Evidence Record

Exhibit 2

1. Documents supporting or otherwise concerning your answer to the above interrogatory.

Type
exhibit
Court
EDVA
Case
HII v. Cyberlux interpleader
Docket
3:25-cv-00483
Pages
7
Lines
155
SHA-256
2bdaafa17c9f

DISTIL analysis

DISTIL Run
Profile
Standard
Version
1
Doc Type
legal_filing_interrogatory_response
Total Nodes
27
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_filing_interrogatory_response Legalist SPV III, LP through counsel interpleader_action_secured_creditor_claim 2024-03-27 to 2026-03-09
monetary_claim_liquidatedsecurity_interest_perfectedmultiple_advancesongoing_legal_fees
Analytical Frame
financing_dispute_priority_determination
Analytical Summary
This document is Legalist SPV III, LP's response to discovery interrogatories in an interpleader action involving proceeds disputed among multiple creditors of Cyberlux Corporation. Legalist asserts a perfected security interest totaling $13,204,742.88, based on a Second Amended and Restated Government Purchase Order Financing Agreement executed March 27, 2024, and UCC filings on April 1, 2024. The claim comprises $10,033,639.75 in principal advances made between April 2024 and June 2025, plus accrued interest, commitment fees, forbearance fees, and legal costs. Legalist claims priority over competing creditors based on its April 1, 2024 perfection date in Nevada and North Carolina, where Cyberlux is incorporated and headquartered respectively. The response demonstrates a systematic financing relationship with twelve separate advance transactions, including a significant $3,083,639.75 protective advance in June 2025.
Key Points
  • Legalist claims $13,204,742.88 total comprising principal, interest, fees, and legal costs
  • Security interest created March 27, 2024 via Second Amended and Restated Government Purchase Order Financing Agreement
  • UCC Statements filed April 1, 2024 in Nevada and North Carolina establishing perfection priority date
  • Twelve separate advances totaling $10,033,639.75 made between April 2024 and June 2025
  • June 2025 protective advance of $3,083,639.75 represents substantial late-stage financing
  • Claim includes contractual rights to interest, commitment fees, forbearance fees, and attorney fees
  • Legal fees claimed at $351,632.29 as of settlement conference with ongoing accrual
Stage 2
Core — Entities, Events, Claims
13 nodes
ENT-001
Entity
Legalist SPV III, LP
Legalist SPV III, LP ("Legalist") is the Interpleader Defendant/Claimant asserting a secured creditor claim against proceeds held in interpleader. Legalist is a financing entity that entered into a Government Purchase Order Financing Agreement with Cyberlux.
Page 2 — Interpleader Defendant/Claimant Legalist SPV III, LP ("Legalist"), provides the following response to the pre-settlement interrogatory and requests for production providing in the Joint Discovery Plan (ECF No. 149).
ENT-002
Entity
Cyberlux Corporation
Cyberlux Corporation is the debtor entity that received financing from Legalist. Cyberlux is incorporated in Nevada and headquartered in North Carolina. It is the entity whose accounts receivable and assets are subject to Legalist's security interest.
Page 3, 4 — On March 27, 2024, Legalist entered into a Second Amended and Restated Government Purchase Order Financing Agreement ("Financing Agreement") with Cyberlux, whereby Legalist provided a revolving line of credit in the amount of $7,000,000.00 secured by certain collateral, including accounts receivable.
ENT-003
Entity
HII Mission Technologies Corp.
HII Mission Technologies Corp. is the Interpleader Plaintiff that initiated this action, holding proceeds that are the subject of competing claims among multiple creditors.
Page 2 — HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff, V. CYBERLUX CORPORATION, et al., Interpleader Defendants/Claimants.
EVT-001
Event
Execution of Financing Agreement
On March 27, 2024, Legalist and Cyberlux executed a Second Amended and Restated Government Purchase Order Financing Agreement providing a $7,000,000 revolving line of credit secured by collateral including accounts receivable.
Page 3 — On March 27, 2024, Legalist entered into a Second Amended and Restated Government Purchase Order Financing Agreement ("Financing Agreement") with Cyberlux, whereby Legalist provided a revolving line of credit in the amount of $7,000,000.00 secured by certain collateral, including accounts receivable.
EVT-002
Event
UCC Filing Perfection
On April 1, 2024, Legalist filed UCC financing statements in Nevada and North Carolina to perfect its security interest in Cyberlux's assets and accounts receivable. This establishes Legalist's priority date for secured creditor status.
Page 3 — Pursuant to the Financing Agreement, on April 1, 2024, Legalist filed certain financing statements under the Uniform Commercial Code ("UCC Statements") in Nevada and North Carolina identifying and perfecting its lien on Cyberlux's assets, including its accounts receivable.
