Legal Objection - Post-Judgment Receivership Fee Dispute

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

12 expense. In addition, the Receiver has failed to provide documentary evidence that these expenses were actually incurred and paid. c. The Receiver has failed to provide documentary evidence that all expenses identified in Exhibit 1 for locksmiths, storage, and security were actually incurred and paid. d. All expenses identified in Exhibit 1 for advisory services in Ukraine, travel expenses and per diem related to the Virginia Interpleader, payments to employees, consultant fees, and related matters were not incurred for purposes of collecting the Underlying Judgment and were thus incurred beyond the Receiver’s authority. Defendants also object to all expenses incurred prior to the Receiver’s appointment and after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report ¶ 9, Ex. 3. Nor has the Receiver provided documentary evidence that any of these expenses were actually incurred and paid. 15. Defendants object to subparagraphs “A” through “DD” of paragraph 15 of the Berleth Declaration, as follows: a. Defendants object to subparagraph 15(A) because the Receiver has failed to provide documentary evidence that storage fees were actually incurred. b. Defendants object to subparagraph 15(B) because the retainer was paid to a law firm on August 8, 2025, after the Receiver acknowledged the receivership had concluded. See Original Final Report ¶ 9, Ex. 3. Moreover, as set forth in Defendants’ General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver’s actions taken in that matter were UnofficialCopyOfficeofMarilynBurgessDistrictClerk

21 unnecessary, and not compensable. See Order Denying Expanding Receiver’s Authority, attached as Exhibit 14. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid. y. Defendants object to subparagraph 15(Y). It appears the Receiver is requesting he be reimbursed for paying to Plaintiffs funds received from Legalist to satisfy the Underlying Judgment. The Receiver is not entitled to reimbursement for amounts paid to Plaintiffs as an expense. z. Defendants object to subparagraph 15(Z) because the attorney’s fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report ¶ 9, Ex. 3. Moreover, as set forth in Defendants’ General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver’s actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid. aa. Defendants object to subparagraph 15(AA) because the attorney’s fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report ¶ 9, Ex. 3. Moreover, UnofficialCopyOfficeofMarilynBurgessDistrictClerk

23 collection of the Underlying Judgment, and the Receiver’s actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid. dd. Defendants object to subparagraph 15(DD) because the attorney’s fees and expenses were paid to a law firm after the Receiver acknowledged the receivership had concluded on June 11, 2025. See Original Final Report ¶ 9, Ex. 3. Moreover, as set forth in Defendants’ General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader had nothing to do with this action and the collection of the Underlying Judgment, and the Receiver’s actions taken in that matter were unauthorized and ultra vires. Defendants also object because the Receiver has failed to provide the underlying itemized invoices, without which it is impossible to determine whether the fees and expenses incurred were reasonable and necessary. Defendants further object in that even if authorized, the Receiver has provided no documentary evidence that these expenses were actually incurred and paid. 16. Defendants object to paragraph 16 of the Berleth Declaration because the claimed level of work and attention required by a receivership of less than three weeks in duration was due largely to the Receiver’s unauthorized actions, which exceeded the scope of the Receivership Order. The Underlying Judgment was not recovered by the Receiver but funded by Legalist. UnofficialCopyOfficeofMarilynBurgessDistrictClerk

26 Respectfully submitted, ADAMS & REESE, LLP By: /s/ Evan A. Moeller Evan A. Moeller State Bar No. 24051067 evan.moeller@arlaw.com Aaron G. McLeod State Bar No. 24100888 aaron.mcleod@arlaw.com LyondellBasell Tower 1221 McKinney St., Suite 4400 Houston, Texas 77010 Telephone: (713) 652-5151 Facsimile: (713) 652-5152 Attorneys for Cyberlux Corporation and Mark D. Schmidt CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing was served pursuant to the Texas Rules of Civil Procedure upon all parties on this 27th day of May, 2026. /s/ Evan A. Moeller Evan A. Moeller UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

