The evidence/CXF-S-7DAFAF043463

Context source · CXF-S-7DAFAF043463

Atlantic Wave supplemental claim response — paid collection fees, stock judgment and priority asserted

Original sourceCounsel-signed supplemental interrogatory response, certificate March 24, 2026, exhibited April 15; claimant account with internal inconsistencies and missing cited instruments.
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DISTILLATES

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quotationattribution

Claimants state remaining Texas collection fees have been satisfied and revise their claim to omit those amounts.

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 5 of 8 PagelD# 2768 18. Berleth, as part of his duties as Receiver, evaluated the Stock Claim advanced by AWH and SC and compromised the figure with AWH and SC to a reduced liquidated figure of $6,000,000.00, plus attorney fees and cost. 19. Berleth and AWH entered a Settlement Agreement (the "Receiver Agreement) to be produced as Exhibit D. 20. The Receiver Agreement provided for entry of a Consent Judgment in CL 24-3910 which was entered by the Richmond Circuit Court on December 18, 2025, providing for judgment in the principal amount of $6,000,000, attorney's fees of $25,250.50 costs, and 6% interest from the date of judgment (the "Consent Order"). To be produced as Exhibit E. 21. The Consent Order ratified the Settlement Agreement as valid, and further ruled that the Order of Receivership had been properly recorded in the City of Richmond, without objection. 22. In Fairfax, HII, as garnishee had implead the sum of $1,444,543.11 based upon AWH's garnishment referred to herein at paragraph 9. 23. The Fairfax Court ordered the payment of $952,601.71 to AWH as principal and attorney's fees for the Virginia judgment but ruled that it had no jurisdiction to determine fees for collection activity outside of Virginia as provided by the Settlement Agreement. 24. Accordingly, the claim advanced by AWH and SC against the Disputed Funds are as follows: Remaining collection fees in enforcing the Settlement Agreement in Texas, California and at paragraph 19 of $938,884.88 Summary and Declarations produced as F. Reasonable Attorney's fees necessitated by this Interpleader pursuant to the Settlement Agreement at paragraph 19. The Consent Judgment principal amount $6,000,000 $25,250.50 attorney fees $352.92 costs Per diem interest in the amount of 986.30/day beginning February 5, 2026.
claimallegation

AWH and Secure Community present a joint supplemental response signed by Charles A. Gavin. AWH states it solely owns Secure Community and th

AWH and Secure Community present a joint supplemental response signed by Charles A. Gavin. AWH states it solely owns Secure Community and that they assert the same claims without independent double recovery. The certificate says March 24, 2026; the federal exhibit filing is April 15. No separate corporate oath or verification appears.

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EXHIBIT 8 Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 1 of 8 PageID# 2764
claimallegation

The response traces the claim to a 2021 acquisition, June 15, 2023 settlement, HII-related acceleration and all-assets security provision, a

The response traces the claim to a 2021 acquisition, June 15, 2023 settlement, HII-related acceleration and all-assets security provision, and a June 28, 2023 $1,572,500 judgment. It reports filings in North Carolina, Virginia and Texas on July 6, 2023, California October 20, 2023 and Nevada March 20, 2026. It asserts July 6, 2023 priority, rather than proving it through attached instruments.

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 2 of 8 PagelD# 2765 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, V. Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. SUPPLEMENTAL RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH") and in Response to Interpleader Defendant Cyberlux Corporation's (CYBLI) Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; 1. AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC (SCI). Accordingly, while each a party, AWH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide "Marketable Trading" CYBL stock. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreement") dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
claimallegation

Claimants state Berleth used receiver authority to compromise the stock claim at $6 million plus fees and costs, and report a December 18, 2

Claimants state Berleth used receiver authority to compromise the stock claim at $6 million plus fees and costs, and report a December 18, 2025 consent judgment and later reaffirmation. They describe consent-order validation of settlement and recording of receiver authority. Those orders and agreements are cited but not reproduced here.