EVT-003
Event
Initial Advance Series (April-October 2024)
Between April 9, 2024 and October 3, 2024, Legalist made ten separate advances to Cyberlux totaling $6,950,000 under the Financing Agreement. These advances ranged from $120,000 to $2,500,000 and were made at various intervals.
Page 4, 5 — Legalist made advances under the Financing Agreement on the following dates: 4/9/2024: $1,800,000.00 · 4/19/2024: $500,000.00 · 5/2/2024: $500,000.00 · 6/26/2024: $142,000.00 · 7/5/2024: $53,000.00 · 7/16/2024: $2,500,000.00 · 8/2/2024: $650,000.00 · 8/27/2024: $535,000.00 · 10/3/2024: $150,000.00 · 10/3/2024: $120,000.00
EVT-004
Event
June 2025 Protective Advance
In June 2025, Legalist made a protective advance of $3,083,639.75 on behalf of Cyberlux at Cyberlux's request. This was executed through two transactions on June 3 and June 9, 2025, and represents financing beyond the original $7M revolving line.
Page 3, 5 — Legalist also advanced $3,083,639.75 pursuant to the financing agreement at Cyberlux's request in June 2025... · 6/3/2025: $2,755,100.10 · 6/9/2025: $345,000.00. The final two entries covered the $3,083,639.75 protective advance Legalist made on behalf of Cyberlux. Legalist initially advanced $3,100,100.10, and the $16,460.35 difference was applied to its legal fees.
EVT-005
Event
Filing of Discovery Response
On March 9, 2026, Legalist filed its response to the Joint Discovery Plan interrogatory and requests for production in the interpleader action, detailing its claim to the disputed proceeds.
Page 5, 7 — Date: March 9, 2026. LEGALIST SPV III, LP... I hereby certify that on March 9, 2026 a copy of Legalist SPV III, L.P.'s response to the pre-settlement interrogatory providing in the Joint Discovery Plan was served by email on all counsel of record in this case.
CLM-001
Claim
Total Liquidated Claim Amount
Legalist claims a total of $13,204,742.88 in liquidated amounts against the interpleader proceeds. This claim is described as liquidated based on specific sums loaned to or advanced on behalf of Cyberlux pursuant to the Financing Agreement, plus accrued unpaid interest, fees, and attorneys' fees and costs.
Page 2, 3 — Legalist claims $13,204,742.88, comprising of: · $10,033,639.75 principal · $2,653,970.84 unpaid interest · $112,500.00 commitment fee · $53,000.00 forbearance fee · $312,959.79 paid legal fees and costs · $38,672.50 unpaid legal fees and costs. The full amount claimed is liquidated based on specific sums loaned to or advanced on behalf of Cyberlux pursuant to the Financing Agreement, plus accrued unpaid interest, fees, and attorneys' fees and costs.
CLM-002
Claim
Principal Amount Claim
Legalist claims $10,033,639.75 in principal, representing the total advances made to Cyberlux. This includes $6,950,000 advanced under the original revolving line and an additional $3,083,639.75 protective advance made in June 2025.
Page 2, 3 — Legalist claims $13,204,742.88, comprising of: · $10,033,639.75 principal... Legalist has advanced $6,950,000 of the principal amount identified above pursuant to the Financing Agreement. Legalist also advanced $3,083,639.75 pursuant to the financing agreement at Cyberlux's request in June 2025.
CLM-003
Claim
Perfected Security Interest Claim
Legalist claims a perfected security interest in all of Cyberlux's assets and accounts receivable, including all subject proceeds. The security interest was created March 27, 2024 and perfected April 1, 2024 through UCC filings in Nevada and North Carolina.
Page 3, 4 — Legalist has a perfected security interest in Cyberlux's assets and accounts receivable, including all of the subject proceeds. Legalist's secured interest was created on March 27, 2024, by the Financing Agreement and perfected on April 1, 2024, when Legalist filed UCC Statements where Cyberlux is incorporated, Nevada, and where Cyberlux is headquartered, North Carolina.
CLM-004
Claim
Interest Claim
Legalist claims $2,653,970.84 in unpaid interest on the full principal amount, with continuing accrual. The claim to interest is based on paragraphs 9.1, 9.2, and 9.9(a) of the Financing Agreement.
Page 2, 4 — · $2,653,970.84 unpaid interest... Legalist claims interest on the full principle, pursuant to paragraphs 9.1, 9.2, and 9.9(a) of the Financing Agreement.
CLM-005
Claim
Attorney Fees and Costs Claim
Legalist claims a right to attorney fees and costs pursuant to paragraph 28 of the Financing Agreement. For settlement conference purposes, Legalist claims $351,632.29 total ($312,959.79 paid plus $38,672.50 unpaid), with the amount expected to increase if litigation continues.
