Evidence Record

IP HII EDVA 00483 Doc. 0162

COMES NOW, Mr. Bill Maadarani, by and through his undersigned counsels, and pursuant to Federal Rule of Civil Procedure 24 respectfully moves this court to allow Mr. Maadarani to intervene in the above captioned...

Type
document
Court
EDVA
Case
HII v. Cyberlux interpleader
Docket
3:25-cv-00483
Pages
3
Lines
68
SHA-256
20483aaee7a1

DISTIL analysis

DISTIL Run
Profile
Standard
Version
1
Doc Type
Motion to Intervene
Total Nodes
21
Node Legend
Entity (ENT)
Event (EVT)
Claim (CLM)
Anchor (ANC)
Omission (OMI)
Tension (TEN)
Tell (TEL)
Inference (INF)
Hypothesis (HYP)
Stage 1
Index
Orientation · No nodes
Document Classification
Motion to Intervene Bilal Maadarani via counsel Federal civil litigation - Eastern District of Virginia 2026-04-09
monetary_claimshareholder_disputeemployment_contractinterpleader_action
Analytical Frame
Legal intervention motion in interpleader dispute
Analytical Summary
This is a motion to intervene filed by Bilal Maadarani seeking to enter an ongoing civil case between HII Mission Technologies Corp. and Cyberlux Corp. Maadarani claims both shareholder status and a former employment position as Chief Revenue Officer of Cyberlux. He asserts a contractual entitlement to $1,062,576.98 from funds that HII interpleaded in the case. The motion seeks intervention as of right under Federal Rule of Civil Procedure 24, with permissive intervention as an alternative. Maadarani's claim is based on an alleged contract with Cyberlux d/b/a Datron World Communications, and his reliance upon that contract creates what he presents as a direct financial interest in the interpleaded funds.
Key Points
  • Bilal Maadarani seeks to intervene in existing litigation between HII Mission Technologies and Cyberlux Corp.
  • Maadarani claims dual status as Cyberlux shareholder and former Chief Revenue Officer
  • Claims $1,062,576.98 owed from interpleaded funds based on contract with Cyberlux d/b/a Datron World Communications
  • Motion filed under Fed. R. Civ. P. 24 seeking intervention as of right or permissively
  • Proposed complaint in intervention attached as Exhibit 5 to supporting memorandum
Stage 2
Core — Entities, Events, Claims
10 nodes
ENT-001
Entity
Bilal Maadarani
Mr. Bilal Maadarani (also spelled Bill Maadarani and Maandarani in document), movant seeking intervention. Identified as shareholder of Cyberlux Corp. and former Chief Revenue Officer of that entity.
Page 1 — Mr. Bill Maadarani, by and through his undersigned counsels... Mr. Maadarani is a shareholder of the defendant, Cyberlux Corp., ("Cyberlux") and also its former Chief Revenue Officer.
ENT-002
Entity
HII Mission Technologies Corp.
HII Mission Technologies Corp., plaintiff in the underlying case. Entity that interpleaded disputed funds.
Page 1 — HII MISSION TECHNOLOGIES CORP., Plaintiff... from the monies HII Mission Technologies Corp. ("HII") interpleaded in this case.
ENT-003
Entity
Cyberlux Corp.
Cyberlux Corp., defendant in underlying case. Also doing business as Datron World Communications. Maadarani's former employer and entity in which he holds shares.
Page 1 — CYBERLUX CORP., et. al., Defendants... Mr. Maadarani is a shareholder of the defendant, Cyberlux Corp., ("Cyberlux")... Cyberlux d/b/a Datron World Communications owes Mr. Maadarani $1,062,576.98
ENT-004
Entity
Mohamad A. Akbik, Esq.
Attorney for Maadarani. Florida Bar member 116366, pending Pro Hac Vice admission in Eastern District of Virginia. Based in Clearwater, FL.
Page 2 — Mohamad A Akbik, Esq. (pending Pro Hac Vice admission) FL Bar: 116366 611 S. Fort Harrison Ave., Suite 183 Clearwater, FL 33756
ENT-005
Entity
Keith A. Jaworski, Esq.
Attorney for Maadarani. Virginia State Bar #101178. Member of Woods Rogers Vandeventer Black PLC in Charlottesville, VA.
Page 2, 3 — Keith A. Jaworski, Esq. (VSB #101178) WOODS ROGERS VANDEVENTER BLACK PLC 120 Garrett Street, Suite 304 Charlottesville, VA 22902
EVT-001
Event
Filing of Motion to Intervene
Bilal Maadarani filed motion to intervene in case 3:25-cv-00483-JAG on April 9, 2026, in U.S. District Court for the Eastern District of Virginia, Richmond Division.
Page 1, 2, 3 — Case 3:25-cv-00483-JAG Document 162 Filed 04/09/26... Dated: April 9, 2026 Pinellas County... I hereby certify that on this 9th day of April, 2026
EVT-002
Event
HII Interpleader Action
HII Mission Technologies Corp. interpleaded disputed funds into the court in the underlying case, creating the pool of money from which Maadarani claims entitlement.
Page 1 — from the monies HII Mission Technologies Corp. ("HII") interpleaded in this case.
CLM-001
Claim
Maadarani's Monetary Claim
Maadarani claims Cyberlux d/b/a Datron World Communications owes him $1,062,576.98 from the interpleaded funds based on contract and his reliance upon that contract.
Page 1 — Pursuant to their contract and Mr. Maandarani's reliance upon said contract, Cyberlux d/b/a Datron World Communications owes Mr. Maadarani $1,062,576.98 from the monies HII Mission Technologies Corp. ("HII") interpleaded in this case.
CLM-002
Claim
Dual Status as Shareholder and Former Officer
Maadarani asserts he is both a shareholder of Cyberlux Corp. and its former Chief Revenue Officer, establishing multiple bases for his claimed interest in the dispute.
Page 1 — Mr. Maadarani is a shareholder of the defendant, Cyberlux Corp., ("Cyberlux") and also its former Chief Revenue Officer.
CLM-003
Claim
Intervention as of Right
