Evidence Record

Exhibit 25

Pursuant Rules 26, 33 and 34 of the Federal Rules of Civil Procedure, and the Joint Discovery Plan entered in this case by order dated February 19, 2026 (Doc. 149) (the "Order"), Interpleader Defendant...

Type
exhibit
Court
EDVA
Case
HII v. Cyberlux interpleader
Docket
3:25-cv-00483
Pages
7
Lines
155
SHA-256
fd80eec6d70c

DISTIL analysis

DISTIL Run
Profile
Standard
Version
1
Doc Type
interrogatory_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
interrogatory_response Advanced Navigation & Positioning Corporation via Parker Poe Adams & Bernstein LLP federal_civil_litigation_interpleader 2024-12-20 to 2026-03-09
competing_claimssecured_interestequitable_lienjudgment_enforcement
Analytical Frame
creditor_claim_priority
Analytical Summary
ANPC responds to interrogatories in an interpleader action claiming $3,087,878.86 in proceeds held by HII Mission Technologies. ANPC asserts two bases for its claim: a judgment lien arising from a Writ of Fieri Facias filed September 24, 2025, and an equitable lien arising December 30, 2024, when Cyberlux breached a Purchase Agreement by failing to remit assigned funds. The underlying judgment of $2,926,814.39 was obtained in North Carolina on July 21, 2025, after Cyberlux failed to pay for services ANPC provided under the Purchase Agreement. ANPC claims its equitable lien has priority dating to December 30, 2024, when Cyberlux retained assigned funds rather than paying ANPC. The claim includes $257,828.86 in interest accruing at 8% from July 21, 2025, but excludes attorneys' fees.
Key Points
  • ANPC claims $3,087,878.86 from interpleader proceeds in HII v. Cyberlux litigation
  • Claims based on judgment lien (Sept 2025) and equitable lien (Dec 2024)
  • Underlying judgment of $2,926,814.39 obtained July 21, 2025 in North Carolina
  • Equitable lien arises from Cyberlux's retention of funds assigned to ANPC under Purchase Agreement
  • ANPC asserts equitable lien priority date of December 30, 2024
  • Interest claim of $257,828.86 accruing at 8% from judgment date
Stage 2
Core — Entities, Events, Claims
19 nodes
ENT-001
Entity
Advanced Navigation & Positioning Corporation (ANPC)
Interpleader defendant and creditor claiming proceeds from HII Mission Technologies Corp. holding. Claims judgment lien and equitable lien against Cyberlux Corporation for unpaid services under Purchase Agreement.
Page 2 — INTERPLEADER DEFENDANT ADVANCED NAVIGATION & POSITIONING CORPORATION'S RESPONSE TO INTERROGATORIES
ENT-002
Entity
Cyberlux Corporation
Defendant entity that breached Purchase Agreement with ANPC by failing to pay for services. Subject of judgment and garnishment actions. Assigned funds to ANPC under Purchase Agreement but retained them instead.
Page 3 — ANPC filed a complaint against Cyberlux in North Carolina as a result of Cyberlux's breach of a purchase agreement entered into between Cyberlux and ANPC
ENT-003
Entity
HII Mission Technologies Corp.
Plaintiff in interpleader action and garnishee. Entity holding proceeds subject to competing claims. Served with Garnishment Summons on October 8, 2025.
Page 3 — served on HII Mission Technologies Corp. ("HII") and Cyberlux Corporation ("Cyberlux")
ENT-004
Entity
Parker Poe Adams & Bernstein LLP
Law firm representing ANPC in interpleader action. Counsel includes Joel D. Schwartz (Virginia Bar), Catherine G. Clodfelter (NC Bar), and Charles E. Raynal IV (NC Bar).
Page 5 — Joel D. Schwartz Virginia Bar No. 97979 PARKER POE ADAMS & BERNSTEIN LLP 1400 K Street NW, Suite 1000 Washington, DC 20005-2403
EVT-001
Event
Purchase Agreement execution
ANPC and Cyberlux entered into Purchase Agreement under which ANPC agreed to provide services that Cyberlux would use to produce products for sale to its customer.
Page 3 — In the Purchase Agreement, ANPC agreed to provide services to Cyberlux that Cyberlux would use to produce products that Cyberlux then sold to its customer.
EVT-002
Event
ANPC performance under Purchase Agreement
ANPC performed its obligations under the Purchase Agreement by providing services and assets to produce products that Cyberlux sold to its customer.
Page 3 — ANPC performed under the Purchase Agreement, but Cyberlux failed to pay in full in accordance with the Purchase Agreement.
EVT-003
Event
Cyberlux breach of Purchase Agreement
Cyberlux failed to pay ANPC in full in accordance with Purchase Agreement. Specifically failed to pay pursuant to final invoice dated December 20, 2024, with payment due December 30, 2024.
Page 3, 4 — ANPC performed under the Purchase Agreement, but Cyberlux failed to pay in full in accordance with the Purchase Agreement... when Cyberlux breached the Purchase Agreement by failing to pay ANPC the Assigned Funds pursuant to the final invoice dated as of December 20, 2024, payment for which was due under the Purchase Agreement by December 30, 2024.
EVT-004
Event
North Carolina lawsuit filing
ANPC filed complaint against Cyberlux in North Carolina as result of Cyberlux's breach of Purchase Agreement.
Page 3 — ANPC filed a complaint against Cyberlux in North Carolina as a result of Cyberlux's breach of a purchase agreement entered into between Cyberlux and ANPC
EVT-005
Event
North Carolina judgment entry
Durham County Superior Court entered judgment in favor of ANPC against Cyberlux on July 21, 2025, in amount of $2,926,814.39 in case Advanced Navigation & Positioning Corporation vs. Cyberlux Corporation, 25-CVS-005686-310.
