The evidence/CXF-S-82382B29595B

Context source · CXF-S-82382B29595B

February 26 joint settlement motion — signed parties, unsigned proposed receivership discharge

Original sourceParty-signed settlement request and attached unsigned proposed order; no executed judicial discharge or proved payment in this source.
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SHA-256 82382b29595b40b8f12c…10 pages · 444 KB

DISTILLATES

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quotationattribution

Defendants expressly relinquish challenges to the specified $873,849.02 fee disbursement within the stated legal limit.

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3 in two pending Virginia actions: (1) Case No. CL24-3910, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, pending in the Circuit Court of the City of Richmond, State of Virginia (“Stock Case”); and (2) Case No. 3:25-cv-00483, HII Mission Technologies Corp. v. Cyberlux Corp., et al., pending in the United States District Court for the Eastern District of Virginia, Richmond Division, (“Interpleader Action”). Under Texas Civil Practice and Remedies Code Section 31.002(e), Plaintiffs, as the judgment-creditors, are “entitled to recover reasonable costs, including attorney’s fees” for their efforts to obtain turnover relief in this Texas enforcement action. The Parties stipulate that Plaintiffs’ reasonable costs and attorneys’ fees recoverable under Section 31.002(e) are $873,849.02.1 The Receivership Order provides that “Receiver’s fees and expenses are considered costs of court” and the fee is “equal to 25% of … all recoveries and credits against the [Underlying Judgment].” The Parties stipulate that Receiver’s fees and expenses are $218,462.30—that is, 25% of the $873,849.02 recovery against the Underlying Judgment to Plaintiffs. The Parties therefore respectfully ask that this Court: (1) order Receiver to disburse $873,849.02 to Plaintiffs within two business days of entry of this Court’s order; (2) permit Receiver to retain $218,462.30, representing Receiver’s recoverable fees and expenses; and (3) release $1,991,328.43 to Legalist SPV III, LP within two business days of entry of the Court’s order. Furthermore, the Parties ask the Court to order Receiver to provide notice 1 Defendants waive and forever relinquish any right for reconsideration, appeal, or bankruptcy relief on the disbursement of $873,849.02 in attorneys’ fees and costs to Plaintiffs, as allowed to the fullest extent by law. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 4 of 10 PageID# 2853
claimallegation

Federal Exhibit17 filed April15,2026 as EDVA175-19 contains a February26 joint motion and proposed order in Texas cause2024-48085. Pages6/10

Federal Exhibit17 filed April15,2026 as EDVA175-19 contains a February26 joint motion and proposed order in Texas cause2024-48085. Pages6/10 display William Welter signatures for both creditors, Mark D. Schmidt signatures for Cyberlux and himself, James Sadigh and Elizabeth G. Myers signatures. Page6 bears Alexander J. Pennetti’s /s/ service certification for February25, one day before the motion’s printed date. The proposed judge signature line on page9 is blank.

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EXHIBIT 17 Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 1 of 10 PageID# 2850
claimallegation

The motion recounts a June23,2023 Virginia $1,572,500 principal judgment, partial payments and May22,2025 Texas receivership. It says Novemb

The motion recounts a June23,2023 Virginia $1,572,500 principal judgment, partial payments and May22,2025 Texas receivership. It says November2025 Virginia payment was $1,140,004.66 but its listed components $952,601.71 and $187,399.95 total $1,140,001.66, a $3 discrepancy. The source leaves Texas enforcement costs outstanding.

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT OF and SECURE COMMUNITY, LLC, § § Plaintiffs/Judgment-Creditor § § v. § HARRIS COUNTY, TEXAS § CYBERLUX CORPORATION and § MARK D. SCHMIDT, Individually, § § Defendant/Judgment Debtors. § 129TH JUDICIAL DISTRICT PLAINTIFFS’ AND DEFENDANTS’ JOINT NOTICE OF SETTLEMENT AND JOINT MOTION FOR RELEASE OF FUNDS, FOR SATISFACTION OF JUDGMENT, AND TO DISSOLVE RECEIVERSHIP COME NOW, Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC (“ Plaintiffs”) and Cyberlux Corporation and Mark D. Schmidt (“Defendants”) (collectively, the “Parties”), and file this Joint Notice of Settlement and Joint Motion for Release of Funds, for Satisfaction of Judgment, and to Dissolve Receivership. In support thereof, the Parties state: I. INTRODUCTION 1. On June 23, 2023, a Virginia court presiding over Case No. CL22-3882-4, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, in the Circuit Court of the City of Richmond, State of Virginia, entered a judgment (“Underlying Judgment”) in favor of Plaintiffs and against Defendants, in the principal sum of $1,572,500.00. 2. Following entry of the Underlying Judgment, Defendants made certain partial payments towards the balance due on the Underlying Judgment. 3. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court, initiating this enforcement and collection action. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 2 of 10 PageID# 2851
claimallegation

The parties expressly resolve remaining disputes in this Texas enforcement action only. They exclude the Virginia Stock Case CL24-3910 and f

The parties expressly resolve remaining disputes in this Texas enforcement action only. They exclude the Virginia Stock Case CL24-3910 and federal interpleader3:25-cv-00483 from the joint motion’s resolution. Its settlement language is not an omnibus resolution of those separate disputes.