Maadarani seeks intervention as a matter of right under Federal Rule of Civil Procedure 24, asserting a sufficient legal interest to warrant mandatory intervention.
Page 1 — pursuant to Federal Rule of Civil Procedure 24 respectfully moves this court to allow Mr. Maadarani to intervene in the above captioned suit... Mr. Maadarani seeks to intervene as a matter of right or in the alternative permissively.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
5 nodes
TEN-001
Tension
Name Spelling Inconsistency
The movant's name appears with three different spellings in the document: 'Bilal Maadarani' (title), 'Bill Maadarani' (initial reference), and 'Maandarani' (within paragraph). This inconsistency could raise authentication or identity questions.
Page 1 — MR. BILAL MAADARANI'S MOTION TO INTERVENE... COMES NOW, Mr. Bill Maadarani... Pursuant to their contract and Mr. Maandarani's reliance... In support of this motion Mr. Maddarani submits
QST-001
Question
Nature of Underlying Contract
What is the specific nature and terms of the contract between Maadarani and Cyberlux that forms the basis of the $1,062,576.98 claim? The motion references 'their contract' and Maadarani's 'reliance upon said contract' but provides no details about contract type, date, or specific terms.
Page 1 — Pursuant to their contract and Mr. Maandarani's reliance upon said contract, Cyberlux d/b/a Datron World Communications owes Mr. Maadarani $1,062,576.98
QST-002
Question
Basis for Claimed Amount
How was the specific amount of $1,062,576.98 calculated? The precise figure suggests a mathematical calculation, but no methodology, formula, or supporting calculation is provided in the motion.
Page 1 — Cyberlux d/b/a Datron World Communications owes Mr. Maadarani $1,062,576.98 from the monies HII Mission Technologies Corp. ("HII") interpleaded in this case.
QST-003
Question
Relationship Between Employment and Shareholder Roles
How do Maadarani's dual roles as former Chief Revenue Officer and current shareholder relate to his contractual claim? Is the claimed debt related to employment compensation, equity interests, or another arrangement?
Page 1 — Mr. Maadarani is a shareholder of the defendant, Cyberlux Corp., ("Cyberlux") and also its former Chief Revenue Officer. Pursuant to their contract and Mr. Maandarani's reliance upon said contract, Cyberlux d/b/a Datron World Communications owes Mr. Maadarani $1,062,576.98
QST-004
Question
Size of Interpleaded Fund
What is the total amount of funds that HII interpleaded? Is Maadarani's claim for the entire interpleaded amount, or is he claiming a portion of a larger fund that may have multiple claimants?
Page 1 — from the monies HII Mission Technologies Corp. ("HII") interpleaded in this case.
Stage 4
Interpretive — Inferences, Omissions, Patterns
6 nodes
INF-001
Inference
Competing Claims on Interpleaded Funds
The fact that HII filed an interpleader action suggests multiple parties claim entitlement to the same funds. Maadarani's intervention motion implies he is not currently a party to the dispute, suggesting other entities or individuals are likely claiming the same interpleaded money.
Page 1 — from the monies HII Mission Technologies Corp. ("HII") interpleaded in this case... Mr. Maadarani seeks to intervene as a matter of right
INF-002
Inference
Urgency Suggested by Intervention Timing
Maadarani's decision to intervene at this stage (Document 162 in the case sequence) suggests either recent awareness of the interpleaded funds or a strategic timing decision. The case number (3:25-cv-00483) indicates the case was filed in 2025, making this an intervention approximately one year into the litigation.
Page 1 — Case 3:25-cv-00483-JAG Document 162 Filed 04/09/26
INF-003
Inference
Reliance Language Suggests Detrimental Change
The specific mention of Maadarani's 'reliance upon said contract' suggests he may have altered his position or suffered detriment based on the contractual promises. This language is typical in promissory estoppel or detrimental reliance arguments.
Page 1 — Pursuant to their contract and Mr. Maandarani's reliance upon said contract, Cyberlux d/b/a Datron World Communications owes Mr. Maadarani $1,062,576.98
OMI-001
Omission
No Explanation for Former Officer Status
The motion identifies Maadarani as 'former Chief Revenue Officer' but provides no explanation of when or why his employment ended, whether termination was voluntary or involuntary, or how the employment termination relates to the claimed debt.
Page 1 — Mr. Maadarani is a shareholder of the defendant, Cyberlux Corp., ("Cyberlux") and also its former Chief Revenue Officer.
OMI-002
Omission
No Description of Underlying Dispute
The motion provides no context about the nature of the underlying dispute between HII and Cyberlux that led to the interpleader action. Understanding that dispute would illuminate why these funds are contested and Maadarani's relationship to the controversy.
Page 1 — HII MISSION TECHNOLOGIES CORP., Plaintiff Case No. 3:25-cv-00483-JAG v. CYBERLUX CORP., et. al., Defendants.
OMI-003
Omission
No Reference to Other Claimants
While the motion asserts Maadarani's entitlement to specific funds, it makes no reference to whether other parties are claiming the same money, what their claims might be, or how Maadarani's claim relates to or conflicts with other potential claimants.
Page 1 — from the monies HII Mission Technologies Corp. ("HII") interpleaded in this case.

