Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
claimallegation
The August 4, 2025 federal Exhibit 7 contains an April 24–May 19 email chain. Walton’s April 24 and May 6 messages identify an initial and s
The August 4, 2025 federal Exhibit 7 contains an April 24–May 19 email chain. Walton’s April 24 and May 6 messages identify an initial and supplemental Atlantic Wave letter concerning funds held for Cyberlux. The referenced letters are not reproduced in this nine-page exhibit.
Read the anchor · page 1
EXHIBIT 7
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 1 of 9 PageID# 540
claimallegation
Belote asks what amount Atlantic Wave contends is secured, contrasting more than $7,774,000 claimed in the April 24 letter with a minimum $9
Belote asks what amount Atlantic Wave contends is secured, contrasting more than $7,774,000 claimed in the April 24 letter with a minimum $912,000 judgment balance. Petersen points to the garnishment summons. Belote distinguishes a separate claimed security interest from the judgment lien and asks whether it exceeds the summons’ approximately $1.44 million. His questions seek clarification; they do not concede priority or enforceability.
Read the anchor · page 4
3
dwalton@bellnunnally.com
T: 214.740.1445 | F: 214.740.5745
2323 Ross Avenue, Suite 1900 | Dallas, Texas 75201
LinkedIn | Facebook | Twitter | View Bio
www.bellnunnally.com
IMPORTANT \ CONFIDENTIAL: This message contains information from the law firm of Bell Nunnally & Martin LLP that may be subject to the attorney-client
privilege or work product doctrine, or may be otherwise confidential and exempt from disclosure under applicable law. Unless expressly stated otherwise,
nothing contained in this message should be construed as a digital or electronic signature, nor is this message intended to reflect an intention to make an
agreement by electronic means. DO NOT COPY OR FORWARD TO UNAUTHORIZED PERSONS. If you are not the intended recipient or the employee or agent
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, copying or forwarding of this
communication is strictly prohibited. Unauthorized interception of this message may be in violation of the Electronic Communications Privacy Act, 18 U.S.C. §
2510, et seq. If you have received this communication in error, please notify us immediately at our telephone number: (214) 740-1400.
From: Belote, Clark J. <clark.belote@kaufcan.com>
Sent: Thursday, May 15, 2025 1:52 PM
To: Chap Petersen <jcp@petersenfirm.com>; David A. Walton <dwalton@bellnunnally.com>
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds [IMAN-IMANACTIVE.FID760274]
This Message has originated outside your organization.
Chap, not exactly.
In addition to the judgment lien, my understanding is that AW contends that it has a separate security interest
in Cyberlux’s accounts, which AW contends it perfected with the UCC-1 filing in the attached. The June 28,
2023 Amended Final Order Judgment says: “That the parties have agreed to a security interest and lien
interest in all property of Defendants in favor of Plaintiffs until all sums are paid, and such security interest may
be further memorialized through the filing of appropriate UCC-1 forms and the filing of appropriate Liens.”
I wanted to understand whether Atlantic Wave contends that its debt or claims against Cyberlux are secured in
an amount over and above the $1.44mm on the face of the garnishment summons. The answer may be no.
But, it would be helpful for HII to understand Atlantic Wave’s position.
Thanks
Clark J. Belote
Kaufman & Canoles, P.C.
clark.belote@kaufcan.com
T. (757) 624.3109
F. (888) 360.9092
150 W. Main Street, Suite 2100
Norfolk, VA 23510
www.kaufCAN.com
LinkedIn
From: Chap Petersen <jcp@petersenfirm.com>
Sent: Thursday, May 15, 2025 2:32 PM
To: Belote, Clark J. <clark.belote@kaufcan.com>; David A. Walton <dwalton@bellnunnally.com>
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds [IMAN-IMANACTIVE.FID760274]
Clark:
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 4 of 9 PageID# 543
claimallegation
Walton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-relat
Walton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-related fees, stock-status damages and all assets. He alleges defaults permitting enforcement and says Virginia, Texas and North Carolina UCC forms are attached. Those Atlantic Wave forms are not included here; the exhibit ends with two Legalist forms. He authorises direct discussion with Will Welter.
Read the anchor · page 3
2
Just to clarify one more thing: does AW contend that its claimed security interest in the accounts receivable of
Cyberlux has priority over the claimed security interest of Legalist in Cyberlux’s accounts receivable?
Clark J. Belote
Kaufman & Canoles, P.C.
clark.belote@kaufcan.com
T. (757) 624.3109
F. (888) 360.9092
150 W. Main Street, Suite 2100
Norfolk, VA 23510
www.kaufCAN.com
LinkedIn
From: David A. Walton <dwalton@bellnunnally.com>
Sent: Monday, May 19, 2025 9:56 AM
To: Belote, Clark J. <clark.belote@kaufcan.com>; willwelter@aol.com
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>; Chap Petersen <jcp@petersenfirm.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds
Clark:
Please feel free to further discuss this issue with Will Welter, copied on this email. You are authorized to speak
with him directly, as needed.
Put simply, yes, Atlantic Wave’s position is it has a security interest in debts or claims against Cyberlux over and above the $1.44mm on the face of the garnishment summons. The settlement agreement between Cyberlux and Atlantic Wave provides for more than just the actual amount owed under the Amended Final Order and Judgment, for example, it provides Atlantic Wave the right to repayment of attorneys’ fees and costs in any action caused by a breach of the settlement agreement, and damages associated with the failure to bring Cyberlux’s stock to Pink Current status and to remedy the caveat emptor classification on such stock. Moreover, the settlement agreement explicitly provides: “Defendants [Cyberlux & Schmidt] agree and grant to Plaintiff [Atlantic Wave & Secure Community] a full security interest and lien interest in all of Defendants’ assets, including but not limited to IP, subsidiaries, contractual rights, accounts receivables, drone sales, etc., which may, in Plaintiff’s sole discretion, be memorialized through the filing of UCC-1 forms and Liens.”
Atlantic Wave contends that Cyberlux has defaulted on the settlement agreement in several respects as set forth in prior communications and filings, which permits Atlantic Wave to enforce the security interest (authorized by the settlement agreement) against Cyberlux on the collateral or assets described in the UCC-1 forms. Attached are those UCC-1 forms that were filed in Virginia, Texas, and North Carolina.
