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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
observationobservation
Judgment 29 August 2025; certification 19 December; signature 9 March 2026; claimed balance through 29 March.
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EXHIBIT 27
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claimallegation
EDVA Document 175-29 Exhibit 27, filed 15 April 2026, contains Thin Air Gear LLC’s objections and responses under the 19 February 2026 Joint
EDVA Document 175-29 Exhibit 27, filed 15 April 2026, contains Thin Air Gear LLC’s objections and responses under the 19 February 2026 Joint Discovery Plan, ECF 149. Counsel dates and certifies email service on 9 March 2026. No separate party oath or verification is included.
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EXHIBIT 27
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claimallegation
The response bears /s/ Stephen L. Neal, Jr., Esq., with Stephen J. Stine also named, and certifies email service to all counsel of record on
The response bears /s/ Stephen L. Neal, Jr., Esq., with Stephen J. Stine also named, and certifies email service to all counsel of record on 9 March 2026. This records counsel’s certification, not independent receipt or verification of every underlying debt fact.
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With respect to 1(g), see response to 1(d), supra.
TAG reserves the right to amend and/or supplement this Response based upon the
discovery of additional responsive information and/or documents.
DOCUMENT REQUEST 1: Documents supporting or otherwise concerning your answer
to the above interrogatory.
OBJECTION AND RESPONSE TO DOCUMENT REQUEST 1: TAG objects to this
Request on the ground that it calls for the production of information and documents protected
by the attorney-client privilege and attorney work-product doctrine. Subject to, and without
waiving, the forgoing Objection, TAG will produce responsive documents within its
possession, custody, and/or control.
DOCUMENT REQUEST 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.
OBJECTION AND RESPONSE TO DOCUMENT REQUEST 2: TAG objects to this
Request on the ground that it calls for the production of information and documents protected
by the attorney-client privilege and attorney work-product doctrine. Subject to, and without
waiving, the forgoing Objection, TAG will produce responsive documents within its
possession, custody, and/or control.
TAG reserves the right to amend and/or supplement these Responses based upon the
discovery of additional responsive information and/or documents.
Dated: March 9, 2026
Respectfully submitted,
/s/ Stephen L. Neal, Jr., Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
5
claimallegation
TAG reports a 5 September 2023 contract with Cyberlux Corporation d/b/a Catalyst Machineworks LLC, described as its wholly owned subsidiary,
TAG reports a 5 September 2023 contract with Cyberlux Corporation d/b/a Catalyst Machineworks LLC, described as its wholly owned subsidiary, for 2,100 wheeled drone kit bags at $887,900. It reports a $150,000 deposit on 14 September 2023. The response connects the bag manufacture to the HII subcontract but does not attach the original contract.
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
claimallegation
TAG says it produced all 2,100 bags, delivered 1,722 to Cyberlux’s Spring, Texas warehouse and retains 378 pending final payment. It reports
TAG says it produced all 2,100 bags, delivered 1,722 to Cyberlux’s Spring, Texas warehouse and retains 378 pending final payment. It reports a $365,049.42 balance as of 18 November 2024, including a 1.5% monthly late fee, and unanswered demands. The response contains no ledger bridging contract price less deposit to that balance.
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
claimallegation
TAG says it filed Colorado action 1:25-cv-00805 on 12 March 2025 for breach, civil theft and what the supplied page literally prints as “jus
TAG says it filed Colorado action 1:25-cv-00805 on 12 March 2025 for breach, civil theft and what the supplied page literally prints as “just enrichment”. It claims proper service and no answer. It reports an August 29, 2025 default judgment of $1,224,275.14: $1,220,838.54 treble damages, $2,765 fees and $671.60 costs. Certification is dated 19 December 2025; it is not presented here as a second additive principal debt.
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
claimallegation
TAG claims $1,385,489.46 through 29 March 2026, comprising $1,224,275.14 judgment, $97,941.93 prejudgment simple interest at 8% and $63,272.