Page 4 — ANPC's Claimed Amount became liquidated once the Durham County Superior Court entered the Judgment in favor of ANPC against Cyberlux in Advanced Navigation & Positioning Corporation vs. Cyberlux Corporation, 25-CVS-005686-310 on July 21, 2025, in the amount of $2,926,814.39
EVT-006
Event
Judgment domestication in Virginia
ANPC's North Carolina judgment was domesticated in Virginia, serving as basis for subsequent garnishment actions.
Page 4 — ANPC received the Judgment against Cyberlux, which Judgment was domesticated in Virginia and served as the basis for the Garnishment Summons issued to HII and Cyberlux.
EVT-007
Event
Writ of Fieri Facias filing
ANPC filed Writ of Fieri Facias on September 24, 2025 in Richmond County. This filing created ANPC's security interest and was used to initiate garnishment proceedings.
Page 3, 4 — ANPC has a lien on the proceeds pursuant to a Writ of Fieri Facias filed on September 24, 2025 in Richmond County... ANPC's security interest arose when ANPC filed the Writ of Fieri Facias on September 24, 2025.
EVT-008
Event
Garnishment Summons service
ANPC served Garnishment Summons on October 8, 2025 on HII Mission Technologies Corp. and Cyberlux Corporation to garnish monies owed by Cyberlux in amount of $2,926,814.39.
Page 3 — which Writ of Fieri Facias was used to initiate a Garnishment Summons on October 8, 2025, and served on HII Mission Technologies Corp. ("HII") and Cyberlux Corporation ("Cyberlux"). ANPC filed the Writ of Fieri Facias and moved to garnish monies owed by Cyberlux to ANPC from garnishee HII in the amount of $2,926,814.39
EVT-009
Event
Joint Discovery Plan order
Court entered Joint Discovery Plan on February 19, 2026 (Doc. 149), which included interrogatory requirements that ANPC's response addresses.
Page 2 — Pursuant Rules 26, 33 and 34 of the Federal Rules of Civil Procedure, and the Joint Discovery Plan entered in this case by order dated February 19, 2026 (Doc. 149) (the "Order")
EVT-010
Event
Interrogatory response filing
ANPC filed response to interrogatories on March 9, 2026, through counsel Joel D. Schwartz of Parker Poe Adams & Bernstein LLP.
Page 5 — This 9th day of March, 2026. /s/ Joel D. Schwartz
CLM-001
Claim
ANPC proceeds claim of $3,087,878.86
ANPC claims total of $3,087,878.86 from interpleader proceeds, consisting of $2,926,814.39 principal judgment amount plus $257,828.86 accrued interest. Does not include attorneys' fees.
Page 3, 5 — ANPC claims $3,087,878.86 of the proceeds (the "Claimed Amount")... ANPC claims $257,828.86 of interest... ANPC is not claiming attorneys' fees as part of its Claimed Amount.
CLM-002
Claim
Judgment lien on proceeds
ANPC claims lien on proceeds pursuant to Writ of Fieri Facias filed September 24, 2025 in Richmond County, which created security interest on that date.
Page 3, 4 — ANPC has a lien on the proceeds pursuant to a Writ of Fieri Facias filed on September 24, 2025 in Richmond County... ANPC's security interest arose when ANPC filed the Writ of Fieri Facias on September 24, 2025.
CLM-003
Claim
Equitable lien with December 2024 priority
ANPC claims equitable lien on proceeds arising December 30, 2024, when Cyberlux breached Purchase Agreement by failing to pay assigned funds. Claims this equitable lien provides earlier priority date than judgment lien.
Page 4, 5 — ANPC additionally claims an equitable lien that arose, at the earliest, on December 30, 2024, when Cyberlux breached the Purchase Agreement by failing to pay ANPC the Assigned Funds pursuant to the final invoice dated as of December 20, 2024, payment for which was due under the Purchase Agreement by December 30, 2024. Because the equitable lien arose when Cyberlux failed to provide the Assigned Funds to ANPC in accordance with the Purchase Agreement, the equitable lien therefore arose on December 30, 2024.
CLM-004
Claim
Fund assignment under Purchase Agreement
ANPC claims that Cyberlux assigned certain funds to ANPC under Purchase Agreement to compensate ANPC for services and assets provided to produce products. Cyberlux retained these assigned funds instead of paying ANPC.
Page 4 — Specifically, Cyberlux assigned certain funds (the "Assigned Funds") to ANPC under the Purchase Agreement, which funds were to compensate ANPC for services and assets that ANPC provided to produce the products that Cyberlux then sold to its customer. Cyberlux did not provide the Assigned Funds to ANPC upon such Assigned Funds becoming due and owing and instead retained the Assigned Funds to serve other parties and produce other products.
CLM-005
Claim
Interest claim at 8% from July 21, 2025
ANPC claims $257,828.86 in interest accruing from July 21, 2025 at legal rate of 8% on principal amount until satisfied pursuant to North Carolina statutes.
Page 5 — ANPC claims $257,828.86 of interest, which began accruing on July 21, 2025 at the legal rate of 8% on the principal amount until satisfied pursuant to N.C. Gen. Stat. §§ 24-1, 24-5.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
7 nodes
QUO-001
Quotation
Interrogatory question on claim nature
Court-ordered interrogatory requires explanation of claim nature including amount, legal basis, liquidation, security interest details, priority date, interest rights, and attorneys' fees.
Page 2, 3 — 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 attorneys' fees and, if so, the basis therefore and the amount you will claim; (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.