Page 2, 3, 4 — · $312,959.79 paid legal fees and costs · $38,672.50 unpaid legal fees and costs... Legalist claims a right to attorney fees and costs, pursuant to paragraph 28 of the Financing Agreement. For the purposes of the upcoming settlement conference Legalist claims legal fees and costs of $351,632.29, although this amount will increase if this litigation continues beyond the settlement conference.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
8 nodes
QUO-001
Quotation
UCC Priority Date Statutory Basis
Legalist cites specific Virginia, Nevada, and North Carolina UCC statutes establishing the legal framework for its security interest perfection and priority: Va. Code Ann. §§ 8.9A-310, 8.9A-307(b); Nev. Rev. Stat. Ann. §§ 104.9310, 104.9307; N.C. Gen. Stat. §§ 25-9-310, 25-9-307.
Page 4 — Va. Code Ann. §§ 8.9A-310, 8.9A-307(b); see also Nev. Rev. Stat. Ann. §§ 104.9310, 104.9307; N.C. Gen. Stat. §§ 25-9-310, 25-9-307.
TLL-001
Tell
Application of Initial Advance to Legal Fees
A footnote reveals that the June 2025 protective advance was initially $3,100,100.10, but $16,460.35 was applied to Legalist's legal fees, resulting in the net $3,083,639.75 principal amount claimed.
Page 5 — The final two entries covered the $3,083,639.75 protective advance Legalist made on behalf of Cyberlux. Legalist initially advanced $3,100,100.10, and the $16,460.35 difference was applied to its legal fees.
TLL-002
Tell
Commitment and Forbearance Fees Structure
The claim breakdown separately itemizes a $112,500 commitment fee and a $53,000 forbearance fee, suggesting distinct contractual events. The forbearance fee amount matches one of the July 2024 advances ($53,000 on 7/5/2024), potentially indicating a restructuring or accommodation event.
Page 2, 3, 4 — · $112,500.00 commitment fee · $53,000.00 forbearance fee... The Financing Agreement also provides for Legalist's right to interest (paragraphs 9.1, 9.2, and 9.9(a)), commitment fees (paragraph 9.4), forbearance fees (paragraph 9.9(b)), and attorney fees and costs (paragraph 29).
TEN-001
Tension
June 2025 Protective Advance Timing
The June 2025 protective advance of $3,083,639.75 occurs nearly fourteen months after the initial financing and represents approximately 44% of the total principal claimed. This significant late-stage advance at Cyberlux's request suggests deteriorating financial conditions and raises questions about whether this was a defensive move to protect Legalist's position or new value provided to a struggling borrower.
Page 3, 5 — Legalist also advanced $3,083,639.75 pursuant to the financing agreement at Cyberlux's request in June 2025... · 6/3/2025: $2,755,100.10 · 6/9/2025: $345,000.00
TEN-002
Tension
Revolving Line Limit vs. Actual Advances
The Financing Agreement provided a $7,000,000 revolving line of credit, yet Legalist advanced $6,950,000 under this facility and then an additional $3,083,639.75 in June 2025. The total principal of $10,033,639.75 significantly exceeds the stated revolving line amount, indicating either a modification of terms, exercise of overadvance provisions, or a separate financing mechanism.
Page 3 — Legalist entered into a Second Amended and Restated Government Purchase Order Financing Agreement ("Financing Agreement") with Cyberlux, whereby Legalist provided a revolving line of credit in the amount of $7,000,000.00... Legalist has advanced $6,950,000 of the principal amount identified above pursuant to the Financing Agreement. Legalist also advanced $3,083,639.75 pursuant to the financing agreement at Cyberlux's request in June 2025.
QST-001
Question
Nature of Competing Claims in Interpleader
The document identifies this as an interpleader action with multiple claimants (Cyberlux Corporation, et al.) competing for proceeds held by HII Mission Technologies Corp., but provides no detail on the other claimants' identities, claim amounts, or legal theories. Who are the other claimants and what is the total amount of proceeds being disputed?
Page 2 — HII MISSION TECHNOLOGIES CORP., Interpleader Plaintiff, V. CYBERLUX CORPORATION, et al., Interpleader Defendants/Claimants... Explain the nature of your claim to any of the proceeds that are the subject of this interpleader
QST-002
Question
Source of Interpleader Proceeds
The document refers to 'proceeds that are the subject of this interpleader' but never identifies what these proceeds represent. Given the reference to 'Government Purchase Order Financing Agreement' and HII Mission Technologies as holder, are these proceeds from government contracts or purchase orders that Cyberlux had with HII or a related entity?
Page 2, 3 — Explain the nature of your claim to any of the proceeds that are the subject of this interpleader... Second Amended and Restated Government Purchase Order Financing Agreement... secured by certain collateral, including accounts receivable.
QST-003
Question
Status of Cyberlux Financial Condition
