EDVA ECF175-22 filed15 April2026; March2 hearing in Harris129th case2024-48085.
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EXHIBIT 20 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 1 of 50 PageID# 2864
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EXHIBIT 20 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 1 of 50 PageID# 2864
16HearingMarch 2, 2026Thursday. That is point No. 1. Point No. 2 is if you wish to take the dueorder of pleadings, the motion to withdraw by ThompsonCoburn has been pending before the Court sinceJanuary 5th. Sign their order on the motion towithdraw, they're out. We will deal with the rest of itwhether at 1:30 or whether at another day that the Courtcan give us at least probably a half a day, if not awhole day. Point No. 3, since Thursday of last week,you now have, at last count, six or seven parties thathave intervened in this lawsuit. Those six or seven arecreditors, who are also joining in the expansion of thereceivership. So this little game that is afoot betweenCyberlux and Atlantic to, A, completely, as Mr. Berlethsaid, hose the receiver, that needs to be shelved. B, the fact that there are other partiesnow before you, who are also judgment creditors, who arealso seeking relief in your court, could never bedisposed of on a two-day motion to dissolve thereceivership. Three, you couldn't ever and wouldn'tever, I imagine, Your Honor, dissolve the receivershipwithout a proper accounting and a report by the 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 17 of 50 PageID# 2880
EDVA 3:25-cv-00483-JAG ECF175-22, filed April15,2026 as Exhibit20, reproduces the March2,2026 Gomez hearing in Harris129th case2024-48085. Jennifer Gajevsky certifies the transcript; filing in EDVA is not adoption of its assertions.
EXHIBIT 20 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 1 of 50 PageID# 2864
Berleth offers interim $873,000 payment and argues it moots the joint motion while leaving expansion for later. Myers explains she seeks only currently available remainder in registry, not clawback of spent payments. Mahendru renews absence of shared settlement and notice objections.
27HearingMarch 2, 2026$1.4 million? They're asking me to distribute all of themoney right now and terminate the receivership and thenlater I can go and fight for my fees, which --THE COURT: Understood.MR. BERLETH: -- I can't do that. If you want to terminate the receivershiptoday, Judge, I have the order that was presented tothis Court months ago that they objected to, withupdated numbers. The receiver's motion to terminate, itgets them what they want. You never have to hear theword "Cyberlux" again. And the other creditors can goand get another receivership out of another court.THE COURT: I'm about to recess thehearing. Is there anything else you want to say?MR. ARDMORE: Thank you, Your Honor. I think that the fees to pay the attorneysfor the creditor have been agreed by, I think, everyone.So I don't think that there's any dispute over theamount of the fees. It's in the settlement agreement.And Mr. Berleth says that he's got the check ready togo.THE COURT: You're either opposed or inagreement? 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 28 of 50 PageID# 2891
Berleth says $873,000 concerns fees since May22,2025, estimates about $2.6million remains from $3.083million, quotes his invoice exactly $1,594,719.94, and proposes remaining funds go to Virginia. Gomez uses rounded hypothetical arithmetic and says claimed receiver fees need proof and are not necessarily contract-bound; no exact audited balance or approved fee follows.
31HearingMarch 2, 2026fees incurred by Atlantic Waves from May 22nd, 2025, todate, right? That's all that is. That does not addressthe underlying judgment. Originally, this Court asked me to collect$2.1 million. With my expenses and fees on top of thatcame to about $3 million. That $3 million has beenspent in part, but it's mostly sitting intact in myIOLTA. The Texas Access to Justice Foundation is a hugefan of mine now. It's sitting there, waiting ondistribution.THE COURT: Right. So if you have -- andI don't know how much. You said 400,000 to 2.6,roughly?MR. BERLETH: Yeah, it's about there.THE COURT: Okay. It's 2.6. So --MR. BERLETH: I mean, I have spent -- Imean, some of it was money that I spent out of mypocket; and some of it was money that I spent --THE COURT: Let's say there's 2.6. MR. BERLETH: Okay.THE COURT: So if we give them 800, thatgets us to 1.8, right?MR. BERLETH: Ballpark. THE COURT: Yeah.MR. BERLETH: Well, it's actually 873. So 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 32 of 50 PageID# 2895
Myers opposes an interim-only label because the payment settles the Texas matter. Berleth questions existence of a separate agreement; Myers and Ardmore confirm one exists but is confidential. Ardmore says termination is agreed without a fixed date and can proceed in pieces. The agreement itself is not presented in this source.
