Evidence Record

Exhibit 34

WeShield: $3,905,541.64 Roman: $576,436.03 MAS: $215,062.95 Sinensky: $310,097.79

Type
exhibit
Court
EDVA
Case
HII v. Cyberlux interpleader
Docket
3:25-cv-00483
Pages
2
Lines
77
SHA-256
5d9c9e87fc12

DISTIL analysis

DISTIL Run
Profile
Standard
Version
1
Doc Type
court_exhibit_creditor_priority_statement
Total Nodes
29
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
court_exhibit_creditor_priority_statement Legalist civil_litigation_receivership 2017-08-21 to 2026-03-20
secured_creditor_positioningpriority_disputemultiple_creditorsgovernment_claim_present
Analytical Frame
creditor_rights_priority_dispute
Analytical Summary
This exhibit presents Legalist's formal position on creditor priority in case 3:25-cv-00483-JAG, filed April 15, 2026. Legalist claims secured creditor status with an April 1, 2024 priority date for $13,608,702.73. The document catalogs eleven other claimants including the United States Government (secured, various dates, $1,149,776.34 total), four confessed judgment debtors (secured, October 2025, totaling approximately $5,007,138.41), ANPC (secured, October 24, 2025, $3,087,878.86), Atlantic Wave/Secured Community (secured, March 20, 2026, $6,025,603.42), and four unsecured creditors totaling over $18.9 million. Legalist strategically reserves the right to challenge other claims if summary judgment is denied, while currently accepting their assertions at face value because none present facts that would establish priority over Legalist's position.
Key Points
  • Legalist asserts secured creditor status with $13,608,702.73 claim and April 1, 2024 priority date
  • Eleven other creditors listed with claims totaling approximately $30+ million
  • United States Government holds secured claims totaling $1,149,776.34 with earliest priority date of August 21, 2017
  • Four confessed judgment debtors hold secured positions dated October 23-24, 2025
  • Legalist conditionally accepts other creditors' claims while preserving right to challenge if summary judgment denied
Stage 2
Core — Entities, Events, Claims
20 nodes
ENT-001
Entity
Legalist
Legalist, secured creditor claiming $13,608,702.73 with April 1, 2024 priority date
Page 2 — Legalist Secured April 1, 2024 $13,608,702.73
ENT-002
Entity
United States Government
United States Government, secured creditor with multiple claims totaling $1,149,776.34, earliest priority August 21, 2017
Page 2 — United States Government Secured August 21, 2017 October 10, 2023 $40,755.31 $2,617.01 October 10, 2023 April 30, 2024 April 30, 2024 $320.48 $358.73 $87,188.95 April 30, 2024 $149,003.11 April 30, 2024 $869,532.75 $1,149,776.34 (total)
ENT-003
Entity
WeShield
WeShield, confessed judgment debtor with secured claim of $3,905,541.64, October 23, 2025 priority
Page 2 — Confessed Judgment Debtors Secured October 23, 2025 WeShield: $3,905,541.64
ENT-004
Entity
Roman
Roman, confessed judgment debtor with secured claim of $576,436.03, October 23, 2025 priority
Page 2 — Confessed Judgment Debtors Secured October 23, 2025 Roman: $576,436.03
ENT-005
Entity
MAS
MAS, confessed judgment debtor with secured claim of $215,062.95, October 23, 2025 priority
Page 2 — Confessed Judgment Debtors Secured October 23, 2025 MAS: $215,062.95
ENT-006
Entity
Sinensky
Sinensky, confessed judgment debtor with secured claim of $310,097.79, October 23, 2025 priority
Page 2 — Confessed Judgment Debtors Secured October 23, 2025 Sinensky: $310,097.79
ENT-007
Entity
ANPC
ANPC, secured creditor claiming $3,087,878.86 with October 24, 2025 priority date
Page 2 — ANPC Secured October 24, 2025 $3,087,878,86
ENT-008
Entity
Atlantic Wave/Secured Community
Atlantic Wave/Secured Community, secured creditor claiming $6,025,603.42 with March 20, 2026 priority date
Page 2 — Atlantic Wave / Secured Community Secured March 20, 2026 $6,025,603.42
ENT-009
Entity
Thin Air Gear
Thin Air Gear, unsecured creditor claiming $1,385,489.46
Page 2 — Thin Air Gear Unsecured n/a $1,385,489.46
ENT-010
Entity
Fairwinds Technologies
Fairwinds Technologies, unsecured creditor claiming $2,348,542.00
Page 2 — Fairwinds Technologies Unsecured n/a $2,348,542.00
ENT-011
Entity
ARG Group, LLC
ARG Group, LLC, unsecured creditor claiming $14,118,618.61
Page 2 — ARG Group, LLC Unsecured n/a $14,118,618.61
ENT-012
Entity
Receiver
Receiver, unsecured party with no specified claim amount
Page 2 — Receiver Unsecured n/a n/a
ENT-013
Entity
Maadarani
Maadarani, unsecured creditor with motion to intervene pending, claiming $1,062,576.98
Page 2 — Maadarani (motion to intervene pending) Unsecured n/a $1,062,576.98
EVT-001
Event
Document filing April 15, 2026
Case document 175-36 filed in case 3:25-cv-00483-JAG on April 15, 2026
Page 1, 2 — Case 3:25-cv-00483-JAG Document 175-36 Filed 04/15/26
CLM-001
Claim
Legalist secured claim $13.6M
Legalist claims secured creditor status for $13,608,702.73 with April 1, 2024 priority date
Page 2 — Legalist Secured April 1, 2024 $13,608,702.73
CLM-002
Claim
US Government secured claims total
United States Government claims secured creditor status for multiple obligations totaling $1,149,776.34 with priority dates ranging from August 21, 2017 to April 30, 2024
