Evidence Record

Declaration of William Welter in Support of Plaintiffs Atlantic Wave Holdings, LLC’s and Secure Community, LLC’s Further Supplemental Update re: Defendants’ Motion to Vacate

1. I am the Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC, Plaintiffs in this matter. I have personal knowledge of the facts stated herein and, if called upon to testify,...

Type: declaration
Court: SDCAL
Case: Atlantic Wave / Cyberlux litigation
Pages: 10
Lines: 522
SHA-256: d339b83d62b0

DISTIL analysis

DISTIL Run

Profile

Standard

Version

Doc Type

court_declaration

Total Nodes

Node Legend

Entity (ENT)

Event (EVT)

Claim (CLM)

Anchor (ANC)

Omission (OMI)

Tension (TEN)

Tell (TEL)

Inference (INF)

Hypothesis (HYP)

Stage 1

Index

Orientation · No nodes

Document Classification

court_declaration plaintiff_managing_director civil_litigation_judgment_enforcement 2023-09-08 to 2024-11-07

asset_transfercourt_misrepresentationcontract_terminationfactoring_assignment

Analytical Frame

fraudulent_transfer_analysis

Analytical Summary

William Welter, Managing Director of Atlantic Wave Holdings and Secure Community, declares that defendants Cyberlux Corporation and Mark Schmidt have systematically concealed assets and misrepresented material facts to avoid satisfying a Virginia judgment. Key evidence includes a $38.7 million payment received by Cyberlux in September 2023 that was not disclosed or used to satisfy the judgment, assignment of contract receivables to factoring company Legalist SVP III in April 2024 without notice, and termination of a U.S. Government drone contract in May 2024 that defendants repeatedly cited as the payment source. Defendants falsely told plaintiffs in October 2023 there had been "no drone sales" despite receiving the substantial payment. Defendants' counsel also falsely represented to a Texas court in October 2024 that a stay had been granted in Virginia proceedings when no such stay existed.

Key Points

Cyberlux received $38.7 million payment from HII Technical on September 8, 2023
Defendants assigned future contract payments to factoring company Legalist in April 2024 without disclosure
U.S. Government drone contract terminated in May 2024 but not disclosed to plaintiffs
Defendants falsely stated "no drone sales" in October 2023 despite receiving substantial funds
Defendants' counsel misrepresented to Texas court that Virginia stay was granted

Stage 2

Core — Entities, Events, Claims

20 nodes

ENT-001

Entity

William Welter

Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC, the plaintiffs in this litigation matter

Page 2 — I am the Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC, Plaintiffs in this matter.

ENT-002

Entity

Atlantic Wave Holdings, LLC

Virginia limited liability company, plaintiff in the case seeking to enforce a judgment against defendants

Page 1 — ATLANTIC WAVE HOLDINGS, LLC, a Virginia limited liability company

ENT-003

Entity

Secure Community, LLC

Virginia limited liability company, co-plaintiff with Atlantic Wave Holdings in judgment enforcement action

Page 1 — SECURE COMMUNITY, LLC, a Virginia limited Liability company

ENT-004

Entity

Cyberlux Corporation

Nevada corporation, defendant in judgment enforcement litigation, holder of government drone contract and recipient of substantial payments

Page 1 — CYBERLUX CORPORATION, a Nevada Corporation

ENT-005

Entity

Mark D. Schmidt

Individual defendant alongside Cyberlux Corporation in the judgment enforcement action

Page 1 — MARK D. SCHMIDT, Defendants

ENT-006

Entity

Legalist SVP III

Factoring company that purchases accounts receivable at a discount. Defendants assigned their interests in future government contract payments to Legalist without notifying plaintiffs.

Page 2 — Defendants assigned their interests in future payments from a U.S. Government contract that should have been used to pay Plaintiffs, to Legalist SVP III ("Legalist"), a factoring company, without notifying Plaintiffs. A factoring company purchases accounts receivable from businesses at a discount, providing them with immediate cash flow.

