Context source · CXF-S-6F0C277FCD40
6f0c277fcd4062c17d7c…7 pages · 301 KBDISTILLATES
Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
The proposed priority route assumes the cited underpaid-worker/withheld-funds framework governs this claimed compensation and interpleader res; the brief has not independently established that predicate.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Plaintiff Case No. 3:25-cv-00483-JAG v. CYBERLUX CORP., et. al., Defendants. MEMORANDUM OF LAW IS SUPPORT OF MR. BILAL MAADARANI’S MOTION FOR SUMMARY JUDGMENT COMES NOW, Mr. Bilal Maadarani, through his undersigned attorneys, and in support of his Motion for Summary Judgment states as follows: Procedural Background On April 9, 2026, Mr. Maadarani, through his attorneys, filed a motion to intervene along with a proposed complaint. While that motion is pending, Mr. Maadarani understands the court has set an April 15, 2026 deadline to file motions for summary judgment. In order to comply with that scheduling order, Mr. Maadarani now files this motion for summary judgment as to count one (Judgment in Interpleader Pursuant to 28 U.S.C. § 1335 and 28 U.S.C. § 2361) and count two (Breach ofContract) of his proposed complaint in intervention (exhibit 1). Page 1 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 1 of 7 PageID# 2545
Statement ofMaterial Facts as to Which There is No Genuine Dispute I- Mr. Maadarani was an Employee ofCyberlux Mr. Maadarani was an employee ofCyberlux. Mr. Maadarani held an employee contract with Datron World Communications (“Datron”). Datron is a wholly owned subsidiary of Cyberlux and Cyberlux does business as Datron (exhibit 3). Mr. Maadarani had an @cyberlux.com email address (exhibit 4) and was listed as ChiefRevenue Officer for both entities. The CEO ofCyberlux, Mr. Mark Schmidt (“Mr. Schmidt”) signed a management certification on May 15, 2025, listing Mr. Maadarani as Cyberlux’s ChiefRevenue Officer (exhibit 2). Mr. Maadarani’s declaration further explains his role at Cyberlux (exhibit 3). There is no genuine dispute that Mr. Maadarani was employed by Cyberlux d/b/a Datron pursuant to an employment contract. IE Cyberlux owes Mr. Maadarani $1,062,576.98 in Employee Wages Mr. Maadarani was hired specifically to win the contract with HII that is the basis ofthis interpleader (exhibit 3). Mr. Maadarani’s efforts were paramount in not only securing the subcontract with HII but also fulfilling it by securing the deal with the Ukrainian government. For his efforts, he is entitled to compensation in the amount of $1,062,576.98. Both Mr. Maadarani’s sworn affidavit and emails from Mr. Schmidt demonstrate that Cyberlux acknowledged its debt to Mr. Maadarani. Mr. Maadarani pursued a breach of contract against Page 2 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 2 of 7 PageID# 2546
Bilal Maadarani’s memorandum is EDVA 3:25-cv-00483-JAG Document 171, filed 15 April 2026. It says his April 9 intervention motion remains pending and seeks summary judgment by the scheduling deadline on proposed complaint counts one, interpleader under §§1335/2361, and two, breach of contract. Filing this motion does not establish intervention was granted.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Plaintiff Case No. 3:25-cv-00483-JAG v. CYBERLUX CORP., et. al., Defendants. MEMORANDUM OF LAW IS SUPPORT OF MR. BILAL MAADARANI’S MOTION FOR SUMMARY JUDGMENT COMES NOW, Mr. Bilal Maadarani, through his undersigned attorneys, and in support of his Motion for Summary Judgment states as follows: Procedural Background On April 9, 2026, Mr. Maadarani, through his attorneys, filed a motion to intervene along with a proposed complaint. While that motion is pending, Mr. Maadarani understands the court has set an April 15, 2026 deadline to file motions for summary judgment. In order to comply with that scheduling order, Mr. Maadarani now files this motion for summary judgment as to count one (Judgment in Interpleader Pursuant to 28 U.S.C. § 1335 and 28 U.S.C. § 2361) and count two (Breach ofContract) of his proposed complaint in intervention (exhibit 1). Page 1 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 1 of 7 PageID# 2545
Maadarani asserts an employment contract with Datron World Communications, describes Datron as Cyberlux’s wholly owned subsidiary and Cyberlux doing business as Datron, and relies on a Cyberlux email address, chief-revenue-officer roles and a May 15, 2025 Schmidt management certification. These are his employment/entity-liability propositions; the cited exhibits are absent from this seven-page brief.
