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Sources/GT-S-D5AA4414CB21

Context source · GT-S-D5AA4414CB21

Filed affidavit concerning the programme

Original sourceSworn declaration
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SHA-256 d5aa4414cb218533eac8…67 pages · 18 MB

DISTILLATES

What the source contains

Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.

observationobservation

Controlling number

$38.7 million

Read the anchor · page 18
According to the sworn declaration of William Welter in the Atlantic Wave case, bank records produced in discovery confirmed that Cyberlux "received a payment of $38.7 million from a US Government contract to supply drones to Ukraine on September 8, 2023." Rather than use these funds to satisfy creditor obligations or maintain business operations, "Defendants transferred significant sums of money to personal 10
observationobservation

Controlling number

$79 million

Read the anchor · page 23
Montague rendered valuable services to Cyberlux, including identifying acquisition targets, negotiating complex commercial transactions, developing strategic business relationships, and specifically sourcing the $79 million HII contract for Ukraine drone sales.
claimallegation

Source proposition

Despite receiving approximately $38.7 million in payments during 2023 under the Ukraine drone contract-a Commissionable Contract expressly identified in Schedule 2 of the Agreement and subject to the 5% commission rate-Cyberlux has failed to pay Montague any portion of the $1,935,000 in commissions due on these receipts.

Read the anchor · page 15
Despite receiving approximately $38.7 million in payments during 2023 under the Ukraine drone contract-a Commissionable Contract expressly identified in Schedule 2 of the Agreement and subject to the 5% commission rate-Cyberlux has failed to pay Montague any portion of the $1,935,000 in commissions due on these receipts.
claimallegation

Source proposition

Montague rendered valuable services to Cyberlux, including identifying acquisition targets, negotiating complex commercial transactions, developing strategic business relationships, and specifically sourcing the $79 million HII contract for Ukraine drone sales.

Read the anchor · page 23
Montague rendered valuable services to Cyberlux, including identifying acquisition targets, negotiating complex commercial transactions, developing strategic business relationships, and specifically sourcing the $79 million HII contract for Ukraine drone sales.
claimallegation

Source proposition

Based on information available to Montague, including Cyberlux's public financial disclosures and RFA Responses, Cyberlux received approximately $38.7 million in payments from HII during September 2023 under the Ukraine drone contract.

Read the anchor · page 4
Based on information available to Montague, including Cyberlux's public financial disclosures and RFA Responses, Cyberlux received approximately $38.7 million in payments from HII during September 2023 under the Ukraine drone contract.
claimallegation

Source proposition

Cyberlux has actively encumbered the Ukraine drone contract receivables-the very receivables on which Montague holds commission rights-to secure financing that prejudices Montague's interests.

Read the anchor · page 19
Cyberlux has actively encumbered the Ukraine drone contract receivables-the very receivables on which Montague holds commission rights-to secure financing that prejudices Montague's interests.
entityobservation

Atlantic Wave Holdings, LLC

Read the anchor · page 15
ract during 2023. 23. Furthermore, based upon documents filed by the former receiver of Cyberlux, in Atlantic Wave Holdings, LLC, et al. v. Cyberlux Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris County, Texas (the "Atlantic Wave case"), Montague has learned that HII is expected to make an additional payment of $25,795,303.38 to Cyberlux in the near term. 24. These payments-both the $38.7 million payment and the forthcoming $25.7 payment-are subject to Montague's entitlement to commissions at the contractual rate of 5% under the 2023 Consulting Agreement. Ma
entityobservation

Cyberlux Corporation

Read the anchor · page 3
yable pursuant to the Agreement. A true and correct copy of this Memorandum is attached to the Verified Complaint as Exhibit C. COMMISSION STRUCTURE FOR UKRAINE DRONE CONTRACTS 7. Under Section 3.3 of the 2023 Agreement, Montague is to receive five percent (5%) of the gross amounts payable to Cyberlux for "Ukraine-related commercial contracts." 8. Schedule 2 of the 2023 Agreement specifically identifies as a Commissionable Contract "[t]hat certain line of business related to the sale of tactical drones from time to time for use by the Ministry of Defense of Ukraine, including without limitatio
entityobservation

HII Mission Technologies Corp.

