Evidence Record
Plaintiff’s Complaint
Pursuant to Rule 6(b) of the North Carolina Rules of Civil Procedure. Defendant Cyberlux Corporation (hereinafter collectively referred to as "Defendant") respectfully moves this Court for an order extending the time, though and including...
DISTIL analysis
DISTIL Run
Profile
Standard
Version
1
Doc Type
Motion for Extension of Time
Total Nodes
24
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
Motion for Extension of Time Defense counsel (Chuck Watts) representing Cyberlux Corporation Civil litigation, North Carolina Superior Court, Durham County May 23, 2025 - June 24, 2025
typographical_error_in_deadlineprocedural_motionpre_answer_stage
Analytical Frame
Procedural motion in contract/business dispute
Analytical Summary
This is a defendant's motion for extension of time to respond to a complaint in a civil action between The ARG Group, LLC (plaintiff) and Cyberlux Corporation (defendant) filed in Durham County Superior Court. Defense counsel Chuck Watts filed the motion on May 23, 2025, requesting an extension through June 24, 2025 to file an answer or responsive pleading. The motion asserts that the original deadline has not expired, that additional time is needed to prepare a response, that no prior extensions have been obtained, and that the request is made in good faith. A notable typographical error appears in the motion where the requested deadline is stated as 'June 24, 2024' in one location, creating ambiguity about the intended year.
Key Points
- Defendant Cyberlux Corporation seeks extension to respond to plaintiff's complaint through June 24, 2025
- Motion filed pursuant to NC Rule of Civil Procedure 6(b) on May 23, 2025
- Defense counsel represents that original deadline has not expired and no prior extensions obtained
- Motion asserts good faith basis with no intent to delay
- Typographical error appears stating deadline as 'June 24, 2024' instead of 2025 in one instance
Stage 2
Core — Entities, Events, Claims
12 nodes
ENT-001
Entity
The ARG Group, LLC
The ARG Group, LLC is the plaintiff in this civil action filed in Durham County Superior Court, North Carolina.
Page 1 — THE ARG GROUP, LLC.
)
)
Plaintiff,
ENT-002
Entity
Cyberlux Corporation
Cyberlux Corporation is the defendant in this civil action, represented by Chuck Watts.
Page 1 — CYBERLUX CORPORATION.
)
)
Defendant.
ENT-003
Entity
Chuck Watts
Chuck Watts is the attorney representing defendant Cyberlux Corporation, NC Bar #21766, with office at 732 Ninth Street #553, Durham, NC 27705.
Page 1 — Chuck Watts (NC Bar #21766)
732 Ninth Street #553
Durham, NC 27705
CDWatts@me.com
Telephone: 919-491-0560
ENT-004
Entity
Christian Lunghi
Christian Lunghi is the attorney representing plaintiff The ARG Group, LLC, with office at Post Office Box 20248, Raleigh, NC 27619, email CLungi@andersonandjones.com.
Page 2 — Christian Lunghi
Post Office Box 20248
Raleigh, NC 27619
CLungi@@andersonandjones.com
Attorney for Plaintiff
ENT-005
Entity
Durham County Superior Court
The General Court of Justice, Superior Court Division, Durham County, North Carolina, Case No. 25CV004246-310.
Page 1 — STATE OF NORTH CAROLINA
DURHAM COUNTY
IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
FILE NO. 25CV004246-310
EVT-001
Event
Filing of Motion for Extension
On May 23, 2025, defendant Cyberlux Corporation filed a motion for extension of time to respond to plaintiff's complaint.
Page 1 — This the 23 day of May 23, 2025.
EVT-002
Event
Electronic Filing Timestamp
The motion was electronically filed on May 23, 2025 at 4:06 PM through the Durham Superior Court County Clerk of Superior Court system.
Page 1 — Electronically Filed Date: 5/23/2025 4:06 PM Durham Superior Court County Clerk of Superior Court
CLM-001
Claim
Request for Extension Through June 24, 2025
Defendant requests an order extending the time through and including June 24, 2025 within which to serve an answer or other responsive pleading.
Page 1 — Defendant Cyberlux Corporation (hereinafter collectively referred to as "Defendant") respectfully moves this Court for an order extending the time, though and including June 24, 2025, within which to serve an answer or other responsive pleading.
CLM-002
Claim
Original Deadline Not Expired
Defendant asserts that the time within which to answer or otherwise respond to Plaintiff's Complaint has not expired as of the motion filing date.
Page 1 — In support of this Motion, Defendants respectfully show that the time within which to answer or otherwise respond to Plaintiffs' Complaint has not expired
CLM-003
Claim
Need for Additional Time
Defendant claims to require additional time to prepare its answer or other responsive pleading.
Page 1 — that the City Defendants require additional time to prepare its answer or other responsive pleading
CLM-004
Claim
No Prior Extensions
Defendant represents that no prior extensions of time have been obtained in this matter.
Page 1 — that no prior extensions of time have been obtained
CLM-005
Claim
Good Faith Motion
Defendant asserts that this motion is being made in good faith and not for purposes of delay.
Page 1 — that this motion is being made in good faith and not for purposes of delay
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
6 nodes
TEN-001
Tension
Reference to 'City Defendants' in Corporate Case
The motion refers to 'City Defendants' requiring additional time, but the case caption identifies only Cyberlux Corporation as the defendant, with no municipal party listed.
Page 1 — that the City Defendants require additional time to prepare its answer or other responsive pleading
TEN-002
Tension
Year Discrepancy in Requested Deadline
The motion requests an extension 'through and including June 24, 2025' in the introductory paragraph but states 'June 24, 2024' in the prayer for relief section, creating a one-year discrepancy.