Statement ofMaterial Facts as to Which There is No Genuine Dispute I- Mr. Maadarani was an Employee ofCyberlux Mr. Maadarani was an employee ofCyberlux. Mr. Maadarani held an employee contract with Datron World Communications (“Datron”). Datron is a wholly owned subsidiary of Cyberlux and Cyberlux does business as Datron (exhibit 3). Mr. Maadarani had an @cyberlux.com email address (exhibit 4) and was listed as ChiefRevenue Officer for both entities. The CEO ofCyberlux, Mr. Mark Schmidt (“Mr. Schmidt”) signed a management certification on May 15, 2025, listing Mr. Maadarani as Cyberlux’s ChiefRevenue Officer (exhibit 2). Mr. Maadarani’s declaration further explains his role at Cyberlux (exhibit 3). There is no genuine dispute that Mr. Maadarani was employed by Cyberlux d/b/a Datron pursuant to an employment contract. IE Cyberlux owes Mr. Maadarani $1,062,576.98 in Employee Wages Mr. Maadarani was hired specifically to win the contract with HII that is the basis ofthis interpleader (exhibit 3). Mr. Maadarani’s efforts were paramount in not only securing the subcontract with HII but also fulfilling it by securing the deal with the Ukrainian government. For his efforts, he is entitled to compensation in the amount of $1,062,576.98. Both Mr. Maadarani’s sworn affidavit and emails from Mr. Schmidt demonstrate that Cyberlux acknowledged its debt to Mr. Maadarani. Mr. Maadarani pursued a breach of contract against Page 2 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 2 of 7 PageID# 2546
He claims he was hired to win the HII contract, played a paramount role in obtaining and fulfilling it through a Ukrainian-government deal, and is owed $1,062,576.98 as employee compensation. He characterises his affidavit and Schmidt emails as acknowledging the debt, without reproducing the calculation or those communications.
Statement ofMaterial Facts as to Which There is No Genuine Dispute I- Mr. Maadarani was an Employee ofCyberlux Mr. Maadarani was an employee ofCyberlux. Mr. Maadarani held an employee contract with Datron World Communications (“Datron”). Datron is a wholly owned subsidiary of Cyberlux and Cyberlux does business as Datron (exhibit 3). Mr. Maadarani had an @cyberlux.com email address (exhibit 4) and was listed as ChiefRevenue Officer for both entities. The CEO ofCyberlux, Mr. Mark Schmidt (“Mr. Schmidt”) signed a management certification on May 15, 2025, listing Mr. Maadarani as Cyberlux’s ChiefRevenue Officer (exhibit 2). Mr. Maadarani’s declaration further explains his role at Cyberlux (exhibit 3). There is no genuine dispute that Mr. Maadarani was employed by Cyberlux d/b/a Datron pursuant to an employment contract. IE Cyberlux owes Mr. Maadarani $1,062,576.98 in Employee Wages Mr. Maadarani was hired specifically to win the contract with HII that is the basis ofthis interpleader (exhibit 3). Mr. Maadarani’s efforts were paramount in not only securing the subcontract with HII but also fulfilling it by securing the deal with the Ukrainian government. For his efforts, he is entitled to compensation in the amount of $1,062,576.98. Both Mr. Maadarani’s sworn affidavit and emails from Mr. Schmidt demonstrate that Cyberlux acknowledged its debt to Mr. Maadarani. Mr. Maadarani pursued a breach of contract against Page 2 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 2 of 7 PageID# 2546
The brief says he obtained a clerk’s default against Datron in California after it failed to answer an employment-wage complaint. It argues that default admits well-pleaded allegations and applies that effect to Cyberlux d/b/a Datron. The source does not include the default, a final damages judgment or a determination binding Cyberlux as distinct from Datron.
