Evidence Record

Exhibit 27

In accordance with Federal Rules of Civil Procedure 33 and 34 and the Court's February 19, 2026 Order entering the Joint Discovery Plan (ECF 149), Intervenor/Claimant Thin Air Gear, LLC ("TAG"), by and through...

Type
exhibit
Court
EDVA
Case
HII v. Cyberlux interpleader
Docket
3:25-cv-00483
Pages
7
Lines
171
SHA-256
3bd2104bfe67

DISTIL analysis

DISTIL Run
Profile
Standard
Version
1
Doc Type
Legal Filing - Discovery Response
Total Nodes
32
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 Filing - Discovery Response Thin Air Gear, LLC via counsel Stephen L. Neal, Jr., Esq. Federal civil litigation, interpleader action concerning contract dispute proceeds 2023-09-05 to 2026-03-29
monetary_judgmenttreble_damagesdefault_judgmentmulti_district_litigationattorney_fee_claim
Analytical Frame
Contract breach, judgment enforcement, and priority claims in interpleader proceedings
Analytical Summary
This discovery response documents Thin Air Gear LLC's claim to interpleaded funds arising from a breach of contract by Cyberlux Corporation. TAG contracted to produce 2,100 wheeled drone kit bags for $887,900, delivered the goods, but received only partial payment. After Cyberlux failed to respond to demands or defend litigation, TAG obtained a default judgment in Colorado federal court for $1,224,275.14 including treble damages under Colorado civil theft law. TAG now asserts a secured claim to $1,385,489.46 plus ongoing fees and interest from funds held in this Virginia interpleader action, establishing priority dates of August 29, 2025 (initial judgment) or December 19, 2025 (certified judgment). The response reveals coordinated legal strategy across multiple jurisdictions to enforce a substantial judgment against a non-responsive defendant.
Key Points
  • TAG contracted with Cyberlux on September 5, 2023 to produce 2,100 drone kit bags for $887,900
  • TAG delivered 1,722 bags to Cyberlux's Texas warehouse; 378 bags retained pending payment
  • Cyberlux paid $150,000 deposit but failed to pay remaining $365,049.42 balance despite demands
  • TAG obtained Colorado default judgment on August 29, 2025 for $1,224,275.14 including treble damages under civil theft statute
  • TAG claims total of $1,385,489.46 plus fees from interpleaded funds, with priority dating to August or December 2025
  • Colorado law provides 8% pre-judgment simple interest and 8% post-judgment compound interest
Stage 2
Core — Entities, Events, Claims
19 nodes
ENT-001
Entity
Thin Air Gear, LLC (TAG)
Intervenor/Claimant in the interpleader action, manufacturer of drone kit bags under contract with Cyberlux, represented by The Stine Law Firm, PLLC
Page 2 — Intervenor/Claimant Thin Air Gear, LLC ("TAG"), by and through its undersigned counsel of record
ENT-002
Entity
Cyberlux Corporation / Catalyst Machineworks
Defendant entity that contracted with TAG for drone bag production; Catalyst Machineworks, LLC identified as wholly owned subsidiary of Cyberlux Corporation; failed to pay contract balance and defaulted in Colorado litigation
Page 3 — Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux Corporation (collectively, "Cyberlux")
ENT-003
Entity
HII Mission Technologies Corp.
Plaintiff in the interpleader action; had Subcontract with Cyberlux that is the subject of the Amended Complaint
Page 3 — the Subcontract (the "Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is the subject of HII's First Amended Complaint for Interpleader
ENT-004
Entity
Stephen L. Neal, Jr., Esq. and Stephen J. Stine, Esq.
Attorneys representing Thin Air Gear, LLC from The Stine Law Firm, PLLC in Fairfax, Virginia
Page 6, 7 — 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
Contract Execution (September 5, 2023)
Cyberlux entered into contract with TAG to produce 2,100 wheeled drone kit bags for total price of $887,900.00
Page 3 — on September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). [...] The total agreed contract price for the Contract was $887,900.00.
EVT-002
Event
Deposit Payment (September 14, 2023)
Cyberlux paid deposit of $150,000 toward the contract
Page 3 — Cyberlux paid a deposit of $150,000 on September 14, 2023.
EVT-003
Event
Contract Performance by TAG
TAG produced and assembled all 2,100 drone kit bags pursuant to the Contract; delivered 1,722 bags to Cyberlux's warehouse in Spring, Texas; retained 378 bags pending final payment
Page 3 — TAG produced and assembled all 2,100 drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG pending final payment on the Contract.
EVT-004
Event
Balance Due Calculation (November 18, 2024)
As of November 18, 2024, the balance due including 1.5% monthly late fee on past due amounts totaled $365,049.42
Page 3 — As of November 18, 2024, the balance due, including a 1.5% late fee per month on past due amounts, was $365,049.42.
EVT-005
Event
Payment Demands and Non-Response
TAG sent multiple demands to Cyberlux for payment of remaining balance but received no response to any demands
Page 3 — TAG sent multiple demands to Cyberlux for payment of the remaining balance, but received no response to any of these demands.
EVT-006
Event
Colorado Action Filed (March 12, 2025)
TAG filed diversity action against Cyberlux in U.S. District Court for District of Colorado, Case No. 1:25-cv-00805, alleging breach of contract, unjust enrichment, and civil theft under Colorado law
Page 3, 4 — Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case No. 1:25-cv-00805 (the "Colorado Action"), alleging breach of contract, unjust enrichment, and civil theft under Colorado law, which provides for treble damages, attorneys' fees, and costs if TAG prevailed in the Colorado Action.
