June 15, 2023 signed settlement — payments, stock remedy, security and disclosure limits
Original sourceSigned settlement copy with handwritten/highlight annotations and missing referenced consent-judgment exhibit; contractual undertakings and representations, not proof of performance or priority.
Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
quotationattribution
The executed settlement acknowledges $922,500 remaining IP instalments and $650,000 consulting balance after specified prior payments.
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Cyberlux Settlement Agreement Final 002 -1 pdf
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EXHIBIT
SETTLEMENT AGREEMENT
This Settlement Agreement (the "Agreement") is made as of this 15thth day of June 2023,
by and between ATLANTIC WAVE HOLDINGS. LLC. SECURE COMMUNITY, LLO
(collectively,iPlaintiffs"), CYBERLUX CORPORATION AND MARK D. SCHMIDT
(collectively, 'Defendants), and STRIKEPOINT CONSULTING, LLC ("Strikepointi) a
separate panty with some common interest holders to the Plaintiffs. Plainuffs, Defendants, and
Strikepoint shall collectively be referred to as the "Parties to this Agreementiạiand Plaintiffs and
Detendants shall collectively be referred to as "Parties to the Litigationi
RECITALS
WHEREAS, Plaintiffs and Defendants entered into an agreement on October 8, 2021,
which compensated Plaintiffs for the reacquisition by Defendant Cyberlux of certain intellectual
property in exchange for certain installment payments of fixed liquidated sums by Defendants to
Plaintiffs and "Freely Trading stock. which had fallen into arrears ("the IP Agreement):
WHEREAS, on September 24, 2021 an agreement was executed between an entity
described asẠStrikepoints Consulting. LLC" and Defendant Cyberlux Corporation for certain
consulting services (the Strikepoint Consulting Agreement), which called for, inter alia,
installment payments of fixed liquidated sums owed by Defendants to Plaintiff, which also fell into
arrears:
WHEREAS, Plaintifts filed its Complaint for breach of said agreements in the Circuit Court
of the City of Richnond, Virginia (the Court"). against Defendants in the civil action titled,
Atlantic Wave Holdings, LLC and Secure Community, LLC V. Cyberlux Corporation and Mark D.
Schmid: (Case No. CL22-3882) (the "Litigation"). which remains pending:
WHEREAS. the Parties to this Agreement desire to resolve and settle any and all existing
disputes between the Plaintiffs and Defendants and between Strikepoint and Defendants to
chiminate uncertainty and tacilitate hinal resolution of their respective relationships between the
parties; and
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The April 15, 2026 Exhibit 9 contains a settlement dated June 15, 2023 among Atlantic Wave, Secure Community, Cyberlux, Schmidt and Strikepo
The April 15, 2026 Exhibit 9 contains a settlement dated June 15, 2023 among Atlantic Wave, Secure Community, Cyberlux, Schmidt and Strikepoint. Signatures appear for special counsel Charles Watts Jr., Schmidt individually and as Cyberlux president, Welter for AWH/SC and Strikepoint, and Cheri Nolan for Strikepoint, each dated June 15. The file contains agreement pages 1–12; print footers indicate an original 15-page document, and the referenced consent-judgment Exhibit A is absent.
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2772
claimallegation
Confidentiality contains written notice and fourteen-day cure language with specified use of litigation information for collection or defenc
Confidentiality contains written notice and fourteen-day cure language with specified use of litigation information for collection or defence and reasonable privacy efforts. Non-disparagement expressly runs only through December 31, 2023 and likewise has notice/cure language. The document does not establish any breach, notice or cure.
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Emptor" restriction) and will continuc to usc any and all reasonable efforts to maintain compliance
at all times.
10.
Financial Statements: Defendants herchy represent that any Financial Statements
published or produced hereunder or publicly filed which Plaintifi has rehed upon in entering into
this Agreement. have been prepared in good faith and in accordance with OTC standards and are
materially true and accurate.
11.
OTC Markets: Defendants hereby represent that Defendants are using any and all
reasonable efforts to resolve all issues with OTC Markets that is causing the OTC Markets to issue
its cateat emptor restriction and will continue to use any and all reasonable efforts to have the
Caveat Emptor restriction currently imposed by OTC Markets removed so that the stock will be
returned to "Pink Current as soon as reasonably possible.
12.
Stockholders' Rights: The parties agree that this agreement shall not affect
Plaintiff s rights as stockholders in any manner going forward.
13.
Confidentiality of Settlement Terms and Discovery Information. The terms and
circumstances of this Agreement, and all documents and information disclosed in the Litigation,
are completely confidential between the Parties and shall not be disclosed to anybody else. Any
disclosure or violation shall be deemed a breach of this Agreement. If a Party discloses confidential
information in material violation of this paragraph, then, following written notice to such Party
summarizing such violation and such Party's failure to cure such material violation within fourteen
(14) days of receiving such notice. then such Party may be deemed to have breached this
Agreement. If a breach is to occur, notwithstanding the foregoing. Plaintiffs shall be entitled to
use any information received in the Lungation if necessary to collect sums owing under this
Agreement and/or to defend against any claims of breach, and Defendants shall be entitled to use
such information to defend against any claims of breach, though reasonable efforts will be made
to keep such information private.
8
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claimallegation
The agreement provides integration and written modification, severability, counsel opportunity, electronic counterparts, authority represent
The agreement provides integration and written modification, severability, counsel opportunity, electronic counterparts, authority representations and joint construction. Remedies include enforcement relief; late payments are defined by first-of-month receipt and requested information due within ten calendar days with three-day cure. Virginia law and exclusive Richmond state or federal venue are stated, with submission to jurisdiction. No later amendment or enforcement ruling is included.
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14.
Non-Disparagement. The Parties to this Agreement further agree that, in order to
facilitate the transactions and obligations set forth hercin, during the period from the date of this
Agreement through December 31, 2023. no Party shall communicate, publish, or caused to be
published any comments, statements. or information that could reasonably be expected to adversely
affect the business interests or reputation of any other Party. If it is alleged a party materially
disparaged the other party in violation of this paragraph, then, following written notice to such
Party summarizing such violation and such Party's failure to cure such material violation within
fourteen (14) days of receiving such notice, then such Party may be deemed to have breached this
Agreement.
15. Advice of Counsel: The Parties to this Agreement represent and warrant that they
have chosen to exccute this Agreement of their own volition and free will after fully reviewing the
Agrecinent and having the opportunity to seck the advice of counsel. Accordingly, the rule of
contract interpretation to the effect that any ambiguities are to be resolved against the drafting party
will not be employed in any interpretation of this Agreement.
