Declaration of Charles Watts in Support of Defendants Cyberlux Corporation’s Ex Parte Application to Quash and Recall Plaintiffs’ Request and Application for Writ of Execution
1. I am the special counsel for Defendant Cyberlux Corporation ("Cyberlux"). I am an attorney licensed to practice and in good standing in North Carolina and am located in North Carolina. If called as...
DISTIL analysis
- Cyberlux was current on all settlement payments as of May 31, 2024
- Plaintiffs obtained Virginia state court writ sequestering Cyberlux bank accounts around May 31, 2024
- Sequestration prevented Cyberlux access to funds set aside for June 2024 payment
- Cyberlux requested release of sequestered funds on June 9, 2024; plaintiffs refused
- Plaintiffs characterized Cyberlux as having missed June payment after blocking access to payment funds
- Declaration supports ex parte application to quash writ of execution
Extracted text
4 pages · 5446 charactersHAHN LOESER & PARKS LLP Gabe P. Wright (SBN 208647) One America Plaza 600 W. Broadway, Suite 1500 San Diego, CA 92101 Telephone: 619.810.4300 Facsimile: 619.810.4301
gwright@hahnlaw.com
THOMPSON COBURN LLP JEFFREY N. BROWN, CSB 105520 jbrown@thompsoncoburn.com 10100 Santa Monica Blvd., Suite 500 Los Angeles, California 90067 Tel: 310.282.2500 / Fax: 310.282.2501
EDWARD W. GRAY, JR. (SBN 80966) egray@thompsoncoburn.com 1909 K Street, NW Suite 600 Washington, D.C. 20006 Tel: 202.585.6967 / Fax: 202.585.6969
ALLEN CHESSON & GRIMES DOUGLAS GRIMES (pro hac vice application pending) dgrimes@allenchesson.com 505 N. Church Street Charlotte, NC 28202 Tel: 704.755.6012
Attorneys for Defendant CYBERLUX CORPORATION
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
ATLANTIC WAVE HOLDINGS, LLC, a Virginia limited liability company; and SECURE COMMUNITY, LLC, a Virginia limited Liability company,
Plaintiffs, V.
CYBERLUX CORPORATION, Nevada Corporation;
a
Defendant.
Case No. 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES WATTS IN SUPPORT OF DEFENDANTS CYBERLUX CORPORATION'S EX PARTE APPLICATION TO QUASH AND RECALL PLAINTIFFS' REQUEST AND APPLICATION FOR WRIT OF EXECUTION
Dist. Judge: Ruth Bermudez Montenegro
3:24-cv-00482-RBM-VET
I, Charles Watts, declare:
Executed this 14th day of June, 2024, at Charlotte, North Carolina.
Amy & Wat
Charles Watts
PROOF OF SERVICE [FRCP 5(B)]
STATE OF CALIFORNIA, COUNTY OF SAN DIEGO
I am employed in the County of San Diego, State of California. I am over the age of 18 years and am not a party to the within action; my business address is 600 W. Broadway, Suite 1500, San Diego, CA 92101. My electronic service address is mkanamori@hahnlaw.com.
On June 14, 2024, I served the following document(s) described as:
DECLARATION OF CHARLES WATTS IN SUPPORT OF DEFENDANTS CYBERLUX CORPORATION'S EX PARTE APPLICATION TO QUASH AND RECALL PLAINTIFFS' REQUEST AND APPLICATION FOR WRIT OF EXECUTION
on the interested parties in this action as follows: :selected: BY ELECTRONIC MAIL: A copy of the foregoing document was electronically filed using the CM/ECF system which will send a notice of electronic filing to all CM/ECF participants listed below:
David M. Keithly, SBN 292101 Sara Ross, SBN 346153 Mortenson Taggart Adams LLP 300 Spectrum Center Drive, Ste. 1200 Irvine, CA 92618 Email: dkeithly@mortensontaggart.com sross@mortensontaggart.com
Attorneys for Plaintiffs Atlantic Wave Holdings, LLC Secure Community, LLC
:selected: BY ELECTRONIC MAIL: I caused the documents to be transmitted by electronic mail to the party(s) identified on the below service list using the e-mail address(es) shown. I did not receive, within a reasonable time after transmission, any electronic message or other indication that the transmission(s) were unsuccessful.
James K. Sadigh, SBN 140199 9777 Wilshire Blvd., Suite 400 Beverly Hills, CA 90212 Email: jamessadigh@aol.com Attorneys for Plaintiffs Atlantic Wave Holdings, LLC Secure Community, LLC
I declare that I am employed in the office of a member of the bar of the court at whose direction the service was made.
Executed on June 14, 2024, at San Diego, California.
melisu
Melissa P. Kanamori
Original source file
- File
- aw-awh-sdcal-00482-doc-018-exhibit-2.pdf
- Source UID
- source:0ac0650e4194bd79422b948a8716962ef36991d5764a29547a285ac0003d59e9
- Full SHA-256
- 0ac0650e4194bd79422b948a8716962ef36991d5764a29547a285ac0003d59e9