Evidence Record

Exhibit 4

1. Applicants are judgment creditors of Cyberlux pursuant to the Amended Final Order and Judgment signed on June 28, 2023, which sets forth an award of $1,572,500 "as agreed to by the parties pursuant...

Type: exhibit
Pages: 10
Lines: 365
SHA-256: ce75eecd6d73

DISTIL analysis

DISTIL Run

Profile

Standard

Version

Doc Type

Court Order - Receivership Appointment

Total Nodes

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 Order - Receivership Appointment Harris County District Court, 129th Judicial District Post-judgment collection proceedings; Turnover application; Receivership 2023-06-28 to 2025-06-05

partial_grantreceiver_appointedasset_turnover_ordereddiscovery_compliance_ordered

Analytical Frame

Judgment enforcement, creditor remedies, asset recovery

Analytical Summary

On January 17, 2025, the 129th District Court of Harris County granted in part and denied in part a turnover application by judgment creditors Atlantic Wave Holdings LLC and Secure Community LLC against Cyberlux Corporation, while denying the application against individual defendant Mark Schmidt. The Court appointed Robert W. Berleth as Receiver to aid collection of an amended final judgment originally totaling $1,572,500 plus costs and sanctions, with an outstanding balance of $848,363.37 as of October 31, 2024. The Receivership Property is narrowly defined to include Cyberlux's interests in two facilities (Catalyst MachineWorks in Spring, TX and Datron World Communications in Vista, CA), but explicitly excludes physical property at those locations due to insufficient proof of Cyberlux's interest. Cyberlux is ordered to turn over specified financial documents within 14 days and discovery responses within 30 days, and to deliver checks, cash, securities, and other financial instruments within 10 days, with ongoing turnover obligations for newly received property.

Key Points

Receiver appointed with limited scope over Cyberlux's interests in two facilities, excluding physical property at those locations
Outstanding judgment balance of $848,363.37 as of October 31, 2024, arising from $1,572,500 principal award
Turnover obligations imposed on Cyberlux with specific timelines: 14 days for documents, 10 days for financial instruments, 30 days for discovery responses
Application denied as to defendant Mark Schmidt individually
Court approval required for all sales of Receivership Property
Receiver authorized to seek 25% contingency fee plus expenses, subject to court approval

Stage 2

Core — Entities, Events, Claims

17 nodes

ENT-001

Entity

Atlantic Wave Holdings, LLC

Atlantic Wave Holdings, LLC - Plaintiff and judgment creditor seeking turnover and appointment of receiver

Page 2 — ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC, Plaintiffs

ENT-002

Entity

Secure Community, LLC

Secure Community, LLC - Plaintiff and judgment creditor seeking turnover and appointment of receiver

Page 2 — ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC, Plaintiffs

ENT-003

Entity

Cyberlux Corporation

Cyberlux Corporation - Defendant and judgment debtor subject to turnover order and receivership

Page 2 — CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants

ENT-004

Entity

Mark Schmidt

Mark Schmidt - Individual defendant against whom the turnover application was denied

Page 2 — CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants... the Court GRANTS the Application... on the terms set forth herein and DENIES the Application as to Defendant Mark Schmidt

ENT-005

Entity

Robert W. Berleth

Robert W. Berleth - Court-appointed Receiver with address at 9950 Cypresswood Dr., Suite 200 Houston, Texas 77070; phone: 713-588-6900

ENT-006

Entity

Catalyst MachineWorks, LLC

Catalyst MachineWorks, LLC - Entity with leased office and manufacturing facility at 21631 Rhodes Road, Spring, TX 77388; Cyberlux has an interest in this entity but not necessarily in property at the facility

Page 3 — Its interest, if any, in the leased office and manufacturing facility of Catalyst MachineWorks, LLC, located at 21631 Rhodes Road, Spring, TX 77388, as shown on page 18 of 46 of Applicants' Exhibit 2, admitted into evidence at the hearing; provided, however, this Order shall not apply to property located at the Spring, TX facility, as Applicants have not demonstrated Cyberlux has an interest in such property

ENT-007

Entity

Datron World Communications

Datron World Communications - Entity with leased office and manufacturing facility at 995 Joshua Way, Vista, CA 92081; Cyberlux has an interest in this entity but not in the lease or property at the facility