2 general and specific objections to the Final Report and the Declaration of Robert W. Berleth in Support of Receiver’s Fees and Expenses (“Berleth Declaration”). B. General Objections Defendants submit the following general objections to the Final Report, Berleth Declaration, and Receiver’s Invoice: 1. Defendants object to the Receiver’s requested fee of $1,017,601.11 as unreasonable, unnecessary, and not authorized by the Receivership Order. Paragraph 53 of the Receivership Order provides that the Receiver is entitled “to a fee equal to 25% of all sales of assets that come into his actual, constructive, or legal possession, and all recoveries and credits against the judgment,” so long as the Rohrmoos Ventures elements have been satisfied and after notice and a hearing. See Receivership Order ¶ 53, Ex. 1. To the extent the Receiver collects the full amount of the Underlying Judgment, the Court may award the Receiver 33% of the collected funds. Here, the Receiver did not “collect” the Underlying Judgment by his actions. Rather, on June 11, 2025, Defendants’ lender, Legalist SPV III, LP (“Legalist”), voluntarily wired1 $3,083,639.75 to the Receiver to satisfy the Underlying Judgment. See Original Final Report ¶¶ 2, 6, Exhibit 3; Wire Transfer Confirmation and Judgment Calculation, Ex. 4. Of that amount, $873,849.02 was disbursed to Plaintiffs by the Receiver. The Receiver is thus not entitled to 33% of the Underlying Judgment. Instead, the Receiver is entitled to, at a maximum, 25% of what the Receiver disbursed to Plaintiffs, which is $218,462.30 and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5. Any fee in excess of that amount would be unreasonable under the circumstances. 1 The wire was authorized on June 10, 2025, and processed on June 11, 2025. See Wire Transfer Confirmation, Ex. 4. UnofficialCopyOfficeofMarilynBurgessDistrictClerk

2 general and specific objections to the Final Report and the Declaration of Robert W. Berleth in Support of Receiver’s Fees and Expenses (“Berleth Declaration”). B. General Objections Defendants submit the following general objections to the Final Report, Berleth Declaration, and Receiver’s Invoice: 1. Defendants object to the Receiver’s requested fee of $1,017,601.11 as unreasonable, unnecessary, and not authorized by the Receivership Order. Paragraph 53 of the Receivership Order provides that the Receiver is entitled “to a fee equal to 25% of all sales of assets that come into his actual, constructive, or legal possession, and all recoveries and credits against the judgment,” so long as the Rohrmoos Ventures elements have been satisfied and after notice and a hearing. See Receivership Order ¶ 53, Ex. 1. To the extent the Receiver collects the full amount of the Underlying Judgment, the Court may award the Receiver 33% of the collected funds. Here, the Receiver did not “collect” the Underlying Judgment by his actions. Rather, on June 11, 2025, Defendants’ lender, Legalist SPV III, LP (“Legalist”), voluntarily wired1 $3,083,639.75 to the Receiver to satisfy the Underlying Judgment. See Original Final Report ¶¶ 2, 6, Exhibit 3; Wire Transfer Confirmation and Judgment Calculation, Ex. 4. Of that amount, $873,849.02 was disbursed to Plaintiffs by the Receiver. The Receiver is thus not entitled to 33% of the Underlying Judgment. Instead, the Receiver is entitled to, at a maximum, 25% of what the Receiver disbursed to Plaintiffs, which is $218,462.30 and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5. Any fee in excess of that amount would be unreasonable under the circumstances. 1 The wire was authorized on June 10, 2025, and processed on June 11, 2025. See Wire Transfer Confirmation, Ex. 4. UnofficialCopyOfficeofMarilynBurgessDistrictClerk

3 2. Defendants object to the Receiver’s requested reimbursement of $722,728.68 in expenses to the extent incurred after June 11, 2025, save and except these expenses addressed in paragraph 5, sections j., p., and q. below, to which Defendants object for independent reasons.2 On that date, Legalist voluntarily wired $3,083,639.75 to the Receiver to satisfy the Underlying Judgment. See Wire Transfer Confirmation and Judgment Calculation, Ex. 4. In his original Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Original Final Report,” Ex. 2), filed June 11, 2025, the Receiver conceded that those funds had been received and that “[t]he Receivership ha[d] completed with no further remaining issues pending the final distribution of funds . . . .”. See Original Final Report ¶ 9, Ex. 3. In the Virginia Interpleader, explained in more detail below, the United States District Court for the Eastern District of Virginia likewise held that “Legalist satisfied [the Underlying Judgment] in June 2025.” See E.D. Va. Memorandum Order p. 3, Ex. 6. Thus, any expenses incurred after June 11, 2025, were unreasonable and unnecessary. 3. Defendants object to the Receiver’s requested fee and reimbursement of $722,728.68 in expenses that were incurred for actions taken or for expenses paid that exceeded the scope of the Receiver’s authority under the Receivership Order and TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). The Receiver was appointed as a post-judgment receiver for the sole purpose of collecting the Underlying Judgment against Defendants. Actions taken and expenses incurred beyond that purpose are ultra vires. 3 4. Defendants object to the Receiver’s requested reimbursement of $722,728.68 in expenses to the extent the alleged expenses are otherwise found to be unreasonable, unnecessary, 2 Any objection to all expenses incurred after June 11, 2025 herein is subject to the same exceptions. 3 This is not the first time the Receiver has acted ultra vires. See United States Court of Appeals for the Fifth Circuit - 12.31.24 Per Curiam Opinion, Ex. 7. UnofficialCopyOfficeofMarilynBurgessDistrictClerk

