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Sources/GT-S-DDC018F1AFAA

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Declaration of Anthony R. Gonzalez

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DISTILLATES

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observationobservation

TAG $1,224,275.14 default judgment,29 August2025.

Read the anchor · page 19
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 19 of 145 PagelD# 2153 Case No. 1:25-CV-00805-GPG-MDB Document 27 filed 08/29/25 USDC Colorado pg 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 25-cv-00805-GPG-MDB THIN AIR GEAR, LLC, Plaintiff, V. CYBERLUX CORPORATION d/b/a CATALYST MACHINEWORKS, LLC, Defendant. FINAL JUDGMENT In accordance with the orders filed during the pendency of this case, and pursuant to Federal Rule of Civil Procedure 58(a), the following Final Judgment is hereby entered. Pursuant to the [D. 26] Order entered by Judge Gordon P. Gallagher on August 29, 2025, it is ORDERED that the Recommendation of the United States Magistrate Judge Maritza Dominquez Braswell [D. 25] is AFFIRMED and ADOPTED as an Order of the Court. It is FURTHER ORDERED that Plaintiff's Motion for Entry of Default Judgment [D. 18] is GRANTED, It is FURTHER ORDERED that the parties proposed Order Granting Stipulation for Final Judgment [D. 21] is DENIED AS MOOT. It is FURTHER ORDERED that Plaintiff is awarded $1,224,275.14 in damages. It is FURTHER ORDERED that judgment is entered in favor of Plaintiff and against Defendant. This case is closed. TAG-0003
observationobservation

Legalist claimed $13,204,742.88 as at9 March2026, with ordinary/protective advance distinction.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 40 of 145 PagelD# 2174 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. LEGALIST SPY IL, LP'S RESPONSE TO JOINT DISCOVERY PLAN INTERROGATORY AND REQUESTS FOR PRODUCTION Interpleader Defendant/Claimant Legalist SPV III, LP (Legalist), provides the following response to the pre-settlement interrogatory and requests for production providing in the Joint Discovery Plan (ECF No. 149). Interrogatory Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) the amount of the proceeds that you claim; (b) the legal basis for your right to the proceeds; (c) how the amount you claim became a liquidated amount or, if not liquidated, state so; (d) whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment; (e) whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any; (f) whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim; and (g) for any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed. Response: (a) the amount of the proceeds that you claim Legalist claims $13,204,742.88, comprising of: • $10,033,639.75 principal • $2,653,970.84 unpaid interest • $112,500.00 commitment fee
observationobservation

AW/SC one later $6m stock judgment; initial judgment separately reported satisfied.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 47 of 145 PagelD# 2181 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH') and in Response to Interpleader Defendant Cyberlux Corporation's ("CYBL') Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC ("SC'). Accordingly, while each a party, A WH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide Marketable Trading" CYBL stock. 3. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreemenằ_ dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
observationobservation

Fairwinds $2,348,542; no security, interest or attorney fees asserted.

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Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 131 of 145 PagelD# 2265 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff CYBERLUX CORPORATION; Civil Action No: 3:25-cv-483-JAG ATLANTIC WAVE HOLDINGS, LLC; SECURE COMMUNITY, LLC; LEGALIST SPY III, LP; UNITED STATES OF AMERICA; ADVANCED NAVIGATION AND POSITIONING CORPORATION; and ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation, Interpleader Defendants/Claimants FAIRWINDS TECHNOLOGIES, LLC'S RESPONSE TO THE JOINT DISCOVERY PLAN INTERROGATORY AND DOCUMENT REQUESTS Now comes Interpleader Defendant/Claimant Fairwinds Technologies, LLC ("Fairwinds), who submits the following responses to the Interrogatory and Document Requests agreed to by all Parties in the Joint Discovery Plan [Doc. 147] filed with the Court on February 12, 2026, as follows: INTERROGATORY: Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) The amount of the proceeds that you claim. Response: Cyberlux owes Fairwinds $2,348,542.00. #111272386v1
observationobservation

Modification4 excerpt: only page1 of8; government approval conditions sections3–6.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 145 of 145 PagelD# 2279 Case 4:25-ev-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9 CONFIDENTIAL INFORMATION Page 1 of 8 REDACTED Mission Technologies Modification No. 4 to Subcontract No. P000043846 To Effectuate a Terminotion Settlement This Modification No. 4 to Effectuate a Termination Settlement (the "Agreement"), effectiye as of February 26, 2025, is made by and between HII Mission Technologies Corp. ("HI"), a Delaware company with offices locatea at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (Cyberlux)y a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NÇ 27709 (each a "Party," and collectively, "the Parties"). WHEREAS, the Parties entered into Subcontract No. P000043846, doted Augyst 29, 2023 (the "Subcontract"). issued under HII's Prime Tosk Order 47QFCA22F0039 and Technical Direction Lefter 1-023 (ITDL 231) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the "Government"); WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HIl in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the SWO"); WHEREAS, the Government terminted the TDL 23 work scope Yor convenience on May 13, 2024, and HIl subsequently exercised the termintion provisions of Subcontract Section 32.1 on May 17, 2024; and WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement. NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties age as follows: 1. Review and Approval. a. The Parties acknowledge that pursuant to FAR 49.108-3, the Government expects HIl to submit a subcontractor settlementato The Government Contracting Officer tor review and opproval. Accordingly, the Porties agree thot Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement. Following execution of the Agreement, HIl will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereofter, HIl will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith, to gotain such approval. In furtherance of that effort, Cyberlux shall cooperate with any auditor other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract. 2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action. A division of HIl Issued by: Mission Technologies Commana Media HIl Proprietary
quotationattribution

Cyberlux/Datron acknowledge continuing defaults in the signed restated financing agreement.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 26 of 145 PagelD# 2160 Docusign Envelope ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 Huntington Bank accounts payable aging, and any applicable related contracts Bank: and/or purchase orders not previously provided to Lender Account Name: Cyberlux Corporation (collectively, an "Advance Request") and the completion of Account No: Lender's due diligence relating thereto, and the receipt by Lender ABA No: of a satisfactory counterparty acknowledgement of an executed Instrument of Assignment in the form attached as Exhibit C, 9.9 Borrower acknowledges that Events of Default have Lender shall promptly disburse the requested amount to occurred and are continuing under Section 21 hereunder, Borrower, subject to the terms hereof. including those described in the Notices of Default LENDER SHALL NOT PROCESS MORE THAN ONE delivered to Borrower on November 4, 2024 and March ADVANCE REQUEST PER CALENDAR WEEK. 31, 2025 (collectively, the "Existing Defaults). Subject to the terms of this Section 9.9, Lender agrees to Borrower agrees, in consideration for funds loaned to it temporarily forbear from exercising its rights and by Lender under this Agreement, to pay to Lender the following remedies solely with respect to the Existing Detaults. amounts (pursuant to the wire instructions in Section 5) to be charged thereon: As used herein, the "Forbearance Period" means the period commencing on the Second Amendment Date and 9.1 Subject to the Credit Limit, the total amount of funding ending on the earlier of (a) the date that is 90 days available to Borrower hercunder shall be 50% of the face thereafter, or (b) the occurrence of any Event of Default value of each eligible purchase order, task order, delivery (other than the Existing Defaults), unless extended in order, or statement of work related to writing by Lender in its sole discretion government contracts that (x) has not been disqualified by Lender for credit or other reasons and (y) is not During the Forbearance Period: disputed by the Government Account Debtor (a) Borrower reaffirms its acknowledgment of the (collectively, the "Eligible Purchase Orders"); less Existing Defaults and agrees that, pursuant to Section 22, amounts outstanding hereunder. default interest shall continue to accrue at a rate of 4.75% 9.2 Interest on outstanding principal balances shall accrue per Event of Default, for a combined rate of 9.5% per daily at the U.S. prime rate in effect from time to time annum, compounded and capitalized monthly; (divided by 365) plus 0.0164%, with interest accrued in (b) Borrower shall pay a forbearance fee equal to 1.00% a given calendar month due and payable in arrears on the of the Temporary Increase (as defined below), deemed earlier to occur of the Facility Maturity Date or the last fully earned as of the Second Amendment Date and business day of the following month (the earlier of such capitalized into the principal balance. Such fee shall be date, the "Advance Maturity Date"). paid in three equal monthly installments commencing on 9.3 Omitted. the first Advance Maturity Date following the Second Amendment Date; 9.4 A commitment fee equal to 1.00% of the Credit Limit shall be deemed fully earned by Lender on the date (c) The Credit Limit shall be temporarily increased by hereof and due and payable in 12 equal monthly $5,300,000 (the "Temporary Increase), resulting in a installments beginning upon the first Advance Maturity temporary aggregate Credit Limit of $12,300,000. Borrower may submit an Advance Request under the Temporary Increase solely following (i) Lender's prior 9.5 When advanced amounts outstanding hereunder (a) total written approval, in its sole and absolute discretion, of a between 50% and 75% of the Credit Limit, the written statement detailing the intended use of proceeds, annualized interest rate in Section 9.2 shall be reduced in form and substance satisfactory to Lender, and (ii) by 50 basis points and (b) total at least 75% of the Credit Borrower's delivery of a form of HII Mission Limit, the annualized interest rate in Section 9.2 shall be Technologies Corp. ("HIP") Creditor Certification Form reduced by 75 basis points. acceptable to Lender, in its sole and absolute discretion. 9.6 Subject to Section 9.9, Borrower's aggregate obligations For the avoidance of doubt, no Advance Request shall be hereunder shall not exceed, without Lender's prior funded unless and until HIll has agreed to the form of written approval, the Credit Limit. If such obligations Creditor Certification Form that provides for all amounts either exceed the Credit Limit or individual advances payable by HII to be remitted directly to Lender. exceed the percentages in Section 9.1, Lender shall have Notwithstanding anything to the contrary herein, Lender no obligation to further fund until Borrower pays the may decline to fund any Advance Request under the amount of excess, which Borrower hereby agrees to pay Temporary Increase in its sole and absolute discretion, upon demand. provided that such discretion shall not be exercised unreasonably. Upon expiration of the Forbearance 9.7 All amounts described in this Section 9 (together with all Period, the Credit Limit shall revert to $7,000,000 and other amounts owing hereunder) not due on an Advance all outstanding obligations shall be immediately due and Maturity Date shall be due and payable upon the Facility payable; Maturity Date. (d) Borrower shall deliver to Lender (1) weekly 13-week 9.8 Collections received by Lender in excess of amounts rolling cash flow forecasts and variance reports, each in then owed by Borrower will be remitted to Borrower in form and substance reasonably satisfactory to Lender, due course pursuant to the following wire instructions: 2 LEGALIST_000002
quotationattribution

AW/SC acknowledge satisfaction of their original judgment claim while maintaining the separate stock claim.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 49 of 145 PagelD# 2183 10. The Garnishment in Fairfax is referred to by HII as, in part, a basis for this Interpleader. See First Amended Complaint, paragraphs 50-55. 11. AWH and SC also domesticated the Virginia judgment (CL22-3882) in Harris County Texas where Cyberlux had a drone assembly facility. 12. Upon the domestication of the Virginia Judgment in Texas, Robert Berleth, Esquire was appointed as a Receiver for Cyberlux by Order entered in Harris County TX in Cause No. 202448085. The Order of Receivership is attached as Exhibit 11 to the First Amended Complaint. 13. The Order of Appointment granted broad powers to Berleth including the grant of power over all causes of action. See First Amended Complaint, Exhibit 11, Order, Paragraph 25(1). 14. Meanwhile, CYBL, also failed to provide "Marketable Trading" stock as required, and as required by paragraph 2(e) of the Settlement Agreement (the "Stock Claim"). 15. CYBL stock, if it had been properly administered as required by the Settlement Agreement, would have had significant value on or before October 2021, and was additional consideration for the Settlement Agreement. 16. Paragraph 2(e) of the Settlement Agreement reserved the right in AWH and SC to re-file a Complaint to enforce its rights under the Stock Claim upon breach. 17. Based on the breach, AWH and SC filed a Complaint to enforce its rights under the Stock Claim in Richmond Circuit Court which is pending and is filed as CL 24-3910. 18. Berleth, as part of his duties as Receiver, evaluated the Stock Claim advanced by AWH and SC and compromised the figure with AWH and SC to a reduced liquidated figure of $6,000,000.00, plus attorney fees and cost.
quotationattribution

Fairwinds disclaims security, lien, assignment, interest and attorney fees in its response.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 133 of 145 PagelD# 2267 Response: The amount was liquidated on or about July 8, 2025, when Cyberlux sent to Fairwinds a spreadsheet detailing the amount owed to Fairwinds on its commission based upon the total amount Cyberlux had invoiced HII. (d) Whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment. Response: None. (e) Whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any. Response: None. (f) Whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim. Response: None. (g) For any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed. Response: Not applicable. DOCUMENT REQUEST i: i. Documents supporting or otherwise concerning your answer to the above interrogatory. 3 #111272386v1
quotationattribution

Receiver acknowledges the Texas court has not set his final fees.

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Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 137 of 145 PagelD# 2271 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff, cos cos cos cos cos cos cos Civil Action No. 3:25-cv-00483-JAG CYBERLUX CORP., et al., Interpleader Defendants/Claimants. INTERPLEADER DEFENDANT'S, ROBERT W. BERLETH, AS RECEIVER, RESPONSES TO THE JOINT DISCOVERY PLAN DISCOVERY REQUESTS Interpleader Defendant/Claimant, Robert W. Berleth, as Receiver (the "Receiver), by counsel, hereby submits the following responses to the Joint Discovery Plan Order entered on February 19, 2026 [Doc. 149]. a. Interrogatory: Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) the amount of the proceeds that you claim; (b) the legal basis for your right to the proceeds; (c) how the amount you claim became a liquidated amount or, if not liquidated, state so; (d) whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment; (e) whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any; (f) whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim; and (g) for any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed OBJECTION: The Receiver objects to this interrogatory to subparts (a), (b), (d), (e), and (f) to the extent that they seek disclosure of legal theories, mental impressions, conclusions,
claimallegation

Gonzalez declares personal knowledge as a 65% member of Thin Air Gear (TAG), submitting this evidence for TAG in EDVA 3:25-cv-00483-JAG. He

Gonzalez declares personal knowledge as a 65% member of Thin Air Gear (TAG), submitting this evidence for TAG in EDVA 3:25-cv-00483-JAG. He is not making this declaration for ARG. The docket identifies ECF 165-1 filed 15 April 2026.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 1 of 145 PagelD# 2135 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Plaintiff, Case No. 3:25-cv-483 V. CYBERLUX CORP., et al., Defendants. DECLARATION OF ANTHONY R. GONZALEZ 1, Anthony R. Gonzalez, declare as follows: I am over the age of 18 and competent to make this Declaration. I have personal knowledge of the facts stated in this Declaration. 2. I am the 65% Member of Thin Air Gear, LLC ('TAG") and I submit this Declaration in support of TAG's Motion for Summary Judgment, supporting Memorandum of Law, and other related filings. TAG's Contract With Cyberlux On September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). A true and correct copy of Contract (TAG 0005-6) is attached hereto as Exhibit 1. These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract between Cyberlux and Plaintiff HII Mission Technologies Corp.'s 1
claimallegation

Exhibit 2 is an upside-down photograph of multiple camouflage bags in a carton. It illustrates product appearance; it cannot establish 2,100

Exhibit 2 is an upside-down photograph of multiple camouflage bags in a carton. It illustrates product appearance; it cannot establish 2,100 units manufactured, 1,722 delivered, date, destination, or the contents of each bag.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 10 of 145 PageID# 2144 [Own-image description: Exhibit2 photograph, inverted in the filed page, shows multiple camouflage bags in an open carton. No date, delivery receipt or total production count is demonstrated by the image.]
claimallegation

TAG's Colorado complaint names Cyberlux doing business as Catalyst, pleads jurisdiction/venue and describes Cyberlux as a North Carolina cor

TAG's Colorado complaint names Cyberlux doing business as Catalyst, pleads jurisdiction/venue and describes Cyberlux as a North Carolina corporation. That organisational description differs from the Nevada description in later attached records.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 12 of 145 PagelD# 2146 Case No. 1:25-cv-00805 Document 1 filed 03/12/25 USDC Colorado pg 1 of 6 Case 3:25-cv-00483-JAG Document 1-8 Filed 06/24/25 Page 4 of 13 PagelD# 89 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: THIN AIR GEAR, LLC, Plaintiff, CYBERLUX CORPORATION d/b/a CATALYST MACHINEWORKS, LLC, Defendant. COMPLAINT AND JURY DEMAND Plaintiff Thin Air Gear, LLC, through counsel, KANE LAW FIRM, P.C., for its Complaint states: NATURE OF THE CASE This case arises out of a contractual relationship between the parties. Plaintiff Thin Air Gear, LLC (hereinafter "Thin Air') agreed to manufacture wheeled drone kit bags to the specifications of Defendant Cyberlux Corporation d/b/a Catalyst Machineworks, LLC (hereinafter "Cyberlux"). Cyberlux promised to purchase all bags so manufactured. Thin Air produced all wheeled drone kit bags pursuant to the contract. Cyberlux has refused to pay the balance due on the contract. PARTIES Thin Air is a Nevada limited liability company and has its principal place ofbusiness located at 4196 Center Park Drive, Colorado Springs, CO 80916. Plaintiff is qualified to do business in Colorado and is in good standing. TAG-0021
claimallegation

Colorado complaint alleges the bag contract, manufacture, delivery, retained inventory and unpaid balance. Breach and alternative unjust-enr

Colorado complaint alleges the bag contract, manufacture, delivery, retained inventory and unpaid balance. Breach and alternative unjust-enrichment counts rely on TAG's alleged performance and Cyberlux's benefit/nonpayment.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 14 of 145 PagelD# 2148 Case No. 1:25-cv-00805 Document 1 filed 03/12/25 USDC Colorado pg 3 of 6 Case 3:25-cv-00483-JAG Document 1-8 Filed 06/24/25 Page 6 of 13 PagelD# 91 11. Thin Air is storing the remaining 378 wheeled drone kit bag at their facility in Colorado pending final payment on the Contract. 12. As of November 18, 2024, the balance due on the Contract, including a 1.5% late fee per month on past due amounts, is $365,049.42. 13. Thin Air has sent multiple demands to Cyberlux for payment of the balance due without any response from Cyberlux. 14. Cyberlux is in breach of the Contract for failure to pay the balance due on the Contract. FIRST CLAIM FOR RELIEF (Breach of Contract) 15. Plaintiff re-alleges and incorporates by reference the preceding paragraphs as if fully restated herein. 16. Pursuant to the Contract, Thin Air agreed to produce, assemble and ship to Catalyst Machineworks 2,100 wheeled drone kit bags. 17. Cyberlux agreed to pay Thin Air the sum of $887,900.00 for the contracted items. 18. Thin Air has performed all its obligations pursuant to the terms of the Contract. 19. There is a balance of $365,049.42 due to Thin Air remaining on the Contract. 20. Cyberlux has refused to pay the balance due. 21. Thin Air has shipped 1,722 of the wheeled drone kit bags to the Catalyst Machineworks warehouse in Spring, Texas and will ship the remaining 378 bags that are complete and stored at Thin Air's facility in Colorado Springs upon receipt of the final payment from Cyberlux. 3 TAG-0023
claimallegation

TAG pleads civil theft under Colorado statutes and requests treble damages, fees, costs, interest and jury trial. These pleading allegations

TAG pleads civil theft under Colorado statutes and requests treble damages, fees, costs, interest and jury trial. These pleading allegations remain distinct from the subsequently attached default judgment and do not adjudicate interpleader priority.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 16 of 145 PagelD# 2150 Case No. 1:25-cv-00805 Document 1 filed 03/12/25 USDC Colorado pg 5 of 6 Case 3:25-cv-00483-JAG Document 1-8 Filed 06/24/25 Page 8 of 13 PagelD# 93 Theft. A person commits theft when he or she knowingly obtains, retains, or exercises control over anything of value of another without authorization or by threat or deception... and: (a) Intends to deprive the other person permanently of the use or benefit of the thing of value. 31. As a result of the civil theft committed by Cyberlux, Thin Air is entitled to reimbursement of the deficit amount plus three times that amount, attorney fees and costs pursuant to C.R.S. § 18-4-405 which states: Rights in stolen property. All property obtained by theft, robbery, or burglary shall be restored to the owner, and no sale, whether in good faith on the part of the purchaser or not, shall divest the owner of his rights to such property. The owner may maintain an action not only against the taker thereof but also against any person in whose possession he finds the property. In any such action, the owner may recover two hundred dollars or three times the amount of the actual damages sustained by him, whichever is greater, and may also recover costs of the action and reasonable attorney fees... WHEREFORE, Plaintiff requests that judgment against Defendant be entered as follows: Damages resulting from Defendants' breach including the $365,049.42 outstanding balance due on the Contract and interest from December 2024 to present; Treble damages pursuant to C.R.S. § 18-4-405; Reasonable attorney fees as required by C.R.S. § 18-4-405; d. Costs of litigation; e. Pre-judgment and post-judgment interest at the applicable rates; and f. Such other and further relief as the Court deems just and proper. S TAG-0025
claimallegation

Colorado ECF 27, dated 29 August 2025, adopts the magistrate judge's recommendation, grants the default motion, denies the proposed stipulat

Colorado ECF 27, dated 29 August 2025, adopts the magistrate judge's recommendation, grants the default motion, denies the proposed stipulated final order as moot, awards TAG $1,224,275.14 and closes the case. Exhibits 4 and 5 reproduce the same judgment; Exhibit 5 adds a clerk certification stamp.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 19 of 145 PagelD# 2153 Case No. 1:25-CV-00805-GPG-MDB Document 27 filed 08/29/25 USDC Colorado pg 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 25-cv-00805-GPG-MDB THIN AIR GEAR, LLC, Plaintiff, V. CYBERLUX CORPORATION d/b/a CATALYST MACHINEWORKS, LLC, Defendant. FINAL JUDGMENT In accordance with the orders filed during the pendency of this case, and pursuant to Federal Rule of Civil Procedure 58(a), the following Final Judgment is hereby entered. Pursuant to the [D. 26] Order entered by Judge Gordon P. Gallagher on August 29, 2025, it is ORDERED that the Recommendation of the United States Magistrate Judge Maritza Dominquez Braswell [D. 25] is AFFIRMED and ADOPTED as an Order of the Court. It is FURTHER ORDERED that Plaintiff's Motion for Entry of Default Judgment [D. 18] is GRANTED, It is FURTHER ORDERED that the parties proposed Order Granting Stipulation for Final Judgment [D. 21] is DENIED AS MOOT. It is FURTHER ORDERED that Plaintiff is awarded $1,224,275.14 in damages. It is FURTHER ORDERED that judgment is entered in favor of Plaintiff and against Defendant. This case is closed. TAG-0003
claimallegation

Legalist's Second Amended and Restated Government Purchase Order Financing Agreement names Cyberlux and Datron as borrowers. Its face says e

Legalist's Second Amended and Restated Government Purchase Order Financing Agreement names Cyberlux and Datron as borrowers. Its face says effective 27 March 2024; section 40 expressly supplies the Second Amendment Date 29 April 2025. These are distinct date roles, not two newly proved funding dates.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 25 of 145 PagelD# 2159 Docusign Envelope: ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 SECOND AMENDED AND RESTATED GOVERNMENT local tax requirements not later than the forty fifth (45th) PURCHASE ORDER FINANCING AGREEMENT day after the end of each calendar quarter) that Borrower This Second Amended and Restated Government Purchase Order keeps in the ordinary course of business in accordance Financing Agreement ("Agreement) is made effective as of accepted accounting principles March 27, 2024 by and between Legalist SPV III, LP ("Lender) consistently applied, and Borrower shall certify that all and Cyberlux Corporation and Datron World Communications, information contained therein is and shall be true and Inc. (each and together, "Borrower"). correct ("Quarterly Reporting Obligation). addition to any Quarterly Reporting Obligation, Lender hereby agrees to provide Borrower the services specified Borrower further agrees to provide Lender with a copy in this Agreement and establishes for a period extending one year of the Borrower's books and records otherwise due in from the date hereof (the "Facility Maturity Date") a revolving connection with any Quarterly Reporting Obligation line of credit for Borrower in the aggregate maximum principal promptly upon demand at any time upon reasonable amount of $7,000,000 (the "Credit Limit"). notice to Borrower. ACCOUNTS MANAGEMENT By or before fifteen (15) days after the last business day Borrower shall, before execution of any agreement with of each month, Lender shall provide to Borrower a monthly report a government-related customer (including any prime contractor to (each a 'Loan Report") detailing the current state of Borrower's such a customer) (each, a "Government Account Debtor") in account with Lender based upon documentation then provided by connection with which Borrower desires Lender to provide Borrower to Lender, including balance, individual transactions, financing under this Agreement, provide to Lender the then-available loan amount under the Credit Limit, and related Government Account Debtor's contact information, material information. Borrower shall notify Lender within five (S) days of evidencing any contract with the Goverment Account Debtor, delivery if it disputes any part of a Loan Report. The Loan Report and other information that may be requested. Lender may conduct shall be deemed correct and binding upon Borrower and shall due diligence of such Government Account Debtor. Lender may constitute an account stated between the parties hereto unless establish or modify a maximum credit limit for any Government Lender receives Borrower's written statement of exceptions Account Debtor, without waiving its right at any subsequent time within five (5) days after Borrower's receipt of same. to terminate or modify any prior acceptance. Borrower agrees that all invoices to Government 2. Borrower shall provide to Lender by or before fifteen Account Debtors shall designate Borrower as the sole named (15) days after the last business day of each month: payee together with the following wiring instructions (as Borrower may update from time to time): a. Details of all obligations (including, but not limited to, invoices, aging reports, and related information) of Bank: Silicon Valley Bank Government Account Debtors; Account Name: Legalist SPV III, LP Account No: I b. Details of all accounts payable obligations of Borrower ABA No: relating thereto; Borrower further agrees that all payments made c. A completed Borrowing Base Certificate in the form hereunder shall be made pursuant to the foregoing wire attached as Exhibit A; instructions only. Lender is unable to accept payment by check. d. If applicable, a completed Request for Disbursement in If any payment on an Eligible Purchase Order is received the form attached as Exhibit B; and by Borrower, it shall: e. Such other information as Lender may reasonably a. Hold such payment irrevocably in trust for Lender, request (collectively, an "Information Request"). separate and apart from Borrower's own funds; 3. Borrower warrants and guarantees, by submission of an Deliver such payment within one (1) business day to Advance Request, that: Lender pursuant to the wire instructions contained in a. The services described therein were (or, as applicable, Section 5 hereinabove; and shall be) in fact rendered and that the Eligible Purchase Immediately notify the payee in writing to send future Orders (defined below) evidenced thereby are and will payments to Lender pursuant to such wire instructions. continue to be genuine, bona fide, and collectable and without right of offset, counterclaim, or right of return or Borrower shall designate Lender as a point of contact cancellation; and with all Government Account Debtors and execute all authorizations or other documents requested to establish and b. If it is notified of any dispute, or of any right of offset, maintain Lender's authority to accept, endorse, and deposit all counterclaim, or right of return or cancellation against Government Account Debtor remittances to its own bank account. any Government Account Debtor's obligation to Borrower hereby appoints Lender its agent for the purpose of Borrower, it will immediately notify Lender in writing. executing all such authorizations and other documents. In addition to Borrower's obligation to provide a ADVANCES; COMPENSATION TO LENDER monthly Information Request to Lender, Borrower hereby agrees that it shall also furnish Lender with full Upon Lender's receipt of a request for disbursement, by financial statements (expressly including proof of and through the submission of the Request for Disbursement form payment and/or compliance with all federal, state and/or attached as Exhibit B, current accounts receivable aging, current LEGALIST_000001
claimallegation

The financing agreement states a $7 m revolving credit limit and one-year facility term; monthly reporting includes receivables/payables and

The financing agreement states a $7 m revolving credit limit and one-year facility term; monthly reporting includes receivables/payables and borrowing-base/request forms. Quarterly financials and proof of tax compliance are due within 45 days; records can be demanded during business hours. Loan-report disputes must be notified within five days or the report becomes an account stated under the contract.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 25 of 145 PagelD# 2159 Docusign Envelope: ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 SECOND AMENDED AND RESTATED GOVERNMENT local tax requirements not later than the forty fifth (45th) PURCHASE ORDER FINANCING AGREEMENT day after the end of each calendar quarter) that Borrower This Second Amended and Restated Government Purchase Order keeps in the ordinary course of business in accordance Financing Agreement ("Agreement) is made effective as of accepted accounting principles March 27, 2024 by and between Legalist SPV III, LP ("Lender) consistently applied, and Borrower shall certify that all and Cyberlux Corporation and Datron World Communications, information contained therein is and shall be true and Inc. (each and together, "Borrower"). correct ("Quarterly Reporting Obligation). addition to any Quarterly Reporting Obligation, Lender hereby agrees to provide Borrower the services specified Borrower further agrees to provide Lender with a copy in this Agreement and establishes for a period extending one year of the Borrower's books and records otherwise due in from the date hereof (the "Facility Maturity Date") a revolving connection with any Quarterly Reporting Obligation line of credit for Borrower in the aggregate maximum principal promptly upon demand at any time upon reasonable amount of $7,000,000 (the "Credit Limit"). notice to Borrower. ACCOUNTS MANAGEMENT By or before fifteen (15) days after the last business day Borrower shall, before execution of any agreement with of each month, Lender shall provide to Borrower a monthly report a government-related customer (including any prime contractor to (each a 'Loan Report") detailing the current state of Borrower's such a customer) (each, a "Government Account Debtor") in account with Lender based upon documentation then provided by connection with which Borrower desires Lender to provide Borrower to Lender, including balance, individual transactions, financing under this Agreement, provide to Lender the then-available loan amount under the Credit Limit, and related Government Account Debtor's contact information, material information. Borrower shall notify Lender within five (S) days of evidencing any contract with the Goverment Account Debtor, delivery if it disputes any part of a Loan Report. The Loan Report and other information that may be requested. Lender may conduct shall be deemed correct and binding upon Borrower and shall due diligence of such Government Account Debtor. Lender may constitute an account stated between the parties hereto unless establish or modify a maximum credit limit for any Government Lender receives Borrower's written statement of exceptions Account Debtor, without waiving its right at any subsequent time within five (5) days after Borrower's receipt of same. to terminate or modify any prior acceptance. Borrower agrees that all invoices to Government 2. Borrower shall provide to Lender by or before fifteen Account Debtors shall designate Borrower as the sole named (15) days after the last business day of each month: payee together with the following wiring instructions (as Borrower may update from time to time): a. Details of all obligations (including, but not limited to, invoices, aging reports, and related information) of Bank: Silicon Valley Bank Government Account Debtors; Account Name: Legalist SPV III, LP Account No: I b. Details of all accounts payable obligations of Borrower ABA No: relating thereto; Borrower further agrees that all payments made c. A completed Borrowing Base Certificate in the form hereunder shall be made pursuant to the foregoing wire attached as Exhibit A; instructions only. Lender is unable to accept payment by check. d. If applicable, a completed Request for Disbursement in If any payment on an Eligible Purchase Order is received the form attached as Exhibit B; and by Borrower, it shall: e. Such other information as Lender may reasonably a. Hold such payment irrevocably in trust for Lender, request (collectively, an "Information Request"). separate and apart from Borrower's own funds; 3. Borrower warrants and guarantees, by submission of an Deliver such payment within one (1) business day to Advance Request, that: Lender pursuant to the wire instructions contained in a. The services described therein were (or, as applicable, Section 5 hereinabove; and shall be) in fact rendered and that the Eligible Purchase Immediately notify the payee in writing to send future Orders (defined below) evidenced thereby are and will payments to Lender pursuant to such wire instructions. continue to be genuine, bona fide, and collectable and without right of offset, counterclaim, or right of return or Borrower shall designate Lender as a point of contact cancellation; and with all Government Account Debtors and execute all authorizations or other documents requested to establish and b. If it is notified of any dispute, or of any right of offset, maintain Lender's authority to accept, endorse, and deposit all counterclaim, or right of return or cancellation against Government Account Debtor remittances to its own bank account. any Government Account Debtor's obligation to Borrower hereby appoints Lender its agent for the purpose of Borrower, it will immediately notify Lender in writing. executing all such authorizations and other documents. In addition to Borrower's obligation to provide a ADVANCES; COMPENSATION TO LENDER monthly Information Request to Lender, Borrower hereby agrees that it shall also furnish Lender with full Upon Lender's receipt of a request for disbursement, by financial statements (expressly including proof of and through the submission of the Request for Disbursement form payment and/or compliance with all federal, state and/or attached as Exhibit B, current accounts receivable aging, current LEGALIST_000001
claimallegation

Borrower invoices must name the borrower as payee but direct wires to Legalist. Collections received by a borrower must be held separately i

Borrower invoices must name the borrower as payee but direct wires to Legalist. Collections received by a borrower must be held separately in trust, remitted within one business day, and accompanied by instructions to future payers; Legalist receives collection-agent authority. Visible banking redactions are not reconstructed.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 25 of 145 PagelD# 2159 Docusign Envelope: ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 SECOND AMENDED AND RESTATED GOVERNMENT local tax requirements not later than the forty fifth (45th) PURCHASE ORDER FINANCING AGREEMENT day after the end of each calendar quarter) that Borrower This Second Amended and Restated Government Purchase Order keeps in the ordinary course of business in accordance Financing Agreement ("Agreement) is made effective as of accepted accounting principles March 27, 2024 by and between Legalist SPV III, LP ("Lender) consistently applied, and Borrower shall certify that all and Cyberlux Corporation and Datron World Communications, information contained therein is and shall be true and Inc. (each and together, "Borrower"). correct ("Quarterly Reporting Obligation). addition to any Quarterly Reporting Obligation, Lender hereby agrees to provide Borrower the services specified Borrower further agrees to provide Lender with a copy in this Agreement and establishes for a period extending one year of the Borrower's books and records otherwise due in from the date hereof (the "Facility Maturity Date") a revolving connection with any Quarterly Reporting Obligation line of credit for Borrower in the aggregate maximum principal promptly upon demand at any time upon reasonable amount of $7,000,000 (the "Credit Limit"). notice to Borrower. ACCOUNTS MANAGEMENT By or before fifteen (15) days after the last business day Borrower shall, before execution of any agreement with of each month, Lender shall provide to Borrower a monthly report a government-related customer (including any prime contractor to (each a 'Loan Report") detailing the current state of Borrower's such a customer) (each, a "Government Account Debtor") in account with Lender based upon documentation then provided by connection with which Borrower desires Lender to provide Borrower to Lender, including balance, individual transactions, financing under this Agreement, provide to Lender the then-available loan amount under the Credit Limit, and related Government Account Debtor's contact information, material information. Borrower shall notify Lender within five (S) days of evidencing any contract with the Goverment Account Debtor, delivery if it disputes any part of a Loan Report. The Loan Report and other information that may be requested. Lender may conduct shall be deemed correct and binding upon Borrower and shall due diligence of such Government Account Debtor. Lender may constitute an account stated between the parties hereto unless establish or modify a maximum credit limit for any Government Lender receives Borrower's written statement of exceptions Account Debtor, without waiving its right at any subsequent time within five (5) days after Borrower's receipt of same. to terminate or modify any prior acceptance. Borrower agrees that all invoices to Government 2. Borrower shall provide to Lender by or before fifteen Account Debtors shall designate Borrower as the sole named (15) days after the last business day of each month: payee together with the following wiring instructions (as Borrower may update from time to time): a. Details of all obligations (including, but not limited to, invoices, aging reports, and related information) of Bank: Silicon Valley Bank Government Account Debtors; Account Name: Legalist SPV III, LP Account No: I b. Details of all accounts payable obligations of Borrower ABA No: relating thereto; Borrower further agrees that all payments made c. A completed Borrowing Base Certificate in the form hereunder shall be made pursuant to the foregoing wire attached as Exhibit A; instructions only. Lender is unable to accept payment by check. d. If applicable, a completed Request for Disbursement in If any payment on an Eligible Purchase Order is received the form attached as Exhibit B; and by Borrower, it shall: e. Such other information as Lender may reasonably a. Hold such payment irrevocably in trust for Lender, request (collectively, an "Information Request"). separate and apart from Borrower's own funds; 3. Borrower warrants and guarantees, by submission of an Deliver such payment within one (1) business day to Advance Request, that: Lender pursuant to the wire instructions contained in a. The services described therein were (or, as applicable, Section 5 hereinabove; and shall be) in fact rendered and that the Eligible Purchase Immediately notify the payee in writing to send future Orders (defined below) evidenced thereby are and will payments to Lender pursuant to such wire instructions. continue to be genuine, bona fide, and collectable and without right of offset, counterclaim, or right of return or Borrower shall designate Lender as a point of contact cancellation; and with all Government Account Debtors and execute all authorizations or other documents requested to establish and b. If it is notified of any dispute, or of any right of offset, maintain Lender's authority to accept, endorse, and deposit all counterclaim, or right of return or cancellation against Government Account Debtor remittances to its own bank account. any Government Account Debtor's obligation to Borrower hereby appoints Lender its agent for the purpose of Borrower, it will immediately notify Lender in writing. executing all such authorizations and other documents. In addition to Borrower's obligation to provide a ADVANCES; COMPENSATION TO LENDER monthly Information Request to Lender, Borrower hereby agrees that it shall also furnish Lender with full Upon Lender's receipt of a request for disbursement, by financial statements (expressly including proof of and through the submission of the Request for Disbursement form payment and/or compliance with all federal, state and/or attached as Exhibit B, current accounts receivable aging, current LEGALIST_000001
claimallegation

Advances require supporting records and an acknowledged assignment; at most one request is processed per calendar week. Availability is 50%

