Fairwinds agreement filed in the HII interpleader; filed in HII Mission Technologies Corp. v. Cyberlux Corporation et al., No. 25-00483 (E.D. Va.), ECF No. 70-2
Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
observationobservation
Fairwinds proposed intervention complaint and commission worksheet, August 20, 2025
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#104197055v2
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; ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation, and
ASSURE GLOBAL, LLC d/b/a
WESHIELD,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483
[PROPOSED] COMPLAINT IN INTERVENTION OF
FAIRWINDS TECHNOLOGIES LLC
NOW INTO COURT, through undersigned counsel, comes Interpleader
Defendant/Claimant, Fairwinds Technologies LLC (“Fairwinds”).
1. Intervenor Fairwinds asserts through this complaint its interest in the funds that
plaintiff HII Mission Technologies Corp. (“HII”) has proposed to interplead in this case. Cyberlux
Corporation (“Cyberlux”) agreed to pay Fairwinds in connection with the payment from HII that
HII now proposes to deposit with the Court. Fairwinds has an interest in the interpleaded funds
and seeks a judgment and payment in satisfaction of that interest.
PARTIES
2. Claimant Fairwinds is a limited liability corporation organized under the laws of
the state of Maryland.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 1 of 5 PageID# 772
claimallegation
EDVA70-2 filedAugust20,2025 is labelled PROPOSED COMPLAINT IN INTERVENTION of FairwindsTechnologiesLLC,not a teaming agreement itself. It ad
EDVA70-2 filedAugust20,2025 is labelled PROPOSED COMPLAINT IN INTERVENTION of FairwindsTechnologiesLLC,not a teaming agreement itself. It adopts HII party/jurisdiction allegations and asserts an interest in funds proposed for interpleader. The five-page source includes four pleading pages and one InvoiceSummary exhibit.
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#104197055v2
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; ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation, and
ASSURE GLOBAL, LLC d/b/a
WESHIELD,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483
[PROPOSED] COMPLAINT IN INTERVENTION OF
FAIRWINDS TECHNOLOGIES LLC
NOW INTO COURT, through undersigned counsel, comes Interpleader
Defendant/Claimant, Fairwinds Technologies LLC (“Fairwinds”).
1. Intervenor Fairwinds asserts through this complaint its interest in the funds that
plaintiff HII Mission Technologies Corp. (“HII”) has proposed to interplead in this case. Cyberlux
Corporation (“Cyberlux”) agreed to pay Fairwinds in connection with the payment from HII that
HII now proposes to deposit with the Court. Fairwinds has an interest in the interpleaded funds
and seeks a judgment and payment in satisfaction of that interest.
PARTIES
2. Claimant Fairwinds is a limited liability corporation organized under the laws of
the state of Maryland.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 1 of 5 PageID# 772
claimallegation
Fairwinds alleges an October3,2022 teaming agreement under which it would either serve as prime or,if another prime were chosen,receive8% of
Fairwinds alleges an October3,2022 teaming agreement under which it would either serve as prime or,if another prime were chosen,receive8% of contract value associated with the first1000drones delivered. It alleges another prime was selected and a June7,2023 StrategicBusinessDevelopment,ServiceandSupplyTeamingContract confirmed the8% fee. Neither agreement is appended.
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#104197055v2
3. Upon information and belief, the allegations regarding the parties as set forth in the
Plaintiff HII’s Complaint for Interpleader in paragraphs 3 through 11 accurately describe the
parties named in that complaint.
JURISDICTION AND VENUE
4. Fairwinds accepts the allegations regarding jurisdiction and venue set forth in
Plaintiff HII’s Complaint for Interpleader in paragraphs 12 through 16.
FACTUAL ALLEGATIONS
5. On or about October 3, 2022, Fairwinds and Cyberlux entered into a valid
enforceable Teaming Agreement (the “TA”) in which Fairwinds assisted Cyberlux in securing a
contract vehicle award for the shipment of Cyberlux’s Model K8 Aircraft (“Drones”).
