Evidence Record
Declaration of David Keithly in Support of Opposition of Plaintiffs’ Opposition to Defendants’ Motion to Vacate Sister-State Judgment
1. I am an attorney licensed to practice law in the State of California and am a partner at the law firm Mortenson Taggart Adams LLP. I am one of the attorneys representing Plaintiffs...
DISTIL analysis
DISTIL Run
Profile
Standard
Version
1
Doc Type
Legal Declaration with Anonymous Intelligence Attachment
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 Declaration with Anonymous Intelligence Attachment David M. Keithly, Attorney for Plaintiffs Atlantic Wave Holdings LLC and Secure Community LLC Civil litigation - enforcement of sister-state judgment, defense contractor due diligence 2024-02-15 to 2024-05-20
anonymous_sourcefinancial_allegationsgovernment_contract_verificationcredibility_challenge
Analytical Frame
Legal opposition filing incorporating third-party anonymous intelligence regarding defendant's financial condition and business representations
Analytical Summary
Attorney David M. Keithly submits a declaration supporting plaintiffs' opposition to defendant Cyberlux Corporation's motion to vacate a sister-state judgment. The declaration details defense tactics including refusal to stipulate to dismissal of an incorrectly filed complaint, forcing plaintiffs to incur additional litigation expenses. Most significantly, Keithly attaches an anonymous email received April 26, 2024, from a purported defense industry advisor who conducted due diligence on Cyberlux for potential merger/acquisition. The anonymous source provides detailed allegations regarding Cyberlux's financial distress, misrepresentation of government contracts, lack of required federal licenses, and concerns about the legitimacy of claimed classified work and security clearances.
Key Points
- Defendant Cyberlux refused to stipulate to dismissal of incorrectly filed complaint, forcing additional litigation costs
- Anonymous email from purported defense industry advisor provides intelligence from due diligence investigation of Cyberlux
- Anonymous source alleges Cyberlux's $78.8M drone contract is actually a subcontract through HII Defense, not direct DOD contract
- Source claims Cyberlux lacks ATF licenses required for munitions/weapons work despite claims of 'special activities' group
- Dun & Bradstreet report allegedly shows significant unpaid debts, judgments, and liens including IRS and state tax authorities
- Anonymous source questions legitimacy of security clearances and classified work claims given financial and legal issues
Stage 2
Core — Entities, Events, Claims
18 nodes
ENT-001
Entity
David M. Keithly
Attorney licensed in California, partner at Mortenson Taggart Adams LLP, representing plaintiffs Atlantic Wave Holdings LLC and Secure Community LLC
Page 2 — I am an attorney licensed to practice law in the State of California and am a partner at the law firm Mortenson Taggart Adams LLP. I am one of the attorneys representing Plaintiffs Atlantic Wave Holdings, LLC and Secure Community, LLC
ENT-002
Entity
Atlantic Wave Holdings, LLC
Virginia limited liability company, plaintiff in case 3:24-cv-00482-RBM-VET against Cyberlux Corporation
Page 1 — ATLANTIC WAVE HOLDINGS, LLC, a Virginia limited liability company, and SECURE COMMUNITY, LLC, a Virginia limited Liability company, Plaintiffs
ENT-003
Entity
Secure Community, LLC
Virginia limited liability company, co-plaintiff with Atlantic Wave Holdings in case against Cyberlux Corporation
Page 1 — ATLANTIC WAVE HOLDINGS, LLC, a Virginia limited liability company, and SECURE COMMUNITY, LLC, a Virginia limited Liability company, Plaintiffs
ENT-004
Entity
Cyberlux Corporation
Nevada corporation, defendant in case 3:24-cv-00482-RBM-VET, subject of sister-state judgment enforcement action and anonymous due diligence investigation
Page 1 — CYBERLUX CORPORATION, a Nevada Corporation, Defendant
ENT-005
Entity
Anonymous Defense Industry Advisor
Unidentified individual claiming to advise a significant defense company that was approached by Cyberlux for potential partnership, conducted due diligence investigation
Page 5 — I am an advisor to a significant defense company which was recently approached by Cyberlux. The purpose of the approach was to discuss the potential of partnership (acquisition by, or merging into) with the company I advise.