ENT-007

Entity

Towne Bank

Financial institution that held Cyberlux's account where the $38.7 million payment was deposited. Plaintiffs served discovery on Towne Bank in garnishment proceedings.

Page 2 — Plaintiffs served discovery on Towne Bank in connection with a garnishment action Plaintiffs initiated to garnish Defendants' funds held there

ENT-008

Entity

Doug Grimes

Attorney at Allen, Chesson & Grimes PLLC who communicated with William Welter on behalf of defendants, stating in October 2023 that there had been no drone sales

Page 3 — Despite receiving substantial funds, Defendants falsely stated in October 2023 that there had been "no drone sales," as per an email from Doug Grimes.

ENT-009

Entity

HII Technical

Entity that wired $38,700,600 to Cyberlux Corporation on September 8, 2023, payment linked to drone sales

Page 2 — The statement shows that Cyberlux received a $38,700,600 payment, via wire from "HII Technical" on September 8, 2023, which is linked to drone sales

EVT-001

Event

HII Technical Payment to Cyberlux

On September 8, 2023, Cyberlux Corporation received a wire transfer payment of $38,700,600 from HII Technical, linked to drone sales. This payment is documented in Cyberlux's Towne Bank account statement.

Page 8 — ACH DEPOSIT HII TECHNICAL SO $38,700,600.00 Sep 08

EVT-002

Event

Assignment to Legalist

In April 2024, defendants transferred all revenue from the U.S. Government drone contract by assigning future payments to Legalist SVP III, a factoring company, without informing plaintiffs, stockholders, or the court. This was done during litigation and in anticipation of plaintiffs' writ.

Page 3 — In April 2024, during the litigation and in anticipation of our writ, Defendants transferred all revenue from the drone contract by assigning it to Legalist. This was done without informing Plaintiffs, stockholders, or the Court

EVT-003

Event

July 2024 Reconfirmation of Assignment

Defendants reconfirmed the assignment of contract payments to Legalist in July 2024, further entrenching their strategy to divert funds away from satisfying the judgment.

Page 3 — Defendants reconfirmed this assignment in July 2024, further entrenching their strategy to divert funds away from satisfying the Judgment

EVT-004

Event

Contract Termination May 2024

Cyberlux's U.S. Government drone contract was terminated in May 2024. Defendants failed to disclose this termination despite repeatedly citing the contract as the primary source of funds to satisfy the judgment.

Page 2, 3 — Plaintiffs also recently discovered that Cyberlux failed to disclose the termination of its U.S. Government drone contract in May 2024. For more than a year now, this contract was repeatedly cited by Defendants as the primary source of funds to satisfy the Judgment.

EVT-005

Event

October 28, 2024 Texas Hearing

William Welter attended a hearing telephonically on Cyberlux's motion to vacate plaintiffs' domesticated judgment in Texas. During this hearing, defendants' counsel falsely represented to the court that a stay of enforcement had been entered in Virginia proceedings.

Page 4 — On October 28, 2024, I attended the hearing telephonically on Cyberlux's motion to vacate Plaintiffs' domesticated Judgment in Texas. During this hearing, I heard Defendants' counsel falsely represent to the court that a stay of enforcement was entered in the Virginia proceedings.

EVT-006

Event

Towne Bank Discovery Production

Towne Bank produced Cyberlux's account statement dated September 30, 2023 in response to discovery served by plaintiffs in connection with garnishment action. The statement revealed the $38.7 million payment from HII Technical.

Page 2 — Plaintiffs served discovery on Towne Bank in connection with a garnishment action Plaintiffs initiated to garnish Defendants' funds held there and Towne Bank produced a statement of Cyberlux's account dated September 30, 2023.

EVT-007

Event

October 10, 2023 Email Communication

Doug Grimes sent an email to William Welter stating "It's my understanding there have been no actual drone sales yet" in response to Welter's inquiry about how many drones were sold after October payment was received.

Page 10 — It's my understanding there have been no actual drone sales yet.

