Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
quotationattribution
Schmidt calls customer and representative impact unacceptable and acknowledges missed shipments/customer delivery issues.
Read the anchor · page 26
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Case 3:25-cv-00483-JAG Document 163-1
Filed 04/09/26 Page 65 of 69 PageID#
From: Mark Schmidt <mschmidt@cyberlux.com>
Sent: Wednesday, July 2, 2025 3:49 PM
To: Bill Maadarani <bmaadarani@cyberlux.com>
Subject: Re: Bill's exit path
Brother, I've been trying find words to express my remorse over this situation and have failed to find any that are
adequate. I can say my relationship with you, both our professional and our friendship, is one of the most important
ones I've had in my life, period. What we've done and the times we've had will be the highlights I will always
remember, no matter what. I truly hope we can find a path forward that works for you.
The impact on customers and our reps is unacceptable - I have been dying inside over this and its impact across the
company should have never happened. Between HII and Legalist, we have been pushed into this corner and have to
fight our way out, fighting all our enemies.
I don't want to leave anything to chance if we can find a path forward. Anything is on the table, other than Denis back
coming in:
• Retention bonus ($1M over next four quarters)
• Base salary increase to $250K with revised commission structure, TBD
• Notes and commissions paid out of HII money asap
• Position of President if you want that now
• Board of Directors? You should likely wait until we have D&O insurance soon then join
• Co-share all decision-making between you, me and Chris plus Loren on cash
• Ultimately well bring in a new CEO and I'll move to Chairman as soon as we can execute a strategic plan like
the one I've attached from Roman V - where we uplist to NASDAQ for example, including changing the
Cyberlux name. Roman also has Trump ties and we will get significant Trump-universe board membership.
We are talking to good capital partners now and you need to understand the environment and future. Loren is ready to
discuss at any point. I have attached the cash flow worksheet from Loren that gives you the operating detail. Loren is
available for discussion whenever you have time.
I know you have a dire outlook and I understand. I'm not sure who is advising you, but we are making meaningful
progress, and anyone on our team is available to discuss specifics. Attached is the Stay on the receiver and a Cease
and Desist that effectively ends him. This was done over the last 2 days and clears up the matter significantly, with
only what the receiver will be paid per the upcoming court decision. We were never in 'receivership' as I said, and
now this receiver is boxed up. I have the lead attorney, Jeff Brown, standing by to speak with you about the whole
situation so you have the full picture.
All this is unacceptable I know. We've not been paid by HII per the contract modification, Legalist has reneged on the
new loan agreement, and lawyers have made mistakes, all that led to where we are. All I know to do is fight our
enemies every day like I am, to resolve the critical matters as fast as possible. You should never have to address this
kind of situation with customers and reps. I will work a plan with you for the reps where we make the commission
payments and pay bonuses where you decide, for the missed shipments and customer delivery issues. I will do
whatever is necessary to correct these issues.
observationobservation
California25CU062277C default entered23December2025; no money judgment shown.
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CIV-100
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO: 281510 FOR COURT USE ONLY name: Howard D. Ruddell
FIRM NAME: Moore Ruddell LLP
STREET ADDRESS: 21250 Hawthorne Blvd., Suite 500
city: Torrance STATE: CA ZIP CODE: 90503 ELECTRONICALLY FILED
TELEPHONE NO.: 310-792-7010 FAX NO.: Superior Court of California, E-MAIL ADDRESS: hruddell@mooreruddell.com County of San Diego
ATTORNEY FOR (name): Plaintiff Bilal Maadarani 12/23/2025 2:32:23 PM
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO
STREETADDRESS: 330 West Broadway Clerk of the Superior Court MAILING ADDRESS: 330 West Broadway By J. Siharath ,Deputy Clerk
CITY AND ZIP CODE: San Diego, CA 92101
BRANCH NAME: Hall of Justice
Plaintiff/Petitioner: Bilal Maadarani Defendant/Respondent: Datron World Communications, Inc. CASE NUMBER: REQUEST FOR Entry of Default Clerk's Judgment 25CU062277C
(Application) Court Judgment Not for use in actions under the Fair Debt Buying Practices Act (Civ. Code, 1788.50 et seq.); (see form CIV-105)
1. TO THE CLERK: On the complaint or cross-complaint
filed
a. on (date): November 19, 2025
b. by (name): Plaintiff Bilal Maadarani
c. [x] Enter default of defendant (names): Datron World Communications, Inc.
d. CI request court judgment under Code of Civil Procedure sections 585(b), 585(c), 989, etc., against defendant
(names):
(Testimony required. Apply to the clerk for hearing date, unless the court will enter judgment on an affidavit under Code Civ. Proc., 585(d).) e. [] Enter clerk's judgment
(1) for restitution of the premises only and issue writ of execution on the judgment. Code of Civil Procedure section
1174(c) does not apply. (Code Civ. Proc., 1169.) Include in the judgment all tenants, subtenants, named claimants, and other occupants of the premises. The Prejudgment Claim of Right
to Possession was served in compliance with Code of Civil Procedure section
415.46.
(2) under Code of Civil Procedure section 585(a). (Complete the declaration under Code Civ. Proc., 585.5 on the
reverse (item 5).)
(3)
for default previously entered on (date): 2. Judgment
to be entered. Amount Credits acknowledged Balance
a. Demand of complaint b. Statement of damages"
(1) Special
(2) General
c. Interest d. Costs (see reverse) e. Attorney fees
f. TOTALS
g. Daily damages were demanded in complaint at the rate of: per day beginning (date):
(* Personal
injury or wrongful death actions; Code Civ. Proc., 425.11.) 3. (Check if filed 1in an unlawful detainer case.) Legal document assistant or unlawful detainer assistant information is on the
reverse (complete item 4).
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF)
Date: December 23, 2025 Howard D. Ruddell
FOR COURT (1) Default entered as requested on (date): 12/23/2025 USE ONLY (2) Default NOT entered as requested (state reason): Clerk,
J. Siharath by Deputy Page of
Form Adopted for Mandatory Use REQUEST FOR ENTRY OF DEFAULT
Code of Civil Procedure, §§ 585-587, 1169
Judicial Council of California courts.ca.gov CIV-100 [Rev. January 1, 2023} (Application to Enter Default)
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 37 of 69 PageID#
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[EDVA163-1 page69, filed9April2026. Visible redactions preserved.]
Standard Transfer Company,440 East400 South Suite200 Salt Lake City UT84111,phone8015718844,fax8013284058,Standardtransferco.com.
BILL MAADARANI [address redacted]. CYBERLUX CORPORATION PREFERRED B 0. Acct#:10. ACCOUNT STATEMENT As of10/21/2025.
RESTRICTED BOOK SHARES SUMMARY: RESTRICTED3,000,000.
BOOK-ENTRY SHARES SUMMARY: Free Trading Book-Entry Shares0; Restricted Book-Entry Shares3,000,000; Total Book-Entry Shares3,000,000.
OUTSTANDING SHARES SUMMARY: Book Shares3,000,000.0000; Total Shares3,000,000.0000.
Price Per Share As of10/21/2025,Market Value of Holdings,Cost Basis($): redacted.
TAX LOT DETAIL: Certificate# blank;Acquired02/28/2024;Disposed blank;Lot Shares3,000,000.0000;Basis/Share redacted;Total Cost($)redacted;Gift/Inher blank;Gift Date blank;Gift FMV($)blank. Total lot shares3,000,000;totalcost redacted. Page1.
claimallegation
EDVA171-1 filed15April2026 is a72-page compilation supporting Maadarani: intervention pleading with contract/email/share statement,OTC certi
EDVA171-1 filed15April2026 is a72-page compilation supporting Maadarani: intervention pleading with contract/email/share statement,OTC certification,14April affidavit,repeated July emails,default entry and California complaint with contract. Exact native text excluding stamps matches64mapped pages of accepted163-1; embedded image pixels match except a counsel signature image recompression on currentpage7,visually checked. Copies retain common lineage.
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EXHIBIT 1
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 1 of 72 PageID# 2552
claimallegation
Maadarani’s California complaint25CU062277C filed19November2025 sues Datron and Does1–20 for contract/wage/expense/waiting-time relief. It a
Maadarani’s California complaint25CU062277C filed19November2025 sues Datron and Does1–20 for contract/wage/expense/waiting-time relief. It alleges632,599.48 unpaid:275,000 signing bonus,59,107.66 salary through12November,193,491.82 commissions through30September,20,000 expenses and85,000 fringe benefits; plus20,769 penalties,fees and interest. These are pleaded demands, not awarded amounts.
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MOORE RUDDELL LLP
Bonita D. Moore (SBN 221479) bmoore@mooreruddell.com
Howard D. Ruddell (SBN 281510) hruddell@mooreruddell.com
21250 Hawthorne Blvd., Suite 500 Torrance, CA 90503
Telephone: (310) 792-7010
Fax: (323)530-1113
Attorneys for Plaintiff Bilal Maadarani
ELECTRONICALLY FILED
Superior Court of California, County of San Diego
11/19/2025 3:18:59 PM
Clerk of the Superior Court By M. Acevedo ,Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN DIEGO CENTRAL
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12
13
14 Case No. 25CU062277C
COMPLAINT FOR:
(1) BREACH OF CONTRACT
(2) FAILURE TO PAY EARNED WAGES
(3) FAILURE TO REIMBURSE BUSINESS EXPENSES
BILAL MAADARANI, an individual,
Plaintiff,
DATRON WORLD
COMMUNICATIONS, INC., California Corporation; and DOES 1-20, Defendants.
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(4) WAITING TIME PENALTIES
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COMPLAINT; DEMAND FOR JURY TRIAL
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 12 of 69 PageID#
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claimallegation
The complaint alleges10October2025 breach notice with30days to cure, no response, and12November resignation for good reason. It alleges Datr
The complaint alleges10October2025 breach notice with30days to cure, no response, and12November resignation for good reason. It alleges Datron directed residence in Beirut, whereas the intervention pleading describes Michigan residence; different dates/context do not by themselves establish a false statement.
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- 2 -
COMPLAINT; DEMAND FOR JURY TRIAL
FACTUAL ALLEGATIONS APPLICABLE TO ALL CAUSES OF ACTION
6. Mr. Maadarani was hired as Datron’s Chief Revenue Officer on October 8,
2023.1
7. Pursuant to the terms of his Employment Agreement, Mr. Maadarani’s
“Initial Term” of employment lasted two years – until October 8, 2025 – and thereafter the
Agreement automatically extends for successive periods of one year, unless either party
provides written notice of its intention not to extend the Agreement.
8. Mr. Maadarani was offered a signing bonus of $525,000 (of which $275,000
remains outstanding and past due), an annual salary of $180,000 paid no less frequently
than monthly, a 1.0% commission on all direct sales, and an annual bonus based on a
$20M of booked sales eligibility threshold. In addition, Mr. Maadarani was entitled to
equity awards, fringe benefits, employee benefits, and paid vacation.
9. Mr. Maadarani dedicated the last two years of his life to Datron and
believed strongly in Datron’s ability to succeed and grow.
10. Datron – at the direction of its Chief Executive Officer Mark Schmidt and
Board Members David Downing and John Ringo – has failed to pay Mr. Maadarani the
compensation he has earned over the past two years and, despite multiple requests for
payment to be made in full, Respondent has refused to do so.
11. Mr. Maadarani is owed compensation of $632,599.48, not including
penalties, interest, and/or attorneys’ fees. The figure is broken down as follows:
a. Unpaid signing bonus: $275,000
b. Unpaid salary through November 12, 2025: $59,107.66
c. Unpaid commissions through September 30, 2025: $193,491.82
d. Unreimbursed business expenses: $20,000
e. Unpaid fringe benefits incl. corporate car fees and moving expenses:
$85,000
1
Plaintiff was previously the Director of Sales for Datron before it was acquired in 2023.
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 51 of 72 PageID#
2602
claimallegation
The8October2023 agreement is between Datron World Communications,Inc. and Bilal Maadarani, credits service since18August2008 and appoints Co
The8October2023 agreement is between Datron World Communications,Inc. and Bilal Maadarani, credits service since18August2008 and appoints CompanyGroup CRO reporting to parent Cyberlux CEO. It bears both DocuSign signatures. Two-year initial term renews annually absent30-day notice; October2023 signing bonus525,000 and annual salary180,000 are subject to stated conditions. Parent reporting does not itself make Cyberlux the named employer/signatory.
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Employment Agreement
This Employment Agreement (the “Agreement”) is made and entered into as of October
8, 2023, by and between Bilal Maadarani (the “Executive”) resident at
, and Datron World Communications, Inc., a corporation organized
under the laws of the State of California, with an address at 995 Joshua Way, Suite A, Vista,
California 92081 (the “Company”, and together with affiliates of the Company, the “Company
Group”).
WHEREAS, the Executive has been an employee of the Company and the Company
desires to continue to employ the Executive on the terms and conditions set forth herein; and
WHEREAS, the Executive desires to be employed by the Company and provide services
to the Company Group on such terms and conditions;
NOW, THEREFORE, in consideration of the mutual covenants, promises, and
obligations set forth herein, the parties agree as follows:
1. Term. Subject to Section 5 of this Agreement, the Executive’s initial term of
employment hereunder shall be from the period beginning on October 8, 2023 (the “Effective
Date”); provided that for all purposes where tenure with the Company is considered, the
Executive shall be deemed to have been in the continuous employ of the Company since August
18, 2008. Unless earlier terminated as provided herein, Executive’s initial employment term will
be for a period of two (2) years (the “Initial Term”); and thereafter the Agreement shall be
deemed to be automatically extended, upon the same terms and conditions, for successive
periods of one year, unless either party provides written notice of its intention not to extend the
term at least 30 days prior to any anniversary of the Effective Date falling on or after the second
anniversary of the Effective Date. The period during which the Executive is employed by the
Company hereunder is hereinafter referred to as the “Employment Term.”
2. Position and Duties.
2.1 Position. During the Employment Term, the Executive shall serve as the Chief
Revenue Officer of the Company Group, reporting to the Chief Executive Officer (the “CEO”) of the Company’s parent company, Cyberlux Corporation, a corporation organized
under the laws of the State of Nevada, with an address at 800 Park Offices Drive, Suite
3209, Research Triangle Park, NC 27709 (“Cyberlux”). In such position, the Executive
shall have such duties, authority, and responsibilities at the Company Group as are
established from time to time by the CEO, consistent with the Executive’s position.
2.2 Duties. During the Employment Term, the Executive shall devote all of the
Executive’s business time and attention to the performance of the Executive’s duties
hereunder and will not engage in any other business, profession, or occupation for
compensation or otherwise, without the prior written consent of the CEO.
3. Place of Performance. The principal place of Executive’s employment shall be in the
Company’s headquarters currently located at the address set forth above in Vista, California. The
Executive may work remotely from the Executive’s residence in the United States; provided that
claimallegation
Commission is earned on booked sales subject to365-day non-effectuation clawback and defined adjusted commissionable amount deducting produc
Commission is earned on booked sales subject to365-day non-effectuation clawback and defined adjusted commissionable amount deducting production/development,returns,discounts,freight,taxes and service costs. Direct/FMS regional rates are1%,other directors’ bookings0.5%. Exclusions include training/engineering/repair/warranty,amount below5,001 or25%gross,house/unfunded orders and absent CRM booking history; exceptions/strategic rates require approval. The complaint’s1%all-direct-sales summary omits these qualifications.
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2
if such residence is outside San Diego County, the Executive shall provide no less than 30 days
prior written notice of the anticipated work location. If permitting the Executive to work from
such location would require business license registration of the Company, or tax reporting by the
Company, the Executive shall be responsible for additional costs associated therewith. Subject to
any health or safety concerns related to the COVID-19 pandemic or other similar extraordinary
circumstances, unless mutually agreed between the Executive and the CEO, the Executive shall
be required to spend on average two days per week in the office, when not travelling for the
benefit of the Company Group. The Executive may be required to travel extensively on
Company Group business during the Employment Term. The place of performance of this
Agreement may be changed from time to time upon the mutual agreement of the Executive and
the Company. The Executive hereby consents to the principal place of performance hereunder
being changed to a location in Florida.
4. Compensation.
4.1 Signing Bonus. In recognition of the Executive’s willingness to commit to a
two-year Initial Term, the Company shall pay the Executive a one-time bonus in the amount
of $525,000.00, payable during the month of October, 2023 (the “Signing Bonus”). The
Executive understands and agrees that the Signing Bonus is directly related to his
undertaking to remain with the Company for the Initial Term, and is therefore subject to
clawback in the event of the Executive’s termination during the Initial Term for Cause, or
without Good Reason (each as defined below).