Page 4 — Its interest in Datron World Communications that has a leased office and manufacturing facility located at 995 Joshua Way, Vista, CA 92081, as shown on page 18 of 46 of Applicants' Exhibit 2, admitted into evidence at the hearing; provided, however, this Order shall not apply to the lease of or property located at the Vista, CA facility, as Applicants have not demonstrated Cyberlux has an interest in such property in the form of a leasehold interest or otherwise

ENT-008

Entity

Katharine Battaia Clark

Katharine Battaia Clark - Attorney for Defendants with Thompson Coburn LLP; email: kclark@thompsoncoburn.com

Page 3, 8 — Cyberlux's receipt of a copy of this Order, c/o its attorney of record, Katharine Battaia Clark via email to kclark@thompsoncoburn.com

EVT-001

Event

Amended Final Order and Judgment (June 28, 2023)

Amended Final Order and Judgment entered on June 28, 2023, awarding $1,572,500 as agreed by parties pursuant to separate agreement, plus costs of $177,126.19, and sanctions of $3,895 and $6,842.50, with interest at 12% per annum

Page 2 — Applicants are judgment creditors of Cyberlux pursuant to the Amended Final Order and Judgment signed on June 28, 2023, which sets forth an award of $1,572,500 "as agreed to by the parties pursuant to the parties' separate agreement"; an award of costs of $177,126.19; and "sanctions" in the amounts of $3,895 and $6,842.50, plus interest at 12% per annum "as provided in the parties' agreement."

EVT-002

Event

Partial Payments and Credits Applied

The Final Order has been reduced pursuant to payments of the 'sanctions' amounts and the costs, as well as by application of additional amounts, reducing the balance to $848,363.37 as of October 31, 2024

Page 2 — The Final Order has been reduced pursuant to payments of the "sanctions" amounts and the costs, as well as by application of additional amounts. The amount due pursuant to the Amended Final Order as of October 31, 2024, was $848,363.37.

EVT-003

Event

Turnover Hearing (January 17, 2025)

Hearing held on January 17, 2025, on the Application for Turnover After Judgment and for Appointment of Receiver, including testimony, admitted evidence, and review of papers on the docket

Page 2 — On January 17, 2025, came on to be heard the Application for Turnover After Judgment and for Appointment of Receiver made by Plaintiffs Atlantic Wave Holdings LLC and Secure Community LLC, (hereinafter "Applicants"). After the Court's review of the papers on the docket and the testimony and admitted evidence, the Court GRANTS the Application

EVT-004

Event

Receiver Appointment

Court appointed Robert W. Berleth as Receiver pursuant to Texas Turnover Statute, requiring $2,000 bond, with specified powers and duties to aid collection of judgment against Cyberlux

Page 2 — That Robert W. Berleth ("Receiver"), whose address is 9950 Cypresswood Dr., Suite 200 Houston, Texas 77070; phone: 713-588-6900, is hereby appointed Receiver in this cause pursuant to the Texas Turnover Statute, shall post a $2,000 bond, and shall serve with the powers and duties set forth herein and as limited by applicable law.

EVT-005

Event

Order Entry and Filing (June 5, 2025)

Order filed on June 5, 2025, at 12:13 PM by Shanelle Taylor in the Office of Marilyn Burgess, District Clerk of Harris County

Page 1 — 6/5/2025 12:13 PM Marilyn Burgess - District Clerk Harris County Envelope No. 101664202 By: Shanelle Taylor Filed: 6/5/2025 12:13 PM

CLM-001

Claim

Outstanding Judgment Balance

The amount due pursuant to the Amended Final Order as of October 31, 2024, was $848,363.37

Page 2 — The amount due pursuant to the Amended Final Order as of October 31, 2024, was $848,363.37.