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 4 of 8 PagelD# 2767 against CYBL as the judgment debtor and HII Mission Technologies Corp as Garnishee, as CL 2025-3413. 10. The Garnishment in Fairfax is referred to by HII as, in part, a basis for this Interpleader. See First Amended Complaint, paragraphs 50-55. 11. AWH and SC also domesticated the Virginia judgment (CL22-3882) in Harris County Texas where Cyberlux had a drone assembly facility. 12. Upon the domestication of the Virginia Judgment in Texas, Robert Berleth, Esquire was appointed as a Receiver for Cyberlux by Order entered in Harris County TX in Cause No. 202448085. The Order of Receivership is attached as Exhibit 11 to the First Amended Complaint. 13. The Order of Appointment granted broad powers to Berleth including the grant of power over all causes of action. See First Amended Complaint, Exhibit 11, Order, Paragraph 25(1). 14. Meanwhile, CYBL also failed to provide "Marketable Trading" stock as required, and as required by paragraph 2(e) of the Settlement Agreement (the "Stock Claim"). 15. CYBL stock, if it had been properly administered as required by the Settlement Agreement, would have had significant value on or before October 2021, and was additional consideration for the Settlement Agreement. 16. Paragraph 2(e) of the Settlement Agreement reserved the right in AWH and SC to re-file a Complaint to enforce its rights under the Stock Claim upon breach. 17. Based on the breach, A WH and SC filed a Complaint to enforce its rights under the Stock Claim in Richmond Circuit Court which is pending and is filed as CL 24-3910.
claimallegation

The response reports $1,444,543.11 deposited in Fairfax and $952,601.71 ordered paid to AWH as principal and Virginia fees. Its supplement s

The response reports $1,444,543.11 deposited in Fairfax and $952,601.71 ordered paid to AWH as principal and Virginia fees. Its supplement says remaining Texas collection fees have been satisfied and the Texas case non-suited, replacing the earlier collection-fee claim with $6 million principal, $25,250.50 attorney fees, $352.92 costs, $986.30 daily interest from February 5, 2026 and reasonable interpleader fees. The fixed components sum to $6,025,603.42.

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 5 of 8 PagelD# 2768 18. Berleth, as part of his duties as Receiver, evaluated the Stock Claim advanced by AWH and SC and compromised the figure with AWH and SC to a reduced liquidated figure of $6,000,000.00, plus attorney fees and cost. 19. Berleth and AWH entered a Settlement Agreement (the "Receiver Agreement) to be produced as Exhibit D. 20. The Receiver Agreement provided for entry of a Consent Judgment in CL 24-3910 which was entered by the Richmond Circuit Court on December 18, 2025, providing for judgment in the principal amount of $6,000,000, attorney's fees of $25,250.50 costs, and 6% interest from the date of judgment (the "Consent Order"). To be produced as Exhibit E. 21. The Consent Order ratified the Settlement Agreement as valid, and further ruled that the Order of Receivership had been properly recorded in the City of Richmond, without objection. 22. In Fairfax, HII, as garnishee had implead the sum of $1,444,543.11 based upon AWH's garnishment referred to herein at paragraph 9. 23. The Fairfax Court ordered the payment of $952,601.71 to AWH as principal and attorney's fees for the Virginia judgment but ruled that it had no jurisdiction to determine fees for collection activity outside of Virginia as provided by the Settlement Agreement. 24. Accordingly, the claim advanced by AWH and SC against the Disputed Funds are as follows: Remaining collection fees in enforcing the Settlement Agreement in Texas, California and at paragraph 19 of $938,884.88 Summary and Declarations produced as F. Reasonable Attorney's fees necessitated by this Interpleader pursuant to the Settlement Agreement at paragraph 19. The Consent Judgment principal amount $6,000,000 $25,250.50 attorney fees $352.92 costs Per diem interest in the amount of 986.30/day beginning February 5, 2026.
claimallegation

The earlier amount paragraph includes $938,884.88 collection fees; the later unsupplemented fee answer still includes $938,884 non-Virginia

The earlier amount paragraph includes $938,884.88 collection fees; the later unsupplemented fee answer still includes $938,884 non-Virginia fees even though the supplement removes remaining Texas collection fees. The source does not reconcile any California component or residual fee claim. Do not add the earlier figure to the revised principal automatically.

