Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
claimallegation
Seven-page Exhibit2 filed April15,2026 as EDVA183-2 preserves Legalist’s March9,2026 pre-settlement discovery response and email service cer
Seven-page Exhibit2 filed April15,2026 as EDVA183-2 preserves Legalist’s March9,2026 pre-settlement discovery response and email service certification. Ink signatures appear on response and certificate. The supplied pages contain counsel blocks but no separate sworn corporate verification; the certificate is counsel’s assertion of service, not recipient receipt evidence.
Read the anchor · page 1
EXHIBIT 2
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 1 of 7 PageID# 3920
claimallegation
Legalist claims $13,204,742.88: principal $10,033,639.75; unpaid interest $2,653,970.84; commitment fee $112,500; forbearance fee $53,000; p
Legalist claims $13,204,742.88: principal $10,033,639.75; unpaid interest $2,653,970.84; commitment fee $112,500; forbearance fee $53,000; paid legal fees/costs $312,959.79; unpaid legal fees/costs $38,672.50. These six displayed components sum exactly to the claim. Paid and unpaid legal costs total $351,632.29; paid describes Legalist’s cost status, not debtor repayment.
Read the anchor · page 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
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 2 of 7 PageID# 3921
claimallegation
The response says the March27,2024 Second Amended and Restated Government Purchase Order Financing Agreement provided a $7m revolving facili
The response says the March27,2024 Second Amended and Restated Government Purchase Order Financing Agreement provided a $7m revolving facility, with $6,950,000 advanced plus a $3,083,639.75 June2025 advance requested by Cyberlux. Those two claimed principal components equal $10,033,639.75. It calls the whole claim liquidated; the response does not itself establish court allowance.
Read the anchor · page 3
• $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 perfect ed 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,
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 3 of 7 PageID# 3922
claimallegation
Legalist asserts a security interest created March27,2024, perfected by Nevada and North Carolina filings April1,2024, covering all subject
Legalist asserts a security interest created March27,2024, perfected by Nevada and North Carolina filings April1,2024, covering all subject proceeds and all later advances with that priority date. It cites state statutory provisions. These are claimant security and priority assertions; no determination of attachment, competing ownership or priority is made by this response.
Read the anchor · page 3
• $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 perfect ed 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,
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 3 of 7 PageID# 3922
claimallegation
Ten listed 2024 advances are April9 $1.8m; April19 $500,000; May2 $500,000; June26 $142,000; July5 $53,000; July16 $2.5m; August2 $650,000;
Ten listed 2024 advances are April9 $1.8m; April19 $500,000; May2 $500,000; June26 $142,000; July5 $53,000; July16 $2.5m; August2 $650,000; August27 $535,000; October3 $150,000 and October3 $120,000. They sum $6,950,000. These dates are asserted advance dates, distinct from dates on underlying disbursement requests.
Read the anchor · page 4
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
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 4 of 7 PageID# 3923
claimallegation
June3,2025 $2,755,100.10 and June9 $345,000 total $3,100,100.10. Footnote1 says these covered the $3,083,639.75 protective advance and that
June3,2025 $2,755,100.10 and June9 $345,000 total $3,100,100.10. Footnote1 says these covered the $3,083,639.75 protective advance and that $16,460.35 difference was applied to Legalist’s legal fees. The stated allocation reconciles exactly; the source does not provide bank execution or a full legal-fee ledger to test classification or overlap.
Read the anchor · page 5
• 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:
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, V A 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.
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 5 of 7 PageID# 3924
claimallegation
The response cites agreement paragraphs9.1,9.2 and9.9(a) for continuing interest,9.4 for commitment fee and9.9(b) for forbearance fee. It ci
The response cites agreement paragraphs9.1,9.2 and9.9(a) for continuing interest,9.4 for commitment fee and9.9(b) for forbearance fee. It cites paragraph29 for attorneys’ fees on page3 but paragraph28 on page4. The $351,632.29 fee claim is stated for the upcoming settlement conference and may increase; no interest rate/day-count schedule appears here.