Please feel free to call me at your convenience to discuss.
Take care,
David
David A. Walton | Partner
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 3 of 9 PageID# 542
claimallegation
After Belote asks whether Atlantic Wave claims priority over Legalist, Walton answers yes at 2:41 PM on May 19. He asserts perfection by Jul
After Belote asks whether Atlantic Wave claims priority over Legalist, Walton answers yes at 2:41 PM on May 19. He asserts perfection by July 2023 in Virginia, Texas and North Carolina, contrasts Legalist’s April and July 2024 North Carolina stamps, and on information and belief says Legalist’s interest could not arise before April 2024 receivables sales. These are advocacy positions, not proof of attachment, governing jurisdiction or priority.
Read the anchor · page 2
1
Mohamed Khalil, Ahmed
From: David A. Walton <dwalton@bellnunnally.com>
Sent: Monday, May 19, 2025 2:41 PM
To: Belote, Clark J.; willwelter@aol.com
Cc: David M. Keithly; Evan Sherwood; Freling, Scott; Chap Petersen
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds
Attachments: 2024.04.01_Legalist UCC-1 (North Carolina)-Cyberlux.pdf; 2024.07.15_Legalist UCC-1
(North Carolina)-Schmidt.pdf
Clark:
Yes, Atlantic Wave contends it has priority over Legalist. Atlantic Wave perfected its security interest in July 2023, at the latest, in Virginia, Texas, and North Carolina, whereas the file-stamps on Legalist’s UCC-1 forms, attached hereto, are in April 2024 (as to Cyberlux) and July 2024 (as to Schmidt) in North Carolina only.
Moreover, upon information and belief, the basis of Legalist’s security interest did not and could not arise until April 2024 at the earliest when Cyberlux sold receivables from the drone contract to Legalist—that is, more than eight months after Atlantic Wave had perfected its security interest.
Take care,
David
David A. Walton | Partner
dwalton@bellnunnally.com
T: 214.740.1445 | F: 214.740.5745
2323 Ross Avenue, Suite 1900 | Dallas, Texas 75201
LinkedIn | Facebook | Twitter | View Bio
www.bellnunnally.com
IMPORTANT \ CONFIDENTIAL: This message contains information from the law firm of Bell Nunnally & Martin LLP that may be subject to the attorney-client
privilege or work product doctrine, or may be otherwise confidential and exempt from disclosure under applicable law. Unless expressly stated otherwise,
nothing contained in this message should be construed as a digital or electronic signature, nor is this message intended to reflect an intention to make an
agreement by electronic means. DO NOT COPY OR FORWARD TO UNAUTHORIZED PERSONS. If you are not the intended recipient or the employee or agent
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, copying or forwarding of this
communication is strictly prohibited. Unauthorized interception of this message may be in violation of the Electronic Communications Privacy Act, 18 U.S.C. §
2510, et seq. If you have received this communication in error, please notify us immediately at our telephone number: (214) 740-1400.
From: Belote, Clark J. <clark.belote@kaufcan.com>
Sent: Monday, May 19, 2025 1:15 PM
To: David A. Walton <dwalton@bellnunnally.com>; willwelter@aol.com
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>; Chap Petersen <jcp@petersenfirm.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds [IMAN-IMANACTIVE.FID760274]
This Message has originated outside your organization.
Thank you, David.
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 2 of 9 PageID# 541
claimallegation
Attached Exhibit A identifies CYBERLUX CORPORATION as debtor and Legalist SPV III, LP as secured party, collateral All assets. The visually
Attached Exhibit A identifies CYBERLUX CORPORATION as debtor and Legalist SPV III, LP as secured party, collateral All assets. The visually checked North Carolina stamp is file 20240038686M, April 1, 2024 at 7:44 PM. Corporation Service Company is the filer, not the lender.
Read the anchor · page 8
[Overprinted exhibit filing headers; black redactions in upper-left header area.]
File Number: 20240038686M
Date Filed: 4/1/2024 7:44:00 PM
Elaine F. Marshall
NC Secretary of State
UCC FINANCING STATEMENT
FOLLOW INSTRUCTIONS
A. NAME & PHONE OF CONTACT AT FILER (optional)
Corporation Service Company
B. E-MAIL CONTACT AT FILER (optional)
SPRFiling@cscglobal.com
C. SEND ACKNOWLEDGMENT TO: (Name and Address)
Corporation Service Company
801 Adlai Stevenson Drive
Springfield, IL 62703
THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY
1. DEBTOR'S NAME: Provide only one Debtor name (1a or 1b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 1b, leave all of item 1 blank, check here
and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
1a. ORGANIZATION'S NAME
OR
CYBERLUX CORPORATION
1b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
SUFFIX
1c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
800 Park Offices Dr., Ste. 3209
Research Triangle
NC
27709
USA
2. DEBTOR'S NAME: Provide only one Debtor name (2a or 2b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 2b, leave all of item 2 blank, check here
and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
2a. ORGANIZATION'S NAME
OR 2b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
SUFFIX
2c. MAILING ADDRESS
CITY
STATE POSTAL CODE
COUNTRY
3. SECURED PARTY'S NAME (or NAME of ASSIGNEE of ASSIGNOR SECURED PARTY): Provide only one Secured Party name (3a or 3b)
3а. ORGANIZATION'S NAME
Legalist SPV III, LP
OR 3b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
I SUFFIX
3c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
58 West Portal Ave. #747
San Francisco
CA
94127
USA
4. COLLATERAL: This financing statement covers the following collateral:
All assets
5. Check only if applicable and check only one box: Collateral is
held in a Trust (see UCC1Ad, item 17 and Instructions)
being administered by a Decedent's Personal Representative
ba. Check only if applicable and check only one box:
6b. Check only if applicable and check only one box:
Public-Finance Transaction
Manufactured-Home Transaction
A Debtor is a Transmitting Utility
Agricultural Lien
Non-UCC Filing
7. ALTERNATIVE DESIGNATION (if applicable):
Lessee/Lessor
Consignee/Consignor
Seller/Buyer
Bailee/Bailor
Licensee/Licensor
8. OPTIONAL FILER REFERENCE DATA:
2797 73186
FILING OFFICE COPY - UCC FINANCING STATEMENT (Form UCC1) (Rev. 04/20/11)
International Association of Commercial Administrators (IACA)
claimallegation
Attached Exhibit B names debtor SCHMIDT, MARK, D. and Legalist SPV III, LP, collateral All assets. Its visually checked North Carolina stamp
Attached Exhibit B names debtor SCHMIDT, MARK, D. and Legalist SPV III, LP, collateral All assets. Its visually checked North Carolina stamp is 20240084460A, July 15, 2024 at 8:27 AM. Both forms have upper-left black redactions and overlapping exhibit headers, and neither supplies the underlying security agreement or debt balance.