TAG claims $1,385,489.46 through 29 March 2026, comprising $1,224,275.14 judgment, $97,941.93 prejudgment simple interest at 8% and $63,272.39 postjudgment compound interest at 8%, plus further postjudgment interest and this action’s fees/costs. Those components add to the claimed total. The calculation end date is later than the response’s 9 March signature/service date.
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a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case
No. 1:25-cv-00805 (the "Colorado Action"), alleging breach of contract, just enrichment, and
civil theft under Colorado law, which provides for treble damages, attorneys' fees, and costs if
TAG prevailed in the Colorado Action.
Although Cyberlux was properly served with the complaint in the Colorado Action,
Cyberlux refused or failed to file an answer or otherwise respond to the complaint. Accordingly,
TAG moved for entry of default judgment against Cyberlux. On August 29, 2025, that motion
was granted and Final Judgment was entered against Cyberlux in the total amount of
$1,224,275.14 (the "Final Judgment"), which consisted of treble damages in the amount of
$1,220,838.54, attorneys' fees in the amount of $2,765.00, and costs in the amount of $671.60.
The Final Judgment was Certified on December 19, 2025 (the "Certified Final Judgment").
With respect to the specific subparts of this Interrogatory, TAG states that:
With respect to 1(a), through March 29, 2026, TAG seeks $1,385,489.46 plus all
attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8%
that is incurred after March 29, 2026, from the interpleaded funds. This sum is calculated as
follows: (1) $1,224,275.14 for the Final Judgment/Certified Final Judgment; (2) $97,941.93 in
pre-judgment simple interest at 8% from the date of breach of the Contract until the Final
Judgment was entered on August 29, 2025; $63,272.39 in post-judgment compound interest at
8% from August 29, 2025 through March 29, 2026.
With respect to 1(b), TAG's legal basis for its right to the proceeds is based upon the
Final Judgment and Certified Final Judgment entered by the United States District Court in the
Colorado Action.
With respect to 1(c), the amount TAG claims became a liquidated amount when the
3
claimallegation
TAG bases liquidation and its asserted security interest/lien on the Colorado judgment and certification. It asserts priority from 29 August
TAG bases liquidation and its asserted security interest/lien on the Colorado judgment and certification. It asserts priority from 29 August 2025 or, “At worst”, 19 December 2025. The response supplies no independent security agreement, perfection record or ruling establishing priority in the HII fund.
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a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case
No. 1:25-cv-00805 (the "Colorado Action"), alleging breach of contract, just enrichment, and
civil theft under Colorado law, which provides for treble damages, attorneys' fees, and costs if
TAG prevailed in the Colorado Action.
Although Cyberlux was properly served with the complaint in the Colorado Action,
Cyberlux refused or failed to file an answer or otherwise respond to the complaint. Accordingly,
TAG moved for entry of default judgment against Cyberlux. On August 29, 2025, that motion
was granted and Final Judgment was entered against Cyberlux in the total amount of
$1,224,275.14 (the "Final Judgment"), which consisted of treble damages in the amount of
$1,220,838.54, attorneys' fees in the amount of $2,765.00, and costs in the amount of $671.60.
The Final Judgment was Certified on December 19, 2025 (the "Certified Final Judgment").
With respect to the specific subparts of this Interrogatory, TAG states that:
With respect to 1(a), through March 29, 2026, TAG seeks $1,385,489.46 plus all
attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8%
that is incurred after March 29, 2026, from the interpleaded funds. This sum is calculated as
follows: (1) $1,224,275.14 for the Final Judgment/Certified Final Judgment; (2) $97,941.93 in
pre-judgment simple interest at 8% from the date of breach of the Contract until the Final
Judgment was entered on August 29, 2025; $63,272.39 in post-judgment compound interest at
8% from August 29, 2025 through March 29, 2026.