Read the anchor · page 3
• $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 perfect ed 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,
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 3 of 7 PageID# 3922
claimallegation
Both production responses refer to LEGALIST_000001–20. Those twenty Bates pages are not physically attached to this seven-page source. The r
Both production responses refer to LEGALIST_000001–20. Those twenty Bates pages are not physically attached to this seven-page source. The reference records asserted production, not completeness, receipt or authentication of each underlying document.
Read the anchor · page 5
• 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:
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, V A 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.
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 5 of 7 PageID# 3924
entityobservation
LEGALIST SPV III, LP
Read the anchor · page 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
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 2 of 7 PageID# 3921
entityobservation
HII MISSION TECHNOLOGIES CORP.
Read the anchor · page 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
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 2 of 7 PageID# 3921
entityobservation
CYBERLUX CORPORATION
Read the anchor · page 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
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 2 of 7 PageID# 3921
entityobservation
John M. Erbach
Read the anchor · page 5
• 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:
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, V A 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.
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 5 of 7 PageID# 3924
entityobservation
Christopher W. Bascom
Read the anchor · page 5
• 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:
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, V A 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.
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 5 of 7 PageID# 3924
inferenceinference
The principal increase includes an expressly allocated protective advance; treating all $3,100,100.10 as additional loan principal would con
The principal increase includes an expressly allocated protective advance; treating all $3,100,100.10 as additional loan principal would contradict the source’s $16,460.35 legal-fee allocation.
inferenceinference
Reconciled face arithmetic supports faithful transcription of the claimed balance, not its enforceability, priority or absence of overlappin
Reconciled face arithmetic supports faithful transcription of the claimed balance, not its enforceability, priority or absence of overlapping fees.
otherattribution
Complete supplied 7-page source reviewed at SHA-256 2bdaafa17c9f059be350bed19c0affcbfa8039ab14575bca75475bdc86f716b8. Source assertions, ori
Complete supplied 7-page source reviewed at SHA-256 2bdaafa17c9f059be350bed19c0affcbfa8039ab14575bca75475bdc86f716b8. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Exact version_3274b90926c2423aa88a64e126e23b73; SHA256 2bdaafa17c9f059be350bed19c0affcbfa8039ab14575bca75475bdc86f716b8. Every supplied page read. All substantive page images checked, including financial rows and signatures. Arithmetic independently recomputed; source assertion, entitlement and payment remain separate.
Read the anchor · page 1
EXHIBIT 2
Case 3:25-cv-00483-JAG Document 183-2 Filed 04/15/26 Page 1 of 7 PageID# 3920
questionquestion
What bank and ledger records reconcile the protective advance, $16,460.35 allocation and paid/unpaid legal fees without double counting?
questionquestion
Which operative agreement paragraph governs legal fees, and what rate, dates, day count, payments and credits produce the claimed interest a
Which operative agreement paragraph governs legal fees, and what rate, dates, day count, payments and credits produce the claimed interest and current balance?
questionquestion
Do the produced Bates pages and executed agreement support the asserted collateral, future-advance priority and entitlement to these particu
Do the produced Bates pages and executed agreement support the asserted collateral, future-advance priority and entitlement to these particular proceeds?
distillateobservation
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Ten listed 2024 advances are April9 $1.8m; April19 $500,000; May2 $500,000; June26 $142,000; July5 $53,000; July16 $2.5m; August2 $650,000; August27 $535,000; October3 $150,000 and October3 $120,000. They sum $6,950,000. These dates are asserted advance dates, distinct from dates on underlying disbursement requests.referencesThe ten face amounts sum$6,950,000, including$620,000 directed to Datron-named accounts and$6,330,000 to Cyberlux-named accounts. Each form requests an advance plus applicable per diem; this sum is requested principal, not proof all amounts were disbursed or remain unpaid.
Same ten face amounts total6.95m, but request dates and alleged funding dates are different roles.
Legalist asserts a security interest created March27,2024, perfected by Nevada and North Carolina filings April1,2024, covering all subject proceeds and all later advances with that priority date. It cites state statutory provisions. These are claimant security and priority assertions; no determination of attachment, competing ownership or priority is made by this response.qualifiesThe two statements document state filing notices and collateral descriptions. They contain no loan balance, advance ledger, signed security agreement, continuations or later status search; filing alone does not establish attachment, surviving perfection or priority to particular proceeds.