ENT-006
Entity
HII Defense (Huntington Ingall Industries)
Defense contractor identified as prime contractor for drone contract, with Cyberlux allegedly serving as subcontractor
Page 3, 5 — The contract is in fact a SUBCONTRACT with HII Defense (Huntington Ingall Industries)
ENT-007
Entity
ADS (Atlantic Diving Supply)
Company that allegedly issued subcontract to Cyberlux for approximately $400k for commercial drone variants
Page 5 — An additional SUB contract was issued to Cyberlux by ADS (Atlantic Diving Supply) for approximately $400k for commercial variants of drones.
EVT-001
Event
Defendant Refusal to Stipulate Dismissal
On February 15, 2024, attorney Keithly contacted defendant's counsel requesting stipulation to dismiss incorrectly filed complaint in case 3:24-cv-00196-RBM-VET; defendants refused, compelling plaintiffs to file Rule 41 motion
Page 2 — On February 15, 2024, I contacted Defendants' counsel to request that Defendants stipulate to allow Plaintiffs to dismiss the Complaint that had been incorrectly filed by Plaintiffs' previous counsel in action currently pending before this court. (Case No: 3:24-cv-00196-RBM-VET.). Defendants refused to stipulate to the dismissal of the Complaint, thereby compelling Plaintiffs to incur unnecessary expenses and delays.
EVT-002
Event
Receipt of Anonymous Email
On April 26, 2024, attorney Keithly received anonymous email from purported defense industry advisor sharing due diligence findings on Cyberlux
Page 2 — On April 26, 2024, I received an anonymous email purporting to be from "an advisor to a significant defense company which was recently approached by Cyberlux ... to discuss the potential of partnership (acquisition by, or merging into) with the company I advise."
EVT-003
Event
Cyberlux Approach to Defense Company
Cyberlux approached an unidentified significant defense company to discuss potential partnership, acquisition, or merger, triggering due diligence investigation
Page 5 — I am an advisor to a significant defense company which was recently approached by Cyberlux. The purpose of the approach was to discuss the potential of partnership (acquisition by, or merging into) with the company I advise. We therefore conducted preliminary "lite" due diligence on Cyberlux.
EVT-004
Event
GSA Contract Cancellation
Government cancelled Cyberlux GSA contract GS-07F-9409S on November 2, 2020, though Cyberlux allegedly continues to advertise it on website
Page 5 — the GSA contract (contract GS-07F-9409S) which Cyberlux, to this day, advertises on their website was cancelled by the government on 11/2/2020. This can be verified in the files attached. search term "legal contract cancellation"
CLM-001
Claim
Drone Contract is Subcontract, Not Direct DOD Award
Anonymous source claims the alleged 'secret' contract for 2000 K8 drones at $39.4k per unit is actually a subcontract through HII Defense for Ukraine FMF case, not direct DOD contract with Cyberlux
Page 3, 5 — CYBERLUX is not currently a DIRECT supplier to the US DOD. The alleged "secret" contract for drones can be found through a recipient search at USASPENDING.GOV. The contract is for 2000 K8 drones with a per unit price of $39.4k including training. The contract is in fact a SUBCONTRACT with HII Defense (Huntington Ingall Industries). This is an FMF case for Ukraine.
CLM-002
Claim
Direct DOD Contracts Ceased in 2015
Anonymous source claims direct contracts between US Government and Cyberlux ceased in 2015, with attached files showing all government transactions
Page 5 — I have attached a series of files which show the all transactions between the US Government and Cyberlux. you will note that DIRECT contracts with Cyberlux ceased in 2015. The US government is required to make public all DOD contracts within 90 days of award.
CLM-003
Claim
Significant Unpaid Debts and Judgments
Anonymous source claims Dun & Bradstreet credit report from September 2023 revealed significant unpaid debts, judgments, and UCCs including to IRS, NC Tax Authority, Texas Tax Authority, and private lenders
Page 3, 5 — a Dun and Bradstreet credit report revealed significant unpaid debts, judgements, and UCC's including to the IRS, NC Tax Authority and the Texas Tax Authority as well as private lenders (Sep 2023)
CLM-004
Claim
Lack of Required ATF Licenses
Anonymous source claims neither Cyberlux nor its subsidiaries hold FFL or FEL licenses with ATF, making munitions and weapons work by 'special activities' group impossible, including concerns about fusing, detonators, and explosive payloads on X8 drone
Page 3, 6 — Neither Cyberlux, nor any of its subsidiaries hold FFL or FEL licenses with the ATF (atf.gov) The claims that the "special activities" group deals in munitions and weapons is impossible given the lack of ATF licenses. This concern extends to the fusing, detonators, and explosive payloads used on the X8 drone.