With respect to 1(b), TAG's legal basis for its right to the proceeds is based upon the
Final Judgment and Certified Final Judgment entered by the United States District Court in the
Colorado Action.
With respect to 1(c), the amount TAG claims became a liquidated amount when the
3
claimallegation
TAG asserts Colorado-law entitlement to 8% simple prejudgment and compound postjudgment interest and fees under C.R.S. § 18-4-405. It estima
TAG asserts Colorado-law entitlement to 8% simple prejudgment and compound postjudgment interest and fees under C.R.S. § 18-4-405. It estimates current-action fees/costs exceed $50,000, proposes declarations if needed, and reserves supplementation. This is its legal and amount position, not an independent validation of rates, periods, entitlement or reasonableness.
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United States District Court in the Colorado Action first entered Final Judgment on August 29,
2025, and then again when it Certified the Final Judgment on December 19, 2025.
With respect to 1(d), based upon the Final Judgment and the Certified Final Judgment,
through March 29, 2026, TAG claims a security interest in and lien on $1,385,489.46 plus all
attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8%
that is incurred after March 29, 2026, from the interpleaded funds. The claimed priority date for
the Final Judgment is August 29, 2025, when the Final Judgment was first entered in the
Colorado Action. At worst, the claimed priority date is December 19, 2025, when the Certified
Final Judgment was Certified in the Colorado Action.
With respect to 1(e), TAG claims a right to interest and the amount of claimed interest is
set forth above. The basis for continuing accrual is that, under the governing Colorado law,
TAG is entitled to pre-judgment simple interest at 8% from the date of the breach of the Contract
until the date that the Final Judgment was entered on August 29, 2025. Under the governing
Colorado law, TAG also is entitled to post-judgment compound interest at 8% until the Final
Judgment/Certified Final Judgment is satisfied. TAG reserves the right to supplement this
response as the case proceeds and additional post-judgment interest is incurred.
With respect to 1(f), in accordance with C.R.S. § 18-4-405, TAG has a right to all
attorneys' fees and costs incurred in this action. To date, the attorneys fees and costs that TAG
has incurred are estimated to exceed $50,000 and continue to mount. If needed, TAG will
submit Declaration(s) and supporting evidence to prove-up its attorneys' fees and costs at the
appropriate time and in accordance with the governing Rules and/or Court Orders. TAG
reserves the right to supplement this response as the case proceeds and additional attorneys' fees
and costs are incurred.
4
claimallegation
Interrogatory 1(g) asks secured creditors for actual advance dates. TAG answers by referring to its 1(d) judgment-priority response rather t
Interrogatory 1(g) asks secured creditors for actual advance dates. TAG answers by referring to its 1(d) judgment-priority response rather than supplying a separate schedule of advances. The earlier contract/deposit narrative remains distinct from a demonstrated secured advance.
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Filed 04/15/26 Page 2 of 7 PageID# 2986
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
Case No. 3:25-cv-483
V.
CYBERLUX CORP., et al.,
Defendants.
THIN AIR GEAR, LLC'S OBJECTIONS AND RESPONSES TO INTERROGATORY
AND DOCUMENT REQUESTS
In accordance with Federal Rules of Civil Procedure 33 and 34 and the Court's February
19, 2026 Order entering the Joint Discovery Plan (ECF 149), Intervenor/Claimant Thin Air
Gear, LLC (“TAG”), by and through its undersigned counsel of record, respectfully submits
these Objections and Responses to the 1 Interrogatory and 2 Document Requests (the
"Request" or "Requests") set forth in the Joint Discovery Plan as follows:
INTERROGATORY 1: 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 attorney's fees and, if so, the basis therefore
and the amount you will claim; and (g) for any creditor claiming a secured interest, identify the
1
claimallegation
TAG raises attorney-client/work-product objections, incorporates absent ECF 115-1, and promises production of responsive documents in its po
TAG raises attorney-client/work-product objections, incorporates absent ECF 115-1, and promises production of responsive documents in its possession, custody or control for both general support and security/lien/assignment requests, subject to the objections. The promised documents and actual production are not included.