The pattern of advances, including a substantial June 2025 protective advance, forbearance fees, and the existence of competing creditor claims in interpleader, suggests financial distress. Is Cyberlux in bankruptcy, receivership, or another formal insolvency proceeding, or is this interpleader the sole mechanism for resolving creditor disputes?
Page 2, 3, 5 — · $53,000.00 forbearance fee... Legalist also advanced $3,083,639.75 pursuant to the financing agreement at Cyberlux's request in June 2025... The final two entries covered the $3,083,639.75 protective advance Legalist made on behalf of Cyberlux.
Stage 4
Interpretive — Inferences, Omissions, Patterns
6 nodes
INF-001
Inference
Strategic Timing of UCC Filing
The five-day gap between executing the Financing Agreement (March 27, 2024) and filing UCC Statements (April 1, 2024) suggests deliberate timing. Filing occurred on April 1 and the first advance was made on April 9, establishing perfection before any value was transferred. This sequence protects Legalist's priority against any intervening creditors during the gap period.
Page 3, 4 — On March 27, 2024, Legalist entered into a Second Amended and Restated Government Purchase Order Financing Agreement... on April 1, 2024, Legalist filed certain financing statements under the Uniform Commercial Code... Legalist made advances under the Financing Agreement on the following dates: · 4/9/2024: $1,800,000.00
INF-002
Inference
Escalating Advance Pattern Indicates Distress
The advance pattern shows initial caution ($1.8M first advance) followed by a large $2.5M advance in July 2024, then smaller amounts through October 2024, culminating in the massive June 2025 protective advance. This pattern suggests Cyberlux's financial condition deteriorated significantly between October 2024 and June 2025, requiring emergency financing that Legalist characterized as 'protective' to preserve its collateral position.
Page 4, 5 — Legalist made advances under the Financing Agreement on the following dates: · 4/9/2024: $1,800,000.00... · 7/16/2024: $2,500,000.00... · 10/3/2024: $150,000.00 · 10/3/2024: $120,000.00 · 6/3/2025: $2,755,100.10 · 6/9/2025: $345,000.00... The final two entries covered the $3,083,639.75 protective advance Legalist made on behalf of Cyberlux.
INF-003
Inference
Interest Calculation Suggests Default
The unpaid interest of $2,653,970.84 on principal of $10,033,639.75 represents approximately 26.4% of principal. Given the timeline from first advance (April 2024) to filing (March 2026), this suggests either a very high default interest rate or that interest began accruing on unpaid amounts at an accelerated rate following a default event, likely triggering the forbearance fee as well.
Page 2, 4 — · $10,033,639.75 principal · $2,653,970.84 unpaid interest... · $53,000.00 forbearance fee... Legalist claims interest on the full principle, pursuant to paragraphs 9.1, 9.2, and 9.9(a) of the Financing Agreement.
OMI-001
Omission
No Reference to Amendment Provisions
The document refers to a 'Second Amended and Restated' Financing Agreement, indicating at least two prior versions, but provides no information about when these prior agreements were executed, what terms they contained, or what changes were made. This history may be relevant to priority disputes if other creditors had relationships with Cyberlux under earlier agreements.
Page 3 — On March 27, 2024, Legalist entered into a Second Amended and Restated Government Purchase Order Financing Agreement ("Financing Agreement") with Cyberlux
OMI-002
Omission
No Discussion of Proceeds Amount
While Legalist claims $13,204,742.88, the document never states the total amount of proceeds held by HII Mission Technologies that are the subject of the interpleader. If proceeds are less than Legalist's claim, this would necessitate allocation among creditors, but the document is silent on whether Legalist expects full payment or partial recovery.
Page 2 — Legalist claims $13,204,742.88, comprising of: · $10,033,639.75 principal · $2,653,970.84 unpaid interest · $112,500.00 commitment fee · $53,000.00 forbearance fee · $312,959.79 paid legal fees and costs · $38,672.50 unpaid legal fees and costs
OMI-003
Omission
No Explanation of Protective Advance Authority
The June 2025 'protective advance' exceeded the stated $7M revolving line by over $3M, but the document does not explain what contractual provision authorized this overadvance or whether it required Cyberlux consent beyond the stated 'request.' This omission leaves unclear whether Legalist had unilateral authority to advance additional funds and secure them.
Page 3 — Legalist entered into a Second Amended and Restated Government Purchase Order Financing Agreement ("Financing Agreement") with Cyberlux, whereby Legalist provided a revolving line of credit in the amount of $7,000,000.00... Legalist also advanced $3,083,639.75 pursuant to the financing agreement at Cyberlux's request in June 2025.