CLM-005
Claim
Special Activities Address is Real Estate Agent Office
Anonymous source claims address check of 'Special Activities' group in Q3 2023 revealed address is actually used by a real estate agent in Miami
Page 5 — An address check of the "Special Activities" group (3rd qtr 2023 report) revealed that this address is in fact an address used by a real estate agent in Miami.
CLM-006
Claim
Subsidiaries Not Registered with US Government
Anonymous source claims CMTC LLC and Catalyst Machine Works LLC are not registered with US Government at sam.gov and therefore have never been awarded contracts
Page 5, 6 — CMTC LLC is not registered with the US Government (sam.gov) and therefore has never been awarded contracts (verifiable at usaspending.gov) 8) Catalyst Machine Works LLC s not registered with the US Government (sam.gov) and therefore has never been awarded contracts (verifiable at usaspending.gov)
CLM-007
Claim
Bad Faith Litigation Tactics
Attorney Keithly asserts defendants' bad faith litigation tactics, including refusal to allow dismissal and attempts to delay judgment enforcement, have significantly increased complexity and cost
Page 2 — Defendants' bad faith litigation tactics, including their refusal to allow the dismissal of the incorrect Complaint and their attempts to delay enforcement of the judgment, have significantly increased the complexity and cost of this litigation for Plaintiffs. These tactics not only impede Plaintiffs' rightful collection efforts but also threaten the integrity of judicial proceedings.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
9 nodes
QUO-001
Quotation
Impending Insolvency and Poor Cash Management
Anonymous source asserts suspicion that $78.8M award was factored to provide working capital due to inadequate banking relationships
Page 3, 6 — We suspect that the 78.8m award was "factored" in order to provide working capital as the company appears to have inadequate banking relationships. This gives us the impression of impending insolvency and poor cash management.
QUO-002
Quotation
Dual Litigation Most Troubling Discovery
Anonymous source states the dual litigation between AWH and Cyberlux is perhaps the most troubling discovery as it damaged Mr Schmidt's credibility
Page 5 — During the course of that investigation several issues became known to us, including the dual litigation between AWH and Cyberlux. This action is perhaps the most troubling discovery as it damaged Mr Schmidt's credibility (misuse of funds, withholding information).
TEN-001
Tension
Cancelled GSA Contract Still Advertised
Tension between government cancellation of GSA contract on 11/2/2020 and Cyberlux allegedly continuing to advertise the contract on its website
Page 5 — the GSA contract (contract GS-07F-9409S) which Cyberlux, to this day, advertises on their website was cancelled by the government on 11/2/2020.
TEN-002
Tension
FMF Regulations vs. Commission Payment Commitment
Tension between FMF case regulations restricting payments to third parties for commissions and Cyberlux's alleged commitment to pay AWH $5k commission per drone to settle debt
Page 6 — FMF (foreign military funding) cases are highly regulated from a financial perspective. Most notably the use of funds awarded is auditable by the USG and restricts payments to third parties for commissions etc. Contracts may also include limitations on profits under both FAR and DFAR regulation. As such, we do not understand how Cyberlux could legally commit to paying AWH a $5k commission per drone sold to settle the debt.
TEN-003
Tension
Classified Work Claims vs. Open Assertions
Tension between strong public assertions in legal and financial documents about highly classified work and the contrary nature of how companies executing classified work typically behave
Page 6 — The strong assertions in legal and financial documents that the company is engaged in highly classified work was suspect. This open claim is contrary to the very nature of how companies who DO execute classified work behave.
QST-001
Question
Identity and Motivation of Anonymous Source
Anonymous email sender's identity, true relationship to defense industry, motivation for contacting plaintiffs' counsel, and reliability of provided intelligence remain unverified
Page 2, 5 — On April 26, 2024, I received an anonymous email purporting to be from "an advisor to a significant defense company which was recently approached by Cyberlux"
QST-002
Question
Verification of Attached Government Contract Data
Whether attached files showing government transactions with Cyberlux are authentic and whether claims about contract cessation in 2015 can be independently verified
Page 5 — I have attached a series of files which show the all transactions between the US Government and Cyberlux. you will note that DIRECT contracts with Cyberlux ceased in 2015.