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2 4. On May 22, 2025, pursuant to Section 31.002(b)(3) of the Texas Civil Practice & Remedies Code, this Court appointed Robert W. Berleth (“Receiver”) “to take possession of [Cyberlux] property, sell it, and pay the proceeds to [Plaintiffs] to the extent required to satisfy the judgment.” The Receivership Order entitled Plaintiffs “to collect post-judgment attorneys’ fees under Tex. Civ. Prac. & Rem. Code § 31.002(e).” 5. On November 14, 2025, a Virginia court presiding over Case No. CL-2025- 3413, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation, in the Circuit Court of Fairfax County, State of Virginia, entered a final order (“Final Order”) which, among other things, ordered the clerk of that court to disburse (1) $952,601.71, representing the principal balance owed on the Underlying Judgment; and (2) $187,399.95, representing Plaintiffs’ reasonable attorneys’ fees and costs incurred in the Virginia state court proceedings only. On November 18, 2025, $1,140,004.66 was disbursed to Plaintiffs pursuant to the Final Order. The Final Order did not determine the reasonable post-judgment attorneys’ fees and costs incurred by Plaintiffs in the enforcement and collection of the Underlying Judgment in Texas. 6. On January 6, 2026, Plaintiffs filed their updated Second Amended Motion for Distribution of Funds in this action seeking recovery of $873,849.02, representing the updated reasonable attorneys’ fees and costs incurred by Plaintiffs in the enforcement and collection of the Underlying Judgment in Texas. Plaintiffs therein requested that the $873,849.02 be paid from the $3,083,639.75 in non-exempt funds currently held by Receiver under the Receivership Order. II. ARGUMENT This joint motion resolves all remaining disputes between Plaintiffs and Defendants in this Texas enforcement action. This joint motion does not resolve the Parties’ disputes Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 3 of 10 PageID# 2852
claimallegation

The proposed allocation of $3,083,639.75 is $873,849.02 to the two judgment creditors, $218,462.30 to the receiver and $1,991,328.43 to Lega

The proposed allocation of $3,083,639.75 is $873,849.02 to the two judgment creditors, $218,462.30 to the receiver and $1,991,328.43 to Legalist. These three amounts sum exactly. The receiver figure is called25% of $873,849.02, whose exact quarter is $218,462.255; the displayed fee is4.5cents higher. The source does not explain this small percentage rounding difference.

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3 in two pending Virginia actions: (1) Case No. CL24-3910, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, pending in the Circuit Court of the City of Richmond, State of Virginia (“Stock Case”); and (2) Case No. 3:25-cv-00483, HII Mission Technologies Corp. v. Cyberlux Corp., et al., pending in the United States District Court for the Eastern District of Virginia, Richmond Division, (“Interpleader Action”). Under Texas Civil Practice and Remedies Code Section 31.002(e), Plaintiffs, as the judgment-creditors, are “entitled to recover reasonable costs, including attorney’s fees” for their efforts to obtain turnover relief in this Texas enforcement action. The Parties stipulate that Plaintiffs’ reasonable costs and attorneys’ fees recoverable under Section 31.002(e) are $873,849.02.1 The Receivership Order provides that “Receiver’s fees and expenses are considered costs of court” and the fee is “equal to 25% of … all recoveries and credits against the [Underlying Judgment].” The Parties stipulate that Receiver’s fees and expenses are $218,462.30—that is, 25% of the $873,849.02 recovery against the Underlying Judgment to Plaintiffs. The Parties therefore respectfully ask that this Court: (1) order Receiver to disburse $873,849.02 to Plaintiffs within two business days of entry of this Court’s order; (2) permit Receiver to retain $218,462.30, representing Receiver’s recoverable fees and expenses; and (3) release $1,991,328.43 to Legalist SPV III, LP within two business days of entry of the Court’s order. Furthermore, the Parties ask the Court to order Receiver to provide notice 1 Defendants waive and forever relinquish any right for reconsideration, appeal, or bankruptcy relief on the disbursement of $873,849.02 in attorneys’ fees and costs to Plaintiffs, as allowed to the fullest extent by law. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 4 of 10 PageID# 2853
claimallegation

The parties ask for creditor and Legalist disbursement within two business days of a court order, together with documentation. Satisfaction

The parties ask for creditor and Legalist disbursement within two business days of a court order, together with documentation. Satisfaction and closure are requested upon the creditors’ receipt of $873,849.02; dismissal of Texas actions and termination of the receivership are tied to satisfaction. These requests and conditions do not establish completed transfers or an effective discharge.

