Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
claimallegation
Watts’s declaration, filed14June2024 as SDCA18-2 in3:24-cv-00482-RBM-VET, supports Cyberlux’s application to quash/recall execution. He iden
Watts’s declaration, filed14June2024 as SDCA18-2 in3:24-cv-00482-RBM-VET, supports Cyberlux’s application to quash/recall execution. He identifies personal involvement in settlement payments and signs14June at Charlotte; it is advocacy evidence, not an order granting relief.
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1 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES WATTS
HAHN LOESER & PARKS LLP
Gabe P. Wright (SBN 208647)
One America Plaza
600 W. Broadway, Suite 1500
San Diego, CA 92101
Telephone: 619.810.4300
Facsimile: 619.810.4301
gwright@hahnlaw.com
THOMPSON COBURN LLP
JEFFREY N. BROWN, CSB 105520
jbrown@thompsoncoburn.com
10100 Santa Monica Blvd., Suite 500
Los Angeles, California 90067
Tel: 310.282.2500 / Fax: 310.282.2501
EDWARD W. GRAY, JR. (SBN 80966)
egray@thompsoncoburn.com
1909 K Street, NW Suite 600
Washington, D.C. 20006
Tel: 202.585.6967 / Fax: 202.585.6969
ALLEN CHESSON & GRIMES
DOUGLAS GRIMES (pro hac vice application pending)
dgrimes@allenchesson.com
505 N. Church Street
Charlotte, NC 28202
Tel: 704.755.6012
Attorneys for Defendant CYBERLUX
CORPORATION
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
ATLANTIC WAVE HOLDINGS,
LLC, a Virginia limited liability
company; and SECURE
COMMUNITY, LLC, a Virginia
limited Liability company,
Plaintiffs,
v.
CYBERLUX CORPORATION, a
Nevada Corporation;
Defendant.
Case No. 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES
WATTS IN SUPPORT OF
DEFENDANTS CYBERLUX
CORPORATION’S EX PARTE
APPLICATION TO QUASH AND
RECALL PLAINTIFFS’ REQUEST
AND APPLICATION FOR WRIT OF
EXECUTION
Dist. Judge: Ruth Bermudez Montenegro
Case 3:24-cv-00482-RBM-VET Document 18-2 Filed 06/14/24 PageID.578 Page 1 of 4
claimallegation
Watts states Cyberlux was current on all payments to Atlantic Wave and Secure Community as of31May2024. He identifies no amount or attached
Watts states Cyberlux was current on all payments to Atlantic Wave and Secure Community as of31May2024. He identifies no amount or attached ledger establishing that position, and the statement does not say the entire judgment had been satisfied.
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2 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES WATTS
I, Charles Watts, declare:
1. I am the special counsel for Defendant Cyberlux Corporation
(“Cyberlux”). I am an attorney licensed to practice and in good standing in North
Carolina and am located in North Carolina. If called as a witness, I would
competently testify as to the following facts based on my personal knowledge.
2. I have been personally involved in Cyberlux’s making of payments to
Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively,
“Plaintiffs”) pursuant to the terms of the Settlement Agreement between the parties
for payment of the amounts reflected in the Stipulated Judgment between the parties.
3. As of May 31, 2024, Cyberlux was up to date on all payments to
Plaintiffs.
4. On or about the week of May 31, 2024, Plaintiffs obtained a Writ of Fieri
Facias in Virginia State Court. As a result of this Writ of Fieri Facias, Cyberlux’s
bank accounts were sequestered, preventing Cyberlux from gaining access to the
money it had set aside for the June 2024 payment to Plaintiffs pursuant to the
Settlement Agreement.
5. On or about June 9, 2024, Cyberlux requested that Plaintiffs agree to the
release of those funds so that Cyberlux could make its June payment to Plaintiffs.
Plaintiffs refused Cyberlux’s request.
6. Plaintiffs have since used their own refusal to release the funds that they
had sequestered to take the position that Cyberlux has “missed” its June payment. I
declare under penalty of perjury that the foregoing is true and correct.