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
otherattribution
TAG will produce responsive documents within its possession, custody or control, subject to the stated privilege objections.
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
entityobservation
Thin Air Gear, LLC
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Filed 04/15/26 Page 2 of 7 PageID# 2986
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
HII MISSION TECHNOLOGIES
CORP.,
Plaintiff,
Case No. 3:25-cv-483
V.
CYBERLUX CORP., et al.,
Defendants.
THIN AIR GEAR, LLC'S OBJECTIONS AND RESPONSES TO INTERROGATORY
AND DOCUMENT REQUESTS
In accordance with Federal Rules of Civil Procedure 33 and 34 and the Court's February
19, 2026 Order entering the Joint Discovery Plan (ECF 149), Intervenor/Claimant Thin Air
Gear, LLC (“TAG”), by and through its undersigned counsel of record, respectfully submits
these Objections and Responses to the 1 Interrogatory and 2 Document Requests (the
"Request" or "Requests") set forth in the Joint Discovery Plan as follows:
INTERROGATORY 1: 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 attorney's fees and, if so, the basis therefore
and the amount you will claim; and (g) for any creditor claiming a secured interest, identify the
1
entityobservation
Cyberlux Corporation
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
entityobservation
Catalyst Machineworks, LLC
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
entityobservation
HII Mission Technologies Corp.
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
entityobservation
Stephen L. Neal, Jr.
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With respect to 1(g), see response to 1(d), supra.
TAG reserves the right to amend and/or supplement this Response based upon the
discovery of additional responsive information and/or documents.
DOCUMENT REQUEST 1: Documents supporting or otherwise concerning your answer
to the above interrogatory.
OBJECTION AND RESPONSE TO DOCUMENT REQUEST 1: TAG objects to this
Request on the ground that it calls for the production of information and documents protected
by the attorney-client privilege and attorney work-product doctrine. Subject to, and without
waiving, the forgoing Objection, TAG will produce responsive documents within its
possession, custody, and/or control.
DOCUMENT REQUEST 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.
OBJECTION AND RESPONSE TO DOCUMENT REQUEST 2: TAG objects to this
Request on the ground that it calls for the production of information and documents protected
by the attorney-client privilege and attorney work-product doctrine. Subject to, and without
waiving, the forgoing Objection, TAG will produce responsive documents within its
possession, custody, and/or control.
TAG reserves the right to amend and/or supplement these Responses based upon the
discovery of additional responsive information and/or documents.
Dated: March 9, 2026
Respectfully submitted,
/s/ Stephen L. Neal, Jr., Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
5
entityobservation
Stephen J. Stine
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With respect to 1(g), see response to 1(d), supra.
TAG reserves the right to amend and/or supplement this Response based upon the
discovery of additional responsive information and/or documents.
DOCUMENT REQUEST 1: Documents supporting or otherwise concerning your answer
to the above interrogatory.
OBJECTION AND RESPONSE TO DOCUMENT REQUEST 1: TAG objects to this
Request on the ground that it calls for the production of information and documents protected
by the attorney-client privilege and attorney work-product doctrine. Subject to, and without
waiving, the forgoing Objection, TAG will produce responsive documents within its
possession, custody, and/or control.
DOCUMENT REQUEST 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.
OBJECTION AND RESPONSE TO DOCUMENT REQUEST 2: TAG objects to this
Request on the ground that it calls for the production of information and documents protected
by the attorney-client privilege and attorney work-product doctrine. Subject to, and without
waiving, the forgoing Objection, TAG will produce responsive documents within its
possession, custody, and/or control.
TAG reserves the right to amend and/or supplement these Responses based upon the
discovery of additional responsive information and/or documents.
