The evidence/CXF-S-3BD2104BFE67

Context source · CXF-S-3BD2104BFE67

Exhibit 27

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SHA-256 3bd2104bfe67f28cdd26…7 pages · 5 MB

DISTILLATES

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observationobservation

2,100 bags = 1,722 reportedly delivered + 378 retained.

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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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 Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 1 of 7 PageID# 2985
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 Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 1 of 7 PageID# 2985
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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 6 of 7 PageID# 2990 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 4 of 7 PageID# 2988 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 4 of 7 PageID# 2988 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 5 of 7 PageID# 2989 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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Case 3:25-cv-00483-JAG Document 175-29 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 6 of 7 PageID# 2990 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 6 of 7 PageID# 2990 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 3 of 7 PageID# 2987 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 4 of 7 PageID# 2988 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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Case 3:25-cv-00483-JAG Document 175-29 Filed 04/15/26 Page 6 of 7 PageID# 2990 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.

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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
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%

WEIGH

Explained weighting

A score appears only when its components and change threshold are published.

No published WEIGH run

The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.