Statement ofMaterial Facts as to Which There is No Genuine Dispute I- Mr. Maadarani was an Employee ofCyberlux Mr. Maadarani was an employee ofCyberlux. Mr. Maadarani held an employee contract with Datron World Communications (“Datron”). Datron is a wholly owned subsidiary of Cyberlux and Cyberlux does business as Datron (exhibit 3). Mr. Maadarani had an @cyberlux.com email address (exhibit 4) and was listed as ChiefRevenue Officer for both entities. The CEO ofCyberlux, Mr. Mark Schmidt (“Mr. Schmidt”) signed a management certification on May 15, 2025, listing Mr. Maadarani as Cyberlux’s ChiefRevenue Officer (exhibit 2). Mr. Maadarani’s declaration further explains his role at Cyberlux (exhibit 3). There is no genuine dispute that Mr. Maadarani was employed by Cyberlux d/b/a Datron pursuant to an employment contract. IE Cyberlux owes Mr. Maadarani $1,062,576.98 in Employee Wages Mr. Maadarani was hired specifically to win the contract with HII that is the basis ofthis interpleader (exhibit 3). Mr. Maadarani’s efforts were paramount in not only securing the subcontract with HII but also fulfilling it by securing the deal with the Ukrainian government. For his efforts, he is entitled to compensation in the amount of $1,062,576.98. Both Mr. Maadarani’s sworn affidavit and emails from Mr. Schmidt demonstrate that Cyberlux acknowledged its debt to Mr. Maadarani. Mr. Maadarani pursued a breach of contract against Page 2 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 2 of 7 PageID# 2546
Maadarani alleges Cyberlux specifically promised to pay him from the HII contract monies and that he detrimentally relied on that promise. He seeks those interpleaded funds rather than merely asserting an undifferentiated unsecured debt; the exact promise and reliance evidence are referenced, not supplied.
Datron in state court in California and has obtained a clerk’s default against Datron for its failure to respond to the complaint for employee wages under his employment contract. HI- Mr. Maadarani is Entitled to Recovery from the Interpleaded Funds In acknowledgment ofits debt to Mr. Maadarani, primarily for his services on the HII contract, Cyberlux explicitly promised to pay Mr. Maadarani out ofthe monies it would receive on that contract. Furthermore, Mr. Maadarani relied on those promises to his detriment (exhibit 3). Those specific monies from HII are the subject ofthis interpleader. Legal Argument I. Summary Judgment The court shall grant summary judgment ifthe movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter oflaw. Federal Rule of Civil Procedure 56(a). Summary judgment is proper “ifthe pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter oflaw.” Celotex Corp, v. Catrett, 477 U.S. 317, 322 (1986). The moving party bears the initial burden of stating the basis for its motion and identifying those portions ofthe record demonstrating the absence of genuine issues ofmaterial fact. Celotex, 477 U.S. at 323; Hickson Corp, v. N. Page 3 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 3 of 7 PageID# 2547
The memorandum invokes Rule 56 and cited cases and asserts no contrary evidence from Cyberlux or other parties regarding the amount or source of payment. That is the movant’s evidential position, not a verified absence across the litigation record. Page 4 literally describes the nonmoving party showing an absence of evidence to support the nonmoving party’s case; the source wording is not adopted as a correct statement of the rule.