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 5 of 8 PagelD# 2768 18. Berleth, as part of his duties as Receiver, evaluated the Stock Claim advanced by AWH and SC and compromised the figure with AWH and SC to a reduced liquidated figure of $6,000,000.00, plus attorney fees and cost. 19. Berleth and AWH entered a Settlement Agreement (the "Receiver Agreement) to be produced as Exhibit D. 20. The Receiver Agreement provided for entry of a Consent Judgment in CL 24-3910 which was entered by the Richmond Circuit Court on December 18, 2025, providing for judgment in the principal amount of $6,000,000, attorney's fees of $25,250.50 costs, and 6% interest from the date of judgment (the "Consent Order"). To be produced as Exhibit E. 21. The Consent Order ratified the Settlement Agreement as valid, and further ruled that the Order of Receivership had been properly recorded in the City of Richmond, without objection. 22. In Fairfax, HII, as garnishee had implead the sum of $1,444,543.11 based upon AWH's garnishment referred to herein at paragraph 9. 23. The Fairfax Court ordered the payment of $952,601.71 to AWH as principal and attorney's fees for the Virginia judgment but ruled that it had no jurisdiction to determine fees for collection activity outside of Virginia as provided by the Settlement Agreement. 24. Accordingly, the claim advanced by AWH and SC against the Disputed Funds are as follows: Remaining collection fees in enforcing the Settlement Agreement in Texas, California and at paragraph 19 of $938,884.88 Summary and Declarations produced as F. Reasonable Attorney's fees necessitated by this Interpleader pursuant to the Settlement Agreement at paragraph 19. The Consent Judgment principal amount $6,000,000 $25,250.50 attorney fees $352.92 costs Per diem interest in the amount of 986.30/day beginning February 5, 2026.
claimallegation

Pages 5 and 7 date the stock consent judgment December 18, 2025, but page 6 visibly says liquidation December 18, 2023; the latter is preser

Pages 5 and 7 date the stock consent judgment December 18, 2025, but page 6 visibly says liquidation December 18, 2023; the latter is preserved as an internal date inconsistency. Page 5 reports 6% interest from judgment, while the revised schedule states $986.30 daily beginning February 5, 2026. That daily figure approximates 6% on $6 million over 365 days; the change in starting date requires the cited orders.

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 5 of 8 PagelD# 2768 18. Berleth, as part of his duties as Receiver, evaluated the Stock Claim advanced by AWH and SC and compromised the figure with AWH and SC to a reduced liquidated figure of $6,000,000.00, plus attorney fees and cost. 19. Berleth and AWH entered a Settlement Agreement (the "Receiver Agreement) to be produced as Exhibit D. 20. The Receiver Agreement provided for entry of a Consent Judgment in CL 24-3910 which was entered by the Richmond Circuit Court on December 18, 2025, providing for judgment in the principal amount of $6,000,000, attorney's fees of $25,250.50 costs, and 6% interest from the date of judgment (the "Consent Order"). To be produced as Exhibit E. 21. The Consent Order ratified the Settlement Agreement as valid, and further ruled that the Order of Receivership had been properly recorded in the City of Richmond, without objection. 22. In Fairfax, HII, as garnishee had implead the sum of $1,444,543.11 based upon AWH's garnishment referred to herein at paragraph 9. 23. The Fairfax Court ordered the payment of $952,601.71 to AWH as principal and attorney's fees for the Virginia judgment but ruled that it had no jurisdiction to determine fees for collection activity outside of Virginia as provided by the Settlement Agreement. 24. Accordingly, the claim advanced by AWH and SC against the Disputed Funds are as follows: Remaining collection fees in enforcing the Settlement Agreement in Texas, California and at paragraph 19 of $938,884.88 Summary and Declarations produced as F. Reasonable Attorney's fees necessitated by this Interpleader pursuant to the Settlement Agreement at paragraph 19. The Consent Judgment principal amount $6,000,000 $25,250.50 attorney fees $352.92 costs Per diem interest in the amount of 986.30/day beginning February 5, 2026.
claimallegation

The response attributes the original advance to 2021 intellectual-property transfer and security consideration to settlement performance. It

The response attributes the original advance to 2021 intellectual-property transfer and security consideration to settlement performance. It references Exhibits A–G, including the Nevada UCC, but this eight-page file ends at counsel’s signature/certificate without those attachments. Original litigation numbers also vary: CL22-3882 on page 2 versus CL22-2882 on page 3.