4.2 Base Salary. The Company shall pay the Executive an annual rate of base
salary of U.S.$180,000.00 in periodic installments in accordance with the Company’s
customary payroll practices and applicable wage payment laws, but no less frequently than
monthly. The Executive’s annual base salary, as in effect from time to time, is hereinafter
referred to as “Base Salary.” The Base Salary shall be paid net of any income and payroll
taxes to which such Base Salary is subject, and shall be paid by check denominated in U.S.
dollars or deposited into an account of the Executive maintained with a U.S. National
Association bank.
4.3 Commission. Commission shall be earned when sales are “booked” but shall
be subject to clawback to the extent such sales are not effected within 365 days of the date
booked.
(a) For each sale of Company Group products (the “Product”) sold the
Company shall pay the Executive a percentage commission on the Adjusted
Commissionable Sales Amount (as defined below) according to the Schedule of
Commissions set forth in Exhibit A hereto. For purposes hereof “Adjusted
Commissionable Sales Amount” shall mean the net sales price for each sale of a
Product, meaning the gross sale price for such Product, minus the sum of (i) the cost
of production of such Product, including any development costs allocated thereto, (ii)
the sales price of each Product unit returned to any Company Group member for credit
and the related costs of returning such Product to such company, (iii) discounts to
customers, (iv) freight and transportation costs (including insurance), (v) taxes, tariffs
and duties related to the sale of the Products and (vi) installation and service charges.
claimallegation
Payment schedule normally splits50% after90days and50% after240days; orders above5m permit initial instalments commencing after180days and r
Payment schedule normally splits50% after90days and50% after240days; orders above5m permit initial instalments commencing after180days and remaining payment proportionate to customer receipts, subject to mutual alternatives. Schedule bars advances and allocates regional transitions100/0,75/25,50/50,0/100 at1–30,31–90,91–180,180+days. No sales-level calculation substantiates the demanded commission total.
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3
(b) Commissions will not be earned in respect of training, engineering
services, repair or warranty orders or any order the Adjusted Commissionable Sales
Amount of which is (i) less than US$5,001.00 or (ii) less than 25% of the gross sale
price of such product. In addition, “House Accounts” and unfunded orders shall not be
eligible for commission. No commissions shall be earned in respect of any booked
order that was not previously included in the Company Group’s CRM funnel or
forecast prior to booking will not be eligible. Any exceptions to the limitations set
forth in the immediately preceding three sentences shall be in the sole discretion of
applicable member of the Company Group and shall require the approval the CEO,
and the acknowledgement of the Executive.
(c) The Company Group reserves the right to designate specific accounts
or sales opportunities as “Strategic Accounts” or “House Accounts”. Commission
rates in respect of such accounts shall be determined in the sole discretion of the
applicable member of the Company Group and will be identified in writing. Any
commission to be paid in respect of any Strategic Account shall require the approval
the CEO, and the acknowledgement of the Executive.
(d) Earned commissions shall be payable to the Executive on the following
schedule:
(i) 50% no later than second payroll period of the fiscal month
following 90 days after the original booking date; and
(ii) 50% on the second payroll of the fiscal moth following 240
days after the original booking date; provided that,
(iii) In respect of orders with an Adjusted Commissionable Sales
Amount in excess of US$5,000,000.00, the first 50% shall be payable at the
election of the Company in equal instalments on the normal payroll dates for a
period not to exceed five (5) months, and commencing no later than the second
payroll period of the month following 180 days after original booking date;
and
(iv) the balance of such commission will be paid pro-rata to
amounts received by the applicable member of the Company Group from the
applicable customer, until the applicable commission is paid in full (i.e. if the
customer pays US$100,000.00, and the applicable Adjusted Commissionable
Sales Amount thereof is $60,000.00, and the Executive’s commission rate in
respect of such sale is 1%, the Company shall pay US$600.00 to the
Executive) in the second normal payroll period following receipt thereof by the
applicable member of the Company Group.
Notwithstanding the foregoing, the Company and the Executive may mutually agree to
alternative commission payment schedules in respect of any order or any customer.
4.1 Annual Bonus.
claimallegation
Bonus eligibility is discretionary with2023threshold20mbooked sales and employment on payment day; equity is plan-dependent; expenses follow
Bonus eligibility is discretionary with2023threshold20mbooked sales and employment on payment day; equity is plan-dependent; expenses follow policy. Termination preserves accrued amounts, differentiates pre/post initial-term treatment, conditions early severance on release, and imposes clawback where applicable. GoodReason requires notice within10days,at least30days cure and termination within30days of first grounds; application to alleged chronology is unresolved.
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(a) The Executive shall be eligible to receive an annual bonus (the “Annual Bonus”). However, the decision to provide any Annual Bonus and the
amount and terms of any Annual Bonus shall be in the sole and absolute discretion of
the CEO, in consultation with the Company and other members of the Company
Group (collectively, the “Compensation Committee”). To the extent that Cyberlux or
the Company establishes a compensation committee of the board of directors of such
Company, such committee, together with the CEO (if not a member thereof) shall for
purposes hereof be the “Compensation Committee”). Each year an eligibility
threshold shall be set by the Compensation Committee. For 2023, the Executive’s
Annual Bonus eligibility threshold is set at $20,000,000.00 of booked sales.
(b) In order to be eligible to receive an Annual Bonus, the Executive must
be employed by the Company on the date that Annual Bonuses are paid by the
Company.
4.2 Equity Awards. During the Employment Term, the Executive shall be eligible
to participate in any employee or executive equity awards program, subject to the terms of
the applicable plan, as determined by the Board or the Compensation Committee, in its
discretion.
4.3 Fringe Benefits and Perquisites. During the Employment Term, the Executive
shall be entitled to fringe benefits and perquisites consistent with those provided to similarly
situated executives of the Company.
4.4 Employee Benefits. During the Employment Term, the Executive shall be
entitled to participate in all employee benefit plans, practices, and programs maintained by
the Company, as in effect from time to time (collectively, “Employee Benefit Plans”) to the
extent consistent with applicable law and the terms of the applicable Employee Benefit
Plans. The Company reserves the right to amend or terminate any Employee Benefit Plans at
any time in its sole discretion, subject to the terms of such Employee Benefit Plan and
applicable law.
4.5 Vacation; Paid Time Off. During the Employment Term, the Executive shall
be entitled to [ten (10)] of paid vacation days per calendar year (prorated for partial years) in
accordance with the Company’s vacation policies, as in effect from time to time. The
Executive shall receive other paid time off in accordance with the Company’s policies for
executive officers as such policies may exist from time to time and as required by applicable
law.
4.6 Business Expenses. The Executive shall be entitled to reimbursement for all
reasonable and necessary out-of-pocket business, and travel expenses incurred by the
Executive in connection with the performance of the Executive’s duties hereunder in
accordance with the Company’s expense reimbursement policies and procedures.
4.7 Indemnification. The Company shall indemnify and hold the Executive
harmless as contemplated by the Company’s bylaws for acts and omissions in the
Executive’s capacity as an officer, director, or employee of the Company.
claimallegation
The agreement preserves Company IP/confidentiality,injunctive relief and cooperation; JAMS binding arbitration and jury waiver coexist with
The agreement preserves Company IP/confidentiality,injunctive relief and cooperation; JAMS binding arbitration and jury waiver coexist with California enforcement venue and conditional Florida provisions. Amendments require signed writing/CEO approval; tax409A,assignment,notice,representations,withholding/survival clauses remain. The California jury demand does not show adjudication or waiver of arbitration.
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(c) the applicable date of termination, which shall be no less than thirty
(30) days following the date on which the Notice of Termination is delivered if the
Company terminates the Executive’s employment without Cause; provided that, the
Company shall have the option to provide the Executive with a lump sum payment in
lieu of such notice.
5.6 Resignation of All Other Positions. Upon termination of the Executive’s
employment hereunder for any reason, the Executive shall be deemed to have resigned from
all positions that the Executive holds as an officer or member of the Board (or a committee
thereof) of the Company and any of its affiliates.
6. Confidential Information and Restrictive Covenants. As a condition of the Executive’s
continued employment with the Company:
(a) Ownership of Intellectual Property. The Executive acknowledges and
agrees that (a) as between the Company Group and the Executive, the Company (or
one of its affiliates, as applicable) owns all interests in any patents, trademarks,
copyrights, domain names, works of authorship, trade secrets, or any other intellectual
property (collectively, “Intellectual Property”) in or in respect of the Products and
(b) the Executive shall not acquire any ownership of Intellectual Property owned by or
licensed to the Company or any of its affiliates, under this Agreement. Representative
shall use the Company’s Intellectual Property solely for the purposes of performing its
obligations under this Agreement. All developments, inventions and other things in
which intellectual property rights may be asserted, developed by, or with input from
the Executive during the Employment Term, are solely the Intellectual Property rights
of the Company (to be used, transferred, licensed or otherwise exploited or not
exploited by the Company in its sole discretion).
(b) Non-Disclosure Obligation. The Executive affirms that (i) prior to the
Effective Date, he has, and (ii) on and after the Effective Date (both during the
Employment Term and thereafter) he agrees that he will, treat as confidential and
secret all information, discoveries, customer lists, trade secrets, documents, bids,
proposals, contracts, marketing plans and strategies, computer software, proprietary
computer hardware, pricing, pricing policies, financial information, and other
information and data made available to him during or prior to the Employment Term
that has not become public information, and that it will not, directly or indirectly,
make known, divulge or use any such information, discovery, secret, document, plan,
policy, or data, other than in accordance with this Agreement or as required by law.
The Executive affirms that (i) prior to the Effective Date, he has, and (ii) on and after
the Effective Date (both during the Employment Term and thereafter) he agrees that
he will comply with all Confidential Information and similar policies of the Company
as in effect from time to time.
(c) Injunctive Relief Availability. Notwithstanding the “Arbitration of
Disputes” Section of this Agreement, in the event of a breach or threatened breach by
the Executive of the provisions of this Section, the Company shall be entitled to an
injunction restraining the Executive from disclosing, in whole or in part, the
claimallegation
California clerk J.Siharath entered Datron’s default23December2025 on CIV100. Entry-of-default boxes are marked, judgment boxes and all mone
California clerk J.Siharath entered Datron’s default23December2025 on CIV100. Entry-of-default boxes are marked, judgment boxes and all money amounts blank. Ruddell signed the mailing declaration to Datron’s Vista address; cost and nonmilitary declaration fields are blank. This is an entered default, not a money judgment against Datron or Cyberlux.
Read the anchor · page 45
[Current171-1 page45; source67 counterpart page37 verified by exact comparison; historical stamps below retain origin.]
CIV-100
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO: 281510 FOR COURT USE ONLY name: Howard D. Ruddell
FIRM NAME: Moore Ruddell LLP
STREET ADDRESS: 21250 Hawthorne Blvd., Suite 500
city: Torrance STATE: CA ZIP CODE: 90503 ELECTRONICALLY FILED
TELEPHONE NO.: 310-792-7010 FAX NO.: Superior Court of California, E-MAIL ADDRESS: hruddell@mooreruddell.com County of San Diego
ATTORNEY FOR (name): Plaintiff Bilal Maadarani 12/23/2025 2:32:23 PM
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO
STREETADDRESS: 330 West Broadway Clerk of the Superior Court MAILING ADDRESS: 330 West Broadway By J. Siharath ,Deputy Clerk
CITY AND ZIP CODE: San Diego, CA 92101
BRANCH NAME: Hall of Justice
Plaintiff/Petitioner: Bilal Maadarani Defendant/Respondent: Datron World Communications, Inc. CASE NUMBER: REQUEST FOR Entry of Default Clerk's Judgment 25CU062277C
(Application) Court Judgment Not for use in actions under the Fair Debt Buying Practices Act (Civ. Code, 1788.50 et seq.); (see form CIV-105)
1. TO THE CLERK: On the complaint or cross-complaint
filed
a. on (date): November 19, 2025
b. by (name): Plaintiff Bilal Maadarani
c. [x] Enter default of defendant (names): Datron World Communications, Inc.
d. CI request court judgment under Code of Civil Procedure sections 585(b), 585(c), 989, etc., against defendant
(names):
(Testimony required. Apply to the clerk for hearing date, unless the court will enter judgment on an affidavit under Code Civ. Proc., 585(d).) e. [] Enter clerk's judgment
(1) for restitution of the premises only and issue writ of execution on the judgment. Code of Civil Procedure section
1174(c) does not apply. (Code Civ. Proc., 1169.) Include in the judgment all tenants, subtenants, named claimants, and other occupants of the premises. The Prejudgment Claim of Right
to Possession was served in compliance with Code of Civil Procedure section
415.46.
(2) under Code of Civil Procedure section 585(a). (Complete the declaration under Code Civ. Proc., 585.5 on the
reverse (item 5).)
(3)
for default previously entered on (date): 2. Judgment
to be entered. Amount Credits acknowledged Balance
a. Demand of complaint b. Statement of damages"
(1) Special
(2) General
c. Interest d. Costs (see reverse) e. Attorney fees
f. TOTALS
g. Daily damages were demanded in complaint at the rate of: per day beginning (date):
(* Personal
injury or wrongful death actions; Code Civ. Proc., 425.11.) 3. (Check if filed 1in an unlawful detainer case.) Legal document assistant or unlawful detainer assistant information is on the
reverse (complete item 4).
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF)
Date: December 23, 2025 Howard D. Ruddell
FOR COURT (1) Default entered as requested on (date): 12/23/2025 USE ONLY (2) Default NOT entered as requested (state reason): Clerk,
J. Siharath by Deputy Page of
Form Adopted for Mandatory Use REQUEST FOR ENTRY OF DEFAULT
Code of Civil Procedure, §§ 585-587, 1169
Judicial Council of California courts.ca.gov CIV-100 [Rev. January 1, 2023} (Application to Enter Default)
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 37 of 69 PageID#
2080
[Own image: Entry of Default and enter defendant default checked; clerk entered default12/23/2025 signed J.Siharath. Clerk/court judgment boxes unmarked; every judgment amount blank. Ruddell signature visible.]
claimallegation
The9April2026 intervention complaint seeks1,062,576.98 from the interpleaded funds plus fees/interest and access including sale authority to
The9April2026 intervention complaint seeks1,062,576.98 from the interpleaded funds plus fees/interest and access including sale authority to3mSeriesB. It alleges Cyberlux/Datron interchangeability,contract breach,Schmidt’s July admission and fiduciary breach. Its repetition of those allegations does not establish parent liability,priority or an entered distribution order.
Read the anchor · page 2
Page 1 of 7
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
__________________________________
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff
Case No. 3:25-cv-00483-JAG
v.
CYBERLUX CORP., et. al.,
Defendants.
___________________________________
COMPLAINT IN INTERVENTION OF MR. BILAL MAADARANI
COMES NOW, Mr. Bilal Maadarani, interpleader defendant/claimant, through his
undersigned counsel and states the following:
1. Mr. Maadarani asserts through this complaint his interest in the funds that plaintiff, HII
Mission Technologies Corp. (“HII”) has interpleaded in this case. Cyberlux Corporation
(“Cyberlux”) agreed to pay Mr. Maadarani’s salary, expenses, and commissions from his work
on the HII subcontract for K8 drones directly from the payment that HII has deposited with the
court. Mr. Maadarani has an interest in the interpleaded funds and seeks a judgment and payment
in satisfaction of that interest.
PARTIES
2. Claimant, Mr. Maadarani, is a shareholder of Cyberlux and its former Chief Revenue
Officer. He is a resident of the state of Michigan.
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 41 of 69 PageID#
2084
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 2 of 72 PageID# 2553
claimallegation
Standard Transfer Company’s21October2025 account statement for Bill Maadarani reports3mrestricted book-entry SeriesB,zero free-trading share
Standard Transfer Company’s21October2025 account statement for Bill Maadarani reports3mrestricted book-entry SeriesB,zero free-trading shares,3mtotal,acquisition28February2024; certificate-number field blank. Address,price/value/basis and cost fields are redacted. It documents recorded restricted holdings, not unrestricted sale authority,physical certificate possession or present transfer instructions.
Read the anchor · page 30
[Current171-1 page30; source67 counterpart page69 verified by exact comparison; historical stamps below retain origin.]
[EDVA163-1 page69, filed9April2026. Visible redactions preserved.]
Standard Transfer Company,440 East400 South Suite200 Salt Lake City UT84111,phone8015718844,fax8013284058,Standardtransferco.com.
BILL MAADARANI [address redacted]. CYBERLUX CORPORATION PREFERRED B 0. Acct#:10. ACCOUNT STATEMENT As of10/21/2025.
RESTRICTED BOOK SHARES SUMMARY: RESTRICTED3,000,000.