CLM-002

Claim

Receivership Property Definition - Catalyst MachineWorks

Cyberlux has an interest in Catalyst MachineWorks, LLC, but this Order shall not apply to property located at the Spring, TX facility, as Applicants have not demonstrated Cyberlux has an interest in such property

CLM-003

Claim

Receivership Property Definition - Datron World Communications

Cyberlux has an interest in Datron World Communications, but this Order shall not apply to the lease of or property located at the Vista, CA facility, as Applicants have not demonstrated Cyberlux has an interest in such property in the form of a leasehold interest or otherwise

CLM-004

Claim

Receiver Fee Structure

Page 5 — Applicants assert that a reasonable fee for a postjudgment receiver working under a contingency that requires the advancement of time and expenses without prior investigation into a judgment debtor's assets is twenty-five percent (25%) of all collections and credits against the Judgment

Stage 3

In Situ — Quotations, Tells, Tensions, Questions

9 nodes

QUO-001

Quotation

Court's Grant and Denial Language

The Court explicitly bifurcates relief: granting the turnover application as to Cyberlux Corporation while denying it as to Mark Schmidt individually

Page 2 — the Court GRANTS the Application to aid the collection of the Judgment that is on file in this cause against Defendant Cyberlux Corporation ("Cyberlux") on the terms set forth herein and DENIES the Application as to Defendant Mark Schmidt

QUO-002

Quotation

Principal Award Language

The principal judgment amount was characterized as an agreed-upon sum pursuant to a separate agreement between the parties

Page 2 — which sets forth an award of $1,572,500 "as agreed to by the parties pursuant to the parties' separate agreement"

TLL-001

Tell

Witness Lack of Knowledge - Spring, TX

Applicants' witness testified he has no knowledge of what is located at the Spring, Texas facility, which directly informed the Court's decision to exclude physical property at that location from the receivership

Page 3 — Applicants' witness testified he has no knowledge of what is located at the Spring, Texas facility

TLL-002

Tell

Witness Lack of Knowledge - Vista, CA

Applicants' witness testified he has no knowledge of what is located at the Vista, California facility, which directly informed the Court's decision to exclude the lease and physical property at that location from the receivership

Page 4 — Applicants' witness testified he has no knowledge of what is located at the Vista, California facility

TEN-001

Tension

Broad Request vs. Narrow Grant

The order reveals tension between Applicants' apparent request for broad receivership powers over facilities and physical assets, and the Court's narrow grant limited to corporate interests only, explicitly excluding leases and physical property due to insufficient proof

Page 3, 4 — Its interest, if any, in the leased office and manufacturing facility... provided, however, this Order shall not apply to property located at the Spring, TX facility, as Applicants have not demonstrated Cyberlux has an interest in such property... this Order shall not apply to the lease of or property located at the Vista, CA facility, as Applicants have not demonstrated Cyberlux has an interest in such property in the form of a leasehold interest or otherwise

TEN-002

Tension

Individual vs. Corporate Liability

The order demonstrates a clear legal distinction between corporate judgment debtor Cyberlux and individual defendant Mark Schmidt, with relief granted only against the corporation despite Schmidt being named as a defendant

Page 2 — CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants... the Court GRANTS the Application to aid the collection of the Judgment that is on file in this cause against Defendant Cyberlux Corporation ("Cyberlux") on the terms set forth herein and DENIES the Application as to Defendant Mark Schmidt

QST-001

Question

Nature of Cyberlux's Interest in Entities

What is the precise nature and extent of Cyberlux's interest in Catalyst MachineWorks, LLC and Datron World Communications? The order authorizes receivership over these 'interests' but explicitly excludes leases and physical property, suggesting equity interest, membership interest, or other ownership stake rather than operational control.

Page 3, 4 — Its interest, if any, in the leased office and manufacturing facility of Catalyst MachineWorks, LLC... Its interest in Datron World Communications that has a leased office and manufacturing facility

QST-002

Question

Basis for Excluding Mark Schmidt

What evidence or legal argument led to the denial of the turnover application against Mark Schmidt individually? The order provides no explanation for this denial, suggesting either insufficient proof of personal liability, lack of personal assets subject to turnover, or corporate veil protection.

Page 2 — DENIES the Application as to Defendant Mark Schmidt

QST-003

Question

Pending Discovery Obligations

What specific discovery requests remain outstanding? The order references 'previously spending Request for Admission, Requests for Production, and Interrogatories' suggesting prior non-compliance, but the exact scope and timing of these discovery obligations is unclear.