10.
Entire Agreement. This Agreement constitutes the entire greement between the
Parties pertaining to the matters with which it deals, and it supersedes all prior agreements
pertaining to those matters. This Agreement may only be modified by written consent of the
parties.
17.
Severability of Provisions. If any clause or provision. or any part of any clause or
provision, of this Agreement is found by the court to be illegal, invalid, or unenforceable under
present or future laws, then the remainder of this Agreement shall not be affected thereby, and it
shall be construed as if the unenforceable clause or provision, or the offending part of any clause
or provision, were deleted.
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claimallegation
The agreement recites arrears under an October 8, 2021 IP reacquisition and September 24, 2021 consulting agreement. It states $922,500 IP b
The agreement recites arrears under an October 8, 2021 IP reacquisition and September 24, 2021 consulting agreement. It states $922,500 IP balance after $277,500 payments against $1.2 million, plus $650,000 consulting balance, totalling $1,572,500 jointly and severally under an intended consent judgment, plus costs. The parties’ discharge restriction is expressly to the fullest extent permissible by law, not a judicial determination of bankruptcy treatment.
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Cyberlux Settlement Agreement Final 002 -1 pdf
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EXHIBIT
SETTLEMENT AGREEMENT
This Settlement Agreement (the "Agreement") is made as of this 15thth day of June 2023,
by and between ATLANTIC WAVE HOLDINGS. LLC. SECURE COMMUNITY, LLO
(collectively,iPlaintiffs"), CYBERLUX CORPORATION AND MARK D. SCHMIDT
(collectively, 'Defendants), and STRIKEPOINT CONSULTING, LLC ("Strikepointi) a
separate panty with some common interest holders to the Plaintiffs. Plainuffs, Defendants, and
Strikepoint shall collectively be referred to as the "Parties to this Agreementiạiand Plaintiffs and
Detendants shall collectively be referred to as "Parties to the Litigationi
RECITALS
WHEREAS, Plaintiffs and Defendants entered into an agreement on October 8, 2021,
which compensated Plaintiffs for the reacquisition by Defendant Cyberlux of certain intellectual
property in exchange for certain installment payments of fixed liquidated sums by Defendants to
Plaintiffs and "Freely Trading stock. which had fallen into arrears ("the IP Agreement):
WHEREAS, on September 24, 2021 an agreement was executed between an entity
described asẠStrikepoints Consulting. LLC" and Defendant Cyberlux Corporation for certain
consulting services (the Strikepoint Consulting Agreement), which called for, inter alia,
installment payments of fixed liquidated sums owed by Defendants to Plaintiff, which also fell into
arrears:
WHEREAS, Plaintifts filed its Complaint for breach of said agreements in the Circuit Court
of the City of Richnond, Virginia (the Court"). against Defendants in the civil action titled,
Atlantic Wave Holdings, LLC and Secure Community, LLC V. Cyberlux Corporation and Mark D.
Schmid: (Case No. CL22-3882) (the "Litigation"). which remains pending:
WHEREAS. the Parties to this Agreement desire to resolve and settle any and all existing
disputes between the Plaintiffs and Defendants and between Strikepoint and Defendants to
chiminate uncertainty and tacilitate hinal resolution of their respective relationships between the
parties; and
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claimallegation
The stock reservation permits plaintiffs at their discretion to file a new complaint if Pink Current status and removal of Caveat Emptor res
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.
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Balance of Consulting Agreement: The parties agree to terminate
and resolve any disputes arsing out of the Strikepoint Consulting Agreement for
considcration of: SIX HUNDRED FIFTY THOUSAND DOLLARS (S650,000), is
the balance due and owing for installment payments under the Consulting
Agreement between the parties.
Total Value of the Consent Judgment: The total liquidated sum
that shall be due and owing to Plaintiffs under the parties' Consent Judgment shall
be ONE MILLION FIVE HUNDRED SEVENTY-TWO THOUSAND AND
PIVE HUNDRED DOLLARS ($1,572.500), plus Plaintiffs' costs as defined in
4(d) (the Settlement Consideration). which is the sum of the outstanding
installment payments owing in the IP Agreement, the Strikepoint Consulting
Agreement. and Plaintiffs' costs as appropriately allocated between Plaintiffs and
Strikepoint below.
Effect of Consent Judgment: The Consent Judgment shall be
promptly entered jointly and severally against Defendants and in favor of Plaintiffs
in exchange for payment of the full Settlement Consideration. which shall resolve
the above styled matter. The parties agree that the Consent Judgment shall not be
dischargeable, including by appeal or bankruptcy, in any manner other than by
agreement of the parties. to the fullest extent permissible under the law.
Stock. Norwithstanding the foregoing, the parties agree that entry of
the Consent Judgment awarding FINAL judgment in favor of Plaintiffs and against
Defendants shall resolve the pending Litigation. Notwithstanding entry of a Final
Order. the parties herby agree that if the Cyberlux stock is not brought to current
"Pink Status" and the Cavcar Emptor legend and restriction is not remedied and
removed on or before December 31.2023. Plaintifis shall have the option. at their
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Defendants undertake $3,895 and $6,842.50 sanctions within 21 days of execution; a $150,000 first settlement payment with specified executio
Defendants undertake $3,895 and $6,842.50 sanctions within 21 days of execution; a $150,000 first settlement payment with specified execution/judgment/revenue conditions and an outer 45-day limit; 36 monthly $21,459 payments to plaintiffs and 36 monthly $18,055.56 payments to Strikepoint from July 2023. Actual receipt is required. Arithmetic gives $922,524 including the first payment, $24 above stated IP balance, and $650,000.16 for Strikepoint, $0.16 above its stated balance; no final-payment adjustment is supplied.
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Cyberlux_Settlement_Agrecment_
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sole discretion. to re-file a new complaint related to the breach by Defendants to
create "Negotiable Sharesit as that breach is alleged and defined in the Complaint,
without Defendants asserting a defense of res judicata or collateral estoppel.
Plaintiffs recognize that matters can be delayed at no fault of a party and to that end
shall consider an extension of the aforementioned deadline (December 31. 2023)
upon the showing of credible evidence to do so, for an extension period to be
decided at the reasonable discretion of Plaintiffs.
Compliance with Court Orders dated December 13. 2022 & April 7. 2023.