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3 in two pending Virginia actions: (1) Case No. CL24-3910, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, pending in the Circuit Court of the City of Richmond, State of Virginia (“Stock Case”); and (2) Case No. 3:25-cv-00483, HII Mission Technologies Corp. v. Cyberlux Corp., et al., pending in the United States District Court for the Eastern District of Virginia, Richmond Division, (“Interpleader Action”). Under Texas Civil Practice and Remedies Code Section 31.002(e), Plaintiffs, as the judgment-creditors, are “entitled to recover reasonable costs, including attorney’s fees” for their efforts to obtain turnover relief in this Texas enforcement action. The Parties stipulate that Plaintiffs’ reasonable costs and attorneys’ fees recoverable under Section 31.002(e) are $873,849.02.1 The Receivership Order provides that “Receiver’s fees and expenses are considered costs of court” and the fee is “equal to 25% of … all recoveries and credits against the [Underlying Judgment].” The Parties stipulate that Receiver’s fees and expenses are $218,462.30—that is, 25% of the $873,849.02 recovery against the Underlying Judgment to Plaintiffs. The Parties therefore respectfully ask that this Court: (1) order Receiver to disburse $873,849.02 to Plaintiffs within two business days of entry of this Court’s order; (2) permit Receiver to retain $218,462.30, representing Receiver’s recoverable fees and expenses; and (3) release $1,991,328.43 to Legalist SPV III, LP within two business days of entry of the Court’s order. Furthermore, the Parties ask the Court to order Receiver to provide notice 1 Defendants waive and forever relinquish any right for reconsideration, appeal, or bankruptcy relief on the disbursement of $873,849.02 in attorneys’ fees and costs to Plaintiffs, as allowed to the fullest extent by law. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 4 of 10 PageID# 2853
claimallegation

Footnote1 states defendants waive and forever relinquish reconsideration, appeal or bankruptcy relief on the $873,849.02 attorneys’ fee/cost

Footnote1 states defendants waive and forever relinquish reconsideration, appeal or bankruptcy relief on the $873,849.02 attorneys’ fee/cost disbursement to plaintiffs, to the fullest extent allowed by law. This is a narrowly stated waiver in the signed party agreement, not a ruling that every possible waiver is enforceable or that other disputes are released.

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3 in two pending Virginia actions: (1) Case No. CL24-3910, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, pending in the Circuit Court of the City of Richmond, State of Virginia (“Stock Case”); and (2) Case No. 3:25-cv-00483, HII Mission Technologies Corp. v. Cyberlux Corp., et al., pending in the United States District Court for the Eastern District of Virginia, Richmond Division, (“Interpleader Action”). Under Texas Civil Practice and Remedies Code Section 31.002(e), Plaintiffs, as the judgment-creditors, are “entitled to recover reasonable costs, including attorney’s fees” for their efforts to obtain turnover relief in this Texas enforcement action. The Parties stipulate that Plaintiffs’ reasonable costs and attorneys’ fees recoverable under Section 31.002(e) are $873,849.02.1 The Receivership Order provides that “Receiver’s fees and expenses are considered costs of court” and the fee is “equal to 25% of … all recoveries and credits against the [Underlying Judgment].” The Parties stipulate that Receiver’s fees and expenses are $218,462.30—that is, 25% of the $873,849.02 recovery against the Underlying Judgment to Plaintiffs. The Parties therefore respectfully ask that this Court: (1) order Receiver to disburse $873,849.02 to Plaintiffs within two business days of entry of this Court’s order; (2) permit Receiver to retain $218,462.30, representing Receiver’s recoverable fees and expenses; and (3) release $1,991,328.43 to Legalist SPV III, LP within two business days of entry of the Court’s order. Furthermore, the Parties ask the Court to order Receiver to provide notice 1 Defendants waive and forever relinquish any right for reconsideration, appeal, or bankruptcy relief on the disbursement of $873,849.02 in attorneys’ fees and costs to Plaintiffs, as allowed to the fullest extent by law. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 4 of 10 PageID# 2853
claimallegation

The unsigned proposed order would find the fees recoverable, direct the three-way distribution, discharge the receiver and terminate the rec

The unsigned proposed order would find the fees recoverable, direct the three-way distribution, discharge the receiver and terminate the receivership. It also would stay other pending matters until reasonableness of receiver fees and expenses is determined, despite earlier stated findings allowing those fees. Both pieces of proposed text remain visible; neither is promoted to an issued order.

