (VSB No. 48633) Justin S. Feinman (VSB-No. 87511) WILLIAMS MULLEN, PC 200 South 10th Street, 16th Floor Richmond, Virginia 23219 804.420.6442 wpace@williamsmullen.com jfeinman@williamsmullen.com Counsel for Plaintiffs SEEN and AGREED: Marl D. S Mark D. Schmidt and Cyberlux Corporation 800 Park Offices Drive, Suite 3209 Research Triangle Park, NC 27709 By Mark D. Schmidt, Individually and as President of Cyberlux Corporation Charles Watts, Jr, in his capacity as Special Counsel or Cyberlux Corporation and Mark D. Schmidt 15 [Signature marks present at Plaintiffs counsel, Schmidt, and Watts endorsement lines.]

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.24 Page 12 of 33 55. As a further, direct, and proximate result of DefendantẾrongful conduct, Plaintiff 2 has incurred and will incur expenses to foreclose on the Collateral and recoup monies owned to 3 them including reasonable attorney's fees and legal expenses all to its further damage in an amount 4 according to proof at trial. 5 THIRD CAUSE OF ACTION (Appointment of a Receiver against All Defendants) 7 56. Plaintiff requests that the Court appoint a Receiver and enter its Order providing the Receiver with the appropriate power to oversee the sale of the Collateral and distribute funds 9 pursuant to further Orders of this Court. 10 57. Defendants have a history of mishandling funds and/or claiming that their assets are 11 worthless. 12 58. In the Underlying Lawsuit, Plaintiffs reviewed certified business records from 13 TowneBank and CitiBank, after entry of Sanction Order, that revealed Defendant Schmidt used 14 Cyberlux funds to pay the following credit card balances: (a) February - $21,264.53; (b) March - 15 $28,951.15; (c) April - $24,654.91; and (d) May - $17,843.30. Most of the credit card expenses 16 are not for any valid business purpose, but rather purely personal expenditures by Schmidt. 17 59. The Underlying Lawsuit also revealed that Defendant Schmidt reimbursed himself for 18 personal expenses, such as groceries, gasoline, household expenses, extravagant dinners, and 19 luxury items. For example, Schmidt spent and then reimbursed himself for over $2,700 spent at 20 Tumi (purses, luggage). Cyberlux paid for a meal at a restaurant near Schmidt's home in North 21 Carolina with a bill of $4,799.22. Also, Cyberlux paid for Schmidt's wife to make at least three 22 trips to Manhattan, in the first-class cabin before paying all her restaurant, hotel, and shopping 23 charges. Cyberlux, through Schmidt, even paid for Schmidt's son's alumni association 24 contribution, as well as travel for his daughter and her friends. These examples are only from one 25 credit card that was paid by Cyberlux, and it does not even address the tens of thousands of dollars 26 in cash withdrawals made by Defendant Schmidt. 27 60. Further, as mentioned above, Plaintiffs have proof that Defendants have sold numerous 28 drones, and have misrepresented such information in an effort to avoid their Obligations. COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.24 Page 12 of 33 55. As a further, direct, and proximate result of DefendantẾrongful conduct, Plaintiff 2 has incurred and will incur expenses to foreclose on the Collateral and recoup monies owned to 3 them including reasonable attorney's fees and legal expenses all to its further damage in an amount 4 according to proof at trial. 5 THIRD CAUSE OF ACTION (Appointment of a Receiver against All Defendants) 7 56. Plaintiff requests that the Court appoint a Receiver and enter its Order providing the Receiver with the appropriate power to oversee the sale of the Collateral and distribute funds 9 pursuant to further Orders of this Court. 10 57. Defendants have a history of mishandling funds and/or claiming that their assets are 11 worthless. 12 58. In the Underlying Lawsuit, Plaintiffs reviewed certified business records from 13 TowneBank and CitiBank, after entry of Sanction Order, that revealed Defendant Schmidt used 14 Cyberlux funds to pay the following credit card balances: (a) February - $21,264.53; (b) March - 15 $28,951.15; (c) April - $24,654.91; and (d) May - $17,843.30. Most of the credit card expenses 16 are not for any valid business purpose, but rather purely personal expenditures by Schmidt. 17 59. The Underlying Lawsuit also revealed that Defendant Schmidt reimbursed himself for 18 personal expenses, such as groceries, gasoline, household expenses, extravagant dinners, and 19 luxury items. For example, Schmidt spent and then reimbursed himself for over $2,700 spent at 20 Tumi (purses, luggage). Cyberlux paid for a meal at a restaurant near Schmidt's home in North 21 Carolina with a bill of $4,799.22. Also, Cyberlux paid for Schmidt's wife to make at least three 22 trips to Manhattan, in the first-class cabin before paying all her restaurant, hotel, and shopping 23 charges. Cyberlux, through Schmidt, even paid for Schmidt's son's alumni association 24 contribution, as well as travel for his daughter and her friends. These examples are only from one 25 credit card that was paid by Cyberlux, and it does not even address the tens of thousands of dollars 26 in cash withdrawals made by Defendant Schmidt. 27 60. Further, as mentioned above, Plaintiffs have proof that Defendants have sold numerous 28 drones, and have misrepresented such information in an effort to avoid their Obligations. COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