Within tventy-one (21) days of executon of this Agreement. Defendants shall pay the sanctions
of $3.895.00 and $6.842.50. as provided by the Court's Orders in the Litigation.
How the Settlement Consideration Shall be Paid. The Seutement Consideration
shall be paid by Defendant to Plaintift as follows:
First Settlement Payment: Within thirty (30) days after the
simultaneous execution of this Agreement, and entry of the Consent Judgment, and
the receipt by Cyberlux of its first installment payment for the anticipated sale of
drones or other revenue whichever occurs last. but in no event more than forty-five
(45) days from the exccution of this Agreement. Defendants shall transmit to
Plaintifts. by wire transmission. the non defcasible sum of One Hundred Fifty
Thousand Dollars (S150,000) the "First Settlement Payment"). The delivery of the
First Settlement Payment shall require the actual receipt of the Settlement Payment
by Plaintiffs as set forth herein. Time being of the essence.
b.
Monthly Installments Thereafter to Plaintiffs: Defendants shall
transmit to Plaintiffs, by wire transmission thirty-Six (36) non-defeasible monthly
payments of TWENTY-ONE THOUSAND FOUR HUNDRED AND FIFTY-
NINE DOLLARS ($21. 459.00) payable on the first day of each month, beginning
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claimallegation
Both monthly-payment provisions contain acceleration language up to $5,000 per drone sold within 21 days of defendants or their parent, subs
Both monthly-payment provisions contain acceleration language up to $5,000 per drone sold within 21 days of defendants or their parent, subsidiary, affiliate or assign first receiving payment under any drone purchase contract. This is broader than an HII-only trigger and is conditional on actual receipt. Repeated wording should not automatically be aggregated into a separate $10,000-per-drone obligation without interpretation.
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in July 2023. Monthly payments shall continuc on the first of each month, time
being of the essence, until the total Settlement C'onsideration due to Plaintiffs is
paid. Defendants agree to accelerate and pay the full outstanding balance of all
sums owed under the Consent Judgment up to i total of FIVE THOUSAND
DOLLARS (S5,000) per drone sold within twenty-one (21) days of Defendants, or
any parent's, subsidiary's, affiliate's, or assign's first receipt of payment for any
contract to purchase drone aircraft.
Monthly Installments Thereafter to Strikepoint: Defendants
shall transmit to Strikepoint, by wire transmission.thirty-Six non-defeasible
monthly payments of EIGHTEEN THOUSAND FIFTY-FIVE DOLLARS AND
FIFTY-SIX CENTS (S18.055.56) payable on the first day of each month, beginning
in July of 2023. Monthly payments shall continue on the first of each month. time
being of the essence, until the total Senlement Consideration due to Strikepoint is
paid. Defendants agree to accelerate and pay the full outstanding balance of all
suns owed under the Consent Judgment up to a total of FIVE THOUSAND
DOLLARS ($5,000) per drone sold within twenty-one (21) days of Defendants, or
any parent's, subsidiary's affiliate's. or assign's first receipt of payment for any
contract to purchase drone aircratt.
Costs, including Legal Fees: In addition to the sums above,
Defendants agree to pay all Plaintiffs' costs, including but not limited to, attorney's
fees and expert witness fees. accrued in and with this Litigation within 60 (sixty)
days of the full execution of this Agreement or upon terms agreed to by the parties.
Subject to the following CAP. Plaintifts agrce to CAP costs and attorney's fees, for
cost and attorney's fees relevant the matters dealt with in this settlement agreement,
at 12% of the value of the total scutlement or ONE HUNDRED EIGHTY-EIGHT
S of IS
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claimallegation
Litigation costs including legal and expert fees are due within 60 days or agreed terms, capped for settled matters at 12% or $188,700, arit
Litigation costs including legal and expert fees are due within 60 days or agreed terms, capped for settled matters at 12% or $188,700, arithmetically 12% of $1,572,500. The cap expressly does not restrict breach-related fees; paragraph 19 separately obligates defendants for plaintiffs’ fees and costs in actions caused by breach. This establishes contract language, not the reasonableness or award of any later invoice.
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in July 2023. Monthly payments shall continuc on the first of each month, time
being of the essence, until the total Settlement C'onsideration due to Plaintiffs is
paid. Defendants agree to accelerate and pay the full outstanding balance of all
sums owed under the Consent Judgment up to i total of FIVE THOUSAND
DOLLARS (S5,000) per drone sold within twenty-one (21) days of Defendants, or
any parent's, subsidiary's, affiliate's, or assign's first receipt of payment for any
contract to purchase drone aircraft.
Monthly Installments Thereafter to Strikepoint: Defendants
shall transmit to Strikepoint, by wire transmission.thirty-Six non-defeasible
monthly payments of EIGHTEEN THOUSAND FIFTY-FIVE DOLLARS AND
FIFTY-SIX CENTS (S18.055.56) payable on the first day of each month, beginning
in July of 2023. Monthly payments shall continue on the first of each month. time
being of the essence, until the total Senlement Consideration due to Strikepoint is
paid. Defendants agree to accelerate and pay the full outstanding balance of all
suns owed under the Consent Judgment up to a total of FIVE THOUSAND
DOLLARS ($5,000) per drone sold within twenty-one (21) days of Defendants, or
any parent's, subsidiary's affiliate's. or assign's first receipt of payment for any
contract to purchase drone aircratt.
Costs, including Legal Fees: In addition to the sums above,
Defendants agree to pay all Plaintiffs' costs, including but not limited to, attorney's
fees and expert witness fees. accrued in and with this Litigation within 60 (sixty)
days of the full execution of this Agreement or upon terms agreed to by the parties.
Subject to the following CAP. Plaintifts agrce to CAP costs and attorney's fees, for
cost and attorney's fees relevant the matters dealt with in this settlement agreement,
at 12% of the value of the total scutlement or ONE HUNDRED EIGHTY-EIGHT
S of IS
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claimallegation
The agreement marks judgment satisfied upon all sums paid and requires plaintiffs’ notice within ten business days after complete considerat
The agreement marks judgment satisfied upon all sums paid and requires plaintiffs’ notice within ten business days after complete consideration and satisfaction of all terms. Releases are asymmetrical in timing: defendants release on endorsement with stated enforcement exceptions; plaintiffs and Strikepoint release on first-payment receipt. No payment receipt or notice of satisfaction is attached.