Read the anchor · page 9
[Overprinted exhibit filing headers; black redactions in upper-left header area.]
File Number: 20240084460A
Date Filed: 7/15/2024 8:27:00 AM
Elaine F. Marshall
NC Secretary of State
UCC FINANCING STATEMENT
FOLLOW INSTRUCTIONS
A. NAME & PHONE OF CONTACT AT FILER (optional)
Corporation Service Company
B. E-MAIL CONTACT AT FILER (optional)
SPRFiling@cscglobal.com
C. SEND ACKNOWLEDGMENT TO: (Name and Address)
Corporation Service Company
801 Adlai Stevenson Drive
Springfield, IL 62703
THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY
1. DEBTOR'S NAME: Provide only one Debtor name (1a or 1b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 1b, leave all of item 1 blank, check here
and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
1a. ORGANIZATION'S NAME
OR 1b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
SUFFIX
SCHMIDT
MARK
D.
1c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
1134 Fearrington Post
Pittsboro
NC
27312
USA
2. DEBTOR'S NAME: Provide only one Debtor name (2a or 2b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 2b, leave all of item 2 blank, check here and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
2a. ORGANIZATION'S NAME
OR 2b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME (S)/INITIAL(S)
SUFFIX
2c. MAILING ADDRESS
CITY
STATE POSTAL CODE
COUNTRY
3. SECURED PARTY'S NAME (or NAME of ASSIGNEE of ASSIGNOR SECURED PARTY): Provide only one Secured Party name (3a or 3b)
3а. ORGANIZATION'S NAME
Legalist SPV III, LP
OR 3b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
I SUFFIX
3c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
58 West Portal Ave. #747
San Francisco
CA
94127
USA
4. COLLATERAL: This financing statement covers the following collateral:
All assets
5. Check only if applicable and check only one box: Collateral is
held in a Trust (see UCC1Ad, item 17 and Instructions)
being administered by a Decedent's Personal Representative
ba. Check only if applicable and check only one box:
6b. Check only if applicable and check only one box:
Public-Finance Transaction
Manufactured-Home Transaction
A Debtor is a Transmitting Utility
Agricultural Lien
Non-UCC Filing
7. ALTERNATIVE DESIGNATION (if applicable):
Lessee/Lessor
Consignee/Consignor
Seller/Buyer
Bailee/Bailor
Licensee/Licensor
8. OPTIONAL FILER REFERENCE DATA:
2879 27331
FILING OFFICE COPY - UCC FINANCING STATEMENT (Form UCC1) (Rev. 04/20/11)
International Association of Commercial Administrators (IACA)
entityobservation
David A. Walton
Read the anchor · page 2
1
Mohamed Khalil, Ahmed
From: David A. Walton <dwalton@bellnunnally.com>
Sent: Monday, May 19, 2025 2:41 PM
To: Belote, Clark J.; willwelter@aol.com
Cc: David M. Keithly; Evan Sherwood; Freling, Scott; Chap Petersen
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds
Attachments: 2024.04.01_Legalist UCC-1 (North Carolina)-Cyberlux.pdf; 2024.07.15_Legalist UCC-1
(North Carolina)-Schmidt.pdf
Clark:
Yes, Atlantic Wave contends it has priority over Legalist. Atlantic Wave perfected its security interest in July 2023, at the latest, in Virginia, Texas, and North Carolina, whereas the file-stamps on Legalist’s UCC-1 forms, attached hereto, are in April 2024 (as to Cyberlux) and July 2024 (as to Schmidt) in North Carolina only.
Moreover, upon information and belief, the basis of Legalist’s security interest did not and could not arise until April 2024 at the earliest when Cyberlux sold receivables from the drone contract to Legalist—that is, more than eight months after Atlantic Wave had perfected its security interest.
Take care,
David
David A. Walton | Partner
dwalton@bellnunnally.com
T: 214.740.1445 | F: 214.740.5745
2323 Ross Avenue, Suite 1900 | Dallas, Texas 75201
LinkedIn | Facebook | Twitter | View Bio
www.bellnunnally.com
IMPORTANT \ CONFIDENTIAL: This message contains information from the law firm of Bell Nunnally & Martin LLP that may be subject to the attorney-client
privilege or work product doctrine, or may be otherwise confidential and exempt from disclosure under applicable law. Unless expressly stated otherwise,
nothing contained in this message should be construed as a digital or electronic signature, nor is this message intended to reflect an intention to make an
agreement by electronic means. DO NOT COPY OR FORWARD TO UNAUTHORIZED PERSONS. If you are not the intended recipient or the employee or agent
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, copying or forwarding of this
communication is strictly prohibited. Unauthorized interception of this message may be in violation of the Electronic Communications Privacy Act, 18 U.S.C. §
2510, et seq. If you have received this communication in error, please notify us immediately at our telephone number: (214) 740-1400.
From: Belote, Clark J. <clark.belote@kaufcan.com>
Sent: Monday, May 19, 2025 1:15 PM
To: David A. Walton <dwalton@bellnunnally.com>; willwelter@aol.com
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>; Chap Petersen <jcp@petersenfirm.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds [IMAN-IMANACTIVE.FID760274]
This Message has originated outside your organization.
Thank you, David.
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 2 of 9 PageID# 541
entityobservation
Clark J. Belote
Read the anchor · page 3
2
Just to clarify one more thing: does AW contend that its claimed security interest in the accounts receivable of
Cyberlux has priority over the claimed security interest of Legalist in Cyberlux’s accounts receivable?