Dated: March 9, 2026
Respectfully submitted,
/s/ Stephen L. Neal, Jr., Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
5
eventattribution
TAG reports bag contract.
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date(s) on which advances were made to Cyberlux or on its behalf for which any secured
interest is claimed.
OBJECTION AND RESPONSE TO INTERROGATORY 1: TAG objects to this
Interrogatory on the ground that it calls for the production of information and documents
protected by the attorney-client privilege and attorney work-product doctrine. Subject to, and
without waiving, the forgoing Objection, TAG states that the nature of TAG's claim to any of the
proceeds that are the subject of this interpleader action is set forth in detail in its Complaint in
Intervention (ECF 115-1), which is incorporated herein by reference. In summary, on
September 5, 2023, Cyberlux Corporation d/b/a Catalyst Machineworks, LLC, a wholly owned
subsidiary of Cyberlux Corporation (collectively, "Cyberlux") entered into a contract (the
"Contract") with TAG to produce 2,100 wheeled drone kit bags (the "drone kit bags"). These
drone kit bags were manufactured and sold to Cyberlux pursuant to the Subcontract (the
"Subcontract") between Cyberlux and Plaintiff HII Mission Technologies Corp. ("HII") that is
the subject of HII's First Amended Complaint for Interpleader (the "Amended Complaint"). See
ECF 41 at ¶¶ 17-30. The total agreed contract price for the Contract was $887,900.00. Cyberlux
paid a deposit of $150,000 on September 14, 2023. TAG produced and assembled all 2,100
drone kit bags pursuant to the Contract. TAG then delivered 1,722 of the drone kit bags to
Cyberlux's warehouse in Spring, Texas. The remaining 378 drone kit bags are stored at TAG
pending final payment on the Contract. As of November 18, 2024, the balance due, including a
1.5% late fee per month on past due amounts, was $365,049.42. TAG sent multiple demands to
Cyberlux for payment of the remaining balance, but received no response to any of these
demands.
Because Cyberlux was in material breach of the Contract, on March 12, 2025, TAG filed
2
eventattribution
TAG reports Colorado default judgment.
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a diversity action against Cyberlux in the U.S. District Court for the District of Colorado, Case
No. 1:25-cv-00805 (the "Colorado Action"), alleging breach of contract, just enrichment, and
civil theft under Colorado law, which provides for treble damages, attorneys' fees, and costs if
TAG prevailed in the Colorado Action.
Although Cyberlux was properly served with the complaint in the Colorado Action,
Cyberlux refused or failed to file an answer or otherwise respond to the complaint. Accordingly,
TAG moved for entry of default judgment against Cyberlux. On August 29, 2025, that motion
was granted and Final Judgment was entered against Cyberlux in the total amount of
$1,224,275.14 (the "Final Judgment"), which consisted of treble damages in the amount of
$1,220,838.54, attorneys' fees in the amount of $2,765.00, and costs in the amount of $671.60.
The Final Judgment was Certified on December 19, 2025 (the "Certified Final Judgment").
With respect to the specific subparts of this Interrogatory, TAG states that:
With respect to 1(a), through March 29, 2026, TAG seeks $1,385,489.46 plus all
attorneys' fees and costs incurred in this action and any post-judgment compound interest at 8%
that is incurred after March 29, 2026, from the interpleaded funds. This sum is calculated as
follows: (1) $1,224,275.14 for the Final Judgment/Certified Final Judgment; (2) $97,941.93 in
pre-judgment simple interest at 8% from the date of breach of the Contract until the Final
Judgment was entered on August 29, 2025; $63,272.39 in post-judgment compound interest at
8% from August 29, 2025 through March 29, 2026.
With respect to 1(b), TAG's legal basis for its right to the proceeds is based upon the
Final Judgment and Certified Final Judgment entered by the United States District Court in the
Colorado Action.
With respect to 1(c), the amount TAG claims became a liquidated amount when the
3
eventattribution
Counsel dates response and email-service certificate.