BOOK-ENTRY SHARES SUMMARY: Free Trading Book-Entry Shares0; Restricted Book-Entry Shares3,000,000; Total Book-Entry Shares3,000,000.
OUTSTANDING SHARES SUMMARY: Book Shares3,000,000.0000; Total Shares3,000,000.0000.
Price Per Share As of10/21/2025,Market Value of Holdings,Cost Basis($): redacted.
TAX LOT DETAIL: Certificate# blank;Acquired02/28/2024;Disposed blank;Lot Shares3,000,000.0000;Basis/Share redacted;Total Cost($)redacted;Gift/Inher blank;Gift Date blank;Gift FMV($)blank. Total lot shares3,000,000;totalcost redacted. Page1.
claimallegation
Bill Maadarani’s1July2025 email to Patrick Godfrey, copying Schmidt and Chris Barter, requests negotiated exit discussions covering commissi
Bill Maadarani’s1July2025 email to Patrick Godfrey, copying Schmidt and Chris Barter, requests negotiated exit discussions covering commissions, employment agreement, past salary, convertible notes/common stock, SeriesB access/sale and replacement training. It is an exit request, not the later November resignation.
Read the anchor · page 26
[Current171-1 page26; source67 counterpart page65 verified by exact comparison; historical stamps below retain origin.]
Case 3:25-cv-00483-JAG Document 163-1
Filed 04/09/26 Page 65 of 69 PageID#
From: Mark Schmidt <mschmidt@cyberlux.com>
Sent: Wednesday, July 2, 2025 3:49 PM
To: Bill Maadarani <bmaadarani@cyberlux.com>
Subject: Re: Bill's exit path
Brother, I've been trying find words to express my remorse over this situation and have failed to find any that are
adequate. I can say my relationship with you, both our professional and our friendship, is one of the most important
ones I've had in my life, period. What we've done and the times we've had will be the highlights I will always
remember, no matter what. I truly hope we can find a path forward that works for you.
The impact on customers and our reps is unacceptable - I have been dying inside over this and its impact across the
company should have never happened. Between HII and Legalist, we have been pushed into this corner and have to
fight our way out, fighting all our enemies.
I don't want to leave anything to chance if we can find a path forward. Anything is on the table, other than Denis back
coming in:
• Retention bonus ($1M over next four quarters)
• Base salary increase to $250K with revised commission structure, TBD
• Notes and commissions paid out of HII money asap
• Position of President if you want that now
• Board of Directors? You should likely wait until we have D&O insurance soon then join
• Co-share all decision-making between you, me and Chris plus Loren on cash
• Ultimately well bring in a new CEO and I'll move to Chairman as soon as we can execute a strategic plan like
the one I've attached from Roman V - where we uplist to NASDAQ for example, including changing the
Cyberlux name. Roman also has Trump ties and we will get significant Trump-universe board membership.
We are talking to good capital partners now and you need to understand the environment and future. Loren is ready to
discuss at any point. I have attached the cash flow worksheet from Loren that gives you the operating detail. Loren is
available for discussion whenever you have time.
I know you have a dire outlook and I understand. I'm not sure who is advising you, but we are making meaningful
progress, and anyone on our team is available to discuss specifics. Attached is the Stay on the receiver and a Cease
and Desist that effectively ends him. This was done over the last 2 days and clears up the matter significantly, with
only what the receiver will be paid per the upcoming court decision. We were never in 'receivership' as I said, and
now this receiver is boxed up. I have the lead attorney, Jeff Brown, standing by to speak with you about the whole
situation so you have the full picture.
All this is unacceptable I know. We've not been paid by HII per the contract modification, Legalist has reneged on the
new loan agreement, and lawyers have made mistakes, all that led to where we are. All I know to do is fight our
enemies every day like I am, to resolve the critical matters as fast as possible. You should never have to address this
kind of situation with customers and reps. I will work a plan with you for the reps where we make the commission
payments and pay bonuses where you decide, for the missed shipments and customer delivery issues. I will do
whatever is necessary to correct these issues.
claimallegation
The intervention demand1,062,576.98 exceeds California base demand632,599.48 by429,977.50. No itemised bridge reconciles the amounts; neithe
The intervention demand1,062,576.98 exceeds California base demand632,599.48 by429,977.50. No itemised bridge reconciles the amounts; neither the retention offer nor existing shareholding should automatically be added to wages or treated as a second independent debt.
Read the anchor · page 4
Page 3 of 7
13. All conditions precedent have been performed or have occurred.
14. Cyberlux d/b/a Datron did breach the contract with Mr. Maadarani.
15. Mr. Maadarani did suffer direct damages in the amount of $1,062,576.98.
16. On July 2, 2025, Cyberlux’s CEO, Mr. Schmidt, emailed Mr. Maadarani admitting that
Mr. Maadarani was owed monies including commissions for his work on the HII contract, and
that said monies should be paid from the monies that HII owed to Cyberlux (exhibit B).
17. Mr. Maadarani also owns three million (3,000,000.00) series B Cyberlux shares (exhibit
C). Series B shares equal two hundred (200) shares of common stock.
18. Mr. Schmidt refuses to direct Cyberlux’s transfer company, Standard Registrar and
Transfer Company, to give Mr. Maadarani access to his shares.
19. Cyberlux is a publicly traded corporation with ticker symbol “CYBL”.
20. Mr. Schmidt has fiduciary duties to Mr. Maadarani.
21. Mr. Schmidt actions and omissions have resulted in breaches of his fiduciary duties to
Mr. Maadarani.
CAUSES OF ACTION
COUNT ONE: JUDGMENT IN INTERPLEADER
PURSUANT TO 28 U.S.C. § 1335 AND 28 U.S.C. § 2361
22. Mr. Maadarani incorporates all of the previous paragraphs 1 – 21 as if set forth fully
herein.
23. Pursuant to 28 U.S.C. § 1335 AND 28 U.S.C. § 2361, the court has authority to enter
judgment distributing the interpleaded funds as justice so demands.
24. Mr. Maadarani is entitled to a judgment directing that pursuant to Cyberlux d/b/a
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 43 of 69 PageID#
2086
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 4 of 72 PageID# 2555
claimallegation
Maadarani’s affidavit dated14April2026 bears his DocuSign signature and declares personal knowledge under oath/penalty of perjury. He says w
Maadarani’s affidavit dated14April2026 bears his DocuSign signature and declares personal knowledge under oath/penalty of perjury. He says work with Schmidt began about9August2022,continued throughJune2025,helped secure/fulfil the K8 subcontract,with over10Ukraine trips and official meetings. These are his sworn assertions,not independently documented travel or government acceptance.
Read the anchor · page 38
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
__________________________________
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff Case No. 3:25-cv-00483-JAG
v.
CYBERLUX CORP., et. al.,
Defendants.
___________________________________
AFFIDAVIT OF MR. BILAL MAADARANI
I, Mr. Bilal Maadarani, being duly sworn, do hereby state under oath and under penalty of
perjury that the following facts are true.
1. I am over the age of eighteen (18). I am competent to make this affidavit in support of my
motion for summary judgment, and I have personal knowledge of the facts stated herein.
2. On or about August 9, 2022, I began working with Mr. Mark Schmidt (“Mr. Schmidt”) in
order to support Cyberlux’s efforts to obtain an award from the U.S. government through
the prime contractor, HII Mission Technologies Corp. (“HII”) for the K8 drones that were
for the Ukrainian Ministry of Defense as the end user.
3. Due to my work from August 9, 2022 through June of 2025, Cyberlux did secure said
subcontract and was able to fulfill its obligations under said contract.
4. My work and expertise were instrumental, including over ten (10) trips to Ukraine and
several meetings with Ukrainian government officials, including the Ukrainian ministry
of defense.
5. On or about October 8, 2023 I signed a contract with Mr. Schmidt, who signed on behalf
Datron World Communications, Inc. (“Datron”). Datron is a wholly owned subsidiary of
Cyberlux. Cyberlux does business as Datron.
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 38 of 72 PageID#
2589
claimallegation
Maadarani says Schmidt repeatedly promised inJune2025 to pay commissions/expenses from HII funds,that those promises caused him to stay,and
Maadarani says Schmidt repeatedly promised inJune2025 to pay commissions/expenses from HII funds,that those promises caused him to stay,and that hours-long follow-up calls continued after the July email. This adds a first-person reliance/oral-promise account absent from the earlier compilation; no call recordings or written assignment supplied.
Read the anchor · page 39
Page 2 of 2
6. In June of 2025 Mr. Schmidt and I had many conversations about my receiving the
commissions and expenses that were owed to me. I was promised many times that I
would get paid from the monies that HII were to pay Cyberlux. The reason I stayed at
Cyberlux during that time is because of the promises made to me by Mr. Schmidt.
7. On or about July 2, 2025, Mr. Schmidt sent me an email again promising me payment
from the HII monies. After Mr. Schmidts emails, he would follow up with me via
telephone calls about the payments. Those phone calls would last hours, and he
continued to make promises of payment to me from the monies coming from HII.
8. On or about November 19, 2025 I sued Datron in California for breach of contract
amongst other causes of actions. Datron and Cyberlux were used interchangeably
throughout the time when I was an employee of both entities. I had Datron and Cyberlux
emails as I was listed as the Chief Revenue Officer for both entities. Mr. Schmidt did not
distinguish between both entities and the quarterly filings demonstrates my title as the
Chief Revenue Officer of Cyberlux.
9. Datron was served and on or about December 23, 2025 the clerk issued a default against
Datron for its failure to respond to the complaint.
10. I am currently owed one million and sixty two thousand and five hundred and seventy six
dollars and ninety eight cents ($1,062,576.98) from Cyberlux d/b/a Datron for my work
and pursuant to my contract.
Dated: April 14, 2026
______________________________
Bilal Maadarani
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 39 of 72 PageID#
2590
[Visible DocuSign signature Bilal Maadarani; no notarial jurat supplied.]
claimallegation
He says he worked for both entities with dual emails/CRO titles and Schmidt used Datron/Cyberlux interchangeably,while acknowledging Schmidt
He says he worked for both entities with dual emails/CRO titles and Schmidt used Datron/Cyberlux interchangeably,while acknowledging Schmidt signed the contract for Datron,a wholly owned subsidiary. His claimed1,062,576.98 remains unitemised; dual branding and his liability characterisation do not independently adjudicate Cyberlux’s obligation.
Read the anchor · page 38
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
__________________________________
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff Case No. 3:25-cv-00483-JAG
v.
CYBERLUX CORP., et. al.,
Defendants.
___________________________________
AFFIDAVIT OF MR. BILAL MAADARANI
I, Mr. Bilal Maadarani, being duly sworn, do hereby state under oath and under penalty of
perjury that the following facts are true.
1. I am over the age of eighteen (18). I am competent to make this affidavit in support of my
motion for summary judgment, and I have personal knowledge of the facts stated herein.
2. On or about August 9, 2022, I began working with Mr. Mark Schmidt (“Mr. Schmidt”) in
order to support Cyberlux’s efforts to obtain an award from the U.S. government through
the prime contractor, HII Mission Technologies Corp. (“HII”) for the K8 drones that were
for the Ukrainian Ministry of Defense as the end user.
3. Due to my work from August 9, 2022 through June of 2025, Cyberlux did secure said
subcontract and was able to fulfill its obligations under said contract.
4. My work and expertise were instrumental, including over ten (10) trips to Ukraine and
several meetings with Ukrainian government officials, including the Ukrainian ministry
of defense.
5. On or about October 8, 2023 I signed a contract with Mr. Schmidt, who signed on behalf
Datron World Communications, Inc. (“Datron”). Datron is a wholly owned subsidiary of
Cyberlux. Cyberlux does business as Datron.
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 38 of 72 PageID#
2589
claimallegation
Schmidt’s2July2025 reply expresses remorse and calls customer/representative impact unacceptable; he attributes the situation to HII, Legali
Schmidt’s2July2025 reply expresses remorse and calls customer/representative impact unacceptable; he attributes the situation to HII, Legalist and lawyers, says HII has not paid per the modification and Legalist reneged. These are his explanations, not findings against those parties.
Read the anchor · page 26
[Current171-1 page26; source67 counterpart page65 verified by exact comparison; historical stamps below retain origin.]
Case 3:25-cv-00483-JAG Document 163-1
Filed 04/09/26 Page 65 of 69 PageID#
From: Mark Schmidt <mschmidt@cyberlux.com>
Sent: Wednesday, July 2, 2025 3:49 PM
To: Bill Maadarani <bmaadarani@cyberlux.com>
Subject: Re: Bill's exit path
Brother, I've been trying find words to express my remorse over this situation and have failed to find any that are
adequate. I can say my relationship with you, both our professional and our friendship, is one of the most important
ones I've had in my life, period. What we've done and the times we've had will be the highlights I will always
remember, no matter what. I truly hope we can find a path forward that works for you.
The impact on customers and our reps is unacceptable - I have been dying inside over this and its impact across the
company should have never happened. Between HII and Legalist, we have been pushed into this corner and have to
fight our way out, fighting all our enemies.
I don't want to leave anything to chance if we can find a path forward. Anything is on the table, other than Denis back
coming in:
• Retention bonus ($1M over next four quarters)
• Base salary increase to $250K with revised commission structure, TBD
• Notes and commissions paid out of HII money asap
• Position of President if you want that now
• Board of Directors? You should likely wait until we have D&O insurance soon then join
• Co-share all decision-making between you, me and Chris plus Loren on cash
• Ultimately well bring in a new CEO and I'll move to Chairman as soon as we can execute a strategic plan like
the one I've attached from Roman V - where we uplist to NASDAQ for example, including changing the
Cyberlux name. Roman also has Trump ties and we will get significant Trump-universe board membership.
We are talking to good capital partners now and you need to understand the environment and future. Loren is ready to
discuss at any point. I have attached the cash flow worksheet from Loren that gives you the operating detail. Loren is
available for discussion whenever you have time.
I know you have a dire outlook and I understand. I'm not sure who is advising you, but we are making meaningful
progress, and anyone on our team is available to discuss specifics. Attached is the Stay on the receiver and a Cease
and Desist that effectively ends him. This was done over the last 2 days and clears up the matter significantly, with
only what the receiver will be paid per the upcoming court decision. We were never in 'receivership' as I said, and
now this receiver is boxed up. I have the lead attorney, Jeff Brown, standing by to speak with you about the whole
situation so you have the full picture.
All this is unacceptable I know. We've not been paid by HII per the contract modification, Legalist has reneged on the
new loan agreement, and lawyers have made mistakes, all that led to where we are. All I know to do is fight our
enemies every day like I am, to resolve the critical matters as fast as possible. You should never have to address this
kind of situation with customers and reps. I will work a plan with you for the reps where we make the commission
payments and pay bonuses where you decide, for the missed shipments and customer delivery issues. I will do
whatever is necessary to correct these issues.
claimallegation
Schmidt offers a$1m retention bonus over four quarters,$250,000 salary with commission structure TBD, notes/commissions paid from HII money
Schmidt offers a$1m retention bonus over four quarters,$250,000 salary with commission structure TBD, notes/commissions paid from HII money ASAP, presidency, board membership after D&O insurance, shared decisions with Bill/Chris/Loren, and eventual CEO replacement/uplisting/name change. The conditional menu does not establish acceptance, funding, executed amendment or an unconditional assignment of interpleaded funds.
Read the anchor · page 26
[Current171-1 page26; source67 counterpart page65 verified by exact comparison; historical stamps below retain origin.]
Case 3:25-cv-00483-JAG Document 163-1
Filed 04/09/26 Page 65 of 69 PageID#
From: Mark Schmidt <mschmidt@cyberlux.com>
Sent: Wednesday, July 2, 2025 3:49 PM
To: Bill Maadarani <bmaadarani@cyberlux.com>
Subject: Re: Bill's exit path
Brother, I've been trying find words to express my remorse over this situation and have failed to find any that are
adequate. I can say my relationship with you, both our professional and our friendship, is one of the most important
ones I've had in my life, period. What we've done and the times we've had will be the highlights I will always
remember, no matter what. I truly hope we can find a path forward that works for you.
The impact on customers and our reps is unacceptable - I have been dying inside over this and its impact across the
company should have never happened. Between HII and Legalist, we have been pushed into this corner and have to
fight our way out, fighting all our enemies.
I don't want to leave anything to chance if we can find a path forward. Anything is on the table, other than Denis back
coming in:
• Retention bonus ($1M over next four quarters)
• Base salary increase to $250K with revised commission structure, TBD
• Notes and commissions paid out of HII money asap
• Position of President if you want that now
• Board of Directors? You should likely wait until we have D&O insurance soon then join
• Co-share all decision-making between you, me and Chris plus Loren on cash
• Ultimately well bring in a new CEO and I'll move to Chairman as soon as we can execute a strategic plan like
the one I've attached from Roman V - where we uplist to NASDAQ for example, including changing the
Cyberlux name. Roman also has Trump ties and we will get significant Trump-universe board membership.