34HearingMarch 2, 2026today. I have all of my exhibits ready. I have myinvoice ready, and I'm prepared to take on testimony.THE COURT: I'm assuming that they're notand they would probably want an opportunity to talk, butwho knows.MR. BERLETH: That's what filing thingswith three days' notice gets you.THE COURT: Okay. So best -- is it myunderstanding that there's the -- that if there's aninterim -- is there anybody opposed to the interimdisbursement?MS. MYERS: Your Honor, Cyberlux isopposed, because it doesn't take into account the fullscope of the settlement agreement that the parties haveentered into. We don't oppose the amount, but thatamount represents a full settlement and satisfaction ofthe underlying judgment itself, too. And so that's theopposition. And the settlement agreement frankly mootedtheir motion for interim fees, because it was aresolution of everything before this Court.MR. BERLETH: I don't think there is asettlement agreement, as she's saying, Judge. I'veasked them about that. There is the only signeddocument pursuant to what my conversation with 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 35 of 50 PageID# 2898
Gomez queries whether settlement removes the original receiver purpose. Berleth says about $1million original debt remains after $1.1million paid through Virginia. Sadigh/Myers distinguish settlement of Texas issues from excluded Virginia disputes. These positions do not reconcile the debt or decide settlement effect.
38HearingMarch 2, 2026their joint motion as much as -- let's say I grant theirattorney's fees. They get their money.MR. BERLETH: That's it.THE COURT: And they've settled it --outside they've settled it anyway, then --MR. BERLETH: Sure. Well, they still haveto settle my fee; but yeah.THE COURT: Settle the fee. MR. BERLETH: Correct.THE COURT: But I haven't wound up thereceivership, there hasn't been an accounting, therehasn't been a prove-up on the attorney's fees. MR. BERLETH: Correct.THE COURT: But basically, the winds areout of the sails, at least with respect to the firstorder that was you collected the money, they've settledtheir claims, you've spent what you've spent, and theclaims have been resolved by the original order toappoint.MR. BERLETH: No. Because that 873represents the fees incurred since the inception of thereceivership. The $2.1 million I was originallyassigned to collect, they've been paid $1.1 millionthrough the Virginia court. There is still a ballpark million dollars 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 39 of 50 PageID# 2902
Gomez grants interim payment, expressly defers the effect of the settlement he has not seen, and says no afternoon hearing will occur. Expansion is not taken that day for lack of time. This is not an order terminating or expanding receivership.
41HearingMarch 2, 2026settlement agreement that the parties have alreadysigned. And so, you know, we don't -- I don't disputethat we have agreed to that amount, but that is asettlement and it resolves all remaining issues in thisTexas action. The parties can go fight in Virginia.Those are excluded from the settlement.THE COURT: Okay. So --MR. BERLETH: It doesn't. You have threeintervenors right there. It doesn't resolve theirissues at all.THE COURT: Understood. So it doesn't sound like I have anyobjection to your interim payment. So I'm going to goahead and grant that.MR. ARDMORE: Thank you. Thank you,Your Honor.THE COURT: The issue of the effect of thesettlement agreement, I don't have it before me. And itlooks like there's issues with scheduling. So we'llneed to take that up at a later point. It sounds likethere's objections and we won't be able to resolve that.So the other issue is the motion towithdraw. Do you still want the Court to consider it,or do you want to hold off on it? 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 42 of 50 PageID# 2905
Priddy says Legalist is owed about $13million, advanced over $3million in June expecting receiver termination, and intervened to protect return of excess and potential expansion rights. He expressly supports the joint relief and preserving excess pending fee resolution, although he has not seen the settlement. He characterises the advance as a loan/protective advance to Cyberlux and the funds as Cyberlux property.