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With respect to 1(g), see response to 1(d), supra.
TAG reserves the right to amend and/or supplement this Response based upon the
discovery of additional responsive information and/or documents.
DOCUMENT REQUEST 1: Documents supporting or otherwise concerning your answer
to the above interrogatory.
OBJECTION AND RESPONSE TO DOCUMENT REQUEST 1: TAG objects to this
Request on the ground that it calls for the production of information and documents protected
by the attorney-client privilege and attorney work-product doctrine. Subject to, and without
waiving, the forgoing Objection, TAG will produce responsive documents within its
possession, custody, and/or control.
DOCUMENT REQUEST 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.
OBJECTION AND RESPONSE TO DOCUMENT REQUEST 2: TAG objects to this
Request on the ground that it calls for the production of information and documents protected
by the attorney-client privilege and attorney work-product doctrine. Subject to, and without
waiving, the forgoing Objection, TAG will produce responsive documents within its
possession, custody, and/or control.
TAG reserves the right to amend and/or supplement these Responses based upon the
discovery of additional responsive information and/or documents.
Dated: March 9, 2026
Respectfully submitted,
/s/ Stephen L. Neal, Jr., Esq.
Stephen J. Stine, Esq. (VSB# 66738)
Stephen L. Neal, Jr., Esq. (VSB# 87064)
5
eventattribution
Response filed as Exhibit 27.
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EXHIBIT 27
Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 1 of 7 PageID# 2985
inferenceinference
The response gives a traceable judgment-based claim but does not itself bridge debt liquidation to perfected priority in a specific fund. TA
The response gives a traceable judgment-based claim but does not itself bridge debt liquidation to perfected priority in a specific fund. TAG’s dates and legal labels should remain attributed claims.
inferenceinference
The March 29 calculation is forward-dated relative to March 9 execution; it may be a projection and cannot be represented as an already accr
The March 29 calculation is forward-dated relative to March 9 execution; it may be a projection and cannot be represented as an already accrued March 9 balance.
otherattribution
Complete supplied 7-page source reviewed at SHA-256 3bd2104bfe67f28cdd269d4bdf3f061a930d944407ce643a7971e6c362341c65. Source assertions, ori
Complete supplied 7-page source reviewed at SHA-256 3bd2104bfe67f28cdd269d4bdf3f061a930d944407ce643a7971e6c362341c65. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. All seven source pages fully read in own images; native extraction was stamp-only on substantive pages. Full six-page OCR aid compared with images and corrected; original OCR and source hashes preserved. No recovery of hidden/redacted material.
Read the anchor · page 1
EXHIBIT 27
Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 1 of 7 PageID# 2985
questionquestion
What contract, delivery records and payment ledger reconcile the stated contract price and deposit with the November 2024 balance?
questionquestion
What entered judgment, interest calculation and perfection/priority records establish the enforceable present amount against the interpleade
What entered judgment, interest calculation and perfection/priority records establish the enforceable present amount against the interpleader fund?
questionquestion
Were the promised supporting documents produced, and what actual secured-advance dates answer subpart 1(g)?
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.
TAG claims $1,385,489.46 through 29 March 2026, comprising $1,224,275.14 judgment, $97,941.93 prejudgment simple interest at 8% and $63,272.39 postjudgment compound interest at 8%, plus further postjudgment interest and this action’s fees/costs. Those components add to the claimed total. The calculation end date is later than the response’s 9 March signature/service date.supportsThe March 29 calculation is forward-dated relative to March 9 execution; it may be a projection and cannot be represented as an already accrued March 9 balance.
Specifically named source propositions support the bounded distinction or question.
