Evidence Record
IP HII EDVA 00483 Doc. 0197 Exhibit 15
1. My name is William Welter and I am over the age of 21 years and competent.
DISTIL analysis
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1
Doc Type
Declaration
Total Nodes
33
Node Legend
Entity (ENT)
Event (EVT)
Claim (CLM)
Anchor (ANC)
Omission (OMI)
Tension (TEN)
Tell (TEL)
Inference (INF)
Hypothesis (HYP)
Stage 1
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Document Classification
Declaration William Welter, Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC Federal interpleader litigation involving contract dispute, government subcontract termination, and creditor claims 2022-2026 (litigation period); key events: December 22, 2023 (stop work order), May 17, 2024 (termination), April 22, 2026 (declaration date)
sanctions_grantedmultiple_jurisdictionsgovernment_contract_terminationcreditor_standing_challengeotc_filing_discrepancies
Analytical Frame
Sworn testimony establishing factual basis for summary judgment motion, challenging creditor standing through corporate filing analysis
Analytical Summary
William Welter, Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC, provides sworn testimony in federal interpleader litigation involving Cyberlux Corporation and HII Mission Technologies Corp. Welter establishes his role in multi-jurisdictional enforcement actions against Cyberlux since 2022, noting that courts granted more than four sanctions against Cyberlux across unsuccessful removal attempts and appeals. Critical factual assertions include government issuance of a stop work order on December 22, 2023, and HII's termination of the subcontract on May 17, 2024. Welter's analysis of Cyberlux's mandatory quarterly OTC filings reveals that Fairwinds, ARG, and WeShield parties were not designated as debt holders in any quarter prior to the interpleader action, with WeShield mentioned only after litigation commenced, challenging the standing of these claimants in the current proceedings.
Key Points
- William Welter serves as Managing Director of both Atlantic Wave Holdings, LLC and Secure Community, LLC
- Multi-jurisdictional litigation against Cyberlux since 2022 resulted in more than four court sanctions against Cyberlux
- Government issued stop work order on HII subcontract P000043846 on December 22, 2023
- HII terminated subcontract P000043836 with Cyberlux on May 17, 2024
- Review of Cyberlux OTC filings reveals Fairwinds, ARG, and WeShield parties were not designated as debt holders in any quarter prior to interpleader action
- WeShield parties only mentioned in OTC filings after interpleader action commenced
Stage 2
Core — Entities, Events, Claims
20 nodes
ENT-001
Entity
William Welter
William Welter, over age 21, Managing Director of Atlantic Wave Holdings, LLC (AWH) and Secure Community, LLC (SC). Leads enforcement of AWH's and SC's rights against Cyberlux in Texas, California and Virginia.
Page 1 — My name is William Welter and I am over the age of 21 years and competent. I am the Managing Director of Atlantic Wave Holdings, LLC ("AWH") and Secure Community, LLC ("SC"). I lead the enforcement of AWH's and SC's rights against Cyberlux in Texas, California and Virginia.
ENT-002
Entity
Atlantic Wave Holdings, LLC
Atlantic Wave Holdings, LLC (AWH), a litigant against Cyberlux Corporation since 2022, claimant in interpleader action.
Page 1 — I am the Managing Director of Atlantic Wave Holdings, LLC ("AWH") and Secure Community, LLC ("SC"). I am familiar with Cyberlux Corporation ("CYBL") having been in litigation with CYBL since 2022.
ENT-003
Entity
Secure Community, LLC
Secure Community, LLC (SC), a litigant against Cyberlux Corporation since 2022, claimant in interpleader action.
Page 1 — I am the Managing Director of Atlantic Wave Holdings, LLC ("AWH") and Secure Community, LLC ("SC"). I am familiar with Cyberlux Corporation ("CYBL") having been in litigation with CYBL since 2022.
ENT-004
Entity
Cyberlux Corporation
Cyberlux Corporation (CYBL), party in litigation with Atlantic Wave Holdings and Secure Community since 2022, subject of government contract termination, files quarterly OTC reports.
Page 1, 2 — I am familiar with Cyberlux Corporation ("CYBL") having been in litigation with CYBL since 2022. I have reviewed all corporate Over the Counter Markets (OTC) filings for CYBL between 2022 and the current date. OTC filings are required quarterly and are made under oath by an authorized corporate officer.
ENT-005
Entity
HII Mission Technologies Corp.
HII Mission Technologies Corp., interpleader plaintiff in Case Number 3:25cv483, entered into subcontracts P000043846 and P000043836 with Cyberlux Corporation.
Page 1, 2 — HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, Case Number: 3:25cv483. The government issued a stop work order on the HII P000043846 Subcontract with CYBL on December 22, 2023. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
ENT-006
Entity
Fairwinds
Fairwinds entity, claimant in interpleader action, not designated as CYBL debt holder in OTC filings prior to interpleader action.
Page 2 — Fairwinds, ARG and the WeShield parties are not designated as debt holders of CYBL for any quarter(s) prior to the present Interpleader action. The same corporate filings do not reflect commissions owed or contracts entered with any of the Fairwinds entity, or the ARG entity.
ENT-007
Entity
ARG
ARG entity, claimant in interpleader action, not designated as CYBL debt holder in OTC filings prior to interpleader action.
Page 2 — Fairwinds, ARG and the WeShield parties are not designated as debt holders of CYBL for any quarter(s) prior to the present Interpleader action. The same corporate filings do not reflect commissions owed or contracts entered with any of the Fairwinds entity, or the ARG entity.
ENT-008
Entity
WeShield parties
WeShield parties, claimants in interpleader action, not designated as CYBL debt holders in OTC filings prior to interpleader action, mentioned in OTC filings only after interpleader action commenced.
Page 2 — Fairwinds, ARG and the WeShield parties are not designated as debt holders of CYBL for any quarter(s) prior to the present Interpleader action. The WeShield parties were mentioned only after the Inter-Pleader action commenced.
ENT-009
Entity
Catalyst Machineworks, LLC
Catalyst Machineworks, LLC, entity acquired by Cyberlux Corporation.
Page 1 — This would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL, the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of manufacturing, assemblage, headquarters, origination and all other documents referred to in the Memorandum.
EVT-001
Event
Litigation commencement 2022
Atlantic Wave Holdings and Secure Community entered litigation with Cyberlux Corporation beginning in 2022.
Page 1 — I am familiar with Cyberlux Corporation ("CYBL") having been in litigation with CYBL since 2022.
EVT-002
Event
Stop work order December 22, 2023
Government issued a stop work order on HII subcontract P000043846 with Cyberlux on December 22, 2023.
Page 2 — The government issued a stop work order on the HII P000043846 Subcontract with CYBL on December 22, 2023.
EVT-003
Event
Subcontract termination May 17, 2024
HII Mission Technologies Corp. terminated subcontract P000043836 with Cyberlux on May 17, 2024.
Page 2 — HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
EVT-004
Event
Cyberlux removal actions defeated
In Texas and California, Atlantic Wave defended three attempted unsuccessful removal actions by Cyberlux which were all remanded back to State Court.
Page 1 — In Texas and California, Atlantic Wave defended three attempted unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
EVT-005
Event
Sanctions granted against Cyberlux
Atlantic Wave sought and was granted more than four sanctions against Cyberlux by various courts.
Page 1 — In total, AW sought and was granted more than four sanctions against Cyberlux by the various courts.
EVT-006
Event
Catalyst Machineworks acquisition
Cyberlux Corporation acquired Catalyst Machineworks, LLC.
Page 1 — This would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL, the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of manufacturing, assemblage, headquarters, origination and all other documents referred to in the Memorandum.
CLM-001
Claim
Personal familiarity with factual representations
William Welter claims personal familiarity with all factual representations in the Memorandum in Support of Motion for Summary Judgment, having either participated in their production or reviewed them as part of litigation efforts.
Page 1 — I am personally familiar with all of the factual representations asserted in the Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I either participated in their production or reviewed them as part of my litigation efforts.
CLM-002
Claim
Fairwinds and ARG not designated as debt holders
Fairwinds, ARG and WeShield parties are not designated as debt holders of Cyberlux for any quarter(s) prior to the present interpleader action.
Page 2 — Fairwinds, ARG and the WeShield parties are not designated as debt holders of CYBL for any quarter(s) prior to the present Interpleader action.
CLM-003
Claim
No commissions or contracts reflected for Fairwinds or ARG
Corporate OTC filings do not reflect commissions owed or contracts entered with Fairwinds entity or ARG entity.
Page 2 — The same corporate filings do not reflect commissions owed or contracts entered with any of the Fairwinds entity, or the ARG entity.
CLM-004
Claim
WeShield mentioned only after interpleader commenced
WeShield parties were mentioned in OTC filings only after the interpleader action commenced.
Page 2 — The WeShield parties were mentioned only after the Inter-Pleader action commenced.
CLM-005
Claim
Declaration accuracy and truth
William Welter declares the foregoing is true and accurate to the best of his knowledge under penalty of perjury, executed April 22, 2026.
Page 2 — I declare the foregoing is true and accurate to the best of my knowledge under penalty of perjury. Executed on April 22, 2026
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
8 nodes
QUO-001
Quotation
OTC filing requirements
OTC filings are required quarterly and are made under oath by an authorized corporate officer.
Page 2 — OTC filings are required quarterly and are made under oath by an authorized corporate officer.
TLL-001
Tell
Multi-jurisdictional litigation scope
Welter describes leading enforcement efforts across three states (Texas, California, Virginia), defending against three unsuccessful removal actions, one Writ of Mandamus, one Appeal, and several Court of Appeals motions, all defeated, plus numerous unsuccessful trial court motions.
Page 1 — I lead the enforcement of AWH's and SC's rights against Cyberlux in Texas, California and Virginia. In Texas and California, Atlantic Wave defended three attempted unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
TLL-002
Tell
Comprehensive document review scope
Welter details the comprehensive scope of his document review including Catalyst Machineworks acquisition, OTC quarterly filings, Agreements, UCC-1 filings, Court Orders, and locations of manufacturing, assemblage, headquarters, and origination.
Page 1 — This would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL, the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of manufacturing, assemblage, headquarters, origination and all other documents referred to in the Memorandum.
TEN-001
Tension
Creditor designation timing discrepancy
Tension exists between claims by Fairwinds, ARG, and WeShield parties to be creditors and their absence from Cyberlux's mandatory sworn OTC filings prior to interpleader action. WeShield appears only after litigation commenced, raising questions about legitimacy of claims.
Page 2 — Fairwinds, ARG and the WeShield parties are not designated as debt holders of CYBL for any quarter(s) prior to the present Interpleader action. The same corporate filings do not reflect commissions owed or contracts entered with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only after the Inter-Pleader action commenced.
TEN-002
Tension
Contractual performance vs termination
Tension between government-issued stop work order (December 2023) and eventual HII termination (May 2024) suggests deteriorating contractual relationship with Cyberlux over five-month period.
Page 2 — The government issued a stop work order on the HII P000043846 Subcontract with CYBL on December 22, 2023. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
QST-001
Question
Basis for stop work order
What circumstances led the government to issue a stop work order on the HII-Cyberlux subcontract on December 22, 2023?
Page 2 — The government issued a stop work order on the HII P000043846 Subcontract with CYBL on December 22, 2023.
QST-002
Question
Subcontract number discrepancy
Why do the stop work order and termination reference different subcontract numbers (P000043846 vs P000043836)? Are these separate contracts or is there a transcription error?
Page 2 — The government issued a stop work order on the HII P000043846 Subcontract with CYBL on December 22, 2023. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
QST-003
Question
Nature of sanctions against Cyberlux
What were the specific grounds for the more than four sanctions granted against Cyberlux by various courts?
Page 1 — In total, AW sought and was granted more than four sanctions against Cyberlux by the various courts.
Stage 4
Interpretive — Inferences, Omissions, Patterns
5 nodes
INF-001
Inference
Pattern of litigation abuse by Cyberlux
The multiple unsuccessful removal actions, defeated appeals, and more than four sanctions suggest a pattern of litigation tactics by Cyberlux aimed at delaying or obstructing Atlantic Wave's enforcement actions.
Page 1 — In Texas and California, Atlantic Wave defended three attempted unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court. In total, AW sought and was granted more than four sanctions against Cyberlux by the various courts.
INF-002
Inference
Creditor claims potentially fraudulent
The absence of Fairwinds, ARG, and WeShield from sworn quarterly OTC filings prior to interpleader action, combined with WeShield's appearance only after litigation commenced, suggests these creditor claims may lack legitimate pre-existing basis.
Page 2 — Fairwinds, ARG and the WeShield parties are not designated as debt holders of CYBL for any quarter(s) prior to the present Interpleader action. The same corporate filings do not reflect commissions owed or contracts entered with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only after the Inter-Pleader action commenced. OTC filings are required quarterly and are made under oath by an authorized corporate officer.
INF-003
Inference
Government contract performance failure
The progression from stop work order to termination over a five-month period suggests significant performance failures or compliance issues by Cyberlux on government subcontract work.
Page 2 — The government issued a stop work order on the HII P000043846 Subcontract with CYBL on December 22, 2023. HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
OMI-001
Omission
No explanation for stop work order
Declaration states government issued stop work order but provides no explanation of the underlying cause or justification.
Page 2 — The government issued a stop work order on the HII P000043846 Subcontract with CYBL on December 22, 2023.
OMI-002
Omission
No details on sanction grounds
Declaration states more than four sanctions were granted against Cyberlux but does not specify the nature, grounds, or specific courts that imposed sanctions.
Page 1 — In total, AW sought and was granted more than four sanctions against Cyberlux by the various courts.
Extracted text
2 pages · 2814 charactersFiling Header
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division
HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff,
Case Number: 3:25cv483 V.
ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants.
SECOND DECLARATION OF WILLIAM WELTER ON BEHALF OF ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC
1.
My name is William Welter and I am over the age of 21 years and competent.
2.
I am the Managing Director of Atlantic Wave Holdings, LLC ("AWH") and Secure Community, LLC ("SC").
3.
I am familiar with Cyberlux Corporation ("CYBL") having been in litigation with CYBL since 2022.
4.
I lead the enforcement of AWH's and SC's rights against Cyberlux in Texas, California and Virginia. In Texas and California, Atlantic Wave defended three attempted unsuccessful removal actions by Cyberlux which were all remanded back to State Court, one Writ of Mandamus, one Appeal and several Motions filed in the Court of Appeals, which were all defeated, as well as numerous unsuccessful Motions filed by CYBL in the trial court.
5.
In total, AW sought and was granted more than four sanctions against Cyberlux by the various courts.
6.
I am personally familiar with all of the factual representations asserted in the Memorandum in Support of the Motion for Summary Judgment which are accurate insofar as I either participated in their production or reviewed them as part of my litigation efforts. This would include, but not be limited to, the acquisition of Catalyst Machineworks, LLC by CYBL, the OTC quarterly filings, the Agreements, the UCC-1 filings, the Court Orders, the locations of
manufacturing, assemblage, headquarters, origination and all other documents referred to in the Memorandum.
7.
The government issued a stop work order on the HII P000043846 Subcontract with CYBL on December 22, 2023.
8.
HII terminated Subcontract P000043836 with CYBL on May 17, 2024.
9.
I have reviewed all corporate Over the Counter Markets (OTC) filings for CYBL between 2022 and the current date.
10.
OTC filings are required quarterly and are made under oath by an authorized corporate officer.
11.
Fairwinds, ARG and the WeShield parties are not designated as debt holders of CYBL for any quarter(s) prior to the present Interpleader action.
12.
The same corporate filings do not reflect commissions owed or contracts entered with any of the Fairwinds entity, or the ARG entity. The WeShield parties were mentioned only after the Inter-Pleader action commenced.
I declare the foregoing is true and accurate to the best of my knowledge under penalty of perjury.
Executed on April 22, 2026 BY: William Welter
William Welter
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