CLM-001

Claim

Assignment Without Notice Violated Settlement Agreement

The assignment of contract revenue to Legalist was done in violation of the Settlement Agreement, which requires disclosure of all material information related to drone sales and status.

Page 3 — This was done without informing Plaintiffs, stockholders, or the Court, in violation of the Settlement Agreement, which requires disclosure of all material information related to drone sales and status

CLM-002

Claim

Payment Should Have Satisfied Judgment

The $38,700,600 payment received from HII Technical on September 8, 2023 should have been used to satisfy the judgment in full.

Page 2 — The statement shows that Cyberlux received a $38,700,600 payment, via wire from "HII Technical" on September 8, 2023, which is linked to drone sales and should have been used to satisfy the Judgment in full.

CLM-003

Claim

False Statement About Virginia Stay

The representation made by defendants' counsel that a stay of enforcement was entered in Virginia proceedings was entirely false, as no stay has been granted or even considered in Virginia.

Page 4 — The representation made by Defendants' counsel was entirely false, as no stay has been granted or even considered in Virginia.

CLM-004

Claim

Assignment Shields Assets from Plaintiffs

The assignment of future contract payments to Legalist effectively shields these assets from plaintiffs, even if the contract had remained active.

Page 2 — The assignment effectively shields these assets from Plaintiffs, even if the contract had remained active.

Stage 3

In Situ — Quotations, Tells, Tensions, Questions

9 nodes

QUO-001

Quotation

No Drone Sales Statement

Doug Grimes stated in email to William Welter: "It's my understanding there have been no actual drone sales yet." This was stated in October 2023, after Cyberlux had received the $38.7 million payment in September 2023.

Page 10 — It's my understanding there have been no actual drone sales yet.

TLL-001

Tell

Repeated Assurances About Contract Funds

Defendants made repeated assurances to plaintiffs that funds from the U.S. Government contract would be used to satisfy the judgment, even as they were assigning those same funds to Legalist.

Page 2 — This assignment was made despite Defendants' repeated assurances that funds from the contract would be used to satisfy the Judgment.

TLL-002

Tell

Claims of Imminent Payment

For months, defendants repeatedly asked plaintiffs to delay enforcement of the judgment, claiming they were about to receive an imminent payment under the contract sufficient to satisfy their judgment debt.

Page 3 — for months, Defendants repeatedly asked Plaintiffs to delay enforcement of the Judgment, claiming they were about to receive an imminent payment under the contract sufficient to satisfy their Judgment debt to Plaintiffs.

TEN-001

Tension

Denial of Drone Sales vs. $38.7M Payment

Stark contradiction between defendants' October 2023 statement that there had been "no drone sales" and the documented receipt of $38,700,600 from HII Technical in September 2023 for drone sales.

Page 3 — Despite receiving substantial funds, Defendants falsely stated in October 2023 that there had been "no drone sales," as per an email from Doug Grimes. This falsehood aligns with Defendants' pattern of misrepresentation intended to delay and obfuscate.

TEN-002

Tension

Contract as Payment Source vs. Secret Assignment

Defendants repeatedly cited the government contract as the primary source to satisfy the judgment while simultaneously and secretly assigning those same contract payments to a third-party factoring company.

Page 2 — This assignment was made despite Defendants' repeated assurances that funds from the contract would be used to satisfy the Judgment. The assignment effectively shields these assets from Plaintiffs

TEN-003

Tension

Requests to Delay vs. Contract Already Terminated

Defendants asked plaintiffs to delay enforcement for months claiming imminent payment from the contract, while the contract had actually been terminated in May 2024 without disclosure.

QST-001

Question

Disposition of $38.7M After Receipt

What happened to the $38,700,600 received by Cyberlux on September 8, 2023? The bank statement shows numerous large withdrawals on the same day totaling over $4 million, but the disposition of the remaining approximately $34 million is unclear from this declaration.