EVT-007
Event
Cyberlux Default in Colorado Action
Cyberlux was properly served with complaint in Colorado Action but refused or failed to file answer or otherwise respond
Page 4 — Although Cyberlux was properly served with the complaint in the Colorado Action, Cyberlux refused or failed to file an answer or otherwise respond to the complaint.
EVT-008
Event
Final Judgment Entered (August 29, 2025)
Colorado District Court granted TAG's motion for default judgment and entered Final Judgment against Cyberlux for $1,224,275.14, consisting of treble damages ($1,220,838.54), attorneys' fees ($2,765.00), and costs ($671.60)
Page 4 — Accordingly, TAG moved for entry of default judgment against Cyberlux. On August 29, 2025, that motion was granted and Final Judgment was entered against Cyberlux in the total amount of $1,224,275.14 (the "Final Judgment"), which consisted of treble damages in the amount of $1,220,838.54, attorneys' fees in the amount of $2,765.00, and costs in the amount of $671.60.
EVT-009
Event
Certified Final Judgment (December 19, 2025)
The Final Judgment was Certified on December 19, 2025
Page 4 — The Final Judgment was Certified on December 19, 2025 (the "Certified Final Judgment").
EVT-010
Event
Discovery Response Filed (March 9, 2026)
TAG filed objections and responses to interrogatory and document requests in the Virginia interpleader action
Page 2 — In accordance with Federal Rules of Civil Procedure 33 and 34 and the Court's February 19, 2026 Order entering the Joint Discovery Plan (ECF 149), Intervenor/Claimant Thin Air Gear, LLC ("TAG"), by and through its undersigned counsel of record, respectfully submits these Objections and Responses to the 1 Interrogatory and 2 Document Requests
CLM-001
Claim
TAG's Total Claim Amount
TAG seeks $1,385,489.46 plus all attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8% incurred after March 29, 2026, from the interpleaded funds
Page 4 — With respect to 1(a), through March 29, 2026, TAG seeks $1,385,489.46 plus all attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8% that is incurred after March 29, 2026, from the interpleaded funds.
CLM-002
Claim
Material Breach by Cyberlux
Cyberlux was in material breach of the Contract by failing to pay the remaining balance despite multiple demands from TAG
Page 3, 4 — Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed a diversity action against Cyberlux
CLM-003
Claim
Calculation Breakdown of Total Claim
The $1,385,489.46 total consists of: (1) $1,224,275.14 for Final Judgment/Certified Final Judgment; (2) $97,941.93 in pre-judgment simple interest at 8% from date of breach until August 29, 2025; (3) $63,272.39 in post-judgment compound interest at 8% from August 29, 2025 through March 29, 2026
Page 4 — This sum is calculated as follows: (1) $1,224,275.14 for the Final Judgment/Certified Final Judgment; (2) $97,941.93 in pre-judgment simple interest at 8% from the date of breach of the Contract until the Final Judgment was entered on August 29, 2025; $63,272.39 in post-judgment compound interest at 8% from August 29, 2025 through March 29, 2026.
CLM-004
Claim
Security Interest and Lien Basis
Based upon Final Judgment and Certified Final Judgment, TAG claims security interest in and lien on the claimed amount from interpleaded funds with priority date of August 29, 2025 (initial judgment entry) or at worst December 19, 2025 (certified judgment)
Page 5 — With respect to 1(d), based upon the Final Judgment and the Certified Final Judgment, through March 29, 2026, TAG claims a security interest in and lien on $1,385,489.46 plus all attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8% that is incurred after March 29, 2026, from the interpleaded funds. The claimed priority date for the Final Judgment is August 29, 2025, when the Final Judgment was first entered in the Colorado Action. At worst, the claimed priority date is December 19, 2025, when the Certified Final Judgment was Certified in the Colorado Action.
CLM-005
Claim
Attorney's Fees and Costs Claim
Under C.R.S. § 18-4-405, TAG has right to all attorneys' fees and costs incurred in this action; to date estimated to exceed $50,000 and continuing to mount
Page 5 — With respect to 1(f), in accordance with C.R.S. § 18-4-405, TAG has a right to all attorneys' fees and costs incurred in this action. To date, the attorneys' fees and costs that TAG has incurred are estimated to exceed $50,000 and continue to mount.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
7 nodes
QUO-001
Quotation
Colorado Law Interest Provisions
Under governing Colorado law, TAG is entitled to pre-judgment simple interest at 8% from date of breach until judgment entry, and post-judgment compound interest at 8% until judgment is satisfied
Page 5 — The basis for continuing accrual is that, under the governing Colorado law, TAG is entitled to pre-judgment simple interest at 8% from the date of the breach of the Contract until the date that the Final Judgment was entered on August 29, 2025. Under the governing Colorado law, TAG also is entitled to post-judgment compound interest at 8% until the Final Judgment/Certified Final Judgment is satisfied.
TLL-001
Tell
Partial Delivery and Retention Strategy
TAG delivered majority of goods (1,722 of 2,100 bags) to Cyberlux's warehouse but strategically retained 378 bags pending final payment, indicating leverage strategy
