Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
quotationattribution
Fairwinds disclaims a security interest, lien, assignment, interest and attorneys’ fees in this response.
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3
#111272386v1
Response:
The amount was liquidated on or about July 8, 2025 , when Cyberlux sent to
Fairwinds a spreadsheet detailing the amount owed to Fairwinds on its commission based
upon the total amount Cyberlux had invoiced HII.
(d) Whether you claim a security interest in, lien on, or assignment of all or any portion of
the proceeds and, if so, provide your claimed priority date and explain the basis for your
security interest, lien, or assignment.
Response:
None.
(e) Whether you claim a right to interest and, if so, the amount and basis for continuing
accrual thereof, if any.
Response:
None.
(f) Whether you claim a right to attorneys’ fees and, if so, the basis therefore and the
amount you will claim.
Response:
None.
(g) For any creditor claiming a secured interest, identify the date(s) on which advances
were made to Cyberlux or on its behalf for which any secured interest is claimed.
Response:
Not applicable.
DOCUMENT REQUEST i:
i. Documents supporting or otherwise concerning your answer to the above
interrogatory.
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 4 of 6 PageID# 3007
claimallegation
Fairwinds responds to the joint discovery plan filed February 12, 2026, with response and service dated March 9 and later exhibit filing Apr
Fairwinds responds to the joint discovery plan filed February 12, 2026, with response and service dated March 9 and later exhibit filing April 15. Counsel Breckinridge signs, and General Counsel Thomas Wirth signs a penalty-of-perjury verification qualified by records discovered and inadvertent errors.
Read the anchor · page 1
EXHIBIT 30
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 1 of 6 PageID# 3004
claimallegation
Fairwinds claims Cyberlux owes $2,348,542. It describes an October 3, 2022 teaming agreement giving a prime opportunity or 8% of the first 1
Fairwinds claims Cyberlux owes $2,348,542. It describes an October 3, 2022 teaming agreement giving a prime opportunity or 8% of the first 1,000 drones’ contract value, followed by a June 7, 2023 agreement reaffirming compensation after HII became prime. The agreements themselves are not attached.
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#111272386v1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff
v.
CYBERLUX CORPORATION;
ATLANTIC WAVE HOLDINGS, LLC;
SECURE COMMUNITY, LLC;
LEGALIST SPV III, LP; UNITED
STATES OF AMERICA; ADVANCED
NAVIGATION AND POSITIONING
CORPORATION; and ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483-JAG
FAIRWINDS TECHNOLOGIES, LLC’S
RESPONSE TO THE JOINT DISCOVERY PLAN
INTERROGATORY AND DOCUMENT REQUESTS
Now comes Interpleader Defendant/Claimant Fairwinds Technologies, LLC
(“Fairwinds”), who submits the following responses to the Interrogatory and Document Requests
agreed to by all Parties in the Joint Discovery Plan [Doc. 147] filed with the Court on February
12, 2026, as follows:
INTERROGATORY:
Explain the nature of your claim to any of the proceeds that are the subject of this
interpleader, including an explanation of:
(a) The amount of the proceeds that you claim.
Response:
Cyberlux owes Fairwinds $2,348,542.00.
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 2 of 6 PageID# 3005
claimallegation
Fairwinds says Schmidt supplied a spreadsheet and HII invoices July 8, 2025, leading Fairwinds to invoice its commission. It treats the amou
Fairwinds says Schmidt supplied a spreadsheet and HII invoices July 8, 2025, leading Fairwinds to invoice its commission. It treats the amount as liquidated around that date, says Schmidt promised payment from remaining HII funds and says Cyberlux does not dispute the agreements, amount or payment representation. These are verified Fairwinds descriptions of Cyberlux communications, not the communications themselves.
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2
#111272386v1
(b) The legal basis for your right to the proceeds.