Page 2, 8 — The statement shows that Cyberlux received a $38,700,600 payment, via wire from "HII Technical" on September 8, 2023, which is linked to drone sales and should have been used to satisfy the Judgment in full.

QST-002

Question

Timing of Legalist Assignment Discovery

When exactly did plaintiffs discover the assignment to Legalist? The declaration states they "recently discovered" it but provides specific dates for the April and July 2024 assignments, suggesting documentary evidence exists.

Page 2 — In connection with our attempts to garnish Defendants' funds to satisfy the Virginia Judgment, Plaintiffs recently discovered that Defendants assigned their interests in future payments from a U.S. Government contract

QST-003

Question

Texas Court Response to Misrepresentation

How did the Texas court respond after discovering defendants' counsel's false representation about the Virginia stay? The declaration mentions a 30-day temporary stay was granted but discovery was not halted.

Page 4 — This misrepresentation misled the Texas court into temporarily staying enforcement of the Judgment for 30 days to allow Defendants the opportunity to present evidence of the supposed stay, although it did not halt discovery.

Stage 4

Interpretive — Inferences, Omissions, Patterns

6 nodes

INF-001

Inference

Coordinated Asset Concealment Strategy

The pattern of conduct suggests a coordinated strategy to conceal assets and avoid judgment satisfaction: denying drone sales while receiving payment, assigning future receivables during litigation, failing to disclose contract termination, and misrepresenting facts to multiple courts.

Page 3 — This falsehood aligns with Defendants' pattern of misrepresentation intended to delay and obfuscate.

INF-002

Inference

Anticipatory Transfer to Defeat Judgment

The April 2024 assignment to Legalist appears to be an anticipatory transfer designed to defeat plaintiffs' enforcement efforts, as it was made "during the litigation and in anticipation of our writ" according to the declarant.

Page 3 — In April 2024, during the litigation and in anticipation of our writ, Defendants transferred all revenue from the drone contract by assigning it to Legalist.

INF-003

Inference

Doug Grimes Likely Uninformed or Complicit

Doug Grimes' October 2023 statement about "no drone sales" either indicates he was not informed about the $38.7M payment received the previous month, or he was knowingly making false statements to plaintiffs on behalf of defendants.

Page 3 — Despite receiving substantial funds, Defendants falsely stated in October 2023 that there had been "no drone sales," as per an email from Doug Grimes.

OMI-001

Omission

No Explanation for Large Same-Day Withdrawals

The bank statement shows multiple large withdrawals totaling over $4 million on September 8, 2023, the same day the $38.7M payment was received. The declaration does not explain what these payments were for or to whom they were made.

Page 8 — Sep 08 -$3,000,000.00 Sep 08 -$575,000.00 Sep 08 -$250,000.00 Sep 08 -$100,000.00 Sep 08 -$100,000.00

OMI-002

Omission

Terms of Legalist Assignment Not Disclosed

The declaration references the assignment to Legalist and cites to exhibits, but does not provide details about the terms, amounts, or discount rate of the factoring arrangement, which would be material to understanding the extent of asset diversion.

OMI-003

Omission

Reason for Contract Termination Not Stated

While the declaration states the government drone contract was terminated in May 2024, it does not provide information about why it was terminated, whether for cause, convenience, or other reasons, which could be relevant to assessing defendants' conduct.

Page 2, 3 — Plaintiffs also recently discovered that Cyberlux failed to disclose the termination of its U.S. Government drone contract in May 2024.

Extracted text

10 pages · 12837 characters

Filing Header

David M. Keithly, State Bar No. 292101 dkeithly@mortensontaggart.com Sara K. Ross, State Bar No. 346153 sross@mortensontaggart.com

MORTENSON TAGGART ADAMS LLP 300 Spectrum Center Drive, Suite 1200 Irvine, California 92618 Telephone: (949) 774-2224 Facsimile: (949) 774-2545

Attorneys for Plaintiffs ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC

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, VS. CYBERLUX CORPORATION, a Nevada Corporation and MARK D. SCHMIDT,

Defendants.

