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IP HII EDVA 00483 Doc. 0183 Main

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ECF183filed15April2026;taxas-of13April2026;fund$23,736,937.56;alternative prioritytable physicalpage9.

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. ) ) Interpleader Plaintiff, ) ) v. ) ) CYBERLUX CORPORATION, et al., ) ) Defendants. ) _______________________________________) Case No. 3:25-cv-00483-JAG UNITED STATES’ MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT The United States of America submits this memorandum of law in support of its motion for summary judgment. I. INTRODUCTION There is no dispute that the United States’ tax liens have priority to all other creditors in this lawsuit, except one, Legalist SPV III, L.P., as to which the United States has partial priority. Because the claims of the United States’ (just over $1.1 million) and Legalist (just over $13 million) can be fully paid from the interpleaded funds (over $23 million), and because there is no genuine dispute of material fact that the United States has priority as to all other creditors, the United States is entitled to judgment as a matter of law. II. UNDISPUTED MATERIAL FACTS 1. Plaintiff HII Mission Technologies Corp.’s (“HII”) predecessor entered into a subcontract with Cyberlux, which is incorporated in Nevada and has its principal place of business in North Carolina. ECF 41, ¶¶ 4, 17, 18 . Under the subcontract, Cyberlux would Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 1 of 13 PageID# 3887
claimallegation

The United States moves for summary judgment on tax-lien priority in the HII interpleader. It says HII’s Navy/GSA-related subcontract ended1

The United States moves for summary judgment on tax-lien priority in the HII interpleader. It says HII’s Navy/GSA-related subcontract ended17May2024,the court directed deposit$23,736,937.56 on20February2026,and HII deposited on6March and was dismissed. The motion citesECF41,150,153 and docket entries;it is not itself those orders or a disbursement record.

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. ) ) Interpleader Plaintiff, ) ) v. ) ) CYBERLUX CORPORATION, et al., ) ) Defendants. ) _______________________________________) Case No. 3:25-cv-00483-JAG UNITED STATES’ MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT The United States of America submits this memorandum of law in support of its motion for summary judgment. I. INTRODUCTION There is no dispute that the United States’ tax liens have priority to all other creditors in this lawsuit, except one, Legalist SPV III, L.P., as to which the United States has partial priority. Because the claims of the United States’ (just over $1.1 million) and Legalist (just over $13 million) can be fully paid from the interpleaded funds (over $23 million), and because there is no genuine dispute of material fact that the United States has priority as to all other creditors, the United States is entitled to judgment as a matter of law. II. UNDISPUTED MATERIAL FACTS 1. Plaintiff HII Mission Technologies Corp.’s (“HII”) predecessor entered into a subcontract with Cyberlux, which is incorporated in Nevada and has its principal place of business in North Carolina. ECF 41, ¶¶ 4, 17, 18 . Under the subcontract, Cyberlux would Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 1 of 13 PageID# 3887
claimallegation

Citing IRS officer Carol Davis,the United States claims$1,153,457 as of13April2026 plus later interest for unpaid assessments after notice/d

Citing IRS officer Carol Davis,the United States claims$1,153,457 as of13April2026 plus later interest for unpaid assessments after notice/demand. Table balances are941periodsJune2010$87,454,December2010$149,003,December2012$872,811,December2021$2,625;940December2022$321,December2023$361;and6721December2013penalty$40,882. NFTLdates are21August2017,10October2023 and30April2024,as allocated in the table.

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2 support HII’s work under a prime contract with the Department of the Navy and General Services Administration. ECF 41, ¶ 18. 2. On May 17, 2024, HII terminated the subcontract with Cyberlux and, pursuant to the subcontract, became obligated to pay Cyberlux “a percentage of the Subcontract price corresponding with the percentage of the terminated work actually performed prior to the notice of termination,” plus certain expenses. Id., ¶¶ 21-22. 3. HII commenced this action in interpleader, naming defendant Cyberlux Corporation and Cyberlux’s creditors. Id., ¶ 1. HII sought to deposit certain sums owed to Cyberlux and to which various Cyberlux creditors had made claims. Id., ¶ 2. 4. On February 20, 2026, this Court granted HII’s Motion for Interpleader Deposit and directed HII to deposit $23,736,937.56 (the “Disputed Funds”) into the Court’s Registry Investment System. ECF 150. 5. On March 6, 2026, HII interpleaded the Disputed Funds as directed and was dismissed from this lawsuit. March 6, 2026, Docket Entry reflecting deposit; see also ECF 153 (order acknowledging the deposit and dismissing HII). a. Facts relevant to the United States’ claim. 6. Cyberlux did not pay its taxes and, as a result, the United States has liens on Cyberlux’s property, including the Disputed Funds, in the amount of $1,153,457, plus accruing interest. See generally Declaration of IRS Revenue Officer Carol Davis (Ex. 1). 7. Specifically, a delegate of the Secretary of the Treasury assessed the following unpaid tax liabilities (IRS Forms 940 and 941) and penalties (26 USC § 6721) against Cyberlux Corporation: Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 2 of 13 PageID# 3888
claimallegation

The motion says Legalist and Cyberlux signed a27March2024government-purchase-order financing agreement for$3million secured by all borrower

The motion says Legalist and Cyberlux signed a27March2024government-purchase-order financing agreement for$3million secured by all borrower assets,including contract rights/receivables,and perfected by NevadaUCCfiling1April2024. It says later amendments13July2024 and29April2025postdate all tax notices. The agreement,UCC and amendments are referenced as exhibits,not included in this13-page main filing.