Clark J. Belote
Kaufman & Canoles, P.C.
clark.belote@kaufcan.com
T. (757) 624.3109
F. (888) 360.9092
150 W. Main Street, Suite 2100
Norfolk, VA 23510
www.kaufCAN.com
LinkedIn
From: David A. Walton <dwalton@bellnunnally.com>
Sent: Monday, May 19, 2025 9:56 AM
To: Belote, Clark J. <clark.belote@kaufcan.com>; willwelter@aol.com
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>; Chap Petersen <jcp@petersenfirm.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds
Clark:
Please feel free to further discuss this issue with Will Welter, copied on this email. You are authorized to speak
with him directly, as needed.
Put simply, yes, Atlantic Wave’s position is it has a security interest in debts or claims against Cyberlux over and above the $1.44mm on the face of the garnishment summons. The settlement agreement between Cyberlux and Atlantic Wave provides for more than just the actual amount owed under the Amended Final Order and Judgment, for example, it provides Atlantic Wave the right to repayment of attorneys’ fees and costs in any action caused by a breach of the settlement agreement, and damages associated with the failure to bring Cyberlux’s stock to Pink Current status and to remedy the caveat emptor classification on such stock. Moreover, the settlement agreement explicitly provides: “Defendants [Cyberlux & Schmidt] agree and grant to Plaintiff [Atlantic Wave & Secure Community] a full security interest and lien interest in all of Defendants’ assets, including but not limited to IP, subsidiaries, contractual rights, accounts receivables, drone sales, etc., which may, in Plaintiff’s sole discretion, be memorialized through the filing of UCC-1 forms and Liens.”
Atlantic Wave contends that Cyberlux has defaulted on the settlement agreement in several respects as set forth in prior communications and filings, which permits Atlantic Wave to enforce the security interest (authorized by the settlement agreement) against Cyberlux on the collateral or assets described in the UCC-1 forms. Attached are those UCC-1 forms that were filed in Virginia, Texas, and North Carolina.
Please feel free to call me at your convenience to discuss.
Take care,
David
David A. Walton | Partner
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 3 of 9 PageID# 542
entityobservation
Will Welter
Read the anchor · page 3
2
Just to clarify one more thing: does AW contend that its claimed security interest in the accounts receivable of
Cyberlux has priority over the claimed security interest of Legalist in Cyberlux’s accounts receivable?
Clark J. Belote
Kaufman & Canoles, P.C.
clark.belote@kaufcan.com
T. (757) 624.3109
F. (888) 360.9092
150 W. Main Street, Suite 2100
Norfolk, VA 23510
www.kaufCAN.com
LinkedIn
From: David A. Walton <dwalton@bellnunnally.com>
Sent: Monday, May 19, 2025 9:56 AM
To: Belote, Clark J. <clark.belote@kaufcan.com>; willwelter@aol.com
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>; Chap Petersen <jcp@petersenfirm.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds
Clark:
Please feel free to further discuss this issue with Will Welter, copied on this email. You are authorized to speak
with him directly, as needed.
Put simply, yes, Atlantic Wave’s position is it has a security interest in debts or claims against Cyberlux over and above the $1.44mm on the face of the garnishment summons. The settlement agreement between Cyberlux and Atlantic Wave provides for more than just the actual amount owed under the Amended Final Order and Judgment, for example, it provides Atlantic Wave the right to repayment of attorneys’ fees and costs in any action caused by a breach of the settlement agreement, and damages associated with the failure to bring Cyberlux’s stock to Pink Current status and to remedy the caveat emptor classification on such stock. Moreover, the settlement agreement explicitly provides: “Defendants [Cyberlux & Schmidt] agree and grant to Plaintiff [Atlantic Wave & Secure Community] a full security interest and lien interest in all of Defendants’ assets, including but not limited to IP, subsidiaries, contractual rights, accounts receivables, drone sales, etc., which may, in Plaintiff’s sole discretion, be memorialized through the filing of UCC-1 forms and Liens.”
Atlantic Wave contends that Cyberlux has defaulted on the settlement agreement in several respects as set forth in prior communications and filings, which permits Atlantic Wave to enforce the security interest (authorized by the settlement agreement) against Cyberlux on the collateral or assets described in the UCC-1 forms. Attached are those UCC-1 forms that were filed in Virginia, Texas, and North Carolina.
Please feel free to call me at your convenience to discuss.
Take care,
David
David A. Walton | Partner
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 3 of 9 PageID# 542
entityobservation
Chap Petersen
Read the anchor · page 4
3
dwalton@bellnunnally.com
T: 214.740.1445 | F: 214.740.5745
2323 Ross Avenue, Suite 1900 | Dallas, Texas 75201
LinkedIn | Facebook | Twitter | View Bio
www.bellnunnally.com
IMPORTANT \ CONFIDENTIAL: This message contains information from the law firm of Bell Nunnally & Martin LLP that may be subject to the attorney-client
privilege or work product doctrine, or may be otherwise confidential and exempt from disclosure under applicable law. Unless expressly stated otherwise,
nothing contained in this message should be construed as a digital or electronic signature, nor is this message intended to reflect an intention to make an
agreement by electronic means. DO NOT COPY OR FORWARD TO UNAUTHORIZED PERSONS. If you are not the intended recipient or the employee or agent
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, copying or forwarding of this
communication is strictly prohibited. Unauthorized interception of this message may be in violation of the Electronic Communications Privacy Act, 18 U.S.C. §
2510, et seq. If you have received this communication in error, please notify us immediately at our telephone number: (214) 740-1400.
From: Belote, Clark J. <clark.belote@kaufcan.com>
Sent: Thursday, May 15, 2025 1:52 PM
To: Chap Petersen <jcp@petersenfirm.com>; David A. Walton <dwalton@bellnunnally.com>
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds [IMAN-IMANACTIVE.FID760274]
This Message has originated outside your organization.
Chap, not exactly.