Page 1 — extending the time, though and including June 24, 2025, within which to serve an answer or other responsive pleading... WHEREFORE, Defendant respectfully requests that its motion for extension of time be granted and that an order be entered extending their time through and including June 24, 2024
TEN-003
Tension
Plural 'Defendants' Usage for Single Defendant
The motion inconsistently uses plural forms 'Defendants' and 'their' when referring to what appears to be a single defendant, Cyberlux Corporation.
Page 1 — In support of this Motion, Defendants respectfully show... extending their time through and including June 24, 2024, within which to serve their answer or other responsive pleading
QST-001
Question
Intended Extension Deadline Year
Which year is the actual intended deadline for the extension: June 24, 2024 (which would be in the past relative to the filing date) or June 24, 2025?
Page 1 — extending the time, though and including June 24, 2025, within which to serve an answer... that an order be entered extending their time through and including June 24, 2024
QST-002
Question
Template Source for Motion
Was this motion drafted from a template or previous case involving municipal defendants, given the reference to 'City Defendants' in a case with only a corporate defendant?
Page 1 — that the City Defendants require additional time to prepare its answer or other responsive pleading
QST-003
Question
Original Response Deadline
What was the original deadline for defendant to respond to the complaint, given the assertion that it has not yet expired as of May 23, 2025?
Page 1 — the time within which to answer or otherwise respond to Plaintiffs' Complaint has not expired
Stage 4
Interpretive — Inferences, Omissions, Patterns
6 nodes
INF-001
Inference
Likely Typographical Error - Year 2024
The reference to 'June 24, 2024' in the prayer for relief is most likely a typographical error, as this date would be approximately 11 months prior to the motion filing date of May 23, 2025, making it nonsensical as a future deadline.
Page 1 — This the 23 day of May 23, 2025... that an order be entered extending their time through and including June 24, 2024
INF-002
Inference
Document Template Adaptation Issues
Multiple inconsistencies (reference to 'City Defendants,' plural 'Defendants,' and inconsistent pronoun usage) suggest this motion was adapted from a template or previous filing involving different parties without complete customization.
Page 1 — that the City Defendants require additional time... In support of this Motion, Defendants respectfully show
INF-003
Inference
Routine Procedural Motion
The motion represents a standard, routine procedural request common in civil litigation, with representations of good faith, no prior extensions, and deadline not yet expired suggesting an uncontroversial request.
Page 1 — that this motion is being made in good faith and not for purposes of delay... that no prior extensions of time have been obtained... that the time within which to answer or otherwise respond to Plaintiffs' Complaint has not expired
OMI-001
Omission
No Explanation for Need for Extension
The motion provides no specific explanation or justification for why additional time is needed beyond the general statement that defendant 'require[s] additional time to prepare,' omitting details about complexity, scheduling conflicts, or other typical grounds.
Page 1 — that the City Defendants require additional time to prepare its answer or other responsive pleading
OMI-002
Omission
No Reference to Original Complaint Filing Date
The motion does not state when the original complaint was filed or served, making it impossible to verify from this document alone whether the original deadline has truly not expired.
Page 1 — the time within which to answer or otherwise respond to Plaintiffs' Complaint has not expired
OMI-003
Omission
No Indication of Plaintiff's Position
The motion does not indicate whether plaintiff's counsel was consulted about the extension request or whether plaintiff consents to or opposes the extension, which is sometimes addressed in such motions.
Page 1 — Defendant Cyberlux Corporation (hereinafter collectively referred to as "Defendant") respectfully moves this Court for an order extending the time
Extracted text
2 pages · 1975 charactersFiling Header
STATE OF NORTH CAROLINA DURHAM COUNTY
IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION FILE NO. 25CV004246-310
THE ARG GROUP, LLC.
) )
Plaintiff,
)
)
V.
)
CYBERLUX CORPORATION.
)
)
Defendant.
) )
DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT
Pursuant to Rule 6(b) of the North Carolina Rules of Civil Procedure. Defendant Cyberlux Corporation (hereinafter collectively referred to as "Defendant") respectfully moves this Court for an order extending the time, though and including June 24, 2025, within which to serve an answer or other responsive pleading.
In support of this Motion, Defendants respectfully show that the time within which to answer or otherwise respond to Plaintiffs' Complaint has not expired; that the City Defendants require additional time to prepare its answer or other responsive pleading; that no prior extensions of time have been obtained; and that this motion is being made in good faith and not for purposes of delay.
WHEREFORE, Defendant respectfully requests that its motion for extension of time be granted and that an order be entered extending their time through and including June 24, 2024, within which to serve their answer or other responsive pleading.
This the 23 day of May 23, 2025.
AuSale Chuck Watts (NC Bar #21766) 732 Ninth Street #553 Durham, NC 27705 CDWatts@me.com Telephone: 919-491-0560
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the foregoing MOTION FOR EXTENSION OF TIME upon all parties to this action by depositing a copy thereof in the United States mail, first-class postage prepaid, addressed as follows:
Christian Lunghi Post Office Box 20248 Raleigh, NC 27619 CLungi@@andersonandjones.com Attorney for Plaintiff
This the day of May, 2025. ANDLA Chuck Watts (NC Bar #21766) 792 Ninth Street #553 Durham, NC 27705 CDWatts@me.com Telephone: 919-491-0560
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
- cm-arg-v-cyberlux-durham-nc-exhibit-2.pdf
- Source UID
- source:3ebb7b24723a830fd3a228065aa2ce27b5a12c486e4e931c6ac9ffd2d84889a7
- Full SHA-256
- 3ebb7b24723a830fd3a228065aa2ce27b5a12c486e4e931c6ac9ffd2d84889a7