Evidence Record

Declaration of Clark J. Belote

1. I am over 21 years of age and otherwise competent to make this declaration. I have personal knowledge of the statements contained herein. The statements herein are true and correct to the best...

Type
declaration
Court
EDVA
Case
HII v. Cyberlux interpleader
Docket
3:25-cv-00483
Pages
92
Lines
5847
SHA-256
a415a5006c11

DISTIL analysis

DISTIL Run
Profile
Standard
Version
1
Doc Type
Legal Declaration with Billing Records
Total Nodes
27
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
Legal Declaration with Billing Records Clark J. Belote, Kaufman & Canoles, P.C. Federal Interpleader Litigation - Creditor Dispute February 26, 2025 - January 26, 2026
attorney_feesinterpleader_actionmultiple_creditorsbilling_detailfee_recovery_claim
Analytical Frame
Attorney Fee Documentation for Contested Interpleader
Analytical Summary
This declaration supports HII Mission Technologies' claim for attorney fees and costs totaling $176,098.46 in an interpleader action involving disputed funds from a Cyberlux subcontract. Attorney Clark J. Belote of Kaufman & Canoles declares that the firm served as HII's primary counsel for Virginia and North Carolina matters related to Cyberlux creditor disputes from February 26, 2025 through January 23, 2026. The work encompassed prosecuting the interpleader action in the Eastern District of Virginia, responding to multiple garnishment proceedings in Fairfax County Circuit Court, defending against a separate lawsuit filed by James Curtin, and monitoring related Cyberlux litigation. The fees were billed at discounted rates below the firm's standard rates, and the declaration itemizes work across multiple timekeepers including partners billing at $325-$450/hour and associates at $225-$240/hour. The attached invoices provide detailed time entries showing work on complex jurisdictional issues, motion practice, hearings, and coordination among multiple creditor claimants seeking the same pool of funds.
Key Points
  • Total fees and costs claimed: $176,098.46 for approximately 11 months of work
  • Cyberlux general matter fees: $148,542.50; Curtin litigation fees: $28,263.00
  • Work included federal interpleader action, multiple state garnishment proceedings, and defense of separate federal lawsuit
  • Attorneys billed at discounted rates 10-18% below standard firm rates
  • Primary attorney Clark J. Belote worked 313.6 hours on Cyberlux general matters at $330.52 average rate
  • Major work phases included drafting interpleader complaint, opposing motions to dismiss, attending court hearings, and coordinating responses to competing creditor claims
  • HII received $2.7 million payment from government, triggering multiple creditor claims and garnishment actions
  • Receiver appointed in Texas for Cyberlux, complicating jurisdictional issues
  • Multiple creditors filed motions to intervene in interpleader action
Stage 2
Core — Entities, Events, Claims
17 nodes
ENT-001
Entity
HII Mission Technologies Corp.
HII Mission Technologies Corp., interpleader plaintiff seeking to deposit disputed funds and obtain attorney fees
Page 2 — HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff
ENT-002
Entity
Kaufman & Canoles, P.C.
Law firm representing HII in Cyberlux creditor disputes, Virginia State Bar member firm
Page 2, 4 — I am a member of the Virginia State Bar (VSB # 87310) and a partner with the law firm of Kaufman & Canoles, P.C. ("Kaufman"). Kaufman & Canoles, P.C. has been HII's primary counsel for all Virginia and North Carolina matters related to Cyberlux
ENT-003
Entity
Clark J. Belote
Partner at Kaufman & Canoles, Virginia State Bar #87310, over 10 years experience, primary attorney on matter
Page 2, 3 — I, Clark J. Belote, pursuant to 28 U.S. Code § 1746, declare as follows: I am a member of the Virginia State Bar (VSB # 87310) and a partner with the law firm of Kaufman & Canoles, P.C. Mr. Belote, a partner with over 10 years' experience, billed his time at a discounted rate of $325 per hour in 2025 and $375 per hour in 2026.
ENT-004
Entity
Cyberlux Corporation
Subcontractor to HII, subject of receivership, at center of creditor dispute
Page 2 — CYBERLUX CORPORATION, et al., Interpleader Defendants/Claimants. services rendered arising out of or relating to Cyberlux's creditors and related proceedings
ENT-005
Entity
Atlantic Wave
Creditor of Cyberlux who initiated garnishment proceedings in Fairfax County Circuit Court
Page 4 — On March, 11, 2025, Atlantic Wave served a garnishment summons on HII commencing Case No. CL2025-3413 in the Circuit Court of Fairfax County, Virginia. That garnishment proceeding resulted in detailed pleadings, written discovery, and attendance by Kaufman at hearings in Fairfax Circuit Court on July 11, 2025 and August 15, 2025.
ENT-006
Entity
James Curtin
Pro se plaintiff who filed separate lawsuit against HII in federal court claiming HII liable for Cyberlux acts
Page 4 — On or about September 26, 2025, HII was served with a complaint and summons filed by James Curtin, pro se, in the United States District Court for the Eastern District of Virginia, but transferred to the Middle District of North Carolina. Mr. Curtin alleged that HII was liable for the acts and omissions of Cyberlux and its agents.
ENT-007
Entity
ANPC (Advanced Navigation)
Creditor who served HII with garnishment summons in November 2025
Page 5 — On November 10, 2025, HII was served with a garnishment summons issued on behalf of ANPC in the Circuit Court of Fairfax County
EVT-001
Event
Legal services period
Kaufman & Canoles provided legal services to HII from February 26, 2025 through January 13, 2026 on Cyberlux creditor matters
Page 2 — True and correct copies of Kaufman's invoices for services rendered arising out of or relating to Cyberlux's creditors and related proceedings from February 26, 2025 through January 13, 2026 are attached hereto as Exhibit A.
EVT-002
Event
Interpleader action filing
HII filed federal interpleader action in Eastern District of Virginia Richmond Division, case 3:25-cv-483
Page 2 — Civil Action No.: 3:25-cv-483 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff, v. CYBERLUX CORPORATION, et al., Interpleader Defendants/Claimants
EVT-003
Event
Atlantic Wave garnishment
Atlantic Wave served garnishment summons on HII on March 11, 2025 in Fairfax County Circuit Court Case CL2025-3413, resulting in hearings on July 11 and August 15, 2025
Page 4 — On March, 11, 2025, Atlantic Wave served a garnishment summons on HII commencing Case No. CL2025-3413 in the Circuit Court of Fairfax County, Virginia. That garnishment proceeding resulted in detailed pleadings, written discovery, and attendance by Kaufman at hearings in Fairfax Circuit Court on July 11, 2025 and August 15, 2025.
EVT-004
Event
Curtin lawsuit filing
James Curtin filed pro se complaint against HII on September 26, 2025 in EDVA, later transferred to Middle District of North Carolina
Page 4 — On or about September 26, 2025, HII was served with a complaint and summons filed by James Curtin, pro se, in the United States District Court for the Eastern District of Virginia, but transferred to the Middle District of North Carolina. Mr. Curtin alleged that HII was liable for the acts and omissions of Cyberlux and its agents.
EVT-005
Event
Government payment received
HII received $2.7 million payment from the government, triggering interpleader deposit issues
Page 20 — Draft supplement to garnishment answer based on receipt of $2.7mm from the government
CLM-001
Claim
Total fee claim
Kaufman & Canoles claims total fees and costs of $176,098.46 for services February 26, 2025 through January 23, 2026
Page 5 — The total fees and costs incurred from February 26, 2025 through January 23, 2026 totaled $176,098.46 as follows: KC Fees + Costs Cyberlux General Curtin Total [followed by monthly breakdown table showing $146,105.46 for Cyberlux General and $29,993.00 for Curtin]
CLM-002
Claim
Discounted billing rates
Attorneys billed at discounted rates below standard firm rates: Belote at $325-375/hr vs. $400-450 standard, Lewandowski at $450/hr vs. $525-575 standard
Page 3 — All of the hourly rates listed in Exhibit A are either discounted or usual rates Kaufman bills to clients for similar work. Mr. Lewandowski, a partner with over 30 years' experience, billed his time at a discounted rate of $450 per hour. Mr. Belote, a partner with over 10 years' experience, billed his time at a discounted rate of $325 per hour in 2025 and $375 per hour in 2026. [Footnote 1 shows Regular rates: Belote 400/450, Lewandowski 525/575]
CLM-003
Claim
Reasonableness of fees
The hours spent, hourly rates charged, and costs and expenses incurred were reasonable and necessary
Page 4 — The hours spent, hourly rates charged, and the costs and expenses incurred were reasonable and necessary. Kaufman's rates were and are reasonable and appropriate for this matter and commensurate with the market rates in the market in which they were incurred (e.g., Eastern District of Virginia and Middle District of North Carolina).
CLM-004
Claim
Cyberlux general fees breakdown
Cyberlux General fees incurred were $148,542.50, with Clark Belote working 313.6 hours at $330.52 average rate totaling $103,650
Page 5 — The Cyberlux General fees incurred were $148,542.50 as follows: 0194337+0184359 Cyberlux General Timekeeper Hours Worked Average Rate Amount Fees Billed Belote, Clark J. 313.60 $330.52 $103,650.00 [followed by other timekeepers] Subtotal 457.10 $149,032.50 Less Non-Cyberlux Matters $490.00 TOTAL $148,542.50
CLM-005
Claim
Curtin matter fees breakdown
The Curtin-related fees incurred were $28,263.00, with Belote working 39.1 hours at $325/hr for $12,707.50
Page 5, 6 — The Curtin-related fees incurred were $28,263.00 as follows: 195284 Curtin Timekeeper Hours Worked Rate Amount Fees Billed Belote, Clark J. 39.10 $325.00 $12,707.50 Houchin, Joseph E. 12.50 $400.00 $5,000.00 Jones, Lauren P. 43.70 $225.00 $9,832.50 [continues] Total 98.50 $28,263.00
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
5 nodes
QUO-001
Quotation
Declaration opening
I, Clark J. Belote, pursuant to 28 U.S. Code § 1746, declare as follows: I am over 21 years of age and otherwise competent to make this declaration. I have personal knowledge of the statements contained herein. The statements herein are true and correct to the best of my knowledge, information, and belief.
Page 2 — I, Clark J. Belote, pursuant to 28 U.S. Code § 1746, declare as follows: I am over 21 years of age and otherwise competent to make this declaration. I have personal knowledge of the statements contained herein. The statements herein are true and correct to the best of my knowledge, information, and belief.
QUO-002
Quotation
Contemporaneous time records practice
Kaufman's practice is to record contemporaneous time records each day, recording time spent on any given matter to the tenth of the hour (.1) and to avoid block billing. Exhibit A reflects those contemporaneous time records.
Page 3 — Kaufman's practice is to record contemporaneous time records each day, recording time spent on any given matter to the tenth of the hour (.1) and to avoid block billing. Exhibit A reflects those contemporaneous time records.
QST-001
Question
Fee apportionment clarity
How were fees allocated between work directly related to the interpleader action versus parallel garnishment proceedings, and is there potential for duplication in billing?
Page 5 — Kaufman maintained a matter number for all Cyberlux-related matters, including this interpleader action, but for the litigation commenced by James Curtin. Kaufman maintained a separate matter number for all Curtin-related matters. [However, time entries show work on garnishment actions, interpleader, and Texas receivership all under same matter]
QST-002
Question
Contemporaneous vs. reconstructed billing
The declaration states records were made contemporaneously, but the detailed narrative entries in invoices sometimes contain retrospective language—were any time entries reconstructed or supplemented after the fact?
Page 2, 3 — The record of time and expense reflected on the attached documents was made at or near the time of the work performed and expenses incurred by Kaufman attorneys and staff with knowledge of the events described therein. Kaufman's practice is to record contemporaneous time records each day
TEN-001
Tension
Discount vs. market rate claim
The declaration simultaneously claims rates are 'discounted' below standard and also 'reasonable and appropriate...commensurate with the market rates,' creating ambiguity about baseline for reasonableness assessment
Page 3, 4 — All of the hourly rates listed in Exhibit A are either discounted or usual rates Kaufman bills to clients for similar work. [Later] Kaufman's rates were and are reasonable and appropriate for this matter and commensurate with the market rates in the market in which they were incurred (e.g., Eastern District of Virginia and Middle District of North Carolina).
Stage 4
Interpretive — Inferences, Omissions, Patterns
5 nodes
INF-001
Inference
Multiple proceedings complexity
The existence of parallel state garnishment actions, federal interpleader, separate federal lawsuit, and Texas receivership created exceptional complexity requiring coordination across multiple jurisdictions and forums
Page 4 — Since February 26, 2025, multiple Proceedings related to Cyberlux's liabilities to its creditors have required the attention of HII, and HII has employed counsel to address them. Kaufman & Canoles, P.C. has been HII's primary counsel for all Virginia and North Carolina matters related to Cyberlux, including prosecuting this action, responding to multiple garnishment proceedings commenced by Cyberlux creditors, and monitoring active Cyberlux litigation with Atlantic Wave and Secure in the Circuit Court of the City of Richmond.
INF-002
Inference
Fee reasonableness strategy
The declaration emphasizes discounted rates, contemporaneous record-keeping, and necessity of work to preemptively address potential challenges to fee award reasonableness
Page 3, 4 — All of the hourly rates listed in Exhibit A are either discounted or usual rates Kaufman bills to clients for similar work. [followed by detailed comparison showing discounts] Kaufman's practice is to record contemporaneous time records each day, recording time spent on any given matter to the tenth of the hour (.1) and to avoid block billing. The hours spent, hourly rates charged, and the costs and expenses incurred were reasonable and necessary.
INF-003
Inference
Significant attorney time concentration
Clark Belote personally handled the majority of the work, billing 313.6 hours on Cyberlux general matters (68.6% of total hours) and 39.1 hours on Curtin matter (39.7%), suggesting both matter complexity and potential efficiency concerns
Page 5, 6 — Belote, Clark J. 313.60 [hours] $330.52 [rate] $103,650.00 [Cyberlux] Total [Cyberlux General] 457.10 [hours]. Belote, Clark J. 39.10 [hours] $325.00 [rate] $12,707.50 [Curtin] Total [Curtin] 98.50 [hours]
OMI-001
Omission
No alternative dispute resolution discussion
Declaration does not address whether alternative fee arrangements, fee caps, or settlement discussions regarding fees occurred that might have reduced total costs
Page 2, 3, 4, 5 — [No discussion of fee arrangements, budgets, or attempts to limit costs appears in declaration]
OMI-002
Omission
No discussion of work product efficiency
Declaration does not address whether work product from parallel proceedings was leveraged to reduce duplication, or explain why separate matter coding was used for Curtin case despite substantial factual overlap
Page 5 — Kaufman maintained a matter number for all Cyberlux-related matters, including this interpleader action, but for the litigation commenced by James Curtin. Kaufman maintained a separate matter number for all Curtin-related matters. [But both involve HII liability for Cyberlux obligations]

Extracted text

92 pages · 121739 characters

Declaration of Clark J. Belote — Formatted Extract

Type: declaration
Court: EDVA
Matter: HII v. Cyberlux interpleader
Docket: 3:25-cv-00483
Filing Header

Exhibit

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

HII MISSION TECHNOLOGIES CORP.,

Interpleader Plaintiff,

v.

Civil Action No .: 3:25-cv-483

CYBERLUX CORPORATION, et al.,

Interpleader Defendants/Claimants.

