Evidence Record
IP HII EDVA 00483 Doc. 0164
In accordance with Federal Rule of Civil Procedure 56, Local Civil Rule 56, and the Court's March 31, 2026 Order (ECF 158), Thin Air Gear, LLC ("TAG"), by and through its undersigned counsel of...
DISTIL analysis
DISTIL Run
Profile
Standard
Version
1
Doc Type
Motion for Summary Judgment
Total Nodes
25
Node Legend
Entity (ENT)
Event (EVT)
Claim (CLM)
Anchor (ANC)
Omission (OMI)
Tension (TEN)
Tell (TEL)
Inference (INF)
Hypothesis (HYP)
Stage 1
Index
Orientation · No nodes
Document Classification
Motion for Summary Judgment Thin Air Gear, LLC via The Stine Law Firm, PLLC Federal civil litigation - interpleader action over disputed funds Filed April 15, 2026
multiple_claimantspriority_ordering_requestedsubstantial_amount_claimed
Analytical Frame
Priority dispute among multiple creditors seeking payment from interpleaded funds
Analytical Summary
Thin Air Gear, LLC filed a motion for summary judgment in an interpleader action involving disputed funds, claiming $1,385,489.46 plus fees and requesting first or second priority payment. The motion was filed pursuant to a court order requiring parties to address their priority claims relative to at least nine other competing claimants. TAG's motion includes a memorandum of law and supporting declaration with exhibits addressing claims by ARG Group, Legalist, Atlantic Wave/Secure Community, ANPC, Fairwinds, WeShield Group, USA/IRS, Cyberlux Corporation, and the Receiver. The motion requests post-judgment compound interest at 8% and all attorneys' fees and costs incurred in the action.
Key Points
- Thin Air Gear seeks summary judgment for $1,385,489.46 plus attorneys' fees and costs
- TAG requests first or second priority payment from interpleaded funds
- Motion addresses priority claims of nine other parties per court order
- TAG seeks post-judgment compound interest at 8%
- Court previously ordered parties to address priority and entitlement ordering
Stage 2
Core — Entities, Events, Claims
16 nodes
ENT-001
Entity
Thin Air Gear, LLC
Thin Air Gear, LLC (TAG) is the moving party seeking summary judgment and priority payment from disputed interpleaded funds. Represented by The Stine Law Firm, PLLC.
Page 1 — Thin Air Gear, LLC ("TAG"), by and through its undersigned counsel of record, respectfully submits this Motion for Summary Judgment
ENT-002
Entity
HII Mission Technologies Corp.
HII Mission Technologies Corp. is the plaintiff in the underlying civil action Case No. 3:25-cv-483.
Page 1 — HII MISSION TECHNOLOGIES CORP., Plaintiff, v. CYBERLUX CORP., et al., Defendants.
ENT-003
Entity
Cyberlux Corporation
Cyberlux Corporation is a defendant in the underlying action and one of the parties claiming entitlement to the disputed funds.
Page 1, 2 — CYBERLUX CORP., et al., Defendants... Cyberlux Corporation ("Cyberlux")
ENT-004
Entity
The ARG Group, LLC
The ARG Group, LLC (ARG) is one of the competing claimants to the disputed interpleaded funds.
Page 1 — TAG also addresses the claims made by The ARG Group, LLC ("ARG")
ENT-005
Entity
Legalist SPV III, LP
Legalist SPV III, LP is one of the competing claimants to the disputed interpleaded funds.
Page 1 — Legalist SPV III, LP ("Legalist")
ENT-006
Entity
Atlantic Wave Holdings, LLC and Secure Community, LLC
Atlantic Wave Holdings, LLC and Secure Community, LLC are competing claimants being addressed collectively in TAG's motion.
Page 1 — Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively, "Atlantic Wave/Secure Community")
ENT-007
Entity
Advanced Navigation and Positioning Corp.