QST-003
Question
Security Clearance and Facility Clearance Status
Whether Schmidt, Kalenja, or Cyberlux entities actually possess claimed DOD personal security clearances, facility clearances, or SCIFs given alleged financial and legal issues
Page 6 — Given the significant legal and financial issues we find that it is highly improbable that the US DOD has granted Mr Schmidt, or Mr Kalenja personal security clearances. 2) Given the significant legal and financial issues we find that it is highly improbable that the US DOD has granted Cyberlux or any of its subsidiaries Facility Clearances to execute "classified" contracts. We have been unable to verify that any facilities held by Cyberlux contain SCIFs.
QST-004
Question
Source of Funding for Acquisitions
How Cyberlux has acquired funding to execute purchases of Datron or Catalyst given alleged financial distress and inadequate banking relationships
Page 6 — We have been unable to confidently determine where Cyberlux has been acquiring its funding to execute the purchase of Datron or Catalyst.
Stage 4
Interpretive — Inferences, Omissions, Patterns
5 nodes
INF-001
Inference
Strategic Use of Anonymous Intelligence
Plaintiffs' attorney strategically incorporates anonymous third-party intelligence to support arguments about defendant's financial condition and credibility, providing external corroboration for claims beyond the parties' direct dispute
Page 2 — On April 26, 2024, I received an anonymous email purporting to be from "an advisor to a significant defense company which was recently approached by Cyberlux ... to discuss the potential of partnership"
INF-002
Inference
Pattern of Misrepresentation Allegation
Anonymous source's multiple claims about cancelled contracts still advertised, unregistered subsidiaries, and lack of licenses suggest pattern of potential misrepresentation regarding Cyberlux's government contracting capabilities
Page 5, 6 — the GSA contract (contract GS-07F-9409S) which Cyberlux, to this day, advertises on their website was cancelled by the government on 11/2/2020... CMTC LLC is not registered with the US Government (sam.gov) and therefore has never been awarded contracts... Neither Cyberlux, nor any of its subsidiaries hold FFL or FEL licenses with the ATF
INF-003
Inference
Litigation Strategy to Prevent Asset Dissipation
Plaintiffs' resistance to defendant's motion and emphasis on defendant's alleged asset shielding efforts suggests concern that judgment debtor may be attempting to frustrate collection through corporate restructuring
Page 6 — One legal filing by Mr Ozols asserted that Cyberlux was attempting to shield datron by "transferring, pledging, hypothecating, encumbering" the asset. A merger or acquisition between cyberlux and the company I advise would have made us party to this effort.
OMI-001
Omission
No Direct Response to Specific Due Diligence Claims
Declaration presents anonymous allegations but does not indicate whether plaintiffs have independently verified specific claims about ATF licenses, SAM.gov registrations, or contract status through public records
Page 5 — These elements are verifiable through public records... This can be verified in the files attached
OMI-002
Omission
Underlying Sister-State Judgment Details
Declaration focuses on opposition to vacation motion but provides minimal detail about the underlying sister-state judgment being enforced, its origin, or basis
Page 1 — DECLARATION OF DAVID KEITHLY IN SUPPORT OF OPPOSITION OF PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO VACATE SISTER-STATE JUDGMENT
Extracted text
6 pages · 11289 charactersFiling Header
David M. Keithly, State Bar No. 292101 dkeithly@mortensontaggart.com Sara K. Ross, State Bar No. 346153 sross@mortensontaggart.com
MORTENSON TAGGART ADAMS LLP 300 Spectrum Center Drive, Suite 1200 Irvine, California 92618 Telephone: (949) 774-2224 Facsimile: (949) 774-2545
Attorneys for Plaintiffs ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
ATLANTIC WAVE HOLDINGS, LLC, a Virginia limited liability company, and SECURE COMMUNITY, LLC, a Virginia limited Liability company, Plaintiffs, VS. CYBERLUX CORPORATION, a Nevada Corporation, Defendant.
CASE NO. 3:24-cv-00482-RBM-VET Honorable Ruth Bermudez Montenegro
Declaration
DECLARATION OF DAVID KEITHLY IN SUPPORT OF OPPOSITION OF PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO VACATE SISTER- STATE JUDGMENT
[Filed concurrently with Opposition to Motion to Vacate Sister-State Judgment, Declaration of William Welter and Declaration of James Sadigh]
DATE: June 3, 2024
NO ORAL ARGUMENT UNLESS ORDERED BY THE COURT
Case No. 3:24-cv-00196-RBM-VET
DECLARATION OF DAVID M. KEITHLY
DECLARATION OF DAVID M. KEITHLY
Declaration
I, David M. Keithly, declare as follows:
1.