DECLARATION OF CLARK J. BELOTE
Declaration

I, Clark J. Belote, pursuant to 28 U.S. Code § 1746, declare as follows:

1.
I am over 21 years of age and otherwise competent to make this declaration. I have personal knowledge of the statements contained herein. The statements herein are true and correct to the best of my knowledge, information, and belief.
2.
I am a member of the Virginia State Bar (VSB # 87310) and a partner with the law firm of Kaufman & Canoles, P.C. ("Kaufman").
3.
True and correct copies of Kaufman's invoices for services rendered arising out of or relating to Cyberlux's creditors and related proceedings from February 26, 2025 through January 13, 2026 are attached hereto as Exhibit A. The persons listed therein worked the hours stated in Exhibit A.
4.
The record of time and expense reflected on the attached documents was made at or near the time of the work performed and expenses incurred by Kaufman attorneys and staff with knowledge of the events described therein.
5.
The attached documents are records which were created and kept by Kaufman in its regular practice and its ordinary course of business. Making and keeping the attached records was and is a regular practice of Kaufman's.
6.
Kaufman's practice is to record contemporaneous time records each day, recording time spent on any given matter to the tenth of the hour (.1) and to avoid block billing. Exhibit A reflects those contemporaneous time records.
7.
All of the costs and expenses listed in Exhibit A were actually and reasonably incurred in the course of Kaufman's representation of HII addressing its rights and obligations and with respect to Cyberlux's creditor issues, including this interpleader action.
8.
All of the hourly rates listed in Exhibit A are either discounted or usual rates Kaufman bills to clients for similar work.
9.
Mr. Lewandowski, a partner with over 30 years' experience, billed his time at a discounted rate of $450 per hour.1
10.
Mr. Houchin, a partner with over 14 years' experience, billed his time at a discounted rate of $400 per hour.
11.
Mr. Belote, a partner with over 10 years' experience, billed his time at a discounted rate of $325 per hour in 2025 and $375 per hour in 2026.
12.
Mr. Khalil, a third-year associate, billed his time at a discounted rate of $240 per hour.
13.
Ms. Jones, a second-year associate, billed her time at a discounted rate of $225 per hour.
1
Regular rates for Kaufman timekeepers were:

Name

2025
Rate
2026
Rate

Belote, Clark J.

Houchin, Joseph E.

Jones, Lauren P.

Khalil, Ahmed M.

Lewandowski, Dennis T.

14.
Paralegals billed their time at less than $200 per hour.
15.
Kaufman's rates were and are reasonable and appropriate for this matter and commensurate with the market rates in the market in which they were incurred (e.g., Eastern District of Virginia and Middle District of North Carolina).
16.
The hours spent, hourly rates charged, and the costs and expenses incurred were reasonable and necessary.
17.
Since February 26, 2025, multiple Proceedings related to Cyberlux's liabilities to its creditors have required the attention of HII, and HII has employed counsel to address them. Kaufman & Canoles, P.C. has been HII's primary counsel for all Virginia and North Carolina matters related to Cyberlux, including prosecuting this action, responding to multiple garnishment proceedings commenced by Cyberlux creditors, and monitoring active Cyberlux litigation with Atlantic Wave and Secure in the Circuit Court of the City of Richmond.
18.
On March, 11, 2025, Atlantic Wave served a garnishment summons on HII commencing Case No. CL2025-3413 in the Circuit Court of Fairfax County, Virginia. That garnishment proceeding resulted in detailed pleadings, written discovery, and attendance by Kaufman at hearings in Fairfax Circuit Court on July 11, 2025 and August 15, 2025.
19.
On or about September 26, 2025, HII was served with a complaint and summons filed by James Curtin, pro se, in the United States District Court for the Eastern District of Virginia, but transferred to the Middle District of North Carolina. Mr. Curtin alleged that HII was liable for the acts and omissions of Cyberlux and its agents.
0.
In response, HII, by and through Kaufman & Canoles, P.C., filed a motion to dismiss and related briefing.
21.
On November 10, 2025, HII was served with a garnishment summons issued on behalf of ANPC in the Circuit Court of Fairfax County, causing HII to negotiate stay pleadings with counsel for ANPC.
22.
All of these ongoing proceedings required counsel to monitor, analyze, preserve, and protect HII's interests, rights, and obligations with respect to the Disputed Funds.
23.
The total fees and costs incurred from February 26, 2025 through January 23, 2026 totaled $176,098.46 as follows:

KC Fees + Costs

Cyberlux General

Curtin

Total

February

$65.00

March

$3,347.50

April

$3,637.50

May

$17,685.30

June

$25,551.50

July

$33,655.71

August

$15,373.25

September

$20,821.50

$5,080.50

October

$1,037.50

$17,337.50

November

$4,155.00

$5,845.00

December

$8,037.50

$1,730.00

January

$12,738.20

Total

$146,105.46

$29,993.00

$176,098.46

24.
Kaufman maintained a matter number2 for all Cyberlux-related matters, including this interpleader action, but for the litigation commenced by James Curtin.
25.
Kaufman maintained a separate matter number3 for all Curtin-related matters.
26.
The Curtin-related fees incurred were $28,263.00 as follows:
2
This was matter number 0194337. In addition, for a short period in March and April 2025, time was kept on a general file 0184359.
3
This was known as 0195284.

Curtin

Timekeeper

Hours Worked

Rate

Amount Fees Billed

Belote, Clark J.

39.10

$325.00

$12,707.50

Houchin, Joseph E.

12.50

$400.00

$5,000.00

Jones, Lauren P.

43.70

$225.00

$9,832.50

Mohamed Khalil, Ahmed

2.70

$240.00

$648.00

Rine, Keri-Jo M.

0.50

$150.00

$75.00

Total

98.50

$28,263.00

27.
The Cyberlux General fees incurred were $148,542.50 as follows:

0194337+0184359

Cyberlux General

Timekeeper

Hours Worked

Average Rate

Amount Fees Billed

Belote, Clark J.

313.60

$330.52

$103,650.00

Jones, Lauren P.

20.90

$225.00

$4,702.50

Lewandowski, Dennis T.

57.00

$450.00

$25,650.00

Mohamed Khalil, Ahmed

55.40

$240.00

$13,296.00

Rawls, Charlotte S.

2.20

$190.00

$418.00

Rine, Keri-Jo M.

5.10

$150.00

$765.00

Sykes, Christina M.

2.90

$190.00

$551.00

Subtotal

457.10

$149,032.50

Less Non-Cyberlux Matters

$490.00

TOTAL

$148,542.50

28.
The delta between the fees in | 27 and the total above in | 23 is comprised of costs incurred as shown in the attached invoices, including filing fees, travel costs, mileage, and other expenses.
I declare under penalty of perjury that the foregoing is true and correct.

ClefJe

Dated: 1/27/26

Exhibit A

KSC KAUFMAN & CANOLES we can. and we will.

kaufCAN.com

March 7, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Law Department 11815 Fountain Way, Suite 500 Newport News, VA 23606

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through February 28, 2025 in connection with: ISR (Alion) General Advice and Counsel (HII Matter No. 2022-4364)

02/10/25

Email M. Sheehan re: C.J. Belote

0.10 hrs.

02/12/25 Review and analyze email from Atlantic Wave counsel re: deposition of M. Schmidt and confidentiality order C.J. Belote 0.30 hrs.

02/14/25 Review and analyze removal pleadings filed by Cyberlux in Texas C.J. Belote 0.90 hrs.

02/28/25

Email communication with Atlantic Wave re: settlement C.J. Belote 0.20 hrs.

TOTAL FOR SERVICES $487.50

CURRENT BILLING FOR THIS MATTER

$487.50

TOTAL DUE FOR THIS MATTER

$487.50

BALANCE DUE UPON RECEIPT

HUNTINGTON INGALLS INDUSTRIES, INC.

March 7, 2025

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

1.50

325.00

$487.50

1.50

$487.50

kaufCAN.com

K&C KAUFMAN & CANOLES we can. and we will.

April 8, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Law Department 11815 Fountain Way, Suite 500 Newport News, VA 23606

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through March 31, 2025 in connection with: ISR (Alion) General Advice and Counsel (HII Matter No. 2022-4364)

03/03/25

Telephone conference with Atlantic Wave re: settlement C.J. Belote

0.30 hrs.

03/06/25

Email M. Sheehan re: C.J. Belote

0.10 hrs.

03/10/25

Email client re:

C.J. Belote

0.10 hrs.

03/10/25

C.J. Belote

0.90 hrs.

NOTE: Unrelated to Cyberlux.

03/11/25

Emails with Atlantic Wave re: settlement C.J. Belote

0.30 hrs.

03/13/25

Review and analyze new garnishment summons and issues arising therefrom C.J. Belote 1.10 hrs.

03/14/25

Review and analyze garnishment issues C.J. Belote 1.20 hrs.

03/14/25

NOTE: Unrelated to Cyberlux.

C.J. Belote

0.10 hrs.

03/14/25

Telephone call with M. Sheehan re: C.J. Belote

0.40 hrs.

Page 11 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

April 8, 2025

03/14/25

Multiple phone calls with W. Welter re: garnishment and document requests C.J. Belote 0.40 hrs.

03/17/25

Review and analyze document production issues with respect to confidentiality issues, including multiple emails with client and opposing counsel re: same

C.J. Belote

1.30 hrs.

03/18/25

Draft proposed protective order C.J. Belote

0.70 hrs.

03/18/25

Telephone conference with Virginia counsel

for Cyberlux re: garnishment issues

C.J. Belote

0.20 hrs.

03/19/25

Revise protective order C.J. Belote

0.40 hrs.

03/23/25

Draft potential penalty provision for

protective order

C.J. Belote

0.30 hrs.

03/25/25

Revise proposed protective order C.J. Belote

0.40 hrs.

03/25/25

Telephone conference with Atlantic Wave C.J. Belote

regarding recent Cyberlux litigation 0.40 hrs.

03/26/25

Review edits to proposed protective order C.J. Belote

from Cyberlux and Atlantic Wave counsel 0.20 hrs.

03/27/25

Emails with counsel re: protective order issues for Cyberlux matter C.J. Belote 0.20 hrs.

03/28/25

Review and analyze rulings from the Texas federal court Cyberlux matter and impacts on HII

C.J. Belote

0.40 hrs.

03/31/25

Telephone conference with M. Sheehan regarding

C.J. Belote

0.40 hrs.

03/31/25

Review and analyze new garnishment pleading received by HII C.J. Belote 0.20 hrs.

03/31/25

Telephone conference with opposing C.J. Belote

counsel regarding status of protective order 0.30 hrs.

Filed 02/03/26

Page 12 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

April 8, 2025

TOTAL FOR SERVICES

$3,347.50

CURRENT BILLING FOR THIS MATTER

$3,347.50

TOTAL DUE FOR THIS MATTER

$3,347.50

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

10.30

325.00

$3,347.50

10.30

$3,347.50

Document 144-6 Filed 02/03/26 1742

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

May 8, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Law Department 11815 Fountain Way, Suite 500 Newport News, VA 23606

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through April 30, 2025 in connection with: ISR (Alion) General Advice and Counsel (HII Matter No. 2022-4364)

04/03/25

Review revisions to protective order from Atlantic Wave counsel C.J. Belote 0.30 hrs.

04/04/25

Email Cyberlux counsel regarding protective order changes and concurrence on production of documents C.J. Belote 0.30 hrs.

04/07/25

Email opposing counsel re: garnishment case protective order

C.J. Belote

0.10 hrs.

04/16/25

NOTE: Unrelated to Cyberlux.

C.J. Belote

0.30 hrs.

04/17/25

Review correspondence from Atlantic Wave Texas counsel C.J. Belote 0.80 hrs.

04/18/25

Review additional Texas pleadings related to Cyberlux matter C.J. Belote 0.40 hrs.

04/18/25

Telephone conference with Texas counsel for Atlantic Wave regarding judgment collection issues

C.J. Belote

0.30 hrs.

04/21/25

Telephone conference with counsel status C.J. Belote

for Cyberlux creditor Aerotech regarding settlement

0.20 hrs.

Page 14 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

May 8, 2025

04/23/25

Review latest pleadings in Cyberlux Texas litigation to prepare for garnishment answer and update client

C.J. Belote 1.40 hrs.

04/24/25

Review and analyze new letter from Cyberlux creditor Atlantic Wave C.J. Belote 0.60 hrs.

04/25/25

Review correspondence from Cyberlux creditor Aerotek, Inc. C.J. Belote 0.30 hrs.

04/25/25

Interoffice conference with C.J. Belote re: Fairfax garnishment D.T. Lewandowski 0.20 hrs.

04/27/25

Review correspondence from Cyberlux creditor Thin Air Gear, LLC C.J. Belote 0.30 hrs.

04/28/25

Multiple emails with Atlantic Wave parties re: protective order and production of documents

C.J. Belote 0.60 hrs.

04/28/25

Review additional correspondence from new Cyberlux creditor and impact on garnishment answer

C.J. Belote

0.50 hrs.

04/29/25

Telephone conference with Cyberlux counsel re: garnishment and document production issues

C.J. Belote

0.20 hrs.

04/29/25

Attend call with M. Sheehan and co-counsel re: C.J. Belote 1.10 hrs.

04/29/25

Review and analyze research issues lien attachment to government property C.J. Belote 0.40 hrs.

04/29/25

Re: Cyberlux - review ownership issues re: free and clear certification D.T. Lewandowski 0.20 hrs.

04/30/25

Draft garnishment answer pleading C.J. Belote 1.10 hrs.

04/30/25

Review and analyze UCC liability and lien attachment issues for Cyberlux matter C.J. Belote 0.80 hrs.

HUNTINGTON INGALLS INDUSTRIES, INC.

May 8, 2025

04/30/25

Draft emails to Atlantic Wave counsel re: C.J. Belote

garnishment issues and document production 0.50 hrs.

04/30/25

Re: Cyberlux - review title passage issues

D.T. Lewandowski

0.10 hrs.

TOTAL FOR SERVICES

$3,637.50

CURRENT BILLING FOR THIS MATTER

$3,637.50

TOTAL DUE FOR THIS MATTER $3,637.50

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

10.50

325.00

$3,412.50

D.T. Lewandowski

0.50

450.00

$225.00

11.00

$3,637.50

Document 144-6 Filed 02/03/26 1745

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

July 3, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through May 31, 2025 in connection with: HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

05/01/25

Attend call with Cyberlux counsel S. Lane re: Texas litigation and certification of invoice issues

C.J. Belote

0.50 hrs.

05/01/25

Telephone conference with S. Freling re:

C.J. Belote

0.20 hrs.

05/01/25

Draft answer and plea of nonjoinder to garnishment summons C.J. Belote 1.10 hrs.

05/01/25

Analyze lien attachment issues under applicable UCC and federal government contracts law for Cyberlux drones

C.J. Belote

1.10 hrs.

05/01/25

Re: Cyberlux - review bfp issues D.T. Lewandowski

0.20 hrs.

05/02/25

Telephone conference with Atlantic Wave Texas counsel re: sealing issues C.J. Belote 0.30 hrs.

05/02/25

Review and analyze sealing motion issues for HII documents filed in Texas litigation C.J. Belote 0.70 hrs.

05/02/25

Review and respond to email from Aerotek counsel re: bond status, including review of prime contract bond-related clauses C.J. Belote 0.40 hrs.

HUNTINGTON INGALLS INDUSTRIES, INC. July 3, 2025

05/03/25

Review emails on Cyberlux matter C.J. Belote

0.10 hrs.

05/04/25

Review and analyze proposed sealing motion from Cyberlux C.J. Belote 0.50 hrs.

05/05/25

Review and analyze Atlantic Wave's brief on motion to seal subcontract documents and related issues for C.J. Belote 0.90 hrs.

05/06/25

Re: Cyberlux - review draft Answer to Garnishment Summons D.T. Lewandowski 0.40 hrs.

05/06/25

Teams call with HII to C.J. Belote

0.70 hrs.

05/06/25

Review new correspondence and pleadings from Atlantic Wave counsel re: Virginia state court action C.J. Belote 0.50 hrs.

05/06/25

Draft and revise garnishment answer and plea of nonjoinder C.J. Belote 2.20 hrs.

05/07/25

Teams meeting with HII regarding C.J. Belote

0.70 hrs.

05/07/25

Analyze options for resolving creditor issues and completion of contract for Cyberlux C.J. Belote 1.50 hrs.

05/07/25

Revise garnishment answer and plea of nonjoinder C.J. Belote

0.60 hrs.

05/07/25

Re: Cyberlux - review Bankruptcy and going out of business issues and how to best prepare for same D.T. Lewandowski 0.80 hrs.

05/08/25

Review and analyze multiple issues arising out of potential disclosure of unredacted settlement agreement to Cyberlux creditors, including priority issues and involuntary bankruptcy C.J. Belote 1.10 hrs.

05/08/25

Re: Cyberlux - Review recent correspondence re: matter and options presented D.T. Lewandowski 0.30 hrs.

Page 18 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 3, 2025

05/09/25

Draft and revise email message to all Cyberlux creditors re: unredacted settlement agreement and NDA for same

C.J. Belote

1.10 hrs.

05/10/25

Revise, finalize and send email message to all Cyberlux creditors' counsel re: NDA for, and disclosure of, unredacted settlement agreement

C.J. Belote

0.60 hrs.

05/12/25

Review and compare newly received executed NDAs from creditors' counsel for any changes and next steps on production of unredacted settlement agreement

C.J. Belote

1.50 hrs.