Page 3 — is further Ordered to provide to the Receiver within 30 days hereof a copy of the responses to the previously spending Request for Admission, Requests for Production, and Interrogatories, subject in all respects to the Protective Order entered in this cause

Stage 4

Interpretive — Inferences, Omissions, Patterns

8 nodes

INF-001

Inference

Prior Discovery Non-Compliance

The order's requirement that Cyberlux provide 'responses to the previously spending Request for Admission, Requests for Production, and Interrogatories' within 30 days strongly suggests prior discovery non-compliance or inadequate responses, which likely contributed to the need for receiver appointment and compulsory turnover orders

Page 3 — is further Ordered to provide to the Receiver within 30 days hereof a copy of the responses to the previously spending Request for Admission, Requests for Production, and Interrogatories

INF-002

Inference

Judgment Creditors' Burden of Proof Gap

The explicit court findings that 'Applicants have not demonstrated Cyberlux has an interest in such property' at both facilities, combined with witness testimony of no knowledge of facility contents, suggests Applicants proceeded with the turnover application without adequate asset investigation or discovery, resulting in a significantly narrower receivership scope than likely intended

Page 3, 4 — Applicants have not demonstrated Cyberlux has an interest in such property (and, instead, Applicants' witness testified he has no knowledge of what is located at the Spring, Texas facility)... Applicants have not demonstrated Cyberlux has an interest in such property in the form of a leasehold interest or otherwise (and, instead, Applicants' witness testified he has no knowledge of what is located at the Vista, California facility)

INF-003

Inference

Substantial Judgment Satisfaction

The reduction of the judgment from $1,756,863.69 (principal plus costs plus sanctions) to $848,363.37 represents approximately 52% payment or credit, suggesting significant prior collection efforts or agreed offsets, though the order does not specify the nature of these reductions

Page 2 — which sets forth an award of $1,572,500... an award of costs of $177,126.19; and "sanctions" in the amounts of $3,895 and $6,842.50... The Final Order has been reduced pursuant to payments of the "sanctions" amounts and the costs, as well as by application of additional amounts. The amount due pursuant to the Amended Final Order as of October 31, 2024, was $848,363.37

INF-004

Inference

Corporate Structure and Asset Protection

Cyberlux's interests in two separate operating entities (Catalyst MachineWorks and Datron World Communications) that hold leases and conduct manufacturing operations, combined with the denial of relief against individual defendant Mark Schmidt, suggests a multi-entity corporate structure potentially designed for asset protection or operational separation

Page 2, 3, 4 — Its interest, if any, in the leased office and manufacturing facility of Catalyst MachineWorks, LLC... Its interest in Datron World Communications that has a leased office and manufacturing facility... DENIES the Application as to Defendant Mark Schmidt

OMI-001

Omission

No Explanation for Mark Schmidt Denial

The order provides no factual findings, legal reasoning, or explanation for denying the turnover application against Mark Schmidt individually, despite his being named as a defendant. This omission leaves unexplained whether Schmidt lacks personal liability, has no reachable assets, or is protected by corporate form.

Page 2 — DENIES the Application as to Defendant Mark Schmidt

OMI-002

Omission

Nature of 'Additional Amounts' Applied

The order states the judgment was reduced 'by application of additional amounts' beyond the identified sanctions and costs payments, but does not specify what these additional amounts represent—potentially payments on principal, settlements, offsets, or other credits

Page 2 — The Final Order has been reduced pursuant to payments of the "sanctions" amounts and the costs, as well as by application of additional amounts

OMI-003

Omission

Content of Separate Agreement

The judgment references a 'separate agreement' between the parties that established the $1,572,500 principal amount and 12% interest rate, but the order provides no details about this agreement's terms, nature (settlement, consent judgment, etc.), or other provisions that may affect collection

Page 2 — which sets forth an award of $1,572,500 "as agreed to by the parties pursuant to the parties' separate agreement"... plus interest at 12% per annum "as provided in the parties' agreement"

OMI-004

Omission

Protective Order Terms

The order repeatedly references a 'Protective Order entered in this cause' that governs document disclosure, but provides no details about its confidentiality provisions, scope, or restrictions that may affect the Receiver's ability to share information or market assets

Page 3 — subject in all respects to the Protective Order entered in this cause

Extracted text

10 pages · 14566 characters

Filing Header

6/5/2025 12:13 PM Marilyn Burgess - District Clerk Harris County Envelope No. 101664202 By: Shanelle Taylor Filed: 6/5/2025 12:13 PM