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 2 of 8 PagelD# 2765 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, V. Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. SUPPLEMENTAL RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH") and in Response to Interpleader Defendant Cyberlux Corporation's (CYBLI) Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; 1. AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC (SCI). Accordingly, while each a party, AWH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide "Marketable Trading" CYBL stock. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreement") dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
entityobservation

Atlantic Wave Holdings, LLC

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 2 of 8 PagelD# 2765 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, V. Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. SUPPLEMENTAL RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH") and in Response to Interpleader Defendant Cyberlux Corporation's (CYBLI) Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; 1. AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC (SCI). Accordingly, while each a party, AWH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide "Marketable Trading" CYBL stock. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreement") dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
entityobservation

Secure Community, LLC

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 2 of 8 PagelD# 2765 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, V. Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. SUPPLEMENTAL RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH") and in Response to Interpleader Defendant Cyberlux Corporation's (CYBLI) Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; 1. AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC (SCI). Accordingly, while each a party, AWH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide "Marketable Trading" CYBL stock. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreement") dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
entityobservation

Cyberlux Corporation

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 2 of 8 PagelD# 2765 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, V. Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. SUPPLEMENTAL RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH") and in Response to Interpleader Defendant Cyberlux Corporation's (CYBLI) Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; 1. AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC (SCI). Accordingly, while each a party, AWH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide "Marketable Trading" CYBL stock. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreement") dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
entityobservation

Robert Berleth

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 4 of 8 PagelD# 2767 against CYBL as the judgment debtor and HII Mission Technologies Corp as Garnishee, as CL 2025-3413. 10. The Garnishment in Fairfax is referred to by HII as, in part, a basis for this Interpleader. See First Amended Complaint, paragraphs 50-55. 11. AWH and SC also domesticated the Virginia judgment (CL22-3882) in Harris County Texas where Cyberlux had a drone assembly facility. 12. Upon the domestication of the Virginia Judgment in Texas, Robert Berleth, Esquire was appointed as a Receiver for Cyberlux by Order entered in Harris County TX in Cause No. 202448085. The Order of Receivership is attached as Exhibit 11 to the First Amended Complaint. 13. The Order of Appointment granted broad powers to Berleth including the grant of power over all causes of action. See First Amended Complaint, Exhibit 11, Order, Paragraph 25(1). 14. Meanwhile, CYBL also failed to provide "Marketable Trading" stock as required, and as required by paragraph 2(e) of the Settlement Agreement (the "Stock Claim"). 15. CYBL stock, if it had been properly administered as required by the Settlement Agreement, would have had significant value on or before October 2021, and was additional consideration for the Settlement Agreement. 16. Paragraph 2(e) of the Settlement Agreement reserved the right in AWH and SC to re-file a Complaint to enforce its rights under the Stock Claim upon breach. 17. Based on the breach, A WH and SC filed a Complaint to enforce its rights under the Stock Claim in Richmond Circuit Court which is pending and is filed as CL 24-3910.
entityobservation

Charles A. Gavin

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 8 of 8 PagelD# 2771 SUPPLEMENTAL RESPONSE: 1. See attached UCC lien filed March 20, 2026 in Nevada iI. See attached UCC lien filed March 20, 2026 in Nevada. Respectfully Submitted ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC BY: Charles A. Gavin, SB#3139 Gavin Law, PLC 14321 Winter Breeze Dr., Suite 136 Midlothian, Virginia 23113 (804) 606-7702 (804) 606-7704 Facsimile cgavin@gavinlawplc.com CERTIFICATE I hereby certify that I have electronically filed and sent a copy of the foregoing to counsel of record electronically through ECF this 24ại day of March, 2026. Charles A. Gavin, VSB#31391 Gavin Law, PLC 14321 Winter Breeze Dr., Suite 136 Midlothian, Virginia 23113 (804) 606-7702 (804) 606-7704 Facsimile cgavin@gavinlawplc.com
inferenceinference

The supplement materially narrows the debt presentation but leaves stale fee and date text in place. A usable claim ledger must preserve the

The supplement materially narrows the debt presentation but leaves stale fee and date text in place. A usable claim ledger must preserve the revised amount and flag the unreconciled residual passages rather than mechanically aggregate every number.

omissiongap

The cited settlement, UCC notices, judgments, fee declarations and reaffirmation order are absent from this file despite attachment referenc

The cited settlement, UCC notices, judgments, fee declarations and reaffirmation order are absent from this file despite attachment references.