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THOUSAND SEVEN HUNDRED DOLLARS (S188.700). The CAP does not
apply to restrict or limit Plaintiffs ability to pursue costs and attorney's fees should
Defendants breach this Agreement. This obligation shall be added to the total
balance due specitied in section 2tb1 above and paid to Strikepoint.
Manner of Pavment: All payments shall be wired to Plaintiffs and
to Strikepoint. Information and Instructions for completing the wire transfer shall
be provided to Defendants' Counsel upon exccution of this agreement. Plaintiff
may change its payment instructions from time to time by providing written notice.
Effect of Full Pavment: Upon payment of all sums due and owing
herein, the Judgment entered herein shall be marked "Satisfied.
No Other Beneficiary: The payment of funds herein shall not
operate to release any other pany, other than the Parties to this Agreement, as set
forth below. Nor shall the dismissal of any claim herein inure to the benefit of any
party who is not a Party to this Agreement.
Notice of Satisfaction. Within ten (10) business days of Plaintiff receiving the
complete Settlement Consideration and satisfactions of all terms herein, Plaintiff shall file a Notice
of Satisfaction, pursuant to Va. Code Ann. § 16.1-94.01.
Mutual Release of All Claims. Immediately upon endorsement of this Agreement,
except for the obligations expressly set forth herein and any claims or actions for breach or
enforcement of this Agreement. Défendants Cyberlux Corporation and Mark D. Schmidt,
individually, hereby relcase any and all causes of action, claims, counterclaims, or demands,
present or future, known or unknown, asserted or unasserted, against Plaintiffs or any of Plaintiffs'
members, officers, agents, counsel, employees, and affiliates arising or accruing from the
beginning of time and up to and including the date of this Agreement. including all claims based
upon or in any way relating to the IP Agreement. the Strikepoint Consulting Agreement, Plaintiffs'
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Paragraph 7 grants plaintiffs a full security and lien interest in all defendants’ assets, including IP, subsidiaries, contractual rights, r
Paragraph 7 grants plaintiffs a full security and lien interest in all defendants’ assets, including IP, subsidiaries, contractual rights, receivables and drone sales, with optional UCC memorialisation. Paragraph 8 requires requested negotiation/payment updates and documents only to the extent not classified or restricted, with confidentiality cross-reference printed as paragraph 12 although confidentiality appears at 13. The visible highlight/underline cannot be attributed to a particular annotator.
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Cyberlux_Sculement Agreement
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ownership of stock in Cyberlux Corporation. Plaintiffs prosecution of the Litigation, or the
negotiation and entry into this Agreement. Upon reccipt of the First Settlement Payment. Plaintiff
Secure Communitv. LLC. Plaintiff Atlantic Wave Holdings, L.L.C. and Strikepoint Consulting,
LEC. release any and all known or unknown causes of action. claims, counterclaims, or demands.
present or future, asserted or unasserted, against Defendants or any of Defendant Cyberlux's
members, officers, agents, counsel, employees, and affiliates arising or accruing from the
beginning of time and up to and including the date of this Agreement, including all claims based
upon or in any way relating to the IP Agreement the Strikepoint Consulting Agreement, Plaintiffs'
prosecution of the Litigation, or the negotiation and entry into this Agreement.
Securitv Interest and Lien Interest. Defendants agree and grant to Plaintiff a full
security interest and lien interest in all of Defendants' assets, including but not limited to IPS
subsidiaries, contractual rights, accounts receivable, drone sales. etc. which may, in Plaintiff's sole
discretion, be memorialized through the tiling of OCC-T forms and Liens.
Updates and Continued Cooperation: Defendants, upon demand of Plaintiffs.
shall keep Plaintiffs fully updated as to any and all progress on contract negotiations and provide
documentation about payments received for the sale of drones, including providing copies of
relevant documents requested by Plaintiffs, subject to the confidentiality provisions set forth in
Paragraph 12 below, and to the extent such documents or information are not classified or
restricted. Defendant Cyberlux shall also in good faith provide any assistance that it can reasonably
provide and required by Plaintitis in their effort to bring their CYBL stock shares into compliance
so that the shares will be accepted by a reputable brokerage firm in order to permit the trading of
such shares on the OTC Market .
2. _ Compliance: Defendants represent to Plaintiff Secure Community, LLC that
Defendants have used reasonable efforts to comply with all State. Federal and OTC Markets rules
and regulations (subject to the fact that Cyberlux shares are currently subject to the "Caveat
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Defendants undertake reasonable compliance and OTC remediation efforts and good-faith assistance to make shares acceptable to a reputable br
Defendants undertake reasonable compliance and OTC remediation efforts and good-faith assistance to make shares acceptable to a reputable broker. They represent relied-on financial statements as prepared in good faith under OTC standards and materially accurate. These are representations/effort duties, not independent findings of financial accuracy, regulatory compliance or successful stock remediation.
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ownership of stock in Cyberlux Corporation. Plaintiffs prosecution of the Litigation, or the
negotiation and entry into this Agreement. Upon reccipt of the First Settlement Payment. Plaintiff
Secure Communitv. LLC. Plaintiff Atlantic Wave Holdings, L.L.C. and Strikepoint Consulting,
LEC. release any and all known or unknown causes of action. claims, counterclaims, or demands.
present or future, asserted or unasserted, against Defendants or any of Defendant Cyberlux's
members, officers, agents, counsel, employees, and affiliates arising or accruing from the
beginning of time and up to and including the date of this Agreement, including all claims based
upon or in any way relating to the IP Agreement the Strikepoint Consulting Agreement, Plaintiffs'
prosecution of the Litigation, or the negotiation and entry into this Agreement.
Securitv Interest and Lien Interest. Defendants agree and grant to Plaintiff a full
security interest and lien interest in all of Defendants' assets, including but not limited to IPS
subsidiaries, contractual rights, accounts receivable, drone sales. etc. which may, in Plaintiff's sole
discretion, be memorialized through the tiling of OCC-T forms and Liens.
Updates and Continued Cooperation: Defendants, upon demand of Plaintiffs.
shall keep Plaintiffs fully updated as to any and all progress on contract negotiations and provide
documentation about payments received for the sale of drones, including providing copies of
relevant documents requested by Plaintiffs, subject to the confidentiality provisions set forth in
Paragraph 12 below, and to the extent such documents or information are not classified or
restricted. Defendant Cyberlux shall also in good faith provide any assistance that it can reasonably
provide and required by Plaintitis in their effort to bring their CYBL stock shares into compliance
so that the shares will be accepted by a reputable brokerage firm in order to permit the trading of
such shares on the OTC Market .