Unofficial Copy Office or Marilyn Burgess District Clerk

EXHIBIT 4

ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC, Plaintiffs, §

§ §

IN THE DISTRICT COURT OF

129th JUDICIAL DISTRICT

CYBERLUX CORPORATION and § MARK SCHMIDT, Individually, $ Defendants. §

HARRIS COUNTY, TEXAS

ORDER GRANTING IN PART AND DENYING IN PART TURNOVER AND APPOINTING RECEIVER

On January 17, 2025, came on to be heard the Application for Turnover After Judgment and for Appointment of Receiver made by Plaintiffs Atlantic Wave Holdings LLC and Secure Community LLC, (hereinafter "Applicants"). After the Court's review of the papers on the docket and the testimony and admitted evidence, the Court GRANTS the Application to aid the collection of the Judgment that is on file in this cause against Defendant Cyberlux Corporation ("Cyberlux") on the terms set forth herein and DENIES the Application as to Defendant Mark Schmidt. The Court, therefore, ORDERS, ADJUDGES AND DECREES:

Applicants are judgment creditors of Cyberlux pursuant to the Amended Final Order and Judgment signed on June 28, 2023, which sets forth an award of $1,572,500 "as agreed to by the parties pursuant to the parties' separate agreement"; an award of costs of $177,126.19; and "sanctions" in the amounts of $3,895 and $6,842.50, plus interest at 12% per annum "as provided in the parties' agreement." The Final Order has been reduced pursuant to payments of the "sanctions" amounts and the costs, as well as by application of additional amounts. The amount due pursuant to the Amended Final Order as of October 31, 2024, was $848,363.37.

That Robert W. Berleth ("Receiver"), whose address is 9950 Cypresswood Dr., Suite 200 Houston, Texas 77070; phone: 713-588-6900, is hereby appointed Receiver in this cause pursuant to the Texas Turnover Statute, shall post a $2,000 bond, and shall serve with the powers and duties set forth herein and as limited by applicable law.

That Cyberlux shall make a full and complete disclosure to the Receiver with respect to the Receivership Property (as defined herein) of the matters Cyberlux has been so

EXHIBIT 1-B

a Judgment da EL

ordered to disclose pursuant to this Order and to neither directly nor indirectly interfere or impede the Receiver in his performance of his duties under this Order.

That Cyberlux is Ordered to turnover and deliver custody to the Receiver within fourteen (14) days from Cyberlux's receipt of a copy of this Order, c/o its attorney of record, Katharine Battaia Clark via email to kclark@thompsoncoburn.com, the documents described in Exhibit "A" attached hereto, subject in allrespects to the Protective Order entered in this cause, and is further Ordered to provide to the Receiver within 30 days hereof a copy of the responses to the previously spending Request for Admission, Requests for Production, and Interrogatories, subject in all respects to the Protective Order entered in this cause .

ten (10) days of Cyberlux's receipt of a copy of this Order through its attorney of record, Katharine Battaia Clark via email to kclark@thompsoncoburn.com, all checks, cash, securities (stocks and bonds), promissory notes, of title and contracts that make up the Receivership Property (defined herein), and Cyberlux is hereby Ordered to continue to turnover to the Receiver at the Receiver's address all of said checks, cash, securities (stocks and bonds), promissory notes, documents of title and contracts that make up the Receivership Property (defined herein) within three (3) days from Cyberlux's receipt and possession of such property, if, as and when Cyberlux comes into receipt and possession of any such property, but only for so long as the Amended Final Order remains unsatisfied.

noTravailBe che Fren se Poseship nos ci find her documents o tilcom,al cho-

Receiver shall have all the power and authority allowed by law to take possession of the following of Cyberlux's non-exempt property in its actual or constructive possession or control, which property is defined herein as the "Receivership Property":