Extracted text

7 pages · 7585 characters

Exhibit 2 — Formatted Extract

Type: exhibit
Court: EDVA
Matter: HII v. Cyberlux interpleader
Docket: 3:25-cv-00483
EXHIBIT 2

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION

HII MISSION TECHNOLOGIES CORP.,

Interpleader Plaintiff,

V. CYBERLUX CORPORATION, et al.,

Interpleader Defendants/Claimants.

Civil Action No. 3:25-cv-483-JAG

LEGALIST SPV III, LP'S RESPONSE TO JOINT DISCOVERY PLAN INTERROGATORY AND REQUESTS FOR PRODUCTION

Interpleader Defendant/Claimant Legalist SPV III, LP ("Legalist"), provides the following response to the pre-settlement interrogatory and requests for production providing in the Joint Discovery Plan (ECF No. 149).

Interrogatory

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.

Response:

(a) the amount of the proceeds that you claim

Legalist claims $13,204,742.88, comprising of:

· $10,033,639.75 principal

· $2,653,970.84 unpaid interest

· $112,500.00 commitment fee

· $53,000.00 forbearance fee

· $312,959.79 paid legal fees and costs

· $38,672.50 unpaid legal fees and costs

(b) the legal basis for your right to the proceeds

On March 27, 2024, Legalist entered into a Second Amended and Restated Government Purchase Order Financing Agreement ("Financing Agreement") with Cyberlux, whereby Legalist provided a revolving line of credit in the amount of $7,000,000.00 secured by certain collateral, including accounts receivable. Legalist has advanced $6,950,000 of the principal amount identified above pursuant to the Financing Agreement. Legalist also advanced $3,083,639.75 pursuant to the financing agreement at Cyberlux's request in June 2025. The Financing Agreement also provides for Legalist's right to interest (paragraphs 9.1, 9.2, and 9.9(a)), commitment fees (paragraph 9.4), forbearance fees (paragraph 9.9(b)), and attorney fees and costs (paragraph 29). Pursuant to the Financing Agreement, on April 1, 2024, Legalist filed certain financing statements under the Uniform Commercial Code ("UCC Statements") in Nevada and North Carolina identifying and perfecting its lien on Cyberlux's assets, including its accounts receivable.

