Evidence Record

Declaration of Charles a. Gavin, Counsel for Atlantic Wave Holdings, LLC and Secure Community, LLC

1. Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and this...

Type
declaration
Court
EDVA
Case
HII v. Cyberlux interpleader
Docket
3:25-cv-00483
Pages
3
Lines
104
SHA-256
98323bfc6e96

DISTIL analysis

DISTIL Run
Profile
Standard
Version
1
Doc Type
court_declaration
Total Nodes
42
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_declaration counsel_for_interpleader_defendants interpleader_litigation_garnishment_procedures 2024-2025
service_defects_allegedmultiple_garnishmentsreceivership_authority_issuejudgment_enforcement_disputes
Analytical Frame
procedural_compliance_verification
Analytical Summary
This declaration by Charles A. Gavin, counsel for Atlantic Wave Holdings, LLC and Secure Community, LLC, documents alleged procedural defects in garnishment and writ execution processes initiated by ANPC. Gavin asserts through personal investigation that writs of fieri facias were never properly served on sheriffs in Richmond or Fairfax, and that garnishment documents failed to reflect proper service on judgment debtors. The declaration references multiple related litigation matters across Virginia, North Carolina, and Colorado involving various parties including Cyberlux, ARG, and Thin Air Group. Critical issues include whether a Receiver had authority to resolve claims and whether judgment enforcement procedures complied with Virginia law.
Key Points
  • Counsel personally verified Richmond Circuit Court clerk records show no evidence Writ of Fieri Facias was received or served on Richmond Sheriff
  • Fairfax garnishment file lacks documentation of writ issuance to Fairfax Sheriff; Deputy Sheriff confirmed only garnishment summons received
  • Garnishment documents do not reflect proper service on judgment debtor or execution delivery date
  • Consent Final Order in Richmond case CL24-3910 ruled Receiver Robert Berleth had authority to resolve litigation claim
  • Multiple related cases span Virginia, North Carolina, and Colorado involving Cyberlux, ARG, Thin Air Group, and Catalyst Machineworks
Stage 2
Core — Entities, Events, Claims
24 nodes
ENT-001
Entity
Charles A. Gavin
Attorney licensed in Commonwealth of Virginia, admitted to practice in state and federal court, in practice since 1990, representing Atlantic Wave Holdings LLC and Secure Community LLC in interpleader litigation
Page 1 — Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar with the claims, documents, and information provided to date in the Interpleader.
ENT-002
Entity
Atlantic Wave Holdings, LLC
Interpleader defendant/claimant in case 3:25cv483, represented by Charles A. Gavin
Page 1 — ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC
ENT-003
Entity
Secure Community, LLC
Interpleader defendant/claimant in case 3:25cv483, represented by Charles A. Gavin alongside Atlantic Wave Holdings
Page 1 — DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC
ENT-004
Entity
HII Mission Technologies Corp.
Interpleader plaintiff in case 3:25cv483 in United States District Court for Eastern District of Virginia
Page 1 — HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, V. Case Number: 3:25cv483
ENT-005
Entity
ANPC
Party that requested Writ of Fieri Facias from Richmond Circuit Court and initiated garnishment proceedings in Fairfax
Page 1 — A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained from the City of Richmond Circuit Court is attached hereto as Exhibit A-1. A true and correct copy of ANPC's cover letter to the Circuit Court of the City of Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
ENT-006
Entity
Robert Berleth
Receiver who had authority under Receivership Order to resolve litigation claim in Richmond Circuit case CL24-3910
Page 2 — The Consent Final Order entered in the Richmond Circuit case number CL24-3910 includes a ruling that the Receiver, Robert Berleth, had the authority under the Receivership Order to resolve the litigation claim in CL24-3910.
ENT-007
Entity
Cyberlux (CYBL)
Entity involved in litigation with ARG in North Carolina and Thin Air Group in Colorado; COO sent Creditor Certification Form to HII
Page 2, 3 — The Answer of CYBL to ARG's Complaint in North Carolina is attached hereto as Exhibit A-7. A copy of the Complaint filed by Thin Air Group in Colorado against Cyberlux is attached hereto as Exhibit A-8. A copy of the Creditor Certification Form mailed by Cyberlux' COO to HII dated May 30, 2025ii is attached hereto as Exhibit A-12
ENT-008
Entity
ARG
Entity that filed complaint against Cyberlux in North Carolina
Page 2 — A copy of the Complaint filed by ARG in North Carolina is attached hereto as Exhibit A-6. The Answer of CYBL to ARG's Complaint in North Carolina is attached hereto as Exhibit A-7.
ENT-009
Entity
Thin Air Group