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT OF and SECURE COMMUNITY, LLC, § § Plaintiffs/Judgment-Creditor § § v. § HARRIS COUNTY, TEXAS § CYBERLUX CORPORATION and § MARK D. SCHMIDT, Individually, § § Defendant/Judgment Debtors. § 129TH JUDICIAL DISTRICT ORDER ON JOINT MOTION FOR RELEASE OF FUNDS, FOR SATISFACTION OF JUDGMENT, AND TO DISSOLVE RECEIVERSHIP BEFORE THE COURT IS the Joint Motion for Release of Funds, for Satisfaction of Judgment, and to Dissolve Receivership filed by Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC (“Plaintiffs”) and Cyberlux Corporation and Mark D. Schmidt (“Defendants”) (collectively, the “Parties”). UPON CONSIDERATION of the pleadings, evidence, argument of counsel, consent of the Parties, and for good cause shown, the Court: FINDS THAT the disbursement of funds by the Circuit Court of Fairfax County, Virginia under the terms of the Final Order in Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation, Case No. CL-2025-3413 was made towards satisfaction of the judgment underlying this enforcement action (“Underlying Judgment”). FINDS THAT Plaintiffs are entitled to $873,849.02, which represents the reasonable costs and attorneys’ fees to which Plaintiffs are entitled, including under Texas Civil Practice and Remedies Code § 31.002(e), for their efforts to enforce the Underlying Judgment. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 7 of 10 PageID# 2856
claimallegation

Signature images identify assent to form and substance, including corporate and individual Schmidt roles. The repeated DocuSign envelope lab

Signature images identify assent to form and substance, including corporate and individual Schmidt roles. The repeated DocuSign envelope label and signature appearances do not independently verify certificate timing or cryptographic validity; no completion certificate accompanies this file.

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5 AGREED AS TO FORM AND SUBSTANCE: ________________________________ Atlantic Wave Holdings, LLC ________________________________ Secure Community, LLC James Sadigh Texas Bar No. 24129140 jamessadigh@aol.com JAMES K. SADIGH, ATTORNEY AT LAW 9777 Wilshire Blvd, Ste 400 Beverly Hills, CA 90212 Tel. (310) 747-5919 David A. Walton Texas Bar No. 24042120 dwalton@bellnunnally.com BELL NUNNALLY & MARTIN LLP 2323 Ross Avenue, Suite 1900 Dallas, TX 75201 Tel. (214) 740-1445 Fax (214) 740-5745 Attorneys for Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC ________________________________ Cyberlux Corporation ________________________________ Mark D. Schmidt Elizabeth G. Myers Texas Bar No. 24047767 emyers@thompsoncoburn.com Douglas S. Lang Texas Bar No. 11895500 dlang@thompsoncoburn.com Alexander J. Pennetti Texas Bar No. 24110208 apennetti@thompsoncoburn.com THOMPSON COBURN LLP 2100 Ross Avenue, Suite 3200 Dallas, TX 75201 Tel. (972) 629-7100 Fax (972) 629-7171 Attorneys for Defendants Cyberlux Corporation and Mark D. Schmidt CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing instrument was served on all counsel pursuant to the Texas Rules of Civil Procedure on February 25, 2026. /s/ Alexander J. Pennetti Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 6 of 10 PageID# 2855 [Visual signature transcription: William Welter signs for Atlantic Wave Holdings, LLC and Secure Community, LLC; Mark D. Schmidt signs for Cyberlux Corporation and individually; James Sadigh and Elizabeth G. Myers signatures appear; /s/ Alexander J. Pennetti appears on service certificate.]
otherattribution

Parties agree promptly to dismiss Texas actions involving them upon satisfaction of the underlying judgment; this does not extend to express

Parties agree promptly to dismiss Texas actions involving them upon satisfaction of the underlying judgment; this does not extend to expressly excluded Virginia disputes.