Its interest, if any, in the leased office and manufacturing facility of Catalyst MachineWorks, LLC, located at 21631 Rhodes Road, Spring, TX 77388, as shown on page 18 of 46 of Applicants' Exhibit 2, admitted into evidence at the hearing; provided, however, this Order shall not apply to property located at the Spring, TX facility, as Applicants have not demonstrated Cyberlux has an

interest in such property (and, instead, Applicants' witness testified he has no knowledge of what is located at the Spring, Texas facility);

b. Its interest in Datron World Communications that has a leased office and manufacturing facility located at 995 Joshua Way, Vista, CA 92081, as shown on page 18 of 46 of Applicants' Exhibit 2, admitted into evidence at the hearing; provided, however, this Order shall not apply to the lease of or property located at the Vista, CA facility, as Applicants have not demonstrated Cyberlux has an interest in such property in the form of a leasehold interest or otherwise (and, instead, Applicants' witness testified he has no knowledge of what is located at the Vista, California facility);

Receiver shall have all the power and authority allowed by law to take possession of all documents, books and records reasonably necessary to allow Receiver to evaluate said Receivership Property that is in the actual or constructive possession or control of Cyberlux;

The Receiver is hereby authorized to take all action necessary to gain access to all non- exempt real property, leased premises, storage facilities and safe deposit boxes wherein any real and/or personal property of Debtor may be situated and to seize the contents thereof.

The Receiver is hereby authorized to secure control over the Receivership Property, and engage in presale activities in order to secure the highest and best sales price for such Receivership Property, including but not limited to appraisals, evaluations, listing agreements, advertising agreements, etc. Receiver may not breach the peace but may seek further instruction from this Court. All sales of Receivership Property must be individually approved by this Court with reasonable and adequate notice and opportunity for hearing granted for Applicants and Cyberlux.

10.

Receiver is authorized but not required to (a) disable or remove the Receivership Property or to place the Receivership Property into storage; (b) insure any Receivership Property taken into his possession, and (c) change the locks to premises belonging to

the Debtor, but only with reasonable advance, written notice to the real property owner and/or manager and only to the extent necessary to secure the Receivership Property.

11.

Receiver shall have the power to subpoena from Cyberlux, third parties, and witnesses production of documents, things and information that would assist Receiver in carrying out his duties hereunder, including but not limited to matters concerning the existence, location, and/or value of Cyberlux's non-exempt assets and the location of such assets to the extent related to the Receivership Property.

12.

That any constable, deputy constable, sheriff, deputy sheriff or any other peace officer is hereby authorized to accompany Receiver pursuant to a writ to locations designated by Receiver where Receiver believes the Receivership Property may be located, said

Receiver from carrying out any duty under this Order or interfering with any property subject to this Order.

13.

That any person or any agent of any person, with actual notice of this Order is not to interfere with any property subject to this Order, and is further Ordered not to interfere with the Receiver in the carrying out of any duty under this Order. Third parties are hereby notified that the Receiver, to the exclusion of the Cyberlux, is the party entitled to possess, sell, liquidate and otherwise deal with the Receivership Property, and once any third party receives notice of this Order, they may be subject to liability should they release any of the Receivership Property to Cyberlux unless directed by the Receiver or this Court.

14.

Applicants assert that a reasonable fee for a postjudgment receiver working under a contingency that requires the advancement of time and expenses without prior investigation into a judgment debtor's assets is twenty-five percent (25%) of all collections and credits against the Judgment; the Receiver must demonstrate his faithful discharge of his duties in accordance with this Order upon application to this Court. Receiver is also entitled to reimbursement of reasonable expenses incurred in connection with his collection efforts. To obtain his fee and reimbursement of expenses, Receiver shall first file a motion discussing the relevant factors and considerations to the Court with notice to the parties and set for hearing on reasonable and adequate notice. Receiver may seek interim fees and reimbursements in the same

manner. Receiver's reasonable fees and reasonable expenses will be taxed as costs against Cyberlux.

15.

Any relief requested by Applicants in their Application for Turnover After Judgment and for Appointment of Receiver that is not specifically granted herein is denied.

Unofficial Copy Office of Marilyn Burgess District Clerk

DATE:

DISTRICT COURT JUDGE

EXHIBIT A

DOCUMENTS TO BE TURNED OVER TO RECEIVER

All records, as hereinafter described, concerning affairs of Debtors; unless otherwise noted, for the preceding 36 months:

bank statements; pass books and other bank or financial institution records;

federal income and state franchise tax returns;

real property deeds and deeds of trust (preceding 10 years);

governing documents of Debtor (e.g., articles of incorporation, company agreements, meeting minutes of board meetings, etc.

business journals, ledgers, accounts payable and receivable files, and

credit applications and other documents stating debtor's financial condition.