U230074215520 REAL OF TH STATE OF CALIFORNIA For Office Use Only Office of the Secretary of State UCC FINANCING STATEMENT (UCC 1) -FILED- California Secretary of State 1500 11th Street File No.: U230074215520 LIFORNI Sacramento, California 95814 (916) 653-3516 Date Filed: 10/20/2023 Submitter Information: Contact Name Eric M. Lemmer, Esq. Organization Name Arlington Law Group Phone Number (703) 842-3025šŚź Email Address elemmer@arlingtonlawgroup.com Address 1739 CLARENDON BOULEVARD ARLINGTON, VA 22209 Debtor Information: B2192-3038 10/20/2023 6:59 AM Received by California Secretary of State Debtor Name Mailing Address Mark D. Schmidt 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Cyberlux Corporation 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Secured Party Information: Secured Party Name Mailing Address Atlantic Wave Holdings, LLC 11 S. 12th Street Richmond, VA 23219 Secure Community, LLC 11 S. 12th Street Richmond, VA 23219 Indicate how documentation of Collateral is provided: Entered as Text Description: All of each Debtor's right, title and interest, whether now owned or hereafter acquired, in all of such Debtor's assets, including without limitation (i) any and all inventory (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), equipment, accounts, chattel paper, contractual rights, instruments, letter-of-credit rights, letters of credit, documents, deposit accounts, money, intellectual property (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), general intangibles, accounts receivable and other rights to payment and performance, (ii) any and all furniture, fixtures, attachments, accessions, accessories, fittings, tools, parts, supplies and commingled goods relating to any of the foregoing property, (ill) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, (iv) any and all insurance proceeds relating to any of the foregoing property, (v) any and all goodwill relating to any of the foregoing property, and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Datron World Communications, Inc. Indicate if Collateral is held in a Trust or is being administered by a Decedent's Personal Representative: Not Applicable Select an alternate Financing Statement type: Not Applicable Select an additional alternate Financing Statement type: Not Applicable Page 1 of 2

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.34 Page 22 of 33 For the Forgoing reasons, the Court hereby IMPOSES SANCTIONS on Defendant Cyberlux and ORDERS that Defendant Cyberlux pay the attorney's fees and costs of Plaintiff AWH in the amount of $6,842.50 by May 26, 2023. The Court further ORDERS that Defendant Cyberlux's Answer be struck and further ENTERS DEFAULT JUDGEMENT on behalf of Plaintiff AWH against Plaintiff Cyberlux. The Court DIRECTS Plaintiff A WH to follow the docketing procedures of the Court to set a hearing on damages and Notice Defendant Cyberlux of proceedings. It is further ORDERED that the Clerk shall forward a certified copy of this order to both parties. Endorsements are dispensed with by the Court pursuant to Rule 1:13. ENTER: 3/20/2023 Jacqueline S. McClenney, Judge 25 The Court NOTES that Defendant Cyberlux's written objection did not comply with the requirements of Rule 4:9(b)(ii). _ CL22-3882 Page 616 [Judge signature present.]

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.39 Page 27 of 33 and MARK D. SCHMIDT, to resolve the claims alleged in Plaintiffs' Complaint and certain other claims as agreed to by the parties pursuant to the parties' separate agreement. b. The parties agree that this Final Judgement shall not be dischargeable in bankruptcy to the fullest extent permissible at law, and Defendants hereby waive all rights of reconsideration or appeal. Nor shall it be subject to any contribution or reduced through the payments) of any other parties in this matter. Rather it shall be the sole obligation of Defendants. C. That the Plaintiffs be awarded all of their costs, including reasonable attorney's fees of $177,126.19 per the parties' settlement agreement, evidenced by affidavits, and consented to by defendants, plus sanctions of $3,895.00 and $6,842.50, as provided by the Court's previous Orders, and post judgment interest at the rate of 12% per annum, as provided in the parties' agreement, from the date of entry of this order on the damages incurred in this matter. That the parties have agreed to a security interest and lien interest in all property of Defendants in favor of Plaintiffs until all sums are paid, and such security interest may be further memorialized through the filing of appropriate UCC-1 forms and the filing of appropriate Liens. Plaintiffs' Complaint is hereby dismissed without prejudice. THIS CAUSE IS ENDED. ENTERED this 28th day of June, 2023. [Judge signature present; copy certified by Clerk.] Hon. Jacqueline S. McClenney, Presiding Judge Cireuit Court for the City of Richmond Teste: EDWARD F JEWETT, CLERK