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3 in two pending Virginia actions: (1) Case No. CL24-3910, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, pending in the Circuit Court of the City of Richmond, State of Virginia (“Stock Case”); and (2) Case No. 3:25-cv-00483, HII Mission Technologies Corp. v. Cyberlux Corp., et al., pending in the United States District Court for the Eastern District of Virginia, Richmond Division, (“Interpleader Action”). Under Texas Civil Practice and Remedies Code Section 31.002(e), Plaintiffs, as the judgment-creditors, are “entitled to recover reasonable costs, including attorney’s fees” for their efforts to obtain turnover relief in this Texas enforcement action. The Parties stipulate that Plaintiffs’ reasonable costs and attorneys’ fees recoverable under Section 31.002(e) are $873,849.02.1 The Receivership Order provides that “Receiver’s fees and expenses are considered costs of court” and the fee is “equal to 25% of … all recoveries and credits against the [Underlying Judgment].” The Parties stipulate that Receiver’s fees and expenses are $218,462.30—that is, 25% of the $873,849.02 recovery against the Underlying Judgment to Plaintiffs. The Parties therefore respectfully ask that this Court: (1) order Receiver to disburse $873,849.02 to Plaintiffs within two business days of entry of this Court’s order; (2) permit Receiver to retain $218,462.30, representing Receiver’s recoverable fees and expenses; and (3) release $1,991,328.43 to Legalist SPV III, LP within two business days of entry of the Court’s order. Furthermore, the Parties ask the Court to order Receiver to provide notice 1 Defendants waive and forever relinquish any right for reconsideration, appeal, or bankruptcy relief on the disbursement of $873,849.02 in attorneys’ fees and costs to Plaintiffs, as allowed to the fullest extent by law. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 4 of 10 PageID# 2853
entityobservation

ATLANTIC WAVE HOLDINGS, LLC

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT OF and SECURE COMMUNITY, LLC, § § Plaintiffs/Judgment-Creditor § § v. § HARRIS COUNTY, TEXAS § CYBERLUX CORPORATION and § MARK D. SCHMIDT, Individually, § § Defendant/Judgment Debtors. § 129TH JUDICIAL DISTRICT PLAINTIFFS’ AND DEFENDANTS’ JOINT NOTICE OF SETTLEMENT AND JOINT MOTION FOR RELEASE OF FUNDS, FOR SATISFACTION OF JUDGMENT, AND TO DISSOLVE RECEIVERSHIP COME NOW, Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC (“ Plaintiffs”) and Cyberlux Corporation and Mark D. Schmidt (“Defendants”) (collectively, the “Parties”), and file this Joint Notice of Settlement and Joint Motion for Release of Funds, for Satisfaction of Judgment, and to Dissolve Receivership. In support thereof, the Parties state: I. INTRODUCTION 1. On June 23, 2023, a Virginia court presiding over Case No. CL22-3882-4, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, in the Circuit Court of the City of Richmond, State of Virginia, entered a judgment (“Underlying Judgment”) in favor of Plaintiffs and against Defendants, in the principal sum of $1,572,500.00. 2. Following entry of the Underlying Judgment, Defendants made certain partial payments towards the balance due on the Underlying Judgment. 3. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court, initiating this enforcement and collection action. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 2 of 10 PageID# 2851
entityobservation

SECURE COMMUNITY, LLC

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT OF and SECURE COMMUNITY, LLC, § § Plaintiffs/Judgment-Creditor § § v. § HARRIS COUNTY, TEXAS § CYBERLUX CORPORATION and § MARK D. SCHMIDT, Individually, § § Defendant/Judgment Debtors. § 129TH JUDICIAL DISTRICT PLAINTIFFS’ AND DEFENDANTS’ JOINT NOTICE OF SETTLEMENT AND JOINT MOTION FOR RELEASE OF FUNDS, FOR SATISFACTION OF JUDGMENT, AND TO DISSOLVE RECEIVERSHIP COME NOW, Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC (“ Plaintiffs”) and Cyberlux Corporation and Mark D. Schmidt (“Defendants”) (collectively, the “Parties”), and file this Joint Notice of Settlement and Joint Motion for Release of Funds, for Satisfaction of Judgment, and to Dissolve Receivership. In support thereof, the Parties state: I. INTRODUCTION 1. On June 23, 2023, a Virginia court presiding over Case No. CL22-3882-4, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, in the Circuit Court of the City of Richmond, State of Virginia, entered a judgment (“Underlying Judgment”) in favor of Plaintiffs and against Defendants, in the principal sum of $1,572,500.00. 2. Following entry of the Underlying Judgment, Defendants made certain partial payments towards the balance due on the Underlying Judgment. 3. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court, initiating this enforcement and collection action. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 2 of 10 PageID# 2851
entityobservation