In addition to the judgment lien, my understanding is that AW contends that it has a separate security interest
in Cyberlux’s accounts, which AW contends it perfected with the UCC-1 filing in the attached. The June 28,
2023 Amended Final Order Judgment says: “That the parties have agreed to a security interest and lien
interest in all property of Defendants in favor of Plaintiffs until all sums are paid, and such security interest may
be further memorialized through the filing of appropriate UCC-1 forms and the filing of appropriate Liens.”
I wanted to understand whether Atlantic Wave contends that its debt or claims against Cyberlux are secured in
an amount over and above the $1.44mm on the face of the garnishment summons. The answer may be no.
But, it would be helpful for HII to understand Atlantic Wave’s position.
Thanks
Clark J. Belote
Kaufman & Canoles, P.C.
clark.belote@kaufcan.com
T. (757) 624.3109
F. (888) 360.9092
150 W. Main Street, Suite 2100
Norfolk, VA 23510
www.kaufCAN.com
LinkedIn
From: Chap Petersen <jcp@petersenfirm.com>
Sent: Thursday, May 15, 2025 2:32 PM
To: Belote, Clark J. <clark.belote@kaufcan.com>; David A. Walton <dwalton@bellnunnally.com>
Cc: David M. Keithly <dkeithly@tocounsel.com>; Evan Sherwood <ESherwood@cov.com>; Freling, Scott
<sfreling@cov.com>
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds [IMAN-IMANACTIVE.FID760274]
Clark:
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 4 of 9 PageID# 543
entityobservation
CYBERLUX CORPORATION
Read the anchor · page 8
[Overprinted exhibit filing headers; black redactions in upper-left header area.]
File Number: 20240038686M
Date Filed: 4/1/2024 7:44:00 PM
Elaine F. Marshall
NC Secretary of State
UCC FINANCING STATEMENT
FOLLOW INSTRUCTIONS
A. NAME & PHONE OF CONTACT AT FILER (optional)
Corporation Service Company
B. E-MAIL CONTACT AT FILER (optional)
SPRFiling@cscglobal.com
C. SEND ACKNOWLEDGMENT TO: (Name and Address)
Corporation Service Company
801 Adlai Stevenson Drive
Springfield, IL 62703
THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY
1. DEBTOR'S NAME: Provide only one Debtor name (1a or 1b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 1b, leave all of item 1 blank, check here
and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
1a. ORGANIZATION'S NAME
OR
CYBERLUX CORPORATION
1b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
SUFFIX
1c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
800 Park Offices Dr., Ste. 3209
Research Triangle
NC
27709
USA
2. DEBTOR'S NAME: Provide only one Debtor name (2a or 2b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 2b, leave all of item 2 blank, check here
and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
2a. ORGANIZATION'S NAME
OR 2b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
SUFFIX
2c. MAILING ADDRESS
CITY
STATE POSTAL CODE
COUNTRY
3. SECURED PARTY'S NAME (or NAME of ASSIGNEE of ASSIGNOR SECURED PARTY): Provide only one Secured Party name (3a or 3b)
3а. ORGANIZATION'S NAME
Legalist SPV III, LP
OR 3b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
I SUFFIX
3c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
58 West Portal Ave. #747
San Francisco
CA
94127
USA
4. COLLATERAL: This financing statement covers the following collateral:
All assets
5. Check only if applicable and check only one box: Collateral is
held in a Trust (see UCC1Ad, item 17 and Instructions)
being administered by a Decedent's Personal Representative
ba. Check only if applicable and check only one box:
6b. Check only if applicable and check only one box:
Public-Finance Transaction
Manufactured-Home Transaction
A Debtor is a Transmitting Utility
Agricultural Lien
Non-UCC Filing
7. ALTERNATIVE DESIGNATION (if applicable):
Lessee/Lessor
Consignee/Consignor
Seller/Buyer
Bailee/Bailor
Licensee/Licensor
8. OPTIONAL FILER REFERENCE DATA:
2797 73186
FILING OFFICE COPY - UCC FINANCING STATEMENT (Form UCC1) (Rev. 04/20/11)
International Association of Commercial Administrators (IACA)
entityobservation
Legalist SPV III, LP
Read the anchor · page 8
[Overprinted exhibit filing headers; black redactions in upper-left header area.]
File Number: 20240038686M
Date Filed: 4/1/2024 7:44:00 PM
Elaine F. Marshall
NC Secretary of State
UCC FINANCING STATEMENT
FOLLOW INSTRUCTIONS
A. NAME & PHONE OF CONTACT AT FILER (optional)
Corporation Service Company
B. E-MAIL CONTACT AT FILER (optional)
SPRFiling@cscglobal.com
C. SEND ACKNOWLEDGMENT TO: (Name and Address)
Corporation Service Company
801 Adlai Stevenson Drive
Springfield, IL 62703
THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY
1. DEBTOR'S NAME: Provide only one Debtor name (1a or 1b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 1b, leave all of item 1 blank, check here
and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
1a. ORGANIZATION'S NAME
OR
CYBERLUX CORPORATION
1b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
SUFFIX
1c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
800 Park Offices Dr., Ste. 3209
Research Triangle
NC
27709
USA
2. DEBTOR'S NAME: Provide only one Debtor name (2a or 2b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 2b, leave all of item 2 blank, check here
and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
2a. ORGANIZATION'S NAME
OR 2b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
SUFFIX
2c. MAILING ADDRESS
CITY
STATE POSTAL CODE
COUNTRY
3. SECURED PARTY'S NAME (or NAME of ASSIGNEE of ASSIGNOR SECURED PARTY): Provide only one Secured Party name (3a or 3b)
3а. ORGANIZATION'S NAME
Legalist SPV III, LP
OR 3b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
I SUFFIX
3c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
58 West Portal Ave. #747
San Francisco
CA
94127
USA
4. COLLATERAL: This financing statement covers the following collateral:
All assets
5. Check only if applicable and check only one box: Collateral is
held in a Trust (see UCC1Ad, item 17 and Instructions)
being administered by a Decedent's Personal Representative
ba. Check only if applicable and check only one box:
6b. Check only if applicable and check only one box:
Public-Finance Transaction
Manufactured-Home Transaction
A Debtor is a Transmitting Utility
Agricultural Lien
Non-UCC Filing
7. ALTERNATIVE DESIGNATION (if applicable):
Lessee/Lessor
Consignee/Consignor
Seller/Buyer
Bailee/Bailor
Licensee/Licensor
8. OPTIONAL FILER REFERENCE DATA:
2797 73186
FILING OFFICE COPY - UCC FINANCING STATEMENT (Form UCC1) (Rev. 04/20/11)
International Association of Commercial Administrators (IACA)
entityobservation
SCHMIDT
Read the anchor · page 9
[Overprinted exhibit filing headers; black redactions in upper-left header area.]