Response:
The debt is related to a Teaming Agreement initially entered into by Cyberlux and
Fairwinds on October 3, 2022 , whereby Fairwinds agreed to assist Cyberlux to secure a
contract for the sale of Cyberlux Model K8 Aircraft (“Drones”) and in exchange would be
given the opportunity to serve as prime contractor for the sale of the aircraft , or if another
party was chosen to serve as prime contractor , would receive eight percent ( 8%) of the
contract value associated with the first 1000 Drones delivered. When HII was chosen as
Prime Contractor, Cyberlux and Fairwinds entered into a Strategic Business Development
Service and Supply Teaming Contract (the “Contract”) on June 7, 2023 . that reaffirmed
that Cyberlux would pay Fairwinds eight ( 8%) of the value of the first 1000 D rones
delivered to HII. On July 8, 2025, Mark Schmi dt, Cyberlux’s Chief Executive Officer ,
sent Fairwinds a spreadsheet backed up by invoices to HII documenting the amount
Cyberlux invoiced HII for the Drones and the amount due Fairwinds in exchange for the
consulting and business support services Fairwinds had provided Cyberlux . Fairwinds
responded by issuing an invoice to which Mr. Schmidt said would be paid to Fairwinds out
of the remaining amount HII owed to Cyberlux. Cyberlux told Fairwinds t hose are the
funds placed in deposit with the Court. Cyberlux does not dispute the validity of the
agreements between it and Fairwinds, the amount due to Fairwinds, or the f act that Mr.
Schmidt told Fairwinds it would be paid that amount out of the remaining funds HII owed
to Cyberlux, the same funds deposited with the Court.
(c) How the amount you claim became a liquidated amount or, if not liquidated, state so.
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 3 of 6 PageID# 3006
claimallegation
Fairwinds expressly claims no security interest, lien or assignment of proceeds, no interest and no attorneys’ fees; secured-advance and sec
Fairwinds expressly claims no security interest, lien or assignment of proceeds, no interest and no attorneys’ fees; secured-advance and security-document requests are marked not applicable. This narrows the claim asserted in this response without adjudicating its ultimate right to interpleaded funds.
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#111272386v1
Response:
The amount was liquidated on or about July 8, 2025 , when Cyberlux sent to
Fairwinds a spreadsheet detailing the amount owed to Fairwinds on its commission based
upon the total amount Cyberlux had invoiced HII.
(d) Whether you claim a security interest in, lien on, or assignment of all or any portion of
the proceeds and, if so, provide your claimed priority date and explain the basis for your
security interest, lien, or assignment.
Response:
None.
(e) Whether you claim a right to interest and, if so, the amount and basis for continuing
accrual thereof, if any.
Response:
None.
(f) Whether you claim a right to attorneys’ fees and, if so, the basis therefore and the
amount you will claim.
Response:
None.
(g) For any creditor claiming a secured interest, identify the date(s) on which advances
were made to Cyberlux or on its behalf for which any secured interest is claimed.
Response:
Not applicable.
DOCUMENT REQUEST i:
i. Documents supporting or otherwise concerning your answer to the above
interrogatory.
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 4 of 6 PageID# 3007
claimallegation
Fairwinds identifies responsive documents as Fairwinds-0001 through Fairwinds-0132. Those 132 Bates-numbered pages are referenced but not in
Fairwinds identifies responsive documents as Fairwinds-0001 through Fairwinds-0132. Those 132 Bates-numbered pages are referenced but not included in this six-page exhibit.
Read the anchor · page 5
4
#111272386v1
Response:
Documents responsive to this request are labeled Fairwinds-0001 through Fairwinds-
0132.
DOCUMENT REQUEST ii:
ii. All documents on which you rely to assert any security interest in, lien on, or
assignment of the proceeds that are the subject of this interpleader.
Response:
Not applicable.
Date: March 9, 2026
Respectfully submitted,
ALEXANDER N. BRECKINRIDGE V
(VSB #74708)
MARK A. MINTZ (admitted pro hac vice)
JONES WALKER LLP
1 M Street SE, Suite 600
Washington, DC 20003
Telephone: (202) 203-1021
Facsimile: (202) 203-0000
abreckinridge@joneswalker.com
mmintz@joneswalker.com
Counsel for Intervenor,
Fairwinds Technologies, LLC
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing response was served via email
on all counsel of record.
This the 9th day of March, 2026.
ALEXANDER N. BRECKINRIDGE V
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 5 of 6 PageID# 3008
entityobservation
Fairwinds Technologies, LLC
Read the anchor · page 2
#111272386v1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff
v.