CYBERLUX CORPORATION

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT OF and SECURE COMMUNITY, LLC, § § Plaintiffs/Judgment-Creditor § § v. § HARRIS COUNTY, TEXAS § CYBERLUX CORPORATION and § MARK D. SCHMIDT, Individually, § § Defendant/Judgment Debtors. § 129TH JUDICIAL DISTRICT PLAINTIFFS’ AND DEFENDANTS’ JOINT NOTICE OF SETTLEMENT AND JOINT MOTION FOR RELEASE OF FUNDS, FOR SATISFACTION OF JUDGMENT, AND TO DISSOLVE RECEIVERSHIP COME NOW, Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC (“ Plaintiffs”) and Cyberlux Corporation and Mark D. Schmidt (“Defendants”) (collectively, the “Parties”), and file this Joint Notice of Settlement and Joint Motion for Release of Funds, for Satisfaction of Judgment, and to Dissolve Receivership. In support thereof, the Parties state: I. INTRODUCTION 1. On June 23, 2023, a Virginia court presiding over Case No. CL22-3882-4, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, in the Circuit Court of the City of Richmond, State of Virginia, entered a judgment (“Underlying Judgment”) in favor of Plaintiffs and against Defendants, in the principal sum of $1,572,500.00. 2. Following entry of the Underlying Judgment, Defendants made certain partial payments towards the balance due on the Underlying Judgment. 3. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court, initiating this enforcement and collection action. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 2 of 10 PageID# 2851
entityobservation

MARK D. SCHMIDT

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT OF and SECURE COMMUNITY, LLC, § § Plaintiffs/Judgment-Creditor § § v. § HARRIS COUNTY, TEXAS § CYBERLUX CORPORATION and § MARK D. SCHMIDT, Individually, § § Defendant/Judgment Debtors. § 129TH JUDICIAL DISTRICT PLAINTIFFS’ AND DEFENDANTS’ JOINT NOTICE OF SETTLEMENT AND JOINT MOTION FOR RELEASE OF FUNDS, FOR SATISFACTION OF JUDGMENT, AND TO DISSOLVE RECEIVERSHIP COME NOW, Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC (“ Plaintiffs”) and Cyberlux Corporation and Mark D. Schmidt (“Defendants”) (collectively, the “Parties”), and file this Joint Notice of Settlement and Joint Motion for Release of Funds, for Satisfaction of Judgment, and to Dissolve Receivership. In support thereof, the Parties state: I. INTRODUCTION 1. On June 23, 2023, a Virginia court presiding over Case No. CL22-3882-4, Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt, in the Circuit Court of the City of Richmond, State of Virginia, entered a judgment (“Underlying Judgment”) in favor of Plaintiffs and against Defendants, in the principal sum of $1,572,500.00. 2. Following entry of the Underlying Judgment, Defendants made certain partial payments towards the balance due on the Underlying Judgment. 3. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court, initiating this enforcement and collection action. Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 2 of 10 PageID# 2851
entityobservation

James Sadigh

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5 AGREED AS TO FORM AND SUBSTANCE: ________________________________ Atlantic Wave Holdings, LLC ________________________________ Secure Community, LLC James Sadigh Texas Bar No. 24129140 jamessadigh@aol.com JAMES K. SADIGH, ATTORNEY AT LAW 9777 Wilshire Blvd, Ste 400 Beverly Hills, CA 90212 Tel. (310) 747-5919 David A. Walton Texas Bar No. 24042120 dwalton@bellnunnally.com BELL NUNNALLY & MARTIN LLP 2323 Ross Avenue, Suite 1900 Dallas, TX 75201 Tel. (214) 740-1445 Fax (214) 740-5745 Attorneys for Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC ________________________________ Cyberlux Corporation ________________________________ Mark D. Schmidt Elizabeth G. Myers Texas Bar No. 24047767 emyers@thompsoncoburn.com Douglas S. Lang Texas Bar No. 11895500 dlang@thompsoncoburn.com Alexander J. Pennetti Texas Bar No. 24110208 apennetti@thompsoncoburn.com THOMPSON COBURN LLP 2100 Ross Avenue, Suite 3200 Dallas, TX 75201 Tel. (972) 629-7100 Fax (972) 629-7171 Attorneys for Defendants Cyberlux Corporation and Mark D. Schmidt CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing instrument was served on all counsel pursuant to the Texas Rules of Civil Procedure on February 25, 2026. /s/ Alexander J. Pennetti Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 6 of 10 PageID# 2855 [Visual signature transcription: William Welter signs for Atlantic Wave Holdings, LLC and Secure Community, LLC; Mark D. Schmidt signs for Cyberlux Corporation and individually; James Sadigh and Elizabeth G. Myers signatures appear; /s/ Alexander J. Pennetti appears on service certificate.]
entityobservation