Advances require supporting records and an acknowledged assignment; at most one request is processed per calendar week. Availability is 50% of eligible undisputed government orders less outstanding balances. Stated daily interest is prime divided by 365 plus 0.0164%, with a 1% commitment fee and utilisation discounts of 50/75 basis points.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 26 of 145 PagelD# 2160 Docusign Envelope ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 Huntington Bank accounts payable aging, and any applicable related contracts Bank: and/or purchase orders not previously provided to Lender Account Name: Cyberlux Corporation (collectively, an "Advance Request") and the completion of Account No: Lender's due diligence relating thereto, and the receipt by Lender ABA No: of a satisfactory counterparty acknowledgement of an executed Instrument of Assignment in the form attached as Exhibit C, 9.9 Borrower acknowledges that Events of Default have Lender shall promptly disburse the requested amount to occurred and are continuing under Section 21 hereunder, Borrower, subject to the terms hereof. including those described in the Notices of Default LENDER SHALL NOT PROCESS MORE THAN ONE delivered to Borrower on November 4, 2024 and March ADVANCE REQUEST PER CALENDAR WEEK. 31, 2025 (collectively, the "Existing Defaults). Subject to the terms of this Section 9.9, Lender agrees to Borrower agrees, in consideration for funds loaned to it temporarily forbear from exercising its rights and by Lender under this Agreement, to pay to Lender the following remedies solely with respect to the Existing Detaults. amounts (pursuant to the wire instructions in Section 5) to be charged thereon: As used herein, the "Forbearance Period" means the period commencing on the Second Amendment Date and 9.1 Subject to the Credit Limit, the total amount of funding ending on the earlier of (a) the date that is 90 days available to Borrower hercunder shall be 50% of the face thereafter, or (b) the occurrence of any Event of Default value of each eligible purchase order, task order, delivery (other than the Existing Defaults), unless extended in order, or statement of work related to writing by Lender in its sole discretion government contracts that (x) has not been disqualified by Lender for credit or other reasons and (y) is not During the Forbearance Period: disputed by the Government Account Debtor (a) Borrower reaffirms its acknowledgment of the (collectively, the "Eligible Purchase Orders"); less Existing Defaults and agrees that, pursuant to Section 22, amounts outstanding hereunder. default interest shall continue to accrue at a rate of 4.75% 9.2 Interest on outstanding principal balances shall accrue per Event of Default, for a combined rate of 9.5% per daily at the U.S. prime rate in effect from time to time annum, compounded and capitalized monthly; (divided by 365) plus 0.0164%, with interest accrued in (b) Borrower shall pay a forbearance fee equal to 1.00% a given calendar month due and payable in arrears on the of the Temporary Increase (as defined below), deemed earlier to occur of the Facility Maturity Date or the last fully earned as of the Second Amendment Date and business day of the following month (the earlier of such capitalized into the principal balance. Such fee shall be date, the "Advance Maturity Date"). paid in three equal monthly installments commencing on 9.3 Omitted. the first Advance Maturity Date following the Second Amendment Date; 9.4 A commitment fee equal to 1.00% of the Credit Limit shall be deemed fully earned by Lender on the date (c) The Credit Limit shall be temporarily increased by hereof and due and payable in 12 equal monthly $5,300,000 (the "Temporary Increase), resulting in a installments beginning upon the first Advance Maturity temporary aggregate Credit Limit of $12,300,000. Borrower may submit an Advance Request under the Temporary Increase solely following (i) Lender's prior 9.5 When advanced amounts outstanding hereunder (a) total written approval, in its sole and absolute discretion, of a between 50% and 75% of the Credit Limit, the written statement detailing the intended use of proceeds, annualized interest rate in Section 9.2 shall be reduced in form and substance satisfactory to Lender, and (ii) by 50 basis points and (b) total at least 75% of the Credit Borrower's delivery of a form of HII Mission Limit, the annualized interest rate in Section 9.2 shall be Technologies Corp. ("HIP") Creditor Certification Form reduced by 75 basis points. acceptable to Lender, in its sole and absolute discretion. 9.6 Subject to Section 9.9, Borrower's aggregate obligations For the avoidance of doubt, no Advance Request shall be hereunder shall not exceed, without Lender's prior funded unless and until HIll has agreed to the form of written approval, the Credit Limit. If such obligations Creditor Certification Form that provides for all amounts either exceed the Credit Limit or individual advances payable by HII to be remitted directly to Lender. exceed the percentages in Section 9.1, Lender shall have Notwithstanding anything to the contrary herein, Lender no obligation to further fund until Borrower pays the may decline to fund any Advance Request under the amount of excess, which Borrower hereby agrees to pay Temporary Increase in its sole and absolute discretion, upon demand. provided that such discretion shall not be exercised unreasonably. Upon expiration of the Forbearance 9.7 All amounts described in this Section 9 (together with all Period, the Credit Limit shall revert to $7,000,000 and other amounts owing hereunder) not due on an Advance all outstanding obligations shall be immediately due and Maturity Date shall be due and payable upon the Facility payable; Maturity Date. (d) Borrower shall deliver to Lender (1) weekly 13-week 9.8 Collections received by Lender in excess of amounts rolling cash flow forecasts and variance reports, each in then owed by Borrower will be remitted to Borrower in form and substance reasonably satisfactory to Lender, due course pursuant to the following wire instructions: 2 LEGALIST_000002
claimallegation

Section 9.9 acknowledges continuing defaults notified on 4 November 2024 and 31 March 2025. Borrowers agree the two default charges combine

Section 9.9 acknowledges continuing defaults notified on 4 November 2024 and 31 March 2025. Borrowers agree the two default charges combine to 9.5% annually, compounded/capitalised monthly. Forbearance is limited to existing defaults for 90 days from the Second Amendment Date unless an earlier new default intervenes.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 26 of 145 PagelD# 2160 Docusign Envelope ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 Huntington Bank accounts payable aging, and any applicable related contracts Bank: and/or purchase orders not previously provided to Lender Account Name: Cyberlux Corporation (collectively, an "Advance Request") and the completion of Account No: Lender's due diligence relating thereto, and the receipt by Lender ABA No: of a satisfactory counterparty acknowledgement of an executed Instrument of Assignment in the form attached as Exhibit C, 9.9 Borrower acknowledges that Events of Default have Lender shall promptly disburse the requested amount to occurred and are continuing under Section 21 hereunder, Borrower, subject to the terms hereof. including those described in the Notices of Default LENDER SHALL NOT PROCESS MORE THAN ONE delivered to Borrower on November 4, 2024 and March ADVANCE REQUEST PER CALENDAR WEEK. 31, 2025 (collectively, the "Existing Defaults). Subject to the terms of this Section 9.9, Lender agrees to Borrower agrees, in consideration for funds loaned to it temporarily forbear from exercising its rights and by Lender under this Agreement, to pay to Lender the following remedies solely with respect to the Existing Detaults. amounts (pursuant to the wire instructions in Section 5) to be charged thereon: As used herein, the "Forbearance Period" means the period commencing on the Second Amendment Date and 9.1 Subject to the Credit Limit, the total amount of funding ending on the earlier of (a) the date that is 90 days available to Borrower hercunder shall be 50% of the face thereafter, or (b) the occurrence of any Event of Default value of each eligible purchase order, task order, delivery (other than the Existing Defaults), unless extended in order, or statement of work related to writing by Lender in its sole discretion government contracts that (x) has not been disqualified by Lender for credit or other reasons and (y) is not During the Forbearance Period: disputed by the Government Account Debtor (a) Borrower reaffirms its acknowledgment of the (collectively, the "Eligible Purchase Orders"); less Existing Defaults and agrees that, pursuant to Section 22, amounts outstanding hereunder. default interest shall continue to accrue at a rate of 4.75% 9.2 Interest on outstanding principal balances shall accrue per Event of Default, for a combined rate of 9.5% per daily at the U.S. prime rate in effect from time to time annum, compounded and capitalized monthly; (divided by 365) plus 0.0164%, with interest accrued in (b) Borrower shall pay a forbearance fee equal to 1.00% a given calendar month due and payable in arrears on the of the Temporary Increase (as defined below), deemed earlier to occur of the Facility Maturity Date or the last fully earned as of the Second Amendment Date and business day of the following month (the earlier of such capitalized into the principal balance. Such fee shall be date, the "Advance Maturity Date"). paid in three equal monthly installments commencing on 9.3 Omitted. the first Advance Maturity Date following the Second Amendment Date; 9.4 A commitment fee equal to 1.00% of the Credit Limit shall be deemed fully earned by Lender on the date (c) The Credit Limit shall be temporarily increased by hereof and due and payable in 12 equal monthly $5,300,000 (the "Temporary Increase), resulting in a installments beginning upon the first Advance Maturity temporary aggregate Credit Limit of $12,300,000. Borrower may submit an Advance Request under the Temporary Increase solely following (i) Lender's prior 9.5 When advanced amounts outstanding hereunder (a) total written approval, in its sole and absolute discretion, of a between 50% and 75% of the Credit Limit, the written statement detailing the intended use of proceeds, annualized interest rate in Section 9.2 shall be reduced in form and substance satisfactory to Lender, and (ii) by 50 basis points and (b) total at least 75% of the Credit Borrower's delivery of a form of HII Mission Limit, the annualized interest rate in Section 9.2 shall be Technologies Corp. ("HIP") Creditor Certification Form reduced by 75 basis points. acceptable to Lender, in its sole and absolute discretion. 9.6 Subject to Section 9.9, Borrower's aggregate obligations For the avoidance of doubt, no Advance Request shall be hereunder shall not exceed, without Lender's prior funded unless and until HIll has agreed to the form of written approval, the Credit Limit. If such obligations Creditor Certification Form that provides for all amounts either exceed the Credit Limit or individual advances payable by HII to be remitted directly to Lender. exceed the percentages in Section 9.1, Lender shall have Notwithstanding anything to the contrary herein, Lender no obligation to further fund until Borrower pays the may decline to fund any Advance Request under the amount of excess, which Borrower hereby agrees to pay Temporary Increase in its sole and absolute discretion, upon demand. provided that such discretion shall not be exercised unreasonably. Upon expiration of the Forbearance 9.7 All amounts described in this Section 9 (together with all Period, the Credit Limit shall revert to $7,000,000 and other amounts owing hereunder) not due on an Advance all outstanding obligations shall be immediately due and Maturity Date shall be due and payable upon the Facility payable; Maturity Date. (d) Borrower shall deliver to Lender (1) weekly 13-week 9.8 Collections received by Lender in excess of amounts rolling cash flow forecasts and variance reports, each in then owed by Borrower will be remitted to Borrower in form and substance reasonably satisfactory to Lender, due course pursuant to the following wire instructions: 2 LEGALIST_000002
claimallegation

Gonzalez says Cyberlux doing business as Catalyst contracted on 5 September 2023 for 2,100 drone kit bags at $887,900 and paid a $150,000 de

Gonzalez says Cyberlux doing business as Catalyst contracted on 5 September 2023 for 2,100 drone kit bags at $887,900 and paid a $150,000 deposit on 14 September. TAG manufactured all bags, delivered 1,722 to Spring, Texas, and retained 378 pending final payment.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 1 of 145 PagelD# 2135 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Plaintiff, Case No. 3:25-cv-483 V. CYBERLUX CORP., et al., Defendants. DECLARATION OF ANTHONY R. GONZALEZ 1, Anthony R. Gonzalez, declare as follows: I am over the age of 18 and competent to make this Declaration. I have personal knowledge of the facts stated in this Declaration. 2. I am the 65% Member of Thin Air Gear, LLC ('TAG") and I submit this Declaration in support of TAG's Motion for Summary Judgment, supporting Memorandum of Law, and other related filings. TAG's Contract With Cyberlux On September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). A true and correct copy of Contract (TAG 0005-6) is attached hereto as Exhibit 1. These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract between Cyberlux and Plaintiff HII Mission Technologies Corp.'s 1
claimallegation

Forbearance temporarily increases the credit limit by $5.3 m to $12.3 m and charges $53,000 in three instalments. Advances require approved

Forbearance temporarily increases the credit limit by $5.3 m to $12.3 m and charges $53,000 in three instalments. Advances require approved use and HII creditor certification directing all HII payments to Legalist. Weekly 13-week cash forecasts/variance reports are required; expiry restores the $7 m limit and makes obligations due. No default waiver is given.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 26 of 145 PagelD# 2160 Docusign Envelope ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 Huntington Bank accounts payable aging, and any applicable related contracts Bank: and/or purchase orders not previously provided to Lender Account Name: Cyberlux Corporation (collectively, an "Advance Request") and the completion of Account No: Lender's due diligence relating thereto, and the receipt by Lender ABA No: of a satisfactory counterparty acknowledgement of an executed Instrument of Assignment in the form attached as Exhibit C, 9.9 Borrower acknowledges that Events of Default have Lender shall promptly disburse the requested amount to occurred and are continuing under Section 21 hereunder, Borrower, subject to the terms hereof. including those described in the Notices of Default LENDER SHALL NOT PROCESS MORE THAN ONE delivered to Borrower on November 4, 2024 and March ADVANCE REQUEST PER CALENDAR WEEK. 31, 2025 (collectively, the "Existing Defaults). Subject to the terms of this Section 9.9, Lender agrees to Borrower agrees, in consideration for funds loaned to it temporarily forbear from exercising its rights and by Lender under this Agreement, to pay to Lender the following remedies solely with respect to the Existing Detaults. amounts (pursuant to the wire instructions in Section 5) to be charged thereon: As used herein, the "Forbearance Period" means the period commencing on the Second Amendment Date and 9.1 Subject to the Credit Limit, the total amount of funding ending on the earlier of (a) the date that is 90 days available to Borrower hercunder shall be 50% of the face thereafter, or (b) the occurrence of any Event of Default value of each eligible purchase order, task order, delivery (other than the Existing Defaults), unless extended in order, or statement of work related to writing by Lender in its sole discretion government contracts that (x) has not been disqualified by Lender for credit or other reasons and (y) is not During the Forbearance Period: disputed by the Government Account Debtor (a) Borrower reaffirms its acknowledgment of the (collectively, the "Eligible Purchase Orders"); less Existing Defaults and agrees that, pursuant to Section 22, amounts outstanding hereunder. default interest shall continue to accrue at a rate of 4.75% 9.2 Interest on outstanding principal balances shall accrue per Event of Default, for a combined rate of 9.5% per daily at the U.S. prime rate in effect from time to time annum, compounded and capitalized monthly; (divided by 365) plus 0.0164%, with interest accrued in (b) Borrower shall pay a forbearance fee equal to 1.00% a given calendar month due and payable in arrears on the of the Temporary Increase (as defined below), deemed earlier to occur of the Facility Maturity Date or the last fully earned as of the Second Amendment Date and business day of the following month (the earlier of such capitalized into the principal balance. Such fee shall be date, the "Advance Maturity Date"). paid in three equal monthly installments commencing on 9.3 Omitted. the first Advance Maturity Date following the Second Amendment Date; 9.4 A commitment fee equal to 1.00% of the Credit Limit shall be deemed fully earned by Lender on the date (c) The Credit Limit shall be temporarily increased by hereof and due and payable in 12 equal monthly $5,300,000 (the "Temporary Increase), resulting in a installments beginning upon the first Advance Maturity temporary aggregate Credit Limit of $12,300,000. Borrower may submit an Advance Request under the Temporary Increase solely following (i) Lender's prior 9.5 When advanced amounts outstanding hereunder (a) total written approval, in its sole and absolute discretion, of a between 50% and 75% of the Credit Limit, the written statement detailing the intended use of proceeds, annualized interest rate in Section 9.2 shall be reduced in form and substance satisfactory to Lender, and (ii) by 50 basis points and (b) total at least 75% of the Credit Borrower's delivery of a form of HII Mission Limit, the annualized interest rate in Section 9.2 shall be Technologies Corp. ("HIP") Creditor Certification Form reduced by 75 basis points. acceptable to Lender, in its sole and absolute discretion. 9.6 Subject to Section 9.9, Borrower's aggregate obligations For the avoidance of doubt, no Advance Request shall be hereunder shall not exceed, without Lender's prior funded unless and until HIll has agreed to the form of written approval, the Credit Limit. If such obligations Creditor Certification Form that provides for all amounts either exceed the Credit Limit or individual advances payable by HII to be remitted directly to Lender. exceed the percentages in Section 9.1, Lender shall have Notwithstanding anything to the contrary herein, Lender no obligation to further fund until Borrower pays the may decline to fund any Advance Request under the amount of excess, which Borrower hereby agrees to pay Temporary Increase in its sole and absolute discretion, upon demand. provided that such discretion shall not be exercised unreasonably. Upon expiration of the Forbearance 9.7 All amounts described in this Section 9 (together with all Period, the Credit Limit shall revert to $7,000,000 and other amounts owing hereunder) not due on an Advance all outstanding obligations shall be immediately due and Maturity Date shall be due and payable upon the Facility payable; Maturity Date. (d) Borrower shall deliver to Lender (1) weekly 13-week 9.8 Collections received by Lender in excess of amounts rolling cash flow forecasts and variance reports, each in then owed by Borrower will be remitted to Borrower in form and substance reasonably satisfactory to Lender, due course pursuant to the following wire instructions: 2 LEGALIST_000002
claimallegation

Security provisions grant a broad lien over assets and proceeds, require subordination with an express exception for disputed AW/SC/Strikepo

Security provisions grant a broad lien over assets and proceeds, require subordination with an express exception for disputed AW/SC/Strikepoint liens in identified litigation, preserve debt/security after clawback, and restrict debtor compromises without lender consent. The contractual claim does not itself resolve competing priority.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 27 of 145 PagelD# Docusign Envelope ID: А39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 and (ii) such other information as Lender may reasonably January 30, 2024 and there bearing case no. 3:24-cv-00196-RBM- request; VET, and (b) that certain civil proceeding commenced by the (e) Solely to implement this Section 9.9 and without Atlantic Wave Parties against Borrower and Mark D. Schmidt, waiving any Event of Default, the Facility Maturity Date removed to the United States District Court for the Southern shall be deemed extended through the end of the District of California on or about March 11, 2024 and there Forbearance Period, unless otherwise agreed by Lender bearing case no. 3:24-cv-00482-RBM-VET (collectively, the in writing. "Atlantic Wave Litigation"). (f) Nothing in this Section 9.9 shall constitute a waiver 12. Lender shall have the continuing and exclusive right to of any Event of Default or limit any right or remedy of reapply or reverse and reapply any payment by or on behalf of Lender. This forbearance is limited to the terms set forth Borrower to any portion of Borrower's obligations hereunder if a herein and may be terminated by Lender upon written payment or proceeds thereof, or any part thereof, is subsequently notice following any breach of this Section 9.9 or any invalidated, declared to be fraudulent or preferential, set aside, or other provision of this Agreement. Lender reserves the required to be repaid (including to a trustee, receiver or any other right to assess additional default interest in accordance party under any bankruptcy law, state or federal law, common law with Section 22 for any other Event of Default. or equitable cause). In such event, to the extent of such amount received, the obligations hereunder shall be revived and continue in full force and effect, as if such payment or proceeds had not COLLATERAL been received. Borrower hereby grants to Lender a continuing lien on 13. Omitted. and security interest in all assets of Borrower, including its now existing and hereafter arising rights and interests in the following, Borrower agrees that its grant of a security interest shall wherever located: all goods, accounts, accounts receivable, be resurrected and acknowledges Lender's right to file any equipment, inventory, contract rights or rights to payment of financing statement or similar document that may be necessary or money, leases, license agreements, franchise agreements, general desirable if any amount is reapplied or reversed under Section 12, intangibles, commercial tort claims, documents, instruments even if a prior financing statement has been terminated. (including any promissory notes), chattel paper (whether tangible Lender may, in its sole and absolute discretion, require or electronic), cash, deposit accounts, certificates of deposit, Government Account Debtors to pay Eligible Purchase Orders fixtures, letters of credit rights (whether or not the letter of credit obligations directly to it or an affiliate per Section 5, including (i) is evidenced by a writing), securities, and all other investment notify a Government Account Debtor that its account has been property, supporting obligations, and financial assets; and all assigned to Lender by Borrower and that payment thereof shall be Borrower's books relating to the foregoing, and any and all made to the order of and directly to Lender and (ii) demanding. claims, rights and interests in any of the above and all collecting, or enforcing payment thereof. substitutions for, additions, attachments, accessories, accessions and improvements to and replacements, products, proceeds and After an Event of Default, Lender shall be entitled to take insurance proceeds of any or all of the foregoing (collectively, the the action set forth above with respect to any Collateral. "Collateral). 17. Borrower shall not, without Lender's prior written Borrower authorizes Lender, at its discretion, to file or record a consent in each instance (a) grant an extension of time for financing statement (UCC-1) or any other document necessary or payment of any Eligible Purchase Order, (b) compromise or settle desirable to perfect, maintain, or protect Lender's security interest any Eligible Purchase Order, or (c) grant any credit, discount, in the Collateral. Borrower agrees to execute and deliver any such allowance, deduction, return authorization, or the like with respect documents as may be required by the Lender to facilitate such to any Eligible Purchase Order. Furthermore, Borrower shall (a) filing. use best efforts, and cooperate in good faith as requested by Lender, to ensure timely collection in full of all Collateral and (b) Borrower shall not encumber any Collateral except for take all steps necessary or desirable (including in the performance the grant description in Section 10. To the extent that a security of all contracts and other obligations relating to the Collateral) to interest(s) of a third party predates this Agreement and involves maximize the value of the Collateral and ensure timely the Collateral described in Section 10, as a condition to funding satisfaction of the Borrower's obligations hereunder. described in Section 9, Borrower shall obtain and provide Lender with a subordination agreement with respect to the Collateral in 18. Borrower warrants, represents and/or covenants (as form and substance acceptable to Lender in its sole discretion applicable) that: upon its request, except that Borrower shall not be required to The Collateral is free and clear of all liens, obtain any subordination agreement from, or with respect to the encumbrances, security interests, and adverse claims alleged liens and/or security interests asserted by, Atlantic Wave (other than those granted to Lender hereunder), other Holdings, LLC and/or Secure Community, LLC and/or than the Atlantic Wave Liens; Strikepoint Consulting LLC (collectively, theạiAtlantic Wave Partiesiạ, which asserted liens and/or security interests (the Borrower acknowledges that it shall not obtain any "Atlantic Wave Liens") are described in, and disputed in whole additional financing that is secured by the Collateral after and/or in part by Borrower in, among other things, (a) that certain entering ints Agreement. civil proceeding commenced by the Atlantic Wave Parties against Initials: Borrower and Mark D. Schmidt, removed to the United States District Court for the Southern District of California on or about LEGALIST_000003
claimallegation

Borrowers represent eligible orders genuine/collectable, financial information and liabilities accurate subject to the AW litigation excepti

Borrowers represent eligible orders genuine/collectable, financial information and liabilities accurate subject to the AW litigation exception, taxes compliant and authority valid; the representations are repeated upon each advance. Power-of-attorney provisions permit collections, litigation/proof of claim and mail-related actions with costs charged to borrower.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 28 of 145 PagelD# 2162 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 b. All Eligible Purchase Orders in an Advance Request are acknowledgment is in addition to, and not in lieu of, any and at all times will continue to be genuine, bona fide, obligations under this Section 18. and collectable and without right of offset, counterclaim, or right of return or cancellation; 19. Each warranty and representation contained in this agreement shall be deemed reaffirmed with each Advance Borrower acknowledges that it shall not submit for Request submission and each advance of funds and shall be funding any purchase order that may be disputed or conclusively presumed to have been relied on by Lender cancelled buS Government Account Debtor. regardless of any investigation made, or information possessed, Initials: by Lender. The warranties, representations, agreements, and covenants herein shall be cumulative and in addition to any c. Omitted. contained in any other document or instrument that Borrower Borrower's books and records do and shall fully and gives, or causes to be given, to Lender, either now or hereafter. accurately reflect all of Borrower 's assets and liabilities Borrower acknowledges that it is reaffirming each warranty, other than the Atlantic Wave Litigation (absolute and representation, and/or covenant in Section 18 with each Advance contingent) and have been and shall be kept in the Request the submits. ordinary course of business in accordance with generally accepted accounting principles consistently applied, and Initials: all information contained therein is and shall be true and Borrower hereby irrevocably appoints Lender its true and lawful attorney in fact (which appointment is coupled with an Borrower aaknowledges that its books and records shall interest and irrevocable) to exercise, at any time and from time to time in Lender's sole discretion, the following powers, until all be main a ford accurate. amounts due Lender have been fully, finally, and indefeasibly Initials: paid: (i) receive, take, endorse, assign, deliver, accept, and e. All taxes of any governmental or taxing authority due or deposit, in the name of Lender or Borrower, cash, checks, payable by, or imposed or assessed against, Borrower, commercial paper, drafts, remittances, and other instruments and have and shall be paid in full before delinquency; documents relating to any Eligible Purchase Orders, other Collateral, or the proceeds thereof; (ii) execute and file any Borrowe agroy ledges that it shall timely pay all taxes. financing statement or similar document that may be necessary or Initials: desirable to perfect or maintain the lien and security interest granted herein (Borrower hereby approves and ratifies any There is no action or proceeding pending by or against financing statement filed by Lender against Borrower prior to the Borrower before any court or administrative agency or date hereof); (111) enter into agreements with Government pending, threatened, or imminent governmental Account Debtors, obligors, or third parties in order to enforce or investigation, or other claim, complaint, or prosecution collect upon any Eligible Purchase Orders or other Collateral; (iv) involving Borrower, other than the Atlantic Wave discharge past due taxes, assessments, charges, fees, or liens on the Collateral; (v) contact any Government Account Debtor for Borrower acknowledges that there are no pending any reason; (vi) take or bring, in the name of Lender or Borrower, actions agaisst it (other than the Atlantic Wave all steps, actions, suits, or proceedings necessary or desirable to (a) perform any contract or other arrangement giving rise to any Litigation) MUS Eligible Purchase Orders; and (b) otherwise collect or realize on Initials: any Eligible Purchase Orders, other Collateral, or the proceeds g. Borrower has the legal power and authority to enter into thereof; (vii) settle, adjust, compromise, extend, or renew any Eligible Purchase Orders or other Collateral; (viii) settle, adjust, this agreement and to perform and discharge its obligations hereunder; and or compromise any legal proceedings brought to collect any Eligible Purchase Orders or other Collateral; (ix) prepare, file and Borrower ackaowledges that there is nothing preventing sign Borrower's name on a proof of claim in bankruptcy, it from entent ghto this Agreement. receivership, or similar proceeding against any commercial account debtor or other obligor of Borrower; (x) prepare, file, and Initials: sign Borrower's name on any notice of lien, assignment, or h. No information furnished by or on behalf of Borrower satisfaction of lien or similar document in connection with any (including but not limited to facts, figures, and Eligible Purchase Orders; (xi) change the address for delivery of representations given) contains or shall contain any Borrower's mail to such address as Lender may designate and to untrue statement of, or omit any, material fact. receive, open, and dispose of such mail; and (xii) do all other acts and things reasonably necessary to carry out the terms of this Borrower acknowledges that it has not provided any Agreement and to preserve, protect, or enforce Lender's rights false infirmatio to Lender. with respect to the Collateral. Initials: Borrower ratifies and confirms all acts and deeds lawfully done The foregoing acknowledgments are not intended to be, and shall by Lender pursuant to the foregoing powers of attorney. Borrower not be construed as, an exhaustive list of all potential breaches of further agrees to reimburse Lender on demand for any this Agreement. For the avoidance of doubt, each documented payment made or any out-of-pocket expense incurred by Lender in connection with any of the foregoing; provided that, this authorization shall not relieve Borrower of any of its LEGALIST_000004
claimallegation

Default triggers include false information, covenant breach, insolvency/receiver events, cross-default, tax liens and government-contract te

Default triggers include false information, covenant breach, insolvency/receiver events, cross-default, tax liens and government-contract termination. Contractual remedies include notice-based acceleration, further default interest, costs and indemnity subject to lender gross-negligence/fraud limits; ordinary termination requires 120 days and does not release unpaid security.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 29 of 145 PagelD# 2163 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 obligations under this Agreement. In no event will Lender have Borrower retains or converts moneys properly due to any liability to Borrower for lost profits or other special or Lender, including failing to repay all consequential damages relating to the foregoing or otherwise. outstanding hereunder on an Advance Maturity Date, the TERMINATION BY LENDER Facility Maturity Date, and/or when otherwise due hereunder; 21. An "Event of Default shall be deemed to have occurred and be continuing if: Borrower acknowledges that it shall not misappropriate a. Borrower makes any false, misleading, or untrue any unes Mul So Lender. representation or warranty in connection herewith or Initials: fails to comply with any covenant or agreement herein; Any guarantor of Borrower's obligations to Lender fails Borrower acmowledges that it shall not provide any to perform or observe any obligation to Lender or notifies Lender of an intention to rescind, modify, false informatra to Lender. terminate or revoke any guaranty, or any such guaranty Initials: ceases to be in full force and effect for any reason b. Borrower makes a general assignment for the benefit of its creditors other than Lender or commences or has Borrower acknowledges that any breach by a guarantor commenced against it any proceeding under any title 11 is a defal hergunder. of the United States Code or any similar law existing for the relief from creditors; Initials: Borrower knowledges that it shall not file any i. A federal, state, or local tax lien is filed against the Borrower, its principals, or any Collateral; bankrup energeeding. Initials: Borrower admowledges that it shall not cause any tax liens to be against it or its principals. A receiver or trustee is appointed for Borrower, or any proceeding is instituted for the dissolution or full or Initials: partial liquidation of Borrower; Borrower fails to timely furnish Lender with full Borrower acknowledges that it shall not cause any financial statements as required in Section 3(c) hereinabove; or proceeding Piled leading to liquidation of its assets. Initials: Borrower ackhowledges that it shall provide full financial sta arats in timely fashion. d. A sale or transfer is effected of Borrower in one or a series of related transactions of 50% or more of the Initials: interests of Borrower without the prior written approval Borrower defaults under any other agreement or of Lender; instrument under which Borrower owes or guarantees Borrower actowledges that it shall not sell a majority payment or performance. of the compafy without Lender's prior approval. Borrower acknowledges that a default under any of its Initials: other agrees is a default hereunder. e. Any change occurs in Borrower's business or business Initials: structure, expressly including its ownership or financial 1. Any of Borrower's contracts with any Government condition or there occurs any dispute between its Account Debtor are terminated. principals/managers/officers, any of which (in Lender's sole and absolute discretion) causes Lender to deem Borrower ackhowledges that termination of any contract itself insecure; is grounds oftefault hereunder. Borrower-acknowledges that it shall not change any Initials: material asper of its business structure. The foregoing acknowledgments are not intended to be, and shall Initials: not be construed as, an exhaustive list of all potential Events of Default. For the avoidance of doubt, each acknowledgment is in f. Any subordination agreement whereby any indebtedness addition to, and not in lieu of, any Events of Default under this of Borrower to any third party is subordinated to Section 21. Borrower's obligations to Lender is amended without the prior written consent of Lender or is breached or Borrower shall provide Lender immediate written notice of the repudiated in any manner by Borrower; occurrence of any Event of Default. Borrower acknowledges that it shall not amend any After an Event of Default, Lender may suspend or terminate subordinations agreement without Lender's prior Lender's obligations to make advances and/or render other approval services hereunder upon notice of termination to Borrower, after MDS which all Advance Maturity Dates and the Facility Maturity Date Initials: shall be deemed to have occurred and Borrower shall be obligated, without further demand, protest, or notice of any kind, to pay LEGALIST_000005
claimallegation

Agreement addresses insurance/tax duties, notices and assignment, applies New York law and exclusive venue, and invokes CPLR 3213 with a pay

Agreement addresses insurance/tax duties, notices and assignment, applies New York law and exclusive venue, and invokes CPLR 3213 with a payment defence retained. Brian T. Rice signs for Legalist and Mark D. Schmidt for Cyberlux/Datron; the signature page describes Cyberlux's organisation as North Carolina and Datron's as California.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 30 of 145 PagelD# 2164 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 immediately to Lender the full amount of its outstanding related fees, costs, and expenses, expressly including legal obligations hereunder. Upon the occurrence of an Event of expenses awarded against or incurred by any of them arising out Default, Lender may take all steps necessary or desirable to of or relating to the transactions hereby contemplated, in any way collect such amount, expressly including those in Section 15. whatsoever. Notwithstanding the above, Borrower shall not After an Event of Default, Borrower, its successors or assigns, indemnity if Lender, its affiliates (expressly including Legalist, shall be chargeable with and agrees to pay all costs of collection Inc.), or their respective directors, officers, investors, partners, and defense, including attorneys' fees and costs, actually incurred employees, or agents have committed gross negligent or by Lender, all of which shall accrue interest at the rate specified fraudulent acts in connection with this Agreement. in Section 22 herein below, through the date of repayment in full. NO WAIVER From the occurrence of an Event of Default until Borrower's repayment in full of its obligations hereunder, any The failure of Lender or Borrower to enforce any outstanding obligation shall accrue incremental interest of 4.75% provision hereof, or the failure to exercise any right hereunder, per year, which shall (in addition to the interest rate provided in shall apply only in the particular instance and shall not operate as Section 9.2 and any and all other amounts outstanding) compound a continuing waiver of rights. To the maximum extent permitted and be capitalized monthly. under applicable law, Borrower hereby irrevocably waives any and all rights and remedies now or hereafter conferred by statute In the absence of conditions set forth in Section 21, or otherwise which may require Lender to (a) take any judicial Lender may terminate its obligations under this Agreement upon proceedings in connection with any Collateral or otherwise use 120 days' prior written notice for any reason or no reason, with any Collateral in mitigation of Lender's damages, (b) proceed the full amount of Borrower's outstanding obligations hereunder against any person or entity liable for any obligations as a becoming immediately due and payable on the effective date of condition to or prior to proceeding hereunder, or (c) dispose of sell, or otherwise realize on or collect or apply any personal This agreement and the security interests hereby granted property securing any obligation of Borrower, as a condition to or shall remain in effect until such time as the full amount of prior to proceeding against Borrower hereunder. Borrower's outstanding obligations hereunder have been repaid. INSURANCE REQUIREMENTS All notices and other communications hereunder shall be Borrower shall provide Lender with proof of employee sent by electronic mail and deemed effectively given (i) when bonding (if required by its Government Account Debtors), sent, if sent during normal business hours of the recipient or (ii) if workers compensation, and general liability insurance. Borrower not sent during normal business hours, then on the recipient's next shall notify Lender of any changes in insurance and shall ensure business day. All communications shall be sent to the parties at that Lender is named on the certificate of insurance list as the respective email addresses set forth on the signature page (or certificate holder. as subsequently modified by written notice given in accordance with this Section). INDEMNIFICATION ASSIGNMENT Borrower agrees and warrants circumstances shall its employees be considered employees of This Agreement shall be binding upon and inure to the Lender for any purpose or reason. Such employees shall at all benefit of the parties hereto and their respective heirs, times be recognized as the employees of Borrower for all representatives, and successors. Lender may assign its rights and purposes. Borrower shall, promptly after each pay period as obligations hereunder upon notice to Borrower; provided that required, make payments to the Internal Revenue Service for assignments to an affiliate shall not require prior notice to be federal taxes, to the applicable state authority for state taxes, and to any other governmental agency to which any tax or similar Any attempted assignment by Borrower of its rights or payment obligation is due with respect to its employees' activities. obligations under this Agreement without the prior written Borrower shall cause Lender to be given promptly suitable consent of Lender shall be null and void ab initio and without evidence of all such payments. further effect. Borrower warrants and covenants that all of its SEVERABILITY OF PROVISIONS employees are and shall remain legally entitled to be employed in the United States and agrees to defend and hold harmless Lender, 33 Each provision hereof shall be severable from every its affiliates (expressly including Legalist, Inc.), and their other provision for the purposes of determining legal respective directors, officers, investors, partners, employees, and enforceability of any such provision. agents for any failure by Borrower to comply with relevant GOVERNING LAW AND JURISDICTION immigration, non-discrimination, employment, and/or employee- benefit laws. This Agreement shall be governed by, and construed in accordance with, the laws of the State of New York, without Without limiting any other rights hereunder or under regard to its contlict of law principles, and shall be deemed to applicable law, and without limiting Section 27, Borrower hereby have been negotiated, executed, and performed exclusively agrees to indemnify Lender, its affiliates (expressly including therein. Any dispute, claim, or controversy arising out of or Legalist, Inc.), and their respective directors, officers, investors, relating to this Agreement or the breach, termination, partners, employees, and agents, forthwith upon demand, from enforcement, interpretation, or validity thereof, shall be brought and against any and all damages, losses, claims, liabilities, and exclusively in the state or federal courts located in New York, LEGALIST_000006
claimallegation

Schmidt's restated guaranty covers the $12.3 m financing with continuing obligations, deferred subrogation, costs and personal security. Sec