05/13/25

Draft response to Cyberlux memo re: lien creditor priority issues and UCC 9-406 issues C.J. Belote 0.60 hrs.

05/13/25

Review and analyze Cyberlux memo re: lien creditor priority issues C.J. Belote 2.20 hrs.

05/13/25

Telephone conference with Cyberlux Virginia counsel re: garnishment and priority issues C.J. Belote 0.30 hrs.

05/13/25

Teams call with co-counsel re:

C.J. Belote

0.30 hrs.

05/14/25

Draft and revise portion of letter to Cyberlux responding to Cyberlux "Exhibit A" memo C.J. Belote 1.80 hrs.

05/15/25

Review and analyze multiple emails from Cyberlux counsel re: options and issues for resolution of creditor issues

C.J. Belote

1.50 hrs.

05/15/25

Telephone conference with E. Gray (Cyberlux counsel) regarding Cyberlux funding issues

C.J. Belote

0.40 hrs.

05/16/25

Prepare for and attend call with client re:

C.J. Belote

0.90 hrs.

05/16/25

Email Cyberlux counsel regarding questions on garnishment dismissal and path forward C.J. Belote 0.30 hrs.

05/19/25

Re: Cyberlux - review setoff priority questions D.T. Lewandowski

0.30 hrs.

Page 19 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 3, 2025

05/19/25

Telephone conference with counsel for Cyberlux re: financing for Cyberlux with lender C.J. Belote 0.30 hrs.

05/19/25

Revise draft answer to garnishment summons based on recent correspondence from other creditors

C.J. Belote

2.20 hrs.

05/20/25

Revise garnishment answer and plead of nonjoinder C.J. Belote 1.30 hrs.

05/20/25

Research and analyze lien priority issues C.J. Belote

and interpleader venue for Cyberlux matter 2.00 hrs.

05/20/25

Review caselaw re: interpleader possibility in garnishment, venue for interpleader, and priority of garnishment over UCC security interest A. Mohamed Khalil 2.90 hrs.

05/21/25

Prepare for and attend client call on C.J. Belote

0.80 hrs.

05/21/25

NOTE: Unrelated to Cyberlux. L.P. Jones 0.30 hrs.

05/22/25

Review draft response letter to Cyberlux on financial assurances C.J. Belote 0.40 hrs.

05/23/25

Revise, finalize, and file garnishment answer and plea of nonjoinder C.J. Belote 0.80 hrs.

05/23/25

Extended call with Cyberlux counsel re: payment matters C.J. Belote

potential resolution of garnishment and related

0.90 hrs.

05/23/25

Draft email update to M. Sheehan on C.J. Belote

0.30 hrs.

05/24/25

Review and analyze receiver appointment order for Cyberlux and assess threats for completion of delivery and other next steps C.J. Belote 1.80 hrs.

05/24/25

Extended phone call with R. Berleth, receiver steps at Spring, Texas facility C.J. Belote

appointed for Cyberlux to discuss next 1.10 hrs.

Page 20 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 3, 2025

05/24/25

Teams call with Mission Technologies team re: C.J. Belote

0.60 hrs.

05/25/25

Draft NDA for receiver for delivery of settlement

agreement

C.J. Belote

0.70 hrs.

05/26/25

Communications with S. Freling and client re: C.J. Belote

0.20 hrs.

05/27/25

Check the NC Secretary of State and the Nevada Secretary of State regarding the corporate information and perform UCC lien searches re: Cyberlux

C.S. Rawls

0.70 hrs.

05/27/25

Re: Cyberlux - review Texas Receivership issues D.T. Lewandowski

0.10 hrs.

05/27/25

Draft interpleader complaint re: Cyberlux, including analysis of legal and jurisdictional issues

A. Mohamed Khalil

3.40 hrs.

05/27/25

Review issues surrounding interpleader and C.J. Belote

forthcoming payment from the government 0.70 hrs.

05/27/25

Extended telephone call with Cyberlux counsel regarding payment of funds from the government to the receiver

C.J. Belote

0.50 hrs.

05/28/25

Re: Cyberlux - Review issues after indication D.T. Lewandowski

of payment 0.20 hrs.

05/28/25

Draft supplement to garnishment answer based on receipt of $2.7mm from the government

C.J. Belote :unselected:

1.20 hrs.

05/28/25

Review email updates from M. Sheehan on C.J. Belote

0.10 hrs.

05/28/25

Follow up on pending UCC lien searches C.S. Rawls

0.50 hrs.

05/29/25

Telephone conference with R. Berleth, receiver, settlement agreement proceeds C.J. Belote

re: next steps for Cyberlux and

0.60 hrs.

HUNTINGTON INGALLS INDUSTRIES, INC.

July 3, 2025

05/29/25

Telephone conference with Legalist counsel re: next steps for Cyberlux and settlement agreement proceeds

C.J. Belote

0.60 hrs.

05/29/25

Teams meeting update with M. Sheehan and others re:

C.J. Belote

0.60 hrs.

05/29/25

Review and analyze interpleader issues and Texas subpoena issues

options related to federal jurisdiction and

C.J. Belote

0.90 hrs.

05/29/25

Re: Cyberlux - review draft Supplemental Response

D.T. Lewandowski

0.40 hrs.

05/29/25

Re: Cyberlux - review issues - interpleader

0.20 hrs.

D.T. Lewandowski

05/29/25

Analysis re: statutory interpleader requirements and applicability to Cyberlux matter

A. Mohamed Khalil

0.30 hrs.

05/30/25

Review and respond to proposed motion and order from receiver re: abandonment of warehouse

C.J. Belote

0.80 hrs.

05/30/25

Re: Cyberlux - review Texas Motion and Order and correspondence re: same

D.T. Lewandowski

0.30 hrs.

TOTAL FOR SERVICES

$17,619.50

DISBURSEMENTS AND OTHER FIRM CHARGES

05/29/25

SunTrust Bankcard, NA - NC Secretary of State

- Search Fee

33.00

05/29/25

SunTrust Bankcard, NA - NV Secretary of State - Search Fee

32.80

TOTAL FOR DISBURSEMENTS & OTHER FIRM CHARGES

$65.80

CURRENT BILLING FOR THIS MATTER

$17,685.30

TOTAL DUE FOR THIS MATTER

$17,685.30

BALANCE DUE UPON RECEIPT

July 3, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

44.00

325.00

$14,300.00

L.P. Jones :unselected:

0.30

225.00

$67.50

D.T. Lewandowski

3.20

450.00

$1,440.00

A. Mohamed Khalil

6.60

240.00

$1,584.00

C.S. Rawls

1.20

190.00

$228.00

55.30

$17,619.50

Document 144-6 1752

Filed 02/03/26

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

July 3, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

REMITTANCE ADVICE

For legal services rendered through May 31, 2025

Invoice No. 13065251

Fees:

$17,619.50

Disbursements and other firm charges:

$65.80

Total due for this invoice:

$17,685.30

Pay by eCheck or Credit Card:

Pay by check:

Pay by Wire or ACH transfer:

https://www.kaufcan.com/paymentportal

Kaufman & Canoles, P.C.

P.O. Box 3037

Norfolk, VA 23514

Beneficiary Name and Account:

Kaufman & Canoles, P.C. Operating Receipts

150
West Main Street Suite 2100

Norfolk VA 23510

Account # 0261130242

Beneficiary Bank: TowneBank 109 E. Main Street Norfolk, VA 23510 ABA Routing # 051408949 Swift Code: TOWBUS32

Please reference client matter and (or) invoice number from your statement when making payment. Please send an email to accounting@kaufcan.com to notify us of your payment.

Document 144-6 Filed 02/03/26 1753

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

July 8, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through June 30, 2025 in connection with: HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

06/02/25

Review revised proposed order and email from

Texas counsel for Cyberlux

C.J. Belote

0.50 hrs.

06/02/25

Follow up on UCC lien searches re: Cyberlux C.S. Rawls

0.20 hrs.

06/03/25

Extended Teams call with Cyberlux HII team to C.J. Belote

1.10 hrs.

06/03/25

Telephone conference with Atlantic Wave counsel steps for interpleader

regarding receiver issues and next

C.J. Belote

0.50 hrs.

06/03/25

Revise and finalize supplement to garnishment C.J. Belote

answer 1.10 hrs.

06/03/25

Review of the North Carolina UCC lien search C.S. Rawls

received 0.40 hrs.

06/04/25

Review and analyze latest correspondence from marshaling of assets and list of creditors

the Cyberlux receiver regarding

C.J. Belote

1.40 hrs.

06/04/25

Review UCC search results

D.T. Lewandowski

0.40 hrs.

Page 25 of 92 PageID#

July 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

06/04/25

Consider interpleader options upon IRS liens D.T. Lewandowski 0.20 hrs.

06/04/25

Analysis/review of applicable statutes as to joinder of US as party defendant in connection with federal interpleader action due to IRS tax liens, including review of prerequisites for IRS to act on federal tax lien by levy on accounts receivable A. Mohamed Khalil 0.40 hrs.

06/05/25

Review and analyze Texas case law and statutes to assess risk in opposing Cyberlux receiver's position letter and demands C.J. Belote 2.10 hrs.

06/05/25

Conference call with MT team to C.J. Belote

0.60 hrs.

06/05/25

Review and analyze issues for updating creditor list to Cyberlux under Section 5 of the settlement agreement, including Virginia law on prevention doctrine C.J. Belote 0.50 hrs.

06/05/25

Review Receiver's letter and attachments D.T. Lewandowski

1.30 hrs.

06/05/25

Consider options for proceeding D.T. Lewandowski

0.20 hrs.

06/05/25

Review of the lien search received from Nevada C.S. Rawls

0.40 hrs.

06/06/25

Review and analyze response letter from Cyberlux on obtaining creditor releases C.J. Belote 0.20 hrs.

06/08/25

Review settlement agreement from receiver C.J. Belote

0.30 hrs.

06/09/25

Review status of hearing to terminate Receiver D.T. Lewandowski

0.10 hrs.

06/09/25

Telephone conference with HII team regarding C.J. Belote

0.60 hrs.

06/09/25

Telephone conference with counsel for Legalist C.J. Belote

regarding receivership matter 0.30 hrs.

06/09/25

Telephone conference with counsel for Atlantic Wave regarding receivership matter C.J. Belote 0.40 hrs.

Page 26 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 8, 2025

06/09/25

Email to new counsel in Virginia for Atlantic Wave

C.J. Belote

0.20 hrs.

06/09/25

Review pleadings filed in Texas court related C.J. Belote

to termination of receivership matter

1.40 hrs.

06/10/25

Review and analyze multiple legal and strategic issues for filing interpleader lawsuit in federal court, including venue, jurisdiction, and merits issues

C.J. Belote

2.10 hrs.

06/10/25

Telephone conference with counsel for Cyberlux in Texas regarding potential settlement with the receiver

C.J. Belote

0.30 hrs.

06/10/25

Telephone conference with counsel for Legalist in Texas regarding potential settlement with the receiver

C.J. Belote

0.30 hrs.

06/10/25

Telephone conference with counsel for Atlantic Wave in Virginia regarding potential settlement with the receiver

C.J. Belote

0.50 hrs.

06/10/25

Review and analyze impacts of potential

continuation of receivership in Texas

C.J. Belote

0.90 hrs.

06/10/25

Review various interpleader issues D.T. Lewandowski

1.00 hrs.

06/10/25

Review and consider emails from claimants D.T. Lewandowski

requesting payment 0.20 hrs.

06/10/25

Analyze attorney fee entitlement, setoff and party defendants in federal interpleader action

A. Mohamed Khalil

0.60 hrs.

06/10/25

Review of correspondence from Cyberlux receiver re: impact on interpleader A. Mohamed Khalil 0.30 hrs.

06/10/25

Analyze venue issues for interpleader, A. Mohamed Khalil

including review of applicable statutory authority 0.60 hrs.

06/10/25

Draft/revise federal interpleader complaint re: Cyberlux dispute A. Mohamed Khalil 4.10 hrs.

Page 27 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 8, 2025

06/11/25

Revise draft interpelader complaint for filing in federal court, with analysis of impacts of, and on, garnishment proceedings in state court

C.J. Belote

2.70 hrs.

06/11/25

Review garnishment issues upon filing of

interpleader

D.T. Lewandowski

0.40 hrs.

06/11/25

Initial review of draft Interpleader Complaint D.T. Lewandowski

0.60 hrs.

06/11/25

Review/revise federal interpleader complaint A. Mohamed Khalil

2.60 hrs.

06/12/25

Review and propose revisions to draft Interpleader

Complaints

D.T. Lewandowski

1.10 hrs.

06/12/25

Review impact on garnishments

D.T. Lewandowski

0.10 hrs.

06/12/25

Review Texas Receiver correspondence D.T. Lewandowski

0.10 hrs.

06/12/25

Telephone conference with Texas counsel for Atlantic Wave re: updates on Texas case status

C.J. Belote

0.50 hrs.

06/12/25

Review and analyze motion to terminate C.J. Belote

receivership and order filed by receiver

1.10 hrs.

06/12/25

Review and analyze reply brief pleadings filed C.J. Belote

by Cyberlux in Texas 1.10 hrs.

06/12/25

Analysis of applicable case law re: set off right A. Mohamed Khalil

prior to interpleading funds 1.30 hrs.

06/13/25

Review final letter to receiver from HII Texas C.J. Belote

counsel 0.20 hrs.

06/13/25

Telephone conference with Legalist counsel C.J. Belote

regarding status update

0.20 hrs.

06/13/25

Review recent correspondence re: matter D.T. Lewandowski

0.10 hrs.

Page 28 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 8, 2025

06/16/25

Review status of Receivership and impact of garnishment on interpleader - including timing issues

D.T. Lewandowski

0.30 hrs.

06/16/25

Revise draft complaint for interpleader to be filed in federal court in Virginia C.J. Belote 2.70 hrs.

06/16/25

Analyze issues for addressing Texas receiver and interaction with pending Virginia garnishment action

C.J. Belote

0.40 hrs.

06/17/25

Review and analyze receivership impact on garnishment proceedings in Virginia C.J. Belote 0.30 hrs.

06/19/25

Review and analyze options and risks for pursuing settlement via the Texas receiver, including review of Cyberlux removal pleadings in Tucker case

C.J. Belote

0.60 hrs.

06/19/25

Review and consider Receiver request for 'global' resolution

D.T. Lewandowski

0.20 hrs.

06/20/25

Teams call with HII team to

C.J. Belote

1.00 hrs.

06/20/25

Review and analyze applicable case law re: enjoining state court actions via federal interpleader statute

C.J. Belote

1.60 hrs.

06/20/25

Revise interpleader suit limiting disputed funds to initial payment received from government

A. Mohamed Khalil

1.80 hrs.

06/20/25

Additional review of receivership documents A. Mohamed Khalil

0.30 hrs.

06/20/25

Review final issues re: decision to D.T. Lewandowski 0.20 hrs.

06/22/25

Revise complaint for interpleader in federal court C.J. Belote

0.90 hrs.

06/23/25

Prepare exhibits for interpleader suit A. Mohamed Khalil

2.20 hrs.

Page 29 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 8, 2025

06/23/25

Review applicable case law re: interpleader relief propriety when receivership action is simultaneously pending restricting release of funds or initiation of suit

A. Mohamed Khalil

1.10 hrs.

06/23/25

Prepare for and attend Teams call with HII team re: C.J. Belote 1.00 hrs.

06/23/25

Revise interpleader complaint and review of exhibits for same

C.J. Belote

2.70 hrs.

06/23/25

Draft sealing pleadings for interpleader suit C.J. Belote

exhibits

2.10 hrs.

06/23/25

Research and analyze garnishment injunction and receivership issues arising out filing suit

C.J. Belote

0.90 hrs.

06/23/25

Conference call re: finalization of suit

D.T. Lewandowski :unselected:

0.40 hrs.

06/23/25

Review redlined Complaint D.T. Lewandowski

0.60 hrs.

06/23/25

Review Interpleader issues D.T. Lewandowski

0.40 hrs.

06/23/25

Proof and review final version of complaint D.T. Lewandowski

0.40 hrs.

06/24/25

Revise, finalize, and file Complaint for Interpleader, including corresponding pleadings, e.g., financial disclosure statement and civil cover sheet

C.J. Belote

2.70 hrs.

