Legal Objection - Post-Judgment Receivership Fee Dispute

ATLANTIC WAVE HOLDINGS, LLC and § §

SECURE COMMUNITY, LLC,

§ Plaintiffs/Judgment-Creditors,

V.

CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually,

§ § § § § § Defendants/Judgment Debtors. §

§

IN THE DISTRICT COURT

129TH JUDICIAL DISTRICT

OF HARRIS COUNTY, TEXAS

DEFENDANTS' OBJECTION TO RECEIVER'S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP

Defendants and Former Judgment Debtors Cyberlux Corporation ("Cyberlux") and Mark D. Schmidt ("Schmidt") (collectively, "Defendants") file this Objection to Receiver's Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership ("Objection") and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows:

On May 22, 2025, the Court entered its Order Appointing Receiver ("Receivership Order," attached as Exhibit } appointing Robert W. Berleth ("Receiver") as a post-judgment receiver under TEX. CIV& PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment ("Underlying Judgment") domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership ("Final Report," attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these

general and specific objections to the Final Report and the Declaration of Robert W. Berleth in Support of Receiver's Fees and Expenses ("Berleth Declaration").

Defendants submit the following general objections to the Final Report, Berleth Declaration, and Receiver's Invoice:

2, 6, Exhibit 3; Wire Transfer Confirmation and Judgment Calculation, Ex. 4. Of that amount, $873,849.02 was disbursed to Plaintiffs by the Receiver. The Receiver is thus not entitled to 33% of the Underlying Judgment. Instead, the Receiver is entitled to, at a maximum, 25% of what the Receiver disbursed to Plaintiffs, which is $218,462.30 and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5. Any fee in excess of that amount would be unreasonable under the circumstances.

The wire was authorized on June 10, 2025, and processed on June 11, 2025. See Wire Transfer Confirmation, Ex. 4.

or unauthorized by the Receivership Order at the hearing on Defendants' Motion for Adjudication of the Receiver's Fees and Expenses and Return of Receivership Assets ("Hearing").

Judgment was satisfied on June 11, 2025, the Receiver had no claim to the interpleaded funds. See E.D. Va. Memorandum Order, Ex. 6.

Defendants submit the following specific objections to the Final Report, paragraph by paragraph, as follows:

and so the fee and expenses allegedly incurred were not "customary, reasonable, and necessary." Nor did the Receiver collect the full amount of the Underlying Judgment due to his own actions. Rather, Legalist voluntarily wired $3,083,639.75 to the Receiver to satisfy the Underlying Judgment. See Original Final Report 11 2, 6, Ex. 3. The Receiver is thus not entitled to a fee of 33% of the amount allegedly collected. The Receiver is instead entitled to, at most, $218,462.30, which is 25% of the amounts disbursed by the Receiver in this action and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5.

summarily denied an application to appoint Robert W. Berleth as a general receiver over Cyberlux after this Court had declined to confer that authority here. See Order Denying Ex Parte Emergency Application to Appoint Receiver, attached as Exhibit 11.

a. Defendants object to subparagraph 7(a) of the Final Report in that the funds identified therein were already paid to Plaintiffs pursuant to this Court's March 2, 2026, Order on Judgment Creditors' Second Amended Motion for Distribution of Funds and Defendants' Motion.

b. Defendants object to subparagraph 7(b) of the Final Report because the expenses claimed were unreasonable and unnecessary because they include numerous expenses that were: (a) incurred after June 11, 2025, when the Receivership concluded by the Receiver's own admission; (b) incurred for action taken or expenses paid that exceeded the scope of the receivership under the Receivership Order and TEX. CIV. PRAC. & REM. CODE § 1.002(b)(3); and (c) were otherwise unreasonable and unnecessary.

Defendants object to subparagraph 7(c) of the Final Report because the Receiver's fee should be limited to, at most, $218,462.30, which is 25% of the amounts disbursed by the Receiver in this action and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5.

a. Defendants object to the first subparagraph because neither the fee requested nor actions taken by the Receiver were reasonable;

b. Defendants agree with the second subparagraph that the Receiver disbursed $873,639.75 to Plaintiffs' Counsel;

c. Defendants object to the third subparagraph because they include numerous expenses that were unreasonable and unnecessary because they were: (a) incurred after June 11, 2025, when the Receivership concluded by the Receiver's own admission; (b) incurred for action taken or expenses paid that exceeded the scope of the receivership under the Receivership Order and TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3); and (c) were otherwise unreasonable and unnecessary.

d. Defendants object to the fourth subparagraph because the Receiver's fee should be limited to, at most, $218,462.30, which is 25% of the amounts

disbursed by the Receiver to Plaintiffs in this action and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5.

e. Defendants object to the fifth subparagraph in that the Receivership has already terminated as a matter of law.

f. Defendants object to the sixth subparagraph to the extent the Receiver requests expenses that were unreasonable and unnecessary because they were: (a) incurred after June 11, 2025, when the Receivership concluded by the Receiver's own admission; (b) incurred for action taken or expenses paid that exceeded the scope of the receivership under the Receivership Order and TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3); and (c) were otherwise unreasonable and unnecessary.