Executed this 14th day of June, 2024, at Charlotte, North Carolina.
Charles Watts
Case 3:24-cv-00482-RBM-VET Document 18-2 Filed 06/14/24 PageID.579 Page 2 of 4
claimallegation
He says a Virginia writ obtained around the week of31May caused bank accounts to be sequestered, denying access to money set aside for the J
He says a Virginia writ obtained around the week of31May caused bank accounts to be sequestered, denying access to money set aside for the June payment. He further says Cyberlux requested release around9June and plaintiffs refused. These are his asserted causal facts; the writ, bank restriction and release exchange are not attached.
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2 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES WATTS
I, Charles Watts, declare:
1. I am the special counsel for Defendant Cyberlux Corporation
(“Cyberlux”). I am an attorney licensed to practice and in good standing in North
Carolina and am located in North Carolina. If called as a witness, I would
competently testify as to the following facts based on my personal knowledge.
2. I have been personally involved in Cyberlux’s making of payments to
Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively,
“Plaintiffs”) pursuant to the terms of the Settlement Agreement between the parties
for payment of the amounts reflected in the Stipulated Judgment between the parties.
3. As of May 31, 2024, Cyberlux was up to date on all payments to
Plaintiffs.
4. On or about the week of May 31, 2024, Plaintiffs obtained a Writ of Fieri
Facias in Virginia State Court. As a result of this Writ of Fieri Facias, Cyberlux’s
bank accounts were sequestered, preventing Cyberlux from gaining access to the
money it had set aside for the June 2024 payment to Plaintiffs pursuant to the
Settlement Agreement.
5. On or about June 9, 2024, Cyberlux requested that Plaintiffs agree to the
release of those funds so that Cyberlux could make its June payment to Plaintiffs.
Plaintiffs refused Cyberlux’s request.
6. Plaintiffs have since used their own refusal to release the funds that they
had sequestered to take the position that Cyberlux has “missed” its June payment. I
declare under penalty of perjury that the foregoing is true and correct.
Executed this 14th day of June, 2024, at Charlotte, North Carolina.
Charles Watts
Case 3:24-cv-00482-RBM-VET Document 18-2 Filed 06/14/24 PageID.579 Page 2 of 4
claimallegation
Watts accuses plaintiffs of using their own refusal to release the sequestered money to characterise the June instalment as missed. This is
Watts accuses plaintiffs of using their own refusal to release the sequestered money to characterise the June instalment as missed. This is his explanation of disputed nonpayment, not proof of plaintiffs’ motive or a judicial finding that payment was excused.
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2 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES WATTS
I, Charles Watts, declare:
1. I am the special counsel for Defendant Cyberlux Corporation
(“Cyberlux”). I am an attorney licensed to practice and in good standing in North
Carolina and am located in North Carolina. If called as a witness, I would
competently testify as to the following facts based on my personal knowledge.
2. I have been personally involved in Cyberlux’s making of payments to
Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively,
“Plaintiffs”) pursuant to the terms of the Settlement Agreement between the parties
for payment of the amounts reflected in the Stipulated Judgment between the parties.
3. As of May 31, 2024, Cyberlux was up to date on all payments to
Plaintiffs.
4. On or about the week of May 31, 2024, Plaintiffs obtained a Writ of Fieri
Facias in Virginia State Court. As a result of this Writ of Fieri Facias, Cyberlux’s
bank accounts were sequestered, preventing Cyberlux from gaining access to the
money it had set aside for the June 2024 payment to Plaintiffs pursuant to the
Settlement Agreement.
5. On or about June 9, 2024, Cyberlux requested that Plaintiffs agree to the
release of those funds so that Cyberlux could make its June payment to Plaintiffs.
Plaintiffs refused Cyberlux’s request.
6. Plaintiffs have since used their own refusal to release the funds that they
had sequestered to take the position that Cyberlux has “missed” its June payment. I
declare under penalty of perjury that the foregoing is true and correct.