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Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 2 of 8 PagelD# 2765 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TEHNOLOGIES CORP., Interpleader Plaintiff, V. Case Number: 3:25cv483 ATLANTIC WAVE HOLDINGS, LLC, et al., Interpleader Defendants/Claimants. SUPPLEMENTAL RESPONSE TO INTERROGATORY NUMBER 6 Comes now your Interpleader Defendants, Atlantic Wave Holdings, LLC and Secure Community, LLC, (jointly as "A WH") and in Response to Interpleader Defendant Cyberlux Corporation's (CYBLI) Interrogatory number 6 under the Joint Discovery Plan, hereby answers as follows: Interrogatory: 6(a). Explain the nature of your claim to any of the proceeds that are the subject of this interpleader, including an explanation of (a) the amount of the proceeds that you claim; 1. AWH is a Virginia limited liability company AWH is the sole owner of your Co Interpleader Defendant, Secure Community, LLC (SCI). Accordingly, while each a party, AWH and SC have the same claims and are not independent of one another seeking a double recovery. 2. AWH and SC initiated a claim against CYBL and Mark Schmidt, individually, in the Richmond Circuit Court as CL22-3882 based CYBL's breach of an acquisition agreement, requiring CYBL to 1) pay AWH certain monetary sums and 2) to provide "Marketable Trading" CYBL stock. Following extended litigation, the parties entered into a settlement agreement ("the Settlement Agreement") dated June 15, 2023, in which CYBL and Schmidt agreed inter alia to make a series of payments to AWH and SC and, notably, to bring the CYBL stock marketable by a certain date. The Settlement Agreement is produced as Exhibit A.
otherattribution

Complete supplied 8-page source reviewed at SHA-256 7dafaf04346327a5d0039536d975c34663ac1c59e1d907aff44c5bcb83452289. Source assertions, ori

Complete supplied 8-page source reviewed at SHA-256 7dafaf04346327a5d0039536d975c34663ac1c59e1d907aff44c5bcb83452289. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Exact version_96c32387c5c04ba7add48b9a77da3da8; SHA256 7dafaf04346327a5d0039536d975c34663ac1c59e1d907aff44c5bcb83452289. All eight pages read; revised figures, signature and date inconsistency visually checked. Source typos and original extraction preserved.

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EXHIBIT 8 Case 3:25-cv-00483-JAG Document 175-10 Filed 04/15/26 Page 1 of 8 PageID# 2764
questionquestion

Which consent and reaffirmation orders, payment records and fee reconciliation establish the remaining principal, interest start, residual f

Which consent and reaffirmation orders, payment records and fee reconciliation establish the remaining principal, interest start, residual fees and priority?

distillateobservation

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 response reports $1,444,543.11 deposited in Fairfax and $952,601.71 ordered paid to AWH as principal and Virginia fees. Its supplement says remaining Texas collection fees have been satisfied and the Texas case non-suited, replacing the earlier collection-fee claim with $6 million principal, $25,250.50 attorney fees, $352.92 costs, $986.30 daily interest from February 5, 2026 and reasonable interpleader fees. The fixed components sum to $6,025,603.42.supportsThe table labels confessed-judgment claimants secured October23,2025: WeShield$3,905,541.64, Roman$576,436.03, MAS$215,062.95 and Sinensky$310,097.79. It labels ANPC secured October24,2025 but prints malformed amount$3,087,878,86; intended decimal punctuation requires the primary claim. Atlantic Wave / Secured Community is labelled secured March20,2026 for$6,025,603.42; the source spelling Secured is retained rather than silently replacing it with Secure.