Schmidt's restated guaranty covers the $12.3 m financing with continuing obligations, deferred subrogation, costs and personal security. Section 7 limits enforcement to defaults under agreement 21(a) and(g), notwithstanding broad surrounding language. It provides Delaware governing law and New York arbitration; section 19 gives 29 April 2025 restatement and the image bears Schmidt's signature.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 32 of 145 PagelD# 2166 Docusign Envelope ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 SECOND AMENDED AND RESTATED GUARANTY heirs, executors, administrators, and successors of Guarantor; OF FINANCING AGREEMENT provided this Guaranty may not be assigned without prior This Second Amended and Restated Guaranty of Financing written consent of Lender. Agreement (the "Guaranty") is made effective as of March 27, Lender may enforce this Guaranty only in the event of 2024, by Mark D. Schmidt (Guarantor), in favor of Legalist default under Sections 21(a) and (g) of the Agreement without SPV III, LP ("Lender). Guarantor and Lender are collectively being first required to proceed against the Company, any other referred to as "Parties. party, or any other guarantor (if any) or to attempt to realize on WHEREAS Lender has agreed to fund Cyberlux any Collateral (as defined in the Agreement). The Guarantor Corporation and Datron World Communications, Inc. (each and shall not be entitled to satisfy this Guaranty by contributing together, the "Company") the sum of up to $12,300,000 (the ratably with any other guarantor or by otherwise paying less "Investment") pursuant to a Second Amended and Restated than the entire unpaid Indebtedness. Payment under this Government Purchase Order Financing Agreement among the Guaranty shall be due immediately upon demand by Lender. Company and Lender (as in effect from time to time, the In the event of the death of the Guarantor, the "Agreement'), which is hereby incorporated by reference obligation of the deceased hereunder shall continue in full force and effect against his or her estate as to any Agreement WHEREAS, as a condition precedent to the Investment, obligations that shall have been created or incurred by the Lender requires Guarantor to execute and perform in Company or committed or promised to Lender in any other accordance with this Guaranty; and manner prior to the time when Lender shall have received notice in writing of such death. The executor or administrator of such WHEREAS Guarantor desires to induce Lender to make estate shall be obligated and authorized to pay all Indebtedness the Investment in reliance on this Guaranty. and otherwise to satisfy the Company's obligations under the Guaranty Agreement. NOW, THEREFORE, in consideration of the Investment, 9. This Guaranty is and is intended to be an absolute, and for other good and valuable consideration, the receipt and unconditional and continuing guaranty which shall not be adequacy of which are hereby acknowledged, Guarantor agrees affected by any act or thing whatsoever except as herein as follows: provided, and which shall be independent of and in addition to any other guaranty, endorsement or collateral held by Lender 1. Lender has agreed to make the Investment subject to the with respect to the Agreement or Indebtedness. Guarantor terms and conditions stated in the Agreement. specifically acknowledges and agrees that, as long as the Guarantor hereby guarantees full and complete Company owes obligations under the Agreement, this Guaranty payment and performance of the Agreement by the Company, shall remain in full force and effect. The amount guaranteed including prompt payment of the full amount of Company's hereby shall continue to be guaranteed notwithstanding prior or Indebtedness when due thereunder. subsequent reduction of the Indebtedness by persons or from sources other than the Guarantor, so long as obligations remain For purposes of this Guaranty, the term "Indebtedness" means under the Agreement. the obligation of the Company to pay all obligations to Lender 10. TO thereunder on or before an Advance Maturity Date and/or the secure Guarantor's obligations hereunder, Facility Maturity Date (as defined in the Agreement). Guarantor hereby pledges, assigns, and grants to Lender a security interest in and to any and all right, title, or interest of 3. This Guaranty shall continue in full force and effect until the Guarantor, now existing or hereafter acquired, in all Accounts, Agreement has been fully performed and discharged. The Chattel Paper, Goods (including Inventory and Equipment), Guarantor acknowledges that (1) there may be future advances Instruments, Investment Property, Documents, and General under, or other amendments and modification to, the Intangibles, and all Proceeds thereof. Capitalized terms used Agreement after the date hereof, (ii) the amount of the but not defined in this Section 10 have the meanings given to Indebtedness may fluctuate from time to time hereafter, and (iii) them in the Uniform Commercial Code. this Guaranty shall remain in force at all times hereafter with respect to all obligations under the Agreement, without the Upon the occurrence of a default under the Agreement necessity of amending or modifying this Guaranty or entering or hereunder, Lender may, at its option, call on this Guaranty, into a new or separate agreement with respect thereto. and, if it is not satisfied in full within three days of notice, Lender may proceed at any time thereafter to take any action 4. Guarantor agrees not to assert subrogation rights or any other permitted under the Uniform Commercial Code or other rights of any kind against the Company, until the Agreement applicable law. has been fully performed, and the Guarantor will take no action Notice to Guarantor should be sent to the email that may reasonably be expected to, or which does or shall, impair or limit Lender's ability to recover thereunder. address set forth opposite Guarantor's signature below. 5. In addition to the Indebtedness, the Guarantor agrees to pay 13. This Guaranty shall be govered by the laws of the all costs and expenses incurred by Lender in attempting to state of Delaware, without regard to any conflict of laws collect the Indebtedness and in enforcing this Guaranty. principles. 6. This Guaranty shall inure to the benefit of Lender, its 14. After an Event of Default, Guarantor, its successors or successors in interest and assigns and shall be binding upon the assigns, shall be chargeable with and agrees to pay all costs of collection and defense, including attorneys' fees and costs, LEGALIST_000008
claimallegation

Attached borrowing-base certificate, disbursement request and Eligible Purchase Orders schedule are blank forms/placeholders. No completed b

Attached borrowing-base certificate, disbursement request and Eligible Purchase Orders schedule are blank forms/placeholders. No completed borrowing calculation, requested sum or attached eligible contract appears on these pages; blank no-default certifications are not actual submissions.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 34 of 145 PagelD# 2168 Docusign Envelope ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 Exhibit A Borrowing Base Certificate Borrower: Cyberlux Corporation and Datron World Communications, Inc. Month Ending: Credit Limit: $ 2. Previous Balance (Balance from your last monthly loan report): $ Collections (Any collections from last monthly loan report): $ Current Funded Contracts/PO (Advance Rate: 50%) Contract/PO: 1. Total Amount of Contract/PO: Outstanding on Contract/PO: Remaining Availability: (Line 3(a)(1)(1) - Line 3(a)(i) (2) × Advance Rate) New Request: 5. Collections: iİ. Contract/PO: Outstanding on Contract/PO: 2. Remaining Availability: New Request: 4. Collections: iïi. Contract/PO: 1. Outstanding on Contract/PO: 2. Remaining Availability: S 3. New Request: 4. Collections: b. New Contracts/PO i. Contract/PO: 1. Total Amount of Contracts: 2. Availability: (Line 3(b)(i)(1) x Advance Rate) 3. Requested Distribution: Contract/PO: LEGALIST 000010
claimallegation

Signed Instrument of Assignment assigns accounts identified in an enclosed notice, covers unpaid amounts, names one assignee, prohibits furt

Signed Instrument of Assignment assigns accounts identified in an enclosed notice, covers unpaid amounts, names one assignee, prohibits further assignment and invokes 48 CFR 32.805. Rice and Schmidt signatures appear; this page alone supplies no actual account schedule or proof of notice delivery.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 37 of 145 PagelD# 2171 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 Exhibit C Instrument of Assignment Reference is made to that certain Government Purchase Order Financing Agreement (the "Agreement'), dated as of March 27, 2024, between Cyberlux Corporation and Datron World Communications, Inc., as assignor ("Assignor), and Legalist SPV III, LP as assignee ("Assignee). Capitalized terms used but not defined herein have the meanings assigned to them in the Agreement. For good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Assignor and Assignee agree as follows: 1. Assignor hereby collaterally assigns to Assignee all right and title to, and interest in, any account(s) indicated in the enclosed Notice of Assignment, all rights to payment therefrom, and all proceeds thereof (all as set forth in greater detail in the Agreement). 2. The parties confirm that this instrument is intended to function as an "instrument of assignment within the meaning of 48 CFR § 32.805. 3. The assignment (a) covers all unpaid amounts; (b) is made only to Assignee; and (c) is not subject to further assignment. Assignor hereby ratifies its irrevocable appointment of Assignee as its agent and true and lawful attorney in fact for purposes hereof, including submitting evidence of this assignment to Assignor's contract counterparties. 5. Nothing herein shall supersede or change the Agreement, and both the Agreement and this instrument shall be interpreted together as one document. ASSIGNEE: LEGALIST SOV III, LP By Name: Brian T. Rice :460... Title: Authorized Signatory Address: 58 West Portal Ave. #747 San Francisco, CA 94127 Email: receivables@legalist.com ASSIGNOR: CYBERLUX CORPORATIOI hark v. Secumid Name: Mark D. Schmidt Title: President and CEO Address: 800 Park Offices Dr., Ste. 3209 Research Triangle, NC 27709 Email: mschmidt@cyberlux.com ATRON WORLD COMMUNICATIONS, INC Mark V. Selemidi BY B9EẸ73498ĐE446... * Name: Mark D. Schmidt Title: Address: 995 Joshua Way, Ste. A Vista, CA 92081 Email: mschmidt@cyberlux.com * Authorized representative and corporate secretary LEGALIST 000013
claimallegation

Legalist's 9 March 2026 response claims $13,204,742.88: $10,033,639.75 principal, $2,653,970.84 interest, $112,500 commitment fees, $53,000

Legalist's 9 March 2026 response claims $13,204,742.88: $10,033,639.75 principal, $2,653,970.84 interest, $112,500 commitment fees, $53,000 forbearance fee, $312,959.79 paid legal fees and $38,672.50 unpaid legal fees. These are creditor computations, not an allowed distribution.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 40 of 145 PagelD# 2174 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. LEGALIST SPY IL, LP'S RESPONSE TO JOINT DISCOVERY PLAN INTERROGATORY AND REQUESTS FOR PRODUCTION Interpleader Defendant/Claimant Legalist SPV III, LP (Legalist), provides the following response to the pre-settlement interrogatory and requests for production providing in the Joint Discovery Plan (ECF No. 149). Interrogatory Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) the amount of the proceeds that you claim; (b) the legal basis for your right to the proceeds; (c) how the amount you claim became a liquidated amount or, if not liquidated, state so; (d) whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment; (e) whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any; (f) whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim; and (g) for any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed. Response: (a) the amount of the proceeds that you claim Legalist claims $13,204,742.88, comprising of: • $10,033,639.75 principal • $2,653,970.84 unpaid interest • $112,500.00 commitment fee
claimallegation

Legalist describes principal as $6.95 m ordinary advances plus $3,083,639.75 protective advances; it claims 1 April 2024 UCC priority in Nev

Legalist describes principal as $6.95 m ordinary advances plus $3,083,639.75 protective advances; it claims 1 April 2024 UCC priority in Nevada/North Carolina for the 27 March financing and continuing interest. Legal fees total $351,632.29.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 41 of 145 PagelD# 2175 • $53,000.00 forbearance fee • $312,959.79 paid legal fees and costs • $38,672.50 unpaid legal fees and costs (b) the legal basis for your right to the proceeds On March 27, 2024, Legalist entered into a Second Amended and Restated Government Purchase Order Financing Agreement (Financing Agreement) with Cyberlux, whereby Legalist provided a revolving line of credit in the amount of $7,000,000.00 secured by certain collateral, including accounts receivable. Legalist has advanced $6,950,000 of the principal amount identified above pursuant to the Financing Agreement. Legalist also advanced $3,083,639.75 pursuant to the financing agreement at Cyberlux's request in June 2025. The Financing Agreement also provides for Legalist's right to interest (paragraphs 9.1, 9.2, and 9.9(a)), commitment fees (paragraph 9.4), forbearance fees (paragraph 9.9(b)), and attorney fees and costs (paragraph 29). Pursuant to the Financing Agreement, on April 1, 2024, Legalist filed certain financing statements under the Uniform Commercial Code ("UCC Statements") in Nevada and North Carolina identifying and perfecting its lien on Cyberlux's assets, including its accounts receivable. how the amount you claim became a liquidated amount or, if not liquidated, state so The full amount claimed is liquidated based on specific sums loaned to or advanced on behalf of Cyberlux pursuant to the Financing Agreement, plus accrued unpaid interest, fees, and attorneys' fees and costs. (a) whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment Legalist has a perfected security interest in Cyberlux's assets and accounts receivable, including all of the subject proceeds. Legalist's secured interest was created on March 27, 2024,
claimallegation

Gonzalez asserts TAG is the only interpleader claimant that actually manufactured and sold goods used in the subcontract. That comparative a

Gonzalez asserts TAG is the only interpleader claimant that actually manufactured and sold goods used in the subcontract. That comparative assertion is his position, not an adjudication of every competing claimant's performance.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 2 of 145 PagelD# 2136 ("HII') predecessor in interest and Cyberlux (the "Subcontract') that is the subject of HIl's First Amended Complaint for Interpleader. ECF 41 at 119 17-30. Indeed, the drone kit bags were used to package the drones that were manufactured and sold pursuant to the Subcontract. A true and correct copy of a picture of the drone kit bags (TAG 0007) is attached hereto as Exhibit 2. 5. Importantly, TAG is the only claimant to this action that manufactured and sold anything that is related to the Subcontract. As set forth in the Contract, the total agreed contract price for the Contract was $887,900.00. Cyberlux paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100 drone kit bags in full performance of its obligations under the Contract. TAG then delivered 1,722 of the drone kit bags to Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG pending final payment on the Contract. As of November 18, 2024, the balance due, including a 1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to Cyberlux for payment of the remaining balance, but received no response to any of these demands. The Colorado Action, The Final Judgment, And The Certified Final Judgment 8. Because Cyberlux was in material breach of the Contract at least by December 3, 2024, on March 12, 2025, TAG filed a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case No. 1:25-cv-00805 (the "Colorado Actionằ_ alleging breach of contract, unjust enrichment, and civil theft under Colorado law, which provides for treble damages, attorneys' fees, and costs if TAG prevailed in the Colorado Action. A true and correct copy of the Complaint in the 2
claimallegation

Legalist lists ordinary 2024 advances:9 April $1.8 m;19 April $500,000;2 May $500,000;26 June $142,000;5 July $53,000;16 July $2.5 m;2 Augus

Legalist lists ordinary 2024 advances:9 April $1.8 m;19 April $500,000;2 May $500,000;26 June $142,000;5 July $53,000;16 July $2.5 m;2 August $650,000;27 August $535,000;3 October $150,000 and $120,000. The own image resolves the malformed OCR of the $150,000 entry.

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Case 3:25-cv-00483-JAG Document 165-1 _ Filed 04/15/26 Page 42 of 145 PagelD# 2176 by the Financing Agreement and perfected on April 1, 2024, when Legalist filed UCC Statements where Cyberlux is incorporated, Nevada, and where Cyberlux is headquartered, North Carolina. Va. Code Ann. §§ 8.9A-310, 8.9A-307(b); see also Nev. Rev. Stat. Ann. §§ 104.9310, 104.9307; N.C. Gen. Stat. §§ 25-9-310, 25-9-307. (e) whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any Legalist claims interest on the full principle, pursuant to paragraphs 9.1, 9.2, and 9.9(a) of the Financing Agreement. (I) whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim Legalist claims a right to attorney fees and costs, pursuant to paragraph 28 of the Financing Agreement. For the purposes of the upcoming settlement conference Legalist claims legal fees and costs of $351,632.29, although this amount will increase if this litigation continues beyond the settlement conference. for any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed All advances Legalist has made to Cyberlux are secured by the UCC Statements with a priority date of April 1, 2024, when the UCC Statements were filed. Legalist made advances under the Financing Agreement on the following dates: • 4/9/2024: $1,800,000.00 • 4/19/2024: $500,000.00 • 5/2/2024: $500,000.00 • 6/26/2024: $142,000.00 • 7/5/2024: $53,000.00 • 7/16/2024: $2,500,000.00 • 8/2/2024: $650,000.00 • 8/27/2024: $535,000.00
claimallegation

Legalist lists 3 June 2025 $2,755,100.10 and 9 June $345,000, explaining that the $3,100,100.10 initial advance less $16,460.35 applied to l

Legalist lists 3 June 2025 $2,755,100.10 and 9 June $345,000, explaining that the $3,100,100.10 initial advance less $16,460.35 applied to legal fees equals $3,083,639.75 protective principal. Response cites LEGALIST 000001–20 and is served 9 March 2026; Exhibit 6 here contains only 000001–14.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 43 of 145 PagelD# 2177 • 10/3/2024: $150.00.00 10/3/2024: $120,000.00 • 6/3/2025: $2,755,100.10 • 6/9/2025: $345,000.00ł Requests for Production 1. Documents supporting or otherwise concerning your answer to the above interrogatory. Response: See the documents produced at Bates Nos. LEGALIST_000001-20. 2. All documents on which you rely to assert any security interest in, lien on, or assignment of the proceeds that are the subject of this interpleader. Response: See the documents produced at Bates Nos. LEGALIST_000001-20. Date: March 9, 2026 LEGALIST SPV III, LP By: Timothy G. Moore (VSB No. 41730) tmoore@spottsfain.com John M. Erbach (VSB No. 76695) jerbach@spottsfain.com Christopher W. Bascom (VSB No. 87302) cbascom@spottsfain.com Spotts Fain, P.C. 411 E. Franklin Street, Suite 600 Richmond, VA 23219 (804) 697-2065 (804) 697-2165 Fax Jeff. P Prostok (admitted pro hac vice) 1 The final two entries covered the $3,083,639.75 protective advance Legalist made on behalf of Cyberlux. Legalist initially advanced $3,100,100.10, and the $16,460.35 difference was applied to its legal fees. [Own-image correction: first entry reads 10/3/2024: $150,000.00; next $120,000.00. June entries are $2,755,100.10 and $345,000.00, with footnote explaining $16,460.35 applied to fees.]
claimallegation

AW and Secure Community jointly respond on 9 March 2026, describing AW as SC's sole owner and their claims as the same obligation rather tha

AW and Secure Community jointly respond on 9 March 2026, describing AW as SC's sole owner and their claims as the same obligation rather than additive recoveries. They trace the debt to intellectual-property acquisition and the 15 June 2023 settlement, with a separate contingent stock claim.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 47 of 145 PagelD# 2181 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH') and in Response to Interpleader Defendant Cyberlux Corporation's ("CYBL') Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC ("SC'). Accordingly, while each a party, A WH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide Marketable Trading" CYBL stock. 3. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreemenằ_ dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
claimallegation

AW/SC say the first judgment/related collection was fully satisfied, including $1,444,543.11 garnishment proceeds and $952,601.71 principal/

AW/SC say the first judgment/related collection was fully satisfied, including $1,444,543.11 garnishment proceeds and $952,601.71 principal/fees plus Texas costs. Their separate later stock-related $6 m claim remains asserted; satisfaction of the original case is not a release of every later claim.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 49 of 145 PagelD# 2183 10. The Garnishment in Fairfax is referred to by HII as, in part, a basis for this Interpleader. See First Amended Complaint, paragraphs 50-55. 11. AWH and SC also domesticated the Virginia judgment (CL22-3882) in Harris County Texas where Cyberlux had a drone assembly facility. 12. Upon the domestication of the Virginia Judgment in Texas, Robert Berleth, Esquire was appointed as a Receiver for Cyberlux by Order entered in Harris County TX in Cause No. 202448085. The Order of Receivership is attached as Exhibit 11 to the First Amended Complaint. 13. The Order of Appointment granted broad powers to Berleth including the grant of power over all causes of action. See First Amended Complaint, Exhibit 11, Order, Paragraph 25(1). 14. Meanwhile, CYBL, also failed to provide "Marketable Trading" stock as required, and as required by paragraph 2(e) of the Settlement Agreement (the "Stock Claim"). 15. CYBL stock, if it had been properly administered as required by the Settlement Agreement, would have had significant value on or before October 2021, and was additional consideration for the Settlement Agreement. 16. Paragraph 2(e) of the Settlement Agreement reserved the right in AWH and SC to re-file a Complaint to enforce its rights under the Stock Claim upon breach. 17. Based on the breach, AWH and SC filed a Complaint to enforce its rights under the Stock Claim in Richmond Circuit Court which is pending and is filed as CL 24-3910. 18. Berleth, as part of his duties as Receiver, evaluated the Stock Claim advanced by AWH and SC and compromised the figure with AWH and SC to a reduced liquidated figure of $6,000,000.00, plus attorney fees and cost.
claimallegation

AW/SC claim $6 m plus $25,250.50 fees and $352.92 costs, six-percent interest/$986.30 per day from 5 February 2026, and 6 July 2023 priority

AW/SC claim $6 m plus $25,250.50 fees and $352.92 costs, six-percent interest/$986.30 per day from 5 February 2026, and 6 July 2023 priority. Their account refers to 18 December 2023 liquidation and 2 February 2026 reaffirmance in places, while attached entered orders show 18 December 2025 and 5 February 2026.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 50 of 145 PagelD# 2184 19. Berleth and A WH entered a Settlement Agreement (the Receiver Agreement) to be produced as Exhibit D. 20. The Receiver Agreement provided for entry of a Consent Judgment in CL 24-3910 which was entered by the Richmond Circuit Court on December 18, 2025, providing for judgment in the principal amount of $6,000,000, attorney's fees of $25,250.50 costs, and 6% interest from the date of judgment (the "Consent Order"). To be produced as Exhibit E. 21. The Consent Order ratified the Settlement Agreement as valid, and further ruled that the Order of Receivership had been properly recorded in the City of Richmond, without objection. 22. In Fairfax, HII, as garnishee had implead the sum of $1,444,543.11 based upon AWH's garnishment referred to herein at paragraph 9. 23. The Fairfax Court ordered the payment of $952,601.71 to AWH as principal and attorney's fees for the Virginia judgment but ruled that it had no jurisdiction to determine fees for collection activity outside of Virginia as provided by the Settlement Agreement. 24. Since that ruling, AWH has petitioned the Harris County court for reimbursement of its remaining fees incurred in the Texas action which has been granted by the court and paid to AW. The Texas enforcement action is therefore being non-suited and an order has been submitted. AW and SC have agreed that the underlying case CL23-3882 which was pending in the Circuit Court of the City of Richmond has been fully satisfied. 25. Accordingly, the claim advanced by AWH and SC against the Disputed Funds are as follows: Reasonable Attorney's fees necessitated by this Interpleader pursuant to the Settlement Agreement at paragraph 19. The Consent Judgment principal amount $6,000,000 $25,250.50 attorney fees
claimallegation

The 15 June 2023 settlement traces an 8 October 2021 IP acquisition and 24 September 2021 Strikepoint consultancy. It states $1.2 m less $27

The 15 June 2023 settlement traces an 8 October 2021 IP acquisition and 24 September 2021 Strikepoint consultancy. It states $1.2 m less $277,500 paid leaves $922,500 for IP, plus $650,000 consultancy, producing the $1,572,500 judgment framework. Nondischargeability is qualified by the fullest extent permitted by law.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 54 of 145 PagelD# 2188 Cyberlux Settlement Agreement Final 002 - 1pdf file: C: lisers willu Downlaaas:Cy berlux Settlement_Agreement... EXHIBIT SETTLEMENT AGREEMENT This Senlement Agreement (theiAgreement") is made as of this 15thth day of June 2023, by nd between ATLANTIC WAVE HOLDINGS. LLC. SECURE COMMUNITY, LLO (collectively, "Plaintiffs"), CYBERLUX CORPORATION AND MARK D. SCHMIDT (collectively, Defendants). and STRIKEPOINT CONSULTING, LLC ("Strikepoint") a separate party with some common interest holders to the Plaintifts. Plaimifts, Defendants, and Strikepoint shall collectively be referred to as the Parties to this Agreement" and Plaintiffs and Defendants shall collecuvely be referred to as "Parties to the Litigation. RECITALS WHEREAS, Plaintiffs and Defendants entered into an agreement on October 8, 2021, which compensated Plaintiffs for the reacquisition by Defendant Cyberlux of certain intellectual property in exchange for certain installment payments of fixed liquidated sums by Defendants to Plaintiffs and Freely Trading stock. which had fallen into arrears ("the IP Agreement): WHEREAS, on September 24, 2021. an agreement was executed between an entity described as "Strikepoints Consulting. LLC" and Defendant Cyberlux Corporation for certain consulting services (theiStikepoint Consulting Agreement"), which called for, inter alia, installment payments of fixed liquidated sums owed by Defendants to Plaintiff, which also fell into arrears: WHEREAS, Plaintiffs filed its Complaint for breach of said agreements in the Circuit Court of the City of Richınond, Virginia (the "Courti), against Defendants in the civil action titled, Atlantic Wave Holdings, LEC and Secure Community, LLC V. Cybertus Corporation and Mark D. Schmidt (Case No. CL22-3882) (the "Litigation"]. which remains pending: WITEREAS. the Parties to this Agreement desire to resolve and settle any and all existing disputes between the Plantifts and Defendants and between Strikepoint and Defendants to climate uncertainty and facilitate finat resolution of their respective relationships between the parties; and 1 01 15 G/15/2023, 5:50 PM
claimallegation

The 2023 settlement permits a new stock complaint if Pink/caveat compliance is not restored by 31 December 2023, with a reasonable extension

The 2023 settlement permits a new stock complaint if Pink/caveat compliance is not restored by 31 December 2023, with a reasonable extension and no res judicata/estoppel defence under the agreement. Sanctions of $3,895 and $6,842.50 are due within 21 days.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 56 of 145 PagelD# 2190 Cyberlux Settlement_AFreement Final 002 file://C: Users/willw/Downloads/Cyberlux_Settlement_Agreement... Balance of Consulting Vorcement: The parties agree to terminate and resolve any disputes arising out of the Strikepoint Consulting Agreement for consideration of: SIX HUNDRED FIFTY THOUSAND DOLLARS (S650,000), is the balance due and owing for installment payments under the Consulting Agreement between the partics. Total Value of the Consent Judgment: The total liquidated sum that shall be due and owing to Plaintiffs under the parties' Consent Judgment shall be ONE MILLION FIVE HUNDRED SEVENTY-TWO THOUSAND AND FIVE HUNDRED DOLLARS ($1,572.500), plus Plaintiffs' costs as defined in 4(d) (theạSeulement Consideration"). which is the sum of the outstanding installment payments oming in the IP Agreement, the Strikepoint Consulting Agreement, and Plaintiffs' costs as appropriately allocated between Plaintiffs and Strikepoint below. d. Effect of Consent Judument: The Consent Judgment shall be promptly entered tomtly and severally against Defendants and in favor of Plaintiffs in exchange for payment of the full Settlement Consideration. which shall resolve the above styled matter. The parties agree that the Consent Judgment shall not be dischargeable, including by appeal or bankruptcy, in any manner other than by agreement of the parties, to the fullest extent permissible under the law, Stock. Notwithstanding the foregoing, the parties agree that entry of the Consent Judgment awarding FINAL judgment in favor of Plaintifts and against Defendants shall resolve the pending Litigation. Notwithstanding entry of a Final Order. the parties herby agree that it the Cyberlux stock is not brought to current "Pink Status and the Caveat Emptor legend and restriction is not remedied and removed on or before December 31. 2023. Plaintifts shall have the option. at their 3 of 15 6/15/2023. 5:50 PM
claimallegation

The agreement specifies an initial $150,000 payment tied to execution/judgment/revenue with a 45-day cap; AW instalments are 36 times $21,45

The agreement specifies an initial $150,000 payment tied to execution/judgment/revenue with a 45-day cap; AW instalments are 36 times $21,459 and Strikepoint 36 times $18,055.56. Drone receipts can accelerate payments up to $5,000 per drone within 21 days; ordinary fees are capped at 12%/$188,700, excluding breach fees.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 57 of 145 PagelD# 2191 Cyberlux_Settlement_Agrecment Final 002 - 1 pdf file://C: Users/willw/Downloads/Cyberlux_Settlement_Agreement... sole discretion, to re-file a new complaint related to the breach by Defendants to create "Negotiable Shares" as that breach is alleged and defined in the Complaint, without Defendants asserting a defense of res judicata or collateral estoppel. Plaintiffs recognize that matters can be delayed at no fault of a party and to that end shall consider an extension of the aforementioned deadline (December 31, 2023) upon the showing of credible evidence to do so, for an extension period to be decided at the reasonable discretion of Plaintiffs. 3. Compliance with Court Orders dted December 13. 2022 & April 7. 2023, Within tventy-one (21) days of execution of this Agreement. Defendants shall pay the sanctions of S3,895.00 and S6.842.50. as provided by the Court's Orders in the Litigation. How the Settlement Consideration Shall be Paid. The Sculement Consideration shall be paid by Defendant to Plaintiff as follows: First Settlement Pavment: Within thirty (30) days after the simultaneous exccution of this Agreement, and entry of the Consent Judgment, and the receipt by Cyberlux of its first installment payment for the anticipated sale of drones or other revenue whichever occurs last. but in no event more than forty-five (45) days from the execution of this Agrecment. Defendants shall transmit to Plaimift, by wire transmission. the non defcasible sum of One Hundred Fifty Thousand Dollers ($150.000) (the "First Settlement Payment). The delivery of the First Senlement Payment shall require the actual receipt of the Settlement Payment by Plaintiffs as set forth herein. Time being of the essence. b. Monthly Installments Thereafter to Plaintiffs: Defendants shall transmit to Plaintiffs, by wire transmission thirty-Six (36) non-defeasible monthly payments of TWENTY-ONE THOUSAND FOUR HUNDRED AND FIFTY- NINE DOLLARS ($21.459.00) payable on the first day of each month, beginning 4 ot 15 6/5/2023, S:S0 PM
claimallegation

The 2023 settlement requires wire payments and satisfaction filings within 10 business days of completion. Cyberlux/Schmidt release immediat

The 2023 settlement requires wire payments and satisfaction filings within 10 business days of completion. Cyberlux/Schmidt release immediately, while claimant releases are conditioned on first payment. Other parties are not released; security and access to contract/payment information are retained subject to restricted-information exceptions.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 59 of 145 PagelD# 2193 Cyberlux Settlement Agreemen Final 002 -1.pdf file: C: Users: willw/Downloads Cyberlux Settlement_Agreement... THOUSAND SEVEN HUNDRED DOLLARS (S188.700). The CAP does not apply to restrict or limit Plaintifts ability to pursue costs and attorney's fees should Defendants breach this Agreement. This obligation shall be added to the total balance due specified in section Zibt above and paid to Strikepoint. Manner of Pavment: All payments shall be wired to Plaintiffs and to Strikepoint. Information and Instructions for completing the wire transfer shall be provided to Defendants' Counsel upon execution of this agreement. Plaintiff may change its payment instructions from time to time by providing written notice. Effect of Full Pavment: Upon payment of all sums due and owing herein, the Judgment entered herein shall be marked Satisfied. No Other Beneficiary: The payment of funds herein shall not operate to release any other pany, other than the Parties to this Agreement. as set forth below. Nor shall the dismissal of any claim herein inure to the benefit of any party who is not a Party to this Agrcement. Notice of Satisfaction. Within ten (10) business days of Plaintiff receiving the complete Settlement Consideration and satisfactions of all tenns hercin, Plaintiff shall file a Notice of Satisfaction, pursuant to Va. Code Ann. § 16.1-94.01. Mutual Release of All Claims. Immediately upon endorsement of this Agreement, except for the obligations expressly set forth herein and any claims or actions for breach or entorcement of this Agreemen. Défendants Cyberlux Corporation and Mark D. Schmidt, individually, hereby relcase any and all causes of action, claims, counterclaims, or demands, present or future, known or unknown, asserted or unasserted, against Plaintiffs or any of Plaintiffs' members, officers, agents, counsel, employees, and affiliates arising or accruing from the beginning of time and up to and including the date of this Agreement, including all claims based upon or in any way relating to the IP Agreement, the Strikepoint Consulting Agreement, Plaintiffs' 6 of 15 6/15/2023, 5:50 PM
claimallegation

The 2023 settlement preserves stock rights, requires good-faith financial/OTC work, and sets confidentiality/nondisparagement protections wi

The 2023 settlement preserves stock rights, requires good-faith financial/OTC work, and sets confidentiality/nondisparagement protections with 14-day cure provisions and collection/defence exceptions. Nondisparagement runs through 31 December 2023. Breach remedies include uncapped fees, records within 10 days with 3-day cure, and Richmond/Virginia forum terms.

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Case 3:25-cv-00483-JAG Document 165-1 _ Filed 04/15/26 Page 61 of 145 PagelD# 2195 Cyberlux Settlement Agreement_ Final 002 - 1pdi file: :C: I sers/will Downloads/Cyberlux_Settlement_Agreement... EmptorẠạirestriction) and will continuc to usc any and all reasonable efforts to maintain compliance at all times. 10 Financial Statements: Defendants hereby represent that any Financial Statenients published or produced hereunder or publicly filed which Plaintift has relied upon in entering into this Agreement. have been prepared in good faith and in accordance with OTC standards and are materially truc and accurate. OTC Markets: Defendants hereby represent that Defendants are using any and all reasonable efforts to resolve all issues with OTC Markets that is causing the OTC Markets to issue its cheat emptor restriction and will continue to use any and all reasonable efforts to have the Caveat Emptor restriction currently imposed by OTC Markets removed so that the stock will be returned to 'Pink Current" as soon as reasonably possible. 12. Stockhølders" Riøhts: 'The parties agrec that this agreement shall not affect Plaintiff s rights as stockholders in any manner going forward. 13. Confidentiality of Settlement Terms and Discovers Information. The terns and circumstances of this Agreement, and all documents and information disclosed in the Litigation, are completely confidential between the Partics and shall not be disclosed to anybody else. Any disclosure or violation shall be deemed a breach of this Agreement. If a Party discloses confidential information in material violation of this paragraph, then, following written notice to such Party summarizing such violation and such Party's failure to cure such material violation within fourteen (14) days of receiving such notice. then such Party may be deemed to have breached this Agreement. If a breach is to occur, notwithstanding the foregoing. Plaintiffs shall be entitled to use any information recerved in the Lungation if necessary to collect sums owing under this Agreement and/or to defend against any claims of breach, and Defendants shall be entitled to use such information to defend against any claims of breach, though reasonable efforts will be made to keep such information private. 8 of 15 6/15/2025, 5:50 PM
claimallegation

TAG says the unpaid balance was $365,049.42 on 18 November 2024, including 1.5% monthly late fees; collection attempts failed. Gonzalez says

TAG says the unpaid balance was $365,049.42 on 18 November 2024, including 1.5% monthly late fees; collection attempts failed. Gonzalez says neither Cyberlux nor HII had paid the remaining debt by his declaration.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 2 of 145 PagelD# 2136 ("HII') predecessor in interest and Cyberlux (the "Subcontract') that is the subject of HIl's First Amended Complaint for Interpleader. ECF 41 at 119 17-30. Indeed, the drone kit bags were used to package the drones that were manufactured and sold pursuant to the Subcontract. A true and correct copy of a picture of the drone kit bags (TAG 0007) is attached hereto as Exhibit 2. 5. Importantly, TAG is the only claimant to this action that manufactured and sold anything that is related to the Subcontract. As set forth in the Contract, the total agreed contract price for the Contract was $887,900.00. Cyberlux paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100 drone kit bags in full performance of its obligations under the Contract. TAG then delivered 1,722 of the drone kit bags to Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG pending final payment on the Contract. As of November 18, 2024, the balance due, including a 1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to Cyberlux for payment of the remaining balance, but received no response to any of these demands. The Colorado Action, The Final Judgment, And The Certified Final Judgment 8. Because Cyberlux was in material breach of the Contract at least by December 3, 2024, on March 12, 2025, TAG filed a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case No. 1:25-cv-00805 (the "Colorado Actionằ_ alleging breach of contract, unjust enrichment, and civil theft under Colorado law, which provides for treble damages, attorneys' fees, and costs if TAG prevailed in the Colorado Action. A true and correct copy of the Complaint in the 2
claimallegation

The 2023 signature page bears Charles Watts Jr as special counsel for Cyberlux and Schmidt, Schmidt individually and for Cyberlux, William W

The 2023 signature page bears Charles Watts Jr as special counsel for Cyberlux and Schmidt, Schmidt individually and for Cyberlux, William Welter for AW/SC and Strikepoint, and Cheri Nolan for Strikepoint. Visible dates are 15 June 2023; presence of signatures does not independently determine counsel's broader authority in other matters.

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Case 3:25-cv-00483-JAG Document 165-1 _ Filed 04/15/26 Page 65 of 145 PagelD# 2199 IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals. Date: 06/15/2023 Theres Watts. Ir, in his canci • Special Counsel for Cyberlux Corporation and Vark D. Schmidt Most D. Schnite Dare: 06/15/2023 Mark D. Schmidt, individually and on behalf of Cyberlux Corparation, as its President Datt Dale: June 15, 2023 William Welter. as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community. LLC STRIKEPOINT CONSULTING, LLÇ Dale: 6/15/2623 Cheri Nolan. CF1) and Pressient of Strikepout (onsulting. I. William Welter. Managing Director of Strikepoint Consulting, LLC Dale: June 15,2027 [Own-image transcription of material signature capacity: Charles Watts, Jr., in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Signatures of Schmidt, Welter and Cheri Nolan are present; dates read June15,2023.]
claimallegation

North Carolina filing 20230084472 C is stamped 6 July 2023 at 9:24 am, names Schmidt/Cyberlux debtors and AW plus SC as secured parties, and

North Carolina filing 20230084472 C is stamped 6 July 2023 at 9:24 am, names Schmidt/Cyberlux debtors and AW plus SC as secured parties, and describes broad assets, drone-related IP and Catalyst subsidiary interests. It is a filing record, not a priority judgment.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 66 of 145 PagelD# 2200 File Number: 20230084472C Date Filed: 7/6/2023 9:24:00 AM Elaine F. Marshall NC Secretary of State UCC FINANCING STATEMENT FOLLOW INSTRUCTIONS A. NAME & PHONE OF CONTACT AT FILER (optional) EXHIBIT Arlington Law Group B. E-MAIL CONTACT AT FILER (optional) B-1 elemmer@arlingtonlawgroup.com C. SEND ACKNOWLEDGMENT TO: (Name and Address) Arlington Law Group 1739 Clarendon Boulevard Arlington, VA 22209 J THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY 1. DEBTOR'S NAME: Provide only one Debtor name (1a or 1b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's name will not fit in line 1b, leave all of item 1 blank, check here and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad) 1a. ORGANIZATION'S NAME OR 1b. INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADCITIONAL NAME(S)/INITIAL(S) Schmidt SUFFIx Mark 1c. MAILING ADDRESS D. CITY STATE POSTAL CODE COUNTRY 800 Park Offices Drive, Suite 3209 Research Triangle Park NC 27709 USA 2. DEBTOR'S NAME: Provide only gne Debtor name (2a or 2b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's name will not fit in line 2b, leave all of Item 2 blank, check here and provide the Individual Debtor information In Item 10 of the Financing Statement Addendum (For UCC1Ad) 2a. ORGANIZATION'S NAME Cyberlux Corporation OR 2b. INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADDITIONAL NAME(S)/INITIAL(S) SUFFIX 2c. MAILING ADDRESS CITY STATE POSTAL CODE COUNTRY 800 Park Offices Drive, Suite 3209 Research Triangle Park INC 27709 JUSA 3. SECURED PARTY'S NAME (or NAME of ASSIGNEE of ASSIGNOR SECURED PARTY): Provide only pne Secured Party name (3а or 3b) 3a ORGANIZATION'S NAME Atlantic Wave Holdings, LLC OR 36. INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADDITIONAL NAME(SM/INITIAL(S] | SUFFIX Эc. MAILING ADDRESS CITY STATE POSTAL CODE COUNTRY 11 S. 12th Street 4. COLLATERAL: This financing statement covers the following collateral: 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 instruments, limitation relating to drones), equipment, accounts, chattel paper, contractual rights, letter-of-credit rights, letters of credit, documents, deposit accounts, money, intellectual property (including without limitation relating to drones), 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, (iii) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, proceeds relating to any of the foregoing property, (v) any and all goodwill relating to any of (iv) any and all insurance the foregoing property, and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Catalyst Machineworks, LIC. 5. Check only if appicable and check goly one box: Collateral Is held In a Trust (sae UCC1Ad, Hem 17 and Instructions) 6a. Check only if applicable and check only one box: being administered by a Decedent's Personal Representative Public-Finance Transaction 6b. Check only if applicable and check only one box: Manufactured-Home Transaction A Debtor is a Transmiting Utility Agricultural Lien • Non-UCC Fling 7. ALTERNATIVE DESIGNATION (If applicable): Lessee/Lessor Conalanee/Consignor Bailee/Bailor 8. OPTIONAL FILER REFERENCE DATA: L Licensee/Licensor FILING OFFICE COPY - UCC FINANCING STATEMENT (For UCC1) (Rev. 04/20/11) Intemational Association of Commercial Administrators (IACA)
claimallegation

California filingU 230074215520 is dated 20 October 2023, with 6:58 am filing time and 2028 lapse in the acknowledgment. Collateral specific

California filingU 230074215520 is dated 20 October 2023, with 6:58 am filing time and 2028 lapse in the acknowledgment. Collateral specifically includes tactical communications, Spectre H/M/V technology and Datron interests. Two acknowledgment pages repeat the same filing, not two separate liens.