TLL-001
Tell
Cyberlux diverted assigned funds
ANPC alleges Cyberlux retained assigned funds to serve other parties and produce other products instead of paying ANPC as contractually required.
Page 4 — Cyberlux did not provide the Assigned Funds to ANPC upon such Assigned Funds becoming due and owing and instead retained the Assigned Funds to serve other parties and produce other products.
TLL-002
Tell
Preliminary statement on completeness
ANPC states response is complete and correct as of document date based on reasonable inquiry, but reserves right to amend, supplement, or offer additional evidence at trial.
Page 2 — To the best of ANPC's knowledge, information and belief, formed after reasonable inquiry, this response is complete and correct as of the date of this document. ANPC reserves the right to amend or supplement this response. ANPC also reserves the right to reference, discover or offer into evidence at the time of trial any and all facts, documents and things notwithstanding the initial response.
TEN-001
Tension
Competing priority dates for lien claims
ANPC asserts two different priority dates: judgment lien from September 24, 2025 and equitable lien from December 30, 2024. The equitable lien provides earlier priority but may face greater legal scrutiny than recorded judgment lien.
Page 4, 5 — ANPC's security interest arose when ANPC filed the Writ of Fieri Facias on September 24, 2025. ANPC additionally claims an equitable lien that arose, at the earliest, on December 30, 2024
QST-001
Question
Equitable lien recognition in interpleader
Will court recognize ANPC's equitable lien claim based on retained assigned funds as valid basis for priority over other creditors? Equitable liens require showing of special circumstances beyond ordinary contract breach.
Page 4 — ANPC also claims an equitable lien on the proceeds, which claim is set out in ANPC's Supplemental Answer to HII's Amended Complaint.
QST-002
Question
December 2024 priority date validity
Can ANPC establish December 30, 2024 as equitable lien priority date based solely on payment breach, or does equitable lien require additional elements? Statement 'at the earliest' suggests uncertainty about exact priority date.
Page 4 — ANPC additionally claims an equitable lien that arose, at the earliest, on December 30, 2024
QST-003
Question
Competing claims in interpleader
What other creditors or claimants are asserting rights to the interpleader proceeds, and how will their priority dates compare to ANPC's claimed December 2024 and September 2025 dates?
Page 2 — HII MISSION TECHNOLOGIES CORP., Plaintiff, V. CYBERLUX CORPORATION, et al., Defendants.
Stage 4
Interpretive — Inferences, Omissions, Patterns
6 nodes
INF-001
Inference
Strategic dual-lien assertion
ANPC asserts both judgment lien (legally secure but later dated) and equitable lien (earlier priority but legally uncertain) to maximize chances of priority over competing creditors. This hedging strategy provides fallback if equitable lien claim fails.
Page 3, 4 — ANPC has a lien on the proceeds pursuant to a Writ of Fieri Facias... ANPC also claims an equitable lien on the proceeds
INF-002
Inference
Cyberlux cash flow crisis pattern
Cyberlux's retention of assigned funds to serve other parties and produce other products suggests company was experiencing cash flow problems and attempting to keep business operational by diverting funds from creditor obligations.
Page 4 — Cyberlux did not provide the Assigned Funds to ANPC upon such Assigned Funds becoming due and owing and instead retained the Assigned Funds to serve other parties and produce other products.
INF-003
Inference
Proceeds likely from Cyberlux's customer sales
The interpleader proceeds held by HII likely represent payment for products Cyberlux manufactured using ANPC's services and sold to customer, creating basis for ANPC's equitable lien theory that funds should have been assigned to ANPC.
Page 3, 4 — ANPC agreed to provide services to Cyberlux that Cyberlux would use to produce products that Cyberlux then sold to its customer... which funds were to compensate ANPC for services and assets that ANPC provided to produce the products that Cyberlux then sold to its customer.
OMI-001
Omission
No detail on Purchase Agreement assignment clause
Response does not provide text of Purchase Agreement provision allegedly assigning funds to ANPC. Absence of specific contractual language makes it difficult to evaluate strength of assignment and equitable lien claims.
Page 4 — Cyberlux assigned certain funds (the "Assigned Funds") to ANPC under the Purchase Agreement
OMI-002
Omission
No attorneys' fees calculation despite right
ANPC states it is not claiming attorneys' fees as part of claimed amount, but does not explain whether Purchase Agreement or North Carolina judgment entitles ANPC to fees. This strategic omission may preserve flexibility to claim fees separately.
Page 5 — ANPC is not claiming attorneys' fees as part of its Claimed Amount.
OMI-003
Omission
Missing advances date for secured interest
Response does not identify advances date despite interrogatory specifically requiring date advances were made to Cyberlux for secured interest claims. Only provides breach date December 30, 2024.
Page 5 — The amounts subject to ANPC's equitable lien were effectively advanced at the latest on December 30, 2024, when Cyberlux failed to pay ANPC pursuant to a final invoice.