We are talking to good capital partners now and you need to understand the environment and future. Loren is ready to
discuss at any point. I have attached the cash flow worksheet from Loren that gives you the operating detail. Loren is
available for discussion whenever you have time.
I know you have a dire outlook and I understand. I'm not sure who is advising you, but we are making meaningful
progress, and anyone on our team is available to discuss specifics. Attached is the Stay on the receiver and a Cease
and Desist that effectively ends him. This was done over the last 2 days and clears up the matter significantly, with
only what the receiver will be paid per the upcoming court decision. We were never in 'receivership' as I said, and
now this receiver is boxed up. I have the lead attorney, Jeff Brown, standing by to speak with you about the whole
situation so you have the full picture.
All this is unacceptable I know. We've not been paid by HII per the contract modification, Legalist has reneged on the
new loan agreement, and lawyers have made mistakes, all that led to where we are. All I know to do is fight our
enemies every day like I am, to resolve the critical matters as fast as possible. You should never have to address this
kind of situation with customers and reps. I will work a plan with you for the reps where we make the commission
payments and pay bonuses where you decide, for the missed shipments and customer delivery issues. I will do
whatever is necessary to correct these issues.
claimallegation
Schmidt proposes alternative SeriesB reallocations: Denis retains20m with Bill receiving30m from Schmidt/Treasury/Denis, or Denis retains10m
Schmidt proposes alternative SeriesB reallocations: Denis retains20m with Bill receiving30m from Schmidt/Treasury/Denis, or Denis retains10m with Bill receiving20m from Denis and10m from Schmidt. He claims resulting control above75%, seeks Bill’s help negotiating Denis’s override and ending lawsuits, and allows further dilution for capital. No executed transfers or lawsuit dismissals are supplied.
Read the anchor · page 27
[Current171-1 page27; source67 counterpart page66 verified by exact comparison; historical stamps below retain origin.]
[Own page66 image: repeat email continuation, federal stamp163-1 page66.]
Lastly, Series B and Denis. I've attached two ways this can go, where Denis keeps 20M, and you get 30M shares from the combination of me, Treasury, and Denis; or Denis keeps 10M and you get 20M from Denis and 10M from
me. Either way we have control of >75% and can then restructure as we want. This gives us basically equal footing
as we execute an uplisting. Check out the NASDAQ section of the spreadsheet. We'll likely have to give up more
than this to the capital raising partner but it still nets a big number. I need your help to negotiate with Denis on the rest
of his override BS, whatever makes sense to you. And he drops all his lawsuits for all time.
There is a lot here and I am open to anything and available to discuss at any point.
I love ya Brother - Mark
Mark Schmidt | President and CEO
mschmidt@cyberlux.com
919-434-6608
CYBERLUX®
Harnessing the Future
Visit our Website
From: Bill Maadarani <bmaadarani@cyberlux.com>
Sent: Tuesday, July 1, 2025 6:15 AM
To: Patrick Godfrey <pgodfrey@cyberlux.com>
Cc: Mark Schmidt <mschmidt@cyberlux.com>; Chris Barter <cbarter@cyberlux.com>
Subject: Bill's exit path
Patrick,
I would like to schedule a day to discuss my negotiated exit out of Cyberlux. I'm seeking your assistance in providing
me feedback from the CEO of Cyberlux on the following attachments:
1. Commission on the sales that bought
2. Employment agreement that was signed when I first accepted the position
3. Past due amounts for my salary
4. Convertible notes that are due and common stocks
5. Discussion with corporate attorney concerning my Series B stocks and the path of the sales of those stocks
6. Training for the folks that you need to hire to replace me
Please schedule a meeting for me to discuss this if possible. I'll wait to hear back from the team.
Best Regards,
claimallegation
Schmidt says a stay and cease-and-desist effectively end the receiver, claims they were never in receivership, and identifies only fees as a
Schmidt says a stay and cease-and-desist effectively end the receiver, claims they were never in receivership, and identifies only fees as awaiting decision. The referenced orders, Loren cash-flow worksheet and Roman strategic plan are absent from this compilation; this reassurance does not establish the orders’ actual legal effect.
Read the anchor · page 26
[Current171-1 page26; source67 counterpart page65 verified by exact comparison; historical stamps below retain origin.]
Case 3:25-cv-00483-JAG Document 163-1
Filed 04/09/26 Page 65 of 69 PageID#
From: Mark Schmidt <mschmidt@cyberlux.com>
Sent: Wednesday, July 2, 2025 3:49 PM
To: Bill Maadarani <bmaadarani@cyberlux.com>
Subject: Re: Bill's exit path
Brother, I've been trying find words to express my remorse over this situation and have failed to find any that are
adequate. I can say my relationship with you, both our professional and our friendship, is one of the most important
ones I've had in my life, period. What we've done and the times we've had will be the highlights I will always
remember, no matter what. I truly hope we can find a path forward that works for you.
The impact on customers and our reps is unacceptable - I have been dying inside over this and its impact across the
company should have never happened. Between HII and Legalist, we have been pushed into this corner and have to
fight our way out, fighting all our enemies.
I don't want to leave anything to chance if we can find a path forward. Anything is on the table, other than Denis back
coming in:
• Retention bonus ($1M over next four quarters)
• Base salary increase to $250K with revised commission structure, TBD
• Notes and commissions paid out of HII money asap
• Position of President if you want that now
• Board of Directors? You should likely wait until we have D&O insurance soon then join
• Co-share all decision-making between you, me and Chris plus Loren on cash
• Ultimately well bring in a new CEO and I'll move to Chairman as soon as we can execute a strategic plan like
the one I've attached from Roman V - where we uplist to NASDAQ for example, including changing the
Cyberlux name. Roman also has Trump ties and we will get significant Trump-universe board membership.
We are talking to good capital partners now and you need to understand the environment and future. Loren is ready to
discuss at any point. I have attached the cash flow worksheet from Loren that gives you the operating detail. Loren is
available for discussion whenever you have time.
I know you have a dire outlook and I understand. I'm not sure who is advising you, but we are making meaningful
progress, and anyone on our team is available to discuss specifics. Attached is the Stay on the receiver and a Cease
and Desist that effectively ends him. This was done over the last 2 days and clears up the matter significantly, with
only what the receiver will be paid per the upcoming court decision. We were never in 'receivership' as I said, and
now this receiver is boxed up. I have the lead attorney, Jeff Brown, standing by to speak with you about the whole
situation so you have the full picture.
All this is unacceptable I know. We've not been paid by HII per the contract modification, Legalist has reneged on the
new loan agreement, and lawyers have made mistakes, all that led to where we are. All I know to do is fight our
enemies every day like I am, to resolve the critical matters as fast as possible. You should never have to address this
kind of situation with customers and reps. I will work a plan with you for the reps where we make the commission
payments and pay bonuses where you decide, for the missed shipments and customer delivery issues. I will do
whatever is necessary to correct these issues.
claimallegation
The OTC management certification dated15May2025 is signed /s/Mark Schmidt, selects Alternative Reporting Standard, checks no shell and no ba
The OTC management certification dated15May2025 is signed /s/Mark Schmidt, selects Alternative Reporting Standard, checks no shell and no bankruptcy/reorganisation, and describes disclosures and ownership as of31March2025. It is management certification, not independent audit or proof of later conditions.
Read the anchor · page 32
OTC Markets Group Inc.
Management Certification (Version 1.3 April 2025)
Management Certification
The undersigned, on behalf of Cyberlux Corporation (the “Company”), certifies that the information provided herein
is accurate and complete to the best of the Company’s knowledge.
1. The Company is current in its disclosure obligations pursuant to the following reporting standard:
SEC Reporting Obligations
The Company has a reporting obligation under Section 13 or 15(d) of the Exchange Act
The Company has a reporting obligation under Regulation A (Tier 2)
The Company has a reporting obligation under Regulation Crowdfunding (CF)
Other (please describe)
Other Reporting Obligations
The Company is a U.S. bank, bank holding company, or similar financial institution exempt from SEC
registration, has a reporting obligation to a U.S. Bank Regulator and follows OTC Markets' Bank Reporting
requirements.
The Company is exempt from SEC registration and is reporting under the Alternative Reporting Standard
2. Indicate below whether the Company is a shell company (as defined in Rule 405 of the Securities Act of 1933, Rule
12b-2 of the Exchange Act of 1934 and Rule 15c2-11 of the Exchange Act of 1934):
Yes: [☐] No: [☒]
3. Indicate below whether the Company is subject to Bankruptcy or reorganization proceedings.
Yes: [☐] No: [☒]
4. The Company has a Verified Company Profile on OTCMarkets.com.
5. The Company is duly organized and in good standing under the laws of the state or jurisdiction in which the Company
is organized or does business.
6. The Company understands and acknowledges its obligations to report company-related actions pursuant to Exchange
Act Rule 10b-17 and FINRA Rule 6490.
7. The Company understands and acknowledges its obligations to publicly disclose material information in a timely
manner in accordance with applicable U.S. federal securities laws, including but not limited to Section 10(b) of the
Exchange Act and Rule 10b-5 thereunder.
8. The Company’s transfer agent and its address are listed below. If the Company acts as its own transfer agent,
indicate that by listing the Company and its information in the fields provided.1
1 OTCQX, OTCQB, and OTCID companies are required to retain a transfer agent that participates in the Transfer Agent Verified Shares
Program. OTCID companies that act as their own transfer agent may submit data directly to OTC Markets.
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 32 of 72 PageID#
2583
claimallegation
The ownership table reports Schmidt47m SeriesB54.65%,Downing1m1.16%,Isely2.5m2.91%,Bill3m3.49% and Montague21m24.42% controlled by Denis Kal
The ownership table reports Schmidt47m SeriesB54.65%,Downing1m1.16%,Isely2.5m2.91%,Bill3m3.49% and Montague21m24.42% controlled by Denis Kalenja; Goodman’s literal quantity is2,5000,000 beside2.91%. SeriesB converts200common per preferred; RecoveryFund holds148,000SeriesC98.667% under Jamie Rand. The Goodman malformed quantity is retained, not silently normalised.
Read the anchor · page 33
OTC Markets Group Inc.
Management Certification (Version 1.3 April 2025)
Transfer Agent: Standard Registrar and Transfer Company
Address: 440 East 400 South, Suite 200, Salt Lake City, UT 84111
9. The Company’s most recent Annual Report was prepared by: Mark Schmidt, president, Chief Executive Officer. Director
and Chairman of the Board of Directors of the Company and David Downing, Chief Financial Officer and Director of the
Company.
Below is a list all law firm(s) and attorney(s) (including internal counsel) that acted as the Company’s primary legal
counsel in preparing its most recent annual report or, if no attorney assisted in preparing the disclosure, the person(s)
who prepared the disclosure and their relationship to the Company.
Name: Carl P. Ranno, Esq
Firm: Law Office of Carl P. Ranno
Address: 2733 East Vista Drive, Phoenix, AZ 85032
Phone: 602.493.0369
Email: carlranno@cox.net
Name: Jennifer E.D. Clarke, Esq.
Firm: Tjong & Hsia LLP,
Address: 45 Rockefeller Plaza, 20th Floor, New York, NY 10111
Phone: 516-801-1700
Email: jclarke@tjonghsia.com
10. The Company’s Officers, Directors and 5% Control Persons are listed below:
The table below provides information regarding all officers and directors of the Company, or any person that performs
a similar function, regardless of the number of shares they own. To the best of the Company’s knowledge, it includes
all individuals or entities beneficially owning 5% or more of any class of the issuer’s equity securities. To identify
holders of 5% or more, companies may obtain a recent copy of their shareholder list that includes Non-Objecting
Beneficial Owners or “NOBOs.” SEC Reporting companies may also research their beneficial ownership and insider
transaction filings such as on Schedules 13G or 13D or on Forms 3, 4, and 5.
As of (latest practicable date): 3/31/2025
Names of All
Officers, Directors,
and Control Persons
Affiliation with
Company
(e.g. Officer/
Director/ Owner
of 5% or greater)
Residential
Address
(City / State)
Number of
shares owned
Share
type/class
Ownership
Percentage of Class
Outstanding
Names of control
person(s) if a
corporate entity
Mark D. Schmidt President
Chief Executive
Officer
Director
Chairman
Durham, NC 230,642
47,000,000
Common
Series B
Less than 1%
54.65%
David D. Downing Chief Financial
Officer
Director
Edinboro, PA 42,500
1,000,000
Common
Series
B
Less than 1%
1.16%
John W. Ringo Secretary
Director
Atlanta, GA 123,783 Commo
n
Less than 1%
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 33 of 72 PageID#
2584
claimallegation
Convertible-debt table retains RB loans and two Datron Holdings acquisition notes, Maadarani/Cali transfers and repaid/converted rows. Maada
Convertible-debt table retains RB loans and two Datron Holdings acquisition notes, Maadarani/Cali transfers and repaid/converted rows. Maadarani’s29September2022 note shows110,630 outstanding on100,000principal at0.0049/share or85%10-day average. Robert Miller’s109,414 outstanding conflicts with same-row converted-in-full label; these are issuer table statements requiring reconciliation, not current verified balances.
Read the anchor · page 34
OTC Markets Group Inc.
Management Certification (Version 1.3 April 2025)
Aaron Goodman Chief of Staff
Director
Waccabuc, NY 70,000,000
2,5000,000
Common
Series B
1.2%
2.91%
Larry J. Isely Chief Operating
Officer
Denton, TX 2,500,000 Series B 2.91%
Bill Maadarani Chief Revenue
Officer
Dearborn, MI 3,000,000 Series B 3.49%
Montague Capital
Partners LLC
Strategic
Consultant
Greater than
5% holder
Miami, FL 21,000,000
179,500,000
Series B
Common
24.42%
3.019%
Denis Kalenja controls
this entity
Recovery Fund
USA, LLC
Greater than
5% holder Lutz, FL 148,000 Series C 98.667%
Jamie Rand controls
this entity.
Any additional material details, including conversion terms of any class of the issuer’s equity securities, are below:
Each share of the Company’s Series B Convertible Preferred is convertible into 200 shares of the Company’s
Common Stock at the option of the holder.
Each share of the Company’s Series C Convertible Preferred Stock is convertible into shares of the Company’s
Common Stock at the option of the holder. The conversion rate for such shares is variable, depending on the
ten-day moving average of the price per share of the Company’s Common Stock, based on the following
formula: ($25.20/10DMA)/200.
11. The Company has Convertible Debt as detailed below:
The following is a complete list of the Company’s Convertible Debt which includes all promissory notes, convertible
notes, convertible debentures, or any other debt instruments convertible into a class of the issuer’s equity securities.
The table includes all issued or outstanding convertible debt at any time during the last complete fiscal year and any
interim period between the last fiscal year end and the date of this Certification.
[☐] Check this box to confirm the Company had no Convertible Debt issued or outstanding at any point during this
period.
Date of Note
Issuance
Outstanding
Balance ($)
Principal
Amount at
Issuance ($)
Interest
Accrued ($)
Maturity
Date
Conversion Terms (e.g.
pricing mechanism for
determining conversion of
instrument to shares) Name of Noteholder*
Reason for
Issuance (e.g.
Loan,
Services, etc.)
10/22/2021 1,491,671 1,500,000 241,671 10/22/2023 $0.25 Conversion per
share
RB Capital Partners
(this note has been repaid in
part)
Loan
11/08/2021 1,751,918 1,500,000 251,918 11/08/2023 $0.25 Conversion per
share
RB Capital Partners Loan
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 34 of 72 PageID#
2585
otherattribution
Schmidt proposes notes/commissions from HII money ASAP within retention discussions.
Read the anchor · page 26
[Current171-1 page26; source67 counterpart page65 verified by exact comparison; historical stamps below retain origin.]
Case 3:25-cv-00483-JAG Document 163-1
Filed 04/09/26 Page 65 of 69 PageID#
From: Mark Schmidt <mschmidt@cyberlux.com>
Sent: Wednesday, July 2, 2025 3:49 PM
To: Bill Maadarani <bmaadarani@cyberlux.com>
Subject: Re: Bill's exit path
Brother, I've been trying find words to express my remorse over this situation and have failed to find any that are
adequate. I can say my relationship with you, both our professional and our friendship, is one of the most important
ones I've had in my life, period. What we've done and the times we've had will be the highlights I will always
remember, no matter what. I truly hope we can find a path forward that works for you.