Page 3 — TAG then delivered 1,722 of the drone kit bags to Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG pending final payment on the Contract.
TLL-002
Tell
Complete Non-Engagement by Cyberlux
Pattern of complete non-response from Cyberlux: no response to payment demands, no response to complaint service, no answer or defense filed in Colorado litigation
Page 3, 4 — TAG sent multiple demands to Cyberlux for payment of the remaining balance, but received no response to any of these demands. Although Cyberlux was properly served with the complaint in the Colorado Action, Cyberlux refused or failed to file an answer or otherwise respond to the complaint.
TEN-001
Tension
Multi-Jurisdictional Enforcement Challenge
TAG obtained judgment in Colorado federal court but must now enforce through Virginia interpleader action, creating complexity around priority dates and jurisdictional recognition
Page 3, 4, 2 — on March 12, 2025, TAG filed a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case No. 1:25-cv-00805 [...] In accordance with Federal Rules of Civil Procedure 33 and 34 and the Court's February 19, 2026 Order entering the Joint Discovery Plan (ECF 149), Intervenor/Claimant Thin Air Gear, LLC ("TAG"), by and through its undersigned counsel of record, respectfully submits these Objections and Responses
TEN-002
Tension
Priority Date Ambiguity
TAG asserts two possible priority dates (August 29, 2025 vs. December 19, 2025) reflecting uncertainty about whether initial judgment entry or certification controls for lien priority purposes
Page 5 — The claimed priority date for the Final Judgment is August 29, 2025, when the Final Judgment was first entered in the Colorado Action. At worst, the claimed priority date is December 19, 2025, when the Certified Final Judgment was Certified in the Colorado Action.
QST-001
Question
Relationship Between HII Subcontract and TAG Contract
What is the precise relationship between the HII-Cyberlux Subcontract and the TAG-Cyberlux Contract? Were the drone bags TAG manufactured specifically for fulfillment of HII subcontract obligations?
Page 3 — These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the "Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is the subject of HII's First Amended Complaint for Interpleader
QST-002
Question
Competing Claims to Interpleaded Funds
What other parties are claiming the interpleaded funds, and what are the relative priorities of their claims versus TAG's judgment lien?
Page 2, 3 — the nature of TAG's claim to any of the proceeds that are the subject of this interpleader action [...] CYBERLUX CORP., et al., Defendants.
Stage 4
Interpretive — Inferences, Omissions, Patterns
6 nodes
INF-001
Inference
Strategic Forum Selection for Treble Damages
TAG likely filed in Colorado (rather than Virginia or Texas) specifically to access Colorado's civil theft statute providing treble damages, attorneys' fees, and costs
Page 3, 4 — TAG filed a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case No. 1:25-cv-00805 (the "Colorado Action"), alleging breach of contract, unjust enrichment, and civil theft under Colorado law, which provides for treble damages, attorneys' fees, and costs if TAG prevailed
INF-002
Inference
Cyberlux Corporate Dysfunction or Insolvency
Cyberlux's complete failure to respond to demands, litigation, or defend itself suggests either corporate collapse, insolvency, or deliberate abandonment of legal positions
Page 3, 4 — TAG sent multiple demands to Cyberlux for payment of the remaining balance, but received no response to any of these demands. Although Cyberlux was properly served with the complaint in the Colorado Action, Cyberlux refused or failed to file an answer or otherwise respond to the complaint.
INF-003
Inference
Interpleader as Asset Recovery Mechanism
The Virginia interpleader action appears to be holding funds that would otherwise have gone to Cyberlux, creating opportunity for creditors like TAG to recover against an unresponsive debtor
Page 2, 3 — the nature of TAG's claim to any of the proceeds that are the subject of this interpleader action [...] Plaintiff HII Mission Technologies Corp. ("HII") that is the subject of HII's First Amended Complaint for Interpleader
OMI-001
Omission
No Explanation for Cyberlux's Non-Response Pattern
Document provides no explanation or context for why Cyberlux failed to respond to any demands or litigation despite having received goods and being properly served
Page 3, 4 — TAG sent multiple demands to Cyberlux for payment of the remaining balance, but received no response to any of these demands. Although Cyberlux was properly served with the complaint in the Colorado Action, Cyberlux refused or failed to file an answer or otherwise respond
OMI-002
Omission
Amount of Interpleaded Funds Not Disclosed
Discovery response does not state the total amount of funds being held in the interpleader, making it unclear whether funds are sufficient to satisfy TAG's $1.4M+ claim
Page 4 — With respect to 1(a), through March 29, 2026, TAG seeks $1,385,489.46 plus all attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8% that is incurred after March 29, 2026, from the interpleaded funds.
OMI-003
Omission
No Details on Document Production
TAG's responses to document requests state willingness to produce but provide no specifics about what documents will be produced or when
Page 6 — Subject to, and without waiving, the forgoing Objection, TAG will produce responsive documents within its possession, custody, and/or control.