2. _ Compliance: Defendants represent to Plaintiff Secure Community, LLC that
Defendants have used reasonable efforts to comply with all State. Federal and OTC Markets rules
and regulations (subject to the fact that Cyberlux shares are currently subject to the "Caveat
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Defendants undertake the scheduled monetary payments and conditional acceleration.
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sole discretion. to re-file a new complaint related to the breach by Defendants to
create "Negotiable Sharesit as that breach is alleged and defined in the Complaint,
without Defendants asserting a defense of res judicata or collateral estoppel.
Plaintiffs recognize that matters can be delayed at no fault of a party and to that end
shall consider an extension of the aforementioned deadline (December 31. 2023)
upon the showing of credible evidence to do so, for an extension period to be
decided at the reasonable discretion of Plaintiffs.
Compliance with Court Orders dated December 13. 2022 & April 7. 2023.
Within tventy-one (21) days of executon of this Agreement. Defendants shall pay the sanctions
of $3.895.00 and $6.842.50. as provided by the Court's Orders in the Litigation.
How the Settlement Consideration Shall be Paid. The Seutement Consideration
shall be paid by Defendant to Plaintift as follows:
First Settlement Payment: Within thirty (30) days after the
simultaneous execution of this Agreement, and entry of the Consent Judgment, and
the receipt by Cyberlux of its first installment payment for the anticipated sale of
drones or other revenue whichever occurs last. but in no event more than forty-five
(45) days from the exccution of this Agreement. Defendants shall transmit to
Plaintifts. by wire transmission. the non defcasible sum of One Hundred Fifty
Thousand Dollars (S150,000) the "First Settlement Payment"). The delivery of the
First Settlement Payment shall require the actual receipt of the Settlement Payment
by Plaintiffs as set forth herein. Time being of the essence.
b.
Monthly Installments Thereafter to Plaintiffs: Defendants shall
transmit to Plaintiffs, by wire transmission thirty-Six (36) non-defeasible monthly
payments of TWENTY-ONE THOUSAND FOUR HUNDRED AND FIFTY-
NINE DOLLARS ($21. 459.00) payable on the first day of each month, beginning
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otherattribution
Defendants undertake acceleration tied to first receipt of drone-contract payment.
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Case 3:25-cv-00483-JAG Document 175-11
Filed 04/15/26 Page 6 of 13 PagelD#
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in July 2023. Monthly payments shall continuc on the first of each month, time
being of the essence, until the total Settlement C'onsideration due to Plaintiffs is
paid. Defendants agree to accelerate and pay the full outstanding balance of all
sums owed under the Consent Judgment up to i total of FIVE THOUSAND
DOLLARS (S5,000) per drone sold within twenty-one (21) days of Defendants, or
any parent's, subsidiary's, affiliate's, or assign's first receipt of payment for any
contract to purchase drone aircraft.
Monthly Installments Thereafter to Strikepoint: Defendants
shall transmit to Strikepoint, by wire transmission.thirty-Six non-defeasible
monthly payments of EIGHTEEN THOUSAND FIFTY-FIVE DOLLARS AND
FIFTY-SIX CENTS (S18.055.56) payable on the first day of each month, beginning
in July of 2023. Monthly payments shall continue on the first of each month. time
being of the essence, until the total Senlement Consideration due to Strikepoint is
paid. Defendants agree to accelerate and pay the full outstanding balance of all
suns owed under the Consent Judgment up to a total of FIVE THOUSAND
DOLLARS ($5,000) per drone sold within twenty-one (21) days of Defendants, or
any parent's, subsidiary's affiliate's. or assign's first receipt of payment for any
contract to purchase drone aircratt.
Costs, including Legal Fees: In addition to the sums above,
Defendants agree to pay all Plaintiffs' costs, including but not limited to, attorney's
fees and expert witness fees. accrued in and with this Litigation within 60 (sixty)
days of the full execution of this Agreement or upon terms agreed to by the parties.
Subject to the following CAP. Plaintifts agrce to CAP costs and attorney's fees, for
cost and attorney's fees relevant the matters dealt with in this settlement agreement,
at 12% of the value of the total scutlement or ONE HUNDRED EIGHTY-EIGHT
S of IS
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otherattribution
Defendants grant the stated security interest and undertake requested updates subject to classified/restricted limits.
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Cyberlux_Sculement Agreement
Final
002 -1.pdt
2779 Mile: C: Users willw/Downloads Cyberlux_Settlement_Agreemen...
ownership of stock in Cyberlux Corporation. Plaintiffs prosecution of the Litigation, or the
negotiation and entry into this Agreement. Upon reccipt of the First Settlement Payment. Plaintiff
Secure Communitv. LLC. Plaintiff Atlantic Wave Holdings, L.L.C. and Strikepoint Consulting,
LEC. release any and all known or unknown causes of action. claims, counterclaims, or demands.
present or future, asserted or unasserted, against Defendants or any of Defendant Cyberlux's
members, officers, agents, counsel, employees, and affiliates arising or accruing from the
beginning of time and up to and including the date of this Agreement, including all claims based
upon or in any way relating to the IP Agreement the Strikepoint Consulting Agreement, Plaintiffs'
prosecution of the Litigation, or the negotiation and entry into this Agreement.
Securitv Interest and Lien Interest. Defendants agree and grant to Plaintiff a full
security interest and lien interest in all of Defendants' assets, including but not limited to IPS
subsidiaries, contractual rights, accounts receivable, drone sales. etc. which may, in Plaintiff's sole
discretion, be memorialized through the tiling of OCC-T forms and Liens.
Updates and Continued Cooperation: Defendants, upon demand of Plaintiffs.
shall keep Plaintiffs fully updated as to any and all progress on contract negotiations and provide
documentation about payments received for the sale of drones, including providing copies of
relevant documents requested by Plaintiffs, subject to the confidentiality provisions set forth in
Paragraph 12 below, and to the extent such documents or information are not classified or
restricted. Defendant Cyberlux shall also in good faith provide any assistance that it can reasonably
provide and required by Plaintitis in their effort to bring their CYBL stock shares into compliance
so that the shares will be accepted by a reputable brokerage firm in order to permit the trading of
such shares on the OTC Market .