6. As consideration for its services, Fairwinds would either: (i) be given the
opportunity to serve as prime contractor for any subsequent award; or, (ii) in the event that a party
other than Fairwinds was chosen to serve as the prime contractor for the subsequent award,
Fairwinds would receive eight percent (8%) of the contract value associated with the first one
thousand (1,000) Drones delivered.
7. A company other than Fairwinds was awarded the prime contract to deliver the
Drones.
8. Cyberlux and Fairwinds then entered into a valid and enforceable Strategic
Business Development, Service and Supply Teaming Contract (the “Contract”) on June 7, 2023.
9. Under the Contract, Cyberlux and Fairwinds agreed that Cyberlux would pay
Fairwinds a fee of eight percent (8%) of the value of the first one thousand (1,000) Drones
delivered.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 2 of 5 PageID# 773
claimallegation
Fairwinds alleges Schmidt sent a July8,2025 spreadsheet valuing its claim at$2,348,542,and it invoiced that sum July9. It alleges no payment
Fairwinds alleges Schmidt sent a July8,2025 spreadsheet valuing its claim at$2,348,542,and it invoiced that sum July9. It alleges no payment and Schmidt’s confirmation payment would come from HII funds. Those are pleading assertions; transmission email,invoice itself and payment ledger are not included.
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#104197055v2
10. On July 8, 2025, Cyberlux’s Chief Executive Officer, Mark Schmidt, sent
Fairwinds a spreadsheet detailing the accounting breakdown of the value of the Drones and valued
the amount owed to Fairwinds as $2,348,542.00.1
11. On July 9, 2025, Fairwinds submitted an invoice for $2,348,542.00 to Cyberlux.
12. To date, Cyberlux has not paid Fairwinds any of the amounts due.
13. Mark Schmidt, CEO of Cyberlux, confirmed that Cyberlux would pay Fairwinds
out of the funds to be disbursed by HII Mission Technologies, Corp. (“HII”) when he valued the
amount owed as $2,348,542.00.
14. At the same time, HII initiated an interpleader action in which the funds in question
were placed in the U.S. District Court for the Eastern District of Virginia (Case No. 3:25-cv-483).
CAUSES OF ACTION
COUNT ONE: JUDGMENT IN INTERPLEADER
PURSUANT TO 28 U.S.C. § 1335 AND 28 U.S.C. § 2361
15. Fairwinds incorporates all of the previous paragraphs as if set forth fully herein.
16. 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.
17. Fairwinds is entitled to a judgment directing that, pursuant to Cyberlux’s
agreements with Fairwinds, the Court pay to Fairwinds $2,348,542.00, plus applicable interest, of
the ultimately interpleaded funds.
PRAYER FOR RELIEF
WHEREFORE, Fairwinds respectfully requests the following relief:
1
Exhibit 1, Invoice Summary.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 3 of 5 PageID# 774
claimallegation
It seeks $2,348,542 plus applicable interest under28USC1335/2361 and equitable distribution. Paragraph14 says funds were placed in the feder
It seeks $2,348,542 plus applicable interest under28USC1335/2361 and equitable distribution. Paragraph14 says funds were placed in the federal court while other paragraphs refer to funds proposed or ultimately to be interpleaded; no registry receipt resolves that timing in this source. /s/AlexanderN.BreckinridgeV signs for proposed intervenor.
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#104197055v2
10. On July 8, 2025, Cyberlux’s Chief Executive Officer, Mark Schmidt, sent
Fairwinds a spreadsheet detailing the accounting breakdown of the value of the Drones and valued
the amount owed to Fairwinds as $2,348,542.00.1
11. On July 9, 2025, Fairwinds submitted an invoice for $2,348,542.00 to Cyberlux.
12. To date, Cyberlux has not paid Fairwinds any of the amounts due.
13. Mark Schmidt, CEO of Cyberlux, confirmed that Cyberlux would pay Fairwinds
out of the funds to be disbursed by HII Mission Technologies, Corp. (“HII”) when he valued the
amount owed as $2,348,542.00.
14. At the same time, HII initiated an interpleader action in which the funds in question
were placed in the U.S. District Court for the Eastern District of Virginia (Case No. 3:25-cv-483).