Datron in state court in California and has obtained a clerk’s default against Datron for its failure to respond to the complaint for employee wages under his employment contract. HI- Mr. Maadarani is Entitled to Recovery from the Interpleaded Funds In acknowledgment ofits debt to Mr. Maadarani, primarily for his services on the HII contract, Cyberlux explicitly promised to pay Mr. Maadarani out ofthe monies it would receive on that contract. Furthermore, Mr. Maadarani relied on those promises to his detriment (exhibit 3). Those specific monies from HII are the subject ofthis interpleader. Legal Argument I. Summary Judgment The court shall grant summary judgment ifthe movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter oflaw. Federal Rule of Civil Procedure 56(a). Summary judgment is proper “ifthe pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter oflaw.” Celotex Corp, v. Catrett, 477 U.S. 317, 322 (1986). The moving party bears the initial burden of stating the basis for its motion and identifying those portions ofthe record demonstrating the absence of genuine issues ofmaterial fact. Celotex, 477 U.S. at 323; Hickson Corp, v. N. Page 3 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 3 of 7 PageID# 2547
For priority, the brief invokes Computer Data Systems v Automated Business Systems and 29 CFR 4.187(b)(4)/(b), quoting language about underpaid contract workers and withheld funds, including priority over assignees and tax levy. Whether this claimant, contract and interpleaded money satisfy that regulatory framework is argued rather than demonstrated or decided here.
employee wage debt because of Datron’s failure to respond to that complaint. Notably, pursuant to California law its “failure to answer has the same effect as an express admission ofthe matters well pleaded in the complaint.” Kim v. Westmoore Partners Inc., 201 Cal. App 4th 267 (2011). In other words, Cyberlux d/b/a Datron has admitted the allegations in Mr. Maadarani’s California complaint (exhibit 6). Mr. Maadarani is therefore entitled to summary judgment on count two (breach of contract). This court has authority to orderjudgment from the interpleaded funds by function of 28 U.S.C. § 1335 and 28 U.S.C. § 2361, as included in count one. II. Priority Mr. Maadarani should have priority over the other parties and interveners since “wages due workers underpaid on the contract have priority over any assignee ofthe contractor, including assignments made under the Assignment of Claims Act, 31. U.S.C. 203, 41 U.S.C. 15, to funds withheld under the contract, since an assignee can acquire no greater rights to withheld funds that the assignor has in the absence of an assignment.” Computer Data Systems, Inc, v. Automated Business Systems & Services, Inc., 1992 U.S. Dist. LEXIS 8047 (DCDC 1992) citing 29 CFR 4.187 (b)(4); see also, 29 CFR 4.187 (b) “Priority to withheld funds. The Comptroller General has afforded employee wage claims priority over an Internal Revenue Service levy for unpaid taxes.” Page 5 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 5 of 7 PageID# 2549
Maadarani requests $1,062,576.98 plus costs, reasonable attorney fees, pre- and post-judgment interest and employee-wage priority. Alternatively, if summary judgment is denied, he requests the amount remain in the registry pending trial. These are requested remedies, not an award, reservation order or disbursement.
Conclusion For these reasons, Mr. Maadarani moves this court for summary judgment as to count one and two of his complaint and to award him $1,062,576.98 plus costs, reasonable attorneys’ fees and pre and post judgment interest, and to assign priority in accordance with employee wage claims. Ifthe court determines not to grant summary judgment, movant humbly asks that this amount be kept in the court registry pending a trial. Dated: April 15,2026 Pinellas County, FL Respectfully Submitted, (pending Pro Hac Vice admission) FL Bar: 116366 611 S. Fort Harrison Ave., Suite 183 Clearwater, FL 33756 Telephone: 727-223-3005 Facsimile: 727-223-3578 Email: akbiklaw@outlook.com Keith A. Jaw^i, Esq. (VSB #101178) WOODS ROGERS VANDEVENTER BLACK PLC 120 Garrett Street, Suite 304 Charlottesville, VA 22902 Telephone: 434-220-6825 Facsimile: 434-220-5687 Keith.Jaworski@woodsrogers.com Page 6 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 6 of 7 PageID# 2550[Visual signature block: Mohamad A. Akbik, Esq., pending Pro Hac Vice admission, FL Bar 116366; signature present. Keith A. Jaworski, Esq. (VSB #101178); signature present.]