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4 in the fourth column of paragraph 7. True and correct copies of those NFTLs are attached to Revenue Officer Davis’s Declaration as Attachment B thereto. 11. By virtue of the unpaid assessments described in paragraph 7, above, as of April 13, 2026, Cyberlux Corporation is indebted to the United States in the amount of $1,153,457, plus interest that will continue to accrue according to statute. Id., ¶ 9. b. Facts relevant to Legalist’s claim 12. On March 27, 2024, Legalist and Cyberlux entered into a Government Purchase Order Financing Agreement. Legalist Ans. to Interrogatory B (Ex. 2); Gov. Purchase Ord. Financing Agr., Ex. 3 at LEGALIST000021. 4 13. In that agreement, Legalist agreed to provide Cyberlux a $3,000,000 line of credit. Ex. 3 at LEGALIST000021. In exchange, Cyberlux conveyed to Legalist a “continuing lien on and security interest in all assets of Borrower, including” contract rights and accounts receivable. Id. at LEGALIST000022. 14. On April 1, 2024, Legalist perfected this security interest by filing a UCC Filing Statement in Nevada, where Cyberlux is incorporated. Ex. 3, at LEGALIST000017. Legalist did not provide the $3,000,000 at the time it signed the contract. Rather, Legalist disbursed the following amounts on the following dates: 4 Legalist and Cyberlux amended the Government Purchase Order Financing Agreement on July 13, 2024, see Ex. 3 at LEGALIST000039, and on April 29, 2025. See Ex. 3 at LEGALIST000007. Because both amendments occurred after all NFTLs, they are not relevant to any priority dispute between Legalist and the United States. Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 4 of 13 PageID# 3890
claimallegation

Legalist disbursements are recited as9April2024$1.8million,19April$500k,2May$500k,26June$142k,5July$53k,16July$2.5million,2August$650k,27Aug

Legalist disbursements are recited as9April2024$1.8million,19April$500k,2May$500k,26June$142k,5July$53k,16July$2.5million,2August$650k,27August$535k,3October$150k and$120k,3June2025$2,755,100.10 and9June2025printed$345,000.001. The motion attributes a total claim$13,204,742.88 as of9March2026 plus interest to Legalist’s interrogatory answer.

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5  4/9/2024: $1,800,000.00  4/19/2024: $500,000.00  4/30/2024: This is the date the final IRS NFTL was filed.  5/2/2024: $500,000.00  6/15/2024: This date is 46 days after the filing of all NFTLs. As explained below, advances after this date are subordinate to the IRS tax liens.  6/26/2024: $142,000.00  7/5/2024: $53,000.00  7/16/2024: $2,500,000.00  8/2/2024: $650,000.00  8/27/2024: $535,000.00  10/3/2024: $150,000.00  10/3/2024: $120,000.00  6/3/2025: $2,755,100.10  6/9/2025: $345,000.001 Legalist Ans. to Interrogatory G (Ex. 2). Legalist asserts that, as of March 9, 2026, Cyberlux owes it $13,204,742.88, plus interest accruing from that date. Id. at A. c. Facts relevant to other Cyberlux creditor claims. 15. Aside from Legalist, no other creditor claims a secured interest or lien that rivals the United States’ liens. 16. The Receiver claims a judicial lien as a result of an April 1, 2025, order appointing a receiver. Ex. 4 at p. EX4000002, ¶ d & EX4000006, ¶ 10. 17. Thin Air Gear, LLC asserts a perfected lien as of August 29, 2025 or, “at worst,” December 19, 2025. Ex. 4 at p. EX4000024. 18. Advanced Navigation & Positioning Corporation claims a security interest through its filing of a Writ of Fieri Facias on September 24, 2025 and an equitable lien arising on December 30, 2024. Ex. 4 at p. EX4000026-27. 19. Assure Global LLC d/b/a WeShield, Roman Investments PR LLC, MAS USA MGT LLC, and Michael Sinensky claim a perfected security interest as of October 23, 2025. Ex. 4 at p. EX4000030. Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 5 of 13 PageID# 3891
claimallegation

The government characterises other claimants’liens as later than its notices:receiver1April2025,ThinAirAugust/December2025,ANPCSeptember2025

The government characterises other claimants’liens as later than its notices:receiver1April2025,ThinAirAugust/December2025,ANPCSeptember2025writ/December2024equitablelien,WeShieldgroupOctober2025,and AW/SecureNevadafiling20March2026. It says AW/Secure do not contest federal priority,Fairwinds claims no security interest,and ARG initially disclaimed perfected security. A footnote records ARG’s14April2026changed answer asserting2022/2023priority but says no earlierUCCwas produced. These are the movant’s account of responses,not independent determinations.

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5  4/9/2024: $1,800,000.00  4/19/2024: $500,000.00  4/30/2024: This is the date the final IRS NFTL was filed.  5/2/2024: $500,000.00  6/15/2024: This date is 46 days after the filing of all NFTLs. As explained below, advances after this date are subordinate to the IRS tax liens.  6/26/2024: $142,000.00  7/5/2024: $53,000.00  7/16/2024: $2,500,000.00  8/2/2024: $650,000.00  8/27/2024: $535,000.00  10/3/2024: $150,000.00  10/3/2024: $120,000.00  6/3/2025: $2,755,100.10  6/9/2025: $345,000.001 Legalist Ans. to Interrogatory G (Ex. 2). Legalist asserts that, as of March 9, 2026, Cyberlux owes it $13,204,742.88, plus interest accruing from that date. Id. at A. c. Facts relevant to other Cyberlux creditor claims. 15. Aside from Legalist, no other creditor claims a secured interest or lien that rivals the United States’ liens. 16. The Receiver claims a judicial lien as a result of an April 1, 2025, order appointing a receiver. Ex. 4 at p. EX4000002, ¶ d & EX4000006, ¶ 10. 17. Thin Air Gear, LLC asserts a perfected lien as of August 29, 2025 or, “at worst,” December 19, 2025. Ex. 4 at p. EX4000024. 18. Advanced Navigation & Positioning Corporation claims a security interest through its filing of a Writ of Fieri Facias on September 24, 2025 and an equitable lien arising on December 30, 2024. Ex. 4 at p. EX4000026-27. 19. Assure Global LLC d/b/a WeShield, Roman Investments PR LLC, MAS USA MGT LLC, and Michael Sinensky claim a perfected security interest as of October 23, 2025. Ex. 4 at p. EX4000030. Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 5 of 13 PageID# 3891
claimallegation

The government invokes Rule56,second-stage interpleader andIRC6321–6323. In response to the court’sECF158government-contracting inquiry,coun

The government invokes Rule56,second-stage interpleader andIRC6321–6323. In response to the court’sECF158government-contracting inquiry,counsel says tax-lien priority is governed by theIRC. It argues corporate personal-property NFTLs were correctly filed in NorthCarolina,the principal executive-office state. This limited priority position does not purport to audit or approve the underlying procurement.