CAUSES OF ACTION
COUNT ONE: JUDGMENT IN INTERPLEADER
PURSUANT TO 28 U.S.C. § 1335 AND 28 U.S.C. § 2361
15. Fairwinds incorporates all of the previous paragraphs as if set forth fully herein.
16. 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.
17. Fairwinds is entitled to a judgment directing that, pursuant to Cyberlux’s
agreements with Fairwinds, the Court pay to Fairwinds $2,348,542.00, plus applicable interest, of
the ultimately interpleaded funds.
PRAYER FOR RELIEF
WHEREFORE, Fairwinds respectfully requests the following relief:
1
Exhibit 1, Invoice Summary.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 3 of 5 PageID# 774
claimallegation
The worksheet lists CLIN0002/0003 cost$1,353,669.18/$1,403,585.21;truck1–8 CYBL amounts$1,994,110.32,$1,978,756.15,$2,104,910.92,$2,104,910.
The worksheet lists CLIN0002/0003 cost$1,353,669.18/$1,403,585.21;truck1–8 CYBL amounts$1,994,110.32,$1,978,756.15,$2,104,910.92,$2,104,910.92,$2,688,510.06,$3,138,629.76,$2,759,934.81,$4,212,791.47;CLIN0004$1,615,972.07;and cost-line profits$203,050.38/$210,537.78. Cumulative total is$25,769,369.03. Listed shipment dates spanApril25–June3,2025,not proof of each actual delivery.
The sheet separately tracks CLIN0001 gross closeout shipments$43,759,159.81 against$22,776,605.40 ToUSG credit,leaving$20,982,554.41 dueCYBL. It adds other costs$2,757,254.39,CLIN0004$1,615,972.07 and profits$413,588.16 to$25,769,369.03. Gross drone value and net current amount due are distinct denominators.
Commission block combines392original drones/$14,954,400 with1608closeout drones/$43,759,160,totalling2000/$58,713,560. It displays per-unit
Commission block combines392original drones/$14,954,400 with1608closeout drones/$43,759,160,totalling2000/$58,713,560. It displays per-unit average$29,357,1000-unit value$29,356,780 and8% commission$2,348,542. The1000-unit value uses the unrounded aggregate average; multiplying the displayed rounded per-unit value would differ.8% of$29,356,780 is$2,348,542.40,so displayed commission is whole-dollar rounded.
Original-shipment section contains four two-type groups with K8-1$40,500 and K8-2$36,900 unit prices:24/48,48/72,40/88,24/48 quantities,tota
Original-shipment section contains four two-type groups with K8-1$40,500 and K8-2$36,900 unit prices:24/48,48/72,40/88,24/48 quantities,totalling392/$14,954,400. The last two groups both print DD250referencePNWA9432056002CXX; no silent reference correction is made. Notes distinguish CLIN0001 drone shipping from other expense reimbursements.
The worksheet is an accounting presentation attributed to Schmidt by the pleading,not independently authenticated DD250s,invoices,Government
The worksheet is an accounting presentation attributed to Schmidt by the pleading,not independently authenticated DD250s,invoices,Government acceptance or evidence Fairwinds has a perfected proprietary interest. It calculates an average across2000units to value1000,which requires the actual agreement and delivery sequence to test against the pleaded first1000delivered language.
#104197055v2
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; ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation, and
ASSURE GLOBAL, LLC d/b/a
WESHIELD,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483
[PROPOSED] COMPLAINT IN INTERVENTION OF
FAIRWINDS TECHNOLOGIES LLC
NOW INTO COURT, through undersigned counsel, comes Interpleader
Defendant/Claimant, Fairwinds Technologies LLC (“Fairwinds”).
1. Intervenor Fairwinds asserts through this complaint its interest in the funds that
plaintiff HII Mission Technologies Corp. (“HII”) has proposed to interplead in this case. Cyberlux
Corporation (“Cyberlux”) agreed to pay Fairwinds in connection with the payment from HII that
HII now proposes to deposit with the Court. Fairwinds has an interest in the interpleaded funds
and seeks a judgment and payment in satisfaction of that interest.