Entity that filed complaint against Cyberlux in Colorado and obtained default judgment with final order
Page 3 — A copy of the Complaint filed by Thin Air Group in Colorado against Cyberlux is attached hereto as Exhibit A-8. A copy of the Final Order entered in the Colorado case is attached hereto as Exhibit A-9. A copy of the Affidavit of Thin Air Group to obtain default judgment is attached hereto as Exhibit A-10.
ENT-010
Entity
Catalyst Machineworks LLC
Entity that was terminated according to certificate referenced in declaration
Page 3 — A copy of the Certificate of Termination of Catalyst Machineworks LLC is attached hereto as A-11
EVT-001
Event
Personal review of Richmond Circuit Court records
Counsel Charles Gavin personally reviewed record at City of Richmond Circuit Court clerk's office finding no evidence Writ of Fieri Facias was received by or served on Richmond Sheriff
Page 1 — Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
EVT-002
Event
Personal conversation with Fairfax Deputy Sheriff
Defense counsel personally spoke with Deputy Sheriff in County of Fairfax Sheriff's Office who advised Sheriff only received garnishment summons and did not receive Writ of Fieri Facias from ANPC or Clerk
Page 2 — Defense counsel personally spoke with a Deputy Sheriff in the County of Fairfax Sheriff's Office who advised that the Sheriff only received the garnishment summons, and did not receive a Writ of Fieri Facias from ANPC or the Clerk.
EVT-003
Event
ANPC request for Writ of Fieri Facias
ANPC requested Writ of Fieri Facias from City of Richmond Circuit Court, obtained true and correct copy along with cover letter to Circuit Court
Page 1 — A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained from the City of Richmond Circuit Court is attached hereto as Exhibit A-1. A true and correct copy of ANPC's cover letter to the Circuit Court of the City of Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
EVT-004
Event
Entry of Consent Final Order in Richmond CL24-3910
Consent Final Order entered in Richmond Circuit case CL24-3910 ruling that Receiver Robert Berleth had authority under Receivership Order to resolve litigation claim
Page 2 — The Consent Final Order entered in the Richmond Circuit case number CL24-3910 includes a ruling that the Receiver, Robert Berleth, had the authority under the Receivership Order to resolve the litigation claim in CL24-3910.
EVT-005
Event
ARG complaint filing in North Carolina
ARG filed complaint in North Carolina against Cyberlux, to which CYBL filed an answer
Page 2 — A copy of the Complaint filed by ARG in North Carolina is attached hereto as Exhibit A-6. The Answer of CYBL to ARG's Complaint in North Carolina is attached hereto as Exhibit A-7.
EVT-006
Event
Thin Air Group Colorado litigation
Thin Air Group filed complaint against Cyberlux in Colorado, obtained default judgment with affidavit, and received final order
Page 3 — A copy of the Complaint filed by Thin Air Group in Colorado against Cyberlux is attached hereto as Exhibit A-8. A copy of the Final Order entered in the Colorado case is attached hereto as Exhibit A-9. A copy of the Affidavit of Thin Air Group to obtain default judgment is attached hereto as Exhibit A-10.
EVT-007
Event
Cyberlux COO submission to HII
Cyberlux Chief Operating Officer mailed Creditor Certification Form to HII dated May 30, 2025
Page 3 — A copy of the Creditor Certification Form mailed by Cyberlux' COO to HII dated May 30, 2025ii is attached hereto as Exhibit A-12
CLM-001
Claim
Richmond writ never served on Sheriff
Richmond Circuit Court records do not reflect that Writ of Fieri Facias issued by clerk was ever received by or served on Sheriff of City of Richmond
Page 1 — Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
CLM-002
Claim
Fairfax garnishment lacks service documentation
Review of Fairfax Circuit Court garnishment file does not reflect acknowledgment that garnishment documents were mailed to judgment debtor or that judgment debtor was served
Page 2 — A review of the Fairfax Circuit Court garnishment file does not reflect on the return an acknowledgment that the garnishment documents were mailed to the judgment debtor, or that the judgment debtor was served.
CLM-003
Claim
Fairfax file lacks writ request documentation
Review of Fairfax garnishment 2302516055 file does not reflect request for issuance of Writ of Fieri Facias to be generated by Circuit Court Clerk for service or placement with Sheriff of Fairfax County
Page 2 — A review of Fairfax garnishment 2302516055 file does not reflect the request of the issuance of a Writ of Fieri Facias to be generated by the Circuit Court Clerk for service or placement with the Sheriff of Fairfax County.
CLM-004
Claim
Cover letter lacks writ service request