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Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 68 of 145 PagelD# 2202 U230074215520 STATE OF CALIFORNIA Office of the Secretary of State EXHIBIT For Office Use Only -FILED- 1500 11th Street California Secretary of State Sacramento, California 95814 No.: U230074215520 (916) 653-3516 Date Filed: 10/20/2023 Submitter Information: Contact Name Eric M. Lemmer, Esq. Organization Name Arlington Law Group Phone Number (703) 842-3025 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 Richmona, 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, (i) any and all furniture, fixtures, attachments, accessions, accessories, fittings, tools, parts, supplies and commingled goods relating to any of the foregoing property, (iii) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, (iv) any and ali insurance proceeds relating to any of the foregoing property, (v) any and al goodwill relating to any of the foregoing property, Communications, Inc. and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Datron World 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
claimallegation

Virginia filing 20230706180859 shows 6 July 2023 9:03:16 am; Texas filing 23-0029383626 shows 6 July 2023 9:49 am. Broad drone/Catalyst coll

Virginia filing 20230706180859 shows 6 July 2023 9:03:16 am; Texas filing 23-0029383626 shows 6 July 2023 9:49 am. Broad drone/Catalyst collateral and SC additional-party forms accompany AW claims. Physical 76's Texas filing interrupts the reproduced amended-order page sequence.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 72 of 145 PagelD# EXHIBIT - 3 UCC FINANCING STATEMENT Office of the Clerk FOLLOW INSTRUCTIONS Virginla State Corporaton Commission A. NAME & PHONE OF CONTACT AT FILER (optional) Filing Number: 20230706180859 Filing Date and Time: 7/6/2023 9:03:16 AM Eric Moran Lemmer Total Number of Pages: 2 B. E-MAIL CONTACT AT FILER (optionał) (Document filed electronically) elemmer@arlingtonlawgroup.com C. SEND ACKNOWLEDGEMENT TO: (Name and Address) Eric Moran Lemmer 1739 Clarendon Boulevard Arlington, VA 22209 USA THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY 1. DEBTOR'S NAME: Provide only gne Debtor name (1a or 1b) luse exact full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's name will not fit in line 1b, leave all of Item 1 blank, check here i and provide the Individual Debtor Infomalion in Item 10 of the Financing Statement Addendum (For UCC1Ad) 1a. ORGANIZATION'S NAME OR Tb. INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADDITIONAL NAME(S)/INITIAL(S I SUFFIX Schmidt Mark D. 1c. MAILING ADDRESS CIY 800 Park Offices Drive Suite 3209 Research Triangle Park INC STATE ¡ POSTAL CODE 27709 COUNTRY USA 2. DEBTOR'S NAME: Provide only one Debtor name (2a or 2b) (uss exact, full name; do not omit, modify, or abbrevlate any part of the Debtor's name); if any part of the Individual Debtor's name will not fit in line 2b, leave all of item 2 blank, check hare f and provide the Individual Debtor information in Item 10 of the Financing Statement Addandum (For UCCIAd) 28, ORGANIZATION'S NAME Cyberlux Corporation OR 2b INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADDITIONAL NAME(SVINITIAL(S) | SUFFIX 800 Park Offices Drive Suite 3209 2c. MAILING ADDRESS CITY STATE POSTAL CODE COUNTRY Research Triangle Park INC 27709 JUSA 3. SECURED PARTY'S NAME (or NAME of ASSIGNEE of ASSIGNOR SECURED PARTY): Provide only one Secured Pany name (3a or 3b) 3a. ORGANIZATIONS NAME Atlantic Wave Holdings, LLC OR 3b, INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADDITIONAL NAME(SVINITIAL(S) SUFFIX 3c. MAILING ADDRESS CITY STATE POSTAL CODE COUNTRY 11 S. 12th Street Richmond IVA 23219 USA 4. COLLATERAL: This financing statement covers the following collalaral. 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 drones), 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 drones), general intangibles, accounts receivable and other rights to payment and performance, (li) any and all fumiture, fixtures. attachments, accessions, accessories, fittings, tools, parts, supplies and commingled goods relating to any of the foregoing prozeny. vij 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 Debter Cyberlux Corporation. all subsidiaries of such Debtor, including without limltation Catalyst Machineworks, LLC. 5. Check only if applicable and check only one box: Collateratis held in a Trust (sea UCC1Ad, item 17 and Instructions) baing administered by a Decedent's Personal Representellve 6b. Check only if applicable and chack only one box: Ba. Check only If applicable and check only one box: I Public-Finance Transaction Manufactured-Home Transaction A Debtor is a Transmitting Utility Agricultural Lien 7. ALTERNATIVE DESIGNATION (If applicable): Lessee/Lessor Consignee/Consignol Bailee/Bailor Licensee/Licensor 8. OPTIONAL FILER REFERENCE DATA: FILING OFFICE COPY - UCC FINANCING STATEMENT (Form UCC1) (Rev. 04/20/11)
claimallegation

The 2023 amended final order awards $1,572,500 jointly against Cyberlux/Schmidt, $177,126.19 fees, $3,895/$6,842.50 sanctions and 12% intere

The 2023 amended final order awards $1,572,500 jointly against Cyberlux/Schmidt, $177,126.19 fees, $3,895/$6,842.50 sanctions and 12% interest; records agreed lien and qualified nondischargeability terms; dismisses without prejudice. It bears a June 2023 entry and Schmidt/Watts seen-and-agreed signatures.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 75 of 145 PagelD# 2209 EXHIBIT VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF RICHMOND ATLANTIC WAVE HOLDINGS, LEC AND SECURE COMMUNITY, LLC Plaintiffs, Case No: CL22-3882 - 4 CYBERLUX CORPORATION and MARK D. SCHMIDT, individually Defendants. AMENDED FINAL ORDER AND JUDGEMENT BEFORE THE COURT is a Motion for Entry of an Amended Final Order and Judgment by Plaintiffs ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC, and agreed to by Defendants CYBERLUX CORPORATION and MARK D. SCHMIDT, individually, and as the authorized representative for CYBERLUX CORPORATION, and IT APPEARING to the Court that the parties hereto have reached a settlement agreement that resolves the current need for continuing litigation. UPON CONSIDERATION of the pleadings, the evidence, argument of counsel, the consent of the parties, and for good cause shown, it is hereby ORDERED, ADJUDGED, and DECREED that judgement is GRANTED in favor of Plaintiffs ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, and against Defendants CYBERLUX CORPORATION and MARK D. SCHMIDT, jointly and severally, as follows: a. The Court awards Plaintiffs the sum of ONE MILLION FIVE HUNDRED SEVENTY-TWO THOUSAND AND FIVE HUNDRED DOLLARS ($1,572,500) in compensatory damages, jointly and severally, against Defendants CYBERLUX CORPORATION
claimallegation

The 2 September 2025 receiver settlement resolves the stock dispute for $6 m plus $25,250.50, preserves stock rights and directs payment fro

The 2 September 2025 receiver settlement resolves the stock dispute for $6 m plus $25,250.50, preserves stock rights and directs payment from HII funds. Berleth acts for Cyberlux/Schmidt; releases/dismissal are tied to performance. Claimed lien continuity traces to 2023 rather than a new cash advance.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 79 of 145 PagelD# 2213 EXHIBIT tabbles SETTLEMENT AGREEMENT This Settlement Agreement (Agreement) is made and entered into on this the 2nd" day of September 2025 by and among Atlantic Wave Holdings, LLC (I AWHI), Secure Community, LLC ("SC'), Cyberlux Corporation ("Cyberlux"), and Mark D. Schmidt ("Schmidt") collectively referred to as the "Parties." RECITALS WHEREAS in Case No.: 2400-3910, Plaintiffs filed their Complaint on September 9, 2024. WHEREAS UCC liens were filed in the Commonwealth of Virginia and the States of North Carolina and Texas on July 6, 2023, specifically for the Drone receivables. WHEREAS case no.: 2400-3910 was brought as a result of the alleged breach by Defendants of a settlement agreement between the parties. The Settlement Agreement, among other things includes: A. The Recitals State: WHEREAS, the Porties to this Agreement have been told by Cyberlux for more than six (6) months that Cyberlux anticipates a significant cash flow connected with the sales of certain arone products. and: B. Paragraphs 4(b) and 4(c) state: Defendants agree to accelerate and pay the full outstanding balance of all stits owed under the consent Judgment up to a total of FIVE THOUSAND DOLLARS (S.5,000) per drone sold within twenty-one (21) days of Defendants, or any parent's, subsidiary's, affiliate is, or assign's first receipt of payment for any contract to purchase drone aircraft. WHEREAS the Settlement Agreement was intended to secure Judgment-Creditor's security interest in the HII MISSION TECHNOLOGIES CORP ("HII") drone contract receivables. WHEREAS the Settlement Agreement also required Judgment-Debtors to make the Cyberlux stock marketable by December 31, 2023. Judgment-Debtors have admitted within all their pleadings that they did not make the stock marketable (by removing the Caveat Emptor status) by December 31. 2023. WHEREAS Judgment-Debtors raise no meritorious defenses but instead admit their breach. WHEREAS the Honorable Michael Gomez, on May 22, 2025, appointed Robert B. Berleth of Berleth & Associates, the (the "Undersigned" and also the "Receiver") as the Receiver of Cyberlux Corporation and Mark D. Schmidt in a companion case pending in Harris County
claimallegation

The receiver settlement states 6% compound interest from all signatures, Virginia law and EDVA Richmond bench-trial forum and jury waiver, b

The receiver settlement states 6% compound interest from all signatures, Virginia law and EDVA Richmond bench-trial forum and jury waiver, breach fees and written notices. Welter signs for AW/SC; Berleth signs for Cyberlux/Schmidt with a notarial mark. These terms are distinct from later postjudgment interest wording.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 81 of 145 PagelD# 9. Settlement Agreement Final: The parties agree that this Agreement 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 ot. igation of Defendants. 10. Interest: Compounded interest shall accrue at the rate of 6% per annum from the date this agreement is signed by all parties until paid. This interest component is based on this Agreement and not judgment rate interest by statute. 11. Dispute Resolution: The Parties agree that any disputes arising from this Agreement shall be resolved through a bench trial, with all Parties waiving their rights to a jury trial. Any such action must be brought exclusively in the United States District Court for the Eastern District of Virginia, Richmond Division. 12. Governing Law: This Agreement shall be governed by and construed in accordance with the laws of the Commonwealth of Virginia. 13. Entire Agreement: This Agreement constitutes the entire agreement between the Parties with respect to the subject matter hereof. 14. Severability: If any provision of this Agreement is held to be invalid or unenforceable, the remaining provisions shall continue in full force and effect. 15. Counterparts: This Agreement may be executed in multiple counterparts, each of which shall be deemed an original. 16. Attorneys' Fees and Costs: If either Cyberlux or Mark D. Schmidt breaches the agreement, fails to pay pursuant to demand under Article 5, or seeks to set this Agreement aside, or seeks to render this Agreement unenforceable, AWH and SC shall be entitled to their attorneyẾees and costs incurred to enforce this Agreement, or any breach thereof. 17. Remedies for Breach. In the event of a breach of this Agreement, AWH and SC may seek all legal remedies, including, among others, damages, restitution, consequential damages and injunctive relief. 18. Successorship. This Agreement that the provisions hereof are binding upon the Parties, their employees, affiliates, agents, heirs, successors, and assigns forever. 19. Modification: This Agreement may only be amended by a written instrument executed by all Parties. 20. Waiver: No waiver of any provision of this Agreement shall be effective unless in writing and signed by the Party waiving the right. No waiver of any breach shall be deemed to be a waiver of any other or subsequent breach.
claimallegation

Exhibit 1 to the receiver settlement includes a proposed $6 m consent order with $25,250.50 fees and 6% postjudgment interest. Its judicial

Exhibit 1 to the receiver settlement includes a proposed $6 m consent order with $25,250.50 fees and 6% postjudgment interest. Its judicial entry date/signature are blank; it must not be classified as the entered 18 December order.

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Case 3:25-cv-00483-JAG Document 165-1 _ Filed 04/15/26 Page 84 of 145 PagelD# 2218 EXIBIT «1»
claimallegation

The actual consent final order follows the 16 December 2025 hearing and is entered 18 December 2025. It awards $6 m jointly plus $25,250.50

The actual consent final order follows the 16 December 2025 hearing and is entered 18 December 2025. It awards $6 m jointly plus $25,250.50 and 6% interest, dismisses with prejudice, and relies on receiver authority despite disputes. Quash is denied without ruling on defendants' standing to challenge notice or appellate rights.

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Case 3:25-cv-00483-JAG Document 165-1 • Filed 04/15/26 Page 88 of 145 PagelD# 2222 EXHIBIT E VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF RICHMOND ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC, Plaintiffs, Case No.: CL24-3910 CYBERLUX CORPORATION and MARK D. SCHMIDT, individually, Defendants. CONSENT FINAL ORDER On December 16, 2025, Plaintiffs Atlantic Wave Holdings, LLC and Secure Community, LLC and Defendants Cyberlux Corporation and Mark D. Schmidt, individually, by their Receiver, Robert W. Berleth, Esq. appeared by and through counsel before this Court on the Plaintiffs' Motion to Dissolve Stay and Enter Consent Order. Having considered the arguments and evidence presented, the Court makes the following ruling: It appearing that this matter has been previously visited by the court when Plaintiffs and the Receiver, on September 19, 2025, filed a Joint Motion for Entry of a Consent Order ("First Motionạ entered between Plaintiffs and the Receiver, on behalf of the Plaintiffs. The Defendants objected and the Court allowed the parties to brief the issues, after which the Court entered a written "Opinion and Order" dated October 30, 2025, ruling on the First Motion. As part of the October 30, 2025, order, the Court, among other things, ruled that the Settlement Agreement entered in CL22-3882 between Plaintiffs and Defendants was valid, and ' While the Receivership names Mark D. Schmidt, individually, as a Judgment Debtor, the Receiver has filed an Order in Texas, which has yet to be entered, removing Mark D. Schmidt; individually, from the terms of the Receivership Order in Texas.
claimallegation

The entered order recounts an earlier 30 October stay,4 November Texas abatement and 11 November reconsideration denial as changed circumsta

The entered order recounts an earlier 30 October stay,4 November Texas abatement and 11 November reconsideration denial as changed circumstances. A proposed removal of Schmidt from receivership had not been entered in Texas according to the order; this records the court's then-stated procedural basis.

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Case 3:25-cv-00483-JAG Document 165-1 • Filed 04/15/26 Page 88 of 145 PagelD# 2222 EXHIBIT E VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF RICHMOND ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC, Plaintiffs, Case No.: CL24-3910 CYBERLUX CORPORATION and MARK D. SCHMIDT, individually, Defendants. CONSENT FINAL ORDER On December 16, 2025, Plaintiffs Atlantic Wave Holdings, LLC and Secure Community, LLC and Defendants Cyberlux Corporation and Mark D. Schmidt, individually, by their Receiver, Robert W. Berleth, Esq. appeared by and through counsel before this Court on the Plaintiffs' Motion to Dissolve Stay and Enter Consent Order. Having considered the arguments and evidence presented, the Court makes the following ruling: It appearing that this matter has been previously visited by the court when Plaintiffs and the Receiver, on September 19, 2025, filed a Joint Motion for Entry of a Consent Order ("First Motionạ entered between Plaintiffs and the Receiver, on behalf of the Plaintiffs. The Defendants objected and the Court allowed the parties to brief the issues, after which the Court entered a written "Opinion and Order" dated October 30, 2025, ruling on the First Motion. As part of the October 30, 2025, order, the Court, among other things, ruled that the Settlement Agreement entered in CL22-3882 between Plaintiffs and Defendants was valid, and ' While the Receivership names Mark D. Schmidt, individually, as a Judgment Debtor, the Receiver has filed an Order in Texas, which has yet to be entered, removing Mark D. Schmidt; individually, from the terms of the Receivership Order in Texas.
claimallegation

Gonzalez reports Colorado suit filed 12 March 2025, service 14 March, no response, and a 29 August 2025 default judgment of $1,224,275.14: $

Gonzalez reports Colorado suit filed 12 March 2025, service 14 March, no response, and a 29 August 2025 default judgment of $1,224,275.14: $1,220,838.54 trebled damages, $2,765 fees and $671.60 costs. He identifies a certified copy obtained 19 December 2025.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 3 of 145 PagelD# 2137 Colorado Action (TAG 0021-26) is attached hereto as Exhibit 3. Although Cyberlux was properly served with the complaint in the Colorado Action on March 14, 2025, Cyberlux failed or refused to file an answer or otherwise respond to the complaint. 10. Accordingly, TAG moved for entry of default judgment against Cyberlux. 11. On August 29, 2025, that motion was granted and Final Judgment was entered against Cyberlux in the total amount of $1,224,275.14 (the "Final Judgment"), which consisted of treble damages in the amount of $1,220,838.54, attorneys' fees in the amount of $2,765.00, and costs in the amount of $671.60. A true and correct copy of the Final Judgment (TAG 0003-4) is attached hereto as Exhibit 4. 12. The Final Judgment was Certified on December 19, 2025 (the "Certified Final Judgmen_. A true and correct copy of the Certified Final Judgment (TAG 0001-2) is attached hereto as Exhibit 5. 13. As of the date of execution of this Declaration, HII and Cyberlux have not paid TAG the amounts owed pursuant to the Contract, the Judgments, or otherwise. 14. A true and correct copy of Legalist's Second Amended and Restated Government Purchase Order Financing Agreement including Instrument of Assignment (LEGALIST_000001-14) is attached hereto as Exhibit 6. 15. A true and correct copy of Legalist's Response to Interrogatory 1 is attached hereto as Exhibit 7. 16. A true and correct copy of Atlantic Wave/Secure Community's Response to Interrogatory 1 is attached hereto as Exhibit 8. 17. A true and correct copy of ANPC's Complaint (ANPC 7-12) is attached hereto as 3
claimallegation

The reconsideration order denies the 2 January 2026 motion, leaves the prior ruling standing, terminates suspension and dispenses with the 2

The reconsideration order denies the 2 January 2026 motion, leaves the prior ruling standing, terminates suspension and dispenses with the 24 February hearing. The own image of entry reads 2/5/2026, not the 2 February date elsewhere in the creditor response.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 93 of 145 PagelD# EXHIBIT Virginia: In the Circuit Court of the City of Richmond, Joh Alarshall Courts Failoing ATLANTIC WAVE HOLDINGS, LLC. AND SECURE COMMUNITY, LLC. Plaintiff, Case No. CL24-3910 CYBERLUX CORPORATION and MARK SCHIMIDT, individually Defendants, ORDER On January 2, 2026 Defendants Cyberlux Corporation and Mark D. Schimdt, by counsel, filed an "Emergency Motion to Reconsider and Vacate Consent Final Order and To Suspend Execution Pending the Court's Ruling." Plaintiffs' counsel for Atlantic Wave Holding, LLC, and Secure Community, LLC, subsequently filed a "Response in Opposition to Motion to Reconsider: »2 The Court DENIED Defendants' request to file a Reply. Upon reviewing the parties' current filings, the Court ORDERS that its prior ruling STANDS. Accordingly, the Court hereby DENIES Defendants' Motion to Reconsider and TERMINATES the suspension of the "Consent Final Order." The Court ORDERS the "Consent Final Order" effective as of the entry date of this Order. Pursuant to Rule 4;15(d) of the Supreme Court Rules of Virgina, the Court hereby DENIES the parties' request for a hearing, and further VACATES AND RELEASES the previously scheduled hearing set for February 24, 2026 at 9:00 a.m. The parties are released from their appearances. The Clerk is DIRECTED to forward a certified copy of this Order to the parties. ' Jimmy Robinson, Esq., representing the Defendants. 2 Charles Gavin, Esq., representing the Plaintiffs.
claimallegation

The May 2025 email thread distinguishes AW's lien/stock exposure from the Fairfax garnishment. Belote asks whether AW claims above the rough

The May 2025 email thread distinguishes AW's lien/stock exposure from the Fairfax garnishment. Belote asks whether AW claims above the roughly $1.44 m garnishment and about priority relative to Legalist; Walton answers yes and permits direct contact with Welter. Petersen initially supplies garnishment information; the clarification is not an agreed priority adjudication.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 95 of 145 PagelD# 2229 Case 3:25-cv-00483-JAG Document 1-6 Filed 06/24/25 Page 3 of 9 PagelD# 46 Just to clarify one more thing: does AW contend that its claimed security interest in the accounts receivable of Cyberlux has priority over the claimed security interest of Legalist in Cyberlux's accounts receivable? Clark J. Belote EXIBIT Kaufman & Canoles, P.C. clark.belote@kaufcan.com T. (757) 624.3109 KC F. (888) 360.9092 150 W. Main Street, Suite 2100 Norfolk, VA 23510 KAUFMANS CANOLES www.kaufCAN.com Linkedin From: David A. Walton <dwalton@bellnunnally.com> Sent: Monday, May 19, 2025 9:56 AM To: Belote, Clark J. <clark.belote@kaufcan.com; wil|welter@aol.com Cc: David M. Keithly <dkeithlv@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott <sfreling@cov.com>; Chap Petersen <jcp@petersenfirm.com> Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds Clark: Please feel free to further discuss this issue with Will Welter, copied on this email. You are authorized to speak with him directly, as needed. Put simply, yes, Atlantic Wave's position is it has a security interest in debts or claims against Cyberlux over and above the $1.44mm on the face of the garnishment summons. The settlement agreement between Cyberlux and Atlantic Wave provides for more than just the actual amount owed under the Amended Final Order and Judgment, for example, it provides Atlantic Wave the right to repayment of attorneys' fees and costs in any action caused by a breach of the settlement agreement, and damages associated with the failure to bring Cyberlux's stock to Pink Current status and to remedy the caveat emptor classification on such stock. Moreover, the settlement agreement explicitly provides: "Defendants [Cyberlux & Schmidt] agree and grant to Plaintiff [Atlantic Wave & Secure Community] a full security interest and lien interest in all of Defendants assets, including but not limited to IP, subsidiaries, contractual rights, accounts receivables, drone sales, etc., which may, in Plaintiff's sole discretion, be memorialized through the filing of UCC-1 forms and Liens." Atlantic Wave contends that Cyberlux has defaulted on the settlement agreement in several respects as set forth in prior communications and filings, which permits Atlantic Wave to enforce the security interest (authorized by the settlement agreement) against Cyberlux on the collateral or assets described in the UCC-1 forms. Attached are those UCC-1 forms that were filed in Virginia, Texas, and North Carolina. Please feel free to call me at your convenience to discuss. Take care, David David A. Walton Partner IN BELLNUNNALLY
claimallegation

Walton's 24 April 2025 letter urges HII to retain funds pending creditor conflicts. It asserts at least $912,000 judgment balance, $592,000

Walton's 24 April 2025 letter urges HII to retain funds pending creditor conflicts. It asserts at least $912,000 judgment balance, $592,000 fees and $6,017,250 stock exposure based on 195 m shares and a quoted price; these earlier figures are not the later $6 m judgment or current balances.

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Case 3:25-cv-00483-JAG Document 165-1 • Filed 04/15/26 Page 100 of 145 PagelD# 2234 BIN BELLNUNNALLY David A. Walton TEL: 214.740.1445 FAX: 214.740.5745 DWALTON@BELLNUNNALLY.COM April 24, 2025 VIA EMAIL (clark.belote@kaufcan.com) Clark J. Belote Kaufman & Canoles, P.C. 150 W. Main Street, Suite 2100 Norfolk, VA 23510 RE: Claims to funds held or to be held on behalf of or for the benefit of Cyberlux Corporation. Dear Mr. Belote: This letter serves as formal notice to Huntington Ingalls Industries and HII Mission Technologies Corp. (collectively HII) as to Atlantic Wave Holdings, LLC (Atlantic Wave)'s claims to funds held or to be held by HII on behalf of or for the benefit of Cyberlux Corporation (Cyberlux). Upon information and belief, "Cyberlux has asserted entitlement to payment" from HII pursuant to Subcontract No. P000043846, dated August 29, 2023, HII's Prime Task Order 47QFCA22F0039, and Technical Direction Letter 1-023, as set forth in the Modification No. 4 to Subcontract No. P000043846 to Effectuate a Termination Settlement, effective as of February 26, 2025, by and between HII and Cyberlux. Atlantic Wave hereby asserts it is an interested stakeholder in any payment due and owed to Cyberlux by HII because Cyberlux has not satisfied debts due and owed to Atlantic Wave, in whole or in part, under a valid and enforceable judgment, writ of garnishment, or lien: 1. On June 28, 2023, a Virginia state court signed the Amended Final Order and Judgment against Cyberlux (and Mark D. Schmidt) in Case No. CL22-3882, in the Circuit Court of the City of Richmond, Virginia. The Amended Final Order and Judgment has since been domesticated in California state court in January of 2024 and in Texas state court in July of 2024. The outstanding balance due and owed under the Amended Final Order and Judgment is, at minimum, $912,000, after accounting for any prior payments, credits, or offsets. The Amended Final Order and Judgment, as agreed to by Cyberlux, also provides that "the parties have agreed to a security interest and lien interest in all property of Defendants [Cyberlux and Mark D. Schmidt] in favor of
claimallegation

Walton's letter also lists TAG $365,049.42, Legalist $7,313,627.17 plus $4,364.46 daily, Aerotek $204,705.45 and RB Capital $5,686,960, asse

Walton's letter also lists TAG $365,049.42, Legalist $7,313,627.17 plus $4,364.46 daily, Aerotek $204,705.45 and RB Capital $5,686,960, asserting other claims above $13.5 m. These are counsel's dated descriptions, not verified sums due or independent corroboration of each creditor.

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Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 101 of 145 PagelD# 2235 CLARK J. BELOTE KAUFMAN & CANOLES, P.C. APRIL 24, 2025 PAGEZ OF4 Plaintiffs [Atlantic Wave and Secure Community, LLC] 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." On July 6, 2023, Atlantic Wave filed a UCC Financing Statement (Form UCC1) with the Virginia State Corporation Commission, Office of the Clerk, to perfect Atlantic Wave's security interest in certain collateral of Cyberlux, including but not limited to "money... [and] accounts receivable and other rights to payment and performance." On October 24, 2024, HII filed an Answer to writ of garnishment issued at the request of Atlantic Wave in Case No. CL22-3882-15, in the Circuit Court of the City of Richmond, Virginia, stating itỗ¿s withholding any payment which is or may become due and owing to Cyberlux... pending further order and/or direction of the Court." On June 15, 2023, Atlantic Wave and Cyberlux entered into a Settlement Agreement in Case No. CL22-3882, in the Circuit Court of the City of Richmond, Virginia, wherein Cyberlux agreed to be "responsible for the payment of [Atlantic Wave's] attorneys' fees and costs in any action caused by the breach of this [Settlement] Agreement." As of April 24, 2025, the attorneys' fees and costs incurred by Atlantic Wave caused by Cyberlux's breach of the Settlement Agreement is well in excess of $592,000, and attorneys' fees and costs continue to accrue as a result of Cyberlux's wrongful conduct. Pursuant to the Settlement Agreement, Cyberlux was contractually obligated, among other obligations, to bring its stock to Pink Current status and to remedy the caveat emptor classification on such stock by December 31, 2023, or be subject to additional liability and damages to Atlantic Wave. Cyberlux did not comply with its contractual obligation, which is now the subject of Case No. CL24-3910, in the Circuit Court of the City of Richmond, Virginia. The damages caused by Cyberlux's wrongful conduct is in excess of $6,017,250 (calculated based on a 20-day rolling average share price of $.0308577 for 195,000,000 shares). Based on the foregoing judgment, security interest, and claims, among others, Atlantic Wave contends it is currently owed in excess of $7,774,000, and further contends
claimallegation

ANPC's attached verified complaint describes Cyberlux as Nevada-incorporated and alleges equipment/services including two tactical landing s

ANPC's attached verified complaint describes Cyberlux as Nevada-incorporated and alleges equipment/services including two tactical landing systems, guidance systems, trailer, documents and spares. It says the first three of five milestones were paid and final milestones totalled $2,830,050 on 20 December 2024.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 105 of 145 PagelD# 2239 25CV005686-310 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF DURHAM 25-CVS-_ Advanced Navigation & Positioning Corporation Plaintiff, -V- VERIFIED COMPLAINT Cyberlux Corporation Defendant. Plaintiff, complaining of the Defendant, alleges: PARTIES The Plaintiff Advanced Navigation & Positioning Corporation, ('Plaintiff" or "ANPC") is a Delaware corporation in good standing with a legal existence and the capacity to sue, with its principal place of business located at 489 North 8th Street, Suite 203, Hood River, Oregon, 97031. 2. Upon information and belief, Cyberlux Corporation (*Defendant or "Cyberlux") is a Nevada corporation with its principal place of business in Durham County located at 800 Park Offices Drive, Suite 3209 Research Triangle, North Carolina, 27709 and can be served with process upon its registered agent, CT Corporation System, located at 160 Mine Lake Ct Ste 200, Raleigh, North Carolina 27615. 3. This Court has jurisdiction over the parties to this action pursuant to N.C. General Statute §1-75.4 and other applicable bases for jurisdiction. Venue is proper pursuant to N.C. General Statute §1-82 and other applicable bases for venue. PR Electronically Filed Date: 6/5/2025 4:37 PM Durham Superior Court County Clerk of Superior ANPC_00007
claimallegation

ANPC alleges the customer had paid Cyberlux by 20 December and the sum became due 30 December; a 15 May demand was unfulfilled. It seeks $2,

ANPC alleges the customer had paid Cyberlux by 20 December and the sum became due 30 December; a 15 May demand was unfulfilled. It seeks $2,926,814.39 including $96,764.39 interest at 8%. This attachment is a complaint, not the later judgment.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 107 of 145 PagelD# 2241 14. Pursuant to the Purchase Agreement, Cyberlux was required to pay the Final Invoice within ten days business days of Cyberlux's receipt of payment from Cyberlux's customer. 15. Upon information and belief, Cyberlux had received payment from Cyberlux's customer as of December 20, 2024 sufficient to pay the Final Invoice by December 30, 2024. 16. Cyberlux breached the Purchase Agreement when it failed to make a payment on the Final Invoice on or before December 30, 2024. 17. According to the Purchase Agreement, all disputes arising under the Purchase Agreement must be initially referred to the parties' senior management for resolution. The parties agreed to wait fourteen calendar days following referral to senior management before bringing to court any action arising out of or related to the Purchase Agreement. 18. Upon Cyberlux's failure to pay the Final Invoice in a timely manner, ANPC, by and through its attorney, gave notice to the Buyer's CEO of Cyberlux's failure to make timely payments on May 15, 2025 (the "Payment Dispute Letter"). 19. The Payment Dispute Letter was sent to Cyberlux's CEO via Federal Express and email. 20. As of the date of this Verified Complaint, Cyberlux has not responded to the Payment Dispute Letter. 21. It has been more than fourteen days since ANPC sent the Payment Dispute Letter to Cyberlux. CLAIM FOR RELIEF (Breach of Contract-Purchase Agreement) 22. ANPC incorporates the prior allegations of the Complaint by reference. 23. The Purchase Agreement is a valid and enforceable contract. 24. ANPC has performed all of its obligations under the Purchase Agreement. 3 ANPC_00009
claimallegation

CFO Tim Arbogast verifies the ANPC complaint before an Oregon notary on 5 June 2025 on personal knowledge except matters stated on informati

CFO Tim Arbogast verifies the ANPC complaint before an Oregon notary on 5 June 2025 on personal knowledge except matters stated on information and belief, which he believes true. The visual qualification is preserved; it is not an unqualified firsthand attestation to every allegation.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 110 of 145 PagelD# VERIFICATION Tim Arbogast, being first duly sworn, deposes and says that he is the CFO of Advanced Navigation and Positioning Corporation, a Delaware corporation, and, as such, he is authorized to make this oath; that he has read the foregoing and attached Verified Complaint, and that the same is true of his own personal knowledge except those matters Advanced Navigation and Positioning Corporation OFFICIAL STAMP Emily Joyce NOTARY PUBLIC - OREGON By: Tim Arbogast ›, CFO STATE OF COUNTY OF Personally appeared before me, Tim Arbogast, either being personally known to me or proven by satisfactory evidence (said-evidence being ), and acknowledged that he signed the foregoing document. This the 5 _day of June → 2025. OFFICIAL STAMP Notary Publid, MI уБоусе Emily Joyce NOTARY PUBLIC - OREGON (Type or Print Name) MY COMMISSION EXPIRES MAY 13, 2029 COMMISSION NO. 1058184 My commission expires: May 13,2029 (Notary Seal) 6 ANPC_00012 [Own-image correction: verification is on personal knowledge except those matters stated upon information and belief, which he believes to be true. Tim Arbogast signed before Oregon notary Emily Joyce on5 June2025.]
claimallegation

ANPC's 9 March 2026 response claims $3,087,878.86 and reports a 21 July 2025 judgment of $2,926,814.39,24 September fieri facias and 8 Octob

ANPC's 9 March 2026 response claims $3,087,878.86 and reports a 21 July 2025 judgment of $2,926,814.39,24 September fieri facias and 8 October garnishment of HII. It asserts equitable assignment of receipts allegedly spent on other programmes; the judgment and writ originals are not attached within Exhibit 10.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 112 of 145 PagelD# 2246 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION Case No. 3:25-cv-00483-JAG HII MISSION TECHNOLOGIES CORP., Plaintiff, V. ADVANCED NAVIGATION & POSITIONING CORPORATION'S CYBERLUX CORPORATION, et al., RESPONSE TO INTERROGATORIES Defendants. INTERPLEADER DEFENDANT ADVANCED NAVIGATION & POSITIONING CORPORATION'S RESPONSE TO INTERROGATORIES Pursuant Rules 26, 33 and 34 of the Federal Rules of Civil Procedure, and the Joint Discovery Plan entered in this case by order dated February 19, 2026 (Doc. 149) (the "Order"), Interpleader Defendant Advanced Navigation & Positioning Corporation ("ANPC"), by and through undersigned counsel, submits the following response to the interrogatory set out in Section 6(a) of the Order: Preliminary Statement To the best of ANPC's knowledge, information and belief, formed after reasonable inquiry, this response is complete and correct as of the date of this document. ANPC reserves the right to amend or supplement this response. ANPC also reserves the right to reference, discover or offer into evidence at the time of trial any and all facts, documents and things notwithstanding the initial response. INTERROGATORY 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) the amount of the proceeds that you claim; (b) the legal basis for your right to the proceeds; (c) how the amount you claim became a liquidated amount
claimallegation

ANPC claims priority 24 September 2025 or 30 December 2024 under its equitable-assignment theory, interest of $257,828.86 and no attorney fe

ANPC claims priority 24 September 2025 or 30 December 2024 under its equitable-assignment theory, interest of $257,828.86 and no attorney fees. It characterises unpaid delivery as an effective 30 December advance, not a documented cash loan. The response's interest discussion needs reconciliation with its stated judgment and principal.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 114 of 145 PagelD# 2248 Judgment against Cyberlux, which Judgment was domesticated in Virginia and served as the basis for the Garnishment Summons issued to HII and Cyberlux. ANPC also claims an equitable lien on the proceeds, which claim is set out in ANPC's Supplemental Answer to HII's Amended Complaint. Specifically, Cyberlux assigned certain funds (the "Assigned Funds") to ANPC under the Purchase Agreement, which funds were to compensate ANPC for services and assets that ANPC provided to produce the products that Cyberlux then sold to its customer. Cyberlux did not provide the Assigned Funds to ANPC upon such Assigned Funds becoming due and owing and instead retained the Assigned Funds to serve other parties and produce other products. C. How the amount you claim became a liquidated amount or, if not liquidated, state so. ANPC's Claimed Amount became liquidated once the Durham County Superior Court entered the Judgment in favor of ANPC against Cyberlux in Advanced Navigation & Positioning Corporation vs. Cyberlux Corporation, 25-CVS-005686-310 on July 21, 2025, in the amount of $2,926,814.39, which has continued to accrue interest. d. Whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment. ANPC's security interest arose when ANPC filed the Writ of Fieri Facias on September 24,2025. ANPC additionally claims an equitable lien that arose, at the earliest, on December 30, 2024, when Cyberlux breached the Purchase Agreement by failing to pay ANPC the Assigned Funds pursuant to the final invoice dated as of December 20, 2024, payment for which was due under the Purchase Agreement by December 30, 2024. Because the equitable lien arose when
claimallegation