CASE NO. 3:24-cv-00482-RBM-VET Honorable Ruth Bermudez Montenegro

Declaration

DECLARATION OF WILLIAM WELTER IN SUPPORT OF PLAINTIFFS ATLANTIC WAVE HOLDINGS, LLC'S AND SECURE COMMUNITY, LLC'S FURTHER SUPPLEMENTAL UPDATE RE: DEFENDANTS' MOTION TO VACATE

Filed concurrently with Further Supplemental Update, Declaration of David M. Keithly and Declaration of Federico J. Zablah

NO ORAL ARGUMENT UNLESS ORDERED BY THE COURT

MORTENSON TAGGART ADAMS LLP

DECLARATION OF WILLIAM WELTER

I, William Welter, declare as follows:

I am the Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC, Plaintiffs in this matter. I have personal knowledge of the facts stated herein and, if called upon to testify, I could and would competently testify to them.

In connection with our attempts to garnish Defendants' funds to satisfy the Virginia Judgment, Plaintiffs recently discovered that Defendants assigned their interests in future payments from a U.S. Government contract that should have been used to pay Plaintiffs, to Legalist SVP III ("Legalist"), a factoring company, without notifying Plaintiffs. (Declaration of Federico J. Zablah in Support of Plaintiffs' Further Supplemental Update ("Zablah Decl."), 11 10-12, Ex. D at ][ 12-15.) A factoring company purchases accounts receivable from businesses at a discount, providing them with immediate cash flow. The factoring company then collects the payments directly from the customers as they become due. This assignment was made despite Defendants' repeated assurances that funds from the contract would be used to satisfy the Judgment. The assignment effectively shields these assets from Plaintiffs, even if the contract had remained active.

Plaintiffs served discovery on Towne Bank in connection with a garnishment action Plaintiffs initiated to garnish Defendants' funds held there and Towne Bank produced a statement of Cyberlux's account dated September 30, 2023. The statement shows that Cyberlux received a $38,700,600 payment, via wire from "HII Technical" on September 8, 2023, which is linked to drone sales and should have been used to satisfy the Judgment in full. A true and correct copy of Cyberlux's September 30, 2023 statement from Towne Bank is attached hereto as Exhibit A, with unrelated information redacted.

Plaintiffs also recently discovered that Cyberlux failed to disclose the termination of its U.S. Government drone contract in May 2024. (Zablah Decl., 11

10-12, Ex. D at 117-10). For more than a year now, this contract was repeatedly cited by Defendants as the primary source of funds to satisfy the Judgment. The cancellation of the contract is particularly significant because, for months, Defendants repeatedly asked Plaintiffs to delay enforcement of the Judgment, claiming they were about to receive an imminent payment under the contract sufficient to satisfy their Judgment debt to Plaintiffs. The failure to disclose this termination deprived Plaintiffs of critical revenue that should have been used to satisfy the Judgment, violated the Settlement Agreement's terms, and casts serious doubt on Defendants' ability to pay the Judgment debt.

In April 2024, during the litigation and in anticipation of our writ, Defendants transferred all revenue from the drone contract by assigning it to Legalist. (Zablah Decl., 11 11-13, Ex. C at 11 12-14.) This was done without informing Plaintiffs, stockholders, or the Court, in violation of the Settlement Agreement, which requires disclosure of all material information related to drone sales and status (Dkt. No. 24-1 at 18).

Defendants reconfirmed this assignment in July 2024, further entrenching their strategy to divert funds away from satisfying the Judgment (Zablah Decl., 111, Ex. C at | 15).

Despite receiving substantial funds, Defendants falsely stated in October 2023 that there had been "no drone sales," as per an email from Doug Grimes. This falsehood aligns with Defendants' pattern of misrepresentation intended to delay and obfuscate. A true and correct copy of the October 10, 2023 email from Doug Grimes to me is attached hereto as Exhibit B.