The dated submission bears signatures above Mohamad A. Akbik, marked pending pro hac vice admission, and Keith A. Jaworski of Woods Rogers Vandeventer Black. Jaworski certifies CM/ECF service on all counsel of record on 15 April 2026. The source does not establish later admission, response or disposition.
Conclusion For these reasons, Mr. Maadarani moves this court for summary judgment as to count one and two of his complaint and to award him $1,062,576.98 plus costs, reasonable attorneys’ fees and pre and post judgment interest, and to assign priority in accordance with employee wage claims. Ifthe court determines not to grant summary judgment, movant humbly asks that this amount be kept in the court registry pending a trial. Dated: April 15,2026 Pinellas County, FL Respectfully Submitted, (pending Pro Hac Vice admission) FL Bar: 116366 611 S. Fort Harrison Ave., Suite 183 Clearwater, FL 33756 Telephone: 727-223-3005 Facsimile: 727-223-3578 Email: akbiklaw@outlook.com Keith A. Jaw^i, Esq. (VSB #101178) WOODS ROGERS VANDEVENTER BLACK PLC 120 Garrett Street, Suite 304 Charlottesville, VA 22902 Telephone: 434-220-6825 Facsimile: 434-220-5687 Keith.Jaworski@woodsrogers.com Page 6 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 6 of 7 PageID# 2550[Visual signature block: Mohamad A. Akbik, Esq., pending Pro Hac Vice admission, FL Bar 116366; signature present. Keith A. Jaworski, Esq. (VSB #101178); signature present.]
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Plaintiff Case No. 3:25-cv-00483-JAG v. CYBERLUX CORP., et. al., Defendants. MEMORANDUM OF LAW IS SUPPORT OF MR. BILAL MAADARANI’S MOTION FOR SUMMARY JUDGMENT COMES NOW, Mr. Bilal Maadarani, through his undersigned attorneys, and in support of his Motion for Summary Judgment states as follows: Procedural Background On April 9, 2026, Mr. Maadarani, through his attorneys, filed a motion to intervene along with a proposed complaint. While that motion is pending, Mr. Maadarani understands the court has set an April 15, 2026 deadline to file motions for summary judgment. In order to comply with that scheduling order, Mr. Maadarani now files this motion for summary judgment as to count one (Judgment in Interpleader Pursuant to 28 U.S.C. § 1335 and 28 U.S.C. § 2361) and count two (Breach ofContract) of his proposed complaint in intervention (exhibit 1). Page 1 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 1 of 7 PageID# 2545
Statement ofMaterial Facts as to Which There is No Genuine Dispute I- Mr. Maadarani was an Employee ofCyberlux Mr. Maadarani was an employee ofCyberlux. Mr. Maadarani held an employee contract with Datron World Communications (“Datron”). Datron is a wholly owned subsidiary of Cyberlux and Cyberlux does business as Datron (exhibit 3). Mr. Maadarani had an @cyberlux.com email address (exhibit 4) and was listed as ChiefRevenue Officer for both entities. The CEO ofCyberlux, Mr. Mark Schmidt (“Mr. Schmidt”) signed a management certification on May 15, 2025, listing Mr. Maadarani as Cyberlux’s ChiefRevenue Officer (exhibit 2). Mr. Maadarani’s declaration further explains his role at Cyberlux (exhibit 3). There is no genuine dispute that Mr. Maadarani was employed by Cyberlux d/b/a Datron pursuant to an employment contract. IE Cyberlux owes Mr. Maadarani $1,062,576.98 in Employee Wages Mr. Maadarani was hired specifically to win the contract with HII that is the basis ofthis interpleader (exhibit 3). Mr. Maadarani’s efforts were paramount in not only securing the subcontract with HII but also fulfilling it by securing the deal with the Ukrainian government. For his efforts, he is entitled to compensation in the amount of $1,062,576.98. Both Mr. Maadarani’s sworn affidavit and emails from Mr. Schmidt demonstrate that Cyberlux acknowledged its debt to Mr. Maadarani. Mr. Maadarani pursued a breach of contract against Page 2 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 2 of 7 PageID# 2546