File Number: 20240084460A
Date Filed: 7/15/2024 8:27:00 AM
Elaine F. Marshall
NC Secretary of State
UCC FINANCING STATEMENT
FOLLOW INSTRUCTIONS
A. NAME & PHONE OF CONTACT AT FILER (optional)
Corporation Service Company
B. E-MAIL CONTACT AT FILER (optional)
SPRFiling@cscglobal.com
C. SEND ACKNOWLEDGMENT TO: (Name and Address)
Corporation Service Company
801 Adlai Stevenson Drive
Springfield, IL 62703
THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY
1. DEBTOR'S NAME: Provide only one Debtor name (1a or 1b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 1b, leave all of item 1 blank, check here
and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
1a. ORGANIZATION'S NAME
OR 1b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
SUFFIX
SCHMIDT
MARK
D.
1c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
1134 Fearrington Post
Pittsboro
NC
27312
USA
2. DEBTOR'S NAME: Provide only one Debtor name (2a or 2b) (use exact, full name; do not omit, modify, or abbreviate any part of the Debtor's name); if any part of the Individual Debtor's
name will not fit in line 2b, leave all of item 2 blank, check here and provide the Individual Debtor information in item 10 of the Financing Statement Addendum (Form UCC1Ad)
2a. ORGANIZATION'S NAME
OR 2b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME (S)/INITIAL(S)
SUFFIX
2c. MAILING ADDRESS
CITY
STATE POSTAL CODE
COUNTRY
3. SECURED PARTY'S NAME (or NAME of ASSIGNEE of ASSIGNOR SECURED PARTY): Provide only one Secured Party name (3a or 3b)
3а. ORGANIZATION'S NAME
Legalist SPV III, LP
OR 3b. INDIVIDUAL'S SURNAME
FIRST PERSONAL NAME
ADDITIONAL NAME(S)/INITIAL(S)
I SUFFIX
3c. MAILING ADDRESS
CITY
STATE
POSTAL CODE
COUNTRY
58 West Portal Ave. #747
San Francisco
CA
94127
USA
4. COLLATERAL: This financing statement covers the following collateral:
All assets
5. Check only if applicable and check only one box: Collateral is
held in a Trust (see UCC1Ad, item 17 and Instructions)
being administered by a Decedent's Personal Representative
ba. Check only if applicable and check only one box:
6b. Check only if applicable and check only one box:
Public-Finance Transaction
Manufactured-Home Transaction
A Debtor is a Transmitting Utility
Agricultural Lien
Non-UCC Filing
7. ALTERNATIVE DESIGNATION (if applicable):
Lessee/Lessor
Consignee/Consignor
Seller/Buyer
Bailee/Bailor
Licensee/Licensor
8. OPTIONAL FILER REFERENCE DATA:
2879 27331
FILING OFFICE COPY - UCC FINANCING STATEMENT (Form UCC1) (Rev. 04/20/11)
International Association of Commercial Administrators (IACA)
entityobservation
Atlantic Wave Holdings, LLC
Read the anchor · page 6
5
www.kaufCAN.com
LinkedIn
From: David A. Walton <dwalton@bellnunnally.com>
Sent: Tuesday, May 6, 2025 7:51 PM
To: Belote, Clark J. <clark.belote@kaufcan.com>
Cc: David M. Keithly <dkeithly@tocounsel.com>; willwelter@aol.com
Subject: RE: Atlantic Wave_Letter to HII re Claim to Funds
Importance: High
Clark:
Attached is a supplemental letter on behalf of Atlantic Wave Holdings, LLC, concerning its claim to funds held on behalf of or for the benefit of Cyberlux Corporation. Please do not hesitate to contact me with any questions.
Take care,
David
David A. Walton | Partner
dwalton@bellnunnally.com
T: 214.740.1445 | F: 214.740.5745
2323 Ross Avenue, Suite 1900 | Dallas, Texas 75201
LinkedIn | Facebook | Twitter | View Bio
www.bellnunnally.com
IMPORTANT \ CONFIDENTIAL: This message contains information from the law firm of Bell Nunnally & Martin LLP that may be subject to the attorney-client
privilege or work product doctrine, or may be otherwise confidential and exempt from disclosure under applicable law. Unless expressly stated otherwise,
nothing contained in this message should be construed as a digital or electronic signature, nor is this message intended to reflect an intention to make an
agreement by electronic means. DO NOT COPY OR FORWARD TO UNAUTHORIZED PERSONS. If you are not the intended recipient or the employee or agent
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, copying or forwarding of this
communication is strictly prohibited. Unauthorized interception of this message may be in violation of the Electronic Communications Privacy Act, 18 U.S.C. §
2510, et seq. If you have received this communication in error, please notify us immediately at our telephone number: (214) 740-1400.
From: David A. Walton
Sent: Thursday, April 24, 2025 4:03 PM
To: clark.belote@kaufcan.com
Cc: David M. Keithly <dkeithly@tocounsel.com>; willwelter@aol.com
Subject: Atlantic Wave_Letter to HII re Claim to Funds
Clark:
Attached is a letter on behalf of Atlantic Wave Holdings, LLC, concerning its claim to funds held on behalf of or for the benefit of Cyberlux Corporation. Please do not hesitate to contact me with any questions.
Take care,
David
David A. Walton | Partner
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 6 of 9 PageID# 545
inferenceinference
The exchange provides evidence of HII counsel actively testing both the scope and rank of Atlantic Wave’s claim. Walton’s affirmative answer
The exchange provides evidence of HII counsel actively testing both the scope and rank of Atlantic Wave’s claim. Walton’s affirmative answers establish the asserted position but do not resolve the legal consequences of the filings.
omissiongap
The initial and supplemental letters and Atlantic Wave UCC forms referenced in the chain are absent; only two Legalist financing notices acc
The initial and supplemental letters and Atlantic Wave UCC forms referenced in the chain are absent; only two Legalist financing notices accompany it.