The impact on customers and our reps is unacceptable - I have been dying inside over this and its impact across the
company should have never happened. Between HII and Legalist, we have been pushed into this corner and have to
fight our way out, fighting all our enemies.
I don't want to leave anything to chance if we can find a path forward. Anything is on the table, other than Denis back
coming in:
• Retention bonus ($1M over next four quarters)
• Base salary increase to $250K with revised commission structure, TBD
• Notes and commissions paid out of HII money asap
• Position of President if you want that now
• Board of Directors? You should likely wait until we have D&O insurance soon then join
• Co-share all decision-making between you, me and Chris plus Loren on cash
• Ultimately well bring in a new CEO and I'll move to Chairman as soon as we can execute a strategic plan like
the one I've attached from Roman V - where we uplist to NASDAQ for example, including changing the
Cyberlux name. Roman also has Trump ties and we will get significant Trump-universe board membership.
We are talking to good capital partners now and you need to understand the environment and future. Loren is ready to
discuss at any point. I have attached the cash flow worksheet from Loren that gives you the operating detail. Loren is
available for discussion whenever you have time.
I know you have a dire outlook and I understand. I'm not sure who is advising you, but we are making meaningful
progress, and anyone on our team is available to discuss specifics. Attached is the Stay on the receiver and a Cease
and Desist that effectively ends him. This was done over the last 2 days and clears up the matter significantly, with
only what the receiver will be paid per the upcoming court decision. We were never in 'receivership' as I said, and
now this receiver is boxed up. I have the lead attorney, Jeff Brown, standing by to speak with you about the whole
situation so you have the full picture.
All this is unacceptable I know. We've not been paid by HII per the contract modification, Legalist has reneged on the
new loan agreement, and lawyers have made mistakes, all that led to where we are. All I know to do is fight our
enemies every day like I am, to resolve the critical matters as fast as possible. You should never have to address this
kind of situation with customers and reps. I will work a plan with you for the reps where we make the commission
payments and pay bonuses where you decide, for the missed shipments and customer delivery issues. I will do
whatever is necessary to correct these issues.
entityobservation
Mark Schmidt
Read the anchor · page 41
[Current171-1 page41; source67 counterpart page2 verified by exact comparison; historical stamps below retain origin.]
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 2 of 69 PageID# 2045
From: Mark Schmidt <mschmidt@cyberlux.com>
Sent: Wednesday, July 2, 2025 3:49 PM
To: Bill Maadarani <bmaadarani@cyberlux.com>
Subject: Re: Bill's exit path
Brother, I've been trying find words to express my remorse over this situation and have failed to find any that are
adequate. I can say my relationship with you, both our professional and our friendship, is one of the most important
ones I've had in my life, period. What we've done and the times we've had will be the highlights I will always
remember, no matter what. I truly hope we can find a path forward that works for you.
The impact on customers and our reps is unacceptable - I have been dying inside over this and its impact across the
company should have never happened. Between HII and Legalist, we have been pushed into this corner and have to
fight our way out, fighting all our enemies.
I don't want to leave anything to chance if we can find a path forward. Anything is on the table, other than Denis back
coming in:
• Retention bonus ($1M over next four quarters)
• Base salary increase to $250K with revised commission structure, TBD
• Notes and commissions paid out of HII money asap
• Position of President if you want that now
• Board of Directors? You should likely wait until we have D&O insurance soon then join
• Co-share all decision-making between you, me and Chris plus Loren on cash
• Ultimately we'll bring in a new CEO and I'll move to Chairman as soon as we can execute a strategic plan like
the one I've attached from Roman V - where we uplist to NASDAQ for example, including changing the
Cyberlux name. Roman also has Trump ties and we will get significant Trump-universe board membership.
We are talking to good capital partners now and you need to understand the environment and future. Loren is ready to
discuss at any point. I have attached the cash flow worksheet from Loren that gives you the operating detail. Loren is
available for discussion whenever you have time.
I know you have a dire outlook and I understand. I'm not sure who is advising you, but we are making meaningful
progress, and anyone on our team is available to discuss specifics. Attached is the Stay on the receiver and a Cease
and Desist that effectively ends him. This was done over the last 2 days and clears up the matter significantly, with
only what the receiver will be paid per the upcoming court decision. We were never in 'receivership' as I said, and
now this receiver is boxed up. I have the lead attorney, Jeff Brown, standing by to speak with you about the whole
situation so you have the full picture.
All this is unacceptable I know. We've not been paid by HII per the contract modification, Legalist has reneged on the
new loan agreement, and lawyers have made mistakes, all that led to where we are. All I know to do is fight our
enemies every day like I am, to resolve the critical matters as fast as possible. You should never have to address this
kind of situation with customers and reps. I will work a plan with you for the reps where we make the commission
payments and pay bonuses where you decide, for the missed shipments and customer delivery issues. I will do
whatever is necessary to correct these issues.
entityobservation
Standard Transfer Company
Read the anchor · page 30
[Current171-1 page30; source67 counterpart page69 verified by exact comparison; historical stamps below retain origin.]
[EDVA163-1 page69, filed9April2026. Visible redactions preserved.]
Standard Transfer Company,440 East400 South Suite200 Salt Lake City UT84111,phone8015718844,fax8013284058,Standardtransferco.com.
BILL MAADARANI [address redacted]. CYBERLUX CORPORATION PREFERRED B 0. Acct#:10. ACCOUNT STATEMENT As of10/21/2025.
RESTRICTED BOOK SHARES SUMMARY: RESTRICTED3,000,000.
BOOK-ENTRY SHARES SUMMARY: Free Trading Book-Entry Shares0; Restricted Book-Entry Shares3,000,000; Total Book-Entry Shares3,000,000.
OUTSTANDING SHARES SUMMARY: Book Shares3,000,000.0000; Total Shares3,000,000.0000.
Price Per Share As of10/21/2025,Market Value of Holdings,Cost Basis($): redacted.
TAX LOT DETAIL: Certificate# blank;Acquired02/28/2024;Disposed blank;Lot Shares3,000,000.0000;Basis/Share redacted;Total Cost($)redacted;Gift/Inher blank;Gift Date blank;Gift FMV($)blank. Total lot shares3,000,000;totalcost redacted. Page1.
entityobservation
Howard D. Ruddell
Read the anchor · page 56
1
2
3
4
5
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8
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- 7 -
COMPLAINT; DEMAND FOR JURY TRIAL
6. For an award to Plaintiff of such other and further legal and equitable relief
as the Court may deem just and proper.
DATED: November 19, 2025 MOORE RUDDELL LLP
By:
Howard D. Ruddell
Attorneys for Plaintiff Bilal Maadarani
DEMAND FOR JURY TRIAL
Plaintiff hereby demands trial by jury.
DATED: November 19, 2025 MOORE RUDDELL LLP
By:
Howard D. Ruddell
Attorneys for Plaintiff Bilal Maadarani
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 56 of 72 PageID#
2607
entityobservation
Mohamad A. Akbik
Read the anchor · page 7
Page 6 of 7
B. A judgment for specific performance directing Cyberlux to allow Mr. Maadarani full
access, including authority to sell, to his three million series B shares of Cyberlux.
C. Such other relief as the court deems just and reasonable.
Dated: April 9, 2026
Pinellas County
Respectfully Submitted,
___________________________
Mohamad A. Akbik, Esq.
(pending Pro Hac Vice admission)
FL Bar: 116366
611 S. Fort Harrison Ave., Suite 183
Clearwater, FL 33756
Telephone: 727-223-3005
Facsimile: 727-223-3578
Email: akbiklaw@outlook.com
_________________________________
Keith A. Jaworski, Esq. (VSB #101178)
WOODS ROGERS
VANDEVENTER BLACK PLC
120 Garrett Street, Suite 304
Charlottesville, VA 22902
Telephone: 434-220-6825
Facsimile: 434-220-5687
Keith.Jaworski@woodsrogers.com
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 46 of 69 PageID#
2089
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 7 of 72 PageID# 2558
entityobservation
Keith A. Jaworski
Read the anchor · page 7
Page 6 of 7
B. A judgment for specific performance directing Cyberlux to allow Mr. Maadarani full
access, including authority to sell, to his three million series B shares of Cyberlux.
C. Such other relief as the court deems just and reasonable.
Dated: April 9, 2026
Pinellas County
Respectfully Submitted,
___________________________
Mohamad A. Akbik, Esq.
(pending Pro Hac Vice admission)
FL Bar: 116366
611 S. Fort Harrison Ave., Suite 183
Clearwater, FL 33756
Telephone: 727-223-3005
Facsimile: 727-223-3578
Email: akbiklaw@outlook.com
_________________________________
Keith A. Jaworski, Esq. (VSB #101178)
WOODS ROGERS
VANDEVENTER BLACK PLC
120 Garrett Street, Suite 304
Charlottesville, VA 22902
Telephone: 434-220-6825
Facsimile: 434-220-5687
Keith.Jaworski@woodsrogers.com
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 46 of 69 PageID#
2089
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 7 of 72 PageID# 2558
entityobservation
Bill W. Maadarani
Read the anchor · page 43
[Current171-1 page43; source67 counterpart page4 verified by exact comparison; historical stamps below retain origin.]
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 4 of 69 PageID# 2047
Bill W. Maadarani |Cyberlux Corporation |Datron World Communications, Inc.
Bmaadarani@cyberlux.com | Bmaadarani@dtwc.com
Chief Revenue Officer
995 Joshua Way, Vista, CA 92081 |www.dtwc.com
Cell: 1-586-405-0069 | Cell: +961-71-008726
Performance You Require. Value You Expect™
[Visible OSAC logo: Diplomatic Security Service; Public Private Partnership. Logo presence does not independently establish membership.]
entityobservation
Bilal Maadarani
Read the anchor · page 50
1
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- 1 -
COMPLAINT; DEMAND FOR JURY TRIAL
Plaintiff Bilal Maadarani (“Mr. Maadarani” or “Plaintiff”), by and through his
undersigned counsel, files this complaint against defendant Datron World
Communications, Inc. (“Datron” or “Defendant”) and Does 1-20.
THE PARTIES
1. Plaintiff is currently living in Beirut, Lebanon, at the direction of Datron.
At all relevant times, Plaintiff worked for Datron, who is domiciled in San Diego County,
California.
2. Plaintiff is informed and believes and thereon alleges that defendant Datron
World Communications, Inc. is a California corporation with its principal place of
business at 995 Joshua Way, Suite A, Vista, CA 92081. Datron is, and at all relevant
times herein mentioned was, authorized to do business in the State of California.
3. The true names and capacities, whether individual, corporate, associate or
otherwise, of the defendants denominated as DOES 1-20 inclusive, are unknown at this
time to Plaintiff and therefore said defendants are sued by such fictitious names. Plaintiff
is informed and believes and based thereon alleges that each of the fictitiously named
defendants is responsible, and therefore liable, for the acts and omissions sued upon
herein. Such Doe defendants, by amendment to the Complaint, may be identified as
named defendants herein, when and if Plaintiff learns of their true identity.
JURISDICTION, AND VENUE
4. Jurisdiction is proper in this Court because Defendant is subject to
jurisdiction on claims relating to its activities and wrongful conduct in California as
Plaintiff’s employer, and the amount in controversy exceeds $35,000.
5. Venue is proper in this judicial district pursuant to California Code of Civil
Procedure § 395(a) because Datron’s headquarters is in San Diego County and the
wrongful conduct occurred in San Diego County. Further, Plaintiff’s Employment
Agreement states that “Any action or proceeding by either of the parties to enforce this
Agreement shall be brought only in a state or federal court located in the state of
California, county of San Diego.”
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 50 of 72 PageID#
2601
entityobservation
Datron World Communications, Inc.
Read the anchor · page 58
Employment Agreement
This Employment Agreement (the “Agreement”) is made and entered into as of October
8, 2023, by and between Bilal Maadarani (the “Executive”) resident at
, and Datron World Communications, Inc., a corporation organized
under the laws of the State of California, with an address at 995 Joshua Way, Suite A, Vista,
California 92081 (the “Company”, and together with affiliates of the Company, the “Company
Group”).
WHEREAS, the Executive has been an employee of the Company and the Company
desires to continue to employ the Executive on the terms and conditions set forth herein; and
WHEREAS, the Executive desires to be employed by the Company and provide services
to the Company Group on such terms and conditions;
NOW, THEREFORE, in consideration of the mutual covenants, promises, and
obligations set forth herein, the parties agree as follows:
1. Term. Subject to Section 5 of this Agreement, the Executive’s initial term of
employment hereunder shall be from the period beginning on October 8, 2023 (the “Effective
Date”); provided that for all purposes where tenure with the Company is considered, the
Executive shall be deemed to have been in the continuous employ of the Company since August
18, 2008. Unless earlier terminated as provided herein, Executive’s initial employment term will
be for a period of two (2) years (the “Initial Term”); and thereafter the Agreement shall be
deemed to be automatically extended, upon the same terms and conditions, for successive
periods of one year, unless either party provides written notice of its intention not to extend the
term at least 30 days prior to any anniversary of the Effective Date falling on or after the second
anniversary of the Effective Date. The period during which the Executive is employed by the
Company hereunder is hereinafter referred to as the “Employment Term.”
2. Position and Duties.
2.1 Position. During the Employment Term, the Executive shall serve as the Chief
Revenue Officer of the Company Group, reporting to the Chief Executive Officer (the “CEO”) of the Company’s parent company, Cyberlux Corporation, a corporation organized
under the laws of the State of Nevada, with an address at 800 Park Offices Drive, Suite
3209, Research Triangle Park, NC 27709 (“Cyberlux”). In such position, the Executive
shall have such duties, authority, and responsibilities at the Company Group as are
established from time to time by the CEO, consistent with the Executive’s position.
2.2 Duties. During the Employment Term, the Executive shall devote all of the
Executive’s business time and attention to the performance of the Executive’s duties
hereunder and will not engage in any other business, profession, or occupation for
compensation or otherwise, without the prior written consent of the CEO.
3. Place of Performance. The principal place of Executive’s employment shall be in the
Company’s headquarters currently located at the address set forth above in Vista, California. The
Executive may work remotely from the Executive’s residence in the United States; provided that
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 58 of 72 PageID#
2609
entityobservation
Cyberlux Corporation
Read the anchor · page 58
Employment Agreement
This Employment Agreement (the “Agreement”) is made and entered into as of October
8, 2023, by and between Bilal Maadarani (the “Executive”) resident at
, and Datron World Communications, Inc., a corporation organized
under the laws of the State of California, with an address at 995 Joshua Way, Suite A, Vista,
California 92081 (the “Company”, and together with affiliates of the Company, the “Company
Group”).
WHEREAS, the Executive has been an employee of the Company and the Company
desires to continue to employ the Executive on the terms and conditions set forth herein; and
WHEREAS, the Executive desires to be employed by the Company and provide services
to the Company Group on such terms and conditions;
NOW, THEREFORE, in consideration of the mutual covenants, promises, and
obligations set forth herein, the parties agree as follows:
1. Term. Subject to Section 5 of this Agreement, the Executive’s initial term of
employment hereunder shall be from the period beginning on October 8, 2023 (the “Effective
Date”); provided that for all purposes where tenure with the Company is considered, the
Executive shall be deemed to have been in the continuous employ of the Company since August
18, 2008. Unless earlier terminated as provided herein, Executive’s initial employment term will
be for a period of two (2) years (the “Initial Term”); and thereafter the Agreement shall be
deemed to be automatically extended, upon the same terms and conditions, for successive
periods of one year, unless either party provides written notice of its intention not to extend the
term at least 30 days prior to any anniversary of the Effective Date falling on or after the second
anniversary of the Effective Date. The period during which the Executive is employed by the
Company hereunder is hereinafter referred to as the “Employment Term.”
2. Position and Duties.
2.1 Position. During the Employment Term, the Executive shall serve as the Chief
Revenue Officer of the Company Group, reporting to the Chief Executive Officer (the “CEO”) of the Company’s parent company, Cyberlux Corporation, a corporation organized
under the laws of the State of Nevada, with an address at 800 Park Offices Drive, Suite
3209, Research Triangle Park, NC 27709 (“Cyberlux”). In such position, the Executive
shall have such duties, authority, and responsibilities at the Company Group as are
established from time to time by the CEO, consistent with the Executive’s position.
2.2 Duties. During the Employment Term, the Executive shall devote all of the
Executive’s business time and attention to the performance of the Executive’s duties
hereunder and will not engage in any other business, profession, or occupation for
compensation or otherwise, without the prior written consent of the CEO.