WeShield, Roman Investments, MAS as Rosewood assignee, and Sinensky reserve privilege, confidentiality, burden and supplementation objection

WeShield, Roman Investments, MAS as Rosewood assignee, and Sinensky reserve privilege, confidentiality, burden and supplementation objections. Introductory text says dollar figures as of 19 February 2026 while later text and calculations repeatedly use 9 March 2026; both date statements remain visible.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 119 of 145 PagelD# 2253 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Civil Action No. 3:25-cv-483-JAG Interpleader Plaintiff, V. CYBERLUX CORPORATION, ATLANTIC WAVE HOLDINGS, LLC, SECURE COMMUNITY, LLC, LEGALIST SPV III, L.P., UNITED STATES OF AMERICA, ADVANCED NAVIGATION AND POSITIONING CORPORATION, ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, and MICHAEL SINENSKY, And ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation, Interpleader Defendants/Claimants. JOINT RESPONSES OF INTERVENORS ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, AND MICHAEL SINENSKY TO INTERROGATORY REGARDING NATURE OF CLAIM TO INTERPLEADER PROCEEDS Pursuant to the Court's Order and the applicable Federal Rules of Civil Procedure, Intervenors Assure Global LLC d/b/a WeShield ("WeShield"), Roman Investments PR LLC ("Roman Investments"), MAS USA MGT LLC ("MAS") (as assignee of Rosewood Theater LLC), and Michael Sinensky ("Sinensky") (collectively, "Respondents"), by and through undersigned 1
claimallegation

Gonzalez identifies fourteen exhibits, executes the declaration under penalty of perjury on 14 April 2026, and counsel certifies service on

Gonzalez identifies fourteen exhibits, executes the declaration under penalty of perjury on 14 April 2026, and counsel certifies service on 15 April. His authentication of attached copies does not turn the opposing creditors' contentions into personal knowledge of their underlying transactions.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 3 of 145 PagelD# 2137 Colorado Action (TAG 0021-26) is attached hereto as Exhibit 3. Although Cyberlux was properly served with the complaint in the Colorado Action on March 14, 2025, Cyberlux failed or refused to file an answer or otherwise respond to the complaint. 10. Accordingly, TAG moved for entry of default judgment against Cyberlux. 11. On August 29, 2025, that motion was granted and Final Judgment was entered against Cyberlux in the total amount of $1,224,275.14 (the "Final Judgment"), which consisted of treble damages in the amount of $1,220,838.54, attorneys' fees in the amount of $2,765.00, and costs in the amount of $671.60. A true and correct copy of the Final Judgment (TAG 0003-4) is attached hereto as Exhibit 4. 12. The Final Judgment was Certified on December 19, 2025 (the "Certified Final Judgmen_. A true and correct copy of the Certified Final Judgment (TAG 0001-2) is attached hereto as Exhibit 5. 13. As of the date of execution of this Declaration, HII and Cyberlux have not paid TAG the amounts owed pursuant to the Contract, the Judgments, or otherwise. 14. A true and correct copy of Legalist's Second Amended and Restated Government Purchase Order Financing Agreement including Instrument of Assignment (LEGALIST_000001-14) is attached hereto as Exhibit 6. 15. A true and correct copy of Legalist's Response to Interrogatory 1 is attached hereto as Exhibit 7. 16. A true and correct copy of Atlantic Wave/Secure Community's Response to Interrogatory 1 is attached hereto as Exhibit 8. 17. A true and correct copy of ANPC's Complaint (ANPC 7-12) is attached hereto as 3
claimallegation

The group claims WeShield $3,905,541.64 ($2,916,760 principal/$988,781.64 interest), Roman $576,436.03 ($430,497.41/$145,938.62), MAS $215,0

The group claims WeShield $3,905,541.64 ($2,916,760 principal/$988,781.64 interest), Roman $576,436.03 ($430,497.41/$145,938.62), MAS $215,062.95 ($160,614.60/$54,448.35) and Sinensky $310,097.79 ($231,589.09/$78,508.70), stated through 9 March 2026.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 122 of 145 PagelD# 2256 you claim; (b) the legal basis for your right to the proceeds; (c) how the amount you claim became a liquidated amount or, if not liquidated, state so; (d) whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment; (e) whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any; (f) whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim; and (g) for any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed. RESPONSE TO SUB-PART (a): Amount of Proceeds Claimed. In addition, Respondents object to this sub-part to the extent it requires a final, fixed statement of amounts claimed, as interest continues to accrue daily and the total amounts owed will increase until the interpleaded funds are distributed. Subject to and without waiving this objection and the General Objections, Respondents respond as tollows. • WeShield: $3,905,541.64, consisting of $2,916,760.00 in principal and $988,781.64 in accrued interest through March 9, 2026. • Roman Investments PR LLC: $576,436.03, consisting of $430,497.41 in principal and $145,938.62 in accrued interest through March 9, 2026. • MAS USA MGT LLC: $215,062.95, consisting of $160,614.60 in principal and $54,448.35 in accrued interest through March 9, 2026. • Michael Sinensky: $310,097.79, consisting of $231,589.09 in principal and $78,508.70 in accrued interest through March 9, 2026.
claimallegation

WeShield attributes the Ukrainian drone opportunity to its 12 July 2022 exclusive development agreement, founders' charity work and introduc

WeShield attributes the Ukrainian drone opportunity to its 12 July 2022 exclusive development agreement, founders' charity work and introductions. It says 4 April 2025 settlement compromised commissions to $2.5 m plus 240 m restricted shares, Cyberlux failed to pay, and liquidated damages followed. Underlying confidential agreements are cited but absent from this response.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 123 of 145 PagelD# 2257 RESPONSE TO SUB-PART (b): Legal Basis for Right to Proceeds. Respondents object to this sub-part to the extent it calls for a complete recitation of all legal theories, arguments, and supporting facts, which would be more appropriately addressed through briefing on the merits. Respondents further object to the extent this sub-part seeks information protected by the attorney-client privilege or work product doctrine regarding counsel's legal analysis and litigation strategy. Respondents also object to this sub-part as premature to the extent it calls for legal contentions before the completion of fact discovery. Subject to and without waiving these objections and the General Objections, Respondents respond as follows. WeShield's claim to the interpleaded proceeds is rooted directly in the work it performed that generated the very contract from which those proceeds flow. The Letter Agreement dated July 12, 2022 between Cyberlux Corporation and WeShield' formally engaged WeShield as Cyberlux's exclusive business development partner for Ukrainian government and Ministry of Defense drone contracts. Under that agreement, Cyberlux expressly committed to compensate WeShield for its role in originating and developing the opportunity. WeShield was not a passive participant. At the time that Cyberlux was seeking business partners to help sell products in Ukraine, WeShield's founders, Roman Vintfeld and Michael Sinensky, were actively working in the region through their charity, Worldwide Friends. In fact, both WeShield and its founders all received separate commendations for their work in Ukraine. (AGWS000015-AGWS000017.) WeShield arranged meetings, demonstrations and other connections for Cyberlux in Ukraine. • The Letter Agreement includes confidentiality clauses that prevent it from being produced without a Protective Order. 5
claimallegation

The group reports 11 August 2025 confessions of judgment and a later security agreement. Remaining claims derive from 26 August 2022 stock p

The group reports 11 August 2025 confessions of judgment and a later security agreement. Remaining claims derive from 26 August 2022 stock purchases and 29 October/1 November notes, with 4 April 2025 Rosewood-to-MAS assignment and Roman-to-Sinensky allocations; these are attributed tracing claims, not reproduced transfer instruments.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 124 of 145 PagelD# 2258 The HII subcontract proceeds now at issue in this interpleader, arising from Subcontract No. P000043846 and the Modification Agreement with Huntington Ingalls Industries, Inc. (HII), represent the downstream revenue generated from the Ukrainian drone program that WeShield originated and developed. Cyberlux acknowledged WeShield's role and its obligations in the Agreement of Compromise and Settlement dated April 4, 2025 (the "Settlement Agreement").2 Pursuant to the Settlement Agreement, Cyberlux agreed to pay WeShield $2,500,000.00 plus 240,000,000 shares of restricted common stock as full settlement of all obligations under the Letter Agreement (Settlement Agreement, Section 4). That settlement amount represented a material reduction from the commission WeShield would have been entitled to under the Letter Agreement's commission structure had the full value of the Ukrainian contracts been realized. WeShield accepted this compromised sum in resolution of all disputes under the Letter Agreement. Cyberlux failed to pay. The Settlement Agreement's liquidated damages provision (Section 12) then began to compound Cyberlux's liability. Despite communications regarding the status of payments and assurances, Cyberlux has not paid the amounts due to this date. (AGWS000018- AGWS000025.) On August 11, 2025, Cyberlux confessed judgment in favor of each Respondent in the Superior Court for Durham County, North Carolina. (Confessions of Judgement, AGWS000007- AGWS000014.). Thereafter, Cyberlux and all Respondents entered into a Security Agreement granting each Respondent a perfected security interest in all of Cyberlux's accounts receivable under Subcontract No. P000043846, the very HII proceeds now interpleaded. (Security 2 The Settlement Agreement includes confidentiality clauses that prevent it from being produced without a Protective Order. 6
claimallegation

The group says 24 September 2025 security secured HII subcontractP 000043846 receivables and broad collateral;23 October 2025 Nevada 2025517

The group says 24 September 2025 security secured HII subcontractP 000043846 receivables and broad collateral;23 October 2025 Nevada 2025517121-6 and NC 20250156500 H filings establish its claimed priority. It expressly reserves the court's priority determination and identifies 0.3% per business day interest.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 126 of 145 PagelD# 2260 RESPONSE TO SUB-PART (c): Liquidation of Amount. Respondents object to this sub-part to the extent it calls for a definitive, static statement of a liquidated amount when the obligations accrue interest daily and the final amount distributable to Respondents will depend on the Court's priority rulings and the total amount of interpleaded funds available. Subject to and without waiving this objection and the General Objections, Respondents respond as follows. Subject to the foregoing objections, the amounts claimed are liquidated. The Settlement Agreement fixed Cyberlux's payment obligations to each Respondent with specificity. Section 12 of the Settlement Agreement includes a liquidated damages formula, and the Security Agreement dated September 24, 2025 separately reflects the then-outstanding principal balances owed to each Respondent based on that formula. The Security Agreement also provides for continuing interest at 0.3% per business day. The figures in subpart (a) are calculated through March 9, 2026 using the 0.3% per business day rate under the Security Agreement. Because interest continues to accrue, the total amounts due will increase until paid. RESPONSE TO SUB-PART (d): Security Interest; Priority Date; Basis. Respondents object to this sub-part to the extent it calls for a legal conclusion regarding the validity, perfection, or priority of Respondents' security interest relative to those of other claimants, which is a legal determination to be made by the Court. Respondents further object to this sub-part as premature to the extent it calls for a final priority determination before all relevant priority evidence has been developed in discovery. Subject to and without waiving these objections and the General Objections, Respondents respond as follows.
claimallegation

The group claims continuing 0.3% business-day interest on identified principal but no separate attorney fees, saying the interest covers rec

The group claims continuing 0.3% business-day interest on identified principal but no separate attorney fees, saying the interest covers recovery costs. WeShield's contribution is services/commissions, while other respondents' claims arise from investments. Counsel Marx signs 9 March 2026; no exact cash-advance schedule is supplied here.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 127 of 145 PagelD# 2261 Subject to the foregoing objections, cach Respondent claims a security interest in the interpleaded proceeds. On September 24, 2025, Cyberlux granted cach Respondent a security interest in all of Cyberlux's right, title, and interest in the Collateral, expressly defined to include "all accounts, including without limitation the accounts-receivable of Subcontract No. P000043846 payable by HII Mission Technologies Corp. or its predecessorạas well as chattel paper, commercial tort claims, deposit accounts, equipment, fixtures, general intangibles, goods, instruments, investment property, proceeds, cash and cash equivalents, and letter of credit rights (Security Agreement, AGWS000001, Section 2.1). A UCC-1 Financing Statement was filed with the Nevada Secretary of State on October 23, 2025, Filing No. 2025517121-6. (AGWS000004.) A UCC-1 Financing Statement was filed with the North Carolina Secretary of State also on October 23, 2025, Filing No. 20250156500H. (AGWS000006.) Respondents' claimed priority date is October 23, 2025, the date of UCC-1 filing. The legal basis is the Security Agreement and UCC Article 9 as adopted in Nevada and North Carolina. Respondents reserve all rights with respect to priority as against other claimants, which is a matter for the Court to determine. RESPONSE TO SUB-PART (e): Claim to Interest; Amount and Basis. Respondents object to this sub-part to the extent it calls for a final, fixed statement of interest accrued, as interest continues to accrue on a daily basis and cannot be definitively quantified until the interpleaded funds are distributed or the obligations are satisfied. Subject to and without waiving this objection and the General Objections, Respondents respond as follows. Subject to the foregoing objections, yes, each Respondent claims interest. As set forth in subpart (a), accrued interest through March 9, 2026 is: WeShield, $988,781.64; Roman Investments, $145,938.62; MAS USA MGT LLC, $54,448.35; and Michael Sinensky, $78,508.70. Interest continues to accrue at 0.3% per business day on the outstanding principal balance of each 9
claimallegation

Fairwinds claims $2,348,542 under 3 October 2022 teaming and 7 June 2023 service/supply agreements: prime role or 8% of first 1,000 drones i

Fairwinds claims $2,348,542 under 3 October 2022 teaming and 7 June 2023 service/supply agreements: prime role or 8% of first 1,000 drones if another prime chosen. It says Schmidt's 8 July 2025 invoice-backed spreadsheet acknowledged the amount and promised payment from remaining HII proceeds. These are Fairwinds' statements about Cyberlux's acknowledgement.

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Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 131 of 145 PagelD# 2265 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff CYBERLUX CORPORATION; Civil Action No: 3:25-cv-483-JAG ATLANTIC WAVE HOLDINGS, LLC; SECURE COMMUNITY, LLC; LEGALIST SPY III, LP; UNITED STATES OF AMERICA; ADVANCED NAVIGATION AND POSITIONING CORPORATION; and ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation, Interpleader Defendants/Claimants FAIRWINDS TECHNOLOGIES, LLC'S RESPONSE TO THE JOINT DISCOVERY PLAN INTERROGATORY AND DOCUMENT REQUESTS Now comes Interpleader Defendant/Claimant Fairwinds Technologies, LLC ("Fairwinds), who submits the following responses to the Interrogatory and Document Requests agreed to by all Parties in the Joint Discovery Plan [Doc. 147] filed with the Court on February 12, 2026, as follows: INTERROGATORY: Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) The amount of the proceeds that you claim. Response: Cyberlux owes Fairwinds $2,348,542.00. #111272386v1
claimallegation

Fairwinds says the sum became liquidated around 8 July 2025 and expressly answers none to security/lien/assignment, interest and attorney fe

Fairwinds says the sum became liquidated around 8 July 2025 and expressly answers none to security/lien/assignment, interest and attorney fees; secured-advance dates are not applicable. It cites Fairwinds 0001–0132, not appended here. Thomas Wirth verifies based on existing/discovered records subject to error, with counsel-assisted preparation.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 133 of 145 PagelD# 2267 Response: The amount was liquidated on or about July 8, 2025, when Cyberlux sent to Fairwinds a spreadsheet detailing the amount owed to Fairwinds on its commission based upon the total amount Cyberlux had invoiced HII. (d) Whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment. Response: None. (e) Whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any. Response: None. (f) Whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim. Response: None. (g) For any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed. Response: Not applicable. DOCUMENT REQUEST i: i. Documents supporting or otherwise concerning your answer to the above interrogatory. 3 #111272386v1
claimallegation

Berleth responds as Texas-appointed receiver, reserving privilege. He cannot quantify proceeds or final receiver fees because the Texas cour

Berleth responds as Texas-appointed receiver, reserving privilege. He cannot quantify proceeds or final receiver fees because the Texas court has not fixed them. His response proposes representing a consortium beyond the interpleader parties, rather than identifying an entered all-creditor expansion.

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Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 137 of 145 PagelD# 2271 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff, cos cos cos cos cos cos cos Civil Action No. 3:25-cv-00483-JAG CYBERLUX CORP., et al., Interpleader Defendants/Claimants. INTERPLEADER DEFENDANT'S, ROBERT W. BERLETH, AS RECEIVER, RESPONSES TO THE JOINT DISCOVERY PLAN DISCOVERY REQUESTS Interpleader Defendant/Claimant, Robert W. Berleth, as Receiver (the "Receiver), by counsel, hereby submits the following responses to the Joint Discovery Plan Order entered on February 19, 2026 [Doc. 149]. a. Interrogatory: Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) the amount of the proceeds that you claim; (b) the legal basis for your right to the proceeds; (c) how the amount you claim became a liquidated amount or, if not liquidated, state so; (d) whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment; (e) whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any; (f) whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim; and (g) for any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed OBJECTION: The Receiver objects to this interrogatory to subparts (a), (b), (d), (e), and (f) to the extent that they seek disclosure of legal theories, mental impressions, conclusions,
claimallegation

Receiver says an expanded receivership could settle about 20 litigations for several dozen creditors, conditional on Harris County approval.

Receiver says an expanded receivership could settle about 20 litigations for several dozen creditors, conditional on Harris County approval. He asserts possession of drones from as early as 16 January 2025, no later than 22 May, delivery to HII and resulting registry proceeds; those causal assertions remain his position.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 139 of 145 PagelD# 2273 The Receiver is diligently working with these several dozen creditors to bring a stipulated settlement agreement by the Consortium to the Court for the settlement conference, provided the Court in Harris County expands the Receivership. The stipulated agreement will contain a disbursement of the funds being held in the registry of the Court, and will satisfy some ~20 litigations pending across the country. The Receiver's claims are furthered by the agreement of the Consortium and proposed expansion order of the Receivership to include "all creditors." Secondly, the Receiver had actual physical possession of the drones and still possesses all remaining property of Cyberlux as early as January 16, 2025, but not later than May 22, 2025 to date. The drone assets were carefully inventoried by the Receiver and his staff, then delivered to HII by the Receiver for payment of the entire Corpus of funds from the federal government currently being held in the registry of the Court. The Order Appointing Receiver, pages 18-19, f 53 is instructive when determining the Receiver's fees and expenses. "Specifically, the Court may award the Receiver 33% of collected funds should the Receiver collect the full amount of judgmentằ_See Order Appointing Receiver, pages 18-19, 153. Receiver successfully collected the judgment and he is entitled to at least 25% and up to 33% of the total amounts collected, including, but not limited to, the Corpus interpleaded into the registry of the Court, and his expenses that are currently in excess of $550,000.00. Receiver is entitled to collect his fees and expenses that have not been ruled on by the 129TH District Court. Providing an amount of legal fees at this time is speculative and any amount stated in this sub-part is subject to change. Thusly, by a strict interpretation of the Order Appointing Receiver, the Receiver is therefore entitled 25% of the Corpus as his reasonable fees for work performed in the collection of the drones which have since been liquidated to the funds held by the Court's registry. 3
claimallegation

Receiver claims at least 25% and up to 33% of collected funds, expenses exceeding $550,000, and a judicial lien from 16 January 2025, invoki

Receiver claims at least 25% and up to 33% of collected funds, expenses exceeding $550,000, and a judicial lien from 16 January 2025, invoking quoted appointment-order provisions. He states fees/expenses have not been ruled on and claims no interest. Quoted discretionary may-award 33% language is distinct from his asserted entitlement to 25%.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 139 of 145 PagelD# 2273 The Receiver is diligently working with these several dozen creditors to bring a stipulated settlement agreement by the Consortium to the Court for the settlement conference, provided the Court in Harris County expands the Receivership. The stipulated agreement will contain a disbursement of the funds being held in the registry of the Court, and will satisfy some ~20 litigations pending across the country. The Receiver's claims are furthered by the agreement of the Consortium and proposed expansion order of the Receivership to include "all creditors." Secondly, the Receiver had actual physical possession of the drones and still possesses all remaining property of Cyberlux as early as January 16, 2025, but not later than May 22, 2025 to date. The drone assets were carefully inventoried by the Receiver and his staff, then delivered to HII by the Receiver for payment of the entire Corpus of funds from the federal government currently being held in the registry of the Court. The Order Appointing Receiver, pages 18-19, f 53 is instructive when determining the Receiver's fees and expenses. "Specifically, the Court may award the Receiver 33% of collected funds should the Receiver collect the full amount of judgmentằ_See Order Appointing Receiver, pages 18-19, 153. Receiver successfully collected the judgment and he is entitled to at least 25% and up to 33% of the total amounts collected, including, but not limited to, the Corpus interpleaded into the registry of the Court, and his expenses that are currently in excess of $550,000.00. Receiver is entitled to collect his fees and expenses that have not been ruled on by the 129TH District Court. Providing an amount of legal fees at this time is speculative and any amount stated in this sub-part is subject to change. Thusly, by a strict interpretation of the Order Appointing Receiver, the Receiver is therefore entitled 25% of the Corpus as his reasonable fees for work performed in the collection of the drones which have since been liquidated to the funds held by the Court's registry. 3
claimallegation

TAG quote dated 5 September 2023 prices 400 accelerated-production bags at $399 ($159,600), 1,700 at $379 ($644,300), and foam handling/inst

TAG quote dated 5 September 2023 prices 400 accelerated-production bags at $399 ($159,600), 1,700 at $379 ($644,300), and foam handling/installation for 2,100 at $40 ($84,000), totalling $887,900. The image shows a signature mark at acceptance, without a reliably identified signer.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 7 of 145 PagelD# 2141 QUOTE THIN AIR BEAR for the long haul 09-05-23 4196 Center Park Orive Thin Air Gear Mike Brown B16 896 5656 Cell Colorado Springs CO 80916 mikr@thinairgear com TO Catalyst Machineworks/Cyberlux SHIP TO: 6710 Spring Steubner Rd, Suite 709 Catalyst Machineworks/Cyberlux PMB 103 6710 Spring Steubner Rd, Suite 709 Spnng. TX 77389 PM8 103 Attn. Rick Tucker Spring, TX 77389 Attr: Rick Tucker to Days SHIPPING METHOD SHIPPING TERMS SHIPPING DATE PAYMENT TERMS DUE DATE Truck FOB: Colorado 13 10, Ne: 30 ASAP QTY ПТЕМ В DESCRIPTION UNIT PRICE DISCOUNT LINE TOTAL Wheeled Drone Kit Bag (Prototype/Sampie DRWTK OCP Approved) Acce crated Ramp Up Production 400 $399.00 5159,600.00 Units in 30 days From PO/Deposit Receipt 1,700 DRWTK-OCP Wheeled Drone Kit Bag (Prototype/Sample Standard Production - 200 Units Every Two Approved) $379.00 Weeks After Accelerated Production $644.300.00 Additional Assembly - Recelve Faam 2,100 Inserts; Store; Install; Ship Individual $40.00 Boxes on Pallets Standard Pallet Shipping Included Bags Only 1. Deposit Required to Release All Materials - $150,000.00 2. We will Invoice Per Shipment 3. Terms 1%-N10, N30 $84,000.00 4. Deposit Credit Will Be Applied to Last 400 Shipped and Invoiced DISCOUNT TOTAL SUBTOTAL $887,900.00 SALES TAX TOTAL $887,900.00 Estimated delivery times quoted above begin after recept of Purchase Order and $.130, 900.00 0 sit To accept this quotation, sign here and return to mike@thinalrgear. cor THANK YOU FOR YOUR BUSINESS! TAG-0005 [Own-image correction: deposit required $150,000.00; total $887,900.00. Acceptance line bears an unidentified signature mark.]
claimallegation

Receiver cites Berleth 0001–1328 as appointment/receivership production, with response and service 9 March 2026. This 145-page compilation d

Receiver cites Berleth 0001–1328 as appointment/receivership production, with response and service 9 March 2026. This 145-page compilation does not append that 1328-page production. Service list identifies creditor counsel; it supplies neither allowed claims nor consortium consent.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 140 of 145 PagelD# 2274 (c) The Receiver's claim is based upon the possession of the physical assets (drones) that have since been tendered to the federal government and liquidated as the corpus of funds currently being held in the registry of the Court. Some members of the Consortium have claims for component part claims. (d) Pursuant to the Order Appointing Receiver, at pg. 4, 10ithe Receiver will have a judicial lien on all non-exempt assets of Debtor. ... No one-not even a lien holder with a prior filed deed of trust-can sell property held in custodia legis by a duly appointed Receiver without first obtaining approval from the Court in which the Receivership is pending." Citing First Southern Properties, Inc. v. Vallone, 553 S.W. 2d 339, 343 (Tex. 1976). (e) The Receiver does not claim interest at this time. (f) The basis for a claim to attorneys' fees and costs is the damages incurred in the defense of this matter as the Court appointed receiver, which is a percentage of amounts recovered. (g) Receiver claims a secured interest by judicial lien as of January 16, 2025. b. Document Requests: 1. Documents supporting or otherwise concerning your answer to the above interrogatory. Response: Documents pertaining to Robert W. Berleth's appointment as receiver and documents related to the role as receiver for Cyberlux Corporation, in the Harris County 129TH District Court, Texas, are being produced. Responsive documents are produced herewith as Berleth_0001- Berleth_1328. 4
claimallegation

Exhibit 14 contains only printed page 1 of 8 of Modification 4, effective 26 February 2025, reproduced from TXSD 4:25-cv-01689 ECF 1-2. It r

Exhibit 14 contains only printed page 1 of 8 of Modification 4, effective 26 February 2025, reproduced from TXSD 4:25-cv-01689 ECF 1-2. It recites 29 August 2023 subcontract,22 December 2023 stop work, government termination 13 May 2024 and HII termination 17 May 2024 under section 32.1.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 145 of 145 PagelD# 2279 Case 4:25-ev-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9 CONFIDENTIAL INFORMATION Page 1 of 8 REDACTED Mission Technologies Modification No. 4 to Subcontract No. P000043846 To Effectuate a Terminotion Settlement This Modification No. 4 to Effectuate a Termination Settlement (the "Agreement"), effectiye as of February 26, 2025, is made by and between HII Mission Technologies Corp. ("HI"), a Delaware company with offices locatea at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (Cyberlux)y a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NÇ 27709 (each a "Party," and collectively, "the Parties"). WHEREAS, the Parties entered into Subcontract No. P000043846, doted Augyst 29, 2023 (the "Subcontract"). issued under HII's Prime Tosk Order 47QFCA22F0039 and Technical Direction Lefter 1-023 (ITDL 231) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the "Government"); WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HIl in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the SWO"); WHEREAS, the Government terminted the TDL 23 work scope Yor convenience on May 13, 2024, and HIl subsequently exercised the termintion provisions of Subcontract Section 32.1 on May 17, 2024; and WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement. NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties age as follows: 1. Review and Approval. a. The Parties acknowledge that pursuant to FAR 49.108-3, the Government expects HIl to submit a subcontractor settlementato The Government Contracting Officer tor review and opproval. Accordingly, the Porties agree thot Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement. Following execution of the Agreement, HIl will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereofter, HIl will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith, to gotain such approval. In furtherance of that effort, Cyberlux shall cooperate with any auditor other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract. 2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action. A division of HIl Issued by: Mission Technologies Commana Media HIl Proprietary
claimallegation

Modification 4 section 1 makes sections 3–6 effective/enforceable only upon government contracting-officer approval; HII undertakes submissi

Modification 4 section 1 makes sections 3–6 effective/enforceable only upon government contracting-officer approval; HII undertakes submission/notification and Cyberlux cooperation/access to books and records. Section 2 requires good-faith conferral before money-damages proceedings during review. Missing pages prevent this excerpt establishing the settlement amount, signatures, approval or complete obligations.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 145 of 145 PagelD# 2279 Case 4:25-ev-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9 CONFIDENTIAL INFORMATION Page 1 of 8 REDACTED Mission Technologies Modification No. 4 to Subcontract No. P000043846 To Effectuate a Terminotion Settlement This Modification No. 4 to Effectuate a Termination Settlement (the "Agreement"), effectiye as of February 26, 2025, is made by and between HII Mission Technologies Corp. ("HI"), a Delaware company with offices locatea at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (Cyberlux)y a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NÇ 27709 (each a "Party," and collectively, "the Parties"). WHEREAS, the Parties entered into Subcontract No. P000043846, doted Augyst 29, 2023 (the "Subcontract"). issued under HII's Prime Tosk Order 47QFCA22F0039 and Technical Direction Lefter 1-023 (ITDL 231) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the "Government"); WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HIl in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the SWO"); WHEREAS, the Government terminted the TDL 23 work scope Yor convenience on May 13, 2024, and HIl subsequently exercised the termintion provisions of Subcontract Section 32.1 on May 17, 2024; and WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement. NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties age as follows: 1. Review and Approval. a. The Parties acknowledge that pursuant to FAR 49.108-3, the Government expects HIl to submit a subcontractor settlementato The Government Contracting Officer tor review and opproval. Accordingly, the Porties agree thot Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement. Following execution of the Agreement, HIl will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereofter, HIl will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith, to gotain such approval. In furtherance of that effort, Cyberlux shall cooperate with any auditor other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract. 2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action. A division of HIl Issued by: Mission Technologies Commana Media HIl Proprietary
claimallegation

Quote requires a $150,000 deposit to release materials, invoices per shipment, 1%-10/Net 30 terms and deposit credit against the last 400 sh

Quote requires a $150,000 deposit to release materials, invoices per shipment, 1%-10/Net 30 terms and deposit credit against the last 400 shipped/invoiced. Initial 400 units are specified within 30 days of purchase order/deposit, then 200 every two weeks; delivery timing starts after order and deposit.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 7 of 145 PagelD# 2141 QUOTE THIN AIR BEAR for the long haul 09-05-23 4196 Center Park Orive Thin Air Gear Mike Brown B16 896 5656 Cell Colorado Springs CO 80916 mikr@thinairgear com TO Catalyst Machineworks/Cyberlux SHIP TO: 6710 Spring Steubner Rd, Suite 709 Catalyst Machineworks/Cyberlux PMB 103 6710 Spring Steubner Rd, Suite 709 Spnng. TX 77389 PM8 103 Attn. Rick Tucker Spring, TX 77389 Attr: Rick Tucker to Days SHIPPING METHOD SHIPPING TERMS SHIPPING DATE PAYMENT TERMS DUE DATE Truck FOB: Colorado 13 10, Ne: 30 ASAP QTY ПТЕМ В DESCRIPTION UNIT PRICE DISCOUNT LINE TOTAL Wheeled Drone Kit Bag (Prototype/Sampie DRWTK OCP Approved) Acce crated Ramp Up Production 400 $399.00 5159,600.00 Units in 30 days From PO/Deposit Receipt 1,700 DRWTK-OCP Wheeled Drone Kit Bag (Prototype/Sample Standard Production - 200 Units Every Two Approved) $379.00 Weeks After Accelerated Production $644.300.00 Additional Assembly - Recelve Faam 2,100 Inserts; Store; Install; Ship Individual $40.00 Boxes on Pallets Standard Pallet Shipping Included Bags Only 1. Deposit Required to Release All Materials - $150,000.00 2. We will Invoice Per Shipment 3. Terms 1%-N10, N30 $84,000.00 4. Deposit Credit Will Be Applied to Last 400 Shipped and Invoiced DISCOUNT TOTAL SUBTOTAL $887,900.00 SALES TAX TOTAL $887,900.00 Estimated delivery times quoted above begin after recept of Purchase Order and $.130, 900.00 0 sit To accept this quotation, sign here and return to mike@thinalrgear. cor THANK YOU FOR YOUR BUSINESS! TAG-0005 [Own-image correction: deposit required $150,000.00; total $887,900.00. Acceptance line bears an unidentified signature mark.]
claimallegation

Invoice 8110 dated 5 September 2023 bills Rick Tucker/Catalyst Machine Works $150,000 deposit for 2,100 bags, due 15 September on Net 10; pu

Invoice 8110 dated 5 September 2023 bills Rick Tucker/Catalyst Machine Works $150,000 deposit for 2,100 bags, due 15 September on Net 10; purchase-order field says verbal/email ATT. It prints a 1.5% monthly late fee. An invoice alone is not proof of receipt of funds.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 8 of 145 PagelD# 2142 Thin Alr Gear THIN AIR 4196 Center Park Drive Colorado Springs, CO 80916 SEAR for the long haul (719)302-0563 mike@thinairgear.com http://www.thinairgear.com INVOICE BILL TO SHIP TO INVOICE # 8110 Rick Tucker Rick Tucker DATE 09/05/2023 Catalyst Machine Works Catalyst Machine Works DUE DATE 09/15/2023 6710 Spring Steubner Rd, 21631 Ahodes Rd TERMS Net 10 Suite 709 Suite A105 PMB 103 Spring, TX 77389 USA Spring, TX 77389 USA PURCHASE ORDER Verbal/Email ATT DESCRIPTION OTY RATE AMOUNT DEPOSIT 150,000.00 150,000.00 DEPOSIT - 2,100 Drone Kit bag - Verbal/Email Purchase Order Banking Information: Account Holder: Thin Air Gear, LLC 4196 Center Park Drive Colarado Springs, CO 80916 Bank: First Bank 2 N Cascade Ave., Suite 130 Colorado Springs, CO 80903 ABA ROUNTING NUMBER: 107005047 ACCOUNT NUMBER: 219-120-8114 All Past Due Invoices will be sublect to a 1.5% late fee per month. BALANCE DUE $150,000.00 TAG-0006
otherattribution

Borrowers undertake segregated remittance of received eligible-order payments within one business day.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 25 of 145 PagelD# 2159 Docusign Envelope: ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 SECOND AMENDED AND RESTATED GOVERNMENT local tax requirements not later than the forty fifth (45th) PURCHASE ORDER FINANCING AGREEMENT day after the end of each calendar quarter) that Borrower This Second Amended and Restated Government Purchase Order keeps in the ordinary course of business in accordance Financing Agreement ("Agreement) is made effective as of accepted accounting principles March 27, 2024 by and between Legalist SPV III, LP ("Lender) consistently applied, and Borrower shall certify that all and Cyberlux Corporation and Datron World Communications, information contained therein is and shall be true and Inc. (each and together, "Borrower"). correct ("Quarterly Reporting Obligation). addition to any Quarterly Reporting Obligation, Lender hereby agrees to provide Borrower the services specified Borrower further agrees to provide Lender with a copy in this Agreement and establishes for a period extending one year of the Borrower's books and records otherwise due in from the date hereof (the "Facility Maturity Date") a revolving connection with any Quarterly Reporting Obligation line of credit for Borrower in the aggregate maximum principal promptly upon demand at any time upon reasonable amount of $7,000,000 (the "Credit Limit"). notice to Borrower. ACCOUNTS MANAGEMENT By or before fifteen (15) days after the last business day Borrower shall, before execution of any agreement with of each month, Lender shall provide to Borrower a monthly report a government-related customer (including any prime contractor to (each a 'Loan Report") detailing the current state of Borrower's such a customer) (each, a "Government Account Debtor") in account with Lender based upon documentation then provided by connection with which Borrower desires Lender to provide Borrower to Lender, including balance, individual transactions, financing under this Agreement, provide to Lender the then-available loan amount under the Credit Limit, and related Government Account Debtor's contact information, material information. Borrower shall notify Lender within five (S) days of evidencing any contract with the Goverment Account Debtor, delivery if it disputes any part of a Loan Report. The Loan Report and other information that may be requested. Lender may conduct shall be deemed correct and binding upon Borrower and shall due diligence of such Government Account Debtor. Lender may constitute an account stated between the parties hereto unless establish or modify a maximum credit limit for any Government Lender receives Borrower's written statement of exceptions Account Debtor, without waiving its right at any subsequent time within five (5) days after Borrower's receipt of same. to terminate or modify any prior acceptance. Borrower agrees that all invoices to Government 2. Borrower shall provide to Lender by or before fifteen Account Debtors shall designate Borrower as the sole named (15) days after the last business day of each month: payee together with the following wiring instructions (as Borrower may update from time to time): a. Details of all obligations (including, but not limited to, invoices, aging reports, and related information) of Bank: Silicon Valley Bank Government Account Debtors; Account Name: Legalist SPV III, LP Account No: I b. Details of all accounts payable obligations of Borrower ABA No: relating thereto; Borrower further agrees that all payments made c. A completed Borrowing Base Certificate in the form hereunder shall be made pursuant to the foregoing wire attached as Exhibit A; instructions only. Lender is unable to accept payment by check. d. If applicable, a completed Request for Disbursement in If any payment on an Eligible Purchase Order is received the form attached as Exhibit B; and by Borrower, it shall: e. Such other information as Lender may reasonably a. Hold such payment irrevocably in trust for Lender, request (collectively, an "Information Request"). separate and apart from Borrower's own funds; 3. Borrower warrants and guarantees, by submission of an Deliver such payment within one (1) business day to Advance Request, that: Lender pursuant to the wire instructions contained in a. The services described therein were (or, as applicable, Section 5 hereinabove; and shall be) in fact rendered and that the Eligible Purchase Immediately notify the payee in writing to send future Orders (defined below) evidenced thereby are and will payments to Lender pursuant to such wire instructions. continue to be genuine, bona fide, and collectable and without right of offset, counterclaim, or right of return or Borrower shall designate Lender as a point of contact cancellation; and with all Government Account Debtors and execute all authorizations or other documents requested to establish and b. If it is notified of any dispute, or of any right of offset, maintain Lender's authority to accept, endorse, and deposit all counterclaim, or right of return or cancellation against Government Account Debtor remittances to its own bank account. any Government Account Debtor's obligation to Borrower hereby appoints Lender its agent for the purpose of Borrower, it will immediately notify Lender in writing. executing all such authorizations and other documents. In addition to Borrower's obligation to provide a ADVANCES; COMPENSATION TO LENDER monthly Information Request to Lender, Borrower hereby agrees that it shall also furnish Lender with full Upon Lender's receipt of a request for disbursement, by financial statements (expressly including proof of and through the submission of the Request for Disbursement form payment and/or compliance with all federal, state and/or attached as Exhibit B, current accounts receivable aging, current LEGALIST_000001
otherattribution