U230074215520 REAL OF TH STATE OF CALIFORNIA For Office Use Only Office of the Secretary of State UCC FINANCING STATEMENT (UCC 1) -FILED- California Secretary of State 1500 11th Street File No.: U230074215520 LIFORNI Sacramento, California 95814 (916) 653-3516 Date Filed: 10/20/2023 Submitter Information: Contact Name Eric M. Lemmer, Esq. Organization Name Arlington Law Group Phone Number (703) 842-3025šŚź Email Address elemmer@arlingtonlawgroup.com Address 1739 CLARENDON BOULEVARD ARLINGTON, VA 22209 Debtor Information: B2192-3038 10/20/2023 6:59 AM Received by California Secretary of State Debtor Name Mailing Address Mark D. Schmidt 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Cyberlux Corporation 800 Park Offices Drive Suite 3209 Research Triangle Park, NC 27709 Secured Party Information: Secured Party Name Mailing Address Atlantic Wave Holdings, LLC 11 S. 12th Street Richmond, VA 23219 Secure Community, LLC 11 S. 12th Street Richmond, VA 23219 Indicate how documentation of Collateral is provided: Entered as Text Description: All of each Debtor's right, title and interest, whether now owned or hereafter acquired, in all of such Debtor's assets, including without limitation (i) any and all inventory (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), equipment, accounts, chattel paper, contractual rights, instruments, letter-of-credit rights, letters of credit, documents, deposit accounts, money, intellectual property (including without limitation relating to tactical military communications equipment, HF communication and software solutions equipment, Spectre H series HF transceivers, Spectre M series multi-band SDR transceivers and Spectre V series VHF transceivers, as well as all research and development for future technology), general intangibles, accounts receivable and other rights to payment and performance, (ii) any and all furniture, fixtures, attachments, accessions, accessories, fittings, tools, parts, supplies and commingled goods relating to any of the foregoing property, (ill) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, (iv) any and all insurance proceeds relating to any of the foregoing property, (v) any and all goodwill relating to any of the foregoing property, and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Datron World Communications, Inc. Indicate if Collateral is held in a Trust or is being administered by a Decedent's Personal Representative: Not Applicable Select an alternate Financing Statement type: Not Applicable Select an additional alternate Financing Statement type: Not Applicable Page 1 of 2

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.14 Page 2 of 33 ELECTRONICALLY FILED Alexi Ozols, SBN 286048 Superior Court of Califomia, 2 Ozols Law Firm County of San Diego 8880 Rio San Diego Drive, Suite 800 12/18/2023 at 06:04:05 PM 3 San Diego, CA 92108 Clerk of the Superior Court By Eva Noriega, Deputy Clerk Telephone: (619) 880-2407 4 Email: info@findlegaladvice.org 5 Greta M. Schultz, SBN 290456 Jessica Heppenstall, SBN 259489 Heppenstall & Schultz, A Professional Corporation 7 555 West Beech Street, Suite 235 San Diego, CA 92101 Telephone: (619) 993-9264 Email: greta@heppenstallschultz.com 10 Attorneys for Plaintiffs 11 Atlantic Wave Holdings, LLC Secure Community, LLC 12 Strikepoint Consulting, LLC 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN DIEGO - CENTRAL JUSTICE CENTER 16 17 ATLANTIC WAVE HOLDINGS, LLC, a CASE NO. 37-2023-00055306-CU-MC-CTL Virginia limited liability company, SECURE 18 COMMUNITY, LLC, a Virginia limited 19 liability company, and STRIKEPOINT COMPLAINT CONSULTING, LLC, a Virginia limited 20 liability company, 1. Judicial Foreclosure 2. Injunctive Relief 21 Plaintiffs, 3. Appointment of Receiver 22 VS. 23 CYBERLUX CORPORATION, a Nevada corporation; MARK D. SCHMIDT, an 24 individual; and DOES 1 to 50, Inclusive; 25 Defendants. 26 27 Plaintiff Atlantic Wave Holdings, LLC ("AWH"), Secure Community, LLC ("SC"), and Strikepoint Consulting, LLC ("SPC") (collectively "Plaintiffs') complain and allege as follows: 28 COMPLAINT

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.13 Page 1 of 33 EXHIBIT A

Case 3:24-cv-00196-RBM-VET Document 1-2 Filed 01/30/24 PagelD.13 Page 1 of 33 EXHIBIT A