Advanced Navigation and Positioning Corp. (ANPC) is one of the competing claimants to the disputed funds.
Page 1 — Advanced Navigation and Positioning Corp. ("ANPC")
ENT-008
Entity
Fairwinds Technologies, LLC
Fairwinds Technologies, LLC is one of the competing claimants to the disputed interpleaded funds.
Page 1 — Fairwinds Technologies, LLC ("Fairwinds")
ENT-009
Entity
WeShield Group
The WeShield Group consists of Assure Global LLC d/b/a WeShield, Roman Investments PR, LLC, Mas USA MGT, LLC and Michael Sinesky, collectively claiming entitlement to disputed funds.
Page 1 — Assure Global LLC d/b/a WeShield, Roman Investments PR, LLC, Mas USA MGT, LLC and Michael Sinesky (all collectively, the "WeShield Group")
ENT-010
Entity
USA/IRS
The United States government through the Internal Revenue Service is one of the competing claimants to the disputed funds.
Page 1 — the USA/IRS
ENT-011
Entity
Robert Berleth (Receiver)
Robert Berleth is serving as the Receiver for Cyberlux Corporation and is one of the parties with claims to the disputed funds.
Page 1, 2 — Robert Berleth as the Receiver for Cyberlux (the "Receiver")
ENT-012
Entity
The Stine Law Firm, PLLC
The Stine Law Firm, PLLC serves as counsel for Thin Air Gear, LLC. Attorneys Stephen J. Stine and Stephen L. Neal, Jr. represent TAG in this matter.
Page 2, 3 — Stephen J. Stine, Esq. (VSB# 66738) Stephen L. Neal, Jr., Esq. (VSB# 87064) THE STINE LAW FIRM, PLLC 3900 Jermantown Rd., Suite 300 Fairfax, VA 22030-4900
EVT-001
Event
Court Order to Address Priority Claims
On March 31, 2026, the Court issued an order requiring parties to address the priority of their claims to the Disputed Funds compared to other parties' claims and establish where each party falls in order of priority or entitlement.
Page 1 — the Court's March 31, 2026 Order (ECF 158)... In accordance with the Court's Order to address the "priority of the party's claim to the Disputed Funds as compared to other parties' claims" and "where each party falls in order of priority or entitlement" (ECF 158 at 1-2)
EVT-002
Event
Filing of TAG's Motion for Summary Judgment
Thin Air Gear, LLC filed a Motion for Summary Judgment on April 15, 2026, pursuant to Federal Rule of Civil Procedure 56 and the Court's March 31, 2026 Order.
Page 1, 2 — Dated: April 15, 2026... In accordance with Federal Rule of Civil Procedure 56, Local Civil Rule 56, and the Court's March 31, 2026 Order (ECF 158), Thin Air Gear, LLC ("TAG"), by and through its undersigned counsel of record, respectfully submits this Motion for Summary Judgment
CLM-001
Claim
TAG's $1,385,489.46 Claim Amount
Thin Air Gear, LLC claims entitlement to $1,385,489.46 from the interpleaded funds, plus attorneys' fees, costs, and post-judgment compound interest at 8%.
Page 2 — the Court should grant this Motion, enter summary judgment in favor of TAG in the amount of $1,385,489.46, plus all attorneys' fees and costs incurred in this action and post-judgment compound interest at 8% from the date of judgment until the judgment is fully satisfied
CLM-002
Claim
TAG's Priority Position Request
TAG requests that the Court order it be paid first or second from the interpleaded funds, ahead of other competing claimants.
Page 2 — order that TAG be paid first or second from the interpleaded funds
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
4 nodes
TEN-001
Tension
Multi-Party Priority Competition
At least ten separate parties or groups are competing for priority payment from limited interpleaded funds, creating a zero-sum allocation dispute where TAG's first or second position claim directly conflicts with other claimants' interests.
Page 1, 2 — TAG also addresses the claims made by The ARG Group, LLC ("ARG"), Legalist SPV III, LP ("Legalist"), Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively, "Atlantic Wave/Secure Community"), Advanced Navigation and Positioning Corp. ("ANPC"), Fairwinds Technologies, LLC ("Fairwinds"), Assure Global LLC d/b/a WeShield, Roman Investments PR, LLC, Mas USA MGT, LLC and Michael Sinesky (all collectively, the "WeShield Group"), the USA/IRS, Cyberlux Corporation ("Cyberlux"), and Robert Berleth as the Receiver for Cyberlux (the "Receiver")
QST-001
Question
Basis for TAG's Priority Claim
What is the legal or factual basis for TAG's claim to first or second priority position among the ten competing claimants? The motion references a supporting memorandum and declaration with exhibits, but these documents are not included in the current extraction.
Page 1 — In support of this Motion, TAG submits its Memorandum of Law and Declaration of Anthony R. Gonzalez with attached Exhibits (Exhibit A to the Memorandum)
QST-002
Question
Nature of Underlying Dispute
What is the nature of TAG's relationship to Cyberlux and the underlying dispute that generated the $1.4M claim? The document does not explain whether TAG is a creditor, vendor, investor, or other type of claimant.
Page 1, 2 — HII MISSION TECHNOLOGIES CORP., Plaintiff, v. CYBERLUX CORP., et al., Defendants... TAG in the amount of $1,385,489.46
QST-003
Question
Amount of Total Disputed Funds
What is the total amount of the interpleaded funds available for distribution? TAG claims over $1.38M and seeks first or second position, but the document does not indicate whether the fund is sufficient to pay all claimants or their relative claim amounts.
Page 2 — enter summary judgment in favor of TAG in the amount of $1,385,489.46... order that TAG be paid first or second from the interpleaded funds
Stage 4
Interpretive — Inferences, Omissions, Patterns
5 nodes
INF-001
Inference
Insufficient Funds for All Claimants
The fact that the Court ordered parties to establish priority rankings, combined with TAG's explicit request for first or second position payment, suggests the interpleaded funds are insufficient to satisfy all claims. Otherwise, simple pro rata distribution or sequential payment without priority disputes would be feasible.
Page 1, 2 — In accordance with the Court's Order to address the "priority of the party's claim to the Disputed Funds as compared to other parties' claims" and "where each party falls in order of priority or entitlement" (ECF 158 at 1-2)... order that TAG be paid first or second from the interpleaded funds
INF-002
Inference
Federal Tax Claim Involvement
The involvement of the USA/IRS as a competing claimant suggests Cyberlux or related entities may have significant unpaid federal tax liabilities. Federal tax liens typically receive statutory priority in creditor disputes, which may explain why TAG seeks first or second position rather than outright first position.
Page 1, 2 — the USA/IRS... order that TAG be paid first or second from the interpleaded funds
INF-003
Inference
Cyberlux Financial Distress or Insolvency
The appointment of a receiver for Cyberlux, combined with multiple creditor claims totaling at minimum over $1.38M from TAG alone, indicates Cyberlux is likely in severe financial distress or insolvency proceedings. The interpleader action suggests funds were held by a third party to avoid improper distribution during this distress.
Page 1, 2 — Robert Berleth as the Receiver for Cyberlux (the "Receiver")... enter summary judgment in favor of TAG in the amount of $1,385,489.46
OMI-001
Omission
Absence of Claims Amounts for Other Parties
The motion identifies nine other competing claimant parties or groups but provides no information about the amounts they claim or the basis of their claims. This omission prevents assessment of whether TAG's $1.38M claim is the largest, and whether first or second priority would result in full or partial payment.