PARTIES
2. Claimant Fairwinds is a limited liability corporation organized under the laws of
the state of Maryland.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 1 of 5 PageID# 772
entityobservation
Cyberlux Corporation
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#104197055v2
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; ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation, and
ASSURE GLOBAL, LLC d/b/a
WESHIELD,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483
[PROPOSED] COMPLAINT IN INTERVENTION OF
FAIRWINDS TECHNOLOGIES LLC
NOW INTO COURT, through undersigned counsel, comes Interpleader
Defendant/Claimant, Fairwinds Technologies LLC (“Fairwinds”).
1. Intervenor Fairwinds asserts through this complaint its interest in the funds that
plaintiff HII Mission Technologies Corp. (“HII”) has proposed to interplead in this case. Cyberlux
Corporation (“Cyberlux”) agreed to pay Fairwinds in connection with the payment from HII that
HII now proposes to deposit with the Court. Fairwinds has an interest in the interpleaded funds
and seeks a judgment and payment in satisfaction of that interest.
PARTIES
2. Claimant Fairwinds is a limited liability corporation organized under the laws of
the state of Maryland.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 1 of 5 PageID# 772
entityobservation
Mark Schmidt
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#104197055v2
10. On July 8, 2025, Cyberlux’s Chief Executive Officer, Mark Schmidt, sent
Fairwinds a spreadsheet detailing the accounting breakdown of the value of the Drones and valued
the amount owed to Fairwinds as $2,348,542.00.1
11. On July 9, 2025, Fairwinds submitted an invoice for $2,348,542.00 to Cyberlux.
12. To date, Cyberlux has not paid Fairwinds any of the amounts due.
13. Mark Schmidt, CEO of Cyberlux, confirmed that Cyberlux would pay Fairwinds
out of the funds to be disbursed by HII Mission Technologies, Corp. (“HII”) when he valued the
amount owed as $2,348,542.00.
14. At the same time, HII initiated an interpleader action in which the funds in question
were placed in the U.S. District Court for the Eastern District of Virginia (Case No. 3:25-cv-483).
CAUSES OF ACTION
COUNT ONE: JUDGMENT IN INTERPLEADER
PURSUANT TO 28 U.S.C. § 1335 AND 28 U.S.C. § 2361
15. Fairwinds incorporates all of the previous paragraphs as if set forth fully herein.
16. 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.
17. Fairwinds is entitled to a judgment directing that, pursuant to Cyberlux’s
agreements with Fairwinds, the Court pay to Fairwinds $2,348,542.00, plus applicable interest, of
the ultimately interpleaded funds.
PRAYER FOR RELIEF
WHEREFORE, Fairwinds respectfully requests the following relief:
1
Exhibit 1, Invoice Summary.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 3 of 5 PageID# 774
entityobservation
Alexander N. Breckinridge V
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A. A judgment directing that $2,348,542.00, plus applicable interest, be paid out of
the interpleaded funds to Fairwinds; and
B. Such other relief as the Court deems just and reasonable.
August 20, 2025 Respectfully submitted,
/s/ Alexander N. Breckinridge V
ALEXANDER N. BRECKINRIDGE V
(VSB #74708)
JONES WALKER LLP
1 M Street SE, Suite 600
Washington, DC 20003
Telephone: (202) 203-1021
Facsimile: (202) 203-0000
Email: abreckinridge@joneswalker.com
Counsel for Proposed Intervenor
Fairwinds Technologies, LLC
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 4 of 5 PageID# 775
eventattribution
Fairwinds requests intervention and commission payment.
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#104197055v2
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; ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation, and
ASSURE GLOBAL, LLC d/b/a
WESHIELD,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483
[PROPOSED] COMPLAINT IN INTERVENTION OF
FAIRWINDS TECHNOLOGIES LLC
NOW INTO COURT, through undersigned counsel, comes Interpleader
Defendant/Claimant, Fairwinds Technologies LLC (“Fairwinds”).