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6 20. Atlantic Waive Holdings, LLC and Secure Community, LLC, which has advised undersigned counsel that it does not contest the United States’ priority, claims they perfected a security interest through the filing of UCC Financing Statements, but the statement filed in Nevada (the state of Cyberlux’s incorporation) was not filed until March 20, 2026. Ex. 4 at p. EX4000031. 21. Fairwinds Technologies, LLC does not claim a security interest. Ex. 4 at p. EX4000034, ¶ d. 22. The ARG Group, LLC “does not believe it has a perfected, secured security interest in all or any portion of the proceeds.” Ex. 4 at p. EX4000036, ¶ d.5 III. LEGAL STANDARDS Summary Judgment Standard “Under Rule 56(a), summary judgment is appropriate ‘if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.’ The relevant inquiry in a summary judgment analysis is ‘whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.’” Moore-King v. Cnty. of Chesterfield, Va., 819 F. Supp. 2d 604, 610 (E.D. Va. 2011), aff'd, 708 F.3d 560 (4th Cir. 2013) (quoting Fed.R.Civ.P. 56(a) and Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251–52 (1986)). 5 On April 14, 2026, over five weeks after the deadline to serve interrogatory answers (ECF 149), ARG served new, inconsistent answers to this interrogatory, claiming a secured interest in the Disputed Funds with a “priority date” of February 28, 2022 or, “at worst,” September 8, 2023. ARG does not allege it recorded any security interest, nor has it produced a UCC Filing Statement that predates the NFTLs. Absent such perfection, ARG’s interest, if any, is subordinate to the United States’. 26 U.S.C. § 6323. Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 6 of 13 PageID# 3892
claimallegation

The United States says precise relative priority with Legalist is immaterial because the fund can pay both claims. Alternatively,it proposes

The United States says precise relative priority with Legalist is immaterial because the fund can pay both claims. Alternatively,it proposes first its2017/2023liens,then$2.8millionLegalistadvances,and then itsApril2024liens,arguing security exists only to money advanced and applying a45-day post-notice protection window. It places advances after15June2024behind its final notice and requests full federal payment before remaining creditors. These are requested legal outcomes,not adjudicated priorities.

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9 Here, aside from Legalist, no claimant holds a security interest or lien in the Disputed Funds that was perfected prior to the NFTLs set forth in paragraph II.7, above. The Disputed Funds total $23,736,937.56. As of March 9, 2026, Legalist claims it is owed $13,204,742.88, plus interest. Legalist Ans. to Interrogatory G (Ex. 2). The United States is owed $1,153,457, as of April 13, 2026, plus interest. Davis Decl. (Ex. 1), ¶ 5. The priority dispute between Legalist and the United States is immaterial because there are sufficient interpleaded funds to pay both creditors in full. 2. Should the priority of the United States’ and Legalist’s claim be put at issue, the United States should be fully paid after Legalist is paid $2.8 million. Should the priorty of the United States’ and Legalist’s interests be put at issue, the United States asserts, for the reasons that follow, the following order of priority: Priority Creditor Claim Amount 1 USA $40,882 2 USA $2,937.49 3 Legalist $2,800,000 4 USA $1,106,083.54 Section 6323 of the Internal Revenue Code governs the relative priority of the United States and Legalist’s claims. Under 26 U.S.C. § 6323(a), a federal tax lien “shall not be valid as against any purchaser, holder of a security interest, mechanic's lienor, or judgment lien creditor until notice thereof which meets the requirements of subsection (f) has been filed by the Secretary.” (emphasis added). The term “security interest” means, in pertinent part, “any interest in property acquired by contract for the purpose of securing payment or performance of an obligation or indemnifying against loss or liability. A security interest exists at any time … [only] to the extent that, at such time, the holder has parted with money or money's worth.” 26 Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 9 of 13 PageID# 3895
claimallegation

The alternative table onpage9 lists USA$40,882,$2,937.49 and$1,106,083.54,which sum$1,149,903.03 rather than the requested$1,153,457. Page3’

The alternative table onpage9 lists USA$40,882,$2,937.49 and$1,106,083.54,which sum$1,149,903.03 rather than the requested$1,153,457. Page3’sOctober2023-notice balances total$2,946 rather than$2,937.49;page11describes final-notice liabilities$1,109,629 rather than table$1,106,083.54. These internal amount differences are retained for reconciliation,not silently repaired.

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3 Assessment Type Tax Period Ending Assessment Date NFTL Filing Date Balance1 (as of April 13, 2026) IRS Form 9412 6/30/2010 5/13/2013 4/30/2024 $87,454 IRS Form 941 12/31/2010 4/11/2011 4/30/2024 $149,003 IRS Form 941 12/31/2012 4/01/2013 4/30/2024 $872,811 IRS Form 941 12/31/2021 9/5/2022 10/10/2023 $2,625 IRS Form 940 12/31/2022 2/27/2023 10/10/2023 $321 IRS Form 940 12/31/2023 2/26/2024 4/30/2024 $361 26 USC § 67213 12/31/2013 10/24/2016 8/21/2017 $40,882 TOTAL BALANCE $1,153,457.00 Id., ¶ 5. 8. True and correct copies of account transcripts memorializing these liabilities are attached to Revenue Officer Davis’s Declaration as Attachment A thereto. 9. A delegate of the Secretary of the Treasury gave notice of these assessments to Cyberlux Corporation and made demand upon it for payment of those assessments. Despite notice and demand for payment, Cyberlux Corporation has failed or refused to pay the full amounts due and owing for these assessments. As a result, under 26 U.S.C. § 6321, the unpaid assessment amounts are a lien in favor of the United States upon all property and rights to property belonging to Cyberlux Corporation, including upon the interpleaded proceeds. Id., ¶ 7. 10. The IRS filed Notices of Federal Tax Lien (“NFTLs”) memorializing the liens with the North Carolina Secretary of State. Id., ¶ 8. The NFTLs were filed on the dates set forth 1 This includes assessment amount plus accruals (interest and penalties) accruing through April 13, 2026. 2 IRS Forms 941 are used to report withheld employee income tax and withheld employee and employer Social Security and Medicare tax. IRS Forms 940 are used to report an employer’s Federal Unemployment Tax Act taxes. 3 These are penalties for failure to file returns. Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 3 of 13 PageID# 3889
claimallegation