Unofficial Copy Office of Marilyn Burgess mansstraat Clerk

APPROVED AS TO FORM:

THOMPSON COBURN LLP Katharine Battaia Clark State Bar No. 24046712 Alexander J. Pennetti State Bar State Bar No. 24110208

2100

Ross Avenue, Suite 3200 Dallas, Texas 75201 Tel Phone: (972) 629-7100 Fax: (972) 629-7171 kclark@thompsoncoburn.com apennetti@thompsoncoburn.com

COUNSEL FOR DEFENDANTS

Unofficial Copy Office of Marilyn Burgess District Clerk

ORDER APPOINTING RECEIVER AND TO COMPEL DISCOVERY

EXHIBIT 1-B

Automated Certificate of eService

This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Frankie Huff on behalf of Alex Pennetti Bar No. 24110208 fhuff@thompsoncoburn.com Envelope ID: 101664202

Filing Code Description: Motion (No Fee)

Filing Description: Defendants Objection to Court s Order Appointing Receiver Dated May 22 2025 Status as of 6/5/2025 3:44 PM CST

Case Contacts

Name

BarNumber

TimestampSubmitted

Status

David A.Walton

dwalton@bellnunnally.com

6/5/2025 12:13:55 PM

SENT

LaDonna Arey

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6/5/2025 12:13:55 PM

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Sandra Meiners

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Travis Vargo

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Laurie DeBardeleben

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Roxanna Lock

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6/5/2025 12:13:55 PM

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Shawn Grady

shawn@gradycollectionlaw.com

6/5/2025 12:13:55 PM

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Shawn Grady

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Jeff Brown

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Records Department

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Micah Jackson

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Sheli Davis

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Paula Gentry

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6/5/2025 12:13:55 PM

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Lena Brasher

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Frankie Huff

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Tristian Harris

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Corinne Martin

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Hannah Fischer

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Hannah Petrea

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Michael Poynter

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6/5/2025 12:13:55 PM

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Bernadette Martin

bernadette@gradycollectionlaw.com

6/5/2025 12:13:55 PM

SENT

Bernadette Martin

bernadette@gradycollectionlaw.com

6/5/2025 12:13:55 PM

SENT

Automated Certificate of eService

Frankie Huff on behalf of Alex Pennetti Bar No. 24110208 fhuff@thompsoncoburn.com Envelope ID: 101664202

Filing Code Description: Motion (No Fee)

Filing Description: Defendants Objection to Court s Order Appointing Receiver Dated May 22 2025 Status as of 6/5/2025 3:44 PM CST

Case Contacts

Bernadette Martin

bernadette@gradycollectionlaw.com

6/5/2025 12:13:55 PM

SENT

Alex Pennetti

apennetti@thompsoncoburn.com

6/5/2025 12:13:55 PM

SENT

Douglas S.Lang

dlang@thompsoncoburn.com

6/5/2025 12:13:55 PM

SENT

Katharine Clark

kclark@thompsoncoburn.com

6/5/2025 12:13:55 PM

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Edward W.Gray, Jr.

EGray@thompsoncoburn.com

6/5/2025 12:13:55 PM

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Jocelin A. Tapia

jtapia@thompsoncoburn.com

6/5/2025 12:13:55 PM

SENT

Greg Nieman

gnieman@bellnunnally.com

6/5/2025 12:13:55 PM

SENT

Jemisha Gandhi

jgandhi@bellnunnally.com

6/5/2025 12:13:55 PM

SENT

David M.Keithly

dkeithly@mortensontaggart.com

6/5/2025 12:13:55 PM

SENT

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File: aw-harris-awh-2024-48085-doc-120929914.pdf
Source UID: source:ce75eecd6d73e2be1f460e182159564ce26af98e750ad2dad771138d3914da56
Full SHA-256: ce75eecd6d73e2be1f460e182159564ce26af98e750ad2dad771138d3914da56

DISTIL analysis

Extracted text

Exhibit 4 — Formatted Extract

Original source file