06/24/25

Review and analyze applicable law and issues related to deposit of the funds into the court, including local rules and standing orders

C.J. Belote

0.80 hrs.

06/24/25

Review and analyze applicable law and issues related to the United States as a party defendant for the IRS

C.J. Belote

0.80 hrs.

06/24/25

Review and analyze applicable law and issues need for potential new summonses to issue

related to amendment as of right and the

C.J. Belote

0.50 hrs.

Page 30 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 8, 2025

06/24/25

Review revised Complaint D.T. Lewandowski

1.50 hrs.

06/24/25

Review service issues D.T. Lewandowski

0.20 hrs.

06/24/25

Review various recent correspondence D.T. Lewandowski

0.30 hrs.

06/24/25

Draft 15 proposed summonses for service on C.M. Sykes

interpleader defendants/claimants 0.30 hrs.

06/24/25

Draft master tracking chart for service on C.M. Sykes

interpleader defendants/claimants 0.20 hrs.

06/24/25

Research Nevada and North Carolina for service C.M. Sykes

on interpleader defendants/claimants 0.20 hrs.

06/25/25

Telephone conference with G. Jackson re: C.J. Belote

0.30 hrs.

06/25/25

Telephone conference with Atlantic Wave counsel regarding garnishment and interpleader action C.J. Belote 0.30 hrs.

06/25/25

Review clerk's notice and judge assignment C.J. Belote

0.30 hrs.

06/25/25

Review and analyze waiver of service from C.J. Belote

Berleth 0.30 hrs.

06/25/25

Analyze next steps and approach to potential C.J. Belote

global settlement via Berleth 0.60 hrs.

06/25/25

Review recent correspondence re: receivership D.T. Lewandowski

matter 0.20 hrs.

06/25/25

Revise proposed summonses to include newly C.M. Sykes

assigned case number 0.10 hrs.

06/25/25

Research Oregon and Texas process servers interpleader defendants/claimants C.M. Sykes

for service of Summons and Complaint on 0.30 hrs.

Page 31 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 8, 2025

06/26/25

Review and analyze waiver of service of process issues presented by receiver

C.J. Belote

1.30 hrs.

06/27/25

Email S. Freling re:

C.J. Belote

0.10 hrs.

06/29/25

Review and analyze proposed settlement agreement and related pleadings the Texas receiver

circulated by

C.J. Belote

1.20 hrs.

06/30/25

Review Receiver's documents re: "settlement"

D.T. Lewandowski

0.90 hrs.

06/30/25

Research and analyze interpleader case law issues to address potential raised by Cyberlux

defenses to be

C.J. Belote

1.40 hrs.

06/30/25

Prepare for and attend conference call with counsel various litigation involving same

for Cyberlux re: current

status of

C.J. Belote

0.80 hrs.

06/30/25

Telephone conference with Greg Jackson re:

C.J. Belote

0.20 hrs.

06/30/25

Review and analyze multiple emails from the

receiver related to settlement 0.50 hrs.

C.J. Belote

06/30/25

Draft amended complaint

C.J. Belote

0.90 hrs.

TOTAL FOR SERVICES

$24,898.50

DISBURSEMENTS AND OTHER FIRM CHARGES

06/05/25

CT LIEN SOLUTIONS - Payment of invoice no. 04176932 for lien searches NC and NV

248.00

06/30/25

CLARK J BELOTE - Reimbursement for filing fee for complaint, USDC, EDVA on 06/24/2025.

405.00

TOTAL FOR DISBURSEMENTS & OTHER FIRM CHARGES

$653.00

CURRENT BILLING FOR THIS MATTER

$25,551.50

Filed 02/03/26

Page 32 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

July 8, 2025

TOTAL DUE FOR THIS MATTER $25,551.50

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

48.30

325.00

$15,697.50

D.T. Lewandowski

11.40

450.00

$5,130.00

A. Mohamed Khalil

15.30

240.00

$3,672.00

C.S. Rawls

1.00

190.00

$190.00

C.M. Sykes

1.10

190.00

$209.00

77.10

$24,898.50

Filed 02/03/26

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

July 8, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through June 30, 2025

Invoice No. 1307805

Fees:

$24,898.50

Disbursements and other firm charges:

$653.00

Total due for this invoice:

$25,551.50

Pay by eCheck or Credit Card:

Pay by check:

Pay by Wire or ACH transfer:

https://www.kaufcan.com/paymentportal

Kaufman & Canoles, P.C.

P.O. Box 3037

Norfolk, VA 23514

Beneficiary Name and Account:

Kaufman & Canoles, P.C. Operating Receipts

150
West Main Street Suite 2100

Norfolk VA 23510

Account # 0261130242

Beneficiary Bank: TowneBank 109 E. Main Street Norfolk, VA 23510 ABA Routing # 051408949 Swift Code: TOWBUS32

Please reference client matter and (or) invoice number from your statement when making payment. Please send an email to accounting@kaufcan.com to notify us of your payment.

Filed 02/03/26

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

August 7, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through July 31, 2025 in connection with: HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

07/01/25

Review additional documents regarding Receiver and Stay/appeal of receivership D.T. Lewandowski 0.50 hrs.

07/01/25

Telephone conference with R. Berleth re: proposed settlement C.J. Belote 0.40 hrs.

07/01/25 Call with Cyberlux counsel re: receiver issues

C.J. Belote 0.30 hrs.

07/01/25 Review and analyze issues for amendments to interpleader complaint based on timing of receipt of funds and necessary parties issues

C.J. Belote 0.90 hrs.

07/02/25 Review and analyze docusign notice received from Texas receiver re: "settlement" proposal C.J. Belote 0.20 hrs.

07/02/25

Conduct research regarding interpleader and standard

L.P. Jones

2.10 hrs.

07/03/25 Review and analyze garnishment filing motion for entry of order of payment filed by Atlantic Wave C.J. Belote 0.30 hrs.

Page 35 of 92 PageID#

August 7, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

07/03/25

Telephone conference with Cyberlux counsel re: interpleader action and attempts at settlement

C.J. Belote

0.30 hrs.

07/03/25

Review recent pleadings filed in Texas matters regarding the receiver

C.J. Belote

1.40 hrs.

07/03/25

Review Atlantic Wave garnishment pleadings received and consider issues re: same D.T. Lewandowski 0.70 hrs.

07/03/25

Conduct research to determine standard for L.P. Jones :unselected:

unsupported claimants in interpleader action 0.70 hrs.

07/05/25

Review and analyze motion for entry of a payment order filed by Atlantic Wave in Fairfax garnishment action to articulate response to counsel

C.J. Belote :unselected:

1.60 hrs.

07/07/25

Conduct research re: minimum threshold for interpleader and adding multiple claimants L.P. Jones 1.70 hrs. :unselected:

07/07/25

Review garnishment pleading issues D.T. Lewandowski

0.60 hrs.

07/07/25

review draft garnishment response D.T. Lewandowski

0.30 hrs.

07/07/25

Draft brief and opposition to motion for entry of an order of payment filed by the judgment creditors in Fairfax County

C.J. Belote

5.40 hrs.

07/07/25

Review and analyze additional appellate pleadings filed in Texas C.J. Belote 1.00 hrs.

07/08/25

Revise brief in opposition to Atlantic Wave motion for an order of payment in Fairfax garnishment action

C.J. Belote

2.10 hrs.

07/08/25

Review and analyze applicable case law regarding interpleader issues for potential dropping of parties on amended complaint C.J. Belote 0.50 hrs.

07/08/25

Review email from counsel for Montague C.J. Belote

Capital Partners re: interpleader alleged issues 0.20 hrs.

Page 36 of 92 PageID#

August 7, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

07/08/25

Review recent pleadings filed in garnishment matters D.T. Lewandowski 0.20 hrs.

07/08/25

Draft Fairfax Circuit Court Response/Opposition to Motion form K.M. Rine 0.30 hrs.

07/08/25

Conduct additional research regarding interpleader action

L.P. Jones

1.90 hrs.

07/09/25

Finalize and arrange for filing of Response to Motion for Entry of Order for Payment K.M. Rine 0.40 hrs.

07/09/25

Review Montegue emails D.T. Lewandowski

0.40 hrs.

07/09/25

Revise and finalize brief regarding garnishment action C.J. Belote 2.40 hrs.

07/09/25

Review email from R. Berleth re: Montague Capital Partners C.J. Belote 0.10 hrs.

07/10/25

Review issue of claims to include in interpleader D.T. Lewandowski 0.30 hrs.

07/10/25

Review and revise draft letter to claimants re: issue of claims to include in interpleader D.T. Lewandowski 0.30 hrs.

07/10/25

Update master list of parties to receive claim letters C.M. Sykes 0.30 hrs.

07/10/25

Telephone conference with M. Sheehan re:

C.J. Belote

0.60 hrs.

07/10/25

Draft template letters to potential claimants re: their claims to disputed funds C.J. Belote 1.20 hrs.

07/10/25

Research and analyze interpleader issues to assess possible dropping of defendants in Amended Complaint C.J. Belote 1.30 hrs.

07/10/25

Review email from Legalist counsel on garnishment position C.J. Belote 0.10 hrs.

Page 37 of 92 PageID#

August 7, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

07/11/25

Review and analyze proposed changes to template letter to creditors with multiple revisions to same

C.J. Belote

2.20 hrs.

07/11/25

Review recent correspondence re: matter

D.T. Lewandowski

0.20 hrs.

07/11/25

Review law re: inclusion of claims D.T. Lewandowski

0.20 hrs.

07/11/25

Review multiple revised versions of letter to D.T. Lewandowski

claimants

0.60 hrs.

07/11/25

Update master list of parties to receive claim C.M. Sykes

letter

0.20 hrs.

07/14/25

Revise, finalize, and serve claim confirmation letter to Cyberlux creditors C.J. Belote 2.10 hrs.

07/14/25

Prepare for and attend call with counsel for Montague Capital Partners re: interpleader action

C.J. Belote

0.80 hrs.

07/14/25

Review and analyze responses to claim letter C.J. Belote

from Aerotek counsel and ARG counsel

0.50 hrs.

07/14/25

Review general interpleader issues D.T. Lewandowski

0.40 hrs.

07/14/25

Review recent correspondence from claimants D.T. Lewandowski

0.20 hrs.

07/14/25

Draft 10 claim confirmation letters and serve C.M. Sykes

same 0.90 hrs.

07/14/25

Update claim tracking chart to incorporate issuance C.M. Sykes

of claim confirmation letters 0.10 hrs.

07/15/25

Review and analyze issues for next steps based C.J. Belote

on receipt of government payment 0.30 hrs.

07/15/25

Review emails from creditors in receipt of claim C.J. Belote

letter 0.20 hrs.

Page 38 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

August 7, 2025

07/15/25

Review recent correspondence re: judgment creditor as secured party D.T. Lewandowski 0.10 hrs.

07/15/25

Confirm delivery of claim confirmation letters to Third Generation Development and RB Capital Partners and update claim tracking chart

C.M. Sykes

0.10 hrs.

07/15/25

Draft proposed order dismissing C.M. Sykes

garnishment and denying motion for order of payment 0.20 hrs.

07/16/25

Extended telephone conference with interpleader action C.J. Belote

Cyberlux counsel regarding potential resolution of

0.70 hrs.

07/17/25

Outline arguments for hearing on C.J. Belote

Atlantic Wave garnishment

2.10 hrs.

07/17/25

Travel to Fairfax for hearing on Atlantic payment order

Wave garnishment and motion for entry of a

C.J. Belote

4.00 hrs.

07/17/25

Attend Teams call to

C.J. Belote

0.60 hrs.

07/17/25

Outline testimony and exhibits of T. C.J. Belote

McAtee for hearing on Atlantic Wave garnishment 1.90 hrs.

07/17/25

Review, analyze and respond to filings C.J. Belote

and correspondence by Texas receiver

0.90 hrs.

07/17/25

Review and redact Commercial Subcontract Agreement and Modification No. 4 to Subcontract No. P000043846

K.M. Rine

0.40 hrs.

07/17/25

Call from Virginia Attorney for Receiver D.T. Lewandowski

0.20 hrs.

07/17/25

Review correspondence re: Motion D.T. Lewandowski

filed 0.10 hrs.

07/17/25

Review pleadings filed D.T. Lewandowski

0.40 hrs.

Page 39 of 92 PageID#

August 7, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

07/18/25

Review and analyze issues arising from Receiver's "Joint Motion" to deposit funds, including potential sanctions motion

C.J. Belote

0.60 hrs.

07/18/25

Attend hearing in Fairfax Circuit Court on an order of payment

garnishment summons and motion for entry of

C.J. Belote

6.90 hrs.

07/18/25

Draft Response to Joint Motion to Deposit Funds into Registry of Court, Memorandum in Support of Response, Rule 11 Motion, and Memorandum in Support of Rule 11 Motion

K.M. Rine

1.50 hrs.

07/18/25

Research re: appropriate tool for dropping defendant-claimants from action

L.P. Jones

2.40 hrs.

07/18/25

Review "Joint" Motion D.T. Lewandowski

0.60 hrs.

07/18/25

Consider issues options re: "Joint" Motion D.T. Lewandowski

1.20 hrs.

07/18/25

Review various correspondence from CT and D.T. Lewandowski

others re: "Joint" Motion

0.50 hrs.

07/19/25

Draft brief in response to Receiver's "Joint C.J. Belote

Motion" to deposit funds

1.60 hrs.

07/20/25

Draft and revise response to Receiver's "Joint

Motion" to deposit funds

C.J. Belote

1.40 hrs.

07/21/25

Review draft Response to Joint Motion D.T. Lewandowski

1.60 hrs.

07/21/25

Review various correspondence re: matter D.T. Lewandowski

0.20 hrs.

07/21/25

Revise response to the Receiver's "Joint" motion C.J. Belote

to deposit funds

2.10 hrs.

07/21/25

Telephone conference with M. Sheehan re: C.J. Belote

0.20 hrs.

07/21/25

Review correspondence from counsel for ANPC C.J. Belote

re: claims to funds 0.20 hrs.

Page 40 of 92 PageID#

August 7, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

07/21/25

Review of joint motion by Receiver for deposit of funds A. Mohamed Khalil 0.10 hrs.

07/21/25

Attention to correspondence regarding Receiver filing including potential responses to same

A. Mohamed Khalil 0.10 hrs.

07/22/25

Extended telephone conference with local counsel for Berleth regarding "joint" motion and next steps

C.J. Belote 0.50 hrs.

07/22/25

Review and analyze entered order from Fairfax Circuit Court on Atlantic Wave garnishment C.J. Belote 0.30 hrs.

07/22/25

Review recent Cyberlux appellate filing in Texas C.J. Belote 0.50 hrs.

07/22/25

Review and analyze letter from Landlord of Cyberlux re: claim to funds C.J. Belote 0.60 hrs.

07/22/25

Review recent correspondence re: creditors' response regarding claims to funds D.T. Lewandowski 0.20 hrs.

07/22/25

Review and consider multiple proposed revisions to Response to Receiver D.T. Lewandowski 0.40 hrs.

07/23/25

Review correspondence from various interpleader claimants D.T. Lewandowski 0.20 hrs.

07/23/25

Review multiple motions filed by garnishment creditors in interpleader action D.T. Lewandowski 0.80 hrs.

07/23/25

Review multiple letters from creditors of Cyberlux regarding alleged claims to HII funds for purposes of drafting first amended complaint C.J. Belote 2.00 hrs.

07/23/25

Outline reasons in support of seeking Rule 11 sanctions against Berleth C.J. Belote 0.40 hrs.

07/23/25

Review motions to compel and for scheduling order filed by Atlantic Wave C.J. Belote 0.80 hrs.

07/23/25

Review memorandum in support filed by Receiver as to motion for interpleader deposit A. Mohamed Khalil 0.10 hrs.

Page 41 of 92 PageID#

August 7, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

07/24/25

Analyze and revise amended garnishment order for Fairfax Circuit Court C.J. Belote 0.80 hrs.

07/24/25

Teams call with HII team to

C.J. Belote

1.00 hrs.

07/24/25

Draft first amended complaint in interpleader C.J. Belote

action in federal court

3.20 hrs.

07/24/25

Prepare Exhibits to Amended Complaint K.M. Rine

0.20 hrs.

07/24/25

Determine which defendant claimants should D.T. Lewandowski

remain in Amended Complaint 1.40 hrs.

07/24/25

Review Court Orders on AW and Secure Motions D.T. Lewandowski

0.20 hrs.

07/24/25

Review various correspondence D.T. Lewandowski

0.20 hrs.

07/25/25

Review draft Amended Complaint D.T. Lewandowski

1.00 hrs.

07/25/25

Review recent correspondence re: matter D.T. Lewandowski

0.10 hrs.

07/26/25

Revise amended complaint for interpleader C.J. Belote

0.40 hrs.

07/27/25

Revise amended garnishment order C.J. Belote

0.40 hrs.

07/28/25

Review email from Atlantic Wave counsel on garnishment order and proposed amendment

C.J. Belote

0.20 hrs.

07/28/25

Review edits to amended complaint from S. C.J. Belote

Freling 0.20 hrs.

07/28/25

Telephone conference with J. Erbach (Virginia matter and interpleader suit C.J. Belote

counsel for Legalist) regarding Fairfax 0.20 hrs.

Page 42 of 92 PageID#

August 7, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

07/28/25

Review filings in Texas litigation in Court of Appeals C.J. Belote 0.40 hrs.

07/28/25

Review and analyze case law supporting Advanced Navigation claim to Disputed Funds C.J. Belote 0.80 hrs.

07/28/25

Review first amended interpleader complaint C.J. Belote 1.80 hrs.

07/28/25

Review reply filed by Receiver on "Joint" Motion to Deposit Funds C.J. Belote 0.30 hrs.

07/28/25

Review revised Amended Complaint D.T. Lewandowski

0.80 hrs.

07/28/25

Review Receiver's Reply D.T. Lewandowski

0.30 hrs.

07/29/25

Review Texas Appeal Reply Motion D.T. Lewandowski

0.40 hrs.

07/29/25

Review garnishment deposit and release issues D.T. Lewandowski 0.20 hrs.

07/29/25

Review and analyze strategy and revisions to garnishment order arising out of email from Atlantic Wave counsel re: garnishment proceedings C.J. Belote 1.20 hrs.

07/30/25

Draft motion to dismiss HII from garnishment proceeding upon payment into court C.J. Belote 1.60 hrs.

07/30/25

Draft objections to the Fairfax Circuit Court garnishment order C.J. Belote 0.70 hrs.

07/30/25

Review and analyze strategy and timing of presenting garnishment check and order C.J. Belote 0.30 hrs.

07/30/25

Review recent correspondence D.T. Lewandowski

0.20 hrs.

07/30/25

Draft Order on Fairfax garnishment D.T. Lewandowski 0.20 hrs.

HUNTINGTON INGALLS INDUSTRIES, INC.

August 7, 2025

07/31/25

Prepare Exhibits to Motion to Release and Dismiss

Garnishee Upon Payment

K.M. Rine

0.10 hrs.

07/31/25

Draft Fairfax County Circuit Court Praecipe/Notice

K.M. Rine

0.20 hrs.

07/31/25

Prepare filing packages for Garnishee's Objections Discharge and Dismiss Garnishee

to July 22, 2025 Order

and Motion to

K.M. Rine

0.80 hrs.

07/31/25

Review revised Fairfax garnishment motion

D.T. Lewandowski

0.20 hrs.

07/31/25

Review correspondence re: matter

D.T. Lewandowski

0.20 hrs.

07/31/25

Review, finalize and file motion to dismiss from

garnishment proceeding 1.10 hrs.

C.J. Belote

TOTAL FOR SERVICES

$33,061.50

DISBURSEMENTS AND OTHER FIRM CHARGES

07/21/25

Clark J. Belote - Reimbursement for travel to Fairfax, VA for hearing in Fairfax Circuit Court, including hotel, r/t mileage, parking on 07/17-07/18/2025

451.12

FedEx charges

143.09

TOTAL FOR DISBURSEMENTS & OTHER FIRM CHARGES

$594.21

CURRENT BILLING FOR THIS MATTER

$33,655.71

TOTAL DUE FOR THIS MATTER

$33,655.71

BALANCE DUE UPON RECEIPT

August 7, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

69.30

325.00

$22,522.50

L.P. Jones :unselected:

8.80

225.00

$1,980.00

D.T. Lewandowski

16.80

450.00

$7,560.00

A. Mohamed Khalil

0.30

240.00

$72.00

K.M. Rine

3.90

150.00

$585.00

C.M. Sykes

1.80

190.00

$342.00

100.90

$33,061.50

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

August 7, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through July 31, 2025

Invoice No. 1309948

Fees:

$33,061.50

Disbursements and other firm charges:

$594.21

Total due for this invoice:

$33,655.71

Pay by eCheck or Credit Card:

Pay by check:

Pay by Wire or ACH transfer:

https://www.kaufcan.com/paymentportal

Kaufman & Canoles, P.C.

P.O. Box 3037

Norfolk, VA 23514

Beneficiary Name and Account:

Kaufman & Canoles, P.C. Operating Receipts

150
West Main Street Suite 2100

Norfolk VA 23510

Account # 0261130242

Beneficiary Bank: TowneBank 109 E. Main Street Norfolk, VA 23510 ABA Routing # 051408949 Swift Code: TOWBUS32

Please reference client matter and (or) invoice number from your statement when making payment. Please send an email to accounting@kaufcan.com to notify us of your payment.

Document 144-6 Filed 02/03/26 1775

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

September 8, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through August 31, 2025 in connection with: HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

08/01/25

Prepare for and attend call with HII legal team to

C.J. Belote

1.10 hrs.

08/01/25

Review Complaint against Watt D.T. Lewandowski

0.70 hrs.

08/01/25

Correspondence re: Complaint against Watt D.T. Lewandowski 0.20 hrs.

08/03/25

Draft motion for sanctions against Receiver C.J. Belote 0.60 hrs.

08/04/25

Review and revise Rule 11 Motion and Memorandum against Receiver D.T. Lewandowski 0.90 hrs.

08/04/25

Review draft correspondence to deleted interpleader defendants D.T. Lewandowski 0.20 hrs.

08/04/25

Telephone conference with counsel for WeShield re: interest in interpleader suit C.J. Belote 0.50 hrs.

08/04/25

Draft communications to interpleader defendants and dropped parties re: acceptance of service and notice of first amended complaint C.J. Belote 0.80 hrs.

Page 47 of 92 PageID#

September 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

08/04/25

Draft brief in support of motion for sanctions against the receiver

C.J. Belote

2.80 hrs.

08/04/25

Revise, finalize and file First Amended Interpleader Complaint

C.J. Belote

1.50 hrs.

08/05/25

Revise motion for sanctions and memo in support draft C.J. Belote 1.00 hrs.

08/05/25

Review and address issues with returning summonses related to the original complaint C.J. Belote 0.30 hrs.

08/05/25

Telephone conference with Cyberlux Texas landlord re: interpleader suit issues C.J. Belote 0.30 hrs.

08/05/25

Telephone conference with counsel for Cyberlux re: acceptance of service for interpleader complaint

C.J. Belote

0.20 hrs.

08/05/25

Prepare 15 Summonses for Complaint to return to court as unexecuted

K.M. Rine

0.50 hrs.

08/05/25

Draft Proposed Summons to Attorney General of the United States at Washington, D.C. address

K.M. Rine

0.20 hrs.

08/05/25

Review revised Sanctions Brief and consider issues re: same D.T. Lewandowski 0.40 hrs.

08/06/25

Finalize First Amended Complaint service packages to U.S. Attorney for the Eastern District of Virginia and the U.S. Attorney General K.M. Rine 0.20 hrs.

08/06/25

Arrange for service of First Amended Complaint service packages to U.S. Attorney for the Eastern District of Virginia and the U.S. Attorney General K.M. Rine 0.20 hrs.

08/06/25

Review and analyze motion to intervene filed by WeShield C.J. Belote 0.50 hrs.

08/08/25

Telephone conference with local counsel for Atlantic Wave re: potential settlement conference in interpleader case C.J. Belote 0.30 hrs.

Page 48 of 92 PageID#

September 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

08/08/25

Draft response to WeShield motion to intervene C.J. Belote 0.30 hrs.

08/08/25

Review WeShield intervention pleadings D.T. Lewandowski 0.40 hrs.

08/08/25

Correspondence re: WeShield intervention pleadings D.T. Lewandowski 0.10 hrs.

08/11/25

Review Rule 11 issues upon entry of Order denying 'Joint' Motion D.T. Lewandowski 0.30 hrs.

08/11/25

Review draft Response to Motion to Intervene D.T. Lewandowski 0.30 hrs.

08/11/25

Revise motion for sanctions brief to incorporate Covington comments C.J. Belote 0.90 hrs.

08/11/25

Review and analyze court orders re: Berleth's motion to deposit and Legalist's motion for extension

C.J. Belote

0.40 hrs.

08/11/25

Review amended response to Fairfax motion to dismiss filed by Atlantic Wave C.J. Belote 0.20 hrs.

08/11/25

Review litigation hold notice from pro se plaintiff in Cyberlux action C.J. Belote 0.20 hrs.

08/12/25

Revise response to motion to intervene from WeShield C.J. Belote 0.50 hrs.

08/12/25

Email counsel regarding proposed order for Fairfax garnishment hearing C.J. Belote 0.30 hrs.

08/12/25

Review revised Response to Motion to Intervene D.T. Lewandowski 0.20 hrs.

08/12/25

Correspondence re: Response to Motion to Intervene D.T. Lewandowski 0.10 hrs.

08/13/25

Review MAS et. al. Intervention pleadings D.T. Lewandowski

0.40 hrs.

Page 49 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

September 8, 2025

08/13/25

Review motion to intervene filed by Roman Investments, et al. C.J. Belote 0.90 hrs.

08/14/25

Prepare for hearing in Fairfax Circuit Court on C.J. Belote

motion to dismiss HII from case 1.60 hrs.

08/14/25

Revise multiple versions of proposed orders C.J. Belote

on motion to dismiss HII 0.50 hrs.

08/14/25

Finalize and file response to motion to intervene C.J. Belote

filed by WeShield 0.20 hrs.

08/14/25

Finalize and serve motion for sanctions on C.J. Belote

Berleth's counsel 0.30 hrs.

08/14/25

Follow up with process server re: Affidavit of Attorney General in Richmond

Service for Amended Complaint on US 0.10 hrs.

K.M. Rine

08/14/25

Review updated Response to Motion to D.T. Lewandowski

Intervene 0.30 hrs.

08/14/25

Draft response to Motion to Intervene by Roman A. Mohamed Khalil

Investments, et al. 0.40 hrs.

08/15/25

Review recent correspondence D.T. Lewandowski

0.20 hrs.

08/15/25

Determine results of Fairfax hearing D.T. Lewandowski

0.20 hrs.

08/15/25

Review entered Order re: Fairfax hearing D.T. Lewandowski

0.10 hrs.

08/15/25

Attend hearing in Fairfax Circuit Court to obtain HII from garnishment case C.J. Belote

entry of order dismissing and discharging 8.20 hrs.

08/15/25

Draft email updates and reply to M. Sheehan C.J. Belote

re: 0.30 hrs.

08/18/25

Review Tucker and Whitely Memorandum D.T. Lewandowski

Opinion 0.50 hrs.

Page 50 of 92 PageID#

September 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

08/18/25

Review recent correspondence re: matter D.T. Lewandowski

0.10 hrs.

08/18/25

Review recent filings in Texas C.J. Belote

0.30 hrs.

08/19/25

Finalize and file summons returned executed for service on the United States and response to motion to intervene of Roman Investments

C.J. Belote

0.40 hrs.

08/20/25

Review filed Response to Motion to Intervene D.T. Lewandowski

0.10 hrs.

08/20/25

Review motion to intervene filed by Fairwinds C.J. Belote

0.40 hrs.

08/21/25

Review Fairwinds Intervention pleadings D.T. Lewandowski

0.30 hrs.

08/21/25

Draft response re: Fairwinds Intervention pleadings D.T. Lewandowski

0.10 hrs.

08/21/25

Review issues for response to motion to intervene C.J. Belote

of Fairwinds

0.30 hrs.

08/21/25

Draft reply to motion to intervene by Fairwinds

Technologies LLC

A. Mohamed Khalil

0.80 hrs.

08/22/25

Review litigation hold scope issues

C.J. Belote

0.20 hrs.

08/24/25

Email M. Sheehan re:

C.J. Belote

0.20 hrs.

08/25/25

Review and analyze answers to the complaint C.J. Belote

filed by the receiver and ANPC 0.90 hrs.

08/25/25

Review pleadings filed by interpleader defendants A. Mohamed Khalil

0.30 hrs.

08/26/25

Review Answers and other pleadings filed D.T. Lewandowski

0.60 hrs.

Page 51 of 92 PageID#

September 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

08/27/25

Review answers filed by Atlantic Wave and Secure Community C.J. Belote 0.50 hrs.

08/28/25

Review and analyze issues for outlining motion issues

to deposit draft, including attorneys' fees

C.J. Belote

1.90 hrs.

08/28/25

Review Atlantic Wave and Secure Community Answers

D.T. Lewandowski

0.80 hrs.

08/28/25

Analyze strategy for upcoming motion to deposit interpleader funds A. Mohamed Khalil 0.80 hrs.

08/29/25

Analysis of case law as to expert witness cost recovery in connection with fee motion

A. Mohamed Khalil

2.20 hrs.

08/29/25

Review correspondence re: matter

D.T. Lewandowski

0.10 hrs.

08/29/25

Analyze attorney fee recovery issues C.J. Belote

0.40 hrs.

08/29/25

Revise response to Fairwinds motion to intervene C.J. Belote

0.40 hrs.

08/29/25

Review Texas appeal decision

C.J. Belote

0.30 hrs.

08/30/25

Review and analyze Cyberlux motion to dismiss

0.90 hrs.

C.J. Belote

TOTAL FOR SERVICES

$15,015.00

DISBURSEMENTS AND OTHER FIRM CHARGES

08/07/25

Richmond Court Services Inc. - Payment of Invoice No. RCT- 2025001191 dated 08/14/2025; Service fee for Amended Complaint on USA

73.25

08/19/25

Clark J. Belote - Reimbursement for round VA for Hearing in Fairfax Circuit Court, 08/15/2025

trip travel to Fairfax, including parking fee on

285.00

TOTAL FOR DISBURSEMENTS & OTHER FIRM CHARGES $358.25

HUNTINGTON INGALLS INDUSTRIES, INC.

September 8, 2025

CURRENT BILLING FOR THIS MATTER

$15,373.25

TOTAL DUE FOR THIS MATTER

$15,373.25

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

31.80

325.00

$10,335.00

D.T. Lewandowski

7.60

450.00

$3,420.00

A. Mohamed Khalil

4.50

240.00

$1,080.00

K.M. Rine

1.20

150.00

$180.00

45.10

$15,015.00

Filed 02/03/26

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

September 8, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through August 31, 2025

Invoice No. 1312511

Fees:

$15,015.00

Disbursements and other firm charges:

$358.25

Total due for this invoice:

$15,373.25

Pay by eCheck or Credit Card:

Pay by check:

Pay by Wire or ACH transfer:

https://www.kaufcan.com/paymentportal

Kaufman & Canoles, P.C.

P.O. Box 3037

Norfolk, VA 23514

Beneficiary Name and Account:

Kaufman & Canoles, P.C. Operating Receipts

150
West Main Street Suite 2100

Norfolk VA 23510

Account # 0261130242

Beneficiary Bank: TowneBank 109 E. Main Street Norfolk, VA 23510 ABA Routing # 051408949 Swift Code: TOWBUS32

Please reference client matter and (or) invoice number from your statement when making payment. Please send an email to accounting@kaufcan.com to notify us of your payment.

Document 144-6 Filed 02/03/26 1783

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

October 8, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through September 30, 2025 in connection with: HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

09/01/25

Review emails from co-counsel regarding

C.J. Belote

0.20 hrs.

09/02/25

Review and analyze case law regarding Rule

11
motion for sanctions

C.J. Belote

1.70 hrs.

09/02/25

Telephone conference with opposing counsel C.J. Belote

regarding motion for sanctions 0.40 hrs.

09/02/25

Review Motion to Dismiss and Memorandum

re: same

D.T. Lewandowski

1.00 hrs.

09/03/25

Review Rule 11 - ability to withdraw - issues

D.T. Lewandowski

0.50 hrs.

09/03/25

Review and analyze C.J. Belote

for call with M. Sheehan re:

0.90 hrs.