The15April2026conclusion requests$1,153,457 plus interest through disbursement. William J.Harrington and Jonathan H.Hambrick sign for the Un

The15April2026conclusion requests$1,153,457 plus interest through disbursement. William J.Harrington and Jonathan H.Hambrick sign for the United States;Harrington certifiesCM/ECFfiling/notification that date. No order granting summary judgment or payment appears in this main memorandum.

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12 V. CONCLUSION For these reasons, the United States requests that $1,153,457, as of April 13, 2026, plus interest accruing until the date of disbursement, be paid to the United States from the Disputed Funds. Date: April 15, 2026 Respectfully submitted, BRETT A. SHUMATE Assistant Attorney General JOSHUA WU Deputy Assistant Attorney General, Tax Litigation Branch /s/ William J. Harrington WILLIAM J. HARRINGTON ELIZABETH PRUITT Trial Attorneys, Civil Division Tax Litigation Branch U.S. Department of Justice Post Office Box 227 Washington, DC 20044 Tel: (202) 353-1882 Fax: (202) 514-6866 William.J.Harrington@usdoj.gov Elizabeth.Pruitt@usdoj.gov -and￾TODD BLANCHE Acting Attorney General /s/ Jonathan H. Hambrick JONATHAN H. HAMBRICK VSB NO. 37590 Assistant United States Attorney Eastern District of Virginia 919 E. Main Street, Suite 1900 Richmond, VA 23219 Phone: (804) 819-5400 Fax: (804) 771-2316 E-mail: jay.h.hambrick@usdoj.gov Counsel to the United States Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 12 of 13 PageID# 3898
entityobservation

United States of America

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. ) ) Interpleader Plaintiff, ) ) v. ) ) CYBERLUX CORPORATION, et al., ) ) Defendants. ) _______________________________________) Case No. 3:25-cv-00483-JAG UNITED STATES’ MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT The United States of America submits this memorandum of law in support of its motion for summary judgment. I. INTRODUCTION There is no dispute that the United States’ tax liens have priority to all other creditors in this lawsuit, except one, Legalist SPV III, L.P., as to which the United States has partial priority. Because the claims of the United States’ (just over $1.1 million) and Legalist (just over $13 million) can be fully paid from the interpleaded funds (over $23 million), and because there is no genuine dispute of material fact that the United States has priority as to all other creditors, the United States is entitled to judgment as a matter of law. II. UNDISPUTED MATERIAL FACTS 1. Plaintiff HII Mission Technologies Corp.’s (“HII”) predecessor entered into a subcontract with Cyberlux, which is incorporated in Nevada and has its principal place of business in North Carolina. ECF 41, ¶¶ 4, 17, 18 . Under the subcontract, Cyberlux would Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 1 of 13 PageID# 3887
entityobservation

HII Mission Technologies Corp.

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. ) ) Interpleader Plaintiff, ) ) v. ) ) CYBERLUX CORPORATION, et al., ) ) Defendants. ) _______________________________________) Case No. 3:25-cv-00483-JAG UNITED STATES’ MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT The United States of America submits this memorandum of law in support of its motion for summary judgment. I. INTRODUCTION There is no dispute that the United States’ tax liens have priority to all other creditors in this lawsuit, except one, Legalist SPV III, L.P., as to which the United States has partial priority. Because the claims of the United States’ (just over $1.1 million) and Legalist (just over $13 million) can be fully paid from the interpleaded funds (over $23 million), and because there is no genuine dispute of material fact that the United States has priority as to all other creditors, the United States is entitled to judgment as a matter of law. II. UNDISPUTED MATERIAL FACTS 1. Plaintiff HII Mission Technologies Corp.’s (“HII”) predecessor entered into a subcontract with Cyberlux, which is incorporated in Nevada and has its principal place of business in North Carolina. ECF 41, ¶¶ 4, 17, 18 . Under the subcontract, Cyberlux would Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 1 of 13 PageID# 3887
entityobservation

Cyberlux Corporation

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2 support HII’s work under a prime contract with the Department of the Navy and General Services Administration. ECF 41, ¶ 18. 2. On May 17, 2024, HII terminated the subcontract with Cyberlux and, pursuant to the subcontract, became obligated to pay Cyberlux “a percentage of the Subcontract price corresponding with the percentage of the terminated work actually performed prior to the notice of termination,” plus certain expenses. Id., ¶¶ 21-22. 3. HII commenced this action in interpleader, naming defendant Cyberlux Corporation and Cyberlux’s creditors. Id., ¶ 1. HII sought to deposit certain sums owed to Cyberlux and to which various Cyberlux creditors had made claims. Id., ¶ 2. 4. On February 20, 2026, this Court granted HII’s Motion for Interpleader Deposit and directed HII to deposit $23,736,937.56 (the “Disputed Funds”) into the Court’s Registry Investment System. ECF 150. 5. On March 6, 2026, HII interpleaded the Disputed Funds as directed and was dismissed from this lawsuit. March 6, 2026, Docket Entry reflecting deposit; see also ECF 153 (order acknowledging the deposit and dismissing HII). a. Facts relevant to the United States’ claim. 6. Cyberlux did not pay its taxes and, as a result, the United States has liens on Cyberlux’s property, including the Disputed Funds, in the amount of $1,153,457, plus accruing interest. See generally Declaration of IRS Revenue Officer Carol Davis (Ex. 1). 7. Specifically, a delegate of the Secretary of the Treasury assessed the following unpaid tax liabilities (IRS Forms 940 and 941) and penalties (26 USC § 6721) against Cyberlux Corporation: Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 2 of 13 PageID# 3888
entityobservation

Legalist SPV III, L.P.