Statement ofMaterial Facts as to Which There is No Genuine Dispute I- Mr. Maadarani was an Employee ofCyberlux Mr. Maadarani was an employee ofCyberlux. Mr. Maadarani held an employee contract with Datron World Communications (“Datron”). Datron is a wholly owned subsidiary of Cyberlux and Cyberlux does business as Datron (exhibit 3). Mr. Maadarani had an @cyberlux.com email address (exhibit 4) and was listed as ChiefRevenue Officer for both entities. The CEO ofCyberlux, Mr. Mark Schmidt (“Mr. Schmidt”) signed a management certification on May 15, 2025, listing Mr. Maadarani as Cyberlux’s ChiefRevenue Officer (exhibit 2). Mr. Maadarani’s declaration further explains his role at Cyberlux (exhibit 3). There is no genuine dispute that Mr. Maadarani was employed by Cyberlux d/b/a Datron pursuant to an employment contract. IE Cyberlux owes Mr. Maadarani $1,062,576.98 in Employee Wages Mr. Maadarani was hired specifically to win the contract with HII that is the basis ofthis interpleader (exhibit 3). Mr. Maadarani’s efforts were paramount in not only securing the subcontract with HII but also fulfilling it by securing the deal with the Ukrainian government. For his efforts, he is entitled to compensation in the amount of $1,062,576.98. Both Mr. Maadarani’s sworn affidavit and emails from Mr. Schmidt demonstrate that Cyberlux acknowledged its debt to Mr. Maadarani. Mr. Maadarani pursued a breach of contract against Page 2 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 2 of 7 PageID# 2546
Conclusion For these reasons, Mr. Maadarani moves this court for summary judgment as to count one and two of his complaint and to award him $1,062,576.98 plus costs, reasonable attorneys’ fees and pre and post judgment interest, and to assign priority in accordance with employee wage claims. Ifthe court determines not to grant summary judgment, movant humbly asks that this amount be kept in the court registry pending a trial. Dated: April 15,2026 Pinellas County, FL Respectfully Submitted, (pending Pro Hac Vice admission) FL Bar: 116366 611 S. Fort Harrison Ave., Suite 183 Clearwater, FL 33756 Telephone: 727-223-3005 Facsimile: 727-223-3578 Email: akbiklaw@outlook.com Keith A. Jaw^i, Esq. (VSB #101178) WOODS ROGERS VANDEVENTER BLACK PLC 120 Garrett Street, Suite 304 Charlottesville, VA 22902 Telephone: 434-220-6825 Facsimile: 434-220-5687 Keith.Jaworski@woodsrogers.com Page 6 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 6 of 7 PageID# 2550[Visual signature block: Mohamad A. Akbik, Esq., pending Pro Hac Vice admission, FL Bar 116366; signature present. Keith A. Jaworski, Esq. (VSB #101178); signature present.]
CERTIFICATE OF SERVICE I hereby certify that on this 15th day of April, 2026, a true and correct copy ofthe foregoing was served via CM/ECF, upon all counsel ofrecord. Keith /^Jaworski, Esq. (VSB #101178) WOODS ROGERS VANDEVENTER BLACK PLC 120 Garrett Street, Suite 304 Charlottesville, VA 22902 Telephone: 434-220-6825 Facsimile: 434-220-5687 Keith.Jaworski@woodsrogers.com Page 7 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 7 of 7 PageID# 2551[Visual signature block: Keith A. Jaworski, Esq. (VSB #101178); signature present.]