Page 2 — United States Government Secured August 21, 2017 October 10, 2023 $40,755.31 $2,617.01 October 10, 2023 April 30, 2024 April 30, 2024 $320.48 $358.73 $87,188.95 April 30, 2024 $149,003.11 April 30, 2024 $869,532.75 $1,149,776.34 (total)
CLM-003
Claim
Confessed judgment debtors secured claims
Four confessed judgment debtors claim secured status with October 23, 2025 priority: WeShield ($3,905,541.64), Roman ($576,436.03), MAS ($215,062.95), Sinensky ($310,097.79)
Page 2 — Confessed Judgment Debtors Secured October 23, 2025 WeShield: $3,905,541.64 Roman: $576,436.03 MAS: $215,062.95 Sinensky: $310,097.79
CLM-004
Claim
ANPC secured claim
ANPC claims secured creditor status for $3,087,878.86 with October 24, 2025 priority date
Page 2 — ANPC Secured October 24, 2025 $3,087,878,86
CLM-005
Claim
Atlantic Wave secured claim
Atlantic Wave/Secured Community claims secured creditor status for $6,025,603.42 with March 20, 2026 priority date
Page 2 — Atlantic Wave / Secured Community Secured March 20, 2026 $6,025,603.42
CLM-006
Claim
Unsecured creditor claims totaling $18.9M
Four unsecured creditors claim amounts: Thin Air Gear ($1,385,489.46), Fairwinds Technologies ($2,348,542.00), ARG Group LLC ($14,118,618.61), Maadarani ($1,062,576.98 with pending motion to intervene)
Page 2 — Thin Air Gear Unsecured n/a $1,385,489.46 Fairwinds Technologies Unsecured n/a $2,348,542.00 ARG Group, LLC Unsecured n/a $14,118,618.61 Maadarani (motion to intervene pending) Unsecured n/a $1,062,576.98
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
5 nodes
TEN-001
Tension
Priority date conflict: US Government vs Legalist
United States Government holds earliest secured priority date (August 21, 2017) versus Legalist's April 1, 2024 priority, creating potential priority conflict despite Legalist's larger claim amount
Page 2 — Legalist Secured April 1, 2024 $13,608,702.73 United States Government Secured August 21, 2017
TEN-002
Tension
Secured vs unsecured creditor divide
Clear division between secured creditors (Legalist, US Government, confessed judgment debtors, ANPC, Atlantic Wave) and unsecured creditors (Thin Air Gear, Fairwinds, ARG Group, Maadarani), with unsecured claims totaling approximately $18.9M but lacking security priority
Page 2 — Thin Air Gear Unsecured n/a $1,385,489.46 Fairwinds Technologies Unsecured n/a $2,348,542.00 ARG Group, LLC Unsecured n/a $14,118,618.61
QST-001
Question
Basis for Legalist priority over US Government
What is the legal or factual basis for Legalist's assertion of priority over United States Government claims when the Government holds secured status with a priority date of August 21, 2017, approximately 6.5 years earlier than Legalist's April 1, 2024 priority date?
Page 2 — Legalist Secured April 1, 2024 $13,608,702.73 United States Government Secured August 21, 2017
QST-002
Question
Confessed judgment security mechanism
What security mechanism or legal basis allows the four confessed judgment debtors (WeShield, Roman, MAS, Sinensky) to claim secured creditor status with October 2025 priority dates?
Page 2 — Confessed Judgment Debtors Secured October 23, 2025
QST-003
Question
Maadarani intervention status impact
How will the resolution of Maadarani's pending motion to intervene affect the creditor priority analysis and potential recovery for other creditors?
Page 2 — Maadarani (motion to intervene pending) Unsecured n/a $1,062,576.98
Stage 4
Interpretive — Inferences, Omissions, Patterns
4 nodes
INF-001
Inference
Strategic conditional acceptance
Legalist's stated position of accepting other creditors' claims 'at face value' while reserving rights to challenge if summary judgment denied represents strategic litigation posture: minimizing current disputes to focus on establishing own priority while preserving future challenge options
Page 2 — For this motion, Legalist takes the claims of the other creditors at face value and does not question the non-contradicted facts they have provided, because no other creditor has presented material facts that would entitle it to payment ahead of Legalist. If the Court denies summary judgment to Legalist, Legalist reserves all rights to challenge the factual or legal basis for these claims later.
INF-002
Inference
Legalist priority assertion basis
Legalist's assertion that 'no other creditor has presented material facts that would entitle it to payment ahead of Legalist' implies argument based on security interest strength or contractual priority rather than chronological priority date, given US Government's earlier 2017 priority date
Page 2 — because no other creditor has presented material facts that would entitle it to payment ahead of Legalist
OMI-001
Omission
Missing underlying debt details
The table provides claim amounts and priority dates but omits description of the underlying transactions, security interests, or legal basis for each creditor's claim, making independent verification of priority assertions impossible from this exhibit alone
Page 2 — LEGALIST'S POSITION ON ALL PARTIES PRIORITY
OMI-002
Omission
No debtor identification
Document does not identify the debtor(s) against whom these claims are asserted, though context suggests receivership proceeding with common debtor entity or entities
Page 2 — LEGALIST'S POSITION ON ALL PARTIES PRIORITY