1. Intervenor Fairwinds asserts through this complaint its interest in the funds that
plaintiff HII Mission Technologies Corp. (“HII”) has proposed to interplead in this case. Cyberlux
Corporation (“Cyberlux”) agreed to pay Fairwinds in connection with the payment from HII that
HII now proposes to deposit with the Court. Fairwinds has an interest in the interpleaded funds
and seeks a judgment and payment in satisfaction of that interest.
PARTIES
2. Claimant Fairwinds is a limited liability corporation organized under the laws of
the state of Maryland.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 1 of 5 PageID# 772
inferenceinference
The attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delive
The attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
otherattribution
Complete supplied 5-page source reviewed at SHA-256 fccf2244ca8586a6c03409f46d2d322363ef35ab1a20e2cb505e2588cccf1986. Source assertions, ori
Complete supplied 5-page source reviewed at SHA-256 fccf2244ca8586a6c03409f46d2d322363ef35ab1a20e2cb505e2588cccf1986. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Own complete native text read, all 5 pages; material page images 2,3,4,5 checked. Exact source identity retained; signature observation does not independently authenticate execution.
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#104197055v2
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; ROBERT W.
BERLETH, solely in his capacity as
Receiver for Cyberlux Corporation, and
ASSURE GLOBAL, LLC d/b/a
WESHIELD,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483
[PROPOSED] COMPLAINT IN INTERVENTION OF
FAIRWINDS TECHNOLOGIES LLC
NOW INTO COURT, through undersigned counsel, comes Interpleader
Defendant/Claimant, Fairwinds Technologies LLC (“Fairwinds”).
1. Intervenor Fairwinds asserts through this complaint its interest in the funds that
plaintiff HII Mission Technologies Corp. (“HII”) has proposed to interplead in this case. Cyberlux
Corporation (“Cyberlux”) agreed to pay Fairwinds in connection with the payment from HII that
HII now proposes to deposit with the Court. Fairwinds has an interest in the interpleaded funds
and seeks a judgment and payment in satisfaction of that interest.
PARTIES
2. Claimant Fairwinds is a limited liability corporation organized under the laws of
the state of Maryland.
Case 3:25-cv-00483-JAG Document 70-2 Filed 08/20/25 Page 1 of 5 PageID# 772
questionquestion
What executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valua
What executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
observation
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
The worksheet lists CLIN0002/0003 cost$1,353,669.18/$1,403,585.21;truck1–8 CYBL amounts$1,994,110.32,$1,978,756.15,$2,104,910.92,$2,104,910.92,$2,688,510.06,$3,138,629.76,$2,759,934.81,$4,212,791.47;CLIN0004$1,615,972.07;and cost-line profits$203,050.38/$210,537.78. Cumulative total is$25,769,369.03. Listed shipment dates spanApril25–June3,2025,not proof of each actual delivery.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Fairwinds alleges an October3,2022 teaming agreement under which it would either serve as prime or,if another prime were chosen,receive8% of contract value associated with the first1000drones delivered. It alleges another prime was selected and a June7,2023 StrategicBusinessDevelopment,ServiceandSupplyTeamingContract confirmed the8% fee. Neither agreement is appended.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
The sheet separately tracks CLIN0001 gross closeout shipments$43,759,159.81 against$22,776,605.40 ToUSG credit,leaving$20,982,554.41 dueCYBL. It adds other costs$2,757,254.39,CLIN0004$1,615,972.07 and profits$413,588.16 to$25,769,369.03. Gross drone value and net current amount due are distinct denominators.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
The sheet separately tracks CLIN0001 gross closeout shipments$43,759,159.81 against$22,776,605.40 ToUSG credit,leaving$20,982,554.41 dueCYBL. It adds other costs$2,757,254.39,CLIN0004$1,615,972.07 and profits$413,588.16 to$25,769,369.03. Gross drone value and net current amount due are distinct denominators.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
The worksheet is an accounting presentation attributed to Schmidt by the pleading,not independently authenticated DD250s,invoices,Government acceptance or evidence Fairwinds has a perfected proprietary interest. It calculates an average across2000units to value1000,which requires the actual agreement and delivery sequence to test against the pleaded first1000delivered language.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