Read the anchor · page 1
EXHIBIT 7
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 1 of 9 PageID# 540
otherattribution
Complete supplied 9-page source reviewed at SHA-256 546520c532d2860d3662110493b7fe797831dd4aaee8f36ffcf07c0bcf9fb0d6. Source assertions, ori
Complete supplied 9-page source reviewed at SHA-256 546520c532d2860d3662110493b7fe797831dd4aaee8f36ffcf07c0bcf9fb0d6. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Exact version_95798745bda645fdba3f5a1008b64ae5; SHA256 546520c532d2860d3662110493b7fe797831dd4aaee8f36ffcf07c0bcf9fb0d6. All nine pages read; material email dropouts and UCC stamps visually checked. Source bytes and original extraction unchanged.
Read the anchor · page 1
EXHIBIT 7
Case 3:25-cv-00483-JAG Document 41-7 Filed 08/04/25 Page 1 of 9 PageID# 540
questionquestion
What operative security agreements, Atlantic Wave filings and governing-law analysis establish which claims attach to these receivables and
What operative security agreements, Atlantic Wave filings and governing-law analysis establish which claims attach to these receivables and their priority?
distillateattribution
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Attached Exhibit A identifies CYBERLUX CORPORATION as debtor and Legalist SPV III, LP as secured party, collateral All assets. The visually checked North Carolina stamp is file 20240038686M, April 1, 2024 at 7:44 PM. Corporation Service Company is the filer, not the lender.supportsThe North Carolina statement bears file number20240038686M, filed April1,2024 at7:44PM, names the same corporate debtor and Legalist SPV III, LP, and describes All assets. Corporation Service Company is filer/acknowledgement recipient, not the secured creditor. The original extraction misread the file number; the visible stamp controls the readable correction.
Same North Carolina file 20240038686M and date; duplicate instrument representation, not independent security proof.
Issuer asserts full compliance with AWH settlement, contests new claims and predicts success on counterclaims/injunction; reports RB agreement in principle awaiting binding completion and Aerotek$204,705.45 demand with no answer yet filed. These conflict in posture with creditor accusations and do not establish favourable rulings. Repeated litigation notes are the same issuer account.qualifiesWalton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-related fees, stock-status damages and all assets. He alleges defaults permitting enforcement and says Virginia, Texas and North Carolina UCC forms are attached. Those Atlantic Wave forms are not included here; the exhibit ends with two Legalist forms. He authorises direct discussion with Will Welter.
Issuer claims compliance while creditor counsel asserts defaults and expanded security; both positions retained pending instruments/performance records.
Paragraph 7 grants plaintiffs a full security and lien interest in all defendants’ assets, including IP, subsidiaries, contractual rights, receivables and drone sales, with optional UCC memorialisation. Paragraph 8 requires requested negotiation/payment updates and documents only to the extent not classified or restricted, with confidentiality cross-reference printed as paragraph 12 although confidentiality appears at 13. The visible highlight/underline cannot be attributed to a particular annotator.supportsWalton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-related fees, stock-status damages and all assets. He alleges defaults permitting enforcement and says Virginia, Texas and North Carolina UCC forms are attached. Those Atlantic Wave forms are not included here; the exhibit ends with two Legalist forms. He authorises direct discussion with Will Welter.
Actual paragraph7 supports counsel’s description of all-assets grant, without deciding perfected priority or claim coverage.
After Belote asks whether Atlantic Wave claims priority over Legalist, Walton answers yes at 2:41 PM on May 19. He asserts perfection by July 2023 in Virginia, Texas and North Carolina, contrasts Legalist’s April and July 2024 North Carolina stamps, and on information and belief says Legalist’s interest could not arise before April 2024 receivables sales. These are advocacy positions, not proof of attachment, governing jurisdiction or priority.qualifiesExhibit4 filed April15,2026 contains Nevada receipt and acknowledgement for UCC1 number2024395945-0, work orderW2024040101722, filed April1,2024 at11:49AM (receipt11:49:44). Receipt records approval and$30 filing plus$0.75 service fee. The filer Legalist Inc. is distinct from the named secured party Legalist SPV III, LP.
Walton describes North Carolina-only Legalist stamps; source67 also contains a Nevada April 1 filing. Preserve limited email attachment scope rather than global absence conclusion.
Belote asks what amount Atlantic Wave contends is secured, contrasting more than $7,774,000 claimed in the April 24 letter with a minimum $912,000 judgment balance. Petersen points to the garnishment summons. Belote distinguishes a separate claimed security interest from the judgment lien and asks whether it exceeds the summons’ approximately $1.44 million. His questions seek clarification; they do not concede priority or enforceability.supportsCounsel adds fees exceeding $592,000 and stock damages exceeding $6,017,250, calculated from 195 million shares at $0.0308577, and asserts a composite claim exceeding $7,774,000. The stock calculation yields $6,017,251.50, consistent with the stated lower bound. This combines judgment and contested claims rather than a single adjudicated balance.
Belote expressly refers to April 24 amounts; supports responsive discussion of letter content, not agreement with those amounts.
Belote asks what amount Atlantic Wave contends is secured, contrasting more than $7,774,000 claimed in the April 24 letter with a minimum $912,000 judgment balance. Petersen points to the garnishment summons. Belote distinguishes a separate claimed security interest from the judgment lien and asks whether it exceeds the summons’ approximately $1.44 million. His questions seek clarification; they do not concede priority or enforceability.supportsDid HII counsel accept Atlantic Wave’s asserted priority?
Specifically named source propositions support the bounded distinction or question.
Walton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-related fees, stock-status damages and all assets. He alleges defaults permitting enforcement and says Virginia, Texas and North Carolina UCC forms are attached. Those Atlantic Wave forms are not included here; the exhibit ends with two Legalist forms. He authorises direct discussion with Will Welter.supportsThe initial and supplemental letters and Atlantic Wave UCC forms referenced in the chain are absent; only two Legalist financing notices accompany it.