Extracted text

2 pages · 1452 characters

Exhibit 34 — Formatted Extract

Type: exhibit
Court: EDVA
Matter: HII v. Cyberlux interpleader
Docket: 3:25-cv-00483
EXHIBIT 34

Filed 04/15/26

LEGALIST'S POSITION ON ALL PARTIES PRIORITY1

Claimant(s)

Security

Claimed Priority Date (if applicable)

Amount Claimed

Legalist

Secured

April 1, 2024

$13,608,702.73

United States Government

Secured

August 21, 2017 October 10, 2023

$40,755.31

$2,617.01

October 10, 2023 April 30, 2024 April 30, 2024

$320.48

$358.73

$87,188.95

April 30, 2024

$149,003.11

April 30, 2024

$869,532.75 $1,149,776.34 (total)

Confessed Judgment Debtors

Secured

October 23, 2025

WeShield: $3,905,541.64 Roman: $576,436.03 MAS: $215,062.95 Sinensky: $310,097.79

ANPC

Secured

October 24, 2025

$3,087,878,86

Atlantic Wave / Secured Community

Secured

March 20, 2026

$6,025,603.42

Thin Air Gear

Unsecured

n/a

$1,385,489.46

Fairwinds Technologies

Unsecured

n/a

$2,348,542.00

ARG Group, LLC

Unsecured

n/a

$14,118,618.61

Receiver

Unsecured

n/a

n/a

Maadarani (motion to intervene pending)

Unsecured

n/a

$1,062,576.98

" For this motion, Legalist takes the claims of the other creditors at face value and does not question the non-contradicted facts they have provided, because no other creditor has presented material facts that would entitle it to payment ahead of Legalist. If the Court denies summary judgment to Legalist, Legalist reserves all rights to challenge the factual or legal basis for these claims later.

Original source file

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File
ip-hii-edva-00483-doc-0175-exhibit-36.pdf
Source UID
source:5d9c9e87fc12d0012443e3dee6d43bdb373f14f7a9e8cb85ba54c37ca455c1ce
Full SHA-256
5d9c9e87fc12d0012443e3dee6d43bdb373f14f7a9e8cb85ba54c37ca455c1ce