3 2. Defendants object to the Receiver’s requested reimbursement of $722,728.68 in expenses to the extent incurred after June 11, 2025, save and except these expenses addressed in paragraph 5, sections j., p., and q. below, to which Defendants object for independent reasons.2 On that date, Legalist voluntarily wired $3,083,639.75 to the Receiver to satisfy the Underlying Judgment. See Wire Transfer Confirmation and Judgment Calculation, Ex. 4. In his original Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Original Final Report,” Ex. 2), filed June 11, 2025, the Receiver conceded that those funds had been received and that “[t]he Receivership ha[d] completed with no further remaining issues pending the final distribution of funds . . . .”. See Original Final Report ¶ 9, Ex. 3. In the Virginia Interpleader, explained in more detail below, the United States District Court for the Eastern District of Virginia likewise held that “Legalist satisfied [the Underlying Judgment] in June 2025.” See E.D. Va. Memorandum Order p. 3, Ex. 6. Thus, any expenses incurred after June 11, 2025, were unreasonable and unnecessary. 3. Defendants object to the Receiver’s requested fee and reimbursement of $722,728.68 in expenses that were incurred for actions taken or for expenses paid that exceeded the scope of the Receiver’s authority under the Receivership Order and TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). The Receiver was appointed as a post-judgment receiver for the sole purpose of collecting the Underlying Judgment against Defendants. Actions taken and expenses incurred beyond that purpose are ultra vires. 3 4. Defendants object to the Receiver’s requested reimbursement of $722,728.68 in expenses to the extent the alleged expenses are otherwise found to be unreasonable, unnecessary, 2 Any objection to all expenses incurred after June 11, 2025 herein is subject to the same exceptions. 3 This is not the first time the Receiver has acted ultra vires. See United States Court of Appeals for the Fifth Circuit - 12.31.24 Per Curiam Opinion, Ex. 7. UnofficialCopyOfficeofMarilynBurgessDistrictClerk

6 and so the fee and expenses allegedly incurred were not “customary, reasonable, and necessary.” Nor did the Receiver collect the full amount of the Underlying Judgment due to his own actions. Rather, Legalist voluntarily wired $3,083,639.75 to the Receiver to satisfy the Underlying Judgment. See Original Final Report ¶¶ 2, 6, Ex. 3. The Receiver is thus not entitled to a fee of 33% of the amount allegedly collected. The Receiver is instead entitled to, at most, $218,462.30, which is 25% of the amounts disbursed by the Receiver in this action and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5. 4. Defendants object to paragraph 4 of the Final Report because the expenses that the Receiver alleges to have incurred were not “necessary.” In the Receiver’s Original Final Report, filed on June 11, 2025, the Receiver advised that the receivership had concluded with no further remaining issues pending the final distribution of the funds received from Legalist. See Original Final Report ¶ 9, Ex. 3; E.D. Va. Memorandum Order p. 3, Ex. 6. In the Original Final Report, the Receiver claimed only $83,341.22 in expenses. Id. at ¶ 7(e). The increase of more than $639,000 in alleged expenses results entirely from activities undertaken after the Underlying Judgment was satisfied and receivership had concluded on June 11, 2025, by the Receiver’s own admission. 5. Defendants object to paragraph 5 of the Final Report to the extent it alleges “several potential TRO/serial receiverships . . . will take effect upon the termination of this receivership.” That allegation is irrelevant to this action and appears designed to justify the continuation of receivership proceedings that the Receiver himself represented had concluded long ago. See Original Final Report ¶ 9, Ex. 3. The existence of other potential receiverships does not authorize this Receiver to continue incurring fees and expenses at the expense of Defendants. In one “potential” receivership, the District Court for the 152nd Judicial District of Harris County, Texas UnofficialCopyOfficeofMarilynBurgessDistrictClerk