CYBERLUX CORPORATION;
ATLANTIC WAVE HOLDINGS, LLC;
SECURE COMMUNITY, LLC;
LEGALIST SPV III, LP; UNITED
STATES OF AMERICA; ADVANCED
NAVIGATION AND POSITIONING
CORPORATION; and ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483-JAG
FAIRWINDS TECHNOLOGIES, LLC’S
RESPONSE TO THE JOINT DISCOVERY PLAN
INTERROGATORY AND DOCUMENT REQUESTS
Now comes Interpleader Defendant/Claimant Fairwinds Technologies, LLC
(“Fairwinds”), who submits the following responses to the Interrogatory and Document Requests
agreed to by all Parties in the Joint Discovery Plan [Doc. 147] filed with the Court on February
12, 2026, as follows:
INTERROGATORY:
Explain the nature of your claim to any of the proceeds that are the subject of this
interpleader, including an explanation of:
(a) The amount of the proceeds that you claim.
Response:
Cyberlux owes Fairwinds $2,348,542.00.
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 2 of 6 PageID# 3005
entityobservation
Thomas Wirth
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5
#111272386v1
CERTIFICATION
I, Thomas Wirth, General Counsel of Fairwinds Technologies LLC, declare under penalty
of perjury under the laws of the United States of America that: I am duly authorized to verify the
foregoing interrogatory response s and document requests on behalf of Fairwinds Technologies,
LLC; that the information contained in the foregoing responses has been collected and the
responses prepared with the advice and assistance of counsel; and that, subject to any inadvertent
or undiscovered errors, and based on the records and information still in existence and thus far
discovered, the foregoing responses are true and correct.
THOMAS WIRTH, Esq.
General Counsel of Fairwinds Technologies, LLC
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 6 of 6 PageID# 3009
entityobservation
ALEXANDER N. BRECKINRIDGE V
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4
#111272386v1
Response:
Documents responsive to this request are labeled Fairwinds-0001 through Fairwinds-
0132.
DOCUMENT REQUEST ii:
ii. All documents on which you rely to assert any security interest in, lien on, or
assignment of the proceeds that are the subject of this interpleader.
Response:
Not applicable.
Date: March 9, 2026
Respectfully submitted,
ALEXANDER N. BRECKINRIDGE V
(VSB #74708)
MARK A. MINTZ (admitted pro hac vice)
JONES WALKER LLP
1 M Street SE, Suite 600
Washington, DC 20003
Telephone: (202) 203-1021
Facsimile: (202) 203-0000
abreckinridge@joneswalker.com
mmintz@joneswalker.com
Counsel for Intervenor,
Fairwinds Technologies, LLC
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing response was served via email
on all counsel of record.
This the 9th day of March, 2026.
ALEXANDER N. BRECKINRIDGE V
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 5 of 6 PageID# 3008
inferenceinference
The claimed debt is bounded as a specific commission without a claimed security interest or additional interest and fees; proof of a debt al
The claimed debt is bounded as a specific commission without a claimed security interest or additional interest and fees; proof of a debt alone does not resolve allocation of the interpleaded fund.
omissiongap
The underlying agreements, spreadsheet, invoices and Bates production are not included; the response reports their contents.
Read the anchor · page 2
#111272386v1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES CORP.,
Interpleader Plaintiff
v.
CYBERLUX CORPORATION;
ATLANTIC WAVE HOLDINGS, LLC;
SECURE COMMUNITY, LLC;
LEGALIST SPV III, LP; UNITED
STATES OF AMERICA; ADVANCED
NAVIGATION AND POSITIONING
CORPORATION; and ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483-JAG
FAIRWINDS TECHNOLOGIES, LLC’S
RESPONSE TO THE JOINT DISCOVERY PLAN
INTERROGATORY AND DOCUMENT REQUESTS
Now comes Interpleader Defendant/Claimant Fairwinds Technologies, LLC
(“Fairwinds”), who submits the following responses to the Interrogatory and Document Requests
agreed to by all Parties in the Joint Discovery Plan [Doc. 147] filed with the Court on February
12, 2026, as follows:
INTERROGATORY:
Explain the nature of your claim to any of the proceeds that are the subject of this
interpleader, including an explanation of:
(a) The amount of the proceeds that you claim.
Response:
Cyberlux owes Fairwinds $2,348,542.00.