Defendants object to the Berleth Declaration, paragraph by paragraph, as follows:

demanded. Defendants reserve the right to challenge the Receiver's experience and qualifications at the hearing thereon.

virtually none. The Underlying Judgment was satisfied by Legalist. Defendants also object because, as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader has nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized, ultra vires, and took place after the Receiver acknowledged the receivership had concluded. See Original Final Report 19, Ex. 3.

a. The Receiver has failed to provide itemized invoices for attorney's fees and expenses paid to the Receiver's counsel, without which there is no way to determine whether the fees and expenses paid were reasonable and necessary, even if they were authorized (they were not).

b. Expenses identified in Exhibit 1 for purchasing meals for the Receiver's staff are unreasonable and unnecessary and should not be compensated at Defendants'

expense. In addition, the Receiver has failed to provide documentary evidence that these expenses were actually incurred and paid.

c. The Receiver has failed to provide documentary evidence that all expenses identified in Exhibit 1 for locksmiths, storage, and security were actually incurred and paid.

d. All expenses identified in Exhibit 1 for advisory services in Ukraine, travel expenses and per diem related to the Virginia Interpleader, payments to employees, consultant fees, and related matters were not incurred for purposes of collecting the Underlying Judgment and were thus incurred beyond the Receiver's authority. Defendants also object to all expenses incurred prior to the Receiver's appointment and after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 1 9, Ex. 3. Nor has the Receiver provided documentary evidence that any of these expenses were actually incurred and paid.

a. Defendants object to subparagraph 15(A) because the Receiver has failed to provide documentary evidence that storage fees were actually incurred.

b. Defendants object to subparagraph 15(B) because the retainer was paid to a law firm on August 8, 2025, after the Receiver acknowledged the receivership had concluded. See Original Final Report 1 9, Ex. 3. Moreover, as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were

unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

c. Defendants object to subparagraph 15(C) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

d. Defendants object to subparagraph 15(D) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

e. Defendants object to subparagraph 15(E) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. &

REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

f. Defendants object to subparagraph 15(F) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

g. Defendants object to subparagraph 15(G) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

h. Defendants object to subparagraph 15(H) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Moreover, as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the

collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

i. Defendants object to subparagraph 15(I) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Moreover, as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

Defendants object to subparagraph 15(J) to the extent the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Even if the claimed expenses were authorized, the Receiver has provided no

documentary evidence that these expenses were actually incurred and paid or how much of the alleged retainer was applied in the payment thereof.

k. Defendants object to subparagraph 15(K) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex 3. Moreover, as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

m. Defendants object to subparagraph 15(M) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-

judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

n. Defendants object to subparagraph 15(N) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

o. Defendants object to subparagraph 15(O) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE §_31.002(b)(3). Paying those expenses exceeded the Receiver's authority- Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and

Defendants object to subparagraph 15(P) of the Berleth Declaration because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that if the claimed expenses were

authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid or how much of the alleged retainer was applied in the payment thereof.

q. Defendants object to subparagraph 15(Q) because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

r. Defendants object to subparagraph 15(R) of the Berleth Declaration because paying an attorney to prepare a release of a noncompete agreement for a former employee had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority, as did consulting counsel regarding winding down Cyberlux. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

s. Defendants object to subparagraph 15(S) of the Berleth Declaration because paying employees had nothing to do with the Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Paying those expenses exceeded the Receiver's authority. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

t. Defendants object to subparagraph 15(T) of the Berleth Declaration because the Receiver has provided no documentary evidence that the storage fees were actually incurred and paid.

u. Defendants object to subparagraph 15(U) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 195 Ex. 3. Moreover, as set forth in Defendants' General Objection No. 6, incorporated fully herein by

collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires.> Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

v. Defendants object to subparagraph 15(V) because the Receiver incurred the expenses listed for travel related to the Virginia Interpleader. As set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Additionally, these expenses were incurred after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Defendants also object because the Receiver has

failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

w. Defendants object to subparagraph 15(W) because the Receiver incurred the expenses listed for travel related to the Virginia Interpleader. As set forth in

Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Additionally, these expenses were incurred after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

x. Defendants object to subparagraph 15(X) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Defendants further object because the Court denied the Receiver's motion to expand the receivership, and so any legal fees paid to prepare that motion are unreasonable,

unnecessary, and not compensable. See Order Denying Expanding Receiver's Authority, attached as Exhibit 14. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

y. Defendants object to subparagraph 15(Y). It appears the Receiver is requesting he be reimbursed for paying to Plaintiffs funds received from Legalist to satisfy the Underlying Judgment. The Receiver is not entitled to reimbursement for amounts paid to Plaintiffs as an expense.

z. Defendants object to subparagraph 15(Z) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Moreover, as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

aa. Defendants object to subparagraph 15(AA) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Moreover,

as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver and paid.

bb. Defendants object to subparagraph 15(BB) because the fees and costs identified were incurred by the Receiver in retaining a consultant to analyze Cyberlux's government contracts. These consultant fees were incurred after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 1 9, Ex. 3. Moreover, the consultant work has nothing to do with the Receiver's authority to collect the Underlying Judgment, which had already been satisfied, and so were ultra vires. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

cc. Defendants object to subparagraph 15(CC) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Moreover, as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the

collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

dd. Defendants object to subparagraph 15(DD) because the attorney's fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3. Moreover, as set forth in Defendants' General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver's actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid.