(c) how the amount you claim became a liquidated amount or, if not liquidated, state so

The full amount claimed is liquidated based on specific sums loaned to or advanced on behalf of Cyberlux pursuant to the Financing Agreement, plus accrued unpaid interest, fees, and attorneys' fees and costs.

(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

Legalist has a perfected security interest in Cyberlux's assets and accounts receivable, including all of the subject proceeds. Legalist's secured interest was created on March 27, 2024,

by the Financing Agreement and perfected on April 1, 2024, when Legalist filed UCC Statements where Cyberlux is incorporated, Nevada, and where Cyberlux is headquartered, North Carolina. Va. Code Ann. §§ 8.9A-310, 8.9A-307(b); see also Nev. Rev. Stat. Ann. §§ 104.9310, 104.9307; N.C. Gen. Stat. §§ 25-9-310, 25-9-307.

(e) whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any

Legalist claims interest on the full principle, pursuant to paragraphs 9.1, 9.2, and 9.9(a) of the Financing Agreement.

(f) whether you claim a right to attorneys' fees and, if so, the basis therefore and the amount you will claim

Legalist claims a right to attorney fees and costs, pursuant to paragraph 28 of the Financing Agreement. For the purposes of the upcoming settlement conference Legalist claims legal fees and costs of $351,632.29, although this amount will increase if this litigation continues beyond the settlement conference.

(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

All advances Legalist has made to Cyberlux are secured by the UCC Statements with a priority date of April 1, 2024, when the UCC Statements were filed. Legalist made advances under the Financing Agreement on the following dates:

· 4/9/2024: $1,800,000.00

· 4/19/2024: $500,000.00

· 5/2/2024: $500,000.00

· 6/26/2024: $142,000.00

· 7/5/2024: $53,000.00

· 7/16/2024: $2,500,000.00

· 8/2/2024: $650,000.00

· 8/27/2024: $535,000.00

· 10/3/2024: $150,000.00

· 10/3/2024: $120,000.00

· 6/3/2025: $2,755,100.10

· 6/9/2025: $345,000.001

Requests for Production

1.
Documents supporting or otherwise concerning your answer to the above interrogatory.

Response:

See the documents produced at Bates Nos. LEGALIST_000001-20.

2.
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:

See the documents produced at Bates Nos. LEGALIST_000001-20.

Date: March 9, 2026

LEGALIST SPV III, LP By: PhM. ECula

Timothy G. Moore (VSB No. 41730) tmoore@spottsfain.com John M. Erbach (VSB No. 76695) jerbach@spottsfain.com Christopher W. Bascom (VSB No. 87302) cbascom@spottsfain.com Spotts Fain, P.C. 411 E. Franklin Street, Suite 600 Richmond, VA 23219 (804) 697-2065 (804) 697-2165 Fax

Jeff. P Prostok (admitted pro hac vice)

1
The final two entries covered the $3,083,639.75 protective advance Legalist made on behalf of Cyberlux. Legalist initially advanced $3,100,100.10, and the $16,460.35 difference was applied to its legal fees.

Jeff.Prostok@vhh.law Austin N. Priddy (admitted pro hac vice) austin.priddy@vhh.law Vartabedian Hester & Haynes LLP 301 Commerce Street, Suite 2200 Fort Worth, Texas 76102 Tel. (817) 214-4990 Fax (817) 214-4988

ATTORNEYS FOR LEGALIST SPV III, L.P.

CERTIFICATE OF SERVICE

I hereby certify that on March 9, 2026 a copy of Legalist SPV III, L.P.'s response to the pre-settlement interrogatory providing in the Joint Discovery Plan was served by email on all counsel of record in this case.

Ph M. ECul

Timothy G. Moore (VSB No. 41730) tmoore@spottsfain.com John M. Erbach (VSB No. 76695) jerbach@spottsfain.com Christopher W. Bascom (VSB No. 87302) cbascom@spottsfain.com Spotts Fain, P.C. 411 E. Franklin Street, Suite 600 Richmond, VA 23219 (804) 697-2065 (804) 697-2165 Fax

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ip-hii-edva-00483-doc-0183-exhibit-2.pdf
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2bdaafa17c9f059be350bed19c0affcbfa8039ab14575bca75475bdc86f716b8