42HearingMarch 2, 2026MS. MYERS: Your Honor, I need to knowwhat is going to be heard this afternoon before I askyou --THE COURT: So nothing is going to beheard this afternoon since I'm granting the relief.MS. MYERS: Everything is going to bekicked at a later date?THE COURT: Yes.MR. BERLETH: We need the receiver'smotion to expand because the consortium is looking forthe March 25th settlement -- I'm sorry, I keep saying25th -- 26th --THE COURT: That won't be on today becausewe don't have time.MR. BERLETH: I get that. Can we get --MR. PRIDDY: Judge, can I speak? Irepresent Legalist. They're the largest securedcreditor here. Can I have 60 seconds? I know it's abusy day today, but I think I can help offer someclarification.THE COURT: Yes.MR. PRIDDY: So I represent Legalist SVP.We're owed about 13 million by Cyberlux. We depositedthe 3 million and change with the receiver, my clientdid back in June, with the understanding that it would 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 43 of 50 PageID# 2906
Priddy describes active Virginia discovery, March26 settlement conference and April15 summary-judgment deadlines; Berleth corrects his earlier March25 reference to26 and says he seeks a stipulated consortium allocation. Gomez is comfortable with Virginia disposition. These are then-current schedules and proposed outcomes, not proof of later settlement.
44HearingMarch 2, 2026And, frankly, while the funds are in theregistry, those funds belong to Cyberlux, because wemade that as a loan, a protective advance, to Cyberlux. So that's just some background on kind ofour involvement in the case and why we may want to beinvolved moving forward. But we're fully signed off onthe joint relief that Cyberlux and Atlantic Wave haveasked for today. And then very quickly, on this proceedingthat's taking place in the Eastern District of Virginia,this case has been on file up there since June. It's avery active case. There's 150 docket entries. We'reexchanging discovery as we speak. The court has set a settlement conferencewith its magistrate judge on March 26th. And if theparties can't settle on March 26th, the court has givenus summary judgment deadlines on April 15th. It has indicated that either by settlementagreement or by summary judgment, the court in theEastern District of Virginia intends to rule and disposeof these funds that relates to the additional creditors. We're comfortable with that process.We're fine with everything playing out. The 25 million,or whatever it is, we're fine with that playing out inVirginia. So that's just a little bit of flavor for the 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 45 of 50 PageID# 2908
Berleth states he is tendering a check for $873,639.75 to Ardmore on the record. Walton identifies the January6,2026 second amended distribution motion and February9 proposed order. The transcript proves the tender representation, not bank clearance.
46HearingMarch 2, 2026THE COURT: I can probably do somethingthis week. I just need to figure out what -- MR. BERLETH: Okay.THE COURT: Probably Thursday.MR. BERLETH: I'm not -- actually, thatwas the one day I was going to say I'm not available. Ihave to be in Dallas on Thursday, Judge. But I would like -- while we're on therecord, I am offering Mr. Ardmore a check for$873,639.75. And so I am tendering that to him, on therecord.THE COURT: What's -- where's your motion?MR. ARDMORE: Thank you, Your Honor.MR. BERLETH: It's in the docket.THE COURT: When was it filed?MR. BERLETH: Several months ago. InDecember, I believe.MR. ARDMORE: I'll find out.THE COURT: What's it entitled?MR. WALTON: Your Honor, it was filed onJanuary 6, 2026. It's called Plaintiffs' Second AmendedMotion for Distribution of Funds.THE COURT: Plaintiffs' Second AmendedMotion for Distribution of Funds. I don't see it. Is it the order -- 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 47 of 50 PageID# 2910
With no further hearing that day, Myers elects to proceed with withdrawal and Gomez grants it. Berleth says the receivership remains pending expansion scheduling; the court does not grant that expansion in this hearing.
47HearingMarch 2, 2026MR. WALTON: January 6th.THE COURT: Is it the proposed ordergranting the motion to withdraw?MR. BERLETH: Yes. Correct, Your Honor.It's at 124439250. Oh, wait. That's the motion to withdraw.That's -- I'm sorry. That's the withdrawal of ThompsonCoburn.MR. WALTON: Your Honor, I think theproposed order was filed on February 9th. Although --yeah, February 9th.THE COURT: Okay. I see it.MR. BERLETH: Correct, Judge.And other than that, the receivership isto remain in place. And we will set a motion to expandthe receivership as soon as possible. And I would also like to suggest to theJudge that the motion to withdraw for Thompson Coburnhas not been objected by any party, and if you wantto --THE COURT: Do you wish to continue withthat or pass it?MS. MYERS: As long as nothing is set forhearing later today, we would like to proceed with it.THE COURT: Okay. 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 48 of 50 PageID# 2911
Mahendru disputes notice and availability after the hearing moves from1:30 to11:00, asking withdrawal first. Walton and Myers say notice was given; Myers attributes the move to the clerk and urges settlement before withdrawal/expansion. Procedural notice is contested, not conclusively resolved in these arguments.