Page 1, 2 — TAG also addresses the claims made by The ARG Group, LLC ("ARG"), Legalist SPV III, LP ("Legalist"), Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively, "Atlantic Wave/Secure Community"), Advanced Navigation and Positioning Corp. ("ANPC"), Fairwinds Technologies, LLC ("Fairwinds"), Assure Global LLC d/b/a WeShield, Roman Investments PR, LLC, Mas USA MGT, LLC and Michael Sinesky (all collectively, the "WeShield Group"), the USA/IRS, Cyberlux Corporation ("Cyberlux"), and Robert Berleth as the Receiver for Cyberlux (the "Receiver")
OMI-002
Omission
No Explanation of Claim Basis
The motion does not explain the factual or legal basis for TAG's $1,385,489.46 claim. Whether this represents an unpaid contract amount, damages award, secured debt, or other obligation is not disclosed in the procedural motion itself.
Page 2 — enter summary judgment in favor of TAG in the amount of $1,385,489.46, plus all attorneys' fees and costs incurred in this action
Extracted text
3 pages · 2986 charactersFiling 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-483
)
v.
)
)
CYBERLUX CORP., et al.,
) )
Defendants.
)
)
THIN AIR GEAR, LLC'S MOTION FOR SUMMARY JUDGMENT
In accordance with Federal Rule of Civil Procedure 56, Local Civil Rule 56, and the Court's March 31, 2026 Order (ECF 158), Thin Air Gear, LLC ("TAG"), by and through its undersigned counsel of record, respectfully submits this Motion for Summary Judgment (the "Motion"). In support of this Motion, TAG submits its Memorandum of Law and Declaration of Anthony R. Gonzalez with attached Exhibits (Exhibit A to the Memorandum).
In accordance with the Court's Order to address the "priority of the party's claim to the Disputed Funds as compared to other parties' claims" and "where each party falls in order of priority or entitlement" (ECF 158 at 1-2), in its Memorandum of Law, TAG also addresses the claims made by The ARG Group, LLC ("ARG"), Legalist SPV III, LP ("Legalist"), Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively, "Atlantic Wave/Secure Community"), Advanced Navigation and Positioning Corp. ("ANPC"), Fairwinds Technologies, LLC ("Fairwinds"), Assure Global LLC d/b/a WeShield, Roman Investments PR, LLC, Mas USA MGT, LLC and Michael Sinesky (all collectively, the "WeShield Group"), the USA/IRS, Cyberlux Corporation ("Cyberlux"), and Robert Berleth as the
Receiver for Cyberlux (the "Receiver").
WHEREFORE, the Court should grant this Motion, enter summary judgment in favor of TAG in the amount of $1,385,489.46, plus all attorneys' fees and costs incurred in this action and post-judgment compound interest at 8% from the date of judgment until the judgment is fully satisfied, and order that TAG be paid first or second from the interpleaded funds.
Dated:
April 15, 2026
Respectfully submitted, /s/ Stephen J. Stine, Esq. Stephen J. Stine, Esq. (VSB# 66738) Stephen L. Neal, Jr., Esq. (VSB# 87064) THE STINE LAW FIRM, PLLC 3900 Jermantown Rd., Suite 300 Fairfax, VA 22030-4900 Office Phone: 703.934-4647, Ext. 326 Cell Phone: (703) 501-5366 Fax: (703) 991-6559 Email: stine@stinelaw.com sneal@stinelaw.com
Counsel for Thin Air Gear, LLC
CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of April, 2026, a true and correct copy of the foregoing was served via CM/ECF, upon all counsel of record.
/s/ Stephen J. Stine, Esq. Stephen J. Stine, Esq. (VSB# 66738) Stephen L. Neal, Jr., Esq. (VSB# 87064) THE STINE LAW FIRM, PLLC 3900 Jermantown Rd., Suite 300 Fairfax, VA 22030-4900 Office Phone: 703.934-4647, Ext. 326 Cell Phone: (703) 501-5366 Fax: (703) 991-6559
Email: stine@stinelaw.com sneal@stinelaw.com
Counsel for Thin Air Gear, LLC
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