Borrowers undertake weekly13-week cash forecasting and variance reporting during forbearance.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 26 of 145 PagelD# 2160 Docusign Envelope ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 Huntington Bank accounts payable aging, and any applicable related contracts Bank: and/or purchase orders not previously provided to Lender Account Name: Cyberlux Corporation (collectively, an "Advance Request") and the completion of Account No: Lender's due diligence relating thereto, and the receipt by Lender ABA No: of a satisfactory counterparty acknowledgement of an executed Instrument of Assignment in the form attached as Exhibit C, 9.9 Borrower acknowledges that Events of Default have Lender shall promptly disburse the requested amount to occurred and are continuing under Section 21 hereunder, Borrower, subject to the terms hereof. including those described in the Notices of Default LENDER SHALL NOT PROCESS MORE THAN ONE delivered to Borrower on November 4, 2024 and March ADVANCE REQUEST PER CALENDAR WEEK. 31, 2025 (collectively, the "Existing Defaults). Subject to the terms of this Section 9.9, Lender agrees to Borrower agrees, in consideration for funds loaned to it temporarily forbear from exercising its rights and by Lender under this Agreement, to pay to Lender the following remedies solely with respect to the Existing Detaults. amounts (pursuant to the wire instructions in Section 5) to be charged thereon: As used herein, the "Forbearance Period" means the period commencing on the Second Amendment Date and 9.1 Subject to the Credit Limit, the total amount of funding ending on the earlier of (a) the date that is 90 days available to Borrower hercunder shall be 50% of the face thereafter, or (b) the occurrence of any Event of Default value of each eligible purchase order, task order, delivery (other than the Existing Defaults), unless extended in order, or statement of work related to writing by Lender in its sole discretion government contracts that (x) has not been disqualified by Lender for credit or other reasons and (y) is not During the Forbearance Period: disputed by the Government Account Debtor (a) Borrower reaffirms its acknowledgment of the (collectively, the "Eligible Purchase Orders"); less Existing Defaults and agrees that, pursuant to Section 22, amounts outstanding hereunder. default interest shall continue to accrue at a rate of 4.75% 9.2 Interest on outstanding principal balances shall accrue per Event of Default, for a combined rate of 9.5% per daily at the U.S. prime rate in effect from time to time annum, compounded and capitalized monthly; (divided by 365) plus 0.0164%, with interest accrued in (b) Borrower shall pay a forbearance fee equal to 1.00% a given calendar month due and payable in arrears on the of the Temporary Increase (as defined below), deemed earlier to occur of the Facility Maturity Date or the last fully earned as of the Second Amendment Date and business day of the following month (the earlier of such capitalized into the principal balance. Such fee shall be date, the "Advance Maturity Date"). paid in three equal monthly installments commencing on 9.3 Omitted. the first Advance Maturity Date following the Second Amendment Date; 9.4 A commitment fee equal to 1.00% of the Credit Limit shall be deemed fully earned by Lender on the date (c) The Credit Limit shall be temporarily increased by hereof and due and payable in 12 equal monthly $5,300,000 (the "Temporary Increase), resulting in a installments beginning upon the first Advance Maturity temporary aggregate Credit Limit of $12,300,000. Borrower may submit an Advance Request under the Temporary Increase solely following (i) Lender's prior 9.5 When advanced amounts outstanding hereunder (a) total written approval, in its sole and absolute discretion, of a between 50% and 75% of the Credit Limit, the written statement detailing the intended use of proceeds, annualized interest rate in Section 9.2 shall be reduced in form and substance satisfactory to Lender, and (ii) by 50 basis points and (b) total at least 75% of the Credit Borrower's delivery of a form of HII Mission Limit, the annualized interest rate in Section 9.2 shall be Technologies Corp. ("HIP") Creditor Certification Form reduced by 75 basis points. acceptable to Lender, in its sole and absolute discretion. 9.6 Subject to Section 9.9, Borrower's aggregate obligations For the avoidance of doubt, no Advance Request shall be hereunder shall not exceed, without Lender's prior funded unless and until HIll has agreed to the form of written approval, the Credit Limit. If such obligations Creditor Certification Form that provides for all amounts either exceed the Credit Limit or individual advances payable by HII to be remitted directly to Lender. exceed the percentages in Section 9.1, Lender shall have Notwithstanding anything to the contrary herein, Lender no obligation to further fund until Borrower pays the may decline to fund any Advance Request under the amount of excess, which Borrower hereby agrees to pay Temporary Increase in its sole and absolute discretion, upon demand. provided that such discretion shall not be exercised unreasonably. Upon expiration of the Forbearance 9.7 All amounts described in this Section 9 (together with all Period, the Credit Limit shall revert to $7,000,000 and other amounts owing hereunder) not due on an Advance all outstanding obligations shall be immediately due and Maturity Date shall be due and payable upon the Facility payable; Maturity Date. (d) Borrower shall deliver to Lender (1) weekly 13-week 9.8 Collections received by Lender in excess of amounts rolling cash flow forecasts and variance reports, each in then owed by Borrower will be remitted to Borrower in form and substance reasonably satisfactory to Lender, due course pursuant to the following wire instructions: 2 LEGALIST_000002
otherattribution

Cyberlux undertakes cooperation and books/records access for government review of Modification4.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 145 of 145 PagelD# 2279 Case 4:25-ev-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9 CONFIDENTIAL INFORMATION Page 1 of 8 REDACTED Mission Technologies Modification No. 4 to Subcontract No. P000043846 To Effectuate a Terminotion Settlement This Modification No. 4 to Effectuate a Termination Settlement (the "Agreement"), effectiye as of February 26, 2025, is made by and between HII Mission Technologies Corp. ("HI"), a Delaware company with offices locatea at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (Cyberlux)y a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NÇ 27709 (each a "Party," and collectively, "the Parties"). WHEREAS, the Parties entered into Subcontract No. P000043846, doted Augyst 29, 2023 (the "Subcontract"). issued under HII's Prime Tosk Order 47QFCA22F0039 and Technical Direction Lefter 1-023 (ITDL 231) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the "Government"); WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HIl in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the SWO"); WHEREAS, the Government terminted the TDL 23 work scope Yor convenience on May 13, 2024, and HIl subsequently exercised the termintion provisions of Subcontract Section 32.1 on May 17, 2024; and WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement. NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties age as follows: 1. Review and Approval. a. The Parties acknowledge that pursuant to FAR 49.108-3, the Government expects HIl to submit a subcontractor settlementato The Government Contracting Officer tor review and opproval. Accordingly, the Porties agree thot Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement. Following execution of the Agreement, HIl will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereofter, HIl will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith, to gotain such approval. In furtherance of that effort, Cyberlux shall cooperate with any auditor other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract. 2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action. A division of HIl Issued by: Mission Technologies Commana Media HIl Proprietary
otherattribution

HII undertakes prompt submission and notice concerning government approval.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 145 of 145 PagelD# 2279 Case 4:25-ev-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9 CONFIDENTIAL INFORMATION Page 1 of 8 REDACTED Mission Technologies Modification No. 4 to Subcontract No. P000043846 To Effectuate a Terminotion Settlement This Modification No. 4 to Effectuate a Termination Settlement (the "Agreement"), effectiye as of February 26, 2025, is made by and between HII Mission Technologies Corp. ("HI"), a Delaware company with offices locatea at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (Cyberlux)y a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NÇ 27709 (each a "Party," and collectively, "the Parties"). WHEREAS, the Parties entered into Subcontract No. P000043846, doted Augyst 29, 2023 (the "Subcontract"). issued under HII's Prime Tosk Order 47QFCA22F0039 and Technical Direction Lefter 1-023 (ITDL 231) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the "Government"); WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HIl in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the SWO"); WHEREAS, the Government terminted the TDL 23 work scope Yor convenience on May 13, 2024, and HIl subsequently exercised the termintion provisions of Subcontract Section 32.1 on May 17, 2024; and WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement. NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties age as follows: 1. Review and Approval. a. The Parties acknowledge that pursuant to FAR 49.108-3, the Government expects HIl to submit a subcontractor settlementato The Government Contracting Officer tor review and opproval. Accordingly, the Porties agree thot Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement. Following execution of the Agreement, HIl will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereofter, HIl will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith, to gotain such approval. In furtherance of that effort, Cyberlux shall cooperate with any auditor other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract. 2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action. A division of HIl Issued by: Mission Technologies Commana Media HIl Proprietary
entityobservation

Anthony R. Gonzalez

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 1 of 145 PagelD# 2135 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Plaintiff, Case No. 3:25-cv-483 V. CYBERLUX CORP., et al., Defendants. DECLARATION OF ANTHONY R. GONZALEZ 1, Anthony R. Gonzalez, declare as follows: I am over the age of 18 and competent to make this Declaration. I have personal knowledge of the facts stated in this Declaration. 2. I am the 65% Member of Thin Air Gear, LLC ('TAG") and I submit this Declaration in support of TAG's Motion for Summary Judgment, supporting Memorandum of Law, and other related filings. TAG's Contract With Cyberlux On September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). A true and correct copy of Contract (TAG 0005-6) is attached hereto as Exhibit 1. These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract between Cyberlux and Plaintiff HII Mission Technologies Corp.'s 1
entityobservation

Strikepoint Consulting LLC

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 27 of 145 PagelD# Docusign Envelope ID: А39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 and (ii) such other information as Lender may reasonably January 30, 2024 and there bearing case no. 3:24-cv-00196-RBM- request; VET, and (b) that certain civil proceeding commenced by the (e) Solely to implement this Section 9.9 and without Atlantic Wave Parties against Borrower and Mark D. Schmidt, waiving any Event of Default, the Facility Maturity Date removed to the United States District Court for the Southern shall be deemed extended through the end of the District of California on or about March 11, 2024 and there Forbearance Period, unless otherwise agreed by Lender bearing case no. 3:24-cv-00482-RBM-VET (collectively, the in writing. "Atlantic Wave Litigation"). (f) Nothing in this Section 9.9 shall constitute a waiver 12. Lender shall have the continuing and exclusive right to of any Event of Default or limit any right or remedy of reapply or reverse and reapply any payment by or on behalf of Lender. This forbearance is limited to the terms set forth Borrower to any portion of Borrower's obligations hereunder if a herein and may be terminated by Lender upon written payment or proceeds thereof, or any part thereof, is subsequently notice following any breach of this Section 9.9 or any invalidated, declared to be fraudulent or preferential, set aside, or other provision of this Agreement. Lender reserves the required to be repaid (including to a trustee, receiver or any other right to assess additional default interest in accordance party under any bankruptcy law, state or federal law, common law with Section 22 for any other Event of Default. or equitable cause). In such event, to the extent of such amount received, the obligations hereunder shall be revived and continue in full force and effect, as if such payment or proceeds had not COLLATERAL been received. Borrower hereby grants to Lender a continuing lien on 13. Omitted. and security interest in all assets of Borrower, including its now existing and hereafter arising rights and interests in the following, Borrower agrees that its grant of a security interest shall wherever located: all goods, accounts, accounts receivable, be resurrected and acknowledges Lender's right to file any equipment, inventory, contract rights or rights to payment of financing statement or similar document that may be necessary or money, leases, license agreements, franchise agreements, general desirable if any amount is reapplied or reversed under Section 12, intangibles, commercial tort claims, documents, instruments even if a prior financing statement has been terminated. (including any promissory notes), chattel paper (whether tangible Lender may, in its sole and absolute discretion, require or electronic), cash, deposit accounts, certificates of deposit, Government Account Debtors to pay Eligible Purchase Orders fixtures, letters of credit rights (whether or not the letter of credit obligations directly to it or an affiliate per Section 5, including (i) is evidenced by a writing), securities, and all other investment notify a Government Account Debtor that its account has been property, supporting obligations, and financial assets; and all assigned to Lender by Borrower and that payment thereof shall be Borrower's books relating to the foregoing, and any and all made to the order of and directly to Lender and (ii) demanding. claims, rights and interests in any of the above and all collecting, or enforcing payment thereof. substitutions for, additions, attachments, accessories, accessions and improvements to and replacements, products, proceeds and After an Event of Default, Lender shall be entitled to take insurance proceeds of any or all of the foregoing (collectively, the the action set forth above with respect to any Collateral. "Collateral). 17. Borrower shall not, without Lender's prior written Borrower authorizes Lender, at its discretion, to file or record a consent in each instance (a) grant an extension of time for financing statement (UCC-1) or any other document necessary or payment of any Eligible Purchase Order, (b) compromise or settle desirable to perfect, maintain, or protect Lender's security interest any Eligible Purchase Order, or (c) grant any credit, discount, in the Collateral. Borrower agrees to execute and deliver any such allowance, deduction, return authorization, or the like with respect documents as may be required by the Lender to facilitate such to any Eligible Purchase Order. Furthermore, Borrower shall (a) filing. use best efforts, and cooperate in good faith as requested by Lender, to ensure timely collection in full of all Collateral and (b) Borrower shall not encumber any Collateral except for take all steps necessary or desirable (including in the performance the grant description in Section 10. To the extent that a security of all contracts and other obligations relating to the Collateral) to interest(s) of a third party predates this Agreement and involves maximize the value of the Collateral and ensure timely the Collateral described in Section 10, as a condition to funding satisfaction of the Borrower's obligations hereunder. described in Section 9, Borrower shall obtain and provide Lender with a subordination agreement with respect to the Collateral in 18. Borrower warrants, represents and/or covenants (as form and substance acceptable to Lender in its sole discretion applicable) that: upon its request, except that Borrower shall not be required to The Collateral is free and clear of all liens, obtain any subordination agreement from, or with respect to the encumbrances, security interests, and adverse claims alleged liens and/or security interests asserted by, Atlantic Wave (other than those granted to Lender hereunder), other Holdings, LLC and/or Secure Community, LLC and/or than the Atlantic Wave Liens; Strikepoint Consulting LLC (collectively, theạiAtlantic Wave Partiesiạ, which asserted liens and/or security interests (the Borrower acknowledges that it shall not obtain any "Atlantic Wave Liens") are described in, and disputed in whole additional financing that is secured by the Collateral after and/or in part by Borrower in, among other things, (a) that certain entering ints Agreement. civil proceeding commenced by the Atlantic Wave Parties against Initials: Borrower and Mark D. Schmidt, removed to the United States District Court for the Southern District of California on or about LEGALIST_000003
entityobservation

Charles Watts, Jr.

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Case 3:25-cv-00483-JAG Document 165-1 _ Filed 04/15/26 Page 65 of 145 PagelD# 2199 IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals. Date: 06/15/2023 Theres Watts. Ir, in his canci • Special Counsel for Cyberlux Corporation and Vark D. Schmidt Most D. Schnite Dare: 06/15/2023 Mark D. Schmidt, individually and on behalf of Cyberlux Corparation, as its President Datt Dale: June 15, 2023 William Welter. as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community. LLC STRIKEPOINT CONSULTING, LLÇ Dale: 6/15/2623 Cheri Nolan. CF1) and Pressient of Strikepout (onsulting. I. William Welter. Managing Director of Strikepoint Consulting, LLC Dale: June 15,2027 [Own-image transcription of material signature capacity: Charles Watts, Jr., in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Signatures of Schmidt, Welter and Cheri Nolan are present; dates read June15,2023.]
entityobservation

William Welter

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 83 of 145 PagelD# 2217 IN WITNESS WHEREOF, the Parties hereto have executed this Agreement as of the date first above written. Atlantic Wave Holdings, LLC By: Dr Delt Name: William Welter Title: Managing Director Secure Community, LLC on Delt By: Name: William Welter Title: Managing Director Cyberlux Corporation 025-0 By: Robert Berleth. Court Appointed Receiver for Cyberlux Corporation and Mark D. Schmidt Mark D. Schmidt SHELS MARLE DAVIS :. Glate of Texas xpices 02-25-2029 brary 10 132943751 By: Robert Berleth. Court Appointed Receiver for Cyberlux Corporation and Mark D. Schmidt
entityobservation

Cheri Nolan

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Case 3:25-cv-00483-JAG Document 165-1 _ Filed 04/15/26 Page 65 of 145 PagelD# 2199 IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals. Date: 06/15/2023 Theres Watts. Ir, in his canci • Special Counsel for Cyberlux Corporation and Vark D. Schmidt Most D. Schnite Dare: 06/15/2023 Mark D. Schmidt, individually and on behalf of Cyberlux Corparation, as its President Datt Dale: June 15, 2023 William Welter. as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community. LLC STRIKEPOINT CONSULTING, LLÇ Dale: 6/15/2623 Cheri Nolan. CF1) and Pressient of Strikepout (onsulting. I. William Welter. Managing Director of Strikepoint Consulting, LLC Dale: June 15,2027 [Own-image transcription of material signature capacity: Charles Watts, Jr., in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Signatures of Schmidt, Welter and Cheri Nolan are present; dates read June15,2023.]
entityobservation

Clark J. Belote

Read the anchor · page 95
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 95 of 145 PagelD# 2229 Case 3:25-cv-00483-JAG Document 1-6 Filed 06/24/25 Page 3 of 9 PagelD# 46 Just to clarify one more thing: does AW contend that its claimed security interest in the accounts receivable of Cyberlux has priority over the claimed security interest of Legalist in Cyberlux's accounts receivable? Clark J. Belote EXIBIT Kaufman & Canoles, P.C. clark.belote@kaufcan.com T. (757) 624.3109 KC F. (888) 360.9092 150 W. Main Street, Suite 2100 Norfolk, VA 23510 KAUFMANS CANOLES www.kaufCAN.com Linkedin From: David A. Walton <dwalton@bellnunnally.com> Sent: Monday, May 19, 2025 9:56 AM To: Belote, Clark J. <clark.belote@kaufcan.com; wil|welter@aol.com Cc: David M. Keithly <dkeithlv@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott <sfreling@cov.com>; Chap Petersen <jcp@petersenfirm.com> Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds Clark: Please feel free to further discuss this issue with Will Welter, copied on this email. You are authorized to speak with him directly, as needed. Put simply, yes, Atlantic Wave's position is it has a security interest in debts or claims against Cyberlux over and above the $1.44mm on the face of the garnishment summons. The settlement agreement between Cyberlux and Atlantic Wave provides for more than just the actual amount owed under the Amended Final Order and Judgment, for example, it provides Atlantic Wave the right to repayment of attorneys' fees and costs in any action caused by a breach of the settlement agreement, and damages associated with the failure to bring Cyberlux's stock to Pink Current status and to remedy the caveat emptor classification on such stock. Moreover, the settlement agreement explicitly provides: "Defendants [Cyberlux & Schmidt] agree and grant to Plaintiff [Atlantic Wave & Secure Community] a full security interest and lien interest in all of Defendants assets, including but not limited to IP, subsidiaries, contractual rights, accounts receivables, drone sales, etc., which may, in Plaintiff's sole discretion, be memorialized through the filing of UCC-1 forms and Liens." Atlantic Wave contends that Cyberlux has defaulted on the settlement agreement in several respects as set forth in prior communications and filings, which permits Atlantic Wave to enforce the security interest (authorized by the settlement agreement) against Cyberlux on the collateral or assets described in the UCC-1 forms. Attached are those UCC-1 forms that were filed in Virginia, Texas, and North Carolina. Please feel free to call me at your convenience to discuss. Take care, David David A. Walton Partner IN BELLNUNNALLY
entityobservation

David A. Walton

Read the anchor · page 95
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 95 of 145 PagelD# 2229 Case 3:25-cv-00483-JAG Document 1-6 Filed 06/24/25 Page 3 of 9 PagelD# 46 Just to clarify one more thing: does AW contend that its claimed security interest in the accounts receivable of Cyberlux has priority over the claimed security interest of Legalist in Cyberlux's accounts receivable? Clark J. Belote EXIBIT Kaufman & Canoles, P.C. clark.belote@kaufcan.com T. (757) 624.3109 KC F. (888) 360.9092 150 W. Main Street, Suite 2100 Norfolk, VA 23510 KAUFMANS CANOLES www.kaufCAN.com Linkedin From: David A. Walton <dwalton@bellnunnally.com> Sent: Monday, May 19, 2025 9:56 AM To: Belote, Clark J. <clark.belote@kaufcan.com; wil|welter@aol.com Cc: David M. Keithly <dkeithlv@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott <sfreling@cov.com>; Chap Petersen <jcp@petersenfirm.com> Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds Clark: Please feel free to further discuss this issue with Will Welter, copied on this email. You are authorized to speak with him directly, as needed. Put simply, yes, Atlantic Wave's position is it has a security interest in debts or claims against Cyberlux over and above the $1.44mm on the face of the garnishment summons. The settlement agreement between Cyberlux and Atlantic Wave provides for more than just the actual amount owed under the Amended Final Order and Judgment, for example, it provides Atlantic Wave the right to repayment of attorneys' fees and costs in any action caused by a breach of the settlement agreement, and damages associated with the failure to bring Cyberlux's stock to Pink Current status and to remedy the caveat emptor classification on such stock. Moreover, the settlement agreement explicitly provides: "Defendants [Cyberlux & Schmidt] agree and grant to Plaintiff [Atlantic Wave & Secure Community] a full security interest and lien interest in all of Defendants assets, including but not limited to IP, subsidiaries, contractual rights, accounts receivables, drone sales, etc., which may, in Plaintiff's sole discretion, be memorialized through the filing of UCC-1 forms and Liens." Atlantic Wave contends that Cyberlux has defaulted on the settlement agreement in several respects as set forth in prior communications and filings, which permits Atlantic Wave to enforce the security interest (authorized by the settlement agreement) against Cyberlux on the collateral or assets described in the UCC-1 forms. Attached are those UCC-1 forms that were filed in Virginia, Texas, and North Carolina. Please feel free to call me at your convenience to discuss. Take care, David David A. Walton Partner IN BELLNUNNALLY
entityobservation

Advanced Navigation and Positioning Corporation

Read the anchor · page 110
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 110 of 145 PagelD# VERIFICATION Tim Arbogast, being first duly sworn, deposes and says that he is the CFO of Advanced Navigation and Positioning Corporation, a Delaware corporation, and, as such, he is authorized to make this oath; that he has read the foregoing and attached Verified Complaint, and that the same is true of his own personal knowledge except those matters Advanced Navigation and Positioning Corporation OFFICIAL STAMP Emily Joyce NOTARY PUBLIC - OREGON By: Tim Arbogast ›, CFO STATE OF COUNTY OF Personally appeared before me, Tim Arbogast, either being personally known to me or proven by satisfactory evidence (said-evidence being ), and acknowledged that he signed the foregoing document. This the 5 _day of June → 2025. OFFICIAL STAMP Notary Publid, MI уБоусе Emily Joyce NOTARY PUBLIC - OREGON (Type or Print Name) MY COMMISSION EXPIRES MAY 13, 2029 COMMISSION NO. 1058184 My commission expires: May 13,2029 (Notary Seal) 6 ANPC_00012 [Own-image correction: verification is on personal knowledge except those matters stated upon information and belief, which he believes to be true. Tim Arbogast signed before Oregon notary Emily Joyce on5 June2025.]
entityobservation

Tim Arbogast

Read the anchor · page 110
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 110 of 145 PagelD# VERIFICATION Tim Arbogast, being first duly sworn, deposes and says that he is the CFO of Advanced Navigation and Positioning Corporation, a Delaware corporation, and, as such, he is authorized to make this oath; that he has read the foregoing and attached Verified Complaint, and that the same is true of his own personal knowledge except those matters Advanced Navigation and Positioning Corporation OFFICIAL STAMP Emily Joyce NOTARY PUBLIC - OREGON By: Tim Arbogast ›, CFO STATE OF COUNTY OF Personally appeared before me, Tim Arbogast, either being personally known to me or proven by satisfactory evidence (said-evidence being ), and acknowledged that he signed the foregoing document. This the 5 _day of June → 2025. OFFICIAL STAMP Notary Publid, MI уБоусе Emily Joyce NOTARY PUBLIC - OREGON (Type or Print Name) MY COMMISSION EXPIRES MAY 13, 2029 COMMISSION NO. 1058184 My commission expires: May 13,2029 (Notary Seal) 6 ANPC_00012 [Own-image correction: verification is on personal knowledge except those matters stated upon information and belief, which he believes to be true. Tim Arbogast signed before Oregon notary Emily Joyce on5 June2025.]
entityobservation

Assure Global LLC d/b/a WeShield

Read the anchor · page 119
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 119 of 145 PagelD# 2253 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Civil Action No. 3:25-cv-483-JAG Interpleader Plaintiff, V. CYBERLUX CORPORATION, ATLANTIC WAVE HOLDINGS, LLC, SECURE COMMUNITY, LLC, LEGALIST SPV III, L.P., UNITED STATES OF AMERICA, ADVANCED NAVIGATION AND POSITIONING CORPORATION, ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, and MICHAEL SINENSKY, And ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation, Interpleader Defendants/Claimants. JOINT RESPONSES OF INTERVENORS ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, AND MICHAEL SINENSKY TO INTERROGATORY REGARDING NATURE OF CLAIM TO INTERPLEADER PROCEEDS Pursuant to the Court's Order and the applicable Federal Rules of Civil Procedure, Intervenors Assure Global LLC d/b/a WeShield ("WeShield"), Roman Investments PR LLC ("Roman Investments"), MAS USA MGT LLC ("MAS") (as assignee of Rosewood Theater LLC), and Michael Sinensky ("Sinensky") (collectively, "Respondents"), by and through undersigned 1
entityobservation

Roman Investments PR LLC

Read the anchor · page 119
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 119 of 145 PagelD# 2253 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Civil Action No. 3:25-cv-483-JAG Interpleader Plaintiff, V. CYBERLUX CORPORATION, ATLANTIC WAVE HOLDINGS, LLC, SECURE COMMUNITY, LLC, LEGALIST SPV III, L.P., UNITED STATES OF AMERICA, ADVANCED NAVIGATION AND POSITIONING CORPORATION, ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, and MICHAEL SINENSKY, And ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation, Interpleader Defendants/Claimants. JOINT RESPONSES OF INTERVENORS ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, AND MICHAEL SINENSKY TO INTERROGATORY REGARDING NATURE OF CLAIM TO INTERPLEADER PROCEEDS Pursuant to the Court's Order and the applicable Federal Rules of Civil Procedure, Intervenors Assure Global LLC d/b/a WeShield ("WeShield"), Roman Investments PR LLC ("Roman Investments"), MAS USA MGT LLC ("MAS") (as assignee of Rosewood Theater LLC), and Michael Sinensky ("Sinensky") (collectively, "Respondents"), by and through undersigned 1
entityobservation

Thin Air Gear, LLC

Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 1 of 145 PagelD# 2135 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Plaintiff, Case No. 3:25-cv-483 V. CYBERLUX CORP., et al., Defendants. DECLARATION OF ANTHONY R. GONZALEZ 1, Anthony R. Gonzalez, declare as follows: I am over the age of 18 and competent to make this Declaration. I have personal knowledge of the facts stated in this Declaration. 2. I am the 65% Member of Thin Air Gear, LLC ('TAG") and I submit this Declaration in support of TAG's Motion for Summary Judgment, supporting Memorandum of Law, and other related filings. TAG's Contract With Cyberlux On September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). A true and correct copy of Contract (TAG 0005-6) is attached hereto as Exhibit 1. These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract between Cyberlux and Plaintiff HII Mission Technologies Corp.'s 1
entityobservation

MAS USA MGT LLC

Read the anchor · page 119
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 119 of 145 PagelD# 2253 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Civil Action No. 3:25-cv-483-JAG Interpleader Plaintiff, V. CYBERLUX CORPORATION, ATLANTIC WAVE HOLDINGS, LLC, SECURE COMMUNITY, LLC, LEGALIST SPV III, L.P., UNITED STATES OF AMERICA, ADVANCED NAVIGATION AND POSITIONING CORPORATION, ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, and MICHAEL SINENSKY, And ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation, Interpleader Defendants/Claimants. JOINT RESPONSES OF INTERVENORS ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, AND MICHAEL SINENSKY TO INTERROGATORY REGARDING NATURE OF CLAIM TO INTERPLEADER PROCEEDS Pursuant to the Court's Order and the applicable Federal Rules of Civil Procedure, Intervenors Assure Global LLC d/b/a WeShield ("WeShield"), Roman Investments PR LLC ("Roman Investments"), MAS USA MGT LLC ("MAS") (as assignee of Rosewood Theater LLC), and Michael Sinensky ("Sinensky") (collectively, "Respondents"), by and through undersigned 1
entityobservation

Michael Sinensky

Read the anchor · page 119
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 119 of 145 PagelD# 2253 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Civil Action No. 3:25-cv-483-JAG Interpleader Plaintiff, V. CYBERLUX CORPORATION, ATLANTIC WAVE HOLDINGS, LLC, SECURE COMMUNITY, LLC, LEGALIST SPV III, L.P., UNITED STATES OF AMERICA, ADVANCED NAVIGATION AND POSITIONING CORPORATION, ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, and MICHAEL SINENSKY, And ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation, Interpleader Defendants/Claimants. JOINT RESPONSES OF INTERVENORS ASSURE GLOBAL LLC d/b/a WESHIELD, ROMAN INVESTMENTS PR LLC, MAS USA MGT LLC, AND MICHAEL SINENSKY TO INTERROGATORY REGARDING NATURE OF CLAIM TO INTERPLEADER PROCEEDS Pursuant to the Court's Order and the applicable Federal Rules of Civil Procedure, Intervenors Assure Global LLC d/b/a WeShield ("WeShield"), Roman Investments PR LLC ("Roman Investments"), MAS USA MGT LLC ("MAS") (as assignee of Rosewood Theater LLC), and Michael Sinensky ("Sinensky") (collectively, "Respondents"), by and through undersigned 1
entityobservation

Fairwinds Technologies, LLC

Read the anchor · page 131
Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 131 of 145 PagelD# 2265 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff CYBERLUX CORPORATION; Civil Action No: 3:25-cv-483-JAG ATLANTIC WAVE HOLDINGS, LLC; SECURE COMMUNITY, LLC; LEGALIST SPY III, LP; UNITED STATES OF AMERICA; ADVANCED NAVIGATION AND POSITIONING CORPORATION; and ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation, Interpleader Defendants/Claimants FAIRWINDS TECHNOLOGIES, LLC'S RESPONSE TO THE JOINT DISCOVERY PLAN INTERROGATORY AND DOCUMENT REQUESTS Now comes Interpleader Defendant/Claimant Fairwinds Technologies, LLC ("Fairwinds), who submits the following responses to the Interrogatory and Document Requests agreed to by all Parties in the Joint Discovery Plan [Doc. 147] filed with the Court on February 12, 2026, as follows: INTERROGATORY: Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) The amount of the proceeds that you claim. Response: Cyberlux owes Fairwinds $2,348,542.00. #111272386v1
entityobservation

Thomas Wirth

Read the anchor · page 135
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 135 of 145 PagelD# CERTIFICATION I, Thomas Wirth, General Counsel of Fairwinds Technologies LLC, declare under penalty of perjury under the laws of the United States of America that: I am duly authorized to verify the foregoing interrogatory responses and document requests on behalf of Fairwinds Technologies, LLC; that the information contained in the foregoing responses has been collected and the responses prepared with the advice and assistance of counsel; and that, subject to any inadvertent or undiscovered errors, and based on the records and information still in existence and thus far discovered, the foregoing responses are true and correct. Thomas O. Wish THOMAS WIRTH, Esq. General Counsel of Fairwinds Technologies, LLC 5 #111272386vl
entityobservation

Robert W. Berleth

Read the anchor · page 82
Case 3:25-cv-00483-JAG Document 165-1 _ Filed 04/15/26 Page 82 of 145 PagelD# 2216 21. Notices: All notices, requests, demands. and other communications required or permitted to be given under this Agreement shall be in writing and shall be deemed to have been duly given if sent by certified or registered mail, return receipt requested, and by email with confimation of receipt, to the Parties at the following addresses or to such other addresses as the Parties may designate in writing: • Atlantic Wave Holdings, LLC and Secure Community, LIC: 4201 Wilson Blvd, 3 Floor Arlington, VA 22203 Will Welteribaul.com With copies to: Charles Gavin, Esq. 15271 River's Bend Boulevard Chester, Virginia 23836 Richmond. VA cgavint@rudvcovner.com • Cyberlux Corporation: Robert W. Berleth, Esq. 9950 Cypresswood Dr. Suite 200 Houston. TX 77070 Telephone: 713-588-6900 E-mail: rberleth@berlethlaw.com Keceiver for Defendant • Mark D. Schmidt: Robert W. Berleth, Esquire 9950 Cypresswood Dr.. Suite 200 Houston, TX 77070 Telephone: 713-588-6900 E-mail: rberleth/@berlethlaw.com Receiver for Defendant Signatures to appear on the next page
entityobservation

HII Mission Technologies Corp.

Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 1 of 145 PagelD# 2135 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Plaintiff, Case No. 3:25-cv-483 V. CYBERLUX CORP., et al., Defendants. DECLARATION OF ANTHONY R. GONZALEZ 1, Anthony R. Gonzalez, declare as follows: I am over the age of 18 and competent to make this Declaration. I have personal knowledge of the facts stated in this Declaration. 2. I am the 65% Member of Thin Air Gear, LLC ('TAG") and I submit this Declaration in support of TAG's Motion for Summary Judgment, supporting Memorandum of Law, and other related filings. TAG's Contract With Cyberlux On September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). A true and correct copy of Contract (TAG 0005-6) is attached hereto as Exhibit 1. These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract between Cyberlux and Plaintiff HII Mission Technologies Corp.'s 1
entityobservation

Rick Tucker

Read the anchor · page 8
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 8 of 145 PagelD# 2142 Thin Alr Gear THIN AIR 4196 Center Park Drive Colorado Springs, CO 80916 SEAR for the long haul (719)302-0563 mike@thinairgear.com http://www.thinairgear.com INVOICE BILL TO SHIP TO INVOICE # 8110 Rick Tucker Rick Tucker DATE 09/05/2023 Catalyst Machine Works Catalyst Machine Works DUE DATE 09/15/2023 6710 Spring Steubner Rd, 21631 Ahodes Rd TERMS Net 10 Suite 709 Suite A105 PMB 103 Spring, TX 77389 USA Spring, TX 77389 USA PURCHASE ORDER Verbal/Email ATT DESCRIPTION OTY RATE AMOUNT DEPOSIT 150,000.00 150,000.00 DEPOSIT - 2,100 Drone Kit bag - Verbal/Email Purchase Order Banking Information: Account Holder: Thin Air Gear, LLC 4196 Center Park Drive Colarado Springs, CO 80916 Bank: First Bank 2 N Cascade Ave., Suite 130 Colorado Springs, CO 80903 ABA ROUNTING NUMBER: 107005047 ACCOUNT NUMBER: 219-120-8114 All Past Due Invoices will be sublect to a 1.5% late fee per month. BALANCE DUE $150,000.00 TAG-0006
entityobservation

Cyberlux Corporation

Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 1 of 145 PagelD# 2135 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Plaintiff, Case No. 3:25-cv-483 V. CYBERLUX CORP., et al., Defendants. DECLARATION OF ANTHONY R. GONZALEZ 1, Anthony R. Gonzalez, declare as follows: I am over the age of 18 and competent to make this Declaration. I have personal knowledge of the facts stated in this Declaration. 2. I am the 65% Member of Thin Air Gear, LLC ('TAG") and I submit this Declaration in support of TAG's Motion for Summary Judgment, supporting Memorandum of Law, and other related filings. TAG's Contract With Cyberlux On September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). A true and correct copy of Contract (TAG 0005-6) is attached hereto as Exhibit 1. These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract between Cyberlux and Plaintiff HII Mission Technologies Corp.'s 1
entityobservation

Datron World Communications, Inc.