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 2 of 6 PageID# 3005
otherattribution
Complete supplied 6-page source reviewed at SHA-256 f090745fd61ed079de4c38935a255a638bac79016fa212ad8e8de8f999a2744d. Source assertions, ori
Complete supplied 6-page source reviewed at SHA-256 f090745fd61ed079de4c38935a255a638bac79016fa212ad8e8de8f999a2744d. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Exact version_fa679fecf88c4017a4e139c1c7fc6401; SHA256 f090745fd61ed079de4c38935a255a638bac79016fa212ad8e8de8f999a2744d. All six pages read; counsel/service signatures and verification visually inspected. Response date and later federal exhibit date remain distinct.
Read the anchor · page 1
EXHIBIT 30
Case 3:25-cv-00483-JAG Document 175-32 Filed 04/15/26 Page 1 of 6 PageID# 3004
questionquestion
Do the contracts, July8 spreadsheet and invoices support the commission base and any legally effective right to these particular proceeds?
questionquestion
What does Fairwinds actually claim here?
attribution
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
fairwinds asserts cyberlux owes exactly $2 348 542 00 based on 8% commission on drone deliveries to hiirelates to{"chapter":28,"exposure_lens":"The acquisition-chain inquiry locates the official owner of each technical, financial and contractual decision before drawing any conclusion from institutional involvement.","responsibility":"Requirement, contract vehicle, delegated authority, contracting decisions and settlement review.","sequence":328,"unit_key":"CH28"}
The controlling book database maps this allegation into Part II; the book's explicit control-to-exposure crosswalk places that responsibility in Part III, Chapter 28. This is an identifier-based publication link, not a name match.
Fairwinds asserts Cyberlux owes exactly $2,348,542.00 based on 8% commission on drone deliveries to HIIsupportsfairwinds asserts cyberlux owes exactly $2 348 542 00 based on 8% commission on drone deliveries to hii
This database-linked source passage is the reviewed documentary support mapped to the allegation in the controlling book version.
The worksheet’s original shipment lines total392 units and$14,954,400; combined with1,608 closeout units and$43,759,159.81 they produce2,000 units and$58,713,559.81. It uses average value across all2,000, then1,000 units and8%, yielding$2,348,542.3924, displayed as$2,348,542. Whole-dollar rounding explains the display; the worksheet does not establish that averaging is the contractually required first1,000-unit method.qualifiesFairwinds says Schmidt supplied a spreadsheet and HII invoices July 8, 2025, leading Fairwinds to invoice its commission. It treats the amount as liquidated around that date, says Schmidt promised payment from remaining HII funds and says Cyberlux does not dispute the agreements, amount or payment representation. These are verified Fairwinds descriptions of Cyberlux communications, not the communications themselves.
Calculation supports rounded amount but requires first1,000-unit interpretation.
The June6 signed amendment limits Fairwinds control of government submissions to mutually agreed prime/reseller roles; permits another necessary route if Fairwinds cannot offer agreed services; replaces10% with8% and changes the cap to1,000 units from cumulative awarded units. Other original provisions are continued except as amended.supportsFairwinds claims Cyberlux owes $2,348,542. It describes an October 3, 2022 teaming agreement giving a prime opportunity or 8% of the first 1,000 drones’ contract value, followed by a June 7, 2023 agreement reaffirming compensation after HII became prime. The agreements themselves are not attached.
Signed amendment substantiates the8% rate described in the response.
Fairwinds says Schmidt supplied a spreadsheet and HII invoices July 8, 2025, leading Fairwinds to invoice its commission. It treats the amount as liquidated around that date, says Schmidt promised payment from remaining HII funds and says Cyberlux does not dispute the agreements, amount or payment representation. These are verified Fairwinds descriptions of Cyberlux communications, not the communications themselves.supportsDo the contracts, July8 spreadsheet and invoices support the commission base and any legally effective right to these particular proceeds?
Specifically named source propositions support the bounded distinction or question.
Fairwinds claims Cyberlux owes $2,348,542. It describes an October 3, 2022 teaming agreement giving a prime opportunity or 8% of the first 1,000 drones’ contract value, followed by a June 7, 2023 agreement reaffirming compensation after HII became prime. The agreements themselves are not attached.supportsThe claimed debt is bounded as a specific commission without a claimed security interest or additional interest and fees; proof of a debt alone does not resolve allocation of the interpleaded fund.