I am an attorney licensed to practice law in the State of California and am a partner at the law firm Mortenson Taggart Adams LLP. I am one of the attorneys representing Plaintiffs Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively, "Plaintiffs") in this action. I have personal knowledge of the facts set forth herein and, if called upon as a witness, I could and would competently testify thereto.
2.
On February 15, 2024, I contacted Defendants' counsel to request that Defendants stipulate to allow Plaintiffs to dismiss the Complaint that had been incorrectly filed by Plaintiffs' previous counsel in action currently pending before this court. (Case No: 3:24-cv-00196-RBM-VET.). Defendants refused to stipulate to the dismissal of the Complaint, thereby compelling Plaintiffs to incur unnecessary expenses and delays.
3.
As a result of Defendants' refusal to stipulate to the dismissal of the incorrect Complaint, Plaintiffs were forced to file a motion to dismiss their own Complaint under Rule 41. This motion is now fully briefed and awaiting a decision. 4. Plaintiffs have filed a special motion to strike Defendants' amended counterclaims pursuant to California's anti-SLAPP statute. This motion is fully briefed and awaiting a decision that should dispose of Defendants' counterclaims.
5.
Defendants' bad faith litigation tactics, including their refusal to allow the dismissal of the incorrect Complaint and their attempts to delay enforcement of the judgment, have significantly increased the complexity and cost of this litigation for Plaintiffs. These tactics not only impede Plaintiffs' rightful collection efforts but also threaten the integrity of judicial proceedings.
6.
On April 26, 2024, I received an anonymous email purporting to be from "an advisor to a significant defense company which was recently approached by Cyberlux ... to discuss the potential of partnership (acquisition by, or merging into)
with the company I advise." A true and correct copy of this email is attached hereto as Exhibit A. The email shared information that it claimed was verifiable through public records, including, but not limited to:
a. "a Dun and Bradstreet credit report revealed significant unpaid debts, judgments, and UCC's including to the IRS, NC Tax Authority and the Texas Tax Authority as well as private lenders"
b. "CYBERLUX is not currently a DIRECT supplier to the US DOD. The alleged 'secret' contract for drones can be found through a recipient search at USASPENDING.GOV. The contract is for 2000 K8 drones with a per unit price of $39.4k including training. The contract is in fact a SUBCONTRACT with HII Defense (Huntington Ingall Industries)."
c. Neither Cyberlux, nor any of its subsidiaries hold FFL or FEL licenses with the ATF (atf.gov). The claims that the 'special activities' group deals in munitions and weapons is impossible given the lack of ATF licenses. The concern extends to the fusing, detonators, and explosive payloads used on the X8 drone."
d. "We suspect that the 78.8m award was 'factored' in order to provide working capital as the company appears to have inadequate banking relationships. This gives us the impression of impending insolvency and poor cash management."
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. This declaration was executed on May 20, 2024, at Irvine, California.
David M. Keithly
DECLARATION OF DAVID M. KEITHLY
Exhibit A
Monday, May 20, 2024 at 11:43:55 Pacific Daylight Time
Subject:
Cyberlux
Date:
Friday, April 26, 2024 at 3:37:27 PM Pacific Daylight Time
From:
To:
David M. Keithly, Sara Ross
Attachments: PrimeTransactionsAndSubawards_2024-04-13_H14M34S55768219.zip
CAUTION: This email originated from outside Mortenson Taggart Adams LLP. Exercise caution when opening attachments or clicking links, especially from unknown senders.
I am an advisor to a significant defense company which was recently approached by Cyberlux.
The purpose of the approach was to discuss the potential of partnership (acquisition by, or merging into) with the company I advise.
We therefore conducted preliminary "lite" due diligence on Cyberlux. During the course of that investigation several issues became known to us, including the dual litigation between AWH and Cyberlux. This action is perhaps the most troubling discovery as it damaged Mr Schmidt's credibility (misuse of funds, withholding information).
There are elements which I wish to share with you. These elements are verifiable through public records.