Extracted text

7 pages · 10221 characters

Exhibit 27 — Formatted Extract

Type: exhibit
Court: EDVA
Matter: HII v. Cyberlux interpleader
Docket: 3:25-cv-00483
EXHIBIT 27

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 OBJECTIONS AND RESPONSES TO INTERROGATORY AND DOCUMENT REQUESTS

In accordance with Federal Rules of Civil Procedure 33 and 34 and the Court's February 19, 2026 Order entering the Joint Discovery Plan (ECF 149), Intervenor/Claimant Thin Air Gear, LLC ("TAG"), by and through its undersigned counsel of record, respectfully submits these Objections and Responses to the 1 Interrogatory and 2 Document Requests (the "Request" or "Requests") set forth in the Joint Discovery Plan as follows:

INTERROGATORY 1: Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of: (a) the amount of the proceeds that you claim; (b) the legal basis for your right to the proceeds; (c) how the amount you claim became a liquidated amount or, if not liquidated, state so; (d) whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment; (e) whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any; (f) whether you claim a right to attorney's fees and, if so, the basis therefore and the amount you will claim; and (g) for any creditor claiming a secured interest, identify the

date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed.

OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this Interrogatory on the ground that it calls for the production of information and documents protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the "Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the "Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See ECF 41 at 11 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100 drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG pending final payment on the Contract. As of November 18, 2024, the balance due, including a 1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to Cyberlux for payment of the remaining balance, but received no response to any of these demands.

Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed

a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case No. 1:25-cv-00805 (the "Colorado Action"), alleging breach of contract, unjust enrichment, and civil theft under Colorado law, which provides for treble damages, attorneys' fees, and costs if TAG prevailed in the Colorado Action.

Although Cyberlux was properly served with the complaint in the Colorado Action, Cyberlux refused or failed to file an answer or otherwise respond to the complaint. Accordingly, TAG moved for entry of default judgment against Cyberlux. On August 29, 2025, that motion was granted and Final Judgment was entered against Cyberlux in the total amount of $1,224,275.14 (the "Final Judgment"), which consisted of treble damages in the amount of $1,220,838.54, attorneys' fees in the amount of $2,765.00, and costs in the amount of $671.60. The Final Judgment was Certified on December 19, 2025 (the "Certified Final Judgment").