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
Berleth alleges Cyberlux counsel delayed while arranging settlement without him, identifies other creditors and proposes a consortium for Virginia funds near $25million. He claims a year coordinating creditors, possession/inventory of drones including screws, government shipment/payment and daily facility presence. These are receiver representations, not independent inventory or payment proof.
7HearingMarch 2, 2026nonexistent because there is no remaining receivershipduty here. And then, second, we would ask that youhear our motion to withdraw after whatever ruling youmake on the joint motion.THE COURT: Okay. And so, Mr. Berleth,you're the receiver?MR. BERLETH: I am, Your Honor.Mr. Mahendru is online, and he is unavailable today.Mr. Ardmore filed an interim motion for distribution ofthe funds incurred under 31.002, I believe it's (a), ofthe Texas Turnover Statute to recover the attorney'sfees incurred by Atlantic Waves [sic] since theappointment of receiver, which, Your Honor, they havebeen substantial. Atlantic Wave has had to hire appellatecounsel. They've had to hire counsel in Virginia.They've had to hire multiple attorneys here in Texas, inDallas and in Houston to deal with all of theshenanigans that Cyberlux has been throwing. AndYour Honor is very aware of all the things that havebeen thrown up on the wall by Cyberlux.At this point, Judge, as Mr. Mahendruindicated, Cyberlux and their counsel have beenunavailable to discuss with the receiver at all. They 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 8 of 50 PageID# 2871
Berleth claims $594,000 actual expenses including payroll/rent/transport/counsel, $990,000 unpaid payroll still owed, and paragraph53 entitlement to at least25% or potentially33% of $3,083,000 collected. He estimates $1,017,000 fee plus expenses, objects to $218,000 stipulated by the parties and says this would leave him roughly $400,000 short. No fee award is made here on those figures.
11HearingMarch 2, 2026render the joint settlement -- or joint motion todistribute moot because that's the $873,000 that they'retrying to distribute.THE COURT: So on the issue of -- so Idon't have the time -- I don't have the bandwidth at1:30.MR. BERLETH: Fair enough.THE COURT: I guess the issue is -- Iguess a couple of issues. One is on the expansion ofthe receiver, that was always going to be a heavy lift.I understand that there are underlying issues related tothe other funds that are due, attorney's fees, that kindof thing, open issues. Let's assume for a moment that there's notan expansion of the receivership, right. I'm not sayingthat I'm not considering that right now, but let'sassume that. What is the next fallback?MR. BERLETH: So the next fallback wouldbe the -- the joint motion fails to address thereceiver's fees entirely. At this point I have $594,000in actual expenses that I have incurred in theadministration of this receiver. That includes paying the unpaid payrollthat Cyberlux still has a significant amount owed on.So $990,000 still owed. That includes rent on the 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 12 of 50 PageID# 2875
Berleth clarifies Texas money is in his IOLTA, separate from Virginia funds, says expenses were paid from it, and offers termination under his own proposed order paying his charges. He predicts another Chapter64 receivership and reports $50–60million creditor claims; these remain proposals/estimates.