1)
CYBERLUX is not currently a DIRECT supplier to the US DOD. The alleged "secret" contract for drones can be found through a recipient search at USASPENDING.GOV. The contract is for 2000 K8 drones with a per unit price of $39.4k including training. The contract is in fact a SUBCONTRACT with HII Defense (Huntington Ingall Industries). This is an FMF case for Ukraine.
2)
An additional SUB contract was issued to Cyberlux by ADS (Atlantic Diving Supply) for approximately $400k for commercial variants of drones.
3)
I have attached a series of files which show the all transactions between the US Government and Cyberlux. you will note that DIRECT contracts with Cyberlux ceased in 2015. The US government is required to make public all DOD contracts within 90 days of award.
4)
the GSA contract (contract GS-07F-9409S) which Cyberlux, to this day, advertises on their website was cancelled by the government on 11/2/2020. This can be verified in the files attached. search term "legal contract cancellation"
5)
a Dun and Bradstreet credit report revealed significant unpaid debts, judgements, and UCC's including to the IRS, NC Tax Authority and the Texas Tax Authority as well as private lenders (Sep 2023)
6)
An address check of the "Special Activities" group (3rd qtr 2023 report) revealed that this address is in fact an address used by a real estate agent in Miami.
7)
CMTC LLC is not registered with the US Government (sam.gov) and therefore has never been awarded contracts (verifiable at usaspending.gov)
8)
Catalyst Machine Works LLC s not registered with the US Government (sam.gov)
and therefore has never been awarded contracts (verifiable at usaspending.gov)
9)
Neither Cyberlux, nor any of its subsidiaries hold FFL or FEL licenses with the ATF (atf.gov) The claims that the "special activities" group deals in munitions and weapons is impossible given the lack of ATF licenses. This concern extends to the fusing, detonators, and explosive payloads used on the X8 drone.
Conclusions we reached based on these factual elements
1)
Given the significant legal and financial issues we find that it is highly improbable that the US DOD has granted Mr Schmidt, or Mr Kalenja personal security clearances.
2)
Given the significant legal and financial issues we find that it is highly improbable that the US DOD has granted Cyberlux or any of its subsidiaries Facility Clearances to execute "classified" contracts. We have been unable to verify that any facilities held by Cyberlux contain SCIFs.
3)
Given the past performance history and significant legal, credibility and financial issues we find that is it highly unlikely the DOD would do any DIRECT business with Cyberlux.
4)
We suspect that the 78.8m award was "factored" in order to provide working capital as the company appears to have inadequate banking relationships. This gives us the impression of impending insolvency and poor cash management.
5)
FMF (foreign military funding) cases are highly regulated from a financial perspective. Most notably the use of funds awarded is auditable by the USG and restricts payments to third parties for commissions etc. Contracts may also include limitations on profits under both FAR and DFAR regulation. As such, we do not understand how Cyberlux could legally commit to paying AWH a $5k commission per drone sold to settle the debt.
6)
The manner in which this contract was developed and awarded is suspicious to us. Further feedback from a customer served to, at a minimum, support our concerns. This particular award is part of a highly publicized aid package to Ukraine.
7)
It is not within the normal behavior of the government to classify contract documents (purchase orders, performance contracts etc). Generally the WORK/PRODUCT is classified.
8)
We have been unable to confidently determine where Cyberlux has been acquiring its funding to execute the purchase of Datron or Catalyst.
9)
CMTC appears to have been a shell company started by Mr Watts
10)
The strong assertions in legal and financial documents that the company is engaged in highly classified work was suspect. This open claim is contrary to the very nature of how companies who DO execute classified work behave.
11)
The inconsistencies identified after finer review of the legal narrative seems to imply that Cyberlux's legal team is not being told the truth.
12)
One legal filing by Mr Ozols asserted that Cyberlux was attempting to shield datron by "transferring, pledging, hypothecating, encumbering" the asset. A merger or acquisition between cyberlux and the company I advise would have made us party to this effort. This would have a negative effect on our company's reputation and standing.
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
- aw-awh-sdcal-00482-doc-012-attachment-1.pdf
- Source UID
- source:154912720f7dbecb6bb2b6af238fca84f63be0bb3bbbeca6835be2966154bbd1
- Full SHA-256
- 154912720f7dbecb6bb2b6af238fca84f63be0bb3bbbeca6835be2966154bbd1