TAG says it filed Colorado action 1:25-cv-00805 on 12 March 2025 for breach, civil theft and what the supplied page literally prints as “just enrichment”. It claims proper service and no answer. It reports an August 29, 2025 default judgment of $1,224,275.14: $1,220,838.54 treble damages, $2,765 fees and $671.60 costs. Certification is dated 19 December 2025; it is not presented here as a second additive principal debt.supportsThe response gives a traceable judgment-based claim but does not itself bridge debt liquidation to perfected priority in a specific fund. TAG’s dates and legal labels should remain attributed claims.
Specifically named source propositions support the bounded distinction or question.
TAG reports a 5 September 2023 contract with Cyberlux Corporation d/b/a Catalyst Machineworks LLC, described as its wholly owned subsidiary, for 2,100 wheeled drone kit bags at $887,900. It reports a $150,000 deposit on 14 September 2023. The response connects the bag manufacture to the HII subcontract but does not attach the original contract.supportsWhat contract, delivery records and payment ledger reconcile the stated contract price and deposit with the November 2024 balance?
Specifically named source propositions support the bounded distinction or question.
TAG bases liquidation and its asserted security interest/lien on the Colorado judgment and certification. It asserts priority from 29 August 2025 or, “At worst”, 19 December 2025. The response supplies no independent security agreement, perfection record or ruling establishing priority in the HII fund.supportsDoes TAG’s response establish a perfected first claim to $1,385,489.46 of the fund?
Specifically named source propositions support the bounded distinction or question.
The March 29 calculation is forward-dated relative to March 9 execution; it may be a projection and cannot be represented as an already accrued March 9 balance.supportsDoes TAG’s response establish a perfected first claim to $1,385,489.46 of the fund?
Specifically named source propositions support the bounded distinction or question.
TAG bases liquidation and its asserted security interest/lien on the Colorado judgment and certification. It asserts priority from 29 August 2025 or, “At worst”, 19 December 2025. The response supplies no independent security agreement, perfection record or ruling establishing priority in the HII fund.supportsThe response gives a traceable judgment-based claim but does not itself bridge debt liquidation to perfected priority in a specific fund. TAG’s dates and legal labels should remain attributed claims.
Specifically named source propositions support the bounded distinction or question.
TAG claims $1,385,489.46 through 29 March 2026, comprising $1,224,275.14 judgment, $97,941.93 prejudgment simple interest at 8% and $63,272.39 postjudgment compound interest at 8%, plus further postjudgment interest and this action’s fees/costs. Those components add to the claimed total. The calculation end date is later than the response’s 9 March signature/service date.supportsDoes TAG’s response establish a perfected first claim to $1,385,489.46 of the fund?
Specifically named source propositions support the bounded distinction or question.
TAG says it filed Colorado action 1:25-cv-00805 on 12 March 2025 for breach, civil theft and what the supplied page literally prints as “just enrichment”. It claims proper service and no answer. It reports an August 29, 2025 default judgment of $1,224,275.14: $1,220,838.54 treble damages, $2,765 fees and $671.60 costs. Certification is dated 19 December 2025; it is not presented here as a second additive principal debt.supportsDoes TAG’s response establish a perfected first claim to $1,385,489.46 of the fund?
Specifically named source propositions support the bounded distinction or question.
TAG raises attorney-client/work-product objections, incorporates absent ECF 115-1, and promises production of responsive documents in its possession, custody or control for both general support and security/lien/assignment requests, subject to the objections. The promised documents and actual production are not included.supportsDoes TAG’s response establish a perfected first claim to $1,385,489.46 of the fund?
Specifically named source propositions support the bounded distinction or question.
TAG says it filed Colorado action 1:25-cv-00805 on 12 March 2025 for breach, civil theft and what the supplied page literally prints as “just enrichment”. It claims proper service and no answer. It reports an August 29, 2025 default judgment of $1,224,275.14: $1,220,838.54 treble damages, $2,765 fees and $671.60 costs. Certification is dated 19 December 2025; it is not presented here as a second additive principal debt.supportsWhat entered judgment, interest calculation and perfection/priority records establish the enforceable present amount against the interpleader fund?