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. ) ) Interpleader Plaintiff, ) ) v. ) ) CYBERLUX CORPORATION, et al., ) ) Defendants. ) _______________________________________) Case No. 3:25-cv-00483-JAG UNITED STATES’ MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT The United States of America submits this memorandum of law in support of its motion for summary judgment. I. INTRODUCTION There is no dispute that the United States’ tax liens have priority to all other creditors in this lawsuit, except one, Legalist SPV III, L.P., as to which the United States has partial priority. Because the claims of the United States’ (just over $1.1 million) and Legalist (just over $13 million) can be fully paid from the interpleaded funds (over $23 million), and because there is no genuine dispute of material fact that the United States has priority as to all other creditors, the United States is entitled to judgment as a matter of law. II. UNDISPUTED MATERIAL FACTS 1. Plaintiff HII Mission Technologies Corp.’s (“HII”) predecessor entered into a subcontract with Cyberlux, which is incorporated in Nevada and has its principal place of business in North Carolina. ECF 41, ¶¶ 4, 17, 18 . Under the subcontract, Cyberlux would Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 1 of 13 PageID# 3887
entityobservation

Carol Davis

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2 support HII’s work under a prime contract with the Department of the Navy and General Services Administration. ECF 41, ¶ 18. 2. On May 17, 2024, HII terminated the subcontract with Cyberlux and, pursuant to the subcontract, became obligated to pay Cyberlux “a percentage of the Subcontract price corresponding with the percentage of the terminated work actually performed prior to the notice of termination,” plus certain expenses. Id., ¶¶ 21-22. 3. HII commenced this action in interpleader, naming defendant Cyberlux Corporation and Cyberlux’s creditors. Id., ¶ 1. HII sought to deposit certain sums owed to Cyberlux and to which various Cyberlux creditors had made claims. Id., ¶ 2. 4. On February 20, 2026, this Court granted HII’s Motion for Interpleader Deposit and directed HII to deposit $23,736,937.56 (the “Disputed Funds”) into the Court’s Registry Investment System. ECF 150. 5. On March 6, 2026, HII interpleaded the Disputed Funds as directed and was dismissed from this lawsuit. March 6, 2026, Docket Entry reflecting deposit; see also ECF 153 (order acknowledging the deposit and dismissing HII). a. Facts relevant to the United States’ claim. 6. Cyberlux did not pay its taxes and, as a result, the United States has liens on Cyberlux’s property, including the Disputed Funds, in the amount of $1,153,457, plus accruing interest. See generally Declaration of IRS Revenue Officer Carol Davis (Ex. 1). 7. Specifically, a delegate of the Secretary of the Treasury assessed the following unpaid tax liabilities (IRS Forms 940 and 941) and penalties (26 USC § 6721) against Cyberlux Corporation: Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 2 of 13 PageID# 3888
entityobservation

William J. Harrington

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12 V. CONCLUSION For these reasons, the United States requests that $1,153,457, as of April 13, 2026, plus interest accruing until the date of disbursement, be paid to the United States from the Disputed Funds. Date: April 15, 2026 Respectfully submitted, BRETT A. SHUMATE Assistant Attorney General JOSHUA WU Deputy Assistant Attorney General, Tax Litigation Branch /s/ William J. Harrington WILLIAM J. HARRINGTON ELIZABETH PRUITT Trial Attorneys, Civil Division Tax Litigation Branch U.S. Department of Justice Post Office Box 227 Washington, DC 20044 Tel: (202) 353-1882 Fax: (202) 514-6866 William.J.Harrington@usdoj.gov Elizabeth.Pruitt@usdoj.gov -and￾TODD BLANCHE Acting Attorney General /s/ Jonathan H. Hambrick JONATHAN H. HAMBRICK VSB NO. 37590 Assistant United States Attorney Eastern District of Virginia 919 E. Main Street, Suite 1900 Richmond, VA 23219 Phone: (804) 819-5400 Fax: (804) 771-2316 E-mail: jay.h.hambrick@usdoj.gov Counsel to the United States Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 12 of 13 PageID# 3898
entityobservation

Jonathan H. Hambrick

Read the anchor · page 12
12 V. CONCLUSION For these reasons, the United States requests that $1,153,457, as of April 13, 2026, plus interest accruing until the date of disbursement, be paid to the United States from the Disputed Funds. Date: April 15, 2026 Respectfully submitted, BRETT A. SHUMATE Assistant Attorney General JOSHUA WU Deputy Assistant Attorney General, Tax Litigation Branch /s/ William J. Harrington WILLIAM J. HARRINGTON ELIZABETH PRUITT Trial Attorneys, Civil Division Tax Litigation Branch U.S. Department of Justice Post Office Box 227 Washington, DC 20044 Tel: (202) 353-1882 Fax: (202) 514-6866 William.J.Harrington@usdoj.gov Elizabeth.Pruitt@usdoj.gov -and￾TODD BLANCHE Acting Attorney General /s/ Jonathan H. Hambrick JONATHAN H. HAMBRICK VSB NO. 37590 Assistant United States Attorney Eastern District of Virginia 919 E. Main Street, Suite 1900 Richmond, VA 23219 Phone: (804) 819-5400 Fax: (804) 771-2316 E-mail: jay.h.hambrick@usdoj.gov Counsel to the United States Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 12 of 13 PageID# 3898
eventattribution

United States files priority memorandum and service certificate.