3. Place of Performance. The principal place of Executive’s employment shall be in the
Company’s headquarters currently located at the address set forth above in Vista, California. The
Executive may work remotely from the Executive’s residence in the United States; provided that
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 58 of 72 PageID#
2609
entityobservation
Patrick Godfrey
Read the anchor · page 42
[Current171-1 page42; source67 counterpart page3 verified by exact comparison; historical stamps below retain origin.]
Lastly, Series B and Denis. I've attached two ways this can go, where Denis keeps 20M, and you get 30M shares from the combination of me, Treasury, and Denis; or Denis keeps 10M and you get 20M from Denis and 10M from
me. Either way we have control of >75% and can then restructure as we want. This gives us basically equal footing
as we execute an uplisting. Check out the NASDAQ section of the spreadsheet. We'll likely have to give up more
than this to the capital raising partner but it still nets a big number. I need your help to negotiate with Denis on the rest
of his override BS, whatever makes sense to you. And he drops all his lawsuits for all time.
There is a lot here and I am open to anything and available to discuss at any point.
I love ya Brother - Mark
Mark Schmidt | President and CEO
mschmidt@cyberlux.com
919-434-6608
CYBERLUX®
Harnessing the Future
Visit our Website
From: Bill Maadarani <bmaadarani@cyberlux.com>
Sent: Tuesday, July 1, 2025 6:15 AM
To: Patrick Godfrey <pgodfrey@cyberlux.com>
Cc: Mark Schmidt <mschmidt@cyberlux.com>; Chris Barter <cbarter@cyberlux.com>
Subject: Bill's exit path
Patrick,
I would like to schedule a day to discuss my negotiated exit out of Cyberlux. I'm seeking your assistance in providing
me feedback from the CEO of Cyberlux on the following attachments:
1. Commission on the sales that bought
2. Employment agreement that was signed when I first accepted the position
3. Past due amounts for my salary
4. Convertible notes that are due and common stocks
5. Discussion with corporate attorney concerning my Series B stocks and the path of the sales of those stocks
6. Training for the folks that you need to hire to replace me
Please schedule a meeting for me to discuss this if possible. I'll wait to hear back from the team.
Best Regards,
entityobservation
Chris Barter
Read the anchor · page 42
[Current171-1 page42; source67 counterpart page3 verified by exact comparison; historical stamps below retain origin.]
Lastly, Series B and Denis. I've attached two ways this can go, where Denis keeps 20M, and you get 30M shares from the combination of me, Treasury, and Denis; or Denis keeps 10M and you get 20M from Denis and 10M from
me. Either way we have control of >75% and can then restructure as we want. This gives us basically equal footing
as we execute an uplisting. Check out the NASDAQ section of the spreadsheet. We'll likely have to give up more
than this to the capital raising partner but it still nets a big number. I need your help to negotiate with Denis on the rest
of his override BS, whatever makes sense to you. And he drops all his lawsuits for all time.
There is a lot here and I am open to anything and available to discuss at any point.
I love ya Brother - Mark
Mark Schmidt | President and CEO
mschmidt@cyberlux.com
919-434-6608
CYBERLUX®
Harnessing the Future
Visit our Website
From: Bill Maadarani <bmaadarani@cyberlux.com>
Sent: Tuesday, July 1, 2025 6:15 AM
To: Patrick Godfrey <pgodfrey@cyberlux.com>
Cc: Mark Schmidt <mschmidt@cyberlux.com>; Chris Barter <cbarter@cyberlux.com>
Subject: Bill's exit path
Patrick,
I would like to schedule a day to discuss my negotiated exit out of Cyberlux. I'm seeking your assistance in providing
me feedback from the CEO of Cyberlux on the following attachments:
1. Commission on the sales that bought
2. Employment agreement that was signed when I first accepted the position
3. Past due amounts for my salary
4. Convertible notes that are due and common stocks
5. Discussion with corporate attorney concerning my Series B stocks and the path of the sales of those stocks
6. Training for the folks that you need to hire to replace me
Please schedule a meeting for me to discuss this if possible. I'll wait to hear back from the team.
Best Regards,
entityobservation
Denis Kalenja
Read the anchor · page 34
OTC Markets Group Inc.
Management Certification (Version 1.3 April 2025)
Aaron Goodman Chief of Staff
Director
Waccabuc, NY 70,000,000
2,5000,000
Common
Series B
1.2%
2.91%
Larry J. Isely Chief Operating
Officer
Denton, TX 2,500,000 Series B 2.91%
Bill Maadarani Chief Revenue
Officer
Dearborn, MI 3,000,000 Series B 3.49%
Montague Capital
Partners LLC
Strategic
Consultant
Greater than
5% holder
Miami, FL 21,000,000
179,500,000
Series B
Common
24.42%
3.019%
Denis Kalenja controls
this entity
Recovery Fund
USA, LLC
Greater than
5% holder Lutz, FL 148,000 Series C 98.667%
Jamie Rand controls
this entity.
Any additional material details, including conversion terms of any class of the issuer’s equity securities, are below:
Each share of the Company’s Series B Convertible Preferred is convertible into 200 shares of the Company’s
Common Stock at the option of the holder.
Each share of the Company’s Series C Convertible Preferred Stock is convertible into shares of the Company’s
Common Stock at the option of the holder. The conversion rate for such shares is variable, depending on the
ten-day moving average of the price per share of the Company’s Common Stock, based on the following
formula: ($25.20/10DMA)/200.
11. The Company has Convertible Debt as detailed below:
The following is a complete list of the Company’s Convertible Debt which includes all promissory notes, convertible
notes, convertible debentures, or any other debt instruments convertible into a class of the issuer’s equity securities.
The table includes all issued or outstanding convertible debt at any time during the last complete fiscal year and any
interim period between the last fiscal year end and the date of this Certification.
[☐] Check this box to confirm the Company had no Convertible Debt issued or outstanding at any point during this
period.
Date of Note
Issuance
Outstanding
Balance ($)
Principal
Amount at
Issuance ($)
Interest
Accrued ($)
Maturity
Date
Conversion Terms (e.g.
pricing mechanism for
determining conversion of
instrument to shares) Name of Noteholder*
Reason for
Issuance (e.g.
Loan,
Services, etc.)
10/22/2021 1,491,671 1,500,000 241,671 10/22/2023 $0.25 Conversion per
share
RB Capital Partners
(this note has been repaid in
part)
Loan
11/08/2021 1,751,918 1,500,000 251,918 11/08/2023 $0.25 Conversion per
share
RB Capital Partners Loan
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 34 of 72 PageID#
2585
entityobservation
Standard Registrar
Read the anchor · page 33
OTC Markets Group Inc.
Management Certification (Version 1.3 April 2025)
Transfer Agent: Standard Registrar and Transfer Company
Address: 440 East 400 South, Suite 200, Salt Lake City, UT 84111
9. The Company’s most recent Annual Report was prepared by: Mark Schmidt, president, Chief Executive Officer. Director
and Chairman of the Board of Directors of the Company and David Downing, Chief Financial Officer and Director of the
Company.
Below is a list all law firm(s) and attorney(s) (including internal counsel) that acted as the Company’s primary legal
counsel in preparing its most recent annual report or, if no attorney assisted in preparing the disclosure, the person(s)
who prepared the disclosure and their relationship to the Company.
Name: Carl P. Ranno, Esq
Firm: Law Office of Carl P. Ranno
Address: 2733 East Vista Drive, Phoenix, AZ 85032
Phone: 602.493.0369
Email: carlranno@cox.net
Name: Jennifer E.D. Clarke, Esq.
Firm: Tjong & Hsia LLP,
Address: 45 Rockefeller Plaza, 20th Floor, New York, NY 10111
Phone: 516-801-1700
Email: jclarke@tjonghsia.com
10. The Company’s Officers, Directors and 5% Control Persons are listed below:
The table below provides information regarding all officers and directors of the Company, or any person that performs
a similar function, regardless of the number of shares they own. To the best of the Company’s knowledge, it includes
all individuals or entities beneficially owning 5% or more of any class of the issuer’s equity securities. To identify
holders of 5% or more, companies may obtain a recent copy of their shareholder list that includes Non-Objecting
Beneficial Owners or “NOBOs.” SEC Reporting companies may also research their beneficial ownership and insider
transaction filings such as on Schedules 13G or 13D or on Forms 3, 4, and 5.
As of (latest practicable date): 3/31/2025
Names of All
Officers, Directors,
and Control Persons
Affiliation with
Company
(e.g. Officer/
Director/ Owner
of 5% or greater)
Residential
Address
(City / State)
Number of
shares owned
Share
type/class
Ownership
Percentage of Class
Outstanding
Names of control
person(s) if a
corporate entity
Mark D. Schmidt President
Chief Executive
Officer
Director
Chairman
Durham, NC 230,642
47,000,000
Common
Series B
Less than 1%
54.65%
David D. Downing Chief Financial
Officer
Director
Edinboro, PA 42,500
1,000,000
Common
Series
B
Less than 1%
1.16%
John W. Ringo Secretary
Director
Atlanta, GA 123,783 Commo
n
Less than 1%
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 33 of 72 PageID#
2584
eventattribution
Datron/Maadarani employment agreement.
Read the anchor · page 58
Employment Agreement
This Employment Agreement (the “Agreement”) is made and entered into as of October
8, 2023, by and between Bilal Maadarani (the “Executive”) resident at
, and Datron World Communications, Inc., a corporation organized
under the laws of the State of California, with an address at 995 Joshua Way, Suite A, Vista,
California 92081 (the “Company”, and together with affiliates of the Company, the “Company
Group”).
WHEREAS, the Executive has been an employee of the Company and the Company
desires to continue to employ the Executive on the terms and conditions set forth herein; and
WHEREAS, the Executive desires to be employed by the Company and provide services
to the Company Group on such terms and conditions;
NOW, THEREFORE, in consideration of the mutual covenants, promises, and
obligations set forth herein, the parties agree as follows:
1. Term. Subject to Section 5 of this Agreement, the Executive’s initial term of
employment hereunder shall be from the period beginning on October 8, 2023 (the “Effective
Date”); provided that for all purposes where tenure with the Company is considered, the
Executive shall be deemed to have been in the continuous employ of the Company since August
18, 2008. Unless earlier terminated as provided herein, Executive’s initial employment term will
be for a period of two (2) years (the “Initial Term”); and thereafter the Agreement shall be
deemed to be automatically extended, upon the same terms and conditions, for successive
periods of one year, unless either party provides written notice of its intention not to extend the
term at least 30 days prior to any anniversary of the Effective Date falling on or after the second
anniversary of the Effective Date. The period during which the Executive is employed by the
Company hereunder is hereinafter referred to as the “Employment Term.”
2. Position and Duties.
2.1 Position. During the Employment Term, the Executive shall serve as the Chief
Revenue Officer of the Company Group, reporting to the Chief Executive Officer (the “CEO”) of the Company’s parent company, Cyberlux Corporation, a corporation organized
under the laws of the State of Nevada, with an address at 800 Park Offices Drive, Suite
3209, Research Triangle Park, NC 27709 (“Cyberlux”). In such position, the Executive
shall have such duties, authority, and responsibilities at the Company Group as are
established from time to time by the CEO, consistent with the Executive’s position.
2.2 Duties. During the Employment Term, the Executive shall devote all of the
Executive’s business time and attention to the performance of the Executive’s duties
hereunder and will not engage in any other business, profession, or occupation for
compensation or otherwise, without the prior written consent of the CEO.
3. Place of Performance. The principal place of Executive’s employment shall be in the
Company’s headquarters currently located at the address set forth above in Vista, California. The
Executive may work remotely from the Executive’s residence in the United States; provided that
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 58 of 72 PageID#
2609
eventattribution
Maadarani requests exit negotiations.
Read the anchor · page 42
[Current171-1 page42; source67 counterpart page3 verified by exact comparison; historical stamps below retain origin.]
Lastly, Series B and Denis. I've attached two ways this can go, where Denis keeps 20M, and you get 30M shares from the combination of me, Treasury, and Denis; or Denis keeps 10M and you get 20M from Denis and 10M from
me. Either way we have control of >75% and can then restructure as we want. This gives us basically equal footing
as we execute an uplisting. Check out the NASDAQ section of the spreadsheet. We'll likely have to give up more
than this to the capital raising partner but it still nets a big number. I need your help to negotiate with Denis on the rest
of his override BS, whatever makes sense to you. And he drops all his lawsuits for all time.
There is a lot here and I am open to anything and available to discuss at any point.
I love ya Brother - Mark
Mark Schmidt | President and CEO
mschmidt@cyberlux.com
919-434-6608
CYBERLUX®
Harnessing the Future
Visit our Website
From: Bill Maadarani <bmaadarani@cyberlux.com>
Sent: Tuesday, July 1, 2025 6:15 AM
To: Patrick Godfrey <pgodfrey@cyberlux.com>
Cc: Mark Schmidt <mschmidt@cyberlux.com>; Chris Barter <cbarter@cyberlux.com>
Subject: Bill's exit path
Patrick,
I would like to schedule a day to discuss my negotiated exit out of Cyberlux. I'm seeking your assistance in providing
me feedback from the CEO of Cyberlux on the following attachments:
1. Commission on the sales that bought
2. Employment agreement that was signed when I first accepted the position
3. Past due amounts for my salary
4. Convertible notes that are due and common stocks
5. Discussion with corporate attorney concerning my Series B stocks and the path of the sales of those stocks
6. Training for the folks that you need to hire to replace me
Please schedule a meeting for me to discuss this if possible. I'll wait to hear back from the team.
Best Regards,
eventattribution
Schmidt proposes retention and control arrangements.
Read the anchor · page 41
[Current171-1 page41; source67 counterpart page2 verified by exact comparison; historical stamps below retain origin.]
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 2 of 69 PageID# 2045
From: Mark Schmidt <mschmidt@cyberlux.com>
Sent: Wednesday, July 2, 2025 3:49 PM
To: Bill Maadarani <bmaadarani@cyberlux.com>
Subject: Re: Bill's exit path
Brother, I've been trying find words to express my remorse over this situation and have failed to find any that are
adequate. I can say my relationship with you, both our professional and our friendship, is one of the most important
ones I've had in my life, period. What we've done and the times we've had will be the highlights I will always
remember, no matter what. I truly hope we can find a path forward that works for you.
The impact on customers and our reps is unacceptable - I have been dying inside over this and its impact across the
company should have never happened. Between HII and Legalist, we have been pushed into this corner and have to
fight our way out, fighting all our enemies.
I don't want to leave anything to chance if we can find a path forward. Anything is on the table, other than Denis back
coming in:
• Retention bonus ($1M over next four quarters)
• Base salary increase to $250K with revised commission structure, TBD
• Notes and commissions paid out of HII money asap
• Position of President if you want that now
• Board of Directors? You should likely wait until we have D&O insurance soon then join
• Co-share all decision-making between you, me and Chris plus Loren on cash
• Ultimately we'll bring in a new CEO and I'll move to Chairman as soon as we can execute a strategic plan like
the one I've attached from Roman V - where we uplist to NASDAQ for example, including changing the
Cyberlux name. Roman also has Trump ties and we will get significant Trump-universe board membership.
We are talking to good capital partners now and you need to understand the environment and future. Loren is ready to
discuss at any point. I have attached the cash flow worksheet from Loren that gives you the operating detail. Loren is
available for discussion whenever you have time.
I know you have a dire outlook and I understand. I'm not sure who is advising you, but we are making meaningful
progress, and anyone on our team is available to discuss specifics. Attached is the Stay on the receiver and a Cease
and Desist that effectively ends him. This was done over the last 2 days and clears up the matter significantly, with
only what the receiver will be paid per the upcoming court decision. We were never in 'receivership' as I said, and
now this receiver is boxed up. I have the lead attorney, Jeff Brown, standing by to speak with you about the whole
situation so you have the full picture.
All this is unacceptable I know. We've not been paid by HII per the contract modification, Legalist has reneged on the
new loan agreement, and lawyers have made mistakes, all that led to where we are. All I know to do is fight our
enemies every day like I am, to resolve the critical matters as fast as possible. You should never have to address this
kind of situation with customers and reps. I will work a plan with you for the reps where we make the commission
payments and pay bonuses where you decide, for the missed shipments and customer delivery issues. I will do
whatever is necessary to correct these issues.
eventattribution
California compensation complaint.
Read the anchor · page 49
[Current171-1 page49; source67 counterpart page12 verified by exact comparison; historical stamps below retain origin.]
