Exhibit 30
Now comes Interpleader Defendant/Claimant Fairwinds Technologies, LLC ("Fairwinds"), who submits the following responses to the Interrogatory and Document Requests agreed to by all Parties in the Joint Discovery Plan [Doc. 147] filed with the...
DISTIL analysis
- Fairwinds claims $2,348,542.00 from Cyberlux Corporation in interpleader proceeds
- Claim based on 8% commission agreement for first 1000 Cyberlux Model K8 Aircraft delivered to HII
- Two teaming agreements: October 3, 2022 initial agreement and June 7, 2023 Strategic Business Development Contract
- Debt liquidated July 8, 2025 when Cyberlux CEO Mark Schmidt provided spreadsheet backed by HII invoices
- Cyberlux does not dispute validity of agreements or amount owed
- No security interest, lien, assignment, interest claim, or attorneys' fees sought
Extracted text
6 pages · 6003 charactersIN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division
Interpleader Plaintiff
v. CYBERLUX CORPORATION; ATLANTIC WAVE HOLDINGS, LLC; SECURE COMMUNITY, LLC; LEGALIST SPV III, LP; UNITED STATES OF AMERICA; ADVANCED NAVIGATION AND POSITIONING CORPORATION; and ROBERT W. BERLETH, solely in his capacity as Receiver for Cyberlux Corporation,
Interpleader Defendants/Claimants
Civil Action No: 3:25-cv-483-JAG
Now comes Interpleader Defendant/Claimant Fairwinds Technologies, LLC ("Fairwinds"), who submits the following responses to the Interrogatory and Document Requests agreed to by all Parties in the Joint Discovery Plan [Doc. 147] filed with the Court on February 12, 2026, as follows:
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.
Response:
Cyberlux owes Fairwinds $2,348,542.00.
(b) The legal basis for your right to the proceeds.
The debt is related to a Teaming Agreement initially entered into by Cyberlux and Fairwinds on October 3, 2022, whereby Fairwinds agreed to assist Cyberlux to secure a contract for the sale of Cyberlux Model K8 Aircraft ("Drones") and in exchange would be given the opportunity to serve as prime contractor for the sale of the aircraft, or if another party was chosen to serve as prime contractor, would receive eight percent (8%) of the contract value associated with the first 1000 Drones delivered. When HII was chosen as Prime Contractor, Cyberlux and Fairwinds entered into a Strategic Business Development Service and Supply Teaming Contract (the "Contract") on June 7, 2023. that reaffirmed that Cyberlux would pay Fairwinds eight (8%) of the value of the first 1000 Drones delivered to HII. On July 8, 2025, Mark Schmidt, Cyberlux's Chief Executive Officer, sent Fairwinds a spreadsheet backed up by invoices to HII documenting the amount Cyberlux invoiced HII for the Drones and the amount due Fairwinds in exchange for the consulting and business support services Fairwinds had provided Cyberlux. Fairwinds responded by issuing an invoice to which Mr. Schmidt said would be paid to Fairwinds out of the remaining amount HII owed to Cyberlux. Cyberlux told Fairwinds those are the funds placed in deposit with the Court. Cyberlux does not dispute the validity of the agreements between it and Fairwinds, the amount due to Fairwinds, or the fact that Mr. Schmidt told Fairwinds it would be paid that amount out of the remaining funds HII owed to Cyberlux, the same funds deposited with the Court.
(c) How the amount you claim became a liquidated amount or, if not liquidated, state so.
Response:
The amount was liquidated on or about July 8, 2025, when Cyberlux sent to Fairwinds a spreadsheet detailing the amount owed to Fairwinds on its commission based upon the total amount Cyberlux had invoiced HII.
(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.
Response:
None.
(e) Whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any.
Response:
None.
(f) Whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim.
Response:
None.
(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.
Response:
Not applicable.
i. Documents supporting or otherwise concerning your answer to the above interrogatory.
Response:
Documents responsive to this request are labeled Fairwinds-0001 through Fairwinds- 0132.
DOCUMENT REQUEST ii:
ii. All documents on which you rely to assert any security interest in, lien on, or assignment of the proceeds that are the subject of this interpleader.
Response:
Not applicable.
Date: March 9, 2026
Respectfully submitted,
ALEXANDER N. BRECKINRIDGE V (VSB #74708) MARK A. MINTZ (admitted pro hac vice) JONES WALKER LLP 1 M Street SE, Suite 600 Washington, DC 20003 Telephone: (202) 203-1021 Facsimile: (202) 203-0000 abreckinridge@joneswalker.com mmintz@joneswalker.com Counsel for Intervenor, Fairwinds Technologies, LLC
The undersigned hereby certifies that a copy of the foregoing response was served via email on all counsel of record.
This the 9th day of March, 2026.
ALEXANDER N. BRECKINRIDGE V
I, Thomas Wirth, General Counsel of Fairwinds Technologies LLC, declare under penalty of perjury under the laws of the United States of America that: I am duly authorized to verify the foregoing interrogatory responses and document requests on behalf of Fairwinds Technologies, LLC; that the information contained in the foregoing responses has been collected and the responses prepared with the advice and assistance of counsel; and that, subject to any inadvertent or undiscovered errors, and based on the records and information still in existence and thus far discovered, the foregoing responses are true and correct.
Thomas O. Wirts THOMAS WIRTH, Esq. General Counsel of Fairwinds Technologies, LLC
Original source file
- File
- ip-hii-edva-00483-doc-0175-exhibit-32.pdf
- Source UID
- source:f090745fd61ed079de4c38935a255a638bac79016fa212ad8e8de8f999a2744d
- Full SHA-256
- f090745fd61ed079de4c38935a255a638bac79016fa212ad8e8de8f999a2744d