Read the anchor · page 12
12 V. CONCLUSION For these reasons, the United States requests that $1,153,457, as of April 13, 2026, plus interest accruing until the date of disbursement, be paid to the United States from the Disputed Funds. Date: April 15, 2026 Respectfully submitted, BRETT A. SHUMATE Assistant Attorney General JOSHUA WU Deputy Assistant Attorney General, Tax Litigation Branch /s/ William J. Harrington WILLIAM J. HARRINGTON ELIZABETH PRUITT Trial Attorneys, Civil Division Tax Litigation Branch U.S. Department of Justice Post Office Box 227 Washington, DC 20044 Tel: (202) 353-1882 Fax: (202) 514-6866 William.J.Harrington@usdoj.gov Elizabeth.Pruitt@usdoj.gov -and￾TODD BLANCHE Acting Attorney General /s/ Jonathan H. Hambrick JONATHAN H. HAMBRICK VSB NO. 37590 Assistant United States Attorney Eastern District of Virginia 919 E. Main Street, Suite 1900 Richmond, VA 23219 Phone: (804) 819-5400 Fax: (804) 771-2316 E-mail: jay.h.hambrick@usdoj.gov Counsel to the United States Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 12 of 13 PageID# 3898
eventattribution

Requested tax balance stated asof thisdate.

Read the anchor · page 3
3 Assessment Type Tax Period Ending Assessment Date NFTL Filing Date Balance1 (as of April 13, 2026) IRS Form 9412 6/30/2010 5/13/2013 4/30/2024 $87,454 IRS Form 941 12/31/2010 4/11/2011 4/30/2024 $149,003 IRS Form 941 12/31/2012 4/01/2013 4/30/2024 $872,811 IRS Form 941 12/31/2021 9/5/2022 10/10/2023 $2,625 IRS Form 940 12/31/2022 2/27/2023 10/10/2023 $321 IRS Form 940 12/31/2023 2/26/2024 4/30/2024 $361 26 USC § 67213 12/31/2013 10/24/2016 8/21/2017 $40,882 TOTAL BALANCE $1,153,457.00 Id., ¶ 5. 8. True and correct copies of account transcripts memorializing these liabilities are attached to Revenue Officer Davis’s Declaration as Attachment A thereto. 9. A delegate of the Secretary of the Treasury gave notice of these assessments to Cyberlux Corporation and made demand upon it for payment of those assessments. Despite notice and demand for payment, Cyberlux Corporation has failed or refused to pay the full amounts due and owing for these assessments. As a result, under 26 U.S.C. § 6321, the unpaid assessment amounts are a lien in favor of the United States upon all property and rights to property belonging to Cyberlux Corporation, including upon the interpleaded proceeds. Id., ¶ 7. 10. The IRS filed Notices of Federal Tax Lien (“NFTLs”) memorializing the liens with the North Carolina Secretary of State. Id., ¶ 8. The NFTLs were filed on the dates set forth 1 This includes assessment amount plus accruals (interest and penalties) accruing through April 13, 2026. 2 IRS Forms 941 are used to report withheld employee income tax and withheld employee and employer Social Security and Medicare tax. IRS Forms 940 are used to report an employer’s Federal Unemployment Tax Act taxes. 3 These are penalties for failure to file returns. Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 3 of 13 PageID# 3889
inferenceinference

The government’s review of government-contracting statutes addresses tax-lien priority to the fund. It must not be represented as government

The government’s review of government-contracting statutes addresses tax-lien priority to the fund. It must not be represented as government certification of invoice allowability,contract performance or procurement legality.

inferenceinference

Perfection date alone does not describe the government’s full Legalist-priority theory:it separately tracks actual advance dates and a claim

Perfection date alone does not describe the government’s full Legalist-priority theory:it separately tracks actual advance dates and a claimed statutory window. Retain those components before assigning a single priority label to the entire Legalist balance.

inferenceinference

The principal request and alternative priority table contain different tax components;the total request should not silently overwrite the ta

The principal request and alternative priority table contain different tax components;the total request should not silently overwrite the table or vice versa. Underlying IRS schedules and any corrected submission are needed.

otherattribution

Complete supplied 13-page source reviewed at SHA-256 57fccba839a9d1b4a85220dbe7ea170d581046407c9a43d0138fc53bfbf497ad. Source assertions, or

Complete supplied 13-page source reviewed at SHA-256 57fccba839a9d1b4a85220dbe7ea170d581046407c9a43d0138fc53bfbf497ad. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Read full native text of all13pages of registered57fccba8 PDF,including footnotes,advance repetitions,ARGchanged-answer footnote and service. Originalpages3,5,7,9,12,13checked the complete tax table,advance list,limited government-contracting paragraph,alternative priority table and signed filing/service details. Arithmetic comparison of the printed tax values flags a$3,553.97difference between alternative-table total and requested total;no value was substituted.

Read the anchor · page 1
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. ) ) Interpleader Plaintiff, ) ) v. ) ) CYBERLUX CORPORATION, et al., ) ) Defendants. ) _______________________________________) Case No. 3:25-cv-00483-JAG UNITED STATES’ MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT The United States of America submits this memorandum of law in support of its motion for summary judgment. I. INTRODUCTION There is no dispute that the United States’ tax liens have priority to all other creditors in this lawsuit, except one, Legalist SPV III, L.P., as to which the United States has partial priority. Because the claims of the United States’ (just over $1.1 million) and Legalist (just over $13 million) can be fully paid from the interpleaded funds (over $23 million), and because there is no genuine dispute of material fact that the United States has priority as to all other creditors, the United States is entitled to judgment as a matter of law. II. UNDISPUTED MATERIAL FACTS 1. Plaintiff HII Mission Technologies Corp.’s (“HII”) predecessor entered into a subcontract with Cyberlux, which is incorporated in Nevada and has its principal place of business in North Carolina. ECF 41, ¶¶ 4, 17, 18 . Under the subcontract, Cyberlux would Case 3:25-cv-00483-JAG Document 183 Filed 04/15/26 Page 1 of 13 PageID# 3887
questionquestion

What Davis transcripts,NFTLs and corrected payoff schedule reconcile the tax components and accrued interest?

questionquestion

What operative financing provisions,advance records and priority ruling determine Legalist’s protected amount and treatment of later advance

What operative financing provisions,advance records and priority ruling determine Legalist’s protected amount and treatment of later advances?

questionquestion

What order resolved this motion and what sums were actually disbursed to the United States and Legalist?

questionquestion

What complete creditor interrogatories and ARGsupplement support or dispute the government’s characterisation of competing interests?