Cover letter forwarded to clerk pursuant to garnishment issuance does not reflect request for service of any Writ of Fieri Facias on Sheriff of Fairfax County
Page 2 — The cover letter forwarded to the clerk pursuant to the garnishment issuance does not reflect a request for service of any Writ of Fieri Facias on the Sheriff of Fairfax County.
CLM-005
Claim
Fairfax Sheriff only received garnishment summons
Deputy Sheriff in Fairfax County Sheriff's Office advised that Sheriff only received garnishment summons and did not receive Writ of Fieri Facias from ANPC or Clerk
Page 2 — Defense counsel personally spoke with a Deputy Sheriff in the County of Fairfax Sheriff's Office who advised that the Sheriff only received the garnishment summons, and did not receive a Writ of Fieri Facias from ANPC or the Clerk.
CLM-006
Claim
Docket sheet lacks writ issuance record
Fairfax garnishment docket sheet does not reflect issuance of Writ of Fieri Facias to Sheriff or return of the writ
Page 2 — The Fairfax garnishment docket sheet does not reflect issuance of a Writ of Fieri Facias to the Sheriff or a return of the writ.
CLM-007
Claim
Garnishment suggestion lacks execution date
Suggestion for summons of garnishment reflects original judgment date as August 21, 2025, but does not reflect date of execution delivery
Page 2 — The suggestion for summons of garnishment attached hereto reflects the original judgment date as August 21, 2025, but does not reflect a date of execution delivery.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
12 nodes
QUO-001
Quotation
Declarant identification and qualifications
Gavin identifies himself as attorney licensed in Virginia, admitted to state and federal practice since 1990, representing AWH and SC in interpleader
Page 1 — Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar with the claims, documents, and information provided to date in the Interpleader.
QUO-002
Quotation
Personal investigation foundation
Gavin states all related declarations are based on his personal investigation or documents he personally gathered and reviewed
Page 1 — All related declarations contained herein are based on my personal investigation or documents gathered and reviewed by me personally.
QUO-003
Quotation
Perjury attestation
Gavin declares statement true under penalty of perjury
Page 3 — I declare the above to be true under the penalty of perjury.
TLL-001
Tell
Richmond clerk records show no writ receipt
Physical examination of Richmond Circuit Court clerk's office records revealed absence of documentation showing writ was received by or served on Richmond Sheriff
Page 1 — Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
TLL-002
Tell
Deputy Sheriff oral confirmation of limited receipt
Fairfax Deputy Sheriff verbally advised defense counsel in personal conversation that only garnishment summons was received, not writ
Page 2 — Defense counsel personally spoke with a Deputy Sheriff in the County of Fairfax Sheriff's Office who advised that the Sheriff only received the garnishment summons, and did not receive a Writ of Fieri Facias from ANPC or the Clerk.
TEN-001
Tension
Writ issued but never delivered to enforcement authority
Richmond Circuit Court clerk issued Writ of Fieri Facias, yet records show no evidence it was received by or served on the Sheriff responsible for executing it
Page 1 — Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
TEN-002
Tension
Judgment date documented but execution delivery date missing
Garnishment suggestion records original judgment date of August 21, 2025, but lacks any documentation of when execution was delivered for enforcement
Page 2 — The suggestion for summons of garnishment attached hereto reflects the original judgment date as August 21, 2025, but does not reflect a date of execution delivery.
TEN-003
Tension
Garnishment file silent on judgment debtor service
Fairfax garnishment file contains no acknowledgment that garnishment documents were mailed to or served on judgment debtor, despite proceeding through court system
Page 2 — A review of the Fairfax Circuit Court garnishment file does not reflect on the return an acknowledgment that the garnishment documents were mailed to the judgment debtor, or that the judgment debtor was served.
QST-001
Question
What happened to Richmond writ after issuance?
If Richmond Circuit Court clerk issued the Writ of Fieri Facias as documented, what happened to it between issuance and the point it should have reached the Richmond Sheriff? Was it lost, never transmitted, or improperly documented?
Page 1 — Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
QST-002
Question
Was Fairfax writ ever requested from clerk?
Did ANPC or counsel actually request that Fairfax Circuit Court Clerk generate a Writ of Fieri Facias for service, or was only garnishment summons sought? File and cover letter both silent on writ request.