09/04/25

Review Motion to Dismiss filed by Cyberlux

L.P. Jones

0.60 hrs.

09/04/25

Prepare for and attend call with counsel for C.J. Belote

the receiver re: sanction motion 0.90 hrs.

Page 55 of 92 PageID#

October 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

09/04/25

Outline arguments for brief in opposition to motion to dismiss C.J. Belote 1.30 hrs.

09/04/25

Review jurisdictional and related issues in D.T. Lewandowski

response to Cyberlux Motion to Dismiss 0.60 hrs.

09/05/25

Conduct research re: perfecting IRS tax L.P. Jones

liens for opposition to Cyberlux's MTD 1.80 hrs.

09/05/25

Draft brief in opposition to motion to dismiss C.J. Belote

filed by Cyberlux 6.50 hrs.

09/06/25

Draft brief in opposition to motion to dismiss C.J. Belote

filed by Cyberlux 1.50 hrs.

09/07/25

Draft rebuttal to Cyberlux's IRS tax lien L.P. Jones

argument 0.90 hrs.

09/07/25

Review Cyberlux's cited authorities for accuracy of quotes included in their brief L.P. Jones 1.10 hrs.

09/08/25

Draft and revise opposition including misrepresentations in Cyberlux's brief and adding additional case law support L.P. Jones 1.80 hrs.

09/08/25

Review Curtin Amended Complaint D.T. Lewandowski

0.80 hrs.

09/08/25

Review and revise Memorandum in Opposition to Cyberlux Motion to Dismiss Interpleader

D.T. Lewandowski

0.80 hrs.

09/08/25

Review recent correspondence D.T. Lewandowski

0.20 hrs.

09/08/25

Review Receiver's pleadings to supplement D.T. Lewandowski

receivership 0.60 hrs.

09/08/25

Draft brief in opposition to motion to dismiss filed by Cyberlux C.J. Belote 3.80 hrs.

09/09/25

Revise brief in opposition to motion to dismiss filed by Cyberlux C.J. Belote 1.40 hrs.

Page 56 of 92 PageID#

October 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

09/09/25

Review Legalist Answer D.T. Lewandowski 0.20 hrs.

09/09/25

Review Thin Air Gear correspondence and Judgment pleadings D.T. Lewandowski 0.10 hrs.

09/10/25

Review revisions to Response to Motion to Dismiss D.T. Lewandowski 0.20 hrs.

09/10/25

Review and consider Matt Sheehan comments to

D.T. Lewandowski

0.20 hrs.

09/10/25

Review response to D.T. Lewandowski 0.10 hrs.

09/10/25

Review Atlantic Wave Response to Motion to Dismiss D.T. Lewandowski 0.20 hrs.

09/10/25

Revise brief in opposition to motion to dismiss filed by Cyberlux C.J. Belote 1.80 hrs.

09/10/25

Draft motion to deposit including memorandum in support of same A. Mohamed Khalil 1.90 hrs.

09/11/25

Analyze issues for motion to deposit case law C.J. Belote 0.30 hrs.

09/11/25

Continue drafting memorandum in support of motion for interpleader relief. including review of applicable case law A. Mohamed Khalil 7.40 hrs.

09/11/25

Review Court Docket re: recent pleadings filed D.T. Lewandowski 0.10 hrs.

09/11/25

Review pleadings recently filed - Receiver Opposition to Motion to Dismiss D.T. Lewandowski 0.30 hrs.

09/12/25

Revise, finalize, and file brief in opposition to motion to dismiss of Cyberlux C.J. Belote 2.50 hrs.

09/12/25

Review briefs in opposition to motion to dismiss filed by Legalist and others C.J. Belote 0.20 hrs.

Page 57 of 92 PageID#

October 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

09/12/25

Analysis of jurisdictional issue as to revisions to motion as to

including evaluation of ,

A. Mohamed Khalil

0.50 hrs.

09/12/25

Review draft reply to Cyberlux motion to dismiss A. Mohamed Khalil

0.20 hrs.

09/12/25

Review Legalist/United States response in opposition A. Mohamed Khalil

to motion to dismiss by Cyberlux 0.20 hrs.

09/12/25

Review various final versions of HII Opposition to D.T. Lewandowski

Motion to Dismiss 0.40 hrs.

09/15/25

Email Cyberlux counsel re: request for call C.J. Belote

0.10 hrs.

09/16/25

Review recent pleadings filed - multiple Responses D.T. Lewandowski

to Cyberlux Motion to Dismiss 0.50 hrs.

09/16/25

Review and analyze Curtin's Motion for Leave to File Amicus Brief and Amicus Curiae Brief

L.P. Jones

1.10 hrs.

09/16/25

Review and analyze issues related to James Curtin filing C.J. Belote 0.80 hrs.

09/16/25

Review motion for leave to file amicus brief/accompanying brief filed by James Curtin A. Mohamed Khalil 0.10 hrs.

09/17/25

Review Amicus Motion and Brief D.T. Lewandowski

0.50 hrs.

09/17/25

Conduct research regarding standard for allowing L.P. Jones

amicus brief 1.60 hrs.

09/18/25

Draft Memo in Opposition to Curtin's Motion for Leave L.P. Jones 2.90 hrs.

09/18/25

Telephone conference with counsel for Cyberlux C.J. Belote

re: settlement prospects 0.40 hrs.

09/19/25

Review and analyze Cyberlux reply brief in support C.J. Belote

of motion to dismiss 0.40 hrs.

Page 58 of 92 PageID#

October 8, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

09/19/25

Review Cyberlux Reply Brief re: Motion to Dismiss

D.T. Lewandowski

0.50 hrs.

09/19/25

Consider issues re: Cyberlux Reply Brief D.T. Lewandowski

0.10 hrs.

09/23/25

Email counsel for Atlantic Wave re: motion to C.J. Belote

deposit timing 0.20 hrs.

09/23/25

Revise memorandum in support of motion for review of applicable case law

interpleader relief, including additional

A. Mohamed Khalil

2.00 hrs.

09/23/25

Review issues for indemnity of attorneys' fees C.J. Belote

0.20 hrs.

09/24/25

Review recently filed Texas pleadings re: receiver C.J. Belote

0.20 hrs.

09/25/25

Revise motion for interpleader relief and deposit C.J. Belote

of funds 1.50 hrs.

09/25/25

Revise brief in opposition to motion for leave to C.J. Belote

file amicus brief by J. Curtin 0.60 hrs.

09/25/25

Revise motion for interpleader relief, including A. Mohamed Khalil

memorandum in support 0.50 hrs.

09/25/25

Review steps to be taken as to motion for deposit, type

including review of deposit account

A. Mohamed Khalil

0.10 hrs.

09/26/25

Continue revising memorandum in support of

motion to deposit

A. Mohamed Khalil

2.50 hrs.

09/26/25

Review edits to motion to deposit and brief C.J. Belote

0.20 hrs.

09/27/25

Finish revising memorandum in support of motion of citations within

for interpleader relief, including review

A. Mohamed Khalil

3.20 hrs.

09/29/25

Revise motion to deposit and brief in support C.J. Belote

1.30 hrs.

Page 59 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

October 8, 2025

09/30/25

Review answer filed by United States of America

C.J. Belote

0.40 hrs.

09/30/25

Review filed Oppositions to Amicus Brief

D.T. Lewandowski

0.30 hrs.

09/30/25

Review draft Deposit pleadings

D.T. Lewandowski

0.80 hrs.

TOTAL FOR SERVICES

$20,821.50

CURRENT BILLING FOR THIS MATTER

$20,821.50

TOTAL DUE FOR THIS MATTER

$20,821.50

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

29.70

325.00

$9,652.50

L.P. Jones

11.80

225.00

$2,655.00

D.T. Lewandowski

9.00

450.00

$4,050.00

A. Mohamed Khalil

18.60

240.00

$4,464.00

69.10

$20,821.50

Filed 02/03/26

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

October 8, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered

Invoice No.

through September 30, 2025

Fees:

$20,821.50

Total due for this invoice:

$20,821.50

Pay by eCheck or Credit Card:

Pay by check:

Pay by Wire or ACH transfer:

https://www.kaufcan.com/paymentportal

Kaufman & Canoles, P.C.

P.O. Box 3037

Norfolk, VA 23514

Beneficiary Name and Account:

Kaufman & Canoles, P.C. Operating Receipts

150
West Main Street Suite 2100

Norfolk VA 23510

Account # 0261130242

Beneficiary Bank: TowneBank 109 E. Main Street Norfolk, VA 23510 ABA Routing # 051408949 Swift Code: TOWBUS32

Please reference client matter and (or) invoice number from your statement when making payment. Please send an email to accounting@kaufcan.com to notify us of your payment.

Document 144-6 Filed 02/03/26 1790

kaufCAN.com

K&C KAUFMAN & CANOLES we can. and we will.

October 9, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through September 30, 2025 in connection with: HII MT - Curtin v. Watts Litigation (Matter No. 2025-12613)

09/08/25

Retrieve and Organize Curtin First Amended Complaint and all 36 Exhibits to same K.M. Rine 0.50 hrs.

09/08/25

Review applicable case law as to Va. in context of recoupment

Code § 8.9A-404(a)(1) applicability to deduct fees

A. Mohamed Khalil

2.70 hrs.

09/08/25

Review and analyze complaint and related pleadings C.J. Belote 1.10 hrs.

09/09/25

Review and analyze pro se Plaintiff Curtin's Complaint and attached exhibits L.P. Jones 1.20 hrs.

09/09/25

Begin gathering case law in support of motion to dismiss Curtin's Complaint L.P. Jones 1.60 hrs.

09/09/25

Review and analyze complaint and potential defenses and counterclaims C.J. Belote 0.40 hrs.

09/10/25

Draft arguments for Motion to Dismiss re: breach of fiduciary duty and negligent supervision claims

L.P. Jones

3.10 hrs.

09/11/25

Continue drafting and revising arguments for Motion to Dismiss L.P. Jones 2.90 hrs.

October 9, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

09/17/25

Draft letter to Cyberlux re: indemnification L.P. Jones 0.90 hrs.

09/17/25

Update and add additional case law to outline of motion to dismiss for NC matter L.P. Jones 0.90 hrs.

09/17/25

Analyze issues for notice and demand for indemnity letter to Cyberlux based on complaint

C.J. Belote 0.60 hrs.

09/18/25

Revise and update letter to Cyberlux re: Curtin v. Watts to include subcontract provisions and argument in support

L.P. Jones 0.80 hrs.

09/18/25

Revise letter to Cyberlux re: notice of indemnity C.J. Belote 0.20 hrs.

09/19/25

Draft Opposition to Curtin's Motion for Leave L.P. Jones 1.90 hrs.

09/19/25

Revise indemnity notice letter to Cyberlux C.J. Belote 0.50 hrs.

09/23/25

Review and analyze service of process issues and arguments for motion to dismiss C.J. Belote 0.60 hrs.

09/24/25

Analyze potential lack of standing arguments C.J. Belote 0.30 hrs.

09/29/25

Review correspondence on service of complaint from J. Curtin C.J. Belote 0.20 hrs.

09/30/25

Review letter from J. Curtin re: service and litigation hold C.J. Belote 0.30 hrs.

TOTAL FOR SERVICES $5,080.50

CURRENT BILLING FOR THIS MATTER $5,080.50

TOTAL DUE FOR THIS MATTER

$5,080.50

HUNTINGTON INGALLS INDUSTRIES, INC.

October 9, 2025

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

4.20

325.00

$1,365.00

L.P. Jones

13.30

225.00

$2,992.50

A. Mohamed Khalil

2.70

240.00

$648.00

K.M. Rine

0.50

150.00

$75.00

20.70

$5,080.50

kaufCAN.com

K&C KAUFMAN & CANOLES we can. and we will.

November 5, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through October 31, 2025 in connection with: HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

10/01/25

Review recent correspondence re: matter D.T. Lewandowski

0.10 hrs.

10/02/25

Review status - Rule 11 Motion D.T. Lewandowski

0.10 hrs.

10/03/25

Prepare for and attend extended telephone conference with M. Sheehan and team re:

C.J. Belote

1.40 hrs.

10/17/25

Review recent Cyberlux pleadings and

update M. Sheehan re:

C.J. Belote

0.50 hrs.

10/17/25

Review recent correspondence and Deposit Funds

attachments regarding status of our draft Motion to

D.T. Lewandowski

0.30 hrs.

10/20/25

Telephone conference with counsel for C.J. Belote

Cyberlux landlord in Texas re: status of litigation 0.30 hrs.

10/29/25

Review recent pleadings filed by Cyberlux Court

in Richmond Circuit Court and Texas Appeals

C.J. Belote

0.30 hrs.

TOTAL FOR SERVICES

$1,037.50

HUNTINGTON INGALLS INDUSTRIES, INC.

November 5, 2025

CURRENT BILLING FOR THIS MATTER

$1,037.50

TOTAL DUE FOR THIS MATTER

$1,037.50

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

2.50

325.00

$812.50

D.T. Lewandowski

0.50

450.00

$225.00

3.00

$1,037.50

Document 144-6 1795

Filed 02/03/26

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

November 5, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered

Invoice No.

through October 31, 2025

Fees:

$1,037.50

Total due for this invoice:

$1,037.50

Pay by eCheck or Credit Card:

Pay by check:

Pay by Wire or ACH transfer:

https://www.kaufcan.com/paymentportal

Kaufman & Canoles, P.C.

P.O. Box 3037

Norfolk, VA 23514

Beneficiary Name and Account:

Kaufman & Canoles, P.C. Operating Receipts

150
West Main Street Suite 2100

Norfolk VA 23510

Account # 0261130242

Beneficiary Bank: TowneBank 109 E. Main Street Norfolk, VA 23510 ABA Routing # 051408949 Swift Code: TOWBUS32

Please reference client matter and (or) invoice number from your statement when making payment. Please send an email to accounting@kaufcan.com to notify us of your payment.

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

November 5, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through October 31, 2025 in connection with: HII MT - Curtin v. Watts Litigation (Matter No. 2025-12613)

10/01/25

Begin research re: standing and lack L.P. Jones

of subject matter jurisdiction for motion to dismiss 0.80 hrs.

10/01/25

Receive and review complaint and confer with defense team regarding

J.E. Houchin

0.60 hrs.

10/01/25

Analyze and outline arguments for C.J. Belote

motion to dismiss

0.80 hrs.

10/03/25

Begin drafting motion to dismiss amended complaint L.P. Jones 1.80 hrs.

10/05/25

Continue drafting memo in support of motion to dismiss L.P. Jones 1.10 hrs.

10/06/25

Continue drafting memo in support of motion to dismiss

L.P. Jones :unselected:

2.90 hrs.

10/07/25

Continue drafting memo in support of motion to dismiss

L.P. Jones :unselected:

0.90 hrs.

10/08/25

Finalize first draft of motion to dismiss L.P. Jones

and accompanying memorandum of law 0.60 hrs.

Page 68 of 92 PageID#

November 5, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

10/09/25

Review docket status

C.J. Belote

0.10 hrs.

10/12/25

Revise brief in support of motion to dismiss C.J. Belote

1.40 hrs.

10/13/25

Revise brief in support of motion to dismiss C.J. Belote

complaint 0.70 hrs.

10/13/25

Analyze local rules regarding special appearance and prepare same

and corporate disclosure requirements

J.E. Houchin

0.60 hrs.

10/13/25

Revise and update draft of memo in support of support, etc.

motion to dismiss with addition case law

L.P. Jones

2.20 hrs.

10/14/25

Review docket status and service issues C.J. Belote

0.20 hrs.

10/14/25

Review emails from client and plan for upcoming L.P. Jones

meeting 0.10 hrs.

10/15/25

Review draft motion and memo and participate in conference call with client discussing

J.E. Houchin

0.70 hrs.

10/15/25

Revise brief in support of motion to dismiss C.J. Belote

2.10 hrs.

10/15/25

Telephone conference with R. Platt and M. Sheehan re:

C.J. Belote

0.70 hrs.

10/15/25

Meet with client to discuss revisions to Memo L.P. Jones

0.40 hrs.

10/15/25

Continue revising and updating memo based L.P. Jones

on suggested revisions from client 4.40 hrs.

10/16/25

Review brief in support of motion to dismiss C.J. Belote

0.40 hrs.

HUNTINGTON INGALLS INDUSTRIES, INC. November 5, 2025

10/16/25 Review tracked changes sent by client and address all comments to include researching and drafting additional case law support, etc. L.P. Jones 4.10 hrs.