Throughout this period, Defendants also attempted to sell company assets and filed lawsuits in Virginia, misleading courts in both California and Texas by asserting that these filings were dispositive of the Judgment's validity. However, since filing these lawsuits on July 8, 2024, Defendants have taken no substantive

action, continuing their dilatory tactics (Zablah Decl., 11 13-17; Dkt No. 31 at 11 2- 13).

Plaintiffs' Judgment is rapidly losing all collateral due to Defendants' continued stalling and asset diversion strategies, necessitating swift judicial intervention to prevent further injustice.

10.

On October 28, 2024, I attended the hearing telephonically on Cyberlux's motion to vacate Plaintiffs' domesticated Judgment in Texas. During this hearing, I heard Defendants' counsel falsely represent to the court that a stay of enforcement was entered in the Virginia proceedings.

11.

The representation made by Defendants' counsel was entirely false, as no stay has been granted or even considered in Virginia. (Zablah Decl., 11 4-5.) This misrepresentation misled the Texas court into temporarily staying enforcement of the Judgment for 30 days to allow Defendants the opportunity to present evidence of the supposed stay, although it did not halt discovery.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. This declaration was executed on November 7, 2024, at Tappahannock, VA.

/s/ William Welter William Welter Managing Director Atlantic Wave Holdings, LLC Secure Community, LLC

Exhibit A

Filed 11/07/24

Oh4q 202408 2133947.pdf of 10

TOWNE BANK

P.O. Box 2818 Norfolk, VA 23501-2818 Return Service Requested

52454

MTB3733S093023092629 01 000000000 52454 010 CYBERLUX CORPORATION

Account Number:

XXXXX 6642

Statement Date:

09/30/2023

Items Enclosed:

Page:

of 9

Member Service Information

Lost or Stolen Card: 888-638-6718

Email Inquiries: info@townebank.com

Visit Us Online: www.townebank.com

Visit Us on Facebook! www.facebook.com/townebank

Account Assistance: 919-415-4377

52454

0228259 0001-0009 0000000000000000

As always, online banking provides the latest balance information for your accounts!

VALUE CLASSIC

Account Number:

XXXXXX6642

Balance Summary

Beginning Balance as of 09/01/23

$20,087.01

+ Deposits and Credits (10)

$38,701,840.13

- Checks Posted (0)

$0.00

- Withdrawals and Debits (118)

$23,240,154.65

Ending Balance as of 09/30/23

$15,481,772.49

Number of Days in Statement Period

Items Enclosed

Transaction Detail

Date

Description

Sep 01

Sep 05

Sep 06

Deposits

Withdrawals

-$6,000.00

-$40.00

-$8,000.00

-$3,000.00

Serving Others. Enriching Lives.®

Image Subpoena Case 3:24-CV-00482-RBM-VET 0666CM20988642 BIMY

202408

Document 32-3

of 10

Filed 11/07/24

file

Sers/Willw/L

OW RageID,998 707

Bage 0h4q_20240.

How to Balance Your Checkbook

STEP 1: Verify that all transactions shown on your checking account statement are recorded in your checkbook. (Remember to include interest earned and fees paid.)

Your Adjusted Statement Balance and your checkbook balance should be equal.

If these balances are different:

· Check your figures in balancing.

· Check your addition and subtraction in your checkbook record. We suggest you use a calculator for accuracy.

· Review last month's statement.

IMPORTANT: If there are any errors, notify your branch office at once.

STEP 2: List all deposits and other additions not shown on this statement.

Date

Amount

Total Step 2

STEP 3: List all outstanding checks, purchases and other subtractions not shown on this statement.