Extracted text

3 pages · 2573 characters

IP HII EDVA 00483 Doc. 0162 — Formatted Extract

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

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION

HII MISSION TECHNOLOGIES CORP.,

Plaintiff

Case No. 3:25-cv-00483-JAG

v.

CYBERLUX CORP., et. al.,

Defendants.

MR. BILAL MAADARANI'S MOTION TO INTERVENE

COMES NOW, Mr. Bill Maadarani, by and through his undersigned counsels, and pursuant to Federal Rule of Civil Procedure 24 respectfully moves this court to allow Mr. Maadarani to intervene in the above captioned suit. In support of this motion, Mr. Maadarani submits the attached memorandum of law with exhibits, including the proposed complaint in intervention which is attached as exhibit 5 to the memorandum of law.

Mr. Maadarani is a shareholder of the defendant, Cyberlux Corp., ("Cyberlux") and also its former Chief Revenue Officer. Pursuant to their contract and Mr. Maandarani's reliance upon said contract, Cyberlux d/b/a Datron World Communications owes Mr. Maadarani $1,062,576.98 from the monies HII Mission Technologies Corp. ("HII") interpleaded in this case.

Mr. Maadarani seeks to intervene as a matter of right or in the alternative permissively. In support of this motion Mr. Maddarani submits his memorandum of law with attached exhibits and proposed complaint in intervention.

For all the reasons set forth in Mr. Maadarani's memorandum of law, he humbly requests that the court grant this motion and deem the attached complaint as filed upon entry of an order granting this motion.

Dated: April 9, 2026 Pinellas County

Respectfully Submitted, Ce

Mohamad A Akbik, Esq.

(pending Pro Hac Vice admission)

FL Bar: 116366

611
S. Fort Harrison Ave., Suite 183

Clearwater, FL 33756

Telephone:

727-223-3005

Facsimile:

727-223-3578

Email: akbiklaw@outlook.com

han

Keith A. Jaworski, Esq. (VSB #101178) WOODS ROGERS VANDEVENTER BLACK PLC 120 Garrett Street, Suite 304 Charlottesville, VA 22902 Telephone: 434-220-6825 Facsimile: 434-220-5687 Keith.Jaworski@woodsrogers.com

CERTIFICATE OF SERVICE

I hereby certify that on this 9th day of April, 2026, a true and correct copy of the foregoing was served via CM/ECF, upon all counsel of record.

The fe

Keith A. Jaworski, Esq. (VSB #101178) WOODS ROGERS VANDEVENTER BLACK PLC 120 Garrett Street, Suite 304 Charlottesville, VA 22902 Telephone: 434-220-6825 Facsimile: 434-220-5687 Keith.Jaworski@woodsrogers.com

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