Specifically named source propositions support the bounded distinction or question.
Fairwinds identifies responsive documents as Fairwinds-0001 through Fairwinds-0132. Those 132 Bates-numbered pages are referenced but not included in this six-page exhibit.supportsWhat does Fairwinds actually claim here?
Specifically named source propositions support the bounded distinction or question.
Fairwinds says Schmidt supplied a spreadsheet and HII invoices July 8, 2025, leading Fairwinds to invoice its commission. It treats the amount as liquidated around that date, says Schmidt promised payment from remaining HII funds and says Cyberlux does not dispute the agreements, amount or payment representation. These are verified Fairwinds descriptions of Cyberlux communications, not the communications themselves.supportsThe underlying agreements, spreadsheet, invoices and Bates production are not included; the response reports their contents.
Specifically named source propositions support the bounded distinction or question.
Fairwinds identifies responsive documents as Fairwinds-0001 through Fairwinds-0132. Those 132 Bates-numbered pages are referenced but not included in this six-page exhibit.supportsThe underlying agreements, spreadsheet, invoices and Bates production are not included; the response reports their contents.
Specifically named source propositions support the bounded distinction or question.
Fairwinds says Schmidt supplied a spreadsheet and HII invoices July 8, 2025, leading Fairwinds to invoice its commission. It treats the amount as liquidated around that date, says Schmidt promised payment from remaining HII funds and says Cyberlux does not dispute the agreements, amount or payment representation. These are verified Fairwinds descriptions of Cyberlux communications, not the communications themselves.supportsWhat does Fairwinds actually claim here?
Specifically named source propositions support the bounded distinction or question.
Fairwinds expressly claims no security interest, lien or assignment of proceeds, no interest and no attorneys’ fees; secured-advance and security-document requests are marked not applicable. This narrows the claim asserted in this response without adjudicating its ultimate right to interpleaded funds.supportsWhat does Fairwinds actually claim here?
Specifically named source propositions support the bounded distinction or question.
Fairwinds claims Cyberlux owes $2,348,542. It describes an October 3, 2022 teaming agreement giving a prime opportunity or 8% of the first 1,000 drones’ contract value, followed by a June 7, 2023 agreement reaffirming compensation after HII became prime. The agreements themselves are not attached.supportsThe underlying agreements, spreadsheet, invoices and Bates production are not included; the response reports their contents.
Specifically named source propositions support the bounded distinction or question.
Fairwinds claims Cyberlux owes $2,348,542. It describes an October 3, 2022 teaming agreement giving a prime opportunity or 8% of the first 1,000 drones’ contract value, followed by a June 7, 2023 agreement reaffirming compensation after HII became prime. The agreements themselves are not attached.supportsWhat does Fairwinds actually claim here?
Specifically named source propositions support the bounded distinction or question.
Fairwinds expressly claims no security interest, lien or assignment of proceeds, no interest and no attorneys’ fees; secured-advance and security-document requests are marked not applicable. This narrows the claim asserted in this response without adjudicating its ultimate right to interpleaded funds.supportsDo the contracts, July8 spreadsheet and invoices support the commission base and any legally effective right to these particular proceeds?
Specifically named source propositions support the bounded distinction or question.
Fairwinds expressly claims no security interest, lien or assignment of proceeds, no interest and no attorneys’ fees; secured-advance and security-document requests are marked not applicable. This narrows the claim asserted in this response without adjudicating its ultimate right to interpleaded funds.supportsThe claimed debt is bounded as a specific commission without a claimed security interest or additional interest and fees; proof of a debt alone does not resolve allocation of the interpleaded fund.
Specifically named source propositions support the bounded distinction or question.
Fairwinds claims Cyberlux owes $2,348,542. It describes an October 3, 2022 teaming agreement giving a prime opportunity or 8% of the first 1,000 drones’ contract value, followed by a June 7, 2023 agreement reaffirming compensation after HII became prime. The agreements themselves are not attached.supportsDo the contracts, July8 spreadsheet and invoices support the commission base and any legally effective right to these particular proceeds?
Specifically named source propositions support the bounded distinction or question.
WEIGH
Explained weighting
A score appears only when its components and change threshold are published.
No published WEIGH run
The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.