To the extent Exhibit 1 to the Berleth Declaration lists fees and expenses not cited in the declaration and addressed above, Defendants object to those fees and expenses, as follows:

a. Defendants object to all fees and expenses incurred related to the Virginia Interpleader for the reasons set forth in Defendants' General Objection No. 6, incorporated fully herein by reference.

b. Defendants object to all fees and expenses incurred to pay employees because paying employees had nothing to do with the Receiver's appointment as a post- judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC.& REM. CODE § 31.002(b)(3).

c. Defendants object to all fees and expenses incurred for security, a constable, locksmiths, and storage fees because the Receiver has failed to provide documentary evidence that those expenses were actually incurred and actually paid.

d. Defendants object to all fees and expenses incurred for North Axis Advisory, to other consultants, and for staff meals, as those matters had nothing to do with the

Receiver's appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3).

e. Defendants object to all fees and expenses incurred prior to the Receiver's appointment and after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report 19, Ex. 3.

f. Defendants object to all fees and expenses not supported by documentary evidence that the fees and expenses were actually incurred and paid.

WHEREFORE, Defendants and Former Judgment Debtors Cyberlux Corporation and court sustain this Objection, deny the relief requested in the Final Report except as to confirming the receivership has terminated as a matter of law, and grant the Defendants and Judgment Debtors such other and further relief to which they may be justly entitled.

Unofficial Copy Office of Måsilyles, Bly g auss DiskriCel Clerka

Respectfully submitted,

By: /s/ Evan A. Moeller Evan A. Moeller State Bar No. 24051067 evan.moeller@arlaw.com

Aaron G. McLeod

State Bar No. 24100888 aaron.mcleod@arlaw.com LyondellBasell Tower 1221 McKinney St., Suite 4400 Houston, Texas 77010 Telephone: (713) 652-5151

Facsimile: 6713) 652-5152

Attorneys for Cyberlux Corporation and Mark D. Schmidt

Unofficial Copy Office of militar en Base a & M Con Cle

I hereby certify that a copy of the above and foregoing was served pursuant to the Texas Rules of Civil Procedure upon all parties on this 27th day of May, 2026.

/s/ Evan A. Moeller Evan A. Moeller

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Monica Rodgriguez on behalf of Evan Moeller Bar No. 24051067 monica.rodriguez@arlaw.com Envelope ID: 115418415

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Monica Rodgriguez on behalf of Evan Moeller Bar No. 24051067 monica.rodriguez@arlaw.com Envelope ID: 115418415

Filing Code Description: Motion (No Fee)

Filing Description: Defendants' Objection to Receiver's Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership Status as of 5/28/2026 10:22 AM CST

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5/27/2026 7:59:12 PM

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Monica Rodriguez

monica.rodriguez@arlaw.com

5/27/2026 7:59:12 PM

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Daniel AArdmore

daniel.ardmore@ardmorelawfirm.com

5/27/2026 7:59:12 PM

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Automated Certificate of eService

This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Monica Rodgriguez on behalf of Evan Moeller Bar No. 24051067 monica.rodriguez@arlaw.com

Envelope ID: 115418415

Filing Code Description: Motion (No Fee)

Filing Description: Defendants' Objection to Receiver's Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership Status as of 5/28/2026 10:22 AM CST

Case Contacts

Daniel AArdmore

daniel.ardmore@ardmorelawfirm.com

5/27/2026 7:59:12 PM

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Farah Ardmore

farah.ardmore@ardmorelawfirm.com

5/27/2026 7:59:12 PM

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Hannah Fischer

hfischer@thompsoncoburn.com

5/27/2026 7:59:12 PM

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Jocelin A.Tapia

jtapia@thompsoncoburn.com

5/27/2026 7:59:12 PM

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Jemisha Gandhi

jgandhi@bellnunnally.com

5/27/2026 7:59:12 PM

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David M.Keithly

dkeithly@mortensontaggart.com

5/27/2026 7:59:12 PM

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Tia Archuleta

tia.archuleta@ecf.courtdrive.com

5/27/2026 7:59:12 PM

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Tia Archuleta

tia.archuleta@vkhh.com

5/27/2026 7:59:12 PM

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Austin DPriddy

Austin.Priddy@vkhh.com

5/27/2026 7:59:12 PM

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Unofficial Copy