Check#/Description

Amount

Total Step 3

Enter the ending balance for your checking account from the front of this statement = Add all deposits and other additions not shown on this statement (Total Step 2)+ $

SUBTOTAL=

Subtract all outstanding checks, purchases and other subtractions not shown on this statement (Total Step 3) - $

THIS AMOUNT SHOULD MATCH THE BALANCE IN YOUR CHECKBOOK = $

THIS NOTICE APPLIES TO INDIVIDUAL CONSUMERS - In Case of Errors or Questions About Your Electronic Transfers If you think your statement or receipt is wrong, or if you need more information about a transaction on your statement, write us on a separate sheet at: Attn: EFT Dept, TowneBank, P.O. Box 2818, Norfolk, VA 23501-2818 . Phone (888) 638-6718

We must hear from you no later than sixty (60) days after we sent you the first statement on which the error or problem appeared. In your letter, give us the following information: Your name, account number and the dollar amount of the suspected error or transfer. Describe the error or transfer and explain, if you can, why you believe there is an error. If you need more information, describe the item you are not sure about.

We will investigate your complaint and will correct any error promptly. If we require more than ten (10) days to do this, we will credit your account for the amount you think is in error so that you will have use of the money during the time it takes us to complete our investigation.

Public Funds are secured. Depositor reports are available upon request.

MEMBER FDIC

LENDER

Image Subpoena Case 3:24-cv-00482-RBM-VET 0000002707606642 0h4q 2024081

Document .par of 10

32-3 file Jsers/willw/ Dow

Filed 11/07/24

PageID 999 8991008862707

Page

0h4q_20240.

T TOWNE BANK

P.O. Box 2818 Norfolk, VA 23501-2818 Return Service Requested

Account Owner:

CYBERLUX CORPORATION

Statement Date:

09/30/2023

Page :

of 9

Transaction Detail (Continued)

Date

Description

Deposits

Withdrawals

Sep 07

-$750.00

I I

Sep 08

ACH DEPOSIT HII TECHNICAL SO

$38,700,600.00

Sep 08

-$3,000,000.00

Sep 08

-$575,000.00

Sep 08

-$250,000.00

Sep 08

-$100,000.00

Sep 08

-$100,000.00

Sep 08

-$89,477.76

Sep 08

-$85,768.25

Sep 08

-$50,000.00

Sep 08

-$50,000.00

Sep 08

-$25,000.00

Sep 08

-$18,540.35

Sep 08

-$10,500.00

Sep 08

-$10,000.00

Sep 08

-$10,000.00

Sep 08

-$6,500.00

Sep 08

-$40.00

Sep 08

-$40.00

Sep 08

-$40.00

Sep 08

-$40.00

Sep 11

$120.00

Sep 11

$120.00

Document 32-3 9 of 10

Filed 11/07/24

PageID.1000

Exhibit B

of 10

Filed 11/07/24

PageID.1001

Page

From: Doug Grimes <dgrimes@allenchesson.com> Date: October 10, 2023 at 3:40:36PM EDT To: willwelter@aol.com

Subject: RE: Cyberlux

Will, It's my understanding there have been no actual drone sales yet. Happy to discuss at your convenience.

Doug Grimes Allen, Chesson & Grimes PLLC 505 N. Church Street Charlotte, NC 28202 704-755-6012 dgrimes@allenchesson.com www.allenchesson.com

From: willwelter@aol.com <willwelter@aol.com> Sent: Monday, October 9, 2023 12:39 PM To: Doug Grimes <dgrimes@allenchesson.com> Subject: Re: Cyberlux

Hi, Doug We received the October payment. Can you advise how many drones were sold? Thanks

Original source file

No source file is attached yet. The record is ready for the PDF/media link when the attachment importer is connected.

File: aw-awh-sdcal-00482-doc-032-attachment-3.pdf
Source UID: source:d339b83d62b069a8f185d51603b11391c214a79c5d1bab657eb66ec4c56b4619
Full SHA-256: d339b83d62b069a8f185d51603b11391c214a79c5d1bab657eb66ec4c56b4619

DISTIL analysis

Extracted text

Declaration of William Welter in Support of Plaintiffs Atlantic Wave Holdings, LLC's and Secure Community, LLC's Further Supplemental Update re: Defendants' Motion to Vacate — Formatted Extract

Original source file