10/17/25

Finalize ensuring compliance with applicable statutes and local rules and file notice of appearance, corporate disclosure, motion to dismiss, and memorandum in support ensuring service on Plaintiff J.E. Houchin 1.30 hrs.

10/17/25

Revise, finalize and prepare for filing brief in support of motion to dismiss and related pleadings C.J. Belote 2.10 hrs.

10/20/25

Review and analyze emails from Plaintiff Curtin re: opposition and motion to stay L.P. Jones 0.50 hrs.

10/20/25

Review opposition to motion to dismiss filed by J. Curtin C.J. Belote

0.80 hrs.

10/20/25

Review motion to dismiss filed by City of Greensboro C.J. Belote

0.30 hrs.

10/20/25

Revise and finalize notice of special appearance C.J. Belote

0.30 hrs.

10/20/25

Receive and review Plaintiff's response in opposition to motion to dismiss and correspondence from Plaintiff regarding proposed stay J.E. Houchin 0.60 hrs.

10/20/25

Analyze motion to dismiss filed by co-defendant J.E. Houchin

0.30 hrs.

10/21/25

Review emails re: stay request and responsive pleadings of Cyberlux C.J. Belote 0.30 hrs.

10/22/25

Follow and review emails from co-defense counsel and Plaintiff re: motion to stay, service, etc. L.P. Jones 0.20 hrs.

10/22/25

Conference call with client regarding

J.E. Houchin

0.20 hrs.

10/22/25 Telephone conference with R. Platt and J. Bauer re: C.J. Belote

0.30 hrs.

HUNTINGTON INGALLS INDUSTRIES, INC. November 5, 2025

10/22/25 Outline arguments for reply brief in support of motion to dismiss, including analysis of applicable case law C.J. Belote 4.10 hrs.

10/23/25

Review and analyze Plaintiff's opposition L.P. Jones

0.90 hrs.

10/23/25

Begin drafting reply brief to Plaintiff's opposition L.P. Jones

3.80 hrs.

10/23/25 Draft portions of reply brief in support of motion to dismiss C.J. Belote 1.90 hrs.

10/24/25 Review reply brief in support of motion to dismiss C.J. Belote

0.80 hrs.

10/24/25

Draft and revise reply brief to Plaintiff's opposition L.P. Jones 3.10 hrs.

10/26/25

Revise reply brief in support of motion to dismiss C.J. Belote 0.50 hrs.

10/27/25 Analyze and supplement reply to Plaintiff's opposition to motion to dismiss J.E. Houchin 0.80 hrs.

10/27/25

Revise reply brief in support of motion to dismiss C.J. Belote

3.00 hrs.

10/29/25

Review and analyze motion to dismiss filed by Chuck Watts C.J. Belote 0.40 hrs.

10/29/25

Receive and analyze motion to dismiss filed by co-defendant J.E. Houchin 0.30 hrs.

10/29/25 Review cited cases in Chuck Watt's brief for accuracy and potential use in reply brief L.P. Jones 0.60 hrs.

10/30/25

Conference call with client discussing

J.E. Houchin

0.30 hrs.

10/30/25 Receive and analyze response in opposition to co-defendant's motion to dismiss J.E. Houchin 0.70 hrs.

HUNTINGTON INGALLS INDUSTRIES, INC.

November 5, 2025

10/30/25

Attend Teams meeting re:

L.P. Jones

0.30 hrs.

10/30/25

Teams meeting with HII re:

C.J. Belote

0.40 hrs.

10/30/25

Revise reply brief in support of motion to dismiss C.J. Belote 0.80 hrs.

10/31/25

Revise reply brief in support of motion to dismiss

C.J. Belote 3.20 hrs.

TOTAL FOR SERVICES

$17,337.50

CURRENT BILLING FOR THIS MATTER

$17,337.50

TOTAL DUE FOR THIS MATTER $17,337.50

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

25.60

325.00

$8,320.00

J.E. Houchin

6.40

400.00

$2,560.00

L.P. Jones

28.70

225.00

$6,457.50

60.70

$17,337.50

kaufCAN.com

K&C KAUFMAN & CANOLES we can. and we will.

December 3, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through November 30, 2025 in connection with: HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

11/02/25

Review notice of supplementation filed by Roman Investments C.J. Belote 0.20 hrs.

11/03/25

Review recent ruling in Cyberlux state court matters for any impact on receiver and EDVA matter C.J. Belote 0.30 hrs.

11/06/25

Review and respond to email from Atlantic Wave counsel re: timing of ruling C.J. Belote 0.10 hrs.

11/10/25

Review issues regarding new garnishment and best ways to resolve D.T. Lewandowski 0.30 hrs.

11/10/25

Review Receiver's Counsel's letter re: demand to deposit funds D.T. Lewandowski 0.20 hrs.

11/10/25

Review and analyze garnishment summons from Advanced Navigation C.J. Belote 1.00 hrs.

11/11/25

Review options per Receiver's request for a deposit order D.T. Lewandowski 0.30 hrs.

11/11/25

Telephone conference with client re:

C.J. Belote

0.60 hrs.

Page 73 of 92 PageID#

December 3, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

11/11/25

Draft proposed order for motion to deposit C.J. Belote 1.90 hrs.

11/12/25

Email Receiver's counsel and ANPC counsel re: calls to discuss next steps C.J. Belote 0.10 hrs.

11/13/25

Review and analyze Judge Gibney order on Cyberlux phantom citations C.J. Belote 0.30 hrs.

11/13/25

Telephone conference with counsel for Advanced Navigation re: garnishment proceeding and seeking stay/continuance of same C.J. Belote 0.40 hrs.

11/13/25

Telephone conference with counsel for Receiver re: request for motion to deposit funds and related issues

C.J. Belote

0.60 hrs.

11/13/25

Telephone conference with R. Platt re:

C.J. Belote

0.50 hrs.

11/13/25

Review Court Order re: Cyberlux incorrect citations D.T. Lewandowski 0.10 hrs.

11/14/25

Review and analyze Fairfax garnishment case order and effects of same C.J. Belote 0.50 hrs.

11/14/25

Review Fairfax Order and issues re: same D.T. Lewandowski

0.20 hrs.

11/16/25

Draft email response to receiver's counsel addressing November 10 letter C.J. Belote 0.30 hrs.

11/17/25

Revise and finalize email response to receiver's counsel re: motion to deposit C.J. Belote 0.40 hrs.

11/17/25

Telephone conference with counsel for Thin Air Gear re: payment to Cyberlux C.J. Belote 0.10 hrs.

11/19/25

Telephone conference with counsel for Thin Air Gear re: nonpayment to Cyberlux C.J. Belote 0.30 hrs.

11/19/25

Review correspondence and suggested changes to deposit order D.T. Lewandowski 0.20 hrs.

Page 74 of 92 PageID#

December 3, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

11/20/25

Review brief filed by Cyberlux re:

court's show cause order

C.J. Belote

0.20 hrs.

11/21/25

Review Cyberlux Court ordered response to incorrect citations

D.T. Lewandowski

0.50 hrs.

11/24/25

Review notice of lien filing from former Atlantic Wave Counsel

C.J. Belote

0.20 hrs.

11/24/25

Review and respond to email from cause response

current Atlantic Wave counsel re: Cyberlux show

C.J. Belote

0.20 hrs.

11/24/25

Email follow up to receiver counsel C.J. Belote

re: proposed order or other deposit next steps

0.10 hrs.

11/24/25

Review and revise garnishment stay pleadings received from ANPC counsel C.J. Belote 1.10 hrs.

11/24/25

Review draft Motion and Order re: Stay and new Garnishment proceedings

D.T. Lewandowski

0.40 hrs.

11/26/25

Review email proposal from receiver's counsel re: interpleader deposit

C.J. Belote

0.20 hrs.

11/26/25

Review recent correspondence re:

matter

D.T. Lewandowski

0.10 hrs.

TOTAL FOR SERVICES

$4,155.00

CURRENT BILLING FOR THIS MATTER

$4,155.00

TOTAL DUE FOR THIS MATTER

$4,155.00

BALANCE DUE UPON RECEIPT

December 3, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

9.60

325.00

$3,120.00

D.T. Lewandowski

2.30

450.00

$1,035.00

11.90

$4,155.00

Document 144-6 1805

Filed 02/03/26

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

December 3, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered

Invoice No.

through November 30, 2025

Fees:

$4,155.00

Total due for this invoice:

$4,155.00

Pay by eCheck or Credit Card:

Pay by check:

Pay by Wire or ACH transfer:

https://www.kaufcan.com/paymentportal

Kaufman & Canoles, P.C.

P.O. Box 3037

Norfolk, VA 23514

Beneficiary Name and Account:

Kaufman & Canoles, P.C. Operating Receipts

150
West Main Street Suite 2100

Norfolk VA 23510

Account # 0261130242

Beneficiary Bank: TowneBank 109 E. Main Street Norfolk, VA 23510 ABA Routing # 051408949 Swift Code: TOWBUS32

Please reference client matter and (or) invoice number from your statement when making payment. Please send an email to accounting@kaufcan.com to notify us of your payment.

kaufCAN.com

K&C KAUFMAN & CANOLES we can. and we will.

December 3, 2025

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

B.H. Whitt

For legal services rendered through November 30, 2025 in connection with: HII MT - Curtin v. Watts Litigation (Matter No. 2025-12613)

11/01/25

Revise reply brief in support of motion to dismiss C.J. Belote 0.20 hrs.

11/03/25

Revise, finalize and coordinate filing of reply brief in support of motion to dismiss C.J. Belote 1.40 hrs.

11/03/25

Respond to email from counsel for the City of Greensboro regarding EDVA matter C.J. Belote 0.20 hrs.

11/03/25

Receive and analyze Plaintiff's motion for determination as part of litigation strategy development J.E. Houchin 0.30 hrs.

11/03/25

Supplement and finalize reply brief in opposition to Plaintiff's response to motion to dismiss and file same ensuring compliance with applicable rules J.E. Houchin 0.40 hrs.

11/04/25

Receive and analyze Plaintiff's response in opposition to co-defendant's motion to dismiss and motion for determination of service

J.E. Houchin

0.50 hrs.

11/04/25

Review additional filings by J. Curtin C.J. Belote

0.40 hrs.

11/05/25

Receive and analyze plaintiff's "notice of relevant information" and confer with defense team regarding J.E. Houchin 0.60 hrs.

Page 78 of 92 PageID#

December 3, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

11/05/25

Receive and analyze Order denying Motion for Default J.E. Houchin 0.30 hrs.

11/05/25

Review and analyze new filing by Curtin purporting to supplement the record C.J. Belote 1.20 hrs.

11/06/25

Review Curtin emails and filings re: default of Watts Law C.J. Belote 0.20 hrs.

11/06/25

Receive and review correspondence between plaintiff and co-defendant regarding service of process

J.E. Houchin 0.10 hrs.

11/06/25

Review and analyze emails between plaintiff and C. Watts including attached documents L.P. Jones 0.90 hrs.

11/07/25

Review reply brief of City of Greensboro in support of motion to dismiss C.J. Belote 0.30 hrs.

11/07/25

Receive and analyze co-defendant's reply to motion to dismiss and plaintiff's notice of filings

J.E. Houchin 0.40 hrs.

11/07/25

Receive and analyze supplemental filing by plaintiff submitted in support of prior motion for service

J.E. Houchin 0.20 hrs.

11/10/25

Receive and review text order from magistrate denying plaintiff's various motions directed against co-defendant J.E. Houchin 0.10 hrs.

11/11/25

Receive and review series of emails from plaintiff and confer with defense team regarding J.E. Houchin 0.30 hrs.

11/11/25

Review settlement email from J. Curtin C.J. Belote 0.20 hrs.

11/12/25

Telephone call from counsel for Cyberlux requesting conference call J.E. Houchin 0.30 hrs.

11/12/25

Receive and analyze plaintiff's supplemental filing to prior motion for determination J.E. Houchin 0.20 hrs.

Page 79 of 92 PageID#

December 3, 2025

HUNTINGTON INGALLS INDUSTRIES, INC.

11/12/25

Review email re: reach out from new Cyberlux counsel in North Carolina

C.J. Belote

0.20 hrs.

11/13/25

Conference call with counsel for co-defendants J.E. Houchin

regarding case status

0.40 hrs.

11/13/25

Telephone conference with new counsel for Cyberlux in Curtin proceeding re: responsive pleadings

C.J. Belote

0.40 hrs.

11/14/25

Review and analyze settlement issues and

options based on City settling out

C.J. Belote

0.50 hrs.

11/17/25

Review Cyberlux motion to dismiss C.J. Belote

0.20 hrs.

11/18/25

Receive and analyze motion to dismiss filed filed by plaintiff

by co-defendant and response in opposition

J.E. Houchin

0.50 hrs.

11/19/25

Review and analyze Curtin's opposition to motion to dismiss

C.J. Belote

0.70 hrs.

11/20/25

Review and analyze plaintiff's motions for counsel

partial resolution and related emails from

L.P. Jones

0.80 hrs.

11/20/25

Receive and review recent pro se filing from plaintiff J.E. Houchin 0.10 hrs.

11/20/25

Receive and review additional filings from plaintiff analyzing as part of response strategy development

J.E. Houchin

0.60 hrs.

11/20/25

Conference call client regarding J.E. Houchin

0.40 hrs.

11/20/25

Review and analyze multiple filings by Curtin C.J. Belote

re: settlement with City of Greensboro 0.70 hrs.

11/20/25

Prepare for and attend call with M. Sheehan

and R. Platt re:

C.J. Belote

0.60 hrs.

11/23/25

Review latest pleading filed by J. Curtin C.J. Belote

0.30 hrs.

Page 80 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC. December 3, 2025

11/25/25 Receive and review reply brief by co-defendant and supplemental filing from plaintiff J.E. Houchin

0.40 hrs.

11/25/25

Review reply brief filed by Cyberlux in support of motion to dismiss C.J. Belote 0.20 hrs.

11/25/25

Review and analyze Curtin filings for C.J. Belote

1.20 hrs.

11/26/25

Review additional pleadings filed by J. Curtin and forward to client C.J. Belote 0.20 hrs.

TOTAL FOR SERVICES $5,845.00

CURRENT BILLING FOR THIS MATTER

$5,845.00

TOTAL DUE FOR THIS MATTER

$5,845.00

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

9.30

325.00

$3,022.50

J.E. Houchin

6.10

400.00

$2,440.00

L.P. Jones

1.70

225.00

$382.50

17.10

$5,845.00

Document 144-6 Filed 02/03/26 1810

kaufCAN.com

K&C KAUFMAN & CANOLES we can. and we will.

January 9, 2026

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

K.B. Burch

For legal services rendered through December 31, 2025 in connection with: HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

12/01/25

Telephone conference with client re:

C.J. Belote

0.80 hrs.

12/01/25

Revise motion to deposit brief C.J. Belote

0.90 hrs.

12/01/25

Attend strategy call as to A. Mohamed Khalil 0.60 hrs.

12/03/25

Telephone conference with counsel for ANPC re: revisions to proposed garnishment stay pleadings

C.J. Belote

0.20 hrs.

12/03/25

Review and analyze motion to intervene filed by Thin Air Gear C.J. Belote 1.80 hrs.

12/03/25

Email Receiver's counsel re: potential motion to deposit C.J. Belote 0.20 hrs.

12/03/25

Review recent Texas pleadings C.J. Belote 0.20 hrs.

12/03/25

Review Thin Air Gear motion to intervene, memorandum in support of motion to intervene, and proposed complaint to intervene, including review of claims made as to lack of notice of nonpayment and creditor certification A. Mohamed Khalil 0.40 hrs.

Page 82 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

January 9, 2026

12/04/25

Review Thin Air Gear Intervention pleadings D.T. Lewandowski 0.40 hrs.

12/04/25

Revise brief in support of motion for interpleader relief C.J. Belote 1.80 hrs.

12/04/25

Analyze response issues for Thin Air Gear's Motion to Intervene C.J. Belote 0.50 hrs.

12/05/25

Analyze and revise ANPC garnishment proposed pleadings to

C.J. Belote

2.10 hrs.

12/05/25

Review issues regarding most recent garnishment - retention of lieu D.T. Lewandowski 0.60 hrs.

12/08/25

Draft response to Thin Air Gear motion to intervene C.J. Belote 1.80 hrs.