Specifically named source propositions support the bounded distinction or question.
Walton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-related fees, stock-status damages and all assets. He alleges defaults permitting enforcement and says Virginia, Texas and North Carolina UCC forms are attached. Those Atlantic Wave forms are not included here; the exhibit ends with two Legalist forms. He authorises direct discussion with Will Welter.supportsWhat operative security agreements, Atlantic Wave filings and governing-law analysis establish which claims attach to these receivables and their priority?
Specifically named source propositions support the bounded distinction or question.
Attached Exhibit B names debtor SCHMIDT, MARK, D. and Legalist SPV III, LP, collateral All assets. Its visually checked North Carolina stamp is 20240084460A, July 15, 2024 at 8:27 AM. Both forms have upper-left black redactions and overlapping exhibit headers, and neither supplies the underlying security agreement or debt balance.supportsWhat operative security agreements, Atlantic Wave filings and governing-law analysis establish which claims attach to these receivables and their priority?
Specifically named source propositions support the bounded distinction or question.
Walton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-related fees, stock-status damages and all assets. He alleges defaults permitting enforcement and says Virginia, Texas and North Carolina UCC forms are attached. Those Atlantic Wave forms are not included here; the exhibit ends with two Legalist forms. He authorises direct discussion with Will Welter.supportsDid HII counsel accept Atlantic Wave’s asserted priority?
Specifically named source propositions support the bounded distinction or question.
The August 4, 2025 federal Exhibit 7 contains an April 24–May 19 email chain. Walton’s April 24 and May 6 messages identify an initial and supplemental Atlantic Wave letter concerning funds held for Cyberlux. The referenced letters are not reproduced in this nine-page exhibit.supportsThe initial and supplemental letters and Atlantic Wave UCC forms referenced in the chain are absent; only two Legalist financing notices accompany it.
Specifically named source propositions support the bounded distinction or question.
Attached Exhibit A identifies CYBERLUX CORPORATION as debtor and Legalist SPV III, LP as secured party, collateral All assets. The visually checked North Carolina stamp is file 20240038686M, April 1, 2024 at 7:44 PM. Corporation Service Company is the filer, not the lender.supportsThe initial and supplemental letters and Atlantic Wave UCC forms referenced in the chain are absent; only two Legalist financing notices accompany it.
Specifically named source propositions support the bounded distinction or question.
Belote asks what amount Atlantic Wave contends is secured, contrasting more than $7,774,000 claimed in the April 24 letter with a minimum $912,000 judgment balance. Petersen points to the garnishment summons. Belote distinguishes a separate claimed security interest from the judgment lien and asks whether it exceeds the summons’ approximately $1.44 million. His questions seek clarification; they do not concede priority or enforceability.supportsThe exchange provides evidence of HII counsel actively testing both the scope and rank of Atlantic Wave’s claim. Walton’s affirmative answers establish the asserted position but do not resolve the legal consequences of the filings.
Specifically named source propositions support the bounded distinction or question.
After Belote asks whether Atlantic Wave claims priority over Legalist, Walton answers yes at 2:41 PM on May 19. He asserts perfection by July 2023 in Virginia, Texas and North Carolina, contrasts Legalist’s April and July 2024 North Carolina stamps, and on information and belief says Legalist’s interest could not arise before April 2024 receivables sales. These are advocacy positions, not proof of attachment, governing jurisdiction or priority.supportsWhat operative security agreements, Atlantic Wave filings and governing-law analysis establish which claims attach to these receivables and their priority?
Specifically named source propositions support the bounded distinction or question.
Walton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-related fees, stock-status damages and all assets. He alleges defaults permitting enforcement and says Virginia, Texas and North Carolina UCC forms are attached. Those Atlantic Wave forms are not included here; the exhibit ends with two Legalist forms. He authorises direct discussion with Will Welter.supportsThe exchange provides evidence of HII counsel actively testing both the scope and rank of Atlantic Wave’s claim. Walton’s affirmative answers establish the asserted position but do not resolve the legal consequences of the filings.
Specifically named source propositions support the bounded distinction or question.
Attached Exhibit B names debtor SCHMIDT, MARK, D. and Legalist SPV III, LP, collateral All assets. Its visually checked North Carolina stamp is 20240084460A, July 15, 2024 at 8:27 AM. Both forms have upper-left black redactions and overlapping exhibit headers, and neither supplies the underlying security agreement or debt balance.supportsThe initial and supplemental letters and Atlantic Wave UCC forms referenced in the chain are absent; only two Legalist financing notices accompany it.
Specifically named source propositions support the bounded distinction or question.
After Belote asks whether Atlantic Wave claims priority over Legalist, Walton answers yes at 2:41 PM on May 19. He asserts perfection by July 2023 in Virginia, Texas and North Carolina, contrasts Legalist’s April and July 2024 North Carolina stamps, and on information and belief says Legalist’s interest could not arise before April 2024 receivables sales. These are advocacy positions, not proof of attachment, governing jurisdiction or priority.supportsThe exchange provides evidence of HII counsel actively testing both the scope and rank of Atlantic Wave’s claim. Walton’s affirmative answers establish the asserted position but do not resolve the legal consequences of the filings.
Specifically named source propositions support the bounded distinction or question.
After Belote asks whether Atlantic Wave claims priority over Legalist, Walton answers yes at 2:41 PM on May 19. He asserts perfection by July 2023 in Virginia, Texas and North Carolina, contrasts Legalist’s April and July 2024 North Carolina stamps, and on information and belief says Legalist’s interest could not arise before April 2024 receivables sales. These are advocacy positions, not proof of attachment, governing jurisdiction or priority.supportsDid HII counsel accept Atlantic Wave’s asserted priority?
Specifically named source propositions support the bounded distinction or question.
Attached Exhibit A identifies CYBERLUX CORPORATION as debtor and Legalist SPV III, LP as secured party, collateral All assets. The visually checked North Carolina stamp is file 20240038686M, April 1, 2024 at 7:44 PM. Corporation Service Company is the filer, not the lender.supportsWhat operative security agreements, Atlantic Wave filings and governing-law analysis establish which claims attach to these receivables and their priority?
Specifically named source propositions support the bounded distinction or question.
WEIGH
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