Page 2 — A review of Fairfax garnishment 2302516055 file does not reflect the request of the issuance of a Writ of Fieri Facias to be generated by the Circuit Court Clerk for service or placement with the Sheriff of Fairfax County. The cover letter forwarded to the clerk pursuant to the garnishment issuance does not reflect a request for service of any Writ of Fieri Facias on the Sheriff of Fairfax County.
QST-003
Question
Was judgment debtor served in Fairfax garnishment?
Fairfax garnishment file lacks acknowledgment of service on judgment debtor. Was service attempted and failed, was it accomplished through means not reflected in the file, or was this procedural step omitted?
Page 2 — A review of the Fairfax Circuit Court garnishment file does not reflect on the return an acknowledgment that the garnishment documents were mailed to the judgment debtor, or that the judgment debtor was served.
QST-004
Question
What is relationship between receivership authority and garnishments?
Consent Final Order ruled Receiver Berleth had authority to resolve litigation claim in CL24-3910. Does this receivership authority affect validity of ANPC's garnishment proceedings or create competing claims?
Page 2 — The Consent Final Order entered in the Richmond Circuit case number CL24-3910 includes a ruling that the Receiver, Robert Berleth, had the authority under the Receivership Order to resolve the litigation claim in CL24-3910.
Stage 4
Interpretive — Inferences, Omissions, Patterns
6 nodes
INF-001
Inference
Service defects appear systematic not isolated
Multiple alleged service defects across two jurisdictions (Richmond writ not reaching Sheriff, Fairfax lacking writ request and debtor service documentation, Deputy Sheriff confirmation) suggest systematic procedural problems rather than isolated clerical errors
Page 1, 2 — Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond. Defense counsel personally spoke with a Deputy Sheriff in the County of Fairfax Sheriff's Office who advised that the Sheriff only received the garnishment summons, and did not receive a Writ of Fieri Facias from ANPC or the Clerk.
INF-002
Inference
Declaration challenges ANPC judgment enforcement validity
By documenting multiple procedural defects in writ service and garnishment procedures, declaration appears designed to challenge validity of ANPC's judgment enforcement efforts and potentially priority of claims in interpleader
Page 1 — DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC... Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
INF-003
Inference
Multi-state litigation suggests complex creditor disputes
Presence of related litigation in Virginia, North Carolina, and Colorado involving Cyberlux, ARG, Thin Air Group, and multiple garnishments suggests complex web of creditor claims and competing interests underlying interpleader action
Page 2, 3 — A copy of the Complaint filed by ARG in North Carolina is attached hereto as Exhibit A-6. A copy of the Complaint filed by Thin Air Group in Colorado against Cyberlux is attached hereto as Exhibit A-8. A copy of the Final Order entered in the Colorado case is attached hereto as Exhibit A-9.
OMI-001
Omission
No explanation for service documentation gaps
Declaration identifies multiple instances where required service documentation is absent from court files but does not offer or explore explanations for these gaps beyond asserting they do not exist in reviewed records
Page 1, 2 — Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond. A review of the Fairfax Circuit Court garnishment file does not reflect on the return an acknowledgment that the garnishment documents were mailed to the judgment debtor, or that the judgment debtor was served.
OMI-002
Omission
Limited detail on Receiver authority implications
Declaration references Consent Final Order ruling that Receiver Berleth had authority to resolve litigation claim in CL24-3910 but does not explain how this authority relates to ANPC garnishment proceedings or interpleader claims
Page 2 — The Consent Final Order entered in the Richmond Circuit case number CL24-3910 includes a ruling that the Receiver, Robert Berleth, had the authority under the Receivership Order to resolve the litigation claim in CL24-3910.
OMI-003
Omission
No context for multi-state litigation relationships
Declaration lists multiple related cases in North Carolina and Colorado involving Cyberlux, ARG, and Thin Air Group but does not explain how these cases relate to the Virginia interpleader or why they are relevant to service defect claims
Page 2, 3 — A copy of the Complaint filed by ARG in North Carolina is attached hereto as Exhibit A-6. The Answer of CYBL to ARG's Complaint in North Carolina is attached hereto as Exhibit A-7. A copy of the Complaint filed by Thin Air Group in Colorado against Cyberlux is attached hereto as Exhibit A-8.