9 disbursed by the Receiver to Plaintiffs in this action and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5. e. Defendants object to the fifth subparagraph in that the Receivership has already terminated as a matter of law. f. Defendants object to the sixth subparagraph to the extent the Receiver requests expenses that were unreasonable and unnecessary because they were: (a) incurred after June 11, 2025, when the Receivership concluded by the Receiver’s own admission; (b) incurred for action taken or expenses paid that exceeded the scope of the receivership under the Receivership Order and TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3); and (c) were otherwise unreasonable and unnecessary. D. Objections to Berleth Declaration Defendants object to the Berleth Declaration, paragraph by paragraph, as follows: 1. Paragraph 1 of the Berleth Declaration does not require an objection. Defendants reserve the right to challenge the Receiver’s experience and qualifications at the hearing thereon.5 2. Defendants object to paragraph 2 of the Berleth Declaration to the extent it is offered to establish the Receiver’s qualifications to justify the unreasonable, unnecessary, and/or unauthorized fee and expenses demanded. Defendants reserve the right to challenge the Receiver’s experience and qualifications at the hearing thereon. 3. Defendants object to paragraph 3 of the Berleth Declaration to the extent it is offered to establish the Receiver’s qualifications to justify the exorbitant fee and expenses 5 See Bankr. S.D. Tex. Memorandum Opinion and Order, Ex. 12; S.D. Tex. Memorandum Opinion and Order, Ex. 13. UnofficialCopyOfficeofMarilynBurgessDistrictClerk

11 virtually none. The Underlying Judgment was satisfied by Legalist. Defendants also object because, as set forth in Defendants’ General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader has nothing to do with this action and the collection of the Underlying Judgment, and the Receiver’s actions taken in that matter were unauthorized, ultra vires, and took place after the Receiver acknowledged the receivership had concluded. See Original Final Report ¶ 9, Ex. 3. 13. Defendants object to paragraph 13 of the Berleth Declaration because actions taken to maintain the warehouse, provide oversight and payroll, and handle deliveries had nothing to do with the Receiver’s appointment as a post-judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). Those actions are ultra vires. Defendants also object because as set forth in Defendants’ General Objection No. 6, incorporated fully herein by reference, the Virginia Interpleader has nothing to do with this action and the collection of the Underlying Judgment, and the Receiver’s actions taken in that matter were unauthorized, ultra vires, and took place after the Receiver acknowledged the receivership had concluded. See Original Final Report ¶ 9, Ex. 3. 14. Defendants object to paragraph 14 of the Berleth Declaration and Exhibit 1 cited therein for the following reasons: a. The Receiver has failed to provide itemized invoices for attorney’s fees and expenses paid to the Receiver’s counsel, without which there is no way to determine whether the fees and expenses paid were reasonable and necessary, even if they were authorized (they were not). b. Expenses identified in Exhibit 1 for purchasing meals for the Receiver’s staff are unreasonable and unnecessary and should not be compensated at Defendants’ UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

2 general and specific objections to the Final Report and the Declaration of Robert W. Berleth in Support of Receiver’s Fees and Expenses (“Berleth Declaration”). B. General Objections Defendants submit the following general objections to the Final Report, Berleth Declaration, and Receiver’s Invoice: 1. Defendants object to the Receiver’s requested fee of $1,017,601.11 as unreasonable, unnecessary, and not authorized by the Receivership Order. Paragraph 53 of the Receivership Order provides that the Receiver is entitled “to a fee equal to 25% of all sales of assets that come into his actual, constructive, or legal possession, and all recoveries and credits against the judgment,” so long as the Rohrmoos Ventures elements have been satisfied and after notice and a hearing. See Receivership Order ¶ 53, Ex. 1. To the extent the Receiver collects the full amount of the Underlying Judgment, the Court may award the Receiver 33% of the collected funds. Here, the Receiver did not “collect” the Underlying Judgment by his actions. Rather, on June 11, 2025, Defendants’ lender, Legalist SPV III, LP (“Legalist”), voluntarily wired1 $3,083,639.75 to the Receiver to satisfy the Underlying Judgment. See Original Final Report ¶¶ 2, 6, Exhibit 3; Wire Transfer Confirmation and Judgment Calculation, Ex. 4. Of that amount, $873,849.02 was disbursed to Plaintiffs by the Receiver. The Receiver is thus not entitled to 33% of the Underlying Judgment. Instead, the Receiver is entitled to, at a maximum, 25% of what the Receiver disbursed to Plaintiffs, which is $218,462.30 and the amount agreed upon via settlement between Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5. Any fee in excess of that amount would be unreasonable under the circumstances. 1 The wire was authorized on June 10, 2025, and processed on June 11, 2025. See Wire Transfer Confirmation, Ex. 4. UnofficialCopyOfficeofMarilynBurgessDistrictClerk