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.

The proposed waterfall pays USA $1,149,776.34, Legalist’sasserted22May2025 secured balance $7,313,627.17, then receiver fee $5,934,234.39, leaving $9,339,299.66. The receiver argues his fee is analogous to a bankruptcy administrative priority. He alternatively says if the court entrusts the whole or post-USA/Legalist remainder to him, he will take a pro-rata portion with the listed unsecured creditors. This conditional alternative is not the same as irrevocably waiving his priority claim.qualifiesCiting IRS officer Carol Davis,the United States claims$1,153,457 as of13April2026 plus later interest for unpaid assessments after notice/demand. Table balances are941periodsJune2010$87,454,December2010$149,003,December2012$872,811,December2021$2,625;940December2022$321,December2023$361;and6721December2013penalty$40,882. NFTLdates are21August2017,10October2023 and30April2024,as allocated in the table.

Receiveruses$1,149,776.34 whilegovernment’slaterassessedpayoffstatementuses$1,153,457;scope/date/interestmustbereconciled.

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Confidence 75%Link weight 50%
Legalist disbursements are recited as9April2024$1.8million,19April$500k,2May$500k,26June$142k,5July$53k,16July$2.5million,2August$650k,27August$535k,3October$150k and$120k,3June2025$2,755,100.10 and9June2025printed$345,000.001. The motion attributes a total claim$13,204,742.88 as of9March2026 plus interest to Legalist’s interrogatory answer.referencesProstok declares that Legalist transferred the described funds and they are currently held in his law firm’s trust account. The declaration contains no bank record or evidence that the receiver or judgment creditor has received them.

ListedJune2025advance can be compared with Prostok’sfunds-in-trust account;dates and actual destination still require primary records.