Revised fixed components equal table amount $6,025,603.42; table classification/date is separate from claimant July2023 priority assertion.

50%
Confidence 75%Link weight 50%
Claimants state Berleth used receiver authority to compromise the stock claim at $6 million plus fees and costs, and report a December 18, 2025 consent judgment and later reaffirmation. They describe consent-order validation of settlement and recording of receiver authority. Those orders and agreements are cited but not reproduced here.supportsThe possession and access provisions encompass nonexempt property, IP, records, accounts, contract rights and receivables. They permit access to premises, changing locks, reasonable destructive entry and property surveillance, and disabling or removing property. The same text disclaims specified maintenance, insurance, lease and tax duties unless specifically ordered. Authority to act does not establish an actual entry, seizure or ownership determination.

Order includes causes-of-action control; that text alone does not validate this particular compromise or later judgment.

50%
Confidence 75%Link weight 50%
The stock reservation permits plaintiffs at their discretion to file a new complaint if Pink Current status and removal of Caveat Emptor restriction are not achieved by December 31, 2023, without res judicata or collateral-estoppel defence. Plaintiffs must consider extension on credible evidence of delay without fault, with period at their reasonable discretion. This preserves a remedy; it is not a guaranteed stock valuation or automatic damages award.supportsClaimants state Berleth used receiver authority to compromise the stock claim at $6 million plus fees and costs, and report a December 18, 2025 consent judgment and later reaffirmation. They describe consent-order validation of settlement and recording of receiver authority. Those orders and agreements are cited but not reproduced here.

Stock-remedy reservation supplies underlying contractual context, not proof of later settlement authority or $6m damages.