26 Respectfully submitted, ADAMS & REESE, LLP By: /s/ Evan A. Moeller Evan A. Moeller State Bar No. 24051067 evan.moeller@arlaw.com Aaron G. McLeod State Bar No. 24100888 aaron.mcleod@arlaw.com LyondellBasell Tower 1221 McKinney St., Suite 4400 Houston, Texas 77010 Telephone: (713) 652-5151 Facsimile: (713) 652-5152 Attorneys for Cyberlux Corporation and Mark D. Schmidt CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing was served pursuant to the Texas Rules of Civil Procedure upon all parties on this 27th day of May, 2026. /s/ Evan A. Moeller Evan A. Moeller UnofficialCopyOfficeofMarilynBurgessDistrictClerk

26 Respectfully submitted, ADAMS & REESE, LLP By: /s/ Evan A. Moeller Evan A. Moeller State Bar No. 24051067 evan.moeller@arlaw.com Aaron G. McLeod State Bar No. 24100888 aaron.mcleod@arlaw.com LyondellBasell Tower 1221 McKinney St., Suite 4400 Houston, Texas 77010 Telephone: (713) 652-5151 Facsimile: (713) 652-5152 Attorneys for Cyberlux Corporation and Mark D. Schmidt CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing was served pursuant to the Texas Rules of Civil Procedure upon all parties on this 27th day of May, 2026. /s/ Evan A. Moeller Evan A. Moeller UnofficialCopyOfficeofMarilynBurgessDistrictClerk

24 17. Defendants object to paragraph 17 of the Berleth Declaration because the Receiver’s claimed fee exceeds the scope of the Receivership order and should be limited to, at most, $218,462.30, which is 25% of the amounts disbursed by the Receiver to Plaintiffs in this action and the amount agreed upon by Plaintiffs and Defendants. See Joint Notice of Settlement, Ex. 5. The expenses claimed are also unreasonable and were unnecessary because they were: (a) incurred after June 11, 2025, when the Receivership concluded by the Receiver’s own admission; (b) incurred for action taken or expenses paid that exceeded the scope of the receivership under the Receivership Order and TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3); and (c) were otherwise unreasonable and unnecessary. To the extent Exhibit 1 to the Berleth Declaration lists fees and expenses not cited in the declaration and addressed above, Defendants object to those fees and expenses, as follows: a. Defendants object to all fees and expenses incurred related to the Virginia Interpleader for the reasons set forth in Defendants’ General Objection No. 6, incorporated fully herein by reference. b. Defendants object to all fees and expenses incurred to pay employees because paying employees had nothing to do with the Receiver’s appointment as a post￾judgment receiver to collect the Underlying Judgment, as provided under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3). c. Defendants object to all fees and expenses incurred for security, a constable, locksmiths, and storage fees because the Receiver has failed to provide documentary evidence that those expenses were actually incurred and actually paid. d. Defendants object to all fees and expenses incurred for North Axis Advisory, to other consultants, and for staff meals, as those matters had nothing to do with the UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk

CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendants/Judgment Debtors. § § § § § § § § § § § IN THE DISTRICT COURT 129TH JUDICIAL DISTRICT OF HARRIS COUNTY, TEXAS DEFENDANTS’ OBJECTION TO RECEIVER’S FOURTH AND FINAL REPORT, FINAL ACCOUNTING, VERIFIED MOTION FOR DISBURSEMENT OF FUNDS AND MOTION TO TERMINATE RECEIVERSHIP Defendants and Former Judgment Debtors Cyberlux Corporation (“Cyberlux”) and Mark D. Schmidt (“Schmidt”) (collectively, “Defendants”) file this Objection to Receiver’s Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds and Motion to Terminate Receivership (“Objection”) and request a ruling on all objections herein. In support thereof, Defendants rely on the exhibits attached to this Objection and respectfully show unto the Court as follows: A. Introduction On May 22, 2025, the Court entered its Order Appointing Receiver (“Receivership Order,” attached as Exhibit 1) appointing Robert W. Berleth (“Receiver”) as a post-judgment receiver under TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3) to collect an underlying Virginia state-court judgment (“Underlying Judgment”) domesticated in this Court against Defendants. On May 7, 2026, the Receiver filed his Fourth and Final Report, Final Accounting, Verified Motion for Disbursement of Funds, and Motion to Terminate Receivership (“Final Report,” attached as Exhibit 2). Pursuant to paragraph 47 of the Receivership Order, Defendants hereby submit these 5/27/2026 7:59 PM Marilyn Burgess - District Clerk Harris County Envelope No. 115418415 By: Alyssa Henderson Filed: 5/27/2026 7:59 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk