Context source · CXF-S-DCA49912CE86

6January2026 creditor motion seeks857734.19fee distribution from receiver

SHA-256 dca49912ce86ad664791…6 pages · 315 KB

DISTILLATES

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observationobservation

Requested857734.19; asserted receiverfund3083639.75; two-business-day deadline conditional on court order.

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants/Judgment-Debtors. § § § § § § § § § IN THE DISTRICT COURT 129th JUDICIAL DISTRICT HARRIS COUNTY, TEXAS PLAINTIFFS’ SECOND AMENDED MOTION FOR DISTRIBUTION OF FUNDS Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC (Plaintiffs) file this second amended motion seeking court approval for the distribution of non- exempt funds held by the Receiver under the Order Appointing Receiver (Receivership Order), signed on May 22, 2025. I. INTRODUCTION On June 23, 2023, a Virginia state court presiding over Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt , Case No. CL22-3882-4, in the Circuit Court of the City of Richmond, State of Virginia, entered a Judgment (Underlying Judgment) in favor of Plaintiffs and against Defendants/Judgment-Debtors Cyberlux Corporation and Mark D. Schmidt (Defendants), in the principal sum of $1,572,500.00 plus costs, fees, and sanctions. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court. After significant gamesmanship and litigation tactics deployed by Defendants to avoid satisfying the Underlying Judgment, on May 22, 2025, pursuant to Texas Civil Practice & Remedies Code § 31.002(b)(3), this Court signed the Receivership Order. The Receivership Order appointed Receiver, among other duties and responsibilities, “to take possession of [Cyberlux 1/6/2026 6:47 PM Marilyn Burgess - District Clerk Harris County Envelope No. 109732259 By: Shanelle Taylor Filed: 1/6/2026 6:47 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 2 of 6 PageID# 2815

claimallegation

HarrisCounty2024-48085 second-amended distribution motion filed6January2026 at6:47PM, /s/DanielArdmore, reproduced as EDVA175-16filed15April

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EXHIBIT 14 Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 1 of 6 PageID# 2814

claimallegation

Plaintiffs describe23June2023Richmond1,572,500judgment,30July2024enforcement petition and22May2025receivership; allege receiver took$3,083,6

Plaintiffs describe23June2023Richmond1,572,500judgment,30July2024enforcement petition and22May2025receivership; allege receiver took$3,083,639.75non-exempt Cyberlux funds inJune2025 and stillholds them. No bankstatement or turnover inventory supplied.

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants/Judgment-Debtors. § § § § § § § § § IN THE DISTRICT COURT 129th JUDICIAL DISTRICT HARRIS COUNTY, TEXAS PLAINTIFFS’ SECOND AMENDED MOTION FOR DISTRIBUTION OF FUNDS Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC (Plaintiffs) file this second amended motion seeking court approval for the distribution of non- exempt funds held by the Receiver under the Order Appointing Receiver (Receivership Order), signed on May 22, 2025. I. INTRODUCTION On June 23, 2023, a Virginia state court presiding over Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt , Case No. CL22-3882-4, in the Circuit Court of the City of Richmond, State of Virginia, entered a Judgment (Underlying Judgment) in favor of Plaintiffs and against Defendants/Judgment-Debtors Cyberlux Corporation and Mark D. Schmidt (Defendants), in the principal sum of $1,572,500.00 plus costs, fees, and sanctions. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court. After significant gamesmanship and litigation tactics deployed by Defendants to avoid satisfying the Underlying Judgment, on May 22, 2025, pursuant to Texas Civil Practice & Remedies Code § 31.002(b)(3), this Court signed the Receivership Order. The Receivership Order appointed Receiver, among other duties and responsibilities, “to take possession of [Cyberlux 1/6/2026 6:47 PM Marilyn Burgess - District Clerk Harris County Envelope No. 109732259 By: Shanelle Taylor Filed: 1/6/2026 6:47 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 2 of 6 PageID# 2815

claimallegation

They state FairfaxCL-2025-3413order14November2025 directed$952,601.71principal balance plus$187,399.95Virginiafees/costs, then report$1,140,

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2 Corporation] property, sell it, and pay the proceeds to [Plaintiffs] to the extent required to satisfy the judgment.” In June of 2025, over six months ago, Receiver took possession of $3,083,639.75 in non- exempt funds of Cyberlux Corporation under the Receivership Order. Paragraph 53 of the Receivership Order directs Receiver to pay the funds, after set offs as Receiver deems reasonable, to Plaintiffs within a reasonable time. In a contemporaneous garnishment proceeding in Virginia, on November 14, 2025, the Circuit Court of Fairfax County, Virginia in Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation, Case No. CL-2025-3413 entered its Final Order (Order) which, among other things, ordered the Virginia court clerk 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. On November 18, 2025, $1,140,004.66 of the garnished funds was disbursed to Plaintiffs. While the Virginia state court ruled Plaintiffs are entitled to all costs and fees by statute and under the Settlement Agreement, the Virginia state court only had jurisdiction to award costs and fees incurred in the Virginia state court proceedings. As a result, Plaintiffs’ reasonable attorneys’ fees and costs incurred in this enforcement proceeding remain outstanding. Plaintiffs are owed at least $857,734.19 in reasonable attorneys’ fees and cost in this Texas enforcement proceeding and the other related proceedings in Texas. Rather than satisfy the judgment in June of 2023, Defendants chose to resist, delay, and interfere with Plaintiffs’ collection efforts needlessly increasing interest accrued on the judgment as well as attorney fees and costs incurred by Plaintiffs. For example, Defendants filed numerous unsuccessful motions in this Court, filed two unsuccessful removals to Texas federal court (one of which led to sanctions UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 3 of 6 PageID# 2816

claimallegation

Plaintiffs assert at least$857,734.19Texasfees/costs remain, say invoices/affidavits supplied toreceiver and offer in-camera production. Ask

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2 Corporation] property, sell it, and pay the proceeds to [Plaintiffs] to the extent required to satisfy the judgment.” In June of 2025, over six months ago, Receiver took possession of $3,083,639.75 in non- exempt funds of Cyberlux Corporation under the Receivership Order. Paragraph 53 of the Receivership Order directs Receiver to pay the funds, after set offs as Receiver deems reasonable, to Plaintiffs within a reasonable time. In a contemporaneous garnishment proceeding in Virginia, on November 14, 2025, the Circuit Court of Fairfax County, Virginia in Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation, Case No. CL-2025-3413 entered its Final Order (Order) which, among other things, ordered the Virginia court clerk 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. On November 18, 2025, $1,140,004.66 of the garnished funds was disbursed to Plaintiffs. While the Virginia state court ruled Plaintiffs are entitled to all costs and fees by statute and under the Settlement Agreement, the Virginia state court only had jurisdiction to award costs and fees incurred in the Virginia state court proceedings. As a result, Plaintiffs’ reasonable attorneys’ fees and costs incurred in this enforcement proceeding remain outstanding. Plaintiffs are owed at least $857,734.19 in reasonable attorneys’ fees and cost in this Texas enforcement proceeding and the other related proceedings in Texas. Rather than satisfy the judgment in June of 2023, Defendants chose to resist, delay, and interfere with Plaintiffs’ collection efforts needlessly increasing interest accrued on the judgment as well as attorney fees and costs incurred by Plaintiffs. For example, Defendants filed numerous unsuccessful motions in this Court, filed two unsuccessful removals to Texas federal court (one of which led to sanctions UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 3 of 6 PageID# 2816

claimallegation

Motion expressly excludes RichmondstockCL24003910, EDVAinterpleader3:25-cv-00483 and other distinct unpleaded claims. It seeks liquidated un

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3 and an admonition being imposed against Defendants), and initiated and filed multiple unsuccessful challenges to the Court of Appeals, First District of Texas. II. ARGUMENT This motion resolves the liquidated damages of the Underlying Judgment in this enforcement action. This motion does not resolve matters before the Richmond, Virginia, Circuit Court, Cause No. CL24003910 (Stock Case), the interpleader action before the United States District Court for the Eastern District of Virginia, Richmond Division, Case 3:25-cv-00483 (Interpleader Action), or any other separate and distinct claims not specifically pleaded in this enforcement action. Under section 31.002(e) of the Texas Civil Practice and Remedies Code and the Settlement Agreement, Plaintiffs are “entitled to recover reasonable costs, including attorney’s fees.” Plaintiffs have provided to Receiver true and correct copies of the attorneys’ fees and costs incurred by Plaintiffs in the Texas proceedings, and supporting attorney fee affidavits, for review and consideration, and Plaintiffs will proffer the same documents to the Court for in camera inspection if necessary. Accordingly, Plaintiffs hereby contend that the Rohrmoos Ventures elements have been satisfied and that Plaintiffs’ reasonable attorneys’ fees and costs incurred and recoverable under Tex. Civ. Prac. & Rem. Code § 31.002(e) (and the Settlement Agreement) are at least, $ 857,734.19 and further contends that Receiver should promptly pay $857,734.19 to Plaintiffs from the $3,083,639.75 in non-exempt funds currently held by Receiver under the Receivership Order. UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 4 of 6 PageID# 2817

claimallegation

Alleged gamesmanship, unsuccessful removals/appeals and resulting fee increases are advocates’ explanation; cited sanctions and fee-law enti

Alleged gamesmanship, unsuccessful removals/appeals and resulting fee increases are advocates’ explanation; cited sanctions and fee-law entitlement require original rulings and reasonable-fee proof.

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2 Corporation] property, sell it, and pay the proceeds to [Plaintiffs] to the extent required to satisfy the judgment.” In June of 2025, over six months ago, Receiver took possession of $3,083,639.75 in non- exempt funds of Cyberlux Corporation under the Receivership Order. Paragraph 53 of the Receivership Order directs Receiver to pay the funds, after set offs as Receiver deems reasonable, to Plaintiffs within a reasonable time. In a contemporaneous garnishment proceeding in Virginia, on November 14, 2025, the Circuit Court of Fairfax County, Virginia in Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation, Case No. CL-2025-3413 entered its Final Order (Order) which, among other things, ordered the Virginia court clerk 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. On November 18, 2025, $1,140,004.66 of the garnished funds was disbursed to Plaintiffs. While the Virginia state court ruled Plaintiffs are entitled to all costs and fees by statute and under the Settlement Agreement, the Virginia state court only had jurisdiction to award costs and fees incurred in the Virginia state court proceedings. As a result, Plaintiffs’ reasonable attorneys’ fees and costs incurred in this enforcement proceeding remain outstanding. Plaintiffs are owed at least $857,734.19 in reasonable attorneys’ fees and cost in this Texas enforcement proceeding and the other related proceedings in Texas. Rather than satisfy the judgment in June of 2023, Defendants chose to resist, delay, and interfere with Plaintiffs’ collection efforts needlessly increasing interest accrued on the judgment as well as attorney fees and costs incurred by Plaintiffs. For example, Defendants filed numerous unsuccessful motions in this Court, filed two unsuccessful removals to Texas federal court (one of which led to sanctions UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 3 of 6 PageID# 2816

entityobservation

Atlantic Wave Holdings, LLC

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants/Judgment-Debtors. § § § § § § § § § IN THE DISTRICT COURT 129th JUDICIAL DISTRICT HARRIS COUNTY, TEXAS PLAINTIFFS’ SECOND AMENDED MOTION FOR DISTRIBUTION OF FUNDS Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC (Plaintiffs) file this second amended motion seeking court approval for the distribution of non- exempt funds held by the Receiver under the Order Appointing Receiver (Receivership Order), signed on May 22, 2025. I. INTRODUCTION On June 23, 2023, a Virginia state court presiding over Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt , Case No. CL22-3882-4, in the Circuit Court of the City of Richmond, State of Virginia, entered a Judgment (Underlying Judgment) in favor of Plaintiffs and against Defendants/Judgment-Debtors Cyberlux Corporation and Mark D. Schmidt (Defendants), in the principal sum of $1,572,500.00 plus costs, fees, and sanctions. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court. After significant gamesmanship and litigation tactics deployed by Defendants to avoid satisfying the Underlying Judgment, on May 22, 2025, pursuant to Texas Civil Practice & Remedies Code § 31.002(b)(3), this Court signed the Receivership Order. The Receivership Order appointed Receiver, among other duties and responsibilities, “to take possession of [Cyberlux 1/6/2026 6:47 PM Marilyn Burgess - District Clerk Harris County Envelope No. 109732259 By: Shanelle Taylor Filed: 1/6/2026 6:47 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 2 of 6 PageID# 2815

entityobservation

Secure Community, LLC

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants/Judgment-Debtors. § § § § § § § § § IN THE DISTRICT COURT 129th JUDICIAL DISTRICT HARRIS COUNTY, TEXAS PLAINTIFFS’ SECOND AMENDED MOTION FOR DISTRIBUTION OF FUNDS Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC (Plaintiffs) file this second amended motion seeking court approval for the distribution of non- exempt funds held by the Receiver under the Order Appointing Receiver (Receivership Order), signed on May 22, 2025. I. INTRODUCTION On June 23, 2023, a Virginia state court presiding over Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt , Case No. CL22-3882-4, in the Circuit Court of the City of Richmond, State of Virginia, entered a Judgment (Underlying Judgment) in favor of Plaintiffs and against Defendants/Judgment-Debtors Cyberlux Corporation and Mark D. Schmidt (Defendants), in the principal sum of $1,572,500.00 plus costs, fees, and sanctions. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court. After significant gamesmanship and litigation tactics deployed by Defendants to avoid satisfying the Underlying Judgment, on May 22, 2025, pursuant to Texas Civil Practice & Remedies Code § 31.002(b)(3), this Court signed the Receivership Order. The Receivership Order appointed Receiver, among other duties and responsibilities, “to take possession of [Cyberlux 1/6/2026 6:47 PM Marilyn Burgess - District Clerk Harris County Envelope No. 109732259 By: Shanelle Taylor Filed: 1/6/2026 6:47 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 2 of 6 PageID# 2815

entityobservation

Cyberlux Corporation

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2 Corporation] property, sell it, and pay the proceeds to [Plaintiffs] to the extent required to satisfy the judgment.” In June of 2025, over six months ago, Receiver took possession of $3,083,639.75 in non- exempt funds of Cyberlux Corporation under the Receivership Order. Paragraph 53 of the Receivership Order directs Receiver to pay the funds, after set offs as Receiver deems reasonable, to Plaintiffs within a reasonable time. In a contemporaneous garnishment proceeding in Virginia, on November 14, 2025, the Circuit Court of Fairfax County, Virginia in Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation, Case No. CL-2025-3413 entered its Final Order (Order) which, among other things, ordered the Virginia court clerk 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. On November 18, 2025, $1,140,004.66 of the garnished funds was disbursed to Plaintiffs. While the Virginia state court ruled Plaintiffs are entitled to all costs and fees by statute and under the Settlement Agreement, the Virginia state court only had jurisdiction to award costs and fees incurred in the Virginia state court proceedings. As a result, Plaintiffs’ reasonable attorneys’ fees and costs incurred in this enforcement proceeding remain outstanding. Plaintiffs are owed at least $857,734.19 in reasonable attorneys’ fees and cost in this Texas enforcement proceeding and the other related proceedings in Texas. Rather than satisfy the judgment in June of 2023, Defendants chose to resist, delay, and interfere with Plaintiffs’ collection efforts needlessly increasing interest accrued on the judgment as well as attorney fees and costs incurred by Plaintiffs. For example, Defendants filed numerous unsuccessful motions in this Court, filed two unsuccessful removals to Texas federal court (one of which led to sanctions UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 3 of 6 PageID# 2816

entityobservation

Mark D. Schmidt

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants/Judgment-Debtors. § § § § § § § § § IN THE DISTRICT COURT 129th JUDICIAL DISTRICT HARRIS COUNTY, TEXAS PLAINTIFFS’ SECOND AMENDED MOTION FOR DISTRIBUTION OF FUNDS Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC (Plaintiffs) file this second amended motion seeking court approval for the distribution of non- exempt funds held by the Receiver under the Order Appointing Receiver (Receivership Order), signed on May 22, 2025. I. INTRODUCTION On June 23, 2023, a Virginia state court presiding over Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt , Case No. CL22-3882-4, in the Circuit Court of the City of Richmond, State of Virginia, entered a Judgment (Underlying Judgment) in favor of Plaintiffs and against Defendants/Judgment-Debtors Cyberlux Corporation and Mark D. Schmidt (Defendants), in the principal sum of $1,572,500.00 plus costs, fees, and sanctions. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court. After significant gamesmanship and litigation tactics deployed by Defendants to avoid satisfying the Underlying Judgment, on May 22, 2025, pursuant to Texas Civil Practice & Remedies Code § 31.002(b)(3), this Court signed the Receivership Order. The Receivership Order appointed Receiver, among other duties and responsibilities, “to take possession of [Cyberlux 1/6/2026 6:47 PM Marilyn Burgess - District Clerk Harris County Envelope No. 109732259 By: Shanelle Taylor Filed: 1/6/2026 6:47 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 2 of 6 PageID# 2815

entityobservation

Robert W. Berleth

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4 III. CONCLUSION WHEREFORE, PREMISES CONSIDERED, Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC, respectfully ask that this Court order Receiver Robert W. Berleth and Berleth & Associates, PLLC, to disburse $857,734.19 to Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC, within two business days of entry of this Court’s order. Dated: January 6, 2026. By: /s/ Daniel A. Ardmore Daniel A. Ardmore Texas Bar No. 24142224 ardmorelawfirm@gmail.com Ardmore Law Firm, PLLC. 20333 State Highway 249, Suite 200 Houston, TX 77070 Tel. (832) 930-1116 James K. Sadigh Texas Bar No. 24129140 jamessadigh@aol.com Attorney at Law 9777 Wilshire Boulevard, Suite 400 Beverly Hills, CA 90212-1910 Tel. (310) 747-5919 David A. Walton Texas Bar No. 24042120 dwalton@bellnunnally.com Bell Nunnally & Martin, LLP 2323 Ross Avenue, Suite 1900 Dallas, Texas 75201 Tel. (214) 740-1445 Attorneys for Atlantic Wave Holdings, LLC, and Secure Community, LLC UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 5 of 6 PageID# 2818

entityobservation

Daniel A. Ardmore

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4 III. CONCLUSION WHEREFORE, PREMISES CONSIDERED, Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC, respectfully ask that this Court order Receiver Robert W. Berleth and Berleth & Associates, PLLC, to disburse $857,734.19 to Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC, within two business days of entry of this Court’s order. Dated: January 6, 2026. By: /s/ Daniel A. Ardmore Daniel A. Ardmore Texas Bar No. 24142224 ardmorelawfirm@gmail.com Ardmore Law Firm, PLLC. 20333 State Highway 249, Suite 200 Houston, TX 77070 Tel. (832) 930-1116 James K. Sadigh Texas Bar No. 24129140 jamessadigh@aol.com Attorney at Law 9777 Wilshire Boulevard, Suite 400 Beverly Hills, CA 90212-1910 Tel. (310) 747-5919 David A. Walton Texas Bar No. 24042120 dwalton@bellnunnally.com Bell Nunnally & Martin, LLP 2323 Ross Avenue, Suite 1900 Dallas, Texas 75201 Tel. (214) 740-1445 Attorneys for Atlantic Wave Holdings, LLC, and Secure Community, LLC UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 5 of 6 PageID# 2818

entityobservation

James K. Sadigh

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4 III. CONCLUSION WHEREFORE, PREMISES CONSIDERED, Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC, respectfully ask that this Court order Receiver Robert W. Berleth and Berleth & Associates, PLLC, to disburse $857,734.19 to Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC, within two business days of entry of this Court’s order. Dated: January 6, 2026. By: /s/ Daniel A. Ardmore Daniel A. Ardmore Texas Bar No. 24142224 ardmorelawfirm@gmail.com Ardmore Law Firm, PLLC. 20333 State Highway 249, Suite 200 Houston, TX 77070 Tel. (832) 930-1116 James K. Sadigh Texas Bar No. 24129140 jamessadigh@aol.com Attorney at Law 9777 Wilshire Boulevard, Suite 400 Beverly Hills, CA 90212-1910 Tel. (310) 747-5919 David A. Walton Texas Bar No. 24042120 dwalton@bellnunnally.com Bell Nunnally & Martin, LLP 2323 Ross Avenue, Suite 1900 Dallas, Texas 75201 Tel. (214) 740-1445 Attorneys for Atlantic Wave Holdings, LLC, and Secure Community, LLC UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 5 of 6 PageID# 2818

entityobservation

David A. Walton

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4 III. CONCLUSION WHEREFORE, PREMISES CONSIDERED, Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC, respectfully ask that this Court order Receiver Robert W. Berleth and Berleth & Associates, PLLC, to disburse $857,734.19 to Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC, within two business days of entry of this Court’s order. Dated: January 6, 2026. By: /s/ Daniel A. Ardmore Daniel A. Ardmore Texas Bar No. 24142224 ardmorelawfirm@gmail.com Ardmore Law Firm, PLLC. 20333 State Highway 249, Suite 200 Houston, TX 77070 Tel. (832) 930-1116 James K. Sadigh Texas Bar No. 24129140 jamessadigh@aol.com Attorney at Law 9777 Wilshire Boulevard, Suite 400 Beverly Hills, CA 90212-1910 Tel. (310) 747-5919 David A. Walton Texas Bar No. 24042120 dwalton@bellnunnally.com Bell Nunnally & Martin, LLP 2323 Ross Avenue, Suite 1900 Dallas, Texas 75201 Tel. (214) 740-1445 Attorneys for Atlantic Wave Holdings, LLC, and Secure Community, LLC UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 5 of 6 PageID# 2818

eventattribution

Texas filed stamp6:47PM.

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1 CAUSE NO. 2024-48085 ATLANTIC WAVE HOLDINGS, LLC AND SECURE COMMUNITY, LLC Plaintiffs/Judgment-Creditors, v. CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendants/Judgment-Debtors. § § § § § § § § § IN THE DISTRICT COURT 129th JUDICIAL DISTRICT HARRIS COUNTY, TEXAS PLAINTIFFS’ SECOND AMENDED MOTION FOR DISTRIBUTION OF FUNDS Plaintiffs/Judgment-Creditors Atlantic Wave Holdings, LLC and Secure Community, LLC (Plaintiffs) file this second amended motion seeking court approval for the distribution of non- exempt funds held by the Receiver under the Order Appointing Receiver (Receivership Order), signed on May 22, 2025. I. INTRODUCTION On June 23, 2023, a Virginia state court presiding over Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation and Mark D. Schmidt , Case No. CL22-3882-4, in the Circuit Court of the City of Richmond, State of Virginia, entered a Judgment (Underlying Judgment) in favor of Plaintiffs and against Defendants/Judgment-Debtors Cyberlux Corporation and Mark D. Schmidt (Defendants), in the principal sum of $1,572,500.00 plus costs, fees, and sanctions. On July 30, 2024, Plaintiffs filed a Petition to Enforce the Underlying Judgment in this Court. After significant gamesmanship and litigation tactics deployed by Defendants to avoid satisfying the Underlying Judgment, on May 22, 2025, pursuant to Texas Civil Practice & Remedies Code § 31.002(b)(3), this Court signed the Receivership Order. The Receivership Order appointed Receiver, among other duties and responsibilities, “to take possession of [Cyberlux 1/6/2026 6:47 PM Marilyn Burgess - District Clerk Harris County Envelope No. 109732259 By: Shanelle Taylor Filed: 1/6/2026 6:47 PM UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 2 of 6 PageID# 2815

eventattribution

Motion alleges Virginia remittance; no receipt supplied.

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2 Corporation] property, sell it, and pay the proceeds to [Plaintiffs] to the extent required to satisfy the judgment.” In June of 2025, over six months ago, Receiver took possession of $3,083,639.75 in non- exempt funds of Cyberlux Corporation under the Receivership Order. Paragraph 53 of the Receivership Order directs Receiver to pay the funds, after set offs as Receiver deems reasonable, to Plaintiffs within a reasonable time. In a contemporaneous garnishment proceeding in Virginia, on November 14, 2025, the Circuit Court of Fairfax County, Virginia in Atlantic Wave Holdings, LLC and Secure Community, LLC v. Cyberlux Corporation, Case No. CL-2025-3413 entered its Final Order (Order) which, among other things, ordered the Virginia court clerk 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. On November 18, 2025, $1,140,004.66 of the garnished funds was disbursed to Plaintiffs. While the Virginia state court ruled Plaintiffs are entitled to all costs and fees by statute and under the Settlement Agreement, the Virginia state court only had jurisdiction to award costs and fees incurred in the Virginia state court proceedings. As a result, Plaintiffs’ reasonable attorneys’ fees and costs incurred in this enforcement proceeding remain outstanding. Plaintiffs are owed at least $857,734.19 in reasonable attorneys’ fees and cost in this Texas enforcement proceeding and the other related proceedings in Texas. Rather than satisfy the judgment in June of 2023, Defendants chose to resist, delay, and interfere with Plaintiffs’ collection efforts needlessly increasing interest accrued on the judgment as well as attorney fees and costs incurred by Plaintiffs. For example, Defendants filed numerous unsuccessful motions in this Court, filed two unsuccessful removals to Texas federal court (one of which led to sanctions UnofficialCopyOfficeofMarilynBurgessDistrictClerk Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 3 of 6 PageID# 2816

inferenceinference

StatedVirginia components sum$1,140,001.66, three dollars less than reported$1,140,004.66remittance. Preserve the discrepancy; no remittance

StatedVirginia components sum$1,140,001.66, three dollars less than reported$1,140,004.66remittance. Preserve the discrepancy; no remittance correction is established.

inferenceinference

Nonopposition and claimed invoice delivery do not prove court-approved fee reasonableness or actual distribution. The express exclusion of s

Nonopposition and claimed invoice delivery do not prove court-approved fee reasonableness or actual distribution. The express exclusion of stock/interpleader matters prevents this request being treated as universal satisfaction.

otherattribution

Complete supplied 6-page source reviewed at SHA-256 dca49912ce86ad6647919ba9b2fa035d1a4cfe04a13ee0bfac38f43e72ce5f9d. Source assertions, ori

Complete supplied 6-page source reviewed at SHA-256 dca49912ce86ad6647919ba9b2fa035d1a4cfe04a13ee0bfac38f43e72ce5f9d. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Own exact SHA256 dca49912ce86ad6647919ba9b2fa035d1a4cfe04a13ee0bfac38f43e72ce5f9d verified; complete own-source text and all rendered pages read. Page-level corrections explicitly attributed; no absent document or performed act inferred.

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EXHIBIT 14 Case 3:25-cv-00483-JAG Document 175-16 Filed 04/15/26 Page 1 of 6 PageID# 2814

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Which order/remittance reconciles the3dollar discrepancy, and which billing/fee order supports857734.19and actual receiver payment?

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The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.

Footnote8 expressly says there is no dispute that receiver obtained3083639.75dollars on or about11June2025. Defence uses that receipt date to argue against later turnover fees; the conceded receipt does not concede fee entitlement or continuing custody.supportsPlaintiffs describe23June2023Richmond1,572,500judgment,30July2024enforcement petition and22May2025receivership; allege receiver took$3,083,639.75non-exempt Cyberlux funds inJune2025 and stillholds them. No bankstatement or turnover inventory supplied.

Opposing parties agree on historical receiver receipt amount; date here approximately11June2025. Not proof of current balance.

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Defendants oppose857734.19dollars sought by plaintiffs, asserting no documentary fee evidence supplied to defendants or court, fee proof and cross-examination rights, and turnover-only recovery under section31.002. They contend their own lawyers billing cannot substitute for plaintiffs proof. These are litigated positions, not findings.qualifiesPlaintiffs assert at least$857,734.19Texasfees/costs remain, say invoices/affidavits supplied toreceiver and offer in-camera production. Ask payment of$857,734.19within two business days of order. Supporting billing and granting order absent; requested timing not actual deadline.

Defence denial concerns production to defendants/court, while plaintiffs claim production to receiver and offer in-camera review.

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Defence characterises Fairfax final order as total claim1140004.66 including187399.95 proven fees/costs, argues plaintiffs already received full payment and are judicially estopped from asserting a larger Texas entitlement. Quoted order and chart are missing; payment and preclusion scope cannot be resolved from this response alone.contradictsPlaintiffs assert at least$857,734.19Texasfees/costs remain, say invoices/affidavits supplied toreceiver and offer in-camera production. Ask payment of$857,734.19within two business days of order. Supporting billing and granting order absent; requested timing not actual deadline.

Defence asserts prior total payment bars additional fees, whereas plaintiffs assert remaining Texas entitlement; legal scope disputed, not adjudicated.

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They state FairfaxCL-2025-3413order14November2025 directed$952,601.71principal balance plus$187,399.95Virginiafees/costs, then report$1,140,004.66disbursed18November. These are motion descriptions; order/remittance records absent.supportsWhich order/remittance reconciles the3dollar discrepancy, and which billing/fee order supports857734.19and actual receiver payment?