50%
Confidence 75%Link weight 50%
Claimants state Berleth used receiver authority to compromise the stock claim at $6 million plus fees and costs, and report a December 18, 2025 consent judgment and later reaffirmation. They describe consent-order validation of settlement and recording of receiver authority. Those orders and agreements are cited but not reproduced here.supportsThe cited settlement, UCC notices, judgments, fee declarations and reaffirmation order are absent from this file despite attachment references.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Pages 5 and 7 date the stock consent judgment December 18, 2025, but page 6 visibly says liquidation December 18, 2023; the latter is preserved as an internal date inconsistency. Page 5 reports 6% interest from judgment, while the revised schedule states $986.30 daily beginning February 5, 2026. That daily figure approximates 6% on $6 million over 365 days; the change in starting date requires the cited orders.supportsWhat is the revised fixed claim before accruing interest and interpleader fees?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The response traces the claim to a 2021 acquisition, June 15, 2023 settlement, HII-related acceleration and all-assets security provision, and a June 28, 2023 $1,572,500 judgment. It reports filings in North Carolina, Virginia and Texas on July 6, 2023, California October 20, 2023 and Nevada March 20, 2026. It asserts July 6, 2023 priority, rather than proving it through attached instruments.supportsWhich consent and reaffirmation orders, payment records and fee reconciliation establish the remaining principal, interest start, residual fees and priority?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The earlier amount paragraph includes $938,884.88 collection fees; the later unsupplemented fee answer still includes $938,884 non-Virginia fees even though the supplement removes remaining Texas collection fees. The source does not reconcile any California component or residual fee claim. Do not add the earlier figure to the revised principal automatically.supportsWhich consent and reaffirmation orders, payment records and fee reconciliation establish the remaining principal, interest start, residual fees and priority?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Pages 5 and 7 date the stock consent judgment December 18, 2025, but page 6 visibly says liquidation December 18, 2023; the latter is preserved as an internal date inconsistency. Page 5 reports 6% interest from judgment, while the revised schedule states $986.30 daily beginning February 5, 2026. That daily figure approximates 6% on $6 million over 365 days; the change in starting date requires the cited orders.supportsWhich consent and reaffirmation orders, payment records and fee reconciliation establish the remaining principal, interest start, residual fees and priority?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The earlier amount paragraph includes $938,884.88 collection fees; the later unsupplemented fee answer still includes $938,884 non-Virginia fees even though the supplement removes remaining Texas collection fees. The source does not reconcile any California component or residual fee claim. Do not add the earlier figure to the revised principal automatically.supportsWhat is the revised fixed claim before accruing interest and interpleader fees?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The response reports $1,444,543.11 deposited in Fairfax and $952,601.71 ordered paid to AWH as principal and Virginia fees. Its supplement says remaining Texas collection fees have been satisfied and the Texas case non-suited, replacing the earlier collection-fee claim with $6 million principal, $25,250.50 attorney fees, $352.92 costs, $986.30 daily interest from February 5, 2026 and reasonable interpleader fees. The fixed components sum to $6,025,603.42.supportsThe supplement materially narrows the debt presentation but leaves stale fee and date text in place. A usable claim ledger must preserve the revised amount and flag the unreconciled residual passages rather than mechanically aggregate every number.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The response traces the claim to a 2021 acquisition, June 15, 2023 settlement, HII-related acceleration and all-assets security provision, and a June 28, 2023 $1,572,500 judgment. It reports filings in North Carolina, Virginia and Texas on July 6, 2023, California October 20, 2023 and Nevada March 20, 2026. It asserts July 6, 2023 priority, rather than proving it through attached instruments.supportsThe cited settlement, UCC notices, judgments, fee declarations and reaffirmation order are absent from this file despite attachment references.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Pages 5 and 7 date the stock consent judgment December 18, 2025, but page 6 visibly says liquidation December 18, 2023; the latter is preserved as an internal date inconsistency. Page 5 reports 6% interest from judgment, while the revised schedule states $986.30 daily beginning February 5, 2026. That daily figure approximates 6% on $6 million over 365 days; the change in starting date requires the cited orders.supportsThe supplement materially narrows the debt presentation but leaves stale fee and date text in place. A usable claim ledger must preserve the revised amount and flag the unreconciled residual passages rather than mechanically aggregate every number.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The response attributes the original advance to 2021 intellectual-property transfer and security consideration to settlement performance. It references Exhibits A–G, including the Nevada UCC, but this eight-page file ends at counsel’s signature/certificate without those attachments. Original litigation numbers also vary: CL22-3882 on page 2 versus CL22-2882 on page 3.supportsThe cited settlement, UCC notices, judgments, fee declarations and reaffirmation order are absent from this file despite attachment references.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The earlier amount paragraph includes $938,884.88 collection fees; the later unsupplemented fee answer still includes $938,884 non-Virginia fees even though the supplement removes remaining Texas collection fees. The source does not reconcile any California component or residual fee claim. Do not add the earlier figure to the revised principal automatically.supportsThe supplement materially narrows the debt presentation but leaves stale fee and date text in place. A usable claim ledger must preserve the revised amount and flag the unreconciled residual passages rather than mechanically aggregate every number.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Claimants state Berleth used receiver authority to compromise the stock claim at $6 million plus fees and costs, and report a December 18, 2025 consent judgment and later reaffirmation. They describe consent-order validation of settlement and recording of receiver authority. Those orders and agreements are cited but not reproduced here.supportsWhich consent and reaffirmation orders, payment records and fee reconciliation establish the remaining principal, interest start, residual fees and priority?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The response reports $1,444,543.11 deposited in Fairfax and $952,601.71 ordered paid to AWH as principal and Virginia fees. Its supplement says remaining Texas collection fees have been satisfied and the Texas case non-suited, replacing the earlier collection-fee claim with $6 million principal, $25,250.50 attorney fees, $352.92 costs, $986.30 daily interest from February 5, 2026 and reasonable interpleader fees. The fixed components sum to $6,025,603.42.supportsWhich consent and reaffirmation orders, payment records and fee reconciliation establish the remaining principal, interest start, residual fees and priority?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The response reports $1,444,543.11 deposited in Fairfax and $952,601.71 ordered paid to AWH as principal and Virginia fees. Its supplement says remaining Texas collection fees have been satisfied and the Texas case non-suited, replacing the earlier collection-fee claim with $6 million principal, $25,250.50 attorney fees, $352.92 costs, $986.30 daily interest from February 5, 2026 and reasonable interpleader fees. The fixed components sum to $6,025,603.42.supportsWhat is the revised fixed claim before accruing interest and interpleader fees?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%

WEIGH

Explained weighting

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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.