Actual UCC statements establish filing notice, not every attachment or priority proposition asserted in the response.
The table lists judgment $1,572,500 at12.00%; prejudgment $0 at0.00%; postjudgment $420,121.22; trial attorneys’ fees $187,863.69; RO attorneys’ fees $1,750; receiver’s fee $765,113.62; expenses $83,341.22; Grady attorneys’ fees $21,677.50; Vargo attorneys’ fees $21,880; Caudle attorneys’ fees $9,392.50. All displayed monetary components sum exactly $3,083,639.75.referencesJune3,2025 $2,755,100.10 and June9 $345,000 total $3,100,100.10. Footnote1 says these covered the $3,083,639.75 protective advance and that $16,460.35 difference was applied to Legalist’s legal fees. The stated allocation reconciles exactly; the source does not provide bank execution or a full legal-fee ledger to test classification or overlap.
Schedule total exactly matches later Legalist response protective-advance component; same amount does not authenticate allowance or payment.
Legalist claims $13,204,742.88: principal $10,033,639.75; unpaid interest $2,653,970.84; commitment fee $112,500; forbearance fee $53,000; paid legal fees/costs $312,959.79; unpaid legal fees/costs $38,672.50. These six displayed components sum exactly to the claim. Paid and unpaid legal costs total $351,632.29; paid describes Legalist’s cost status, not debtor repayment.supportsWhat bank and ledger records reconcile the protective advance, $16,460.35 allocation and paid/unpaid legal fees without double counting?
Specifically named source propositions support the bounded distinction or question.
June3,2025 $2,755,100.10 and June9 $345,000 total $3,100,100.10. Footnote1 says these covered the $3,083,639.75 protective advance and that $16,460.35 difference was applied to Legalist’s legal fees. The stated allocation reconciles exactly; the source does not provide bank execution or a full legal-fee ledger to test classification or overlap.supportsThe principal increase includes an expressly allocated protective advance; treating all $3,100,100.10 as additional loan principal would contradict the source’s $16,460.35 legal-fee allocation.
Specifically named source propositions support the bounded distinction or question.
The response cites agreement paragraphs9.1,9.2 and9.9(a) for continuing interest,9.4 for commitment fee and9.9(b) for forbearance fee. It cites paragraph29 for attorneys’ fees on page3 but paragraph28 on page4. The $351,632.29 fee claim is stated for the upcoming settlement conference and may increase; no interest rate/day-count schedule appears here.supportsReconciled face arithmetic supports faithful transcription of the claimed balance, not its enforceability, priority or absence of overlapping fees.
Specifically named source propositions support the bounded distinction or question.
Legalist asserts a security interest created March27,2024, perfected by Nevada and North Carolina filings April1,2024, covering all subject proceeds and all later advances with that priority date. It cites state statutory provisions. These are claimant security and priority assertions; no determination of attachment, competing ownership or priority is made by this response.supportsDo the produced Bates pages and executed agreement support the asserted collateral, future-advance priority and entitlement to these particular proceeds?
Specifically named source propositions support the bounded distinction or question.
June3,2025 $2,755,100.10 and June9 $345,000 total $3,100,100.10. Footnote1 says these covered the $3,083,639.75 protective advance and that $16,460.35 difference was applied to Legalist’s legal fees. The stated allocation reconciles exactly; the source does not provide bank execution or a full legal-fee ledger to test classification or overlap.supportsDoes the June2025 cash total equal the protective principal claimed?
Specifically named source propositions support the bounded distinction or question.
Legalist asserts a security interest created March27,2024, perfected by Nevada and North Carolina filings April1,2024, covering all subject proceeds and all later advances with that priority date. It cites state statutory provisions. These are claimant security and priority assertions; no determination of attachment, competing ownership or priority is made by this response.supportsReconciled face arithmetic supports faithful transcription of the claimed balance, not its enforceability, priority or absence of overlapping fees.