Read the anchor · page 31
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 31 of 145 PagelD# 2165 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 New York. The parties hereby irrevocably submit to the exclusive IN WITNESS WHEREOF, the undersigned have duly executed jurisdiction of such courts and waive any objection to the venue this Agreement as of the first date written above. or jurisdiction based on forum non conveniens or any other grounds. LENDER: The parties intend, and Borrower hereby acknowledges LEGALIST SEV III, LP and agrees, that this Agreement (including any and all obligations By to repay amounts advanced hereunder, whether principal, interest, Name: Brian T. Rice HOL.. fees, costs, or otherwise) constitutes an instrument for the Title: Authorized Signatory payment of money only, within the meaning of New York Civil Address: 58 West Portal Ave. #747 Practice Law and Rules ( CPLR) 3213. If Borrower fails to San Francisco, CA 94127 make any such payment when due under this Agreement, Lender Email: receivables(@legalist.com shall be entitled to move for relief under CPLR 3213, and Borrower expressly waives any defense thereunder except for BORROWER: proof of payment. CYBERLUX CORPORATION Service of any notice under this Agreement may occur Mark V. Semidt by electronic mail. Name: Mark D. Schmidt AUTHORITY AND EFFECTIVENESS Title: President and CEO Address: 800 Park Offices Dr., Ste. 3209 Borrower hereby represents that it is a duly authorized Research Triangle, NC 27709 and existing entity in good standing under the laws of the Email: mschmidt@cyberlux.com jurisdiction of organization set forth on the signature page. The execution, delivery, and performance hereof and the other Jurisdiction of Organization: documents hereby contemplated are, and shall remain, within North Carolina Borrower's powers, have been duly authorized, and are not in contravention of any law, rule, or regulation, or the terms of any contract, agreement or undertaking to which Borrower is a party DA RAN 9. SEMMUNICATIONS, INC. or by which it is bound. Name: Mark D. Schmidt MISCELLANEOUS Title: 38. Each party represents to the other parties that it (a) has Address: 995 Joshua Way, Ste. A read this agreement, (b) has been represented in the preparation, Vista, CA 92081 negotiation. and execution of this Agreement by legal counsel of Email: mschmidt@cyberlux.com the party's own choice or has voluntarily declined to seek such Jurisdiction of Organization: counsel; (c) understands the terms and consequences of this California Agreement; and (d) is fully aware of the legal and binding effect of this Agreement. This agreement supersedes all prior or contemporaneous agreements and understandings between the parties, verbal or written, express or implied, relating to the subject matter hereof. 4/29/2025 _ (the "Second Amendment Date"), that certain Amended and Restated Government Purchase Order Financing Agreement dated March 27, 2024 by and between Legalist SPV III, LP and Cyberlux Corporation and Datron World Communications, Inc. shall be amended, restated, and superseded in its entirety by this Agreement. LEGALIST 000007
entityobservation

Legalist SPV III, LP

Read the anchor · page 31
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 31 of 145 PagelD# 2165 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 New York. The parties hereby irrevocably submit to the exclusive IN WITNESS WHEREOF, the undersigned have duly executed jurisdiction of such courts and waive any objection to the venue this Agreement as of the first date written above. or jurisdiction based on forum non conveniens or any other grounds. LENDER: The parties intend, and Borrower hereby acknowledges LEGALIST SEV III, LP and agrees, that this Agreement (including any and all obligations By to repay amounts advanced hereunder, whether principal, interest, Name: Brian T. Rice HOL.. fees, costs, or otherwise) constitutes an instrument for the Title: Authorized Signatory payment of money only, within the meaning of New York Civil Address: 58 West Portal Ave. #747 Practice Law and Rules ( CPLR) 3213. If Borrower fails to San Francisco, CA 94127 make any such payment when due under this Agreement, Lender Email: receivables(@legalist.com shall be entitled to move for relief under CPLR 3213, and Borrower expressly waives any defense thereunder except for BORROWER: proof of payment. CYBERLUX CORPORATION Service of any notice under this Agreement may occur Mark V. Semidt by electronic mail. Name: Mark D. Schmidt AUTHORITY AND EFFECTIVENESS Title: President and CEO Address: 800 Park Offices Dr., Ste. 3209 Borrower hereby represents that it is a duly authorized Research Triangle, NC 27709 and existing entity in good standing under the laws of the Email: mschmidt@cyberlux.com jurisdiction of organization set forth on the signature page. The execution, delivery, and performance hereof and the other Jurisdiction of Organization: documents hereby contemplated are, and shall remain, within North Carolina Borrower's powers, have been duly authorized, and are not in contravention of any law, rule, or regulation, or the terms of any contract, agreement or undertaking to which Borrower is a party DA RAN 9. SEMMUNICATIONS, INC. or by which it is bound. Name: Mark D. Schmidt MISCELLANEOUS Title: 38. Each party represents to the other parties that it (a) has Address: 995 Joshua Way, Ste. A read this agreement, (b) has been represented in the preparation, Vista, CA 92081 negotiation. and execution of this Agreement by legal counsel of Email: mschmidt@cyberlux.com the party's own choice or has voluntarily declined to seek such Jurisdiction of Organization: counsel; (c) understands the terms and consequences of this California Agreement; and (d) is fully aware of the legal and binding effect of this Agreement. This agreement supersedes all prior or contemporaneous agreements and understandings between the parties, verbal or written, express or implied, relating to the subject matter hereof. 4/29/2025 _ (the "Second Amendment Date"), that certain Amended and Restated Government Purchase Order Financing Agreement dated March 27, 2024 by and between Legalist SPV III, LP and Cyberlux Corporation and Datron World Communications, Inc. shall be amended, restated, and superseded in its entirety by this Agreement. LEGALIST 000007
entityobservation

Mark D. Schmidt

Read the anchor · page 31
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 31 of 145 PagelD# 2165 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 New York. The parties hereby irrevocably submit to the exclusive IN WITNESS WHEREOF, the undersigned have duly executed jurisdiction of such courts and waive any objection to the venue this Agreement as of the first date written above. or jurisdiction based on forum non conveniens or any other grounds. LENDER: The parties intend, and Borrower hereby acknowledges LEGALIST SEV III, LP and agrees, that this Agreement (including any and all obligations By to repay amounts advanced hereunder, whether principal, interest, Name: Brian T. Rice HOL.. fees, costs, or otherwise) constitutes an instrument for the Title: Authorized Signatory payment of money only, within the meaning of New York Civil Address: 58 West Portal Ave. #747 Practice Law and Rules ( CPLR) 3213. If Borrower fails to San Francisco, CA 94127 make any such payment when due under this Agreement, Lender Email: receivables(@legalist.com shall be entitled to move for relief under CPLR 3213, and Borrower expressly waives any defense thereunder except for BORROWER: proof of payment. CYBERLUX CORPORATION Service of any notice under this Agreement may occur Mark V. Semidt by electronic mail. Name: Mark D. Schmidt AUTHORITY AND EFFECTIVENESS Title: President and CEO Address: 800 Park Offices Dr., Ste. 3209 Borrower hereby represents that it is a duly authorized Research Triangle, NC 27709 and existing entity in good standing under the laws of the Email: mschmidt@cyberlux.com jurisdiction of organization set forth on the signature page. The execution, delivery, and performance hereof and the other Jurisdiction of Organization: documents hereby contemplated are, and shall remain, within North Carolina Borrower's powers, have been duly authorized, and are not in contravention of any law, rule, or regulation, or the terms of any contract, agreement or undertaking to which Borrower is a party DA RAN 9. SEMMUNICATIONS, INC. or by which it is bound. Name: Mark D. Schmidt MISCELLANEOUS Title: 38. Each party represents to the other parties that it (a) has Address: 995 Joshua Way, Ste. A read this agreement, (b) has been represented in the preparation, Vista, CA 92081 negotiation. and execution of this Agreement by legal counsel of Email: mschmidt@cyberlux.com the party's own choice or has voluntarily declined to seek such Jurisdiction of Organization: counsel; (c) understands the terms and consequences of this California Agreement; and (d) is fully aware of the legal and binding effect of this Agreement. This agreement supersedes all prior or contemporaneous agreements and understandings between the parties, verbal or written, express or implied, relating to the subject matter hereof. 4/29/2025 _ (the "Second Amendment Date"), that certain Amended and Restated Government Purchase Order Financing Agreement dated March 27, 2024 by and between Legalist SPV III, LP and Cyberlux Corporation and Datron World Communications, Inc. shall be amended, restated, and superseded in its entirety by this Agreement. LEGALIST 000007
entityobservation

Brian T. Rice

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 31 of 145 PagelD# 2165 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 New York. The parties hereby irrevocably submit to the exclusive IN WITNESS WHEREOF, the undersigned have duly executed jurisdiction of such courts and waive any objection to the venue this Agreement as of the first date written above. or jurisdiction based on forum non conveniens or any other grounds. LENDER: The parties intend, and Borrower hereby acknowledges LEGALIST SEV III, LP and agrees, that this Agreement (including any and all obligations By to repay amounts advanced hereunder, whether principal, interest, Name: Brian T. Rice HOL.. fees, costs, or otherwise) constitutes an instrument for the Title: Authorized Signatory payment of money only, within the meaning of New York Civil Address: 58 West Portal Ave. #747 Practice Law and Rules ( CPLR) 3213. If Borrower fails to San Francisco, CA 94127 make any such payment when due under this Agreement, Lender Email: receivables(@legalist.com shall be entitled to move for relief under CPLR 3213, and Borrower expressly waives any defense thereunder except for BORROWER: proof of payment. CYBERLUX CORPORATION Service of any notice under this Agreement may occur Mark V. Semidt by electronic mail. Name: Mark D. Schmidt AUTHORITY AND EFFECTIVENESS Title: President and CEO Address: 800 Park Offices Dr., Ste. 3209 Borrower hereby represents that it is a duly authorized Research Triangle, NC 27709 and existing entity in good standing under the laws of the Email: mschmidt@cyberlux.com jurisdiction of organization set forth on the signature page. The execution, delivery, and performance hereof and the other Jurisdiction of Organization: documents hereby contemplated are, and shall remain, within North Carolina Borrower's powers, have been duly authorized, and are not in contravention of any law, rule, or regulation, or the terms of any contract, agreement or undertaking to which Borrower is a party DA RAN 9. SEMMUNICATIONS, INC. or by which it is bound. Name: Mark D. Schmidt MISCELLANEOUS Title: 38. Each party represents to the other parties that it (a) has Address: 995 Joshua Way, Ste. A read this agreement, (b) has been represented in the preparation, Vista, CA 92081 negotiation. and execution of this Agreement by legal counsel of Email: mschmidt@cyberlux.com the party's own choice or has voluntarily declined to seek such Jurisdiction of Organization: counsel; (c) understands the terms and consequences of this California Agreement; and (d) is fully aware of the legal and binding effect of this Agreement. This agreement supersedes all prior or contemporaneous agreements and understandings between the parties, verbal or written, express or implied, relating to the subject matter hereof. 4/29/2025 _ (the "Second Amendment Date"), that certain Amended and Restated Government Purchase Order Financing Agreement dated March 27, 2024 by and between Legalist SPV III, LP and Cyberlux Corporation and Datron World Communications, Inc. shall be amended, restated, and superseded in its entirety by this Agreement. LEGALIST 000007
entityobservation

Atlantic Wave Holdings, LLC

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 47 of 145 PagelD# 2181 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH') and in Response to Interpleader Defendant Cyberlux Corporation's ("CYBL') Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC ("SC'). Accordingly, while each a party, A WH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide Marketable Trading" CYBL stock. 3. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreemenằ_ dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
entityobservation

Secure Community, LLC

Read the anchor · page 47
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 47 of 145 PagelD# 2181 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH') and in Response to Interpleader Defendant Cyberlux Corporation's ("CYBL') Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC ("SC'). Accordingly, while each a party, A WH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide Marketable Trading" CYBL stock. 3. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreemenằ_ dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
eventattribution

AW/SC/Strikepoint and Cyberlux/Schmidt execute original settlement.

Read the anchor · page 54
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 54 of 145 PagelD# 2188 Cyberlux Settlement Agreement Final 002 - 1pdf file: C: lisers willu Downlaaas:Cy berlux Settlement_Agreement... EXHIBIT SETTLEMENT AGREEMENT This Senlement Agreement (theiAgreement") is made as of this 15thth day of June 2023, by nd between ATLANTIC WAVE HOLDINGS. LLC. SECURE COMMUNITY, LLO (collectively, "Plaintiffs"), CYBERLUX CORPORATION AND MARK D. SCHMIDT (collectively, Defendants). and STRIKEPOINT CONSULTING, LLC ("Strikepoint") a separate party with some common interest holders to the Plaintifts. Plaimifts, Defendants, and Strikepoint shall collectively be referred to as the Parties to this Agreement" and Plaintiffs and Defendants shall collecuvely be referred to as "Parties to the Litigation. RECITALS WHEREAS, Plaintiffs and Defendants entered into an agreement on October 8, 2021, which compensated Plaintiffs for the reacquisition by Defendant Cyberlux of certain intellectual property in exchange for certain installment payments of fixed liquidated sums by Defendants to Plaintiffs and Freely Trading stock. which had fallen into arrears ("the IP Agreement): WHEREAS, on September 24, 2021. an agreement was executed between an entity described as "Strikepoints Consulting. LLC" and Defendant Cyberlux Corporation for certain consulting services (theiStikepoint Consulting Agreement"), which called for, inter alia, installment payments of fixed liquidated sums owed by Defendants to Plaintiff, which also fell into arrears: WHEREAS, Plaintiffs filed its Complaint for breach of said agreements in the Circuit Court of the City of Richınond, Virginia (the "Courti), against Defendants in the civil action titled, Atlantic Wave Holdings, LEC and Secure Community, LLC V. Cybertus Corporation and Mark D. Schmidt (Case No. CL22-3882) (the "Litigation"]. which remains pending: WITEREAS. the Parties to this Agreement desire to resolve and settle any and all existing disputes between the Plantifts and Defendants and between Strikepoint and Defendants to climate uncertainty and facilitate finat resolution of their respective relationships between the parties; and 1 01 15 G/15/2023, 5:50 PM
eventattribution

AW/SC receiver settlement dated2 September2025.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 79 of 145 PagelD# 2213 EXHIBIT tabbles SETTLEMENT AGREEMENT This Settlement Agreement (Agreement) is made and entered into on this the 2nd" day of September 2025 by and among Atlantic Wave Holdings, LLC (I AWHI), Secure Community, LLC ("SC'), Cyberlux Corporation ("Cyberlux"), and Mark D. Schmidt ("Schmidt") collectively referred to as the "Parties." RECITALS WHEREAS in Case No.: 2400-3910, Plaintiffs filed their Complaint on September 9, 2024. WHEREAS UCC liens were filed in the Commonwealth of Virginia and the States of North Carolina and Texas on July 6, 2023, specifically for the Drone receivables. WHEREAS case no.: 2400-3910 was brought as a result of the alleged breach by Defendants of a settlement agreement between the parties. The Settlement Agreement, among other things includes: A. The Recitals State: WHEREAS, the Porties to this Agreement have been told by Cyberlux for more than six (6) months that Cyberlux anticipates a significant cash flow connected with the sales of certain arone products. and: B. Paragraphs 4(b) and 4(c) state: Defendants agree to accelerate and pay the full outstanding balance of all stits owed under the consent Judgment up to a total of FIVE THOUSAND DOLLARS (S.5,000) per drone sold within twenty-one (21) days of Defendants, or any parent's, subsidiary's, affiliate is, or assign's first receipt of payment for any contract to purchase drone aircraft. WHEREAS the Settlement Agreement was intended to secure Judgment-Creditor's security interest in the HII MISSION TECHNOLOGIES CORP ("HII") drone contract receivables. WHEREAS the Settlement Agreement also required Judgment-Debtors to make the Cyberlux stock marketable by December 31, 2023. Judgment-Debtors have admitted within all their pleadings that they did not make the stock marketable (by removing the Caveat Emptor status) by December 31. 2023. WHEREAS Judgment-Debtors raise no meritorious defenses but instead admit their breach. WHEREAS the Honorable Michael Gomez, on May 22, 2025, appointed Robert B. Berleth of Berleth & Associates, the (the "Undersigned" and also the "Receiver") as the Receiver of Cyberlux Corporation and Mark D. Schmidt in a companion case pending in Harris County
eventattribution

AW/SC consent final order entered18 December2025.

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Case 3:25-cv-00483-JAG Document 165-1 _ Filed 04/15/26 Page 91 of 145 PagelD# makes no ruling on whether the Defendants had standing to claim defective notice and makes no ruling on whether the Defendants have any appellate rights. It is SO ORDERED. ENTERED This 18 day of December, 2025 Hanorable Jacque ine S. McClenney, Presiding Judge Circut Court for the City of Richmond, Virginia WE ASK FOR THIS: A Copy Teste: EDWARD F. JEWETT, CLERK Charles A. Gavin, VSB#31391 or. Kwanda fandaph oc. Rudy Coyner, Attorneys at Law 13271 Rivers Bend Blvd. Chester, Virgnia 23836 (804) 748-3600, ext. 306 (804) 748-4671 facsimile E-mail: ggavin@rudycoyner.com Counsel for Atlantic Wave Holdings, LLC and Secure Community, LLC Veron E. Inge, Jr. #32699 Robert N. Drewry, VSB #91282 Whiteford Tayior & Preston, LLP Two James Center 1021 E. Cary Street, Suite 2001 Richmond, VA 23219 804.977.3301 804.977.3291 Facsimile vinge@whitefordlaw.com rdrewry@whitefordlaw.com Counsel for Robert W. Berleth, Receiver 4
eventattribution

AW reconsideration denial entry reads5 February2026.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 93 of 145 PagelD# EXHIBIT Virginia: In the Circuit Court of the City of Richmond, Joh Alarshall Courts Failoing ATLANTIC WAVE HOLDINGS, LLC. AND SECURE COMMUNITY, LLC. Plaintiff, Case No. CL24-3910 CYBERLUX CORPORATION and MARK SCHIMIDT, individually Defendants, ORDER On January 2, 2026 Defendants Cyberlux Corporation and Mark D. Schimdt, by counsel, filed an "Emergency Motion to Reconsider and Vacate Consent Final Order and To Suspend Execution Pending the Court's Ruling." Plaintiffs' counsel for Atlantic Wave Holding, LLC, and Secure Community, LLC, subsequently filed a "Response in Opposition to Motion to Reconsider: »2 The Court DENIED Defendants' request to file a Reply. Upon reviewing the parties' current filings, the Court ORDERS that its prior ruling STANDS. Accordingly, the Court hereby DENIES Defendants' Motion to Reconsider and TERMINATES the suspension of the "Consent Final Order." The Court ORDERS the "Consent Final Order" effective as of the entry date of this Order. Pursuant to Rule 4;15(d) of the Supreme Court Rules of Virgina, the Court hereby DENIES the parties' request for a hearing, and further VACATES AND RELEASES the previously scheduled hearing set for February 24, 2026 at 9:00 a.m. The parties are released from their appearances. The Clerk is DIRECTED to forward a certified copy of this Order to the parties. ' Jimmy Robinson, Esq., representing the Defendants. 2 Charles Gavin, Esq., representing the Plaintiffs.
eventattribution

Creditor responses dated9 March2026; computation qualifications retained.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 43 of 145 PagelD# 2177 • 10/3/2024: $150.00.00 10/3/2024: $120,000.00 • 6/3/2025: $2,755,100.10 • 6/9/2025: $345,000.00ł Requests for Production 1. Documents supporting or otherwise concerning your answer to the above interrogatory. Response: See the documents produced at Bates Nos. LEGALIST_000001-20. 2. All documents on which you rely to assert any security interest in, lien on, or assignment of the proceeds that are the subject of this interpleader. Response: See the documents produced at Bates Nos. LEGALIST_000001-20. Date: March 9, 2026 LEGALIST SPV III, LP By: Timothy G. Moore (VSB No. 41730) tmoore@spottsfain.com John M. Erbach (VSB No. 76695) jerbach@spottsfain.com Christopher W. Bascom (VSB No. 87302) cbascom@spottsfain.com Spotts Fain, P.C. 411 E. Franklin Street, Suite 600 Richmond, VA 23219 (804) 697-2065 (804) 697-2165 Fax Jeff. P Prostok (admitted pro hac vice) 1 The final two entries covered the $3,083,639.75 protective advance Legalist made on behalf of Cyberlux. Legalist initially advanced $3,100,100.10, and the $16,460.35 difference was applied to its legal fees. [Own-image correction: first entry reads 10/3/2024: $150,000.00; next $120,000.00. June entries are $2,755,100.10 and $345,000.00, with footnote explaining $16,460.35 applied to fees.]
eventattribution

Gonzalez signs under penalty of perjury.

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Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 4 of 145 PagelD# Exhibit 9. 18. A true and correct copy of ANPC's Response to Interrogatory 1 is attached hereto as Exhibit 10. 19. A true and correct copy of the WeShield Group's Response to Interrogatory 1 is attached hereto as Exhibit 11. 20. A true and correct copy of Fairwind's Response to Interrogatory 1 is attached hereto as Exhibit 12. 21. A true and correct copy of the Receiver's Response to Interrogatory 1 is attached hereto as Exhibit 13. 22. A true and correct copy of Modification 4 to the Subcontract is attached hereto as Exhibit 14. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the forgoing is true and correct. Anthony gonzalez Executed on April 14, 2026 Anthony R. Gonzalez 4
eventattribution

EDVA docket header identifies filing of ECF165-1.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 1 of 145 PagelD# 2135 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Plaintiff, Case No. 3:25-cv-483 V. CYBERLUX CORP., et al., Defendants. DECLARATION OF ANTHONY R. GONZALEZ 1, Anthony R. Gonzalez, declare as follows: I am over the age of 18 and competent to make this Declaration. I have personal knowledge of the facts stated in this Declaration. 2. I am the 65% Member of Thin Air Gear, LLC ('TAG") and I submit this Declaration in support of TAG's Motion for Summary Judgment, supporting Memorandum of Law, and other related filings. TAG's Contract With Cyberlux On September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). A true and correct copy of Contract (TAG 0005-6) is attached hereto as Exhibit 1. These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract between Cyberlux and Plaintiff HII Mission Technologies Corp.'s 1
eventattribution

NC, VA and TX filing records bear6 July2023 dates.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 66 of 145 PagelD# 2200 File Number: 20230084472C Date Filed: 7/6/2023 9:24:00 AM Elaine F. Marshall NC Secretary of State UCC FINANCING STATEMENT FOLLOW INSTRUCTIONS A. NAME & PHONE OF CONTACT AT FILER (optional) EXHIBIT Arlington Law Group B. E-MAIL CONTACT AT FILER (optional) B-1 elemmer@arlingtonlawgroup.com C. SEND ACKNOWLEDGMENT TO: (Name and Address) Arlington Law Group 1739 Clarendon Boulevard Arlington, VA 22209 J THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY 1. DEBTOR'S NAME: Provide only one Debtor name (1a or 1b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's name will not fit in line 1b, leave all of item 1 blank, check here and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad) 1a. ORGANIZATION'S NAME OR 1b. INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADCITIONAL NAME(S)/INITIAL(S) Schmidt SUFFIx Mark 1c. MAILING ADDRESS D. CITY STATE POSTAL CODE COUNTRY 800 Park Offices Drive, Suite 3209 Research Triangle Park NC 27709 USA 2. DEBTOR'S NAME: Provide only gne Debtor name (2a or 2b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's name will not fit in line 2b, leave all of Item 2 blank, check here and provide the Individual Debtor information In Item 10 of the Financing Statement Addendum (For UCC1Ad) 2a. ORGANIZATION'S NAME Cyberlux Corporation OR 2b. INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADDITIONAL NAME(S)/INITIAL(S) SUFFIX 2c. MAILING ADDRESS CITY STATE POSTAL CODE COUNTRY 800 Park Offices Drive, Suite 3209 Research Triangle Park INC 27709 JUSA 3. SECURED PARTY'S NAME (or NAME of ASSIGNEE of ASSIGNOR SECURED PARTY): Provide only pne Secured Party name (3а or 3b) 3a ORGANIZATION'S NAME Atlantic Wave Holdings, LLC OR 36. INDIVIDUAL'S SURNAME FIRST PERSONAL NAME ADDITIONAL NAME(SM/INITIAL(S] | SUFFIX Эc. MAILING ADDRESS CITY STATE POSTAL CODE COUNTRY 11 S. 12th Street 4. COLLATERAL: This financing statement covers the following collateral: 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 instruments, limitation relating to drones), equipment, accounts, chattel paper, contractual rights, letter-of-credit rights, letters of credit, documents, deposit accounts, money, intellectual property (including without limitation relating to drones), 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, (iii) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, proceeds relating to any of the foregoing property, (v) any and all goodwill relating to any of (iv) any and all insurance the foregoing property, and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Catalyst Machineworks, LIC. 5. Check only if appicable and check goly one box: Collateral Is held In a Trust (sae UCC1Ad, Hem 17 and Instructions) 6a. Check only if applicable and check only one box: being administered by a Decedent's Personal Representative Public-Finance Transaction 6b. Check only if applicable and check only one box: Manufactured-Home Transaction A Debtor is a Transmiting Utility Agricultural Lien • Non-UCC Fling 7. ALTERNATIVE DESIGNATION (If applicable): Lessee/Lessor Conalanee/Consignor Bailee/Bailor 8. OPTIONAL FILER REFERENCE DATA: L Licensee/Licensor FILING OFFICE COPY - UCC FINANCING STATEMENT (For UCC1) (Rev. 04/20/11) Intemational Association of Commercial Administrators (IACA)
eventattribution

TAG quote and deposit invoice dated5 September2023.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 7 of 145 PagelD# 2141 QUOTE THIN AIR BEAR for the long haul 09-05-23 4196 Center Park Orive Thin Air Gear Mike Brown B16 896 5656 Cell Colorado Springs CO 80916 mikr@thinairgear com TO Catalyst Machineworks/Cyberlux SHIP TO: 6710 Spring Steubner Rd, Suite 709 Catalyst Machineworks/Cyberlux PMB 103 6710 Spring Steubner Rd, Suite 709 Spnng. TX 77389 PM8 103 Attn. Rick Tucker Spring, TX 77389 Attr: Rick Tucker to Days SHIPPING METHOD SHIPPING TERMS SHIPPING DATE PAYMENT TERMS DUE DATE Truck FOB: Colorado 13 10, Ne: 30 ASAP QTY ПТЕМ В DESCRIPTION UNIT PRICE DISCOUNT LINE TOTAL Wheeled Drone Kit Bag (Prototype/Sampie DRWTK OCP Approved) Acce crated Ramp Up Production 400 $399.00 5159,600.00 Units in 30 days From PO/Deposit Receipt 1,700 DRWTK-OCP Wheeled Drone Kit Bag (Prototype/Sample Standard Production - 200 Units Every Two Approved) $379.00 Weeks After Accelerated Production $644.300.00 Additional Assembly - Recelve Faam 2,100 Inserts; Store; Install; Ship Individual $40.00 Boxes on Pallets Standard Pallet Shipping Included Bags Only 1. Deposit Required to Release All Materials - $150,000.00 2. We will Invoice Per Shipment 3. Terms 1%-N10, N30 $84,000.00 4. Deposit Credit Will Be Applied to Last 400 Shipped and Invoiced DISCOUNT TOTAL SUBTOTAL $887,900.00 SALES TAX TOTAL $887,900.00 Estimated delivery times quoted above begin after recept of Purchase Order and $.130, 900.00 0 sit To accept this quotation, sign here and return to mike@thinalrgear. cor THANK YOU FOR YOUR BUSINESS! TAG-0005 [Own-image correction: deposit required $150,000.00; total $887,900.00. Acceptance line bears an unidentified signature mark.]
eventattribution

California AW/SC filing and acknowledgment.

Read the anchor · page 68
Case 3:25-cV-00483-JAG Document 165-1 Filed 04/15/26 Page 68 of 145 PagelD# 2202 U230074215520 STATE OF CALIFORNIA Office of the Secretary of State EXHIBIT For Office Use Only -FILED- 1500 11th Street California Secretary of State Sacramento, California 95814 No.: U230074215520 (916) 653-3516 Date Filed: 10/20/2023 Submitter Information: Contact Name Eric M. Lemmer, Esq. Organization Name Arlington Law Group Phone Number (703) 842-3025 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 Richmona, 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, (i) any and all furniture, fixtures, attachments, accessions, accessories, fittings, tools, parts, supplies and commingled goods relating to any of the foregoing property, (iii) any and all additions, replacements of and substitutions for all or any part of any of the foregoing property, (iv) any and ali insurance proceeds relating to any of the foregoing property, (v) any and al goodwill relating to any of the foregoing property, Communications, Inc. and (vi) in the case of Debtor Cyberlux Corporation, all subsidiaries of such Debtor, including without limitation Datron World 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
eventattribution

Legalist financing face uses27 March2024.

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Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 25 of 145 PagelD# 2159 Docusign Envelope: ID: A39ABOEF-BE15-4B0B-8FEF-542FC1B5F558 SECOND AMENDED AND RESTATED GOVERNMENT local tax requirements not later than the forty fifth (45th) PURCHASE ORDER FINANCING AGREEMENT day after the end of each calendar quarter) that Borrower This Second Amended and Restated Government Purchase Order keeps in the ordinary course of business in accordance Financing Agreement ("Agreement) is made effective as of accepted accounting principles March 27, 2024 by and between Legalist SPV III, LP ("Lender) consistently applied, and Borrower shall certify that all and Cyberlux Corporation and Datron World Communications, information contained therein is and shall be true and Inc. (each and together, "Borrower"). correct ("Quarterly Reporting Obligation). addition to any Quarterly Reporting Obligation, Lender hereby agrees to provide Borrower the services specified Borrower further agrees to provide Lender with a copy in this Agreement and establishes for a period extending one year of the Borrower's books and records otherwise due in from the date hereof (the "Facility Maturity Date") a revolving connection with any Quarterly Reporting Obligation line of credit for Borrower in the aggregate maximum principal promptly upon demand at any time upon reasonable amount of $7,000,000 (the "Credit Limit"). notice to Borrower. ACCOUNTS MANAGEMENT By or before fifteen (15) days after the last business day Borrower shall, before execution of any agreement with of each month, Lender shall provide to Borrower a monthly report a government-related customer (including any prime contractor to (each a 'Loan Report") detailing the current state of Borrower's such a customer) (each, a "Government Account Debtor") in account with Lender based upon documentation then provided by connection with which Borrower desires Lender to provide Borrower to Lender, including balance, individual transactions, financing under this Agreement, provide to Lender the then-available loan amount under the Credit Limit, and related Government Account Debtor's contact information, material information. Borrower shall notify Lender within five (S) days of evidencing any contract with the Goverment Account Debtor, delivery if it disputes any part of a Loan Report. The Loan Report and other information that may be requested. Lender may conduct shall be deemed correct and binding upon Borrower and shall due diligence of such Government Account Debtor. Lender may constitute an account stated between the parties hereto unless establish or modify a maximum credit limit for any Government Lender receives Borrower's written statement of exceptions Account Debtor, without waiving its right at any subsequent time within five (5) days after Borrower's receipt of same. to terminate or modify any prior acceptance. Borrower agrees that all invoices to Government 2. Borrower shall provide to Lender by or before fifteen Account Debtors shall designate Borrower as the sole named (15) days after the last business day of each month: payee together with the following wiring instructions (as Borrower may update from time to time): a. Details of all obligations (including, but not limited to, invoices, aging reports, and related information) of Bank: Silicon Valley Bank Government Account Debtors; Account Name: Legalist SPV III, LP Account No: I b. Details of all accounts payable obligations of Borrower ABA No: relating thereto; Borrower further agrees that all payments made c. A completed Borrowing Base Certificate in the form hereunder shall be made pursuant to the foregoing wire attached as Exhibit A; instructions only. Lender is unable to accept payment by check. d. If applicable, a completed Request for Disbursement in If any payment on an Eligible Purchase Order is received the form attached as Exhibit B; and by Borrower, it shall: e. Such other information as Lender may reasonably a. Hold such payment irrevocably in trust for Lender, request (collectively, an "Information Request"). separate and apart from Borrower's own funds; 3. Borrower warrants and guarantees, by submission of an Deliver such payment within one (1) business day to Advance Request, that: Lender pursuant to the wire instructions contained in a. The services described therein were (or, as applicable, Section 5 hereinabove; and shall be) in fact rendered and that the Eligible Purchase Immediately notify the payee in writing to send future Orders (defined below) evidenced thereby are and will payments to Lender pursuant to such wire instructions. continue to be genuine, bona fide, and collectable and without right of offset, counterclaim, or right of return or Borrower shall designate Lender as a point of contact cancellation; and with all Government Account Debtors and execute all authorizations or other documents requested to establish and b. If it is notified of any dispute, or of any right of offset, maintain Lender's authority to accept, endorse, and deposit all counterclaim, or right of return or cancellation against Government Account Debtor remittances to its own bank account. any Government Account Debtor's obligation to Borrower hereby appoints Lender its agent for the purpose of Borrower, it will immediately notify Lender in writing. executing all such authorizations and other documents. In addition to Borrower's obligation to provide a ADVANCES; COMPENSATION TO LENDER monthly Information Request to Lender, Borrower hereby agrees that it shall also furnish Lender with full Upon Lender's receipt of a request for disbursement, by financial statements (expressly including proof of and through the submission of the Request for Disbursement form payment and/or compliance with all federal, state and/or attached as Exhibit B, current accounts receivable aging, current LEGALIST_000001
eventattribution

Modification4 excerpt states26 February2025 effective date.

Read the anchor · page 145
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 145 of 145 PagelD# 2279 Case 4:25-ev-01689 Document 1-2 Filed on 04/11/25 in TXSD Page 2 of 9 CONFIDENTIAL INFORMATION Page 1 of 8 REDACTED Mission Technologies Modification No. 4 to Subcontract No. P000043846 To Effectuate a Terminotion Settlement This Modification No. 4 to Effectuate a Termination Settlement (the "Agreement"), effectiye as of February 26, 2025, is made by and between HII Mission Technologies Corp. ("HI"), a Delaware company with offices locatea at 8350 Broad St., Suite 1400, McLean, VA 22102, and Cyberlux Corporation (Cyberlux)y a Nevada company with offices located at 800 Park Offices Drive, Suite 3209, Research Triangle Park, NÇ 27709 (each a "Party," and collectively, "the Parties"). WHEREAS, the Parties entered into Subcontract No. P000043846, doted Augyst 29, 2023 (the "Subcontract"). issued under HII's Prime Tosk Order 47QFCA22F0039 and Technical Direction Lefter 1-023 (ITDL 231) supporting the Department of the Navy and the General Services Administration, Federal Systems Integration and Management Center (each and collectively, the "Government"); WHEREAS, on December 22, 2023, the Government issued a Stop-Work Order on the TDL 23 work scope, and HIl in turn issued a Stop-Work Order on the Subcontract to Cyberlux (the SWO"); WHEREAS, the Government terminted the TDL 23 work scope Yor convenience on May 13, 2024, and HIl subsequently exercised the termintion provisions of Subcontract Section 32.1 on May 17, 2024; and WHEREAS, Cyberlux has asserted entitlement to payment under Subcontract Section 32.1, and following negotiation, the Parties now wish to resolve any disagreement and reach a settlement. NOW, THEREFORE, in consideration of the mutual covenants and agreements exchanged herein and other good and valuable consideration, the Parties age as follows: 1. Review and Approval. a. The Parties acknowledge that pursuant to FAR 49.108-3, the Government expects HIl to submit a subcontractor settlementato The Government Contracting Officer tor review and opproval. Accordingly, the Porties agree thot Sections 3 through 6 of this Agreement shall become effective and enforceable only if and when the Government Contracting Officer approves of the Agreement. Following execution of the Agreement, HIl will promptly submit the Agreement to the Government Contracting Officer as a contractor settlement. Thereofter, HIl will promptly notify Cyberlux if the Government Contracting Officer approves of the Agreement. The Parties shall cooperate in good faith, to gotain such approval. In furtherance of that effort, Cyberlux shall cooperate with any auditor other review directed or conducted by the Government in connection with its review of this Agreement, including by granting the Government or its designee access to all books, records, documents, and other information relating to the Subcontract. 2. Stand Still. During the period of the Government's review of the Agreement, neither Party shall file or otherwise pursue any judicial or other action for money damages against the other with respect to the Subcontract or termination, unless that Party first confers with the other in good faith to discuss options for resolution without such action. A division of HIl Issued by: Mission Technologies Commana Media HIl Proprietary
eventattribution

Financing/guaranty sections specify29 April2025 Second Amendment Date.

Read the anchor · page 31
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 31 of 145 PagelD# 2165 Docusign Envelope ID: A39AB0EF-BE15-4B0B-8FEF-542FC1B5F558 New York. The parties hereby irrevocably submit to the exclusive IN WITNESS WHEREOF, the undersigned have duly executed jurisdiction of such courts and waive any objection to the venue this Agreement as of the first date written above. or jurisdiction based on forum non conveniens or any other grounds. LENDER: The parties intend, and Borrower hereby acknowledges LEGALIST SEV III, LP and agrees, that this Agreement (including any and all obligations By to repay amounts advanced hereunder, whether principal, interest, Name: Brian T. Rice HOL.. fees, costs, or otherwise) constitutes an instrument for the Title: Authorized Signatory payment of money only, within the meaning of New York Civil Address: 58 West Portal Ave. #747 Practice Law and Rules ( CPLR) 3213. If Borrower fails to San Francisco, CA 94127 make any such payment when due under this Agreement, Lender Email: receivables(@legalist.com shall be entitled to move for relief under CPLR 3213, and Borrower expressly waives any defense thereunder except for BORROWER: proof of payment. CYBERLUX CORPORATION Service of any notice under this Agreement may occur Mark V. Semidt by electronic mail. Name: Mark D. Schmidt AUTHORITY AND EFFECTIVENESS Title: President and CEO Address: 800 Park Offices Dr., Ste. 3209 Borrower hereby represents that it is a duly authorized Research Triangle, NC 27709 and existing entity in good standing under the laws of the Email: mschmidt@cyberlux.com jurisdiction of organization set forth on the signature page. The execution, delivery, and performance hereof and the other Jurisdiction of Organization: documents hereby contemplated are, and shall remain, within North Carolina Borrower's powers, have been duly authorized, and are not in contravention of any law, rule, or regulation, or the terms of any contract, agreement or undertaking to which Borrower is a party DA RAN 9. SEMMUNICATIONS, INC. or by which it is bound. Name: Mark D. Schmidt MISCELLANEOUS Title: 38. Each party represents to the other parties that it (a) has Address: 995 Joshua Way, Ste. A read this agreement, (b) has been represented in the preparation, Vista, CA 92081 negotiation. and execution of this Agreement by legal counsel of Email: mschmidt@cyberlux.com the party's own choice or has voluntarily declined to seek such Jurisdiction of Organization: counsel; (c) understands the terms and consequences of this California Agreement; and (d) is fully aware of the legal and binding effect of this Agreement. This agreement supersedes all prior or contemporaneous agreements and understandings between the parties, verbal or written, express or implied, relating to the subject matter hereof. 4/29/2025 _ (the "Second Amendment Date"), that certain Amended and Restated Government Purchase Order Financing Agreement dated March 27, 2024 by and between Legalist SPV III, LP and Cyberlux Corporation and Datron World Communications, Inc. shall be amended, restated, and superseded in its entirety by this Agreement. LEGALIST 000007
eventattribution

Arbogast complaint verification before Oregon notary.