Fairwinds alleges Schmidt sent a July8,2025 spreadsheet valuing its claim at$2,348,542,and it invoiced that sum July9. It alleges no payment and Schmidt’s confirmation payment would come from HII funds. Those are pleading assertions; transmission email,invoice itself and payment ledger are not included.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
The sheet separately tracks CLIN0001 gross closeout shipments$43,759,159.81 against$22,776,605.40 ToUSG credit,leaving$20,982,554.41 dueCYBL. It adds other costs$2,757,254.39,CLIN0004$1,615,972.07 and profits$413,588.16 to$25,769,369.03. Gross drone value and net current amount due are distinct denominators.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Fairwinds alleges an October3,2022 teaming agreement under which it would either serve as prime or,if another prime were chosen,receive8% of contract value associated with the first1000drones delivered. It alleges another prime was selected and a June7,2023 StrategicBusinessDevelopment,ServiceandSupplyTeamingContract confirmed the8% fee. Neither agreement is appended.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Fairwinds alleges Schmidt sent a July8,2025 spreadsheet valuing its claim at$2,348,542,and it invoiced that sum July9. It alleges no payment and Schmidt’s confirmation payment would come from HII funds. Those are pleading assertions; transmission email,invoice itself and payment ledger are not included.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
Original-shipment section contains four two-type groups with K8-1$40,500 and K8-2$36,900 unit prices:24/48,48/72,40/88,24/48 quantities,totalling392/$14,954,400. The last two groups both print DD250referencePNWA9432056002CXX; no silent reference correction is made. Notes distinguish CLIN0001 drone shipping from other expense reimbursements.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
It seeks $2,348,542 plus applicable interest under28USC1335/2361 and equitable distribution. Paragraph14 says funds were placed in the federal court while other paragraphs refer to funds proposed or ultimately to be interpleaded; no registry receipt resolves that timing in this source. /s/AlexanderN.BreckinridgeV signs for proposed intervenor.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Commission block combines392original drones/$14,954,400 with1608closeout drones/$43,759,160,totalling2000/$58,713,560. It displays per-unit average$29,357,1000-unit value$29,356,780 and8% commission$2,348,542. The1000-unit value uses the unrounded aggregate average; multiplying the displayed rounded per-unit value would differ.8% of$29,356,780 is$2,348,542.40,so displayed commission is whole-dollar rounded.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Original-shipment section contains four two-type groups with K8-1$40,500 and K8-2$36,900 unit prices:24/48,48/72,40/88,24/48 quantities,totalling392/$14,954,400. The last two groups both print DD250referencePNWA9432056002CXX; no silent reference correction is made. Notes distinguish CLIN0001 drone shipping from other expense reimbursements.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
It seeks $2,348,542 plus applicable interest under28USC1335/2361 and equitable distribution. Paragraph14 says funds were placed in the federal court while other paragraphs refer to funds proposed or ultimately to be interpleaded; no registry receipt resolves that timing in this source. /s/AlexanderN.BreckinridgeV signs for proposed intervenor.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Fairwinds alleges an October3,2022 teaming agreement under which it would either serve as prime or,if another prime were chosen,receive8% of contract value associated with the first1000drones delivered. It alleges another prime was selected and a June7,2023 StrategicBusinessDevelopment,ServiceandSupplyTeamingContract confirmed the8% fee. Neither agreement is appended.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Original-shipment section contains four two-type groups with K8-1$40,500 and K8-2$36,900 unit prices:24/48,48/72,40/88,24/48 quantities,totalling392/$14,954,400. The last two groups both print DD250referencePNWA9432056002CXX; no silent reference correction is made. Notes distinguish CLIN0001 drone shipping from other expense reimbursements.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
The worksheet is an accounting presentation attributed to Schmidt by the pleading,not independently authenticated DD250s,invoices,Government acceptance or evidence Fairwinds has a perfected proprietary interest. It calculates an average across2000units to value1000,which requires the actual agreement and delivery sequence to test against the pleaded first1000delivered language.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