Specifically named source propositions support the bounded distinction or question.
Both production responses refer to LEGALIST_000001–20. Those twenty Bates pages are not physically attached to this seven-page source. The reference records asserted production, not completeness, receipt or authentication of each underlying document.supportsDo the produced Bates pages and executed agreement support the asserted collateral, future-advance priority and entitlement to these particular proceeds?
Specifically named source propositions support the bounded distinction or question.
The response says the March27,2024 Second Amended and Restated Government Purchase Order Financing Agreement provided a $7m revolving facility, with $6,950,000 advanced plus a $3,083,639.75 June2025 advance requested by Cyberlux. Those two claimed principal components equal $10,033,639.75. It calls the whole claim liquidated; the response does not itself establish court allowance.supportsWhich operative agreement paragraph governs legal fees, and what rate, dates, day count, payments and credits produce the claimed interest and current balance?
Specifically named source propositions support the bounded distinction or question.
June3,2025 $2,755,100.10 and June9 $345,000 total $3,100,100.10. Footnote1 says these covered the $3,083,639.75 protective advance and that $16,460.35 difference was applied to Legalist’s legal fees. The stated allocation reconciles exactly; the source does not provide bank execution or a full legal-fee ledger to test classification or overlap.supportsReconciled face arithmetic supports faithful transcription of the claimed balance, not its enforceability, priority or absence of overlapping fees.
Specifically named source propositions support the bounded distinction or question.
The response cites agreement paragraphs9.1,9.2 and9.9(a) for continuing interest,9.4 for commitment fee and9.9(b) for forbearance fee. It cites paragraph29 for attorneys’ fees on page3 but paragraph28 on page4. The $351,632.29 fee claim is stated for the upcoming settlement conference and may increase; no interest rate/day-count schedule appears here.supportsWhich operative agreement paragraph governs legal fees, and what rate, dates, day count, payments and credits produce the claimed interest and current balance?
Specifically named source propositions support the bounded distinction or question.
June3,2025 $2,755,100.10 and June9 $345,000 total $3,100,100.10. Footnote1 says these covered the $3,083,639.75 protective advance and that $16,460.35 difference was applied to Legalist’s legal fees. The stated allocation reconciles exactly; the source does not provide bank execution or a full legal-fee ledger to test classification or overlap.supportsWhat bank and ledger records reconcile the protective advance, $16,460.35 allocation and paid/unpaid legal fees without double counting?
Specifically named source propositions support the bounded distinction or question.
The response says the March27,2024 Second Amended and Restated Government Purchase Order Financing Agreement provided a $7m revolving facility, with $6,950,000 advanced plus a $3,083,639.75 June2025 advance requested by Cyberlux. Those two claimed principal components equal $10,033,639.75. It calls the whole claim liquidated; the response does not itself establish court allowance.supportsDoes the June2025 cash total equal the protective principal claimed?
Specifically named source propositions support the bounded distinction or question.
Legalist claims $13,204,742.88: principal $10,033,639.75; unpaid interest $2,653,970.84; commitment fee $112,500; forbearance fee $53,000; paid legal fees/costs $312,959.79; unpaid legal fees/costs $38,672.50. These six displayed components sum exactly to the claim. Paid and unpaid legal costs total $351,632.29; paid describes Legalist’s cost status, not debtor repayment.supportsReconciled face arithmetic supports faithful transcription of the claimed balance, not its enforceability, priority or absence of overlapping fees.
Specifically named source propositions support the bounded distinction or question.
The response says the March27,2024 Second Amended and Restated Government Purchase Order Financing Agreement provided a $7m revolving facility, with $6,950,000 advanced plus a $3,083,639.75 June2025 advance requested by Cyberlux. Those two claimed principal components equal $10,033,639.75. It calls the whole claim liquidated; the response does not itself establish court allowance.supportsThe principal increase includes an expressly allocated protective advance; treating all $3,100,100.10 as additional loan principal would contradict the source’s $16,460.35 legal-fee allocation.
Specifically named source propositions support the bounded distinction or question.
WEIGH
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