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Confidence 75%Link weight 50%
The United States says precise relative priority with Legalist is immaterial because the fund can pay both claims. Alternatively,it proposes first its2017/2023liens,then$2.8millionLegalistadvances,and then itsApril2024liens,arguing security exists only to money advanced and applying a45-day post-notice protection window. It places advances after15June2024behind its final notice and requests full federal payment before remaining creditors. These are requested legal outcomes,not adjudicated priorities.supportsWhat does the government seek,and what does it not decide here?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Citing IRS officer Carol Davis,the United States claims$1,153,457 as of13April2026 plus later interest for unpaid assessments after notice/demand. Table balances are941periodsJune2010$87,454,December2010$149,003,December2012$872,811,December2021$2,625;940December2022$321,December2023$361;and6721December2013penalty$40,882. NFTLdates are21August2017,10October2023 and30April2024,as allocated in the table.supportsWhat Davis transcripts,NFTLs and corrected payoff schedule reconcile the tax components and accrued interest?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Legalist disbursements are recited as9April2024$1.8million,19April$500k,2May$500k,26June$142k,5July$53k,16July$2.5million,2August$650k,27August$535k,3October$150k and$120k,3June2025$2,755,100.10 and9June2025printed$345,000.001. The motion attributes a total claim$13,204,742.88 as of9March2026 plus interest to Legalist’s interrogatory answer.supportsWhat operative financing provisions,advance records and priority ruling determine Legalist’s protected amount and treatment of later advances?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The15April2026conclusion requests$1,153,457 plus interest through disbursement. William J.Harrington and Jonathan H.Hambrick sign for the United States;Harrington certifiesCM/ECFfiling/notification that date. No order granting summary judgment or payment appears in this main memorandum.supportsWhat order resolved this motion and what sums were actually disbursed to the United States and Legalist?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The government invokes Rule56,second-stage interpleader andIRC6321–6323. In response to the court’sECF158government-contracting inquiry,counsel says tax-lien priority is governed by theIRC. It argues corporate personal-property NFTLs were correctly filed in NorthCarolina,the principal executive-office state. This limited priority position does not purport to audit or approve the underlying procurement.supportsThe government’s review of government-contracting statutes addresses tax-lien priority to the fund. It must not be represented as government certification of invoice allowability,contract performance or procurement legality.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The motion says Legalist and Cyberlux signed a27March2024government-purchase-order financing agreement for$3million secured by all borrower assets,including contract rights/receivables,and perfected by NevadaUCCfiling1April2024. It says later amendments13July2024 and29April2025postdate all tax notices. The agreement,UCC and amendments are referenced as exhibits,not included in this13-page main filing.supportsPerfection date alone does not describe the government’s full Legalist-priority theory:it separately tracks actual advance dates and a claimed statutory window. Retain those components before assigning a single priority label to the entire Legalist balance.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The alternative table onpage9 lists USA$40,882,$2,937.49 and$1,106,083.54,which sum$1,149,903.03 rather than the requested$1,153,457. Page3’sOctober2023-notice balances total$2,946 rather than$2,937.49;page11describes final-notice liabilities$1,109,629 rather than table$1,106,083.54. These internal amount differences are retained for reconciliation,not silently repaired.supportsWhat Davis transcripts,NFTLs and corrected payoff schedule reconcile the tax components and accrued interest?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The alternative table onpage9 lists USA$40,882,$2,937.49 and$1,106,083.54,which sum$1,149,903.03 rather than the requested$1,153,457. Page3’sOctober2023-notice balances total$2,946 rather than$2,937.49;page11describes final-notice liabilities$1,109,629 rather than table$1,106,083.54. These internal amount differences are retained for reconciliation,not silently repaired.supportsWhat does the government seek,and what does it not decide here?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The15April2026conclusion requests$1,153,457 plus interest through disbursement. William J.Harrington and Jonathan H.Hambrick sign for the United States;Harrington certifiesCM/ECFfiling/notification that date. No order granting summary judgment or payment appears in this main memorandum.supportsThe principal request and alternative priority table contain different tax components;the total request should not silently overwrite the table or vice versa. Underlying IRS schedules and any corrected submission are needed.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
Citing IRS officer Carol Davis,the United States claims$1,153,457 as of13April2026 plus later interest for unpaid assessments after notice/demand. Table balances are941periodsJune2010$87,454,December2010$149,003,December2012$872,811,December2021$2,625;940December2022$321,December2023$361;and6721December2013penalty$40,882. NFTLdates are21August2017,10October2023 and30April2024,as allocated in the table.supportsThe principal request and alternative priority table contain different tax components;the total request should not silently overwrite the table or vice versa. Underlying IRS schedules and any corrected submission are needed.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The United States moves for summary judgment on tax-lien priority in the HII interpleader. It says HII’s Navy/GSA-related subcontract ended17May2024,the court directed deposit$23,736,937.56 on20February2026,and HII deposited on6March and was dismissed. The motion citesECF41,150,153 and docket entries;it is not itself those orders or a disbursement record.supportsThe government’s review of government-contracting statutes addresses tax-lien priority to the fund. It must not be represented as government certification of invoice allowability,contract performance or procurement legality.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Citing IRS officer Carol Davis,the United States claims$1,153,457 as of13April2026 plus later interest for unpaid assessments after notice/demand. Table balances are941periodsJune2010$87,454,December2010$149,003,December2012$872,811,December2021$2,625;940December2022$321,December2023$361;and6721December2013penalty$40,882. NFTLdates are21August2017,10October2023 and30April2024,as allocated in the table.supportsWhat does the government seek,and what does it not decide here?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Legalist disbursements are recited as9April2024$1.8million,19April$500k,2May$500k,26June$142k,5July$53k,16July$2.5million,2August$650k,27August$535k,3October$150k and$120k,3June2025$2,755,100.10 and9June2025printed$345,000.001. The motion attributes a total claim$13,204,742.88 as of9March2026 plus interest to Legalist’s interrogatory answer.supportsPerfection date alone does not describe the government’s full Legalist-priority theory:it separately tracks actual advance dates and a claimed statutory window. Retain those components before assigning a single priority label to the entire Legalist balance.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The15April2026conclusion requests$1,153,457 plus interest through disbursement. William J.Harrington and Jonathan H.Hambrick sign for the United States;Harrington certifiesCM/ECFfiling/notification that date. No order granting summary judgment or payment appears in this main memorandum.supportsThe government’s review of government-contracting statutes addresses tax-lien priority to the fund. It must not be represented as government certification of invoice allowability,contract performance or procurement legality.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The United States says precise relative priority with Legalist is immaterial because the fund can pay both claims. Alternatively,it proposes first its2017/2023liens,then$2.8millionLegalistadvances,and then itsApril2024liens,arguing security exists only to money advanced and applying a45-day post-notice protection window. It places advances after15June2024behind its final notice and requests full federal payment before remaining creditors. These are requested legal outcomes,not adjudicated priorities.supportsPerfection date alone does not describe the government’s full Legalist-priority theory:it separately tracks actual advance dates and a claimed statutory window. Retain those components before assigning a single priority label to the entire Legalist balance.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The alternative table onpage9 lists USA$40,882,$2,937.49 and$1,106,083.54,which sum$1,149,903.03 rather than the requested$1,153,457. Page3’sOctober2023-notice balances total$2,946 rather than$2,937.49;page11describes final-notice liabilities$1,109,629 rather than table$1,106,083.54. These internal amount differences are retained for reconciliation,not silently repaired.supportsThe principal request and alternative priority table contain different tax components;the total request should not silently overwrite the table or vice versa. Underlying IRS schedules and any corrected submission are needed.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The government invokes Rule56,second-stage interpleader andIRC6321–6323. In response to the court’sECF158government-contracting inquiry,counsel says tax-lien priority is governed by theIRC. It argues corporate personal-property NFTLs were correctly filed in NorthCarolina,the principal executive-office state. This limited priority position does not purport to audit or approve the underlying procurement.supportsWhat does the government seek,and what does it not decide here?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The15April2026conclusion requests$1,153,457 plus interest through disbursement. William J.Harrington and Jonathan H.Hambrick sign for the United States;Harrington certifiesCM/ECFfiling/notification that date. No order granting summary judgment or payment appears in this main memorandum.supportsWhat does the government seek,and what does it not decide here?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The motion says Legalist and Cyberlux signed a27March2024government-purchase-order financing agreement for$3million secured by all borrower assets,including contract rights/receivables,and perfected by NevadaUCCfiling1April2024. It says later amendments13July2024 and29April2025postdate all tax notices. The agreement,UCC and amendments are referenced as exhibits,not included in this13-page main filing.supportsWhat operative financing provisions,advance records and priority ruling determine Legalist’s protected amount and treatment of later advances?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The United States says precise relative priority with Legalist is immaterial because the fund can pay both claims. Alternatively,it proposes first its2017/2023liens,then$2.8millionLegalistadvances,and then itsApril2024liens,arguing security exists only to money advanced and applying a45-day post-notice protection window. It places advances after15June2024behind its final notice and requests full federal payment before remaining creditors. These are requested legal outcomes,not adjudicated priorities.supportsWhat operative financing provisions,advance records and priority ruling determine Legalist’s protected amount and treatment of later advances?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The United States says precise relative priority with Legalist is immaterial because the fund can pay both claims. Alternatively,it proposes first its2017/2023liens,then$2.8millionLegalistadvances,and then itsApril2024liens,arguing security exists only to money advanced and applying a45-day post-notice protection window. It places advances after15June2024behind its final notice and requests full federal payment before remaining creditors. These are requested legal outcomes,not adjudicated priorities.supportsWhat order resolved this motion and what sums were actually disbursed to the United States and Legalist?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The government characterises other claimants’liens as later than its notices:receiver1April2025,ThinAirAugust/December2025,ANPCSeptember2025writ/December2024equitablelien,WeShieldgroupOctober2025,and AW/SecureNevadafiling20March2026. It says AW/Secure do not contest federal priority,Fairwinds claims no security interest,and ARG initially disclaimed perfected security. A footnote records ARG’s14April2026changed answer asserting2022/2023priority but says no earlierUCCwas produced. These are the movant’s account of responses,not independent determinations.supportsWhat complete creditor interrogatories and ARGsupplement support or dispute the government’s characterisation of competing interests?

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.