EDVA70-2 filedAugust20,2025 is labelled PROPOSED COMPLAINT IN INTERVENTION of FairwindsTechnologiesLLC,not a teaming agreement itself. It adopts HII party/jurisdiction allegations and asserts an interest in funds proposed for interpleader. The five-page source includes four pleading pages and one InvoiceSummary exhibit.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Commission block combines392original drones/$14,954,400 with1608closeout drones/$43,759,160,totalling2000/$58,713,560. It displays per-unit average$29,357,1000-unit value$29,356,780 and8% commission$2,348,542. The1000-unit value uses the unrounded aggregate average; multiplying the displayed rounded per-unit value would differ.8% of$29,356,780 is$2,348,542.40,so displayed commission is whole-dollar rounded.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
Commission block combines392original drones/$14,954,400 with1608closeout drones/$43,759,160,totalling2000/$58,713,560. It displays per-unit average$29,357,1000-unit value$29,356,780 and8% commission$2,348,542. The1000-unit value uses the unrounded aggregate average; multiplying the displayed rounded per-unit value would differ.8% of$29,356,780 is$2,348,542.40,so displayed commission is whole-dollar rounded.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
The worksheet lists CLIN0002/0003 cost$1,353,669.18/$1,403,585.21;truck1–8 CYBL amounts$1,994,110.32,$1,978,756.15,$2,104,910.92,$2,104,910.92,$2,688,510.06,$3,138,629.76,$2,759,934.81,$4,212,791.47;CLIN0004$1,615,972.07;and cost-line profits$203,050.38/$210,537.78. Cumulative total is$25,769,369.03. Listed shipment dates spanApril25–June3,2025,not proof of each actual delivery.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
It seeks $2,348,542 plus applicable interest under28USC1335/2361 and equitable distribution. Paragraph14 says funds were placed in the federal court while other paragraphs refer to funds proposed or ultimately to be interpleaded; no registry receipt resolves that timing in this source. /s/AlexanderN.BreckinridgeV signs for proposed intervenor.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
The worksheet lists CLIN0002/0003 cost$1,353,669.18/$1,403,585.21;truck1–8 CYBL amounts$1,994,110.32,$1,978,756.15,$2,104,910.92,$2,104,910.92,$2,688,510.06,$3,138,629.76,$2,759,934.81,$4,212,791.47;CLIN0004$1,615,972.07;and cost-line profits$203,050.38/$210,537.78. Cumulative total is$25,769,369.03. Listed shipment dates spanApril25–June3,2025,not proof of each actual delivery.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
EDVA70-2 filedAugust20,2025 is labelled PROPOSED COMPLAINT IN INTERVENTION of FairwindsTechnologiesLLC,not a teaming agreement itself. It adopts HII party/jurisdiction allegations and asserts an interest in funds proposed for interpleader. The five-page source includes four pleading pages and one InvoiceSummary exhibit.supportsThe attached calculation uses an average over2000drones to value a1000-unit commission base,while the pleading describes the first1000delivered. Whether those bases coincide depends on the contracts and delivery mix; a reconciled spreadsheet does not establish entitlement or priority.
Specifically named source propositions support the bounded distinction or question.
Fairwinds alleges Schmidt sent a July8,2025 spreadsheet valuing its claim at$2,348,542,and it invoiced that sum July9. It alleges no payment and Schmidt’s confirmation payment would come from HII funds. Those are pleading assertions; transmission email,invoice itself and payment ledger are not included.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
The worksheet is an accounting presentation attributed to Schmidt by the pleading,not independently authenticated DD250s,invoices,Government acceptance or evidence Fairwinds has a perfected proprietary interest. It calculates an average across2000units to value1000,which requires the actual agreement and delivery sequence to test against the pleaded first1000delivered language.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
EDVA70-2 filedAugust20,2025 is labelled PROPOSED COMPLAINT IN INTERVENTION of FairwindsTechnologiesLLC,not a teaming agreement itself. It adopts HII party/jurisdiction allegations and asserts an interest in funds proposed for interpleader. The five-page source includes four pleading pages and one InvoiceSummary exhibit.supportsWhat executed agreements,delivery sequence,source invoices and payment/priority records verify the8% obligation and its first1000-unit valuation?
Specifically named source propositions support the bounded distinction or question.
WEIGH
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No published WEIGH run
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