12/09/25

Review draft Response to TAG Motion to Intervene D.T. Lewandowski 0.40 hrs.

12/09/25

Revise response to Thin Air Gear motion to intervene C.J. Belote 1.30 hrs.

12/09/25

Telephone conference with counsel for ANPC re: revisions to garnishment pleadings C.J. Belote 0.30 hrs.

12/09/25

Emails with Atlantic Wave counsel re: moving along interpleader action C.J. Belote 0.20 hrs.

12/10/25

Revise response to Thin Air Gear motion to intervene C.J. Belote 1.00 hrs.

12/11/25

Revise, finalize and file response to Thin Air Gear motion to intervene C.J. Belote 0.60 hrs.

12/11/25

Extended telephone conference with Atlantic Wave principal re: updates in Texas and potential settlement proposals C.J. Belote 0.80 hrs.

12/11/25

Review and analyze revised garnishment stay pleadings from ANPC counsel C.J. Belote 0.50 hrs.

HUNTINGTON INGALLS INDUSTRIES, INC. January 9, 2026

12/11/25

Review status of Texas matters D.T. Lewandowski 0.20 hrs.

12/13/25

Review and analyze edits to garnishment pleadings from ANPC and potential changes to

C.J. Belote

0.60 hrs.

12/15/25

Review Rule to Show Cause Order D.T. Lewandowski 0.20 hrs.

12/15/25

Review sanctions show cause order entered by Judge Gibney C.J. Belote 0.20 hrs.

12/15/25 Analyze garnishment issues for Advanced Navigation pleadings and email counsel re: same

C.J. Belote

0.60 hrs.

12/16/25

Analyze garnishment pleading issues including telephone call with J. Dunn C.J. Belote 0.40 hrs.

12/17/25 Review, analyze and revise motion to stay and proposed order from ANPC counsel on garnishment C.J. Belote 0.70 hrs.

12/19/25 Emails on ANPC garnishment pleadings with ANPC counsel C.J. Belote 0.20 hrs.

12/22/25

Email update to R. Platt re: C.J. Belote

0.10 hrs.

Analyze prior motion to deposit outcomes to assess and craft appropriate email response C.J. Belote

2.30 hrs.

12/23/25

12/30/25

Review recent Texas pleadings re: Atlantic Wave receivership and email G. Jackson

C.J. Belote

0.80 hrs.

12/30/25

Review and finalize revised ANPC motion to stay garnishment proceeding and consent order C.J. Belote 0.60 hrs.

TOTAL FOR SERVICES $8,037.50

HUNTINGTON INGALLS INDUSTRIES, INC.

January 9, 2026

CURRENT BILLING FOR THIS MATTER

$8,037.50

TOTAL DUE FOR THIS MATTER

$8,037.50

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

21.50

325.00

$6,987.50

D.T. Lewandowski

1.80

450.00

$810.00

A. Mohamed Khalil

1.00

240.00

$240.00

24.30

$8,037.50

Document 144-6 1814

Filed 02/03/26

kaufCAN.com

KSC KAUFMAN & CANOLES we can. and we will.

January 9, 2026

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

K.B. Burch

For legal services rendered

Invoice No.

through December 31, 2025

Fees:

$8,037.50

Total due for this invoice:

$8,037.50

Pay by eCheck or Credit Card:

Pay by check:

Pay by Wire or ACH transfer:

https://www.kaufcan.com/paymentportal

Kaufman & Canoles, P.C.

P.O. Box 3037

Norfolk, VA 23514

Beneficiary Name and Account:

Kaufman & Canoles, P.C. Operating Receipts

150
West Main Street Suite 2100

Norfolk VA 23510

Account # 0261130242

Beneficiary Bank: TowneBank 109 E. Main Street Norfolk, VA 23510 ABA Routing # 051408949 Swift Code: TOWBUS32

Please reference client matter and (or) invoice number from your statement when making payment. Please send an email to accounting@kaufcan.com to notify us of your payment.

Document 144-6 Filed 02/03/26 1815

kaufCAN.com

K&C KAUFMAN & CANOLES we can. and we will.

January 9, 2026

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Bill No .:

Client No .:

Matter No .:

K.B. Burch

For legal services rendered through December 31, 2025 in connection with: HII MT - Curtin v. Watts Litigation (Matter No. 2025-12613)

12/01/25

Receive and analyze supplemental filings J.E. Houchin

submitted by plaintiff 0.30 hrs.

12/02/25

Receive and analyze correspondence from discussions

pro se plaintiff requesting settlement

J.E. Houchin

0.10 hrs.

12/02/25

Review settlement email from J. Curtin C.J. Belote

0.10 hrs.

12/03/25

Receive and review settlement communication prepare summary of response options to J.E. Houchin

from plaintiff and analyze local rules and plaintiff's serial filings 0.80 hrs.

12/03/25

Draft email to client re:

C.J. Belote

0.50 hrs.

12/04/25

Email J. Curtin re: settlement C.J. Belote

0.20 hrs.

12/10/25

Receive and analyze plaintiff's most recent J.E. Houchin

filing and notice to the Court 0.20 hrs.

12/10/25

Review new filing by Curtin C.J. Belote

0.10 hrs.

Page 87 of 92 PageID#

HUNTINGTON INGALLS INDUSTRIES, INC.

January 9, 2026

12/11/25

Review text order from the court striking plaintiff pleadings C.J. Belote 0.10 hrs.

12/12/25

Analyze FOIA response issues to draft language on request for Cyberlux subcontract C.J. Belote 0.80 hrs.

12/12/25

Conduct research re: federal FOIA and draft proposed response to recent request for documents from the government

L.P. Jones

2.60 hrs.

TOTAL FOR SERVICES

$1,730.00

CURRENT BILLING FOR THIS MATTER

$1,730.00

TOTAL DUE FOR THIS MATTER

$1,730.00

BALANCE DUE UPON RECEIPT

Name

Summary of Fees

Fees

Hours

Rate/Hr

C.J. Belote

1.80

325.00

$585.00

J.E. Houchin

1.40

400.00

$560.00

L.P. Jones

2.60

225.00

$585.00

5.80

$1,730.00

Filed 02/03/26

Page 88 of 92 PageID#

PROFORMA BILLING INSTRUCTIONS

DATE PRINTED:

01/26/2026

FEES BILL-THRU DATE:

01/26/2026

COSTS BILL-THRU DATE:

01/26/2026

CLIENT

BILLING TIMEKEEPER:

MATTER

1007
- K.B. Burch

HUNTINGTON INGALLS INDUSTRIES, INC. HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

UNBILLED TIME (Through 01/26/2026)

DATE

WORK TKPR

WORK HOURS

RATE

VALUE

01/02/26

0.10

375.00

37.50

01/03/26

0.10

375.00

37.50

01/04/26

0.30

450.00

135.00

01/05/26

0.60

375.00

225.00

01/06/26

0.90

375.00

337.50

01/07/26

0.30

375.00

112.50

01/07/26

0.20

375.00

75.00

01/08/26

0.30

450.00

135.00

01/09/26

0.80

375.00

300.00

01/11/26

1.20

375.00

450.00

01/12/26

4.10

375.00

1,537.50

01/12/26

0.80

375.00

300.00

01/12/26

0.40

450.00

180.00

NARRATIVE

PRES TKPR

PRES HOURS

DIS- PLAY

PHASE CODE

TASK CODE

ACT CODE

TIME KEY

Review motion to extend filed by Cyberlux counsel re: show cause

0.10

yes

L210

A104

Email update to client on

0.10

yes

L210

A106

Review Motion to Stay pleadings

0.30

yes

L210

A104

Review response to motion to extend filed by Atlantic Wave and order regarding same

0.60

yes

L210

A104

Review and analyze magistrate judge jurisdiction and settlement conference issues raised by Cyberlux counsel

0.90

yes

L160

A106

Revise and finalize response email communication to Cyberlux counsel regarding magistrate judge jurisdiction and settlement conference

0.30

yes

L160

A108

Review recent Texas litigation pleadings re: Cyberlux

0.20

yes

L210

A104

Review recent correspondence and attachments re: Texas action

0.30

yes

L110

A104

Review and analyze Judge Gibney's order resolving motion to dismiss and motions to intervene and next steps

0.80

yes

L120

A104

Review and analyze case law regarding

1.20

yes

L120

A104

Revise brief in support of motion to deposit funds with

4.10

yes

L210

A103

Review and analyze

0.80

yes

L130

A104

Review Court Opinion

0.40

yes

L110

A104

Filed 02/03/26

Page 89 of 92 PageID#

PROFORMA

BILLING INSTRUCTIONS

DATE PRINTED:

01/26/2026

FEES BILL-THRU DATE:

01/26/2026

COSTS BILL-THRU DATE:

01/26/2026

CLIENT

HUNTINGTON INGALLS INDUSTRIES, INC.

BILLING TIMEKEEPER:

MATTER 0194337

HII MT - Cyberlux Creditor Dispute

1007
- K.B. Burch

(Matter No. 2024-10162)

01/12/26

0.20

450.00

90.00

Consider issues related to attorneys' fees

0.20

yes

L120

A104

01/12/26

0.90

240.00

216.00

Analysis of case law as to

0.90

yes

L120

A104

01/13/26

0.40

450.00

180.00

Review settlement conference issues

0.40

yes

L120

A104

01/13/26

0.10

450.00

45.00

Review recent correspondence re: matter

0.10

yes

L110

A104

01/13/26

0.80

375.00

300.00

Research and analyze

0.80

yes

L130

A102

01/14/26

0.20

450.00

90.00

Review recent correspondence re: matter

0.20

yes

L110

A104

01/14/26

1.90

375.00

712.50

Revise brief in support of motion to deposit to address

1.90

yes

L210

A103

01/14/26

1.60

240.00

384.00

Analysis of caselaw as to r

1.60

yes

L120

A104

01/15/26

1.50

375.00

562.50

Analyze and address brief and affidavit drafting and strategy issues for submission of attorneys fees

1.50

yes

L120

A104

01/16/26

0.80

375.00

300.00

Extended telephone conference with client team re:

0.80

yes

L210

A106

01/16/26

0.20

375.00

75.00

Telephone conference with

0.20

yes

L130

A108

01/16/26

0.60

375.00

225.00

Review edits to motion for settlement conference from Legalist counsel

0.60

yes

L210

A104

01/16/26

0.20

375.00

75.00

Review emails from counsel re: motion for settlement conference pleadings

0.20

yes

L210

A108

01/16/26

2.10

375.00

787.50

Revise memo in support of motion to deposit, including analysis of applicable law on attorneys' fees issues

2.10

yes

L210

A103

01/16/26

0.30

450.00

135.00

Review various and extended correspondence re: matter

0.30

yes

L110

A104

Filed 02/03/26

Page 90 of 92 PageID#

PROFORMA

BILLING INSTRUCTIONS

DATE PRINTED:

01/26/2026

FEES BILL-THRU DATE:

01/26/2026

COSTS BILL-THRU DATE:

01/26/2026

CLIENT

HUNTINGTON INGALLS INDUSTRIES, INC.

BILLING TIMEKEEPER:

MATTER

HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

1007
- K.B. Burch

01/19/26

4.80

375.00

1,800.00

Revise motion to deposit, memo in support of motion to deposit, declaration in support of attorneys' fees, and proposed order

4.80

yes

L210

A103

01/19/26

1.90

240.00

456.00

Review bills for redaction in connection with motion to deposit including request for attorney fee reimbursement

1.90

yes

L130

A104

01/20/26

0.60

375.00

225.00

Draft additional edits to settlement conference motion pleadings to circulate same to counsel

0.60

yes

L210

A103

01/20/26

3.50

240.00

840.00

Continue review and redaction of bills, including review of file as to certain entries to confirm applicability

3.50

yes

L210

A104

01/21/26

1.80

375.00

675.00

Revise brief in support of motion to deposit

1.80

yes

L210

A103

01/21/26

1.10

240.00

264.00

Review CJB comments re: bill redactions; revise redactions and double check all bills

1.10

yes

L210

A103

01/21/26

0.10

240.00

24.00

Review additional case law as to

0.10

yes

L120

A104

01/23/26

0.20

375.00

75.00

Review response filed by Cyberlux counsel to show cause order

0.20

yes

L210

A104

01/23/26

0.20

375.00

75.00

Review proposed email from counsel to Judge Colombell's chambers re: settlement conference and responses to same

0.20

yes

L160

A108

01/23/26

0.70

375.00

262.50

Revise brief in support of motion to deposit, including incorporation of cite check edits

0.70

yes

L210

A103

TOTAL HOURS

36.80

TOTAL PRES HOURS

36.80

TOTAL DOLLAR VALUE

$12,736.50

TOTAL DOLLAR VALUE OF PRES HOURS

$12,736.50

Filed 02/03/26

Page 91 of 92 PageID#

DATE PRINTED:

01/26/2026

FEES BILL-THRU DATE:

01/26/2026

COSTS BILL-THRU DATE:

01/26/2026

PROFORMA

BILLING INSTRUCTIONS

BILLING TIMEKEEPER:

1007
- K.B. Burch

CLIENT

MATTER

HUNTINGTON INGALLS INDUSTRIES, INC. HII MT - Cyberlux Creditor Dispute (Matter No. 2024-10162)

TIMEKEEPER SUMMARY

ID

Summary of Work Time

Dollars

% of Total

Timekeeper

Summary of Pres Time

% of Total

Timekeeper

Hours

Avg. Rate

Hours

Avg. Rate

Dollars

Belote, Clark J.

25.50

375.00

9,562.50

75.08

C.J. Belote

25.50

375.00

$9,562.50

75.08

Lewandowski, Dennis T.

2.20

450.00

990.00

7.77

D.T. Lewandowski

2.20

450.00

$990.00

7.77

Mohamed Khalil, Ahmed

9.10

240.00

2,184.00

17.15

A. Mohamed Khalil

9.10

240.00

$2,184.00

17.15

PROFORMA TOTALS:

36.80

$12,736.50

36.80

$12,736.50

UNBILLED CHARGES (Through 01/26/2026)

DATE

AMOUNT

TKPR

NARRATIVE

DIS- PLAY

CHARGE TYPE

Charge Totals:

$0.00

UNBILLED COSTS (Through 01/26/2026)

DATE

AMOUNT

AUTH BY

COST DESCRIPTION

1.70

Pacer charges

Cost Totals: $1.70

DIS-

TASK

SUMMARY

PLAY

CODE

PHRASE

yes

Pacer charges

TOTAL FEES AND EXPENSES DUE: $12,738.20

Document 144-6 1821

Filed 02/03/26

Page 92 of 92 PageID#

PROFORMA

BILLING INSTRUCTIONS

DATE PRINTED:

01/26/2026

FEES BILL-THRU DATE:

01/26/2026

COSTS BILL-THRU DATE:

01/26/2026

CLIENT 073439

HUNTINGTON INGALLS INDUSTRIES, INC.

BILLING TIMEKEEPER:

MATTER

HII MT - Cyberlux Creditor Dispute

1007
- K.B. Burch

(Matter No. 2024-10162)

TOTAL WRITE-OFFS TO

DATE

BILLING HISTORY

AGING OF ACCOUNTS RECEIVABLE

A/R Fees:

$0.00

Last Bill Date:

01/09/2026

Current:

$0.00

A/R Costs and Other:

$0.00

Last Bill Amount:

$8,037.50

31
to 60 Days:

$0.00

Total Fees Billed:

$124,646.00

61
to 90 Days:

$0.00

TRUST

Last Payment Date:

01/23/2026

91
to 120 Days:

$0.00

Trust Balance:

$0.00

Last Payment Amount:

$8,037.50

121
Days and Over:

$0.00

Total Outstanding Invoices:

$0.00

MONEY ON HAND

Unallocated:

$0.00

MISCELLANEOUS

Remittance Format:

Show Remittance Page

Show Adjustment Option:

Show Adjustments After Fees

Exception Rate:

.10 .15 HII-2023 HII-Cohen HII-Cohen Prints Scans

MATTER ADDRESS

Huntington Ingalls Industries, Inc. Attn: Matthew J. Sheehan Director & Assistant General Counsel Mission Technologies 8350 Broad Street, Suite 1400 McLean, VA 22102

Original source file

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ip-hii-edva-00483-doc-0144-exhibit-6.pdf
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a415a5006c111a45b875c16e54a011ddaabb11749cc01c847f0fb38ec7ae9f49