2. _ Compliance: Defendants represent to Plaintiff Secure Community, LLC that
Defendants have used reasonable efforts to comply with all State. Federal and OTC Markets rules
and regulations (subject to the fact that Cyberlux shares are currently subject to the "Caveat
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otherattribution
Plaintiffs undertake to file notice of satisfaction after complete payment and satisfaction of terms.
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Cyberlux Settlement_Agreement
_Final
002 - 1.pdf
2778 file: C: Users/willw/Downloads Cyberlux Settlement_Agreement...
THOUSAND SEVEN HUNDRED DOLLARS (S188.700). The CAP does not
apply to restrict or limit Plaintiffs ability to pursue costs and attorney's fees should
Defendants breach this Agreement. This obligation shall be added to the total
balance due specitied in section 2tb1 above and paid to Strikepoint.
Manner of Pavment: All payments shall be wired to Plaintiffs and
to Strikepoint. Information and Instructions for completing the wire transfer shall
be provided to Defendants' Counsel upon exccution of this agreement. Plaintiff
may change its payment instructions from time to time by providing written notice.
Effect of Full Pavment: Upon payment of all sums due and owing
herein, the Judgment entered herein shall be marked "Satisfied.
No Other Beneficiary: The payment of funds herein shall not
operate to release any other pany, other than the Parties to this Agreement, as set
forth below. Nor shall the dismissal of any claim herein inure to the benefit of any
party who is not a Party to this Agreement.
Notice of Satisfaction. Within ten (10) business days of Plaintiff receiving the
complete Settlement Consideration and satisfactions of all terms herein, Plaintiff shall file a Notice
of Satisfaction, pursuant to Va. Code Ann. § 16.1-94.01.
Mutual Release of All Claims. Immediately upon endorsement of this Agreement,
except for the obligations expressly set forth herein and any claims or actions for breach or
enforcement of this Agreement. Défendants Cyberlux Corporation and Mark D. Schmidt,
individually, hereby relcase any and all causes of action, claims, counterclaims, or demands,
present or future, known or unknown, asserted or unasserted, against Plaintiffs or any of Plaintiffs'
members, officers, agents, counsel, employees, and affiliates arising or accruing from the
beginning of time and up to and including the date of this Agreement. including all claims based
upon or in any way relating to the IP Agreement. the Strikepoint Consulting Agreement, Plaintiffs'
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entityobservation
Cyberlux Corporation
Read the anchor · page 13
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 13 of 13 PageID#2784
IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals.
[Signature] Charles Watts, Jr. in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Date: 06/15/2023
[Signature] Mark D. Schmidt, individually and on behalf of Cyberlux Corporation, as its President. Date: 06/15/2023
[Signature] William Welter, as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC. Date: June 15, 2023
STRIKEPOINT CONSULTING, LLC
[Signature] Cheri Nolan, CFO and President of Strikepoint Consulting, LLC. Date: 6/15/2023
[Signature] William Welter, Managing Director of Strikepoint Consulting, LLC. Date: June 15, 2023
12
entityobservation
Mark D. Schmidt
Read the anchor · page 13
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 13 of 13 PageID#2784
IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals.
[Signature] Charles Watts, Jr. in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Date: 06/15/2023
[Signature] Mark D. Schmidt, individually and on behalf of Cyberlux Corporation, as its President. Date: 06/15/2023
[Signature] William Welter, as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC. Date: June 15, 2023
STRIKEPOINT CONSULTING, LLC
[Signature] Cheri Nolan, CFO and President of Strikepoint Consulting, LLC. Date: 6/15/2023
[Signature] William Welter, Managing Director of Strikepoint Consulting, LLC. Date: June 15, 2023
12
entityobservation
Atlantic Wave Holdings, LLC
Read the anchor · page 13
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 13 of 13 PageID#2784
IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals.
[Signature] Charles Watts, Jr. in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Date: 06/15/2023
[Signature] Mark D. Schmidt, individually and on behalf of Cyberlux Corporation, as its President. Date: 06/15/2023
[Signature] William Welter, as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC. Date: June 15, 2023
STRIKEPOINT CONSULTING, LLC
[Signature] Cheri Nolan, CFO and President of Strikepoint Consulting, LLC. Date: 6/15/2023
[Signature] William Welter, Managing Director of Strikepoint Consulting, LLC. Date: June 15, 2023
12
entityobservation
Secure Community, LLC
Read the anchor · page 13
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 13 of 13 PageID#2784
IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals.
[Signature] Charles Watts, Jr. in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Date: 06/15/2023
[Signature] Mark D. Schmidt, individually and on behalf of Cyberlux Corporation, as its President. Date: 06/15/2023
[Signature] William Welter, as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC. Date: June 15, 2023
STRIKEPOINT CONSULTING, LLC
[Signature] Cheri Nolan, CFO and President of Strikepoint Consulting, LLC. Date: 6/15/2023
[Signature] William Welter, Managing Director of Strikepoint Consulting, LLC. Date: June 15, 2023
12
entityobservation
Strikepoint Consulting, LLC
Read the anchor · page 13
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 13 of 13 PageID#2784
IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals.
[Signature] Charles Watts, Jr. in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Date: 06/15/2023
[Signature] Mark D. Schmidt, individually and on behalf of Cyberlux Corporation, as its President. Date: 06/15/2023
[Signature] William Welter, as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC. Date: June 15, 2023
STRIKEPOINT CONSULTING, LLC
[Signature] Cheri Nolan, CFO and President of Strikepoint Consulting, LLC. Date: 6/15/2023
[Signature] William Welter, Managing Director of Strikepoint Consulting, LLC. Date: June 15, 2023
12
entityobservation
William Welter
Read the anchor · page 13
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 13 of 13 PageID#2784
IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals.
[Signature] Charles Watts, Jr. in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Date: 06/15/2023
[Signature] Mark D. Schmidt, individually and on behalf of Cyberlux Corporation, as its President. Date: 06/15/2023
[Signature] William Welter, as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC. Date: June 15, 2023
STRIKEPOINT CONSULTING, LLC
[Signature] Cheri Nolan, CFO and President of Strikepoint Consulting, LLC. Date: 6/15/2023
[Signature] William Welter, Managing Director of Strikepoint Consulting, LLC. Date: June 15, 2023
12
entityobservation
Cheri Nolan
Read the anchor · page 13
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 13 of 13 PageID#2784
IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals.