Extracted text

7 pages · 7769 characters

Exhibit 25 — Formatted Extract

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

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION Case No. 3:25-cv-00483-JAG

HII MISSION TECHNOLOGIES CORP.,

Plaintiff,

V. CYBERLUX CORPORATION, et al., Defendants.

ADVANCED NAVIGATION & POSITIONING CORPORATION'S RESPONSE TO INTERROGATORIES

INTERPLEADER DEFENDANT ADVANCED NAVIGATION & POSITIONING CORPORATION'S RESPONSE TO INTERROGATORIES

Pursuant Rules 26, 33 and 34 of the Federal Rules of Civil Procedure, and the Joint Discovery Plan entered in this case by order dated February 19, 2026 (Doc. 149) (the "Order"), Interpleader Defendant Advanced Navigation & Positioning Corporation ("ANPC"), by and through undersigned counsel, submits the following response to the interrogatory set out in Section 6(a) of the Order:

Preliminary Statement

To the best of ANPC's knowledge, information and belief, formed after reasonable inquiry, this response is complete and correct as of the date of this document. ANPC reserves the right to amend or supplement this response. ANPC also reserves the right to reference, discover or offer into evidence at the time of trial any and all facts, documents and things notwithstanding the initial response.

INTERROGATORY

6(a). 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 attorneys' 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.

RESPONSES:

a. The amount of the proceeds that you claim.

ANPC claims $3,087,878.86 of the proceeds (the "Claimed Amount").

b. The legal basis for your right to the proceeds

ANPC has a lien on the proceeds pursuant to a Writ of Fieri Facias filed on September 24, 2025 in Richmond County, which Writ of Fieri Facias was used to initiate a Garnishment Summons on October 8, 2025, and served on HII Mission Technologies Corp. ("HII") and Cyberlux Corporation ("Cyberlux"). ANPC filed the Writ of Fieri Facias and moved to garnish monies owed by Cyberlux to ANPC from garnishee HII in the amount of $2,926,814.39 (the "Garnishment Action").