MOORE RUDDELL LLP
Bonita D. Moore (SBN 221479) bmoore@mooreruddell.com
Howard D. Ruddell (SBN 281510) hruddell@mooreruddell.com
21250 Hawthorne Blvd., Suite 500 Torrance, CA 90503
Telephone: (310) 792-7010
Fax: (323)530-1113
Attorneys for Plaintiff Bilal Maadarani
ELECTRONICALLY FILED
Superior Court of California, County of San Diego
11/19/2025 3:18:59 PM
Clerk of the Superior Court By M. Acevedo ,Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN DIEGO CENTRAL
11
12
13
14 Case No. 25CU062277C
COMPLAINT FOR:
(1) BREACH OF CONTRACT
(2) FAILURE TO PAY EARNED WAGES
(3) FAILURE TO REIMBURSE BUSINESS EXPENSES
BILAL MAADARANI, an individual,
Plaintiff,
DATRON WORLD
COMMUNICATIONS, INC., California Corporation; and DOES 1-20, Defendants.
15
16
17
18
19
20
(4) WAITING TIME PENALTIES
21
22
23
24
25
26
27
28
COMPLAINT; DEMAND FOR JURY TRIAL
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 12 of 69 PageID#
2055
eventattribution
Datron default entered without judgment amount.
Read the anchor · page 45
[Current171-1 page45; source67 counterpart page37 verified by exact comparison; historical stamps below retain origin.]
CIV-100
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO: 281510 FOR COURT USE ONLY name: Howard D. Ruddell
FIRM NAME: Moore Ruddell LLP
STREET ADDRESS: 21250 Hawthorne Blvd., Suite 500
city: Torrance STATE: CA ZIP CODE: 90503 ELECTRONICALLY FILED
TELEPHONE NO.: 310-792-7010 FAX NO.: Superior Court of California, E-MAIL ADDRESS: hruddell@mooreruddell.com County of San Diego
ATTORNEY FOR (name): Plaintiff Bilal Maadarani 12/23/2025 2:32:23 PM
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO
STREETADDRESS: 330 West Broadway Clerk of the Superior Court MAILING ADDRESS: 330 West Broadway By J. Siharath ,Deputy Clerk
CITY AND ZIP CODE: San Diego, CA 92101
BRANCH NAME: Hall of Justice
Plaintiff/Petitioner: Bilal Maadarani Defendant/Respondent: Datron World Communications, Inc. CASE NUMBER: REQUEST FOR Entry of Default Clerk's Judgment 25CU062277C
(Application) Court Judgment Not for use in actions under the Fair Debt Buying Practices Act (Civ. Code, 1788.50 et seq.); (see form CIV-105)
1. TO THE CLERK: On the complaint or cross-complaint
filed
a. on (date): November 19, 2025
b. by (name): Plaintiff Bilal Maadarani
c. [x] Enter default of defendant (names): Datron World Communications, Inc.
d. CI request court judgment under Code of Civil Procedure sections 585(b), 585(c), 989, etc., against defendant
(names):
(Testimony required. Apply to the clerk for hearing date, unless the court will enter judgment on an affidavit under Code Civ. Proc., 585(d).) e. [] Enter clerk's judgment
(1) for restitution of the premises only and issue writ of execution on the judgment. Code of Civil Procedure section
1174(c) does not apply. (Code Civ. Proc., 1169.) Include in the judgment all tenants, subtenants, named claimants, and other occupants of the premises. The Prejudgment Claim of Right
to Possession was served in compliance with Code of Civil Procedure section
415.46.
(2) under Code of Civil Procedure section 585(a). (Complete the declaration under Code Civ. Proc., 585.5 on the
reverse (item 5).)
(3)
for default previously entered on (date): 2. Judgment
to be entered. Amount Credits acknowledged Balance
a. Demand of complaint b. Statement of damages"
(1) Special
(2) General
c. Interest d. Costs (see reverse) e. Attorney fees
f. TOTALS
g. Daily damages were demanded in complaint at the rate of: per day beginning (date):
(* Personal
injury or wrongful death actions; Code Civ. Proc., 425.11.) 3. (Check if filed 1in an unlawful detainer case.) Legal document assistant or unlawful detainer assistant information is on the
reverse (complete item 4).
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF)
Date: December 23, 2025 Howard D. Ruddell
FOR COURT (1) Default entered as requested on (date): 12/23/2025 USE ONLY (2) Default NOT entered as requested (state reason): Clerk,
J. Siharath by Deputy Page of
Form Adopted for Mandatory Use REQUEST FOR ENTRY OF DEFAULT
Code of Civil Procedure, §§ 585-587, 1169
Judicial Council of California courts.ca.gov CIV-100 [Rev. January 1, 2023} (Application to Enter Default)
Case 3:25-cv-00483-JAG Document 163-1 Filed 04/09/26 Page 37 of 69 PageID#
2080
[Own image: Entry of Default and enter defendant default checked; clerk entered default12/23/2025 signed J.Siharath. Clerk/court judgment boxes unmarked; every judgment amount blank. Ruddell signature visible.]
eventattribution
171-1 compilation filed with14April affidavit.
Read the anchor · page 1
EXHIBIT 1
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 1 of 72 PageID# 2552
eventattribution
Maadarani attests to procurement work,oral promises,reliance and asserted balance.
Read the anchor · page 38
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
__________________________________
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff Case No. 3:25-cv-00483-JAG
v.
CYBERLUX CORP., et. al.,
Defendants.
___________________________________
AFFIDAVIT OF MR. BILAL MAADARANI
I, Mr. Bilal Maadarani, being duly sworn, do hereby state under oath and under penalty of
perjury that the following facts are true.
1. I am over the age of eighteen (18). I am competent to make this affidavit in support of my
motion for summary judgment, and I have personal knowledge of the facts stated herein.
2. On or about August 9, 2022, I began working with Mr. Mark Schmidt (“Mr. Schmidt”) in
order to support Cyberlux’s efforts to obtain an award from the U.S. government through
the prime contractor, HII Mission Technologies Corp. (“HII”) for the K8 drones that were
for the Ukrainian Ministry of Defense as the end user.
3. Due to my work from August 9, 2022 through June of 2025, Cyberlux did secure said
subcontract and was able to fulfill its obligations under said contract.
4. My work and expertise were instrumental, including over ten (10) trips to Ukraine and
several meetings with Ukrainian government officials, including the Ukrainian ministry
of defense.
5. On or about October 8, 2023 I signed a contract with Mr. Schmidt, who signed on behalf
Datron World Communications, Inc. (“Datron”). Datron is a wholly owned subsidiary of
Cyberlux. Cyberlux does business as Datron.
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 38 of 72 PageID#
2589
inferenceinference
The exhibits support a documented employment/compensation dispute and restricted shareholding, while parent liability and ownership/priority
The exhibits support a documented employment/compensation dispute and restricted shareholding, while parent liability and ownership/priority in HII funds require additional legal and factual bridges.
inferenceinference
Schmidt’s July communication combines acknowledged customer harm with substantial retention/control offers, indicating an effort to retain M
Schmidt’s July communication combines acknowledged customer harm with substantial retention/control offers, indicating an effort to retain Maadarani; it does not prove any offer was accepted or his external blame accurate.
inferenceinference
The new affidavit strengthens attribution of the oral-promise/reliance account to Maadarani personally,but it remains the same claimant’s ac
The new affidavit strengthens attribution of the oral-promise/reliance account to Maadarani personally,but it remains the same claimant’s account rather than independent corroboration or a priority ruling.
otherattribution
Complete supplied 72-page source reviewed at SHA-256 e640f0a82351946c6888fc25d60a879f4bfb8c77a7227dd45dacc0cd44d2afe4. Source assertions, or
Complete supplied 72-page source reviewed at SHA-256 e640f0a82351946c6888fc25d60a879f4bfb8c77a7227dd45dacc0cd44d2afe4. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Full-source review uses completed accepted source67 reading only for64exactly mapped native-text pages with embedded pixel checks recorded in Source68exact page comparison.json. Page7 signature image recompression visually checked; same substantive signature. New affidavit38–39 fully read native and visual; six new dividers read. Current material images checked for layout,redactions,signatures and overlapping federal stamps. No fictional rereading or independent-source inflation.
Read the anchor · page 1
EXHIBIT 1
Case 3:25-cv-00483-JAG Document 171-1 Filed 04/15/26 Page 1 of 72 PageID# 2552
questionquestion
What sales-level adjusted commission calculation,credits,benefits and accruals reconcile632,599.48 to1,062,576.98?
questionquestion
What assignment,payment undertaking or adjudication establishes Cyberlux liability and priority in the HII fund beyond the named Datron empl
What assignment,payment undertaking or adjudication establishes Cyberlux liability and priority in the HII fund beyond the named Datron employment agreement?
questionquestion
What transfer restrictions,instructions and current register govern the3mSeriesB,and were July reallocation offers ever executed?
questionquestion
How were arbitration,GoodReason notice/cure and commission exclusions addressed in the California default and proposed federal claim?
questionquestion
What contemporaneous communications,travel records and commission ledger corroborate the affidavit’s procurement work,repeated promises,reli
What contemporaneous communications,travel records and commission ledger corroborate the affidavit’s procurement work,repeated promises,reliance and stated balance?
questionquestion
Do these exhibits establish a paid or adjudicated1,062,576.98 entitlement to HII funds?
Maadarani swears that he began working with Schmidt to support Cyberlux's effort to obtain an HII award for K8 drones for Ukraine.
Read the anchor · page 2
MISSION TECHNOLOGIES
CORP.,
Plaintiff
Case No. 3:25-cv-00483-JAG
v.
CYBERLUX CORP., et. al.,
Defendants.
___________________________________
COMPLAINT IN INTERVENTION OF MR. BILAL MAADARANI
COMES NOW, Mr. Bilal Maadarani, interpleader defendant/claimant, through his
undersigned counsel and states the following:
1. Mr. Maadarani asserts through this complaint his interest in the funds that plaintiff, HII
Mission Technologies Corp. (“HII”) has interpleaded in this case. Cyberlux Corporation
(“Cyberlux”) agreed to pay Mr. Maadarani’s salary, expenses, and commissions from his work
on the HII
eventattribution
Datron employment agreement installs Maadarani as group CRO
Datron and Maadarani executed an employment agreement making him CRO of the company group, reporting to Cyberlux's CEO, while recognising continuous Datron tenure since August 2008.
Read the anchor · page 3
forth in
paragraphs 3 through 11 of HII’s first amended complaint for interpleader accurately describes
the parties named in the amended complaint.
JURISDICTION AND VENUE
4. Mr. Maadarani accepts the allegations regarding jurisdiction and venue set forth in
paragraphs 12 through 16 of HII’s amended complaint.
STATEMENT OF FACTS
5. Mr. Maadarani is a shareholder of Cyberlux and its former Chief Revenue Officer.
6. Cyberlux purchased Datron World Communications, Inc. (“Datron”) and has been using
the Datron name since said purchase.
7. Cyberlux officers use the monikers Datron and Cyberlux i
eventattribution
Cyberlux records four $100,000 Maadarani convertible loans
Cyberlux's management certification lists four $100,000 notes originally issued to Bilal Maadarani, each convertible using discounted market-price terms.
Read the anchor · page 2
MISSION TECHNOLOGIES
CORP.,
Plaintiff
Case No. 3:25-cv-00483-JAG
v.
CYBERLUX CORP., et. al.,
Defendants.
___________________________________
COMPLAINT IN INTERVENTION OF MR. BILAL MAADARANI
COMES NOW, Mr. Bilal Maadarani, interpleader defendant/claimant, through his
undersigned counsel and states the following:
1. Mr. Maadarani asserts through this complaint his interest in the funds that plaintiff, HII
Mission Technologies Corp. (“HII”) has interpleaded in this case. Cyberlux Corporation
(“Cyberlux”) agreed to pay Mr. Maadarani’s salary, expenses, and commissions from his work
on the HII
eventattribution
Schmidt proposes replacing Kalenja control bloc with Maadarani
In a direct email, Schmidt offered Maadarani enhanced compensation, the presidency, a possible board seat, and a proposed Series B reallocation intended to produce more than 75 percent control while negotiating Kalenja's exit and dismissal of litigation.
Read the anchor · page 3
forth in
paragraphs 3 through 11 of HII’s first amended complaint for interpleader accurately describes
the parties named in the amended complaint.
JURISDICTION AND VENUE
4. Mr. Maadarani accepts the allegations regarding jurisdiction and venue set forth in
paragraphs 12 through 16 of HII’s amended complaint.
STATEMENT OF FACTS
5. Mr. Maadarani is a shareholder of Cyberlux and its former Chief Revenue Officer.
6. Cyberlux purchased Datron World Communications, Inc. (“Datron”) and has been using
the Datron name since said purchase.
7. Cyberlux officers use the monikers Datron and Cyberlux i
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.
Cyberlux's management certification lists four $100,000 notes originally issued to Bilal Maadarani, each convertible using discounted market-price terms.supports{"timeline_thread":"money","timeline_thread_label":"Money movement"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
The interpleader record expands into competing briefs and exhibits over lien priority, creditor status, and entitlement to the court-held pool.supports{"timeline_thread":"technical","timeline_thread_label":"Technical & delivery"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
Maadarani swears that he began working with Schmidt to support Cyberlux's effort to obtain an HII award for K8 drones for Ukraine.supports{"timeline_thread":"communications","timeline_thread_label":"Communications & influence"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
In a direct email, Schmidt offered Maadarani enhanced compensation, the presidency, a possible board seat, and a proposed Series B reallocation intended to produce more than 75 percent control while negotiating Kalenja's exit and dismissal of litigation.supports{"timeline_thread":"corporate","timeline_thread_label":"Corporate & disclosure"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
Datron and Maadarani executed an employment agreement making him CRO of the company group, reporting to Cyberlux's CEO, while recognising continuous Datron tenure since August 2008.supports{"timeline_thread":"corporate","timeline_thread_label":"Corporate & disclosure"}
This reviewed database occurrence and exact public source passage document the dated event in the public chronology.
{"timeline_thread":"technical","timeline_thread_label":"Technical & delivery"}relates to{"chapter":30,"exposure_lens":"Gatekeeper exposure requires actor-specific proof of the statement or act, the information available at the time, the duty held and the response to contrary material.","responsibility":"Accuracy of sworn accounts and filed positions, professional duties, preservation and custody of the corporate record.","sequence":330,"unit_key":"CH30"}
The controlling book publication map connects this dated event to Part III, Chapter 30. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"money","timeline_thread_label":"Money movement"}relates to{"chapter":30,"exposure_lens":"Gatekeeper exposure requires actor-specific proof of the statement or act, the information available at the time, the duty held and the response to contrary material.","responsibility":"Accuracy of sworn accounts and filed positions, professional duties, preservation and custody of the corporate record.","sequence":330,"unit_key":"CH30"}
The controlling book publication map connects this dated event to Part III, Chapter 30. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"corporate","timeline_thread_label":"Corporate & disclosure"}relates to{"chapter":30,"exposure_lens":"Gatekeeper exposure requires actor-specific proof of the statement or act, the information available at the time, the duty held and the response to contrary material.","responsibility":"Accuracy of sworn accounts and filed positions, professional duties, preservation and custody of the corporate record.","sequence":330,"unit_key":"CH30"}
The controlling book publication map connects this dated event to Part III, Chapter 30. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"communications","timeline_thread_label":"Communications & influence"}relates to{"chapter":30,"exposure_lens":"Gatekeeper exposure requires actor-specific proof of the statement or act, the information available at the time, the duty held and the response to contrary material.","responsibility":"Accuracy of sworn accounts and filed positions, professional duties, preservation and custody of the corporate record.","sequence":330,"unit_key":"CH30"}
The controlling book publication map connects this dated event to Part III, Chapter 30. The connection follows stored event/source and publication identifiers.
{"timeline_thread":"corporate","timeline_thread_label":"Corporate & disclosure"}relates to{"chapter":30,"exposure_lens":"Gatekeeper exposure requires actor-specific proof of the statement or act, the information available at the time, the duty held and the response to contrary material.","responsibility":"Accuracy of sworn accounts and filed positions, professional duties, preservation and custody of the corporate record.","sequence":330,"unit_key":"CH30"}
The controlling book publication map connects this dated event to Part III, Chapter 30. The connection follows stored event/source and publication identifiers.
Maadarani’s affidavit dated14April2026 bears his DocuSign signature and declares personal knowledge under oath/penalty of perjury. He says work with Schmidt began about9August2022,continued throughJune2025,helped secure/fulfil the K8 subcontract,with over10Ukraine trips and official meetings. These are his sworn assertions,not independently documented travel or government acceptance.supportsWhat contemporaneous communications,travel records and commission ledger corroborate the affidavit’s procurement work,repeated promises,reliance and stated balance?
Specifically named source propositions support the bounded distinction or question.