Extracted text

3 pages · 4619 characters

Declaration of Charles a. Gavin, Counsel for Atlantic Wave Holdings, LLC and Secure Community, LLC — Formatted Extract

Type: declaration
Court: EDVA
Matter: HII v. Cyberlux interpleader
Docket: 3:25-cv-00483
Filing Header

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, V.

Case Number: 3:25cv483

ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.

DECLARATION OF CHARLES A. GAVIN, COUNSEL FOR ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC
1.
Your Declarant is Charles A. Gavin. I am greater than 21 years of age. I am an attorney licensed in the Commonwealth of Virginia and admitted to practice in state court and this court. Counsel has been in practice since 1990. I represent AWH and SC and am familiar with the claims, documents, and information provided to date in the Interpleader.
2.
All related declarations contained herein are based on my personal investigation or documents gathered and reviewed by me personally.
3.
A true and correct copy of a Writ of Fieri Facias requested by ANPC and obtained from the City of Richmond Circuit Court is attached hereto as Exhibit A-1.
4.
A true and correct copy of ANPC's cover letter to the Circuit Court of the City of Richmond as obtained from the clerk's office is attached hereto as Exhibit A-2.
5.
Counsel has personally reviewed the record at the City of Richmond Circuit Court clerk's office and it does not reflect that the Writ of Fieri Facias issued by the Richmond Circuit Court clerk was ever received by, or served on, the Sheriff of the City of Richmond.
6.
A copy of the Suggestion for Garnishment, the Garnishment Summons, the service return for the garnishment, the docket sheet for the garnishment, the filing cover letter to the clerk, and the Final Order in the Circuit Court of Fairfax in garnishment CL2025-16055 are attached hereto as Exhibit A-3.
7.
The suggestion for summons of garnishment attached hereto reflects the original judgment date as August 21, 2025, but does not reflect a date of execution delivery.
8.
A review of the Fairfax Circuit Court garnishment file does not reflect on the return an acknowledgment that the garnishment documents were mailed to the judgment debtor, or that the judgment debtor was served.
9.
A review of Fairfax garnishment 2302516055 file does not reflect the request of the issuance of a Writ of Fieri Facias to be generated by the Circuit Court Clerk for service or placement with the Sheriff of Fairfax County.
10.
The cover letter forwarded to the clerk pursuant to the garnishment issuance does not reflect a request for service of any Writ of Fieri Facias on the Sheriff of Fairfax County.
11.
Defense counsel personally spoke with a Deputy Sheriff in the County of Fairfax Sheriff's Office who advised that the Sheriff only received the garnishment summons, and did not receive a Writ of Fieri Facias from ANPC or the Clerk.
12.
The Fairfax garnishment docket sheet does not reflect issuance of a Writ of Fieri Facias to the Sheriff or a return of the writ. A-4
13.
The Consent Final Order entered in the Richmond Circuit case number CL24- 3910 includes a ruling that the Receiver, Robert Berleth, had the authority under the Receivership Order to resolve the litigation claim in CL24-3910. A-5, See Will Welter 179-11, Declaration #25 (Exhibit 9).
14.
A copy of the Complaint filed by ARG in North Carolina is attached hereto as Exhibit A-6.
15.
The Answer of CYBL to ARG's Complaint in North Carolina is attached hereto as Exhibit A-7.
16.
A copy of the Complaint filed by Thin Air Group in Colorado against Cyberlux is attached hereto as Exhibit A-8.
17.
A copy of the Final Order entered in the Colorado case is attached hereto as Exhibit A-9.
18.
A copy of the Affidavit of Thin Air Group to obtain default judgment is attached hereto as Exhibit A-10.
19.
A copy of the Certificate of Termination of Catalyst Machineworks LLC is attached hereto as A-11
20.
A copy of the Creditor Certification Form mailed by Cyberlux' COO to HII dated May 30, 2025ii is attached hereto as Exhibit A-12
21.
A copy of an Order entered in AWH Fairfax garnishment CL2025-3413 is attached hereto A-13.

I declare the above to be true under the penalty of perjury.

Respectfully Submitted

ATLANTIC WAVE, LLC and SECURE COMMUNITY, LLC

BY: Charles A. Gavin, VSB#31391 Gavin Law, PLC Counsel for Atlantic Wave Holdings, LLC and Secure Community, LLC 14321 Winter Breeze Dr., Suite 136 Midlothian, Virginia 23113 (804) 606-7702 (804) 606-7704 Facsimile cgavin@gavinlawplc.com

Original source file

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File
ip-hii-edva-00483-doc-0197-exhibit-1.pdf
Source UID
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Full SHA-256
98323bfc6e960bbef79659be67eee0f172be8694a581e4a6cd2a599378f1defd