[Signature] Charles Watts, Jr. in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Date: 06/15/2023
[Signature] Mark D. Schmidt, individually and on behalf of Cyberlux Corporation, as its President. Date: 06/15/2023
[Signature] William Welter, as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC. Date: June 15, 2023
STRIKEPOINT CONSULTING, LLC
[Signature] Cheri Nolan, CFO and President of Strikepoint Consulting, LLC. Date: 6/15/2023
[Signature] William Welter, Managing Director of Strikepoint Consulting, LLC. Date: June 15, 2023
12
entityobservation
Charles Watts, Jr.
Read the anchor · page 13
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 13 of 13 PageID#2784
IN WITNESS WHEREOF, and intending to be legally bound, the Parties hereto set their hands and seals.
[Signature] Charles Watts, Jr. in his capacity as Special Counsel for Cyberlux Corporation and Mark D. Schmidt. Date: 06/15/2023
[Signature] Mark D. Schmidt, individually and on behalf of Cyberlux Corporation, as its President. Date: 06/15/2023
[Signature] William Welter, as a Managing Director of Atlantic Wave Holdings, LLC and Secure Community, LLC. Date: June 15, 2023
STRIKEPOINT CONSULTING, LLC
[Signature] Cheri Nolan, CFO and President of Strikepoint Consulting, LLC. Date: 6/15/2023
[Signature] William Welter, Managing Director of Strikepoint Consulting, LLC. Date: June 15, 2023
12
inferenceinference
The agreement connects drone cash receipts, settlement repayment, security and bounded information access while preserving a separate stock
The agreement connects drone cash receipts, settlement repayment, security and bounded information access while preserving a separate stock remedy. Those distinct provisions explain later claims but do not establish receipt, priority, breach or the amount of stock damages.
omissiongap
The referenced consent-judgment Exhibit A and original pages beyond agreement page12, performance records and later amendments are absent.
Read the anchor · page 1
EXHIBIT 9
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 1 of 13 PageID#
2772
otherattribution
Complete supplied 13-page source reviewed at SHA-256 c2fae6b706e9814954aa031217a785138e7d463f6079066dbc6c7a7a873dc403. Source assertions, or
Complete supplied 13-page source reviewed at SHA-256 c2fae6b706e9814954aa031217a785138e7d463f6079066dbc6c7a7a873dc403. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Exact version_8f395526823d4c57aa40e5a6a6462a20; SHA256 c2fae6b706e9814954aa031217a785138e7d463f6079066dbc6c7a7a873dc403. All13 supplied pages read; signatures, acceleration and disclosure limits visually checked. Original extraction/bytes preserved; signature-page readable text corrected from image.
Read the anchor · page 1
EXHIBIT 9
Case 3:25-cv-00483-JAG Document 175-11 Filed 04/15/26 Page 1 of 13 PageID#
2772
questionquestion
What complete consent-judgment attachment, actual payment ledger, notices, amendments and later orders reconcile performance, instalment rou
What complete consent-judgment attachment, actual payment ledger, notices, amendments and later orders reconcile performance, instalment rounding and remaining secured claims?
distillategap
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Paragraph 7 grants plaintiffs a full security and lien interest in all defendants’ assets, including IP, subsidiaries, contractual rights, receivables and drone sales, with optional UCC memorialisation. Paragraph 8 requires requested negotiation/payment updates and documents only to the extent not classified or restricted, with confidentiality cross-reference printed as paragraph 12 although confidentiality appears at 13. The visible highlight/underline cannot be attributed to a particular annotator.supportsWalton’s May 19 9:56 AM reply expressly asserts secured claims above the $1.44 million summons, citing settlement provisions on breach-related fees, stock-status damages and all assets. He alleges defaults permitting enforcement and says Virginia, Texas and North Carolina UCC forms are attached. Those Atlantic Wave forms are not included here; the exhibit ends with two Legalist forms. He authorises direct discussion with Will Welter.
Actual paragraph7 supports counsel’s description of all-assets grant, without deciding perfected priority or claim coverage.
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.
The April 15, 2026 Exhibit 9 contains a settlement dated June 15, 2023 among Atlantic Wave, Secure Community, Cyberlux, Schmidt and Strikepoint. Signatures appear for special counsel Charles Watts Jr., Schmidt individually and as Cyberlux president, Welter for AWH/SC and Strikepoint, and Cheri Nolan for Strikepoint, each dated June 15. The file contains agreement pages 1–12; print footers indicate an original 15-page document, and the referenced consent-judgment Exhibit A is absent.supportsThe referenced consent-judgment Exhibit A and original pages beyond agreement page12, performance records and later amendments are absent.
Specifically named source propositions support the bounded distinction or question.
Paragraph 7 grants plaintiffs a full security and lien interest in all defendants’ assets, including IP, subsidiaries, contractual rights, receivables and drone sales, with optional UCC memorialisation. Paragraph 8 requires requested negotiation/payment updates and documents only to the extent not classified or restricted, with confidentiality cross-reference printed as paragraph 12 although confidentiality appears at 13. The visible highlight/underline cannot be attributed to a particular annotator.supportsWhat does this signed settlement add to later creditor summaries?
Specifically named source propositions support the bounded distinction or question.
Paragraph 7 grants plaintiffs a full security and lien interest in all defendants’ assets, including IP, subsidiaries, contractual rights, receivables and drone sales, with optional UCC memorialisation. Paragraph 8 requires requested negotiation/payment updates and documents only to the extent not classified or restricted, with confidentiality cross-reference printed as paragraph 12 although confidentiality appears at 13. The visible highlight/underline cannot be attributed to a particular annotator.supportsThe agreement connects drone cash receipts, settlement repayment, security and bounded information access while preserving a separate stock remedy. Those distinct provisions explain later claims but do not establish receipt, priority, breach or the amount of stock damages.
Specifically named source propositions support the bounded distinction or question.
Defendants undertake $3,895 and $6,842.50 sanctions within 21 days of execution; a $150,000 first settlement payment with specified execution/judgment/revenue conditions and an outer 45-day limit; 36 monthly $21,459 payments to plaintiffs and 36 monthly $18,055.56 payments to Strikepoint from July 2023. Actual receipt is required. Arithmetic gives $922,524 including the first payment, $24 above stated IP balance, and $650,000.16 for Strikepoint, $0.16 above its stated balance; no final-payment adjustment is supplied.supportsWhat complete consent-judgment attachment, actual payment ledger, notices, amendments and later orders reconcile performance, instalment rounding and remaining secured claims?
Specifically named source propositions support the bounded distinction or question.