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Plaintiff Case No. 3:25-cv-00483-JAG v. CYBERLUX CORP., et. al., Defendants. MEMORANDUM OF LAW IS SUPPORT OF MR. BILAL MAADARANI’S MOTION FOR SUMMARY JUDGMENT COMES NOW, Mr. Bilal Maadarani, through his undersigned attorneys, and in support of his Motion for Summary Judgment states as follows: Procedural Background On April 9, 2026, Mr. Maadarani, through his attorneys, filed a motion to intervene along with a proposed complaint. While that motion is pending, Mr. Maadarani understands the court has set an April 15, 2026 deadline to file motions for summary judgment. In order to comply with that scheduling order, Mr. Maadarani now files this motion for summary judgment as to count one (Judgment in Interpleader Pursuant to 28 U.S.C. § 1335 and 28 U.S.C. § 2361) and count two (Breach ofContract) of his proposed complaint in intervention (exhibit 1). Page 1 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 1 of 7 PageID# 2545
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Plaintiff Case No. 3:25-cv-00483-JAG v. CYBERLUX CORP., et. al., Defendants. MEMORANDUM OF LAW IS SUPPORT OF MR. BILAL MAADARANI’S MOTION FOR SUMMARY JUDGMENT COMES NOW, Mr. Bilal Maadarani, through his undersigned attorneys, and in support of his Motion for Summary Judgment states as follows: Procedural Background On April 9, 2026, Mr. Maadarani, through his attorneys, filed a motion to intervene along with a proposed complaint. While that motion is pending, Mr. Maadarani understands the court has set an April 15, 2026 deadline to file motions for summary judgment. In order to comply with that scheduling order, Mr. Maadarani now files this motion for summary judgment as to count one (Judgment in Interpleader Pursuant to 28 U.S.C. § 1335 and 28 U.S.C. § 2361) and count two (Breach ofContract) of his proposed complaint in intervention (exhibit 1). Page 1 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 1 of 7 PageID# 2545
The argument links Datron employment/default to Cyberlux liability and then to specific HII money. Each step needs its own evidence; common ownership or an email domain alone does not establish the whole chain in this source.
The wage-priority argument depends on coverage of the cited withheld-funds framework, not merely the label employee wages or the existence of interpleaded contract proceeds.
The alternative request to preserve money recognises that immediate judgment may not issue; it protects a claimed recovery route without proving present entitlement.
Complete supplied 7-page source reviewed at SHA-256 6f0c277fcd4062c17d7cc99cc787c90054773107be87ddda86a38cad504e9d20. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. All seven native-text pages fully read. Own pages 1,2,5,6,7 visually checked for pending-intervention posture, entity theory, quoted priority, requested remedies, signatures and service. Counsel names recovered from visible signature blocks; no absent exhibit treated as read.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION HII MISSION TECHNOLOGIES CORP., Plaintiff Case No. 3:25-cv-00483-JAG v. CYBERLUX CORP., et. al., Defendants. MEMORANDUM OF LAW IS SUPPORT OF MR. BILAL MAADARANI’S MOTION FOR SUMMARY JUDGMENT COMES NOW, Mr. Bilal Maadarani, through his undersigned attorneys, and in support of his Motion for Summary Judgment states as follows: Procedural Background On April 9, 2026, Mr. Maadarani, through his attorneys, filed a motion to intervene along with a proposed complaint. While that motion is pending, Mr. Maadarani understands the court has set an April 15, 2026 deadline to file motions for summary judgment. In order to comply with that scheduling order, Mr. Maadarani now files this motion for summary judgment as to count one (Judgment in Interpleader Pursuant to 28 U.S.C. § 1335 and 28 U.S.C. § 2361) and count two (Breach ofContract) of his proposed complaint in intervention (exhibit 1). Page 1 of 7 Case 3:25-cv-00483-JAG Document 171 Filed 04/15/26 Page 1 of 7 PageID# 2545
Do the claimant’s work, contract and specific fund meet the invoked wage-priority provisions, and what competing evidence addresses those predicates?
CONNECT
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WEIGH
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