Executed this 14th day of June, 2024, at Charlotte, North Carolina.
Charles Watts
Case 3:24-cv-00482-RBM-VET Document 18-2 Filed 06/14/24 PageID.579 Page 2 of 4
claimallegation
The signed Melissa P. Kanamori proof of service selects CM/ECF electronic service for Keithly/Ross and direct email for Sadigh on14June2024,
The signed Melissa P. Kanamori proof of service selects CM/ECF electronic service for Keithly/Ross and direct email for Sadigh on14June2024, with no failure notice received within a reasonable time. The selected boxes and signature are visible; the certificate is not the email log or proof of actual reading.
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3 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES WATTS
PROOF OF SERVICE
[FRCP 5(B)]
STATE OF CALIFORNIA, COUNTY OF SAN DIEGO
I am employed in the County of San Diego, State of California. I am over
the age of 18 years and am not a party to the within action; my business address is
600 W. Broadway, Suite 1500, San Diego, CA 92101. My electronic service
address is mkanamori@hahnlaw.com.
On June 14, 2024, I served the following document(s) described as:
DECLARATION OF CHARLES WATTS IN SUPPORT OF DEFENDANTS
CYBERLUX CORPORATION’S EX PARTE APPLICATION TO QUASH
AND RECALL PLAINTIFFS’ REQUEST AND APPLICATION FOR WRIT
OF EXECUTION
on the interested parties in this action as follows:
BY ELECTRONIC MAIL: A copy of the foregoing document was
electronically filed using the CM/ECF system which will send a notice of electronic
filing to all CM/ECF participants listed below:
David M. Keithly, SBN 292101
Sara Ross, SBN 346153
Mortenson Taggart Adams LLP
300 Spectrum Center Drive,
Ste. 1200
Irvine, CA 92618
Email: dkeithly@mortensontaggart.com
sross@mortensontaggart.com
Attorneys for Plaintiffs
Atlantic Wave Holdings, LLC
Secure Community, LLC
Case 3:24-cv-00482-RBM-VET Document 18-2 Filed 06/14/24 PageID.580 Page 3 of 4
entityobservation
Charles Watts
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2 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES WATTS
I, Charles Watts, declare:
1. I am the special counsel for Defendant Cyberlux Corporation
(“Cyberlux”). I am an attorney licensed to practice and in good standing in North
Carolina and am located in North Carolina. If called as a witness, I would
competently testify as to the following facts based on my personal knowledge.
2. I have been personally involved in Cyberlux’s making of payments to
Atlantic Wave Holdings, LLC and Secure Community, LLC (collectively,
“Plaintiffs”) pursuant to the terms of the Settlement Agreement between the parties
for payment of the amounts reflected in the Stipulated Judgment between the parties.
3. As of May 31, 2024, Cyberlux was up to date on all payments to
Plaintiffs.
4. On or about the week of May 31, 2024, Plaintiffs obtained a Writ of Fieri
Facias in Virginia State Court. As a result of this Writ of Fieri Facias, Cyberlux’s
bank accounts were sequestered, preventing Cyberlux from gaining access to the
money it had set aside for the June 2024 payment to Plaintiffs pursuant to the
Settlement Agreement.
5. On or about June 9, 2024, Cyberlux requested that Plaintiffs agree to the
release of those funds so that Cyberlux could make its June payment to Plaintiffs.
Plaintiffs refused Cyberlux’s request.
6. Plaintiffs have since used their own refusal to release the funds that they
had sequestered to take the position that Cyberlux has “missed” its June payment. I
declare under penalty of perjury that the foregoing is true and correct.
Executed this 14th day of June, 2024, at Charlotte, North Carolina.
Charles Watts
Case 3:24-cv-00482-RBM-VET Document 18-2 Filed 06/14/24 PageID.579 Page 2 of 4
entityobservation
Melissa P. Kanamori
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DECLARATION OF CHARLES WATTS
BY ELECTRONIC MAIL: I caused the documents to be transmitted by
electronic mail to the party(s) identified on the below service list using the e-mail
address(es) shown. I did not receive, within a reasonable time after transmission, any
electronic message or other indication that the transmission(s) were unsuccessful.
James K. Sadigh, SBN 140199
9777 Wilshire Blvd., Suite 400
Beverly Hills, CA 90212
Email: jamessadigh@aol.com
Attorneys for Plaintiffs
Atlantic Wave Holdings, LLC
Secure Community, LLC
I declare that I am employed in the office of a member of the bar of the court
at whose direction the service was made.
Executed on June 14, 2024, at San Diego, California.
___________________________
Melissa P. Kanamori
Case 3:24-cv-00482-RBM-VET Document 18-2 Filed 06/14/24 PageID.581 Page 4 of 4
inferenceinference
The declaration offers a testable account of payment access being blocked, while distinguishing current instalments from full satisfaction.
The declaration offers a testable account of payment access being blocked, while distinguishing current instalments from full satisfaction. Verification requires the bank restriction and dated payment records.
otherattribution
Complete supplied 4-page source reviewed at SHA-256 0ac0650e4194bd79422b948a8716962ef36991d5764a29547a285ac0003d59e9. Source assertions, ori
Complete supplied 4-page source reviewed at SHA-256 0ac0650e4194bd79422b948a8716962ef36991d5764a29547a285ac0003d59e9. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Full 4-page reading of version_0adbcd6acf804d4283d0cd470e0d2e18, SHA256 0ac0650e4194bd79422b948a8716962ef36991d5764a29547a285ac0003d59e9; source bytes and original extraction preserved.
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DECLARATION OF CHARLES WATTS
HAHN LOESER & PARKS LLP
Gabe P. Wright (SBN 208647)
One America Plaza
600 W. Broadway, Suite 1500
San Diego, CA 92101
Telephone: 619.810.4300
Facsimile: 619.810.4301
gwright@hahnlaw.com
THOMPSON COBURN LLP
JEFFREY N. BROWN, CSB 105520
jbrown@thompsoncoburn.com
10100 Santa Monica Blvd., Suite 500
Los Angeles, California 90067
Tel: 310.282.2500 / Fax: 310.282.2501
EDWARD W. GRAY, JR. (SBN 80966)
egray@thompsoncoburn.com
1909 K Street, NW Suite 600
Washington, D.C. 20006
Tel: 202.585.6967 / Fax: 202.585.6969
ALLEN CHESSON & GRIMES
DOUGLAS GRIMES (pro hac vice application pending)
dgrimes@allenchesson.com
505 N. Church Street
Charlotte, NC 28202
Tel: 704.755.6012
Attorneys for Defendant CYBERLUX
CORPORATION
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
ATLANTIC WAVE HOLDINGS,
LLC, a Virginia limited liability
company; and SECURE
COMMUNITY, LLC, a Virginia
limited Liability company,
Plaintiffs,
v.
CYBERLUX CORPORATION, a
Nevada Corporation;
Defendant.
Case No. 3:24-cv-00482-RBM-VET
DECLARATION OF CHARLES
WATTS IN SUPPORT OF
DEFENDANTS CYBERLUX
CORPORATION’S EX PARTE
APPLICATION TO QUASH AND
RECALL PLAINTIFFS’ REQUEST
AND APPLICATION FOR WRIT OF
EXECUTION
Dist. Judge: Ruth Bermudez Montenegro
Case 3:24-cv-00482-RBM-VET Document 18-2 Filed 06/14/24 PageID.578 Page 1 of 4
questionquestion
Do the bank hold, available balances, settlement schedule and9June release correspondence substantiate the claimed inability to make the Jun
Do the bank hold, available balances, settlement schedule and9June release correspondence substantiate the claimed inability to make the June payment?
questionquestion
What order resolved the quash/recall application and any asserted excuse for nonpayment?
distillateallegation
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Watts accuses plaintiffs of using their own refusal to release the sequestered money to characterise the June instalment as missed. This is his explanation of disputed nonpayment, not proof of plaintiffs’ motive or a judicial finding that payment was excused.supportsThe declaration offers a testable account of payment access being blocked, while distinguishing current instalments from full satisfaction. Verification requires the bank restriction and dated payment records.
Specifically named source propositions support the bounded distinction or question.
Watts states Cyberlux was current on all payments to Atlantic Wave and Secure Community as of31May2024. He identifies no amount or attached ledger establishing that position, and the statement does not say the entire judgment had been satisfied.supportsThe declaration offers a testable account of payment access being blocked, while distinguishing current instalments from full satisfaction. Verification requires the bank restriction and dated payment records.
Specifically named source propositions support the bounded distinction or question.
Watts states Cyberlux was current on all payments to Atlantic Wave and Secure Community as of31May2024. He identifies no amount or attached ledger establishing that position, and the statement does not say the entire judgment had been satisfied.supportsDo the bank hold, available balances, settlement schedule and9June release correspondence substantiate the claimed inability to make the June payment?
Specifically named source propositions support the bounded distinction or question.
Watts’s declaration, filed14June2024 as SDCA18-2 in3:24-cv-00482-RBM-VET, supports Cyberlux’s application to quash/recall execution. He identifies personal involvement in settlement payments and signs14June at Charlotte; it is advocacy evidence, not an order granting relief.supportsWhat order resolved the quash/recall application and any asserted excuse for nonpayment?
Specifically named source propositions support the bounded distinction or question.
He says a Virginia writ obtained around the week of31May caused bank accounts to be sequestered, denying access to money set aside for the June payment. He further says Cyberlux requested release around9June and plaintiffs refused. These are his asserted causal facts; the writ, bank restriction and release exchange are not attached.supportsDo the bank hold, available balances, settlement schedule and9June release correspondence substantiate the claimed inability to make the June payment?
Specifically named source propositions support the bounded distinction or question.
Watts accuses plaintiffs of using their own refusal to release the sequestered money to characterise the June instalment as missed. This is his explanation of disputed nonpayment, not proof of plaintiffs’ motive or a judicial finding that payment was excused.supportsWhat order resolved the quash/recall application and any asserted excuse for nonpayment?
Specifically named source propositions support the bounded distinction or question.
Watts accuses plaintiffs of using their own refusal to release the sequestered money to characterise the June instalment as missed. This is his explanation of disputed nonpayment, not proof of plaintiffs’ motive or a judicial finding that payment was excused.supportsDo the bank hold, available balances, settlement schedule and9June release correspondence substantiate the claimed inability to make the June payment?
Specifically named source propositions support the bounded distinction or question.
He says a Virginia writ obtained around the week of31May caused bank accounts to be sequestered, denying access to money set aside for the June payment. He further says Cyberlux requested release around9June and plaintiffs refused. These are his asserted causal facts; the writ, bank restriction and release exchange are not attached.supportsThe declaration offers a testable account of payment access being blocked, while distinguishing current instalments from full satisfaction. Verification requires the bank restriction and dated payment records.
Specifically named source propositions support the bounded distinction or question.
Watts states Cyberlux was current on all payments to Atlantic Wave and Secure Community as of31May2024. He identifies no amount or attached ledger establishing that position, and the statement does not say the entire judgment had been satisfied.supportsDoes the declaration establish the judgment was paid in full by31May2024?
Specifically named source propositions support the bounded distinction or question.
He says a Virginia writ obtained around the week of31May caused bank accounts to be sequestered, denying access to money set aside for the June payment. He further says Cyberlux requested release around9June and plaintiffs refused. These are his asserted causal facts; the writ, bank restriction and release exchange are not attached.supportsDoes the declaration establish the judgment was paid in full by31May2024?
Specifically named source propositions support the bounded distinction or question.
WEIGH
Explained weighting
A score appears only when its components and change threshold are published.
No published WEIGH run
The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.