Maadarani’s California complaint25CU062277C filed19November2025 sues Datron and Does1–20 for contract/wage/expense/waiting-time relief. It alleges632,599.48 unpaid:275,000 signing bonus,59,107.66 salary through12November,193,491.82 commissions through30September,20,000 expenses and85,000 fringe benefits; plus20,769 penalties,fees and interest. These are pleaded demands, not awarded amounts.supportsWhat sales-level adjusted commission calculation,credits,benefits and accruals reconcile632,599.48 to1,062,576.98?
Specifically named source propositions support the bounded distinction or question.
Schmidt offers a$1m retention bonus over four quarters,$250,000 salary with commission structure TBD, notes/commissions paid from HII money ASAP, presidency, board membership after D&O insurance, shared decisions with Bill/Chris/Loren, and eventual CEO replacement/uplisting/name change. The conditional menu does not establish acceptance, funding, executed amendment or an unconditional assignment of interpleaded funds.supportsSchmidt’s July communication combines acknowledged customer harm with substantial retention/control offers, indicating an effort to retain Maadarani; it does not prove any offer was accepted or his external blame accurate.
Specifically named source propositions support the bounded distinction or question.
Schmidt offers a$1m retention bonus over four quarters,$250,000 salary with commission structure TBD, notes/commissions paid from HII money ASAP, presidency, board membership after D&O insurance, shared decisions with Bill/Chris/Loren, and eventual CEO replacement/uplisting/name change. The conditional menu does not establish acceptance, funding, executed amendment or an unconditional assignment of interpleaded funds.supportsWhat assignment,payment undertaking or adjudication establishes Cyberlux liability and priority in the HII fund beyond the named Datron employment agreement?
Specifically named source propositions support the bounded distinction or question.
The intervention demand1,062,576.98 exceeds California base demand632,599.48 by429,977.50. No itemised bridge reconciles the amounts; neither the retention offer nor existing shareholding should automatically be added to wages or treated as a second independent debt.supportsDo these exhibits establish a paid or adjudicated1,062,576.98 entitlement to HII funds?
Specifically named source propositions support the bounded distinction or question.
Commission is earned on booked sales subject to365-day non-effectuation clawback and defined adjusted commissionable amount deducting production/development,returns,discounts,freight,taxes and service costs. Direct/FMS regional rates are1%,other directors’ bookings0.5%. Exclusions include training/engineering/repair/warranty,amount below5,001 or25%gross,house/unfunded orders and absent CRM booking history; exceptions/strategic rates require approval. The complaint’s1%all-direct-sales summary omits these qualifications.supportsHow were arbitration,GoodReason notice/cure and commission exclusions addressed in the California default and proposed federal claim?
Specifically named source propositions support the bounded distinction or question.
The9April2026 intervention complaint seeks1,062,576.98 from the interpleaded funds plus fees/interest and access including sale authority to3mSeriesB. It alleges Cyberlux/Datron interchangeability,contract breach,Schmidt’s July admission and fiduciary breach. Its repetition of those allegations does not establish parent liability,priority or an entered distribution order.supportsThe exhibits support a documented employment/compensation dispute and restricted shareholding, while parent liability and ownership/priority in HII funds require additional legal and factual bridges.
Specifically named source propositions support the bounded distinction or question.
Schmidt proposes alternative SeriesB reallocations: Denis retains20m with Bill receiving30m from Schmidt/Treasury/Denis, or Denis retains10m with Bill receiving20m from Denis and10m from Schmidt. He claims resulting control above75%, seeks Bill’s help negotiating Denis’s override and ending lawsuits, and allows further dilution for capital. No executed transfers or lawsuit dismissals are supplied.supportsSchmidt’s July communication combines acknowledged customer harm with substantial retention/control offers, indicating an effort to retain Maadarani; it does not prove any offer was accepted or his external blame accurate.
Specifically named source propositions support the bounded distinction or question.
Bonus eligibility is discretionary with2023threshold20mbooked sales and employment on payment day; equity is plan-dependent; expenses follow policy. Termination preserves accrued amounts, differentiates pre/post initial-term treatment, conditions early severance on release, and imposes clawback where applicable. GoodReason requires notice within10days,at least30days cure and termination within30days of first grounds; application to alleged chronology is unresolved.supportsHow were arbitration,GoodReason notice/cure and commission exclusions addressed in the California default and proposed federal claim?
Specifically named source propositions support the bounded distinction or question.
Commission is earned on booked sales subject to365-day non-effectuation clawback and defined adjusted commissionable amount deducting production/development,returns,discounts,freight,taxes and service costs. Direct/FMS regional rates are1%,other directors’ bookings0.5%. Exclusions include training/engineering/repair/warranty,amount below5,001 or25%gross,house/unfunded orders and absent CRM booking history; exceptions/strategic rates require approval. The complaint’s1%all-direct-sales summary omits these qualifications.supportsWhat sales-level adjusted commission calculation,credits,benefits and accruals reconcile632,599.48 to1,062,576.98?
Specifically named source propositions support the bounded distinction or question.
Maadarani’s affidavit dated14April2026 bears his DocuSign signature and declares personal knowledge under oath/penalty of perjury. He says work with Schmidt began about9August2022,continued throughJune2025,helped secure/fulfil the K8 subcontract,with over10Ukraine trips and official meetings. These are his sworn assertions,not independently documented travel or government acceptance.supportsThe new affidavit strengthens attribution of the oral-promise/reliance account to Maadarani personally,but it remains the same claimant’s account rather than independent corroboration or a priority ruling.
Specifically named source propositions support the bounded distinction or question.
He says he worked for both entities with dual emails/CRO titles and Schmidt used Datron/Cyberlux interchangeably,while acknowledging Schmidt signed the contract for Datron,a wholly owned subsidiary. His claimed1,062,576.98 remains unitemised; dual branding and his liability characterisation do not independently adjudicate Cyberlux’s obligation.supportsThe new affidavit strengthens attribution of the oral-promise/reliance account to Maadarani personally,but it remains the same claimant’s account rather than independent corroboration or a priority ruling.
Specifically named source propositions support the bounded distinction or question.
The8October2023 agreement is between Datron World Communications,Inc. and Bilal Maadarani, credits service since18August2008 and appoints CompanyGroup CRO reporting to parent Cyberlux CEO. It bears both DocuSign signatures. Two-year initial term renews annually absent30-day notice; October2023 signing bonus525,000 and annual salary180,000 are subject to stated conditions. Parent reporting does not itself make Cyberlux the named employer/signatory.supportsDo these exhibits establish a paid or adjudicated1,062,576.98 entitlement to HII funds?
Specifically named source propositions support the bounded distinction or question.
The8October2023 agreement is between Datron World Communications,Inc. and Bilal Maadarani, credits service since18August2008 and appoints CompanyGroup CRO reporting to parent Cyberlux CEO. It bears both DocuSign signatures. Two-year initial term renews annually absent30-day notice; October2023 signing bonus525,000 and annual salary180,000 are subject to stated conditions. Parent reporting does not itself make Cyberlux the named employer/signatory.supportsThe exhibits support a documented employment/compensation dispute and restricted shareholding, while parent liability and ownership/priority in HII funds require additional legal and factual bridges.
Specifically named source propositions support the bounded distinction or question.
Standard Transfer Company’s21October2025 account statement for Bill Maadarani reports3mrestricted book-entry SeriesB,zero free-trading shares,3mtotal,acquisition28February2024; certificate-number field blank. Address,price/value/basis and cost fields are redacted. It documents recorded restricted holdings, not unrestricted sale authority,physical certificate possession or present transfer instructions.supportsWhat transfer restrictions,instructions and current register govern the3mSeriesB,and were July reallocation offers ever executed?
Specifically named source propositions support the bounded distinction or question.
Schmidt’s2July2025 reply expresses remorse and calls customer/representative impact unacceptable; he attributes the situation to HII, Legalist and lawyers, says HII has not paid per the modification and Legalist reneged. These are his explanations, not findings against those parties.supportsSchmidt’s July communication combines acknowledged customer harm with substantial retention/control offers, indicating an effort to retain Maadarani; it does not prove any offer was accepted or his external blame accurate.
Specifically named source propositions support the bounded distinction or question.
Bill Maadarani’s1July2025 email to Patrick Godfrey, copying Schmidt and Chris Barter, requests negotiated exit discussions covering commissions, employment agreement, past salary, convertible notes/common stock, SeriesB access/sale and replacement training. It is an exit request, not the later November resignation.supportsSchmidt’s July communication combines acknowledged customer harm with substantial retention/control offers, indicating an effort to retain Maadarani; it does not prove any offer was accepted or his external blame accurate.
Specifically named source propositions support the bounded distinction or question.
Standard Transfer Company’s21October2025 account statement for Bill Maadarani reports3mrestricted book-entry SeriesB,zero free-trading shares,3mtotal,acquisition28February2024; certificate-number field blank. Address,price/value/basis and cost fields are redacted. It documents recorded restricted holdings, not unrestricted sale authority,physical certificate possession or present transfer instructions.supportsThe exhibits support a documented employment/compensation dispute and restricted shareholding, while parent liability and ownership/priority in HII funds require additional legal and factual bridges.
Specifically named source propositions support the bounded distinction or question.
California clerk J.Siharath entered Datron’s default23December2025 on CIV100. Entry-of-default boxes are marked, judgment boxes and all money amounts blank. Ruddell signed the mailing declaration to Datron’s Vista address; cost and nonmilitary declaration fields are blank. This is an entered default, not a money judgment against Datron or Cyberlux.supportsDo these exhibits establish a paid or adjudicated1,062,576.98 entitlement to HII funds?
Specifically named source propositions support the bounded distinction or question.
The9April2026 intervention complaint seeks1,062,576.98 from the interpleaded funds plus fees/interest and access including sale authority to3mSeriesB. It alleges Cyberlux/Datron interchangeability,contract breach,Schmidt’s July admission and fiduciary breach. Its repetition of those allegations does not establish parent liability,priority or an entered distribution order.supportsDo these exhibits establish a paid or adjudicated1,062,576.98 entitlement to HII funds?
Specifically named source propositions support the bounded distinction or question.
The8October2023 agreement is between Datron World Communications,Inc. and Bilal Maadarani, credits service since18August2008 and appoints CompanyGroup CRO reporting to parent Cyberlux CEO. It bears both DocuSign signatures. Two-year initial term renews annually absent30-day notice; October2023 signing bonus525,000 and annual salary180,000 are subject to stated conditions. Parent reporting does not itself make Cyberlux the named employer/signatory.supportsWhat assignment,payment undertaking or adjudication establishes Cyberlux liability and priority in the HII fund beyond the named Datron employment agreement?
Specifically named source propositions support the bounded distinction or question.
He says he worked for both entities with dual emails/CRO titles and Schmidt used Datron/Cyberlux interchangeably,while acknowledging Schmidt signed the contract for Datron,a wholly owned subsidiary. His claimed1,062,576.98 remains unitemised; dual branding and his liability characterisation do not independently adjudicate Cyberlux’s obligation.supportsWhat contemporaneous communications,travel records and commission ledger corroborate the affidavit’s procurement work,repeated promises,reliance and stated balance?
Specifically named source propositions support the bounded distinction or question.
California clerk J.Siharath entered Datron’s default23December2025 on CIV100. Entry-of-default boxes are marked, judgment boxes and all money amounts blank. Ruddell signed the mailing declaration to Datron’s Vista address; cost and nonmilitary declaration fields are blank. This is an entered default, not a money judgment against Datron or Cyberlux.supportsThe exhibits support a documented employment/compensation dispute and restricted shareholding, while parent liability and ownership/priority in HII funds require additional legal and factual bridges.
Specifically named source propositions support the bounded distinction or question.
Schmidt offers a$1m retention bonus over four quarters,$250,000 salary with commission structure TBD, notes/commissions paid from HII money ASAP, presidency, board membership after D&O insurance, shared decisions with Bill/Chris/Loren, and eventual CEO replacement/uplisting/name change. The conditional menu does not establish acceptance, funding, executed amendment or an unconditional assignment of interpleaded funds.supportsDo these exhibits establish a paid or adjudicated1,062,576.98 entitlement to HII funds?
Specifically named source propositions support the bounded distinction or question.
Payment schedule normally splits50% after90days and50% after240days; orders above5m permit initial instalments commencing after180days and remaining payment proportionate to customer receipts, subject to mutual alternatives. Schedule bars advances and allocates regional transitions100/0,75/25,50/50,0/100 at1–30,31–90,91–180,180+days. No sales-level calculation substantiates the demanded commission total.supportsWhat sales-level adjusted commission calculation,credits,benefits and accruals reconcile632,599.48 to1,062,576.98?
Specifically named source propositions support the bounded distinction or question.
Commission is earned on booked sales subject to365-day non-effectuation clawback and defined adjusted commissionable amount deducting production/development,returns,discounts,freight,taxes and service costs. Direct/FMS regional rates are1%,other directors’ bookings0.5%. Exclusions include training/engineering/repair/warranty,amount below5,001 or25%gross,house/unfunded orders and absent CRM booking history; exceptions/strategic rates require approval. The complaint’s1%all-direct-sales summary omits these qualifications.supportsDo these exhibits establish a paid or adjudicated1,062,576.98 entitlement to HII funds?
Specifically named source propositions support the bounded distinction or question.
California clerk J.Siharath entered Datron’s default23December2025 on CIV100. Entry-of-default boxes are marked, judgment boxes and all money amounts blank. Ruddell signed the mailing declaration to Datron’s Vista address; cost and nonmilitary declaration fields are blank. This is an entered default, not a money judgment against Datron or Cyberlux.supportsHow were arbitration,GoodReason notice/cure and commission exclusions addressed in the California default and proposed federal claim?
Specifically named source propositions support the bounded distinction or question.
The intervention demand1,062,576.98 exceeds California base demand632,599.48 by429,977.50. No itemised bridge reconciles the amounts; neither the retention offer nor existing shareholding should automatically be added to wages or treated as a second independent debt.supportsWhat sales-level adjusted commission calculation,credits,benefits and accruals reconcile632,599.48 to1,062,576.98?
Specifically named source propositions support the bounded distinction or question.
Schmidt proposes alternative SeriesB reallocations: Denis retains20m with Bill receiving30m from Schmidt/Treasury/Denis, or Denis retains10m with Bill receiving20m from Denis and10m from Schmidt. He claims resulting control above75%, seeks Bill’s help negotiating Denis’s override and ending lawsuits, and allows further dilution for capital. No executed transfers or lawsuit dismissals are supplied.supportsWhat transfer restrictions,instructions and current register govern the3mSeriesB,and were July reallocation offers ever executed?
Specifically named source propositions support the bounded distinction or question.
Maadarani says Schmidt repeatedly promised inJune2025 to pay commissions/expenses from HII funds,that those promises caused him to stay,and that hours-long follow-up calls continued after the July email. This adds a first-person reliance/oral-promise account absent from the earlier compilation; no call recordings or written assignment supplied.supportsWhat contemporaneous communications,travel records and commission ledger corroborate the affidavit’s procurement work,repeated promises,reliance and stated balance?
Specifically named source propositions support the bounded distinction or question.
The agreement preserves Company IP/confidentiality,injunctive relief and cooperation; JAMS binding arbitration and jury waiver coexist with California enforcement venue and conditional Florida provisions. Amendments require signed writing/CEO approval; tax409A,assignment,notice,representations,withholding/survival clauses remain. The California jury demand does not show adjudication or waiver of arbitration.supportsHow were arbitration,GoodReason notice/cure and commission exclusions addressed in the California default and proposed federal claim?
Specifically named source propositions support the bounded distinction or question.
The9April2026 intervention complaint seeks1,062,576.98 from the interpleaded funds plus fees/interest and access including sale authority to3mSeriesB. It alleges Cyberlux/Datron interchangeability,contract breach,Schmidt’s July admission and fiduciary breach. Its repetition of those allegations does not establish parent liability,priority or an entered distribution order.supportsWhat assignment,payment undertaking or adjudication establishes Cyberlux liability and priority in the HII fund beyond the named Datron employment agreement?
Specifically named source propositions support the bounded distinction or question.
Maadarani says Schmidt repeatedly promised inJune2025 to pay commissions/expenses from HII funds,that those promises caused him to stay,and that hours-long follow-up calls continued after the July email. This adds a first-person reliance/oral-promise account absent from the earlier compilation; no call recordings or written assignment supplied.supportsThe new affidavit strengthens attribution of the oral-promise/reliance account to Maadarani personally,but it remains the same claimant’s account rather than independent corroboration or a priority ruling.
Specifically named source propositions support the bounded distinction or question.
WEIGH
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A score appears only when its components and change threshold are published.
No published WEIGH run
The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.