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.supportsThe agreement connects drone cash receipts, settlement repayment, security and bounded information access while preserving a separate stock remedy. Those distinct provisions explain later claims but do not establish receipt, priority, breach or the amount of stock damages.
Specifically named source propositions support the bounded distinction or question.
Defendants undertake $3,895 and $6,842.50 sanctions within 21 days of execution; a $150,000 first settlement payment with specified execution/judgment/revenue conditions and an outer 45-day limit; 36 monthly $21,459 payments to plaintiffs and 36 monthly $18,055.56 payments to Strikepoint from July 2023. Actual receipt is required. Arithmetic gives $922,524 including the first payment, $24 above stated IP balance, and $650,000.16 for Strikepoint, $0.16 above its stated balance; no final-payment adjustment is supplied.supportsWhat does this signed settlement add to later creditor summaries?
Specifically named source propositions support the bounded distinction or question.
The agreement provides integration and written modification, severability, counsel opportunity, electronic counterparts, authority representations and joint construction. Remedies include enforcement relief; late payments are defined by first-of-month receipt and requested information due within ten calendar days with three-day cure. Virginia law and exclusive Richmond state or federal venue are stated, with submission to jurisdiction. No later amendment or enforcement ruling is included.supportsThe referenced consent-judgment Exhibit A and original pages beyond agreement page12, performance records and later amendments are absent.
Specifically named source propositions support the bounded distinction or question.
The agreement provides integration and written modification, severability, counsel opportunity, electronic counterparts, authority representations and joint construction. Remedies include enforcement relief; late payments are defined by first-of-month receipt and requested information due within ten calendar days with three-day cure. Virginia law and exclusive Richmond state or federal venue are stated, with submission to jurisdiction. No later amendment or enforcement ruling is included.supportsWhat complete consent-judgment attachment, actual payment ledger, notices, amendments and later orders reconcile performance, instalment rounding and remaining secured claims?
Specifically named source propositions support the bounded distinction or question.
Both monthly-payment provisions contain acceleration language up to $5,000 per drone sold within 21 days of defendants or their parent, subsidiary, affiliate or assign first receiving payment under any drone purchase contract. This is broader than an HII-only trigger and is conditional on actual receipt. Repeated wording should not automatically be aggregated into a separate $10,000-per-drone obligation without interpretation.supportsThe agreement connects drone cash receipts, settlement repayment, security and bounded information access while preserving a separate stock remedy. Those distinct provisions explain later claims but do not establish receipt, priority, breach or the amount of stock damages.
Specifically named source propositions support the bounded distinction or question.
Litigation costs including legal and expert fees are due within 60 days or agreed terms, capped for settled matters at 12% or $188,700, arithmetically 12% of $1,572,500. The cap expressly does not restrict breach-related fees; paragraph 19 separately obligates defendants for plaintiffs’ fees and costs in actions caused by breach. This establishes contract language, not the reasonableness or award of any later invoice.supportsWhat does this signed settlement add to later creditor summaries?
Specifically named source propositions support the bounded distinction or question.
The April 15, 2026 Exhibit 9 contains a settlement dated June 15, 2023 among Atlantic Wave, Secure Community, Cyberlux, Schmidt and Strikepoint. Signatures appear for special counsel Charles Watts Jr., Schmidt individually and as Cyberlux president, Welter for AWH/SC and Strikepoint, and Cheri Nolan for Strikepoint, each dated June 15. The file contains agreement pages 1–12; print footers indicate an original 15-page document, and the referenced consent-judgment Exhibit A is absent.supportsWhat complete consent-judgment attachment, actual payment ledger, notices, amendments and later orders reconcile performance, instalment rounding and remaining secured claims?
Specifically named source propositions support the bounded distinction or question.
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.supportsWhat does this signed settlement add to later creditor summaries?
Specifically named source propositions support the bounded distinction or question.
The agreement marks judgment satisfied upon all sums paid and requires plaintiffs’ notice within ten business days after complete consideration and satisfaction of all terms. Releases are asymmetrical in timing: defendants release on endorsement with stated enforcement exceptions; plaintiffs and Strikepoint release on first-payment receipt. No payment receipt or notice of satisfaction is attached.supportsThe referenced consent-judgment Exhibit A and original pages beyond agreement page12, performance records and later amendments are absent.
Specifically named source propositions support the bounded distinction or question.
Defendants undertake reasonable compliance and OTC remediation efforts and good-faith assistance to make shares acceptable to a reputable broker. They represent relied-on financial statements as prepared in good faith under OTC standards and materially accurate. These are representations/effort duties, not independent findings of financial accuracy, regulatory compliance or successful stock remediation.supportsThe agreement connects drone cash receipts, settlement repayment, security and bounded information access while preserving a separate stock remedy. Those distinct provisions explain later claims but do not establish receipt, priority, breach or the amount of stock damages.
Specifically named source propositions support the bounded distinction or question.
Litigation costs including legal and expert fees are due within 60 days or agreed terms, capped for settled matters at 12% or $188,700, arithmetically 12% of $1,572,500. The cap expressly does not restrict breach-related fees; paragraph 19 separately obligates defendants for plaintiffs’ fees and costs in actions caused by breach. This establishes contract language, not the reasonableness or award of any later invoice.supportsWhat complete consent-judgment attachment, actual payment ledger, notices, amendments and later orders reconcile performance, instalment rounding and remaining secured claims?
Specifically named source propositions support the bounded distinction or question.
Both monthly-payment provisions contain acceleration language up to $5,000 per drone sold within 21 days of defendants or their parent, subsidiary, affiliate or assign first receiving payment under any drone purchase contract. This is broader than an HII-only trigger and is conditional on actual receipt. Repeated wording should not automatically be aggregated into a separate $10,000-per-drone obligation without interpretation.supportsWhat does this signed settlement add to later creditor summaries?
Specifically named source propositions support the bounded distinction or question.
The agreement marks judgment satisfied upon all sums paid and requires plaintiffs’ notice within ten business days after complete consideration and satisfaction of all terms. Releases are asymmetrical in timing: defendants release on endorsement with stated enforcement exceptions; plaintiffs and Strikepoint release on first-payment receipt. No payment receipt or notice of satisfaction is attached.supportsWhat complete consent-judgment attachment, actual payment ledger, notices, amendments and later orders reconcile performance, instalment rounding and remaining secured claims?
Specifically named source propositions support the bounded distinction or question.
WEIGH
Explained weighting
A score appears only when its components and change threshold are published.
No published WEIGH run
The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.