ANPC filed the Writ of Fieri Facias and Garnishment Summons because it holds a judgment against Cyberlux that has not been paid (the "Judgment"). ANPC filed a complaint against Cyberlux in North Carolina as a result of Cyberlux's breach of a purchase agreement entered into between Cyberlux and ANPC ("Purchase Agreement"). In the Purchase Agreement, ANPC agreed to provide services to Cyberlux that Cyberlux would use to produce products that Cyberlux then sold to its customer. ANPC performed under the Purchase Agreement, but Cyberlux failed to pay in full in accordance with the Purchase Agreement. ANPC received the

Judgment against Cyberlux, which Judgment was domesticated in Virginia and served as the basis for the Garnishment Summons issued to HII and Cyberlux.

ANPC also claims an equitable lien on the proceeds, which claim is set out in ANPC's Supplemental Answer to HII's Amended Complaint. Specifically, Cyberlux assigned certain funds (the "Assigned Funds") to ANPC under the Purchase Agreement, which funds were to compensate ANPC for services and assets that ANPC provided to produce the products that Cyberlux then sold to its customer. Cyberlux did not provide the Assigned Funds to ANPC upon such Assigned Funds becoming due and owing and instead retained the Assigned Funds to serve other parties and produce other products.

c. How the amount you claim became a liquidated amount or, if not liquidated, state so.

ANPC's Claimed Amount became liquidated once the Durham County Superior Court entered the Judgment in favor of ANPC against Cyberlux in Advanced Navigation & Positioning Corporation vs. Cyberlux Corporation, 25-CVS-005686-310 on July 21, 2025, in the amount of $2,926,814.39, which has continued to accrue interest.

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.

ANPC's security interest arose when ANPC filed the Writ of Fieri Facias on September 24, 2025.

ANPC additionally claims an equitable lien that arose, at the earliest, on December 30, 2024, when Cyberlux breached the Purchase Agreement by failing to pay ANPC the Assigned Funds pursuant to the final invoice dated as of December 20, 2024, payment for which was due under the Purchase Agreement by December 30, 2024. Because the equitable lien arose when

Cyberlux failed to provide the Assigned Funds to ANPC in accordance with the Purchase Agreement, the equitable lien therefore arose on December 30, 2024.

e. Whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any.

ANPC claims $257,828.86 of interest, which began accruing on July 21, 2025 at the legal rate of 8% on the principal amount until satisfied pursuant to N.C. Gen. Stat. §§ 24-1, 24-5.

f. Whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim.

ANPC is not claiming attorneys' fees as part of its Claimed Amount.

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.

The amounts subject to ANPC's equitable lien were effectively advanced at the latest on December 30, 2024, when Cyberlux failed to pay ANPC pursuant to a final invoice.

This 9th day of March, 2026.

/s/ Joel D. Schwartz Joel D. Schwartz Virginia Bar No. 97979 PARKER POE ADAMS & BERNSTEIN LLP 1400 K Street NW, Suite 1000 Washington, DC 20005-2403 Telephone: (202) 434-9100 Fax: (202) 217-2771 Email: joelschwartz@parkerpoe.com

Catherine G. Clodfelter NC Bar No. 47653 (admitted pro hac vice) Charles E. Raynal IV NC Bar No. 32310 (admitted pro hac vice) PARKER POE ADAMS & BERNSTEIN LLP 301 Fayetteville Street, Suite 1400 Raleigh, NC 27601 Telephone: (919) 828-0564 Fax: (919) 834-4564 Email: catherineclodfelter@parkerpoe.com

Filed 04/15/26

charlesraynal@parkerpoe.com Counsel for ANPC

CERTIFICATE OF SERVICE

The undersigned hereby certifies that the foregoing was served by e-mail notification to counsel of record.

This the 9th day of March, 2026.

/s/ Joel D. Schwartz Joel D. Schwartz Virginia Bar No. 97979 Parker Poe Adams & Bernstein LLP 1400 K Street NW, Suite 1000 Washington, DC 20005-2403 Telephone: (202) 434-9100 Fax: (202) 217-2771 Email: joelschwartz@parkerpoe.com Counsel for ANPC

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ip-hii-edva-00483-doc-0175-exhibit-27.pdf
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fd80eec6d70c7b87784596d6b8a8f1e373a253deaf972f94b5f639eeb4f541c4