With respect to the specific subparts of this Interrogatory, TAG states that:

With respect to 1(a), through March 29, 2026, TAG seeks $1,385,489.46 plus all attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8% that is incurred after March 29, 2026, from the interpleaded funds. This sum is calculated as follows: (1) $1,224,275.14 for the Final Judgment/Certified Final Judgment; (2) $97,941.93 in pre-judgment simple interest at 8% from the date of breach of the Contract until the Final Judgment was entered on August 29, 2025; $63,272.39 in post-judgment compound interest at 8% from August 29, 2025 through March 29, 2026.

With respect to 1(b), TAG's legal basis for its right to the proceeds is based upon the Final Judgment and Certified Final Judgment entered by the United States District Court in the Colorado Action.

With respect to 1(c), the amount TAG claims became a liquidated amount when the

United States District Court in the Colorado Action first entered Final Judgment on August 29, 2025, and then again when it Certified the Final Judgment on December 19, 2025.

With respect to 1(d), based upon the Final Judgment and the Certified Final Judgment, through March 29, 2026, TAG claims a security interest in and lien on $1,385,489.46 plus all attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8% that is incurred after March 29, 2026, from the interpleaded funds. The claimed priority date for the Final Judgment is August 29, 2025, when the Final Judgment was first entered in the Colorado Action. At worst, the claimed priority date is December 19, 2025, when the Certified Final Judgment was Certified in the Colorado Action.

With respect to 1(e), TAG claims a right to interest and the amount of claimed interest is set forth above. The basis for continuing accrual is that, under the governing Colorado law, TAG is entitled to pre-judgment simple interest at 8% from the date of the breach of the Contract until the date that the Final Judgment was entered on August 29, 2025. Under the governing Colorado law, TAG also is entitled to post-judgment compound interest at 8% until the Final Judgment/Certified Final Judgment is satisfied. TAG reserves the right to supplement this response as the case proceeds and additional post-judgment interest is incurred.

With respect to 1(f), in accordance with C.R.S. § 18-4-405, TAG has a right to all attorneys' fees and costs incurred in this action. To date, the attorneys' fees and costs that TAG has incurred are estimated to exceed $50,000 and continue to mount. If needed, TAG will submit Declaration(s) and supporting evidence to prove-up its attorneys' fees and costs at the appropriate time and in accordance with the governing Rules and/or Court Orders. TAG reserves the right to supplement this response as the case proceeds and additional attorneys' fees and costs are incurred.

With respect to 1(g), see response to 1(d), supra.

TAG reserves the right to amend and/or supplement this Response based upon the discovery of additional responsive information and/or documents.

DOCUMENT REQUEST 1: Documents supporting or otherwise concerning your answer to the above interrogatory.

OBJECTION AND RESPONSE TO DOCUMENT REQUEST 1: TAG objects to this Request on the ground that it calls for the production of information and documents protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and without waiving, the forgoing Objection, TAG will produce responsive documents within its possession, custody, and/or control.

DOCUMENT REQUEST 2: All documents on which you rely to assert any security interest in, lien on, or assignment of the proceeds that are the subject of this interpleader.

OBJECTION AND RESPONSE TO DOCUMENT REQUEST 2: TAG objects to this Request on the ground that it calls for the production of information and documents protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and without waiving, the forgoing Objection, TAG will produce responsive documents within its possession, custody, and/or control.

TAG reserves the right to amend and/or supplement these Responses based upon the discovery of additional responsive information and/or documents.

Dated: March 9, 2026

Respectfully submitted, /s/ Stephen L. Neal, Jr., 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 9th day of March, 2026, a true and correct copy of the foregoing was served via email upon all counsel of record.

/s/ Stephen L. Neal, Jr., 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

Original source file

No source file is attached yet. The record is ready for the PDF/media link when the attachment importer is connected.
File
ip-hii-edva-00483-doc-0175-exhibit-29.pdf
Source UID
source:3bd2104bfe67f28cdd269d4bdf3f061a930d944407ce643a7971e6c362341c65
Full SHA-256
3bd2104bfe67f28cdd269d4bdf3f061a930d944407ce643a7971e6c362341c65