Read the anchor · page 110
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 110 of 145 PagelD# VERIFICATION Tim Arbogast, being first duly sworn, deposes and says that he is the CFO of Advanced Navigation and Positioning Corporation, a Delaware corporation, and, as such, he is authorized to make this oath; that he has read the foregoing and attached Verified Complaint, and that the same is true of his own personal knowledge except those matters Advanced Navigation and Positioning Corporation OFFICIAL STAMP Emily Joyce NOTARY PUBLIC - OREGON By: Tim Arbogast ›, CFO STATE OF COUNTY OF Personally appeared before me, Tim Arbogast, either being personally known to me or proven by satisfactory evidence (said-evidence being ), and acknowledged that he signed the foregoing document. This the 5 _day of June → 2025. OFFICIAL STAMP Notary Publid, MI уБоусе Emily Joyce NOTARY PUBLIC - OREGON (Type or Print Name) MY COMMISSION EXPIRES MAY 13, 2029 COMMISSION NO. 1058184 My commission expires: May 13,2029 (Notary Seal) 6 ANPC_00012 [Own-image correction: verification is on personal knowledge except those matters stated upon information and belief, which he believes to be true. Tim Arbogast signed before Oregon notary Emily Joyce on5 June2025.]
eventattribution

Colorado TAG default judgment.

Read the anchor · page 19
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 19 of 145 PagelD# 2153 Case No. 1:25-CV-00805-GPG-MDB Document 27 filed 08/29/25 USDC Colorado pg 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 25-cv-00805-GPG-MDB THIN AIR GEAR, LLC, Plaintiff, V. CYBERLUX CORPORATION d/b/a CATALYST MACHINEWORKS, LLC, Defendant. FINAL JUDGMENT In accordance with the orders filed during the pendency of this case, and pursuant to Federal Rule of Civil Procedure 58(a), the following Final Judgment is hereby entered. Pursuant to the [D. 26] Order entered by Judge Gordon P. Gallagher on August 29, 2025, it is ORDERED that the Recommendation of the United States Magistrate Judge Maritza Dominquez Braswell [D. 25] is AFFIRMED and ADOPTED as an Order of the Court. It is FURTHER ORDERED that Plaintiff's Motion for Entry of Default Judgment [D. 18] is GRANTED, It is FURTHER ORDERED that the parties proposed Order Granting Stipulation for Final Judgment [D. 21] is DENIED AS MOOT. It is FURTHER ORDERED that Plaintiff is awarded $1,224,275.14 in damages. It is FURTHER ORDERED that judgment is entered in favor of Plaintiff and against Defendant. This case is closed. TAG-0003
inferenceinference

The compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC shar

The compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC share a claim, historic satisfied amounts coexist with later stock liability, interest dates vary, and receiver fees remain contingent.

inferenceinference

Gonzalez calls Exhibit 14 a true copy of Modification 4, but the physical exhibit ends after page 1 of 8. Its approval and records-access cl

Gonzalez calls Exhibit 14 a true copy of Modification 4, but the physical exhibit ends after page 1 of 8. Its approval and records-access clauses are readable; the missing seven pages prevent treating it as a complete settlement instrument.

inferenceinference

TAG has direct judgment evidence, while its only-manufacturer comparison remains a party proposition. ANPC equipment allegations and other s

TAG has direct judgment evidence, while its only-manufacturer comparison remains a party proposition. ANPC equipment allegations and other service-based claims require separate tracing before accepting an exclusive goods-supplier conclusion.

inferenceinference

The financing record distinguishes a 2024 agreement base from a 2025 restatement and forbearance. Blank eligibility schedules cannot demonst

The financing record distinguishes a 2024 agreement base from a 2025 restatement and forbearance. Blank eligibility schedules cannot demonstrate that a particular terminated order qualified or that each later advance satisfied the conditions.

inferenceinference

Ordinary advances listed by Legalist sum to $6,950,000; the protective entries sum to $3,100,100.10, which reconciles to $3,083,639.75 after

Ordinary advances listed by Legalist sum to $6,950,000; the protective entries sum to $3,100,100.10, which reconciles to $3,083,639.75 after its stated $16,460.35 fee allocation. The adjustment prevents counting the same fee as additional principal.

inferenceinference

The entered AW orders control the source record of order dates:18 December 2025 and 5 February 2026. The response contains conflicting year/

The entered AW orders control the source record of order dates:18 December 2025 and 5 February 2026. The response contains conflicting year/day references; preserve its wording while indexing the actual entered orders separately.

inferenceinference

ANPC total $3,087,878.86 equals its $2,830,050 principal plus $257,828.86 interest, rather than the reported $2,926,814.39 judgment plus tha

ANPC total $3,087,878.86 equals its $2,830,050 principal plus $257,828.86 interest, rather than the reported $2,926,814.39 judgment plus that interest. A dated calculation must establish whether the earlier $96,764.39 is embedded, replaced or inadvertently omitted.

inferenceinference

WeShield and the three investment claimants state separate balances totalling $5,007,138.41. Their 19 February introduction conflicts with 9

WeShield and the three investment claimants state separate balances totalling $5,007,138.41. Their 19 February introduction conflicts with 9 March calculations; the total is a computation of asserted balances, not an allowed claim.

inferenceinference

Fairwinds expressly disclaims any lien/assignment/security interest in this response. Its reported promise of payment from HII funds should

Fairwinds expressly disclaims any lien/assignment/security interest in this response. Its reported promise of payment from HII funds should not silently be promoted to an asserted perfected security right.

inferenceinference

Receiver possession and efforts to deliver goods are separate from fee allowance. His quoted discretionary 33% ceiling and asserted 25% enti

Receiver possession and efforts to deliver goods are separate from fee allowance. His quoted discretionary 33% ceiling and asserted 25% entitlement do not establish an entered award; an expanded consortium remains conditional on court action.

otherattribution

Complete supplied 145-page source reviewed at SHA-256 ddc018f1afaa2dd5127c26acb4e0bd13eb7aeae4a456fceccf442c9d5bc43390. Source assertions, o

Complete supplied 145-page source reviewed at SHA-256 ddc018f1afaa2dd5127c26acb4e0bd13eb7aeae4a456fceccf442c9d5bc43390. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Own ECF165-1 file read in full, preserving physical1–145 and embedded exhibit/Bates identities. Fourteen image-only dividers and the bag photograph were inspected; financial forms, redactions, execution blocks, UCC fields and disputed handwritten dates were checked on52 own page images. Image corrections are additive with original text preserved. No other version supplied missing pages or converted blank schedules into completed records. Exhibit4/5 judgment duplication and California acknowledgment repetition are one underlying record each. Cross-source overlap is not counted as independent corroboration.

Read the anchor · page 1
Case 3:25-cv-00483-JAG Document 165-1 Filed 04/15/26 Page 1 of 145 PagelD# 2135 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Plaintiff, Case No. 3:25-cv-483 V. CYBERLUX CORP., et al., Defendants. DECLARATION OF ANTHONY R. GONZALEZ 1, Anthony R. Gonzalez, declare as follows: I am over the age of 18 and competent to make this Declaration. I have personal knowledge of the facts stated in this Declaration. 2. I am the 65% Member of Thin Air Gear, LLC ('TAG") and I submit this Declaration in support of TAG's Motion for Summary Judgment, supporting Memorandum of Law, and other related filings. TAG's Contract With Cyberlux On September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). A true and correct copy of Contract (TAG 0005-6) is attached hereto as Exhibit 1. These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract between Cyberlux and Plaintiff HII Mission Technologies Corp.'s 1
questionquestion

Which entered priority rulings, satisfactions and dated payoff calculations reconcile the creditors without counting AW and SC or historical

Which entered priority rulings, satisfactions and dated payoff calculations reconcile the creditors without counting AW and SC or historical balances twice?

questionquestion

Where are Legalist's completed eligible-order schedules, actual requests, HII creditor certification and proof of assignment notice, particu

Where are Legalist's completed eligible-order schedules, actual requests, HII creditor certification and proof of assignment notice, particularly for the 2025 protective advances?

questionquestion

What original ANPC judgment and interest ledger reconcile the $96,764.39 already included in the judgment with the later $257,828.86 interes

What original ANPC judgment and interest ledger reconcile the $96,764.39 already included in the judgment with the later $257,828.86 interest claim?

questionquestion

Were the receiver's proposed all-creditor expansion and fee award entered, and which consortium members authorised the proposed allocation?

questionquestion

Where are Modification 4 pages 2–8, the signed execution copy and the government approval record, and which sections became enforceable on w

Where are Modification 4 pages 2–8, the signed execution copy and the government approval record, and which sections became enforceable on what date?

questionquestion

Which corporate formation records reconcile North Carolina descriptions in TAG/Legalist documents with Nevada descriptions in ANPC and Modif

Which corporate formation records reconcile North Carolina descriptions in TAG/Legalist documents with Nevada descriptions in ANPC and Modification 4?

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.

Gonzalez declares personal knowledge as a 65% member of Thin Air Gear (TAG), submitting this evidence for TAG in EDVA 3:25-cv-00483-JAG. He is not making this declaration for ARG. The docket identifies ECF 165-1 filed 15 April 2026.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
ANPC's 9 March 2026 response claims $3,087,878.86 and reports a 21 July 2025 judgment of $2,926,814.39,24 September fieri facias and 8 October garnishment of HII. It asserts equitable assignment of receipts allegedly spent on other programmes; the judgment and writ originals are not attached within Exhibit 10.supportsANPC total $3,087,878.86 equals its $2,830,050 principal plus $257,828.86 interest, rather than the reported $2,926,814.39 judgment plus that interest. A dated calculation must establish whether the earlier $96,764.39 is embedded, replaced or inadvertently omitted.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Attached borrowing-base certificate, disbursement request and Eligible Purchase Orders schedule are blank forms/placeholders. No completed borrowing calculation, requested sum or attached eligible contract appears on these pages; blank no-default certifications are not actual submissions.supportsWhere are Legalist's completed eligible-order schedules, actual requests, HII creditor certification and proof of assignment notice, particularly for the 2025 protective advances?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The group claims WeShield $3,905,541.64 ($2,916,760 principal/$988,781.64 interest), Roman $576,436.03 ($430,497.41/$145,938.62), MAS $215,062.95 ($160,614.60/$54,448.35) and Sinensky $310,097.79 ($231,589.09/$78,508.70), stated through 9 March 2026.supportsWeShield and the three investment claimants state separate balances totalling $5,007,138.41. Their 19 February introduction conflicts with 9 March calculations; the total is a computation of asserted balances, not an allowed claim.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The actual consent final order follows the 16 December 2025 hearing and is entered 18 December 2025. It awards $6 m jointly plus $25,250.50 and 6% interest, dismisses with prejudice, and relies on receiver authority despite disputes. Quash is denied without ruling on defendants' standing to challenge notice or appellate rights.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Modification 4 section 1 makes sections 3–6 effective/enforceable only upon government contracting-officer approval; HII undertakes submission/notification and Cyberlux cooperation/access to books and records. Section 2 requires good-faith conferral before money-damages proceedings during review. Missing pages prevent this excerpt establishing the settlement amount, signatures, approval or complete obligations.supportsGonzalez calls Exhibit 14 a true copy of Modification 4, but the physical exhibit ends after page 1 of 8. Its approval and records-access clauses are readable; the missing seven pages prevent treating it as a complete settlement instrument.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Receiver says an expanded receivership could settle about 20 litigations for several dozen creditors, conditional on Harris County approval. He asserts possession of drones from as early as 16 January 2025, no later than 22 May, delivery to HII and resulting registry proceeds; those causal assertions remain his position.supportsReceiver possession and efforts to deliver goods are separate from fee allowance. His quoted discretionary 33% ceiling and asserted 25% entitlement do not establish an entered award; an expanded consortium remains conditional on court action.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
AW and Secure Community jointly respond on 9 March 2026, describing AW as SC's sole owner and their claims as the same obligation rather than additive recoveries. They trace the debt to intellectual-property acquisition and the 15 June 2023 settlement, with a separate contingent stock claim.supportsThe compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC share a claim, historic satisfied amounts coexist with later stock liability, interest dates vary, and receiver fees remain contingent.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Berleth responds as Texas-appointed receiver, reserving privilege. He cannot quantify proceeds or final receiver fees because the Texas court has not fixed them. His response proposes representing a consortium beyond the interpleader parties, rather than identifying an entered all-creditor expansion.supportsReceiver possession and efforts to deliver goods are separate from fee allowance. His quoted discretionary 33% ceiling and asserted 25% entitlement do not establish an entered award; an expanded consortium remains conditional on court action.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
WeShield, Roman Investments, MAS as Rosewood assignee, and Sinensky reserve privilege, confidentiality, burden and supplementation objections. Introductory text says dollar figures as of 19 February 2026 while later text and calculations repeatedly use 9 March 2026; both date statements remain visible.supportsThe compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC share a claim, historic satisfied amounts coexist with later stock liability, interest dates vary, and receiver fees remain contingent.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Forbearance temporarily increases the credit limit by $5.3 m to $12.3 m and charges $53,000 in three instalments. Advances require approved use and HII creditor certification directing all HII payments to Legalist. Weekly 13-week cash forecasts/variance reports are required; expiry restores the $7 m limit and makes obligations due. No default waiver is given.supportsThe financing record distinguishes a 2024 agreement base from a 2025 restatement and forbearance. Blank eligibility schedules cannot demonstrate that a particular terminated order qualified or that each later advance satisfied the conditions.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Fairwinds claims $2,348,542 under 3 October 2022 teaming and 7 June 2023 service/supply agreements: prime role or 8% of first 1,000 drones if another prime chosen. It says Schmidt's 8 July 2025 invoice-backed spreadsheet acknowledged the amount and promised payment from remaining HII proceeds. These are Fairwinds' statements about Cyberlux's acknowledgement.supportsFairwinds expressly disclaims any lien/assignment/security interest in this response. Its reported promise of payment from HII funds should not silently be promoted to an asserted perfected security right.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist describes principal as $6.95 m ordinary advances plus $3,083,639.75 protective advances; it claims 1 April 2024 UCC priority in Nevada/North Carolina for the 27 March financing and continuing interest. Legal fees total $351,632.29.supportsOrdinary advances listed by Legalist sum to $6,950,000; the protective entries sum to $3,100,100.10, which reconciles to $3,083,639.75 after its stated $16,460.35 fee allocation. The adjustment prevents counting the same fee as additional principal.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
AW/SC say the first judgment/related collection was fully satisfied, including $1,444,543.11 garnishment proceeds and $952,601.71 principal/fees plus Texas costs. Their separate later stock-related $6 m claim remains asserted; satisfaction of the original case is not a release of every later claim.supportsThe compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC share a claim, historic satisfied amounts coexist with later stock liability, interest dates vary, and receiver fees remain contingent.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Signed Instrument of Assignment assigns accounts identified in an enclosed notice, covers unpaid amounts, names one assignee, prohibits further assignment and invokes 48 CFR 32.805. Rice and Schmidt signatures appear; this page alone supplies no actual account schedule or proof of notice delivery.supportsThe financing record distinguishes a 2024 agreement base from a 2025 restatement and forbearance. Blank eligibility schedules cannot demonstrate that a particular terminated order qualified or that each later advance satisfied the conditions.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
ANPC alleges the customer had paid Cyberlux by 20 December and the sum became due 30 December; a 15 May demand was unfulfilled. It seeks $2,926,814.39 including $96,764.39 interest at 8%. This attachment is a complaint, not the later judgment.supportsANPC total $3,087,878.86 equals its $2,830,050 principal plus $257,828.86 interest, rather than the reported $2,926,814.39 judgment plus that interest. A dated calculation must establish whether the earlier $96,764.39 is embedded, replaced or inadvertently omitted.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Exhibit 14 contains only printed page 1 of 8 of Modification 4, effective 26 February 2025, reproduced from TXSD 4:25-cv-01689 ECF 1-2. It recites 29 August 2023 subcontract,22 December 2023 stop work, government termination 13 May 2024 and HII termination 17 May 2024 under section 32.1.supportsThe financing record distinguishes a 2024 agreement base from a 2025 restatement and forbearance. Blank eligibility schedules cannot demonstrate that a particular terminated order qualified or that each later advance satisfied the conditions.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Receiver says an expanded receivership could settle about 20 litigations for several dozen creditors, conditional on Harris County approval. He asserts possession of drones from as early as 16 January 2025, no later than 22 May, delivery to HII and resulting registry proceeds; those causal assertions remain his position.supportsWere the receiver's proposed all-creditor expansion and fee award entered, and which consortium members authorised the proposed allocation?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
ANPC's 9 March 2026 response claims $3,087,878.86 and reports a 21 July 2025 judgment of $2,926,814.39,24 September fieri facias and 8 October garnishment of HII. It asserts equitable assignment of receipts allegedly spent on other programmes; the judgment and writ originals are not attached within Exhibit 10.supportsWhat original ANPC judgment and interest ledger reconcile the $96,764.39 already included in the judgment with the later $257,828.86 interest claim?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist lists ordinary 2024 advances:9 April $1.8 m;19 April $500,000;2 May $500,000;26 June $142,000;5 July $53,000;16 July $2.5 m;2 August $650,000;27 August $535,000;3 October $150,000 and $120,000. The own image resolves the malformed OCR of the $150,000 entry.supportsOrdinary advances listed by Legalist sum to $6,950,000; the protective entries sum to $3,100,100.10, which reconciles to $3,083,639.75 after its stated $16,460.35 fee allocation. The adjustment prevents counting the same fee as additional principal.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
ANPC's attached verified complaint describes Cyberlux as Nevada-incorporated and alleges equipment/services including two tactical landing systems, guidance systems, trailer, documents and spares. It says the first three of five milestones were paid and final milestones totalled $2,830,050 on 20 December 2024.supportsANPC total $3,087,878.86 equals its $2,830,050 principal plus $257,828.86 interest, rather than the reported $2,926,814.39 judgment plus that interest. A dated calculation must establish whether the earlier $96,764.39 is embedded, replaced or inadvertently omitted.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Signed Instrument of Assignment assigns accounts identified in an enclosed notice, covers unpaid amounts, names one assignee, prohibits further assignment and invokes 48 CFR 32.805. Rice and Schmidt signatures appear; this page alone supplies no actual account schedule or proof of notice delivery.supportsWhere are Legalist's completed eligible-order schedules, actual requests, HII creditor certification and proof of assignment notice, particularly for the 2025 protective advances?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Receiver claims at least 25% and up to 33% of collected funds, expenses exceeding $550,000, and a judicial lien from 16 January 2025, invoking quoted appointment-order provisions. He states fees/expenses have not been ruled on and claims no interest. Quoted discretionary may-award 33% language is distinct from his asserted entitlement to 25%.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
WeShield attributes the Ukrainian drone opportunity to its 12 July 2022 exclusive development agreement, founders' charity work and introductions. It says 4 April 2025 settlement compromised commissions to $2.5 m plus 240 m restricted shares, Cyberlux failed to pay, and liquidated damages followed. Underlying confidential agreements are cited but absent from this response.supportsTAG has direct judgment evidence, while its only-manufacturer comparison remains a party proposition. ANPC equipment allegations and other service-based claims require separate tracing before accepting an exclusive goods-supplier conclusion.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist lists 3 June 2025 $2,755,100.10 and 9 June $345,000, explaining that the $3,100,100.10 initial advance less $16,460.35 applied to legal fees equals $3,083,639.75 protective principal. Response cites LEGALIST 000001–20 and is served 9 March 2026; Exhibit 6 here contains only 000001–14.supportsOrdinary advances listed by Legalist sum to $6,950,000; the protective entries sum to $3,100,100.10, which reconciles to $3,083,639.75 after its stated $16,460.35 fee allocation. The adjustment prevents counting the same fee as additional principal.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Colorado ECF 27, dated 29 August 2025, adopts the magistrate judge's recommendation, grants the default motion, denies the proposed stipulated final order as moot, awards TAG $1,224,275.14 and closes the case. Exhibits 4 and 5 reproduce the same judgment; Exhibit 5 adds a clerk certification stamp.supportsTAG has direct judgment evidence, while its only-manufacturer comparison remains a party proposition. ANPC equipment allegations and other service-based claims require separate tracing before accepting an exclusive goods-supplier conclusion.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
AW/SC claim $6 m plus $25,250.50 fees and $352.92 costs, six-percent interest/$986.30 per day from 5 February 2026, and 6 July 2023 priority. Their account refers to 18 December 2023 liquidation and 2 February 2026 reaffirmance in places, while attached entered orders show 18 December 2025 and 5 February 2026.supportsWhich entered priority rulings, satisfactions and dated payoff calculations reconcile the creditors without counting AW and SC or historical balances twice?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
AW/SC claim $6 m plus $25,250.50 fees and $352.92 costs, six-percent interest/$986.30 per day from 5 February 2026, and 6 July 2023 priority. Their account refers to 18 December 2023 liquidation and 2 February 2026 reaffirmance in places, while attached entered orders show 18 December 2025 and 5 February 2026.supportsThe compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC share a claim, historic satisfied amounts coexist with later stock liability, interest dates vary, and receiver fees remain contingent.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
AW/SC say the first judgment/related collection was fully satisfied, including $1,444,543.11 garnishment proceeds and $952,601.71 principal/fees plus Texas costs. Their separate later stock-related $6 m claim remains asserted; satisfaction of the original case is not a release of every later claim.supportsWhich entered priority rulings, satisfactions and dated payoff calculations reconcile the creditors without counting AW and SC or historical balances twice?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Receiver claims at least 25% and up to 33% of collected funds, expenses exceeding $550,000, and a judicial lien from 16 January 2025, invoking quoted appointment-order provisions. He states fees/expenses have not been ruled on and claims no interest. Quoted discretionary may-award 33% language is distinct from his asserted entitlement to 25%.supportsThe compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC share a claim, historic satisfied amounts coexist with later stock liability, interest dates vary, and receiver fees remain contingent.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist's Second Amended and Restated Government Purchase Order Financing Agreement names Cyberlux and Datron as borrowers. Its face says effective 27 March 2024; section 40 expressly supplies the Second Amendment Date 29 April 2025. These are distinct date roles, not two newly proved funding dates.supportsThe financing record distinguishes a 2024 agreement base from a 2025 restatement and forbearance. Blank eligibility schedules cannot demonstrate that a particular terminated order qualified or that each later advance satisfied the conditions.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Gonzalez asserts TAG is the only interpleader claimant that actually manufactured and sold goods used in the subcontract. That comparative assertion is his position, not an adjudication of every competing claimant's performance.supportsTAG has direct judgment evidence, while its only-manufacturer comparison remains a party proposition. ANPC equipment allegations and other service-based claims require separate tracing before accepting an exclusive goods-supplier conclusion.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Colorado ECF 27, dated 29 August 2025, adopts the magistrate judge's recommendation, grants the default motion, denies the proposed stipulated final order as moot, awards TAG $1,224,275.14 and closes the case. Exhibits 4 and 5 reproduce the same judgment; Exhibit 5 adds a clerk certification stamp.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
ANPC's attached verified complaint describes Cyberlux as Nevada-incorporated and alleges equipment/services including two tactical landing systems, guidance systems, trailer, documents and spares. It says the first three of five milestones were paid and final milestones totalled $2,830,050 on 20 December 2024.supportsWhich corporate formation records reconcile North Carolina descriptions in TAG/Legalist documents with Nevada descriptions in ANPC and Modification 4?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Modification 4 section 1 makes sections 3–6 effective/enforceable only upon government contracting-officer approval; HII undertakes submission/notification and Cyberlux cooperation/access to books and records. Section 2 requires good-faith conferral before money-damages proceedings during review. Missing pages prevent this excerpt establishing the settlement amount, signatures, approval or complete obligations.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Berleth responds as Texas-appointed receiver, reserving privilege. He cannot quantify proceeds or final receiver fees because the Texas court has not fixed them. His response proposes representing a consortium beyond the interpleader parties, rather than identifying an entered all-creditor expansion.supportsThe compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC share a claim, historic satisfied amounts coexist with later stock liability, interest dates vary, and receiver fees remain contingent.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Exhibit 14 contains only printed page 1 of 8 of Modification 4, effective 26 February 2025, reproduced from TXSD 4:25-cv-01689 ECF 1-2. It recites 29 August 2023 subcontract,22 December 2023 stop work, government termination 13 May 2024 and HII termination 17 May 2024 under section 32.1.supportsWhich corporate formation records reconcile North Carolina descriptions in TAG/Legalist documents with Nevada descriptions in ANPC and Modification 4?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The actual consent final order follows the 16 December 2025 hearing and is entered 18 December 2025. It awards $6 m jointly plus $25,250.50 and 6% interest, dismisses with prejudice, and relies on receiver authority despite disputes. Quash is denied without ruling on defendants' standing to challenge notice or appellate rights.supportsThe entered AW orders control the source record of order dates:18 December 2025 and 5 February 2026. The response contains conflicting year/day references; preserve its wording while indexing the actual entered orders separately.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Gonzalez identifies fourteen exhibits, executes the declaration under penalty of perjury on 14 April 2026, and counsel certifies service on 15 April. His authentication of attached copies does not turn the opposing creditors' contentions into personal knowledge of their underlying transactions.supportsGonzalez calls Exhibit 14 a true copy of Modification 4, but the physical exhibit ends after page 1 of 8. Its approval and records-access clauses are readable; the missing seven pages prevent treating it as a complete settlement instrument.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
ANPC's attached verified complaint describes Cyberlux as Nevada-incorporated and alleges equipment/services including two tactical landing systems, guidance systems, trailer, documents and spares. It says the first three of five milestones were paid and final milestones totalled $2,830,050 on 20 December 2024.supportsTAG has direct judgment evidence, while its only-manufacturer comparison remains a party proposition. ANPC equipment allegations and other service-based claims require separate tracing before accepting an exclusive goods-supplier conclusion.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The group claims WeShield $3,905,541.64 ($2,916,760 principal/$988,781.64 interest), Roman $576,436.03 ($430,497.41/$145,938.62), MAS $215,062.95 ($160,614.60/$54,448.35) and Sinensky $310,097.79 ($231,589.09/$78,508.70), stated through 9 March 2026.supportsWhich entered priority rulings, satisfactions and dated payoff calculations reconcile the creditors without counting AW and SC or historical balances twice?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Section 9.9 acknowledges continuing defaults notified on 4 November 2024 and 31 March 2025. Borrowers agree the two default charges combine to 9.5% annually, compounded/capitalised monthly. Forbearance is limited to existing defaults for 90 days from the Second Amendment Date unless an earlier new default intervenes.supportsThe financing record distinguishes a 2024 agreement base from a 2025 restatement and forbearance. Blank eligibility schedules cannot demonstrate that a particular terminated order qualified or that each later advance satisfied the conditions.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Fairwinds says the sum became liquidated around 8 July 2025 and expressly answers none to security/lien/assignment, interest and attorney fees; secured-advance dates are not applicable. It cites Fairwinds 0001–0132, not appended here. Thomas Wirth verifies based on existing/discovered records subject to error, with counsel-assisted preparation.supportsFairwinds expressly disclaims any lien/assignment/security interest in this response. Its reported promise of payment from HII funds should not silently be promoted to an asserted perfected security right.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
WeShield, Roman Investments, MAS as Rosewood assignee, and Sinensky reserve privilege, confidentiality, burden and supplementation objections. Introductory text says dollar figures as of 19 February 2026 while later text and calculations repeatedly use 9 March 2026; both date statements remain visible.supportsWeShield and the three investment claimants state separate balances totalling $5,007,138.41. Their 19 February introduction conflicts with 9 March calculations; the total is a computation of asserted balances, not an allowed claim.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Forbearance temporarily increases the credit limit by $5.3 m to $12.3 m and charges $53,000 in three instalments. Advances require approved use and HII creditor certification directing all HII payments to Legalist. Weekly 13-week cash forecasts/variance reports are required; expiry restores the $7 m limit and makes obligations due. No default waiver is given.supportsWhere are Legalist's completed eligible-order schedules, actual requests, HII creditor certification and proof of assignment notice, particularly for the 2025 protective advances?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
TAG's Colorado complaint names Cyberlux doing business as Catalyst, pleads jurisdiction/venue and describes Cyberlux as a North Carolina corporation. That organisational description differs from the Nevada description in later attached records.supportsWhich corporate formation records reconcile North Carolina descriptions in TAG/Legalist documents with Nevada descriptions in ANPC and Modification 4?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist's 9 March 2026 response claims $13,204,742.88: $10,033,639.75 principal, $2,653,970.84 interest, $112,500 commitment fees, $53,000 forbearance fee, $312,959.79 paid legal fees and $38,672.50 unpaid legal fees. These are creditor computations, not an allowed distribution.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The reconsideration order denies the 2 January 2026 motion, leaves the prior ruling standing, terminates suspension and dispenses with the 24 February hearing. The own image of entry reads 2/5/2026, not the 2 February date elsewhere in the creditor response.supportsThe entered AW orders control the source record of order dates:18 December 2025 and 5 February 2026. The response contains conflicting year/day references; preserve its wording while indexing the actual entered orders separately.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Agreement addresses insurance/tax duties, notices and assignment, applies New York law and exclusive venue, and invokes CPLR 3213 with a payment defence retained. Brian T. Rice signs for Legalist and Mark D. Schmidt for Cyberlux/Datron; the signature page describes Cyberlux's organisation as North Carolina and Datron's as California.supportsWhich corporate formation records reconcile North Carolina descriptions in TAG/Legalist documents with Nevada descriptions in ANPC and Modification 4?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Attached borrowing-base certificate, disbursement request and Eligible Purchase Orders schedule are blank forms/placeholders. No completed borrowing calculation, requested sum or attached eligible contract appears on these pages; blank no-default certifications are not actual submissions.supportsThe financing record distinguishes a 2024 agreement base from a 2025 restatement and forbearance. Blank eligibility schedules cannot demonstrate that a particular terminated order qualified or that each later advance satisfied the conditions.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist lists 3 June 2025 $2,755,100.10 and 9 June $345,000, explaining that the $3,100,100.10 initial advance less $16,460.35 applied to legal fees equals $3,083,639.75 protective principal. Response cites LEGALIST 000001–20 and is served 9 March 2026; Exhibit 6 here contains only 000001–14.supportsWhere are Legalist's completed eligible-order schedules, actual requests, HII creditor certification and proof of assignment notice, particularly for the 2025 protective advances?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist's 9 March 2026 response claims $13,204,742.88: $10,033,639.75 principal, $2,653,970.84 interest, $112,500 commitment fees, $53,000 forbearance fee, $312,959.79 paid legal fees and $38,672.50 unpaid legal fees. These are creditor computations, not an allowed distribution.supportsThe compilation supplies creditor-specific claim history and direct instruments, but it cannot be summed into a clean debt total: AW/SC share a claim, historic satisfied amounts coexist with later stock liability, interest dates vary, and receiver fees remain contingent.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
ANPC claims priority 24 September 2025 or 30 December 2024 under its equitable-assignment theory, interest of $257,828.86 and no attorney fees. It characterises unpaid delivery as an effective 30 December advance, not a documented cash loan. The response's interest discussion needs reconciliation with its stated judgment and principal.supportsANPC total $3,087,878.86 equals its $2,830,050 principal plus $257,828.86 interest, rather than the reported $2,926,814.39 judgment plus that interest. A dated calculation must establish whether the earlier $96,764.39 is embedded, replaced or inadvertently omitted.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The group claims WeShield $3,905,541.64 ($2,916,760 principal/$988,781.64 interest), Roman $576,436.03 ($430,497.41/$145,938.62), MAS $215,062.95 ($160,614.60/$54,448.35) and Sinensky $310,097.79 ($231,589.09/$78,508.70), stated through 9 March 2026.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Receiver cites Berleth 0001–1328 as appointment/receivership production, with response and service 9 March 2026. This 145-page compilation does not append that 1328-page production. Service list identifies creditor counsel; it supplies neither allowed claims nor consortium consent.supportsWere the receiver's proposed all-creditor expansion and fee award entered, and which consortium members authorised the proposed allocation?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist's 9 March 2026 response claims $13,204,742.88: $10,033,639.75 principal, $2,653,970.84 interest, $112,500 commitment fees, $53,000 forbearance fee, $312,959.79 paid legal fees and $38,672.50 unpaid legal fees. These are creditor computations, not an allowed distribution.supportsWhich entered priority rulings, satisfactions and dated payoff calculations reconcile the creditors without counting AW and SC or historical balances twice?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Berleth responds as Texas-appointed receiver, reserving privilege. He cannot quantify proceeds or final receiver fees because the Texas court has not fixed them. His response proposes representing a consortium beyond the interpleader parties, rather than identifying an entered all-creditor expansion.supportsWere the receiver's proposed all-creditor expansion and fee award entered, and which consortium members authorised the proposed allocation?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Receiver claims at least 25% and up to 33% of collected funds, expenses exceeding $550,000, and a judicial lien from 16 January 2025, invoking quoted appointment-order provisions. He states fees/expenses have not been ruled on and claims no interest. Quoted discretionary may-award 33% language is distinct from his asserted entitlement to 25%.supportsWhich entered priority rulings, satisfactions and dated payoff calculations reconcile the creditors without counting AW and SC or historical balances twice?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Fairwinds claims $2,348,542 under 3 October 2022 teaming and 7 June 2023 service/supply agreements: prime role or 8% of first 1,000 drones if another prime chosen. It says Schmidt's 8 July 2025 invoice-backed spreadsheet acknowledged the amount and promised payment from remaining HII proceeds. These are Fairwinds' statements about Cyberlux's acknowledgement.supportsTAG has direct judgment evidence, while its only-manufacturer comparison remains a party proposition. ANPC equipment allegations and other service-based claims require separate tracing before accepting an exclusive goods-supplier conclusion.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
ANPC alleges the customer had paid Cyberlux by 20 December and the sum became due 30 December; a 15 May demand was unfulfilled. It seeks $2,926,814.39 including $96,764.39 interest at 8%. This attachment is a complaint, not the later judgment.supportsWhat original ANPC judgment and interest ledger reconcile the $96,764.39 already included in the judgment with the later $257,828.86 interest claim?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Exhibit 14 contains only printed page 1 of 8 of Modification 4, effective 26 February 2025, reproduced from TXSD 4:25-cv-01689 ECF 1-2. It recites 29 August 2023 subcontract,22 December 2023 stop work, government termination 13 May 2024 and HII termination 17 May 2024 under section 32.1.supportsWhere are Modification 4 pages 2–8, the signed execution copy and the government approval record, and which sections became enforceable on what date?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Exhibit 14 contains only printed page 1 of 8 of Modification 4, effective 26 February 2025, reproduced from TXSD 4:25-cv-01689 ECF 1-2. It recites 29 August 2023 subcontract,22 December 2023 stop work, government termination 13 May 2024 and HII termination 17 May 2024 under section 32.1.supportsGonzalez calls Exhibit 14 a true copy of Modification 4, but the physical exhibit ends after page 1 of 8. Its approval and records-access clauses are readable; the missing seven pages prevent treating it as a complete settlement instrument.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Receiver claims at least 25% and up to 33% of collected funds, expenses exceeding $550,000, and a judicial lien from 16 January 2025, invoking quoted appointment-order provisions. He states fees/expenses have not been ruled on and claims no interest. Quoted discretionary may-award 33% language is distinct from his asserted entitlement to 25%.supportsWere the receiver's proposed all-creditor expansion and fee award entered, and which consortium members authorised the proposed allocation?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Modification 4 section 1 makes sections 3–6 effective/enforceable only upon government contracting-officer approval; HII undertakes submission/notification and Cyberlux cooperation/access to books and records. Section 2 requires good-faith conferral before money-damages proceedings during review. Missing pages prevent this excerpt establishing the settlement amount, signatures, approval or complete obligations.supportsWhere are Modification 4 pages 2–8, the signed execution copy and the government approval record, and which sections became enforceable on what date?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
AW/SC claim $6 m plus $25,250.50 fees and $352.92 costs, six-percent interest/$986.30 per day from 5 February 2026, and 6 July 2023 priority. Their account refers to 18 December 2023 liquidation and 2 February 2026 reaffirmance in places, while attached entered orders show 18 December 2025 and 5 February 2026.supportsThe entered AW orders control the source record of order dates:18 December 2025 and 5 February 2026. The response contains conflicting year/day references; preserve its wording while indexing the actual entered orders separately.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Receiver claims at least 25% and up to 33% of collected funds, expenses exceeding $550,000, and a judicial lien from 16 January 2025, invoking quoted appointment-order provisions. He states fees/expenses have not been ruled on and claims no interest. Quoted discretionary may-award 33% language is distinct from his asserted entitlement to 25%.supportsReceiver possession and efforts to deliver goods are separate from fee allowance. His quoted discretionary 33% ceiling and asserted 25% entitlement do not establish an entered award; an expanded consortium remains conditional on court action.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
ANPC claims priority 24 September 2025 or 30 December 2024 under its equitable-assignment theory, interest of $257,828.86 and no attorney fees. It characterises unpaid delivery as an effective 30 December advance, not a documented cash loan. The response's interest discussion needs reconciliation with its stated judgment and principal.supportsWhat original ANPC judgment and interest ledger reconcile the $96,764.39 already included in the judgment with the later $257,828.86 interest claim?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Fairwinds says the sum became liquidated around 8 July 2025 and expressly answers none to security/lien/assignment, interest and attorney fees; secured-advance dates are not applicable. It cites Fairwinds 0001–0132, not appended here. Thomas Wirth verifies based on existing/discovered records subject to error, with counsel-assisted preparation.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
AW and Secure Community jointly respond on 9 March 2026, describing AW as SC's sole owner and their claims as the same obligation rather than additive recoveries. They trace the debt to intellectual-property acquisition and the 15 June 2023 settlement, with a separate contingent stock claim.supportsWhich entered priority rulings, satisfactions and dated payoff calculations reconcile the creditors without counting AW and SC or historical balances twice?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
ANPC's 9 March 2026 response claims $3,087,878.86 and reports a 21 July 2025 judgment of $2,926,814.39,24 September fieri facias and 8 October garnishment of HII. It asserts equitable assignment of receipts allegedly spent on other programmes; the judgment and writ originals are not attached within Exhibit 10.supportsWhat does this Gonzalez filing establish about the interpleader claims?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%

WEIGH

Explained weighting

A score appears only when its components and change threshold are published.

No published WEIGH run

The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.