Elizabeth G. Myers

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5 AGREED AS TO FORM AND SUBSTANCE: ________________________________ Atlantic Wave Holdings, LLC ________________________________ Secure Community, LLC James Sadigh Texas Bar No. 24129140 jamessadigh@aol.com JAMES K. SADIGH, ATTORNEY AT LAW 9777 Wilshire Blvd, Ste 400 Beverly Hills, CA 90212 Tel. (310) 747-5919 David A. Walton Texas Bar No. 24042120 dwalton@bellnunnally.com BELL NUNNALLY & MARTIN LLP 2323 Ross Avenue, Suite 1900 Dallas, TX 75201 Tel. (214) 740-1445 Fax (214) 740-5745 Attorneys for Plaintiffs Atlantic Wave Holdings, LLC, and Secure Community, LLC ________________________________ Cyberlux Corporation ________________________________ Mark D. Schmidt Elizabeth G. Myers Texas Bar No. 24047767 emyers@thompsoncoburn.com Douglas S. Lang Texas Bar No. 11895500 dlang@thompsoncoburn.com Alexander J. Pennetti Texas Bar No. 24110208 apennetti@thompsoncoburn.com THOMPSON COBURN LLP 2100 Ross Avenue, Suite 3200 Dallas, TX 75201 Tel. (972) 629-7100 Fax (972) 629-7171 Attorneys for Defendants Cyberlux Corporation and Mark D. Schmidt CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing instrument was served on all counsel pursuant to the Texas Rules of Civil Procedure on February 25, 2026. /s/ Alexander J. Pennetti Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 6 of 10 PageID# 2855 [Visual signature transcription: William Welter signs for Atlantic Wave Holdings, LLC and Secure Community, LLC; Mark D. Schmidt signs for Cyberlux Corporation and individually; James Sadigh and Elizabeth G. Myers signatures appear; /s/ Alexander J. Pennetti appears on service certificate.]
inferenceinference

Party assent supports the requested settlement arrangement but the blank judicial line prevents this copy from establishing receivership ter

Party assent supports the requested settlement arrangement but the blank judicial line prevents this copy from establishing receivership termination.

otherattribution

Complete supplied 10-page source reviewed at SHA-256 82382b29595b40b8f12cbd72fec3ac408c129cd3fe4dba504c36d3c85d667773. Source assertions, or

Complete supplied 10-page source reviewed at SHA-256 82382b29595b40b8f12cbd72fec3ac408c129cd3fe4dba504c36d3c85d667773. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Exact version_be62aa36fcbc4292babe169c227c48a8; SHA256 82382b29595b40b8f12cbd72fec3ac408c129cd3fe4dba504c36d3c85d667773. All10pages read; material signature, conditions, allocation and blank judicial-line images checked. Signature-image text expressly supplemented while original extraction retained.

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EXHIBIT 17 Case 3:25-cv-00483-JAG Document 175-19 Filed 04/15/26 Page 1 of 10 PageID# 2850
questionquestion

What signed order and disbursement records establish which proposed terms were granted, when funds arrived and whether satisfaction or disch

What signed order and disbursement records establish which proposed terms were granted, when funds arrived and whether satisfaction or discharge occurred?

questionquestion

How do the actual Virginia receipt and fee calculation reconcile the $3 payment-component discrepancy and receiver percentage rounding?

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The parties ask for creditor and Legalist disbursement within two business days of a court order, together with documentation. Satisfaction and closure are requested upon the creditors’ receipt of $873,849.02; dismissal of Texas actions and termination of the receivership are tied to satisfaction. These requests and conditions do not establish completed transfers or an effective discharge.referencesThe order grants the judgment creditors’ second amended distribution motion and directs Robert W. Berleth and Berleth & Associates, PLLC to disburse $873,849.02 from non-exempt funds held under the receivership order to Atlantic Wave Holdings, LLC and Secure Community, LLC within two business days of signing. The exact instruction is a creditor disbursement, not merely a court deposit.

Later signed distribution order commands the same creditor sum; it must be read for its own scope rather than treated as adopting this entire proposed three-way allocation and discharge.

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Confidence 75%Link weight 50%
The parties expressly resolve remaining disputes in this Texas enforcement action only. They exclude the Virginia Stock Case CL24-3910 and federal interpleader3:25-cv-00483 from the joint motion’s resolution. Its settlement language is not an omnibus resolution of those separate disputes.referencesThe order dismisses Atlantic Wave Holdings, LLC and Secure Community LLC’s claims to collect and enforce the underlying judgment in this proceeding against Cyberlux Corporation and Mark Schmidt. Its express scope is this collection/enforcement proceeding; it does not say the underlying judgment is vacated, identify a settlement release, or declare all debt paid.

Later nonsuit dismisses this enforcement proceeding, not the expressly excluded disputes.

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Confidence 75%Link weight 50%
The unsigned proposed order would find the fees recoverable, direct the three-way distribution, discharge the receiver and terminate the receivership. It also would stay other pending matters until reasonableness of receiver fees and expenses is determined, despite earlier stated findings allowing those fees. Both pieces of proposed text remain visible; neither is promoted to an issued order.supportsParty assent supports the requested settlement arrangement but the blank judicial line prevents this copy from establishing receivership termination.