Read the anchor · page 4
opportunities, and sourcing the Ukraine drone contracts that became the subject of Cyberlux 's contract with Huntington Ingalls Industries ("HII"). 11. Montague was instrumental in securing the $79 million HII contract for Cyberlux to supply FlightEye drones to Ukraine's Ministry of Defense, which represents the largest contract in Cyberlux' s history. CYBERLUX'S RECEIPT OF CONTRACT PROCEEDS 12. A true and correct co
entityobservation

Legalist

Read the anchor · page 19
ht to payments from the drone contract." 40. That assignment directly conflicts with Montague's contractual right to receive 5% commissions on all Ukraine drone contract payments. Moreover, Legalist's claimed indebtedness, as of January 24, 2025, totaled "$7,313,627.17 with fees accruing at a daily rate of $4,364.46." A June 11, 2025 email confirms that Cyberlux has further encumbered Ukraine drone contract payments-by over $2 million in secured debt-via Legalist's "protective advance." In that email, counsel for Cyberlux confirmed the wire transfer. Cyberlux's Active Measures to Place Assets
entityobservation

Datron World Communications

Read the anchor · page 11
one manufacturing arm of Cyberlux; • Leading, negotiating and closing on Cyberlux' s acquisition of Datron World Communications, Inc. ("Datron") and subsequently integrating 3
entityobservation

Datron World Communications, Inc.

Read the anchor · page 11
one manufacturing arm of Cyberlux; • Leading, negotiating and closing on Cyberlux' s acquisition of Datron World Communications, Inc. ("Datron") and subsequently integrating 3
entityobservation

Denis Kalenja

Read the anchor · page 2
VISION DURHAM COUNTY NO. 25CV006375-310 MONTAGUE CAPITAL PARTNERS, LLC, Plaintiff, vs. AFFIDAVIT OF DENIS KALENJA CYBERLUX CORPORATION Defendant. 1. I am the Managing Partner of Montague Capital Partners, LLC ("Montague"), the plaintiff in this action. I submit this affidavit in support of Mo
entityobservation

HII

Read the anchor · page 4
rone contracts that became the subject of Cyberlux 's contract with Huntington Ingalls Industries ("HII"). 11. Montague was instrumental in securing the $79 million HII contract for Cyberlux to supply FlightEye drones to Ukraine's Ministry of Defense, which represents the largest co
entityobservation

Holly Schmidt

Read the anchor · page 61
16. Admit that Mark Schmidt is the CEO of Cyberlux Corporation. RESPONSE: Admitted. 17. Admit that Holly Schmidt is the spouse of Mark Schmidt. RESPONSE: Admitted. 18. Admit that Cyberlux began transferring funds from the September 2023 HII payment on the same day that the HII payment was re
entityobservation

Legalist SPV III, LP

Read the anchor · page 17
of Asset Dissipation," infra.) Recently, in April 2025, after defaulting on a credit agreement with Legalist SPV III, LP ("Legalist"), Cyberlux amended its line of credit with Legalist to increase 9
entityobservation

Mark Daniel Schmidt

Mark Schmidt

Read the anchor · page 37
d this Agreement as of the day and year first above written. CYB~RLUX ~RATION 7#.e _ By: ~~~k Name: Mark Schmidt Title: CEO -7-
entityobservation

Montague Capital Partners, LLC

Read the anchor · page 2
H CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION DURHAM COUNTY NO. 25CV006375-310 MONTAGUE CAPITAL PARTNERS, LLC, Plaintiff, vs. AFFIDAVIT OF DENIS KALENJA CYBERLUX CORPORATION Defendant. 1. I am the Managing Partner of Montague Capital Partners, LLC ("Montague"), the plaintiff in this actio
entityobservation

United States Government

Government

Read the anchor · page 9
small-cap lighting company into a legitimate defense contractor with tens of millions of dollars in government contracts. 2. Despite Montague's instrumental role in sourcing and securing the largest contract in Cyberlux's history-a $79 million agreement to supply drones to Ukraine's Minist
eventattribution

Dated source occurrence

According to the sworn declaration of William Welter in the Atlantic Wave case, bank records produced in discovery confirmed that Cyberlux "received a payment of $38.7 million from a US Government contract to supply drones to Ukraine on September 8, 2023." Rather than use these funds to satisfy creditor obligations or maintain business operations, "Defendants transferred significant sums of money to personal 10

Read the anchor · page 18
According to the sworn declaration of William Welter in the Atlantic Wave case, bank records produced in discovery confirmed that Cyberlux "received a payment of $38.7 million from a US Government contract to supply drones to Ukraine on September 8, 2023." Rather than use these funds to satisfy creditor obligations or maintain business operations, "Defendants transferred significant sums of money to personal 10
observation

CONNECT

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