Specifically named source propositions support the bounded distinction or question.
TAG asserts Colorado-law entitlement to 8% simple prejudgment and compound postjudgment interest and fees under C.R.S. § 18-4-405. It estimates current-action fees/costs exceed $50,000, proposes declarations if needed, and reserves supplementation. This is its legal and amount position, not an independent validation of rates, periods, entitlement or reasonableness.supportsWhat entered judgment, interest calculation and perfection/priority records establish the enforceable present amount against the interpleader fund?
Specifically named source propositions support the bounded distinction or question.
TAG says it produced all 2,100 bags, delivered 1,722 to Cyberlux’s Spring, Texas warehouse and retains 378 pending final payment. It reports a $365,049.42 balance as of 18 November 2024, including a 1.5% monthly late fee, and unanswered demands. The response contains no ledger bridging contract price less deposit to that balance.supportsWhat contract, delivery records and payment ledger reconcile the stated contract price and deposit with the November 2024 balance?
Specifically named source propositions support the bounded distinction or question.
TAG claims $1,385,489.46 through 29 March 2026, comprising $1,224,275.14 judgment, $97,941.93 prejudgment simple interest at 8% and $63,272.39 postjudgment compound interest at 8%, plus further postjudgment interest and this action’s fees/costs. Those components add to the claimed total. The calculation end date is later than the response’s 9 March signature/service date.supportsWhat entered judgment, interest calculation and perfection/priority records establish the enforceable present amount against the interpleader fund?
Specifically named source propositions support the bounded distinction or question.
TAG bases liquidation and its asserted security interest/lien on the Colorado judgment and certification. It asserts priority from 29 August 2025 or, “At worst”, 19 December 2025. The response supplies no independent security agreement, perfection record or ruling establishing priority in the HII fund.supportsWhat entered judgment, interest calculation and perfection/priority records establish the enforceable present amount against the interpleader fund?
Specifically named source propositions support the bounded distinction or question.
TAG raises attorney-client/work-product objections, incorporates absent ECF 115-1, and promises production of responsive documents in its possession, custody or control for both general support and security/lien/assignment requests, subject to the objections. The promised documents and actual production are not included.supportsWere the promised supporting documents produced, and what actual secured-advance dates answer subpart 1(g)?
Specifically named source propositions support the bounded distinction or question.
Interrogatory 1(g) asks secured creditors for actual advance dates. TAG answers by referring to its 1(d) judgment-priority response rather than supplying a separate schedule of advances. The earlier contract/deposit narrative remains distinct from a demonstrated secured advance.supportsWere the promised supporting documents produced, and what actual secured-advance dates answer subpart 1(g)?
Specifically named source propositions support the bounded distinction or question.
EDVA Document 175-29 Exhibit 27, filed 15 April 2026, contains Thin Air Gear LLC’s objections and responses under the 19 February 2026 Joint Discovery Plan, ECF 149. Counsel dates and certifies email service on 9 March 2026. No separate party oath or verification is included.supportsThe March 29 calculation is forward-dated relative to March 9 execution; it may be a projection and cannot be represented as an already accrued March 9 balance.
Specifically named source propositions support the bounded distinction or question.
The response gives a traceable judgment-based claim but does not itself bridge debt liquidation to perfected priority in a specific fund. TAG’s dates and legal labels should remain attributed claims.supportsDoes TAG’s response establish a perfected first claim to $1,385,489.46 of the fund?
Specifically named source propositions support the bounded distinction or question.
Interrogatory 1(g) asks secured creditors for actual advance dates. TAG answers by referring to its 1(d) judgment-priority response rather than supplying a separate schedule of advances. The earlier contract/deposit narrative remains distinct from a demonstrated secured advance.supportsDoes TAG’s response establish a perfected first claim to $1,385,489.46 of the fund?
Specifically named source propositions support the bounded distinction or question.
WEIGH
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