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The proposed allocation of $3,083,639.75 is $873,849.02 to the two judgment creditors, $218,462.30 to the receiver and $1,991,328.43 to Legalist. These three amounts sum exactly. The receiver figure is called25% of $873,849.02, whose exact quarter is $218,462.255; the displayed fee is4.5cents higher. The source does not explain this small percentage rounding difference.supportsHow do the actual Virginia receipt and fee calculation reconcile the $3 payment-component discrepancy and receiver percentage rounding?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The parties ask for creditor and Legalist disbursement within two business days of a court order, together with documentation. Satisfaction and closure are requested upon the creditors’ receipt of $873,849.02; dismissal of Texas actions and termination of the receivership are tied to satisfaction. These requests and conditions do not establish completed transfers or an effective discharge.supportsWhat signed order and disbursement records establish which proposed terms were granted, when funds arrived and whether satisfaction or discharge occurred?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The parties ask for creditor and Legalist disbursement within two business days of a court order, together with documentation. Satisfaction and closure are requested upon the creditors’ receipt of $873,849.02; dismissal of Texas actions and termination of the receivership are tied to satisfaction. These requests and conditions do not establish completed transfers or an effective discharge.supportsParty assent supports the requested settlement arrangement but the blank judicial line prevents this copy from establishing receivership termination.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Federal Exhibit17 filed April15,2026 as EDVA175-19 contains a February26 joint motion and proposed order in Texas cause2024-48085. Pages6/10 display William Welter signatures for both creditors, Mark D. Schmidt signatures for Cyberlux and himself, James Sadigh and Elizabeth G. Myers signatures. Page6 bears Alexander J. Pennetti’s /s/ service certification for February25, one day before the motion’s printed date. The proposed judge signature line on page9 is blank.supportsParty assent supports the requested settlement arrangement but the blank judicial line prevents this copy from establishing receivership termination.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The proposed allocation of $3,083,639.75 is $873,849.02 to the two judgment creditors, $218,462.30 to the receiver and $1,991,328.43 to Legalist. These three amounts sum exactly. The receiver figure is called25% of $873,849.02, whose exact quarter is $218,462.255; the displayed fee is4.5cents higher. The source does not explain this small percentage rounding difference.supportsWhat signed order and disbursement records establish which proposed terms were granted, when funds arrived and whether satisfaction or discharge occurred?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Federal Exhibit17 filed April15,2026 as EDVA175-19 contains a February26 joint motion and proposed order in Texas cause2024-48085. Pages6/10 display William Welter signatures for both creditors, Mark D. Schmidt signatures for Cyberlux and himself, James Sadigh and Elizabeth G. Myers signatures. Page6 bears Alexander J. Pennetti’s /s/ service certification for February25, one day before the motion’s printed date. The proposed judge signature line on page9 is blank.supportsDoes this copy establish that the receiver was discharged?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The unsigned proposed order would find the fees recoverable, direct the three-way distribution, discharge the receiver and terminate the receivership. It also would stay other pending matters until reasonableness of receiver fees and expenses is determined, despite earlier stated findings allowing those fees. Both pieces of proposed text remain visible; neither is promoted to an issued order.supportsDoes this copy establish that the receiver was discharged?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The unsigned proposed order would find the fees recoverable, direct the three-way distribution, discharge the receiver and terminate the receivership. It also would stay other pending matters until reasonableness of receiver fees and expenses is determined, despite earlier stated findings allowing those fees. Both pieces of proposed text remain visible; neither is promoted to an issued order.supportsWhat signed order and disbursement records establish which proposed terms were granted, when funds arrived and whether satisfaction or discharge occurred?

Specifically named source propositions support the bounded distinction or question.

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Confidence 75%Link weight 50%
The motion recounts a June23,2023 Virginia $1,572,500 principal judgment, partial payments and May22,2025 Texas receivership. It says November2025 Virginia payment was $1,140,004.66 but its listed components $952,601.71 and $187,399.95 total $1,140,001.66, a $3 discrepancy. The source leaves Texas enforcement costs outstanding.supportsHow do the actual Virginia receipt and fee calculation reconcile the $3 payment-component discrepancy and receiver percentage rounding?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The parties ask for creditor and Legalist disbursement within two business days of a court order, together with documentation. Satisfaction and closure are requested upon the creditors’ receipt of $873,849.02; dismissal of Texas actions and termination of the receivership are tied to satisfaction. These requests and conditions do not establish completed transfers or an effective discharge.supportsDoes this copy establish that the receiver was discharged?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%

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