14HearingMarch 2, 2026MR. BERLETH: Correct. Well, it's in thereceiver's IOLTA. It was $3,083,000; but as I've said,I've had to pay payroll and things like that out of it.THE COURT: But that's separate from,like, the Virginia --MR. BERLETH: That is completely separatefrom the Virginia. This is only Atlantic Wave's. Andso what I've done, Judge, if you want to never hear theword "Cyberlux" again -- and trust me, I can share yourempathy on that. What I've done is I -- I already had amotion to terminate the receivership when I received the$3,083,000. What I would like to do is reurge my motionto terminate the receivership with this order, whichdoes terminate the receivership. It does the same thing that Ms. Myers isasking for, which is to terminate the receivership; butit pays the receiver what he's owed. And I'lldistribute the funds. I have the $873,000 check herethat I'll forward in accordance with that order, and thereceivership can be terminated here today right now inthis hearing. With that said, I can assure you that atleast one or more of those creditors are going to bemarching down the hall to Judge Roth -- I think their 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 15 of 50 PageID# 2878
Mahendru says six or seven intervenors joined and that no receiver accounting/report has yet been prepared. He contests resolving their interests on short notice and seeks withdrawal first.
16HearingMarch 2, 2026Thursday. That is point No. 1. Point No. 2 is if you wish to take the dueorder of pleadings, the motion to withdraw by ThompsonCoburn has been pending before the Court sinceJanuary 5th. Sign their order on the motion towithdraw, they're out. We will deal with the rest of itwhether at 1:30 or whether at another day that the Courtcan give us at least probably a half a day, if not awhole day. Point No. 3, since Thursday of last week,you now have, at last count, six or seven parties thathave intervened in this lawsuit. Those six or seven arecreditors, who are also joining in the expansion of thereceivership. So this little game that is afoot betweenCyberlux and Atlantic to, A, completely, as Mr. Berlethsaid, hose the receiver, that needs to be shelved. B, the fact that there are other partiesnow before you, who are also judgment creditors, who arealso seeking relief in your court, could never bedisposed of on a two-day motion to dissolve thereceivership. Three, you couldn't ever and wouldn'tever, I imagine, Your Honor, dissolve the receivershipwithout a proper accounting and a report by the 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 17 of 50 PageID# 2880
Ardmore describes creditor pressure from unpaid lawyers and presses interim distribution. Myers says settlement supersedes that motion, proposes at least $218,000 for receiver, termination except fees/costs, remaining corpus in registry and later accounting/prove-up. This is a proposal, not the court disposition.
18HearingMarch 2, 2026of the Court? And I think it would be extremely helpfulfor the Court to make that decision.THE COURT: One second. Counselor, did you want to say something?MR. ARDMORE: Yes, Your Honor. Thank you.Thank you so much. I would just say that there is a solutionthat does resolve everything very quickly here today.And this has been quite a long road for the creditor.And there has been a lot of expensive, very talentedlitigation attorneys. And so the problem that we're running intoat this point is that the creditor is going to becomeprejudiced here fairly quickly, we believe, or at leastthere's a high risk of that. Because some of theseattorneys with these big fees are getting restless; andwe don't know that, you know, it's going to be so easyto recover attorney fees to defend against attorney feeclaims.And so that's why we've been pushing sohard. And I wrote a letter to the Court a little whileback saying, you know, We're barely hanging on here.So -- but on top of that, just resolving that oneissue -- and we've had a motion pending for quite sometime now. For three or four settings, it's been put 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 19 of 50 PageID# 2882
Sadigh disputes exclusion from mediation, saying Berleth was repeatedly invited, argues creditors can pursue Virginia interpleader directly without receiver percentage fees, and alleges Berleth threatened that Atlantic Wave would receive nothing unless it supported expansion. This is attributed counsel account; the alleged threat and fee motive are not adjudicated facts.
21HearingMarch 2, 2026it will help the Court very much. If you just give meabout two minutes, I can clear up some issues.THE COURT: Okay.MR. SADIGH: First of all, Mr. Berlethsaid that we went to mediation without letting him know.No. He was aware. He was invited more than twice, whenwe went in December and he wanted to do it in January.And his attorney constantly said they're not available. We spent a lot of money, hours and days,to prepare for mediation. We went to mediation withCyberlux. And, unfortunately, because the receiver didnot participate was one of the reasons we couldn'tsucceed in mediation. Second, all of the other creditors thatMr. Berleth eloquently was trying to tell the Court thathe has consortium so he can expand his receivership andgo to Virginia and collect all this money for all ofthem, they have their remedies. There is an interpleader. They're in afederal court in Virginia in the hands of a very ablefederal judge. They can file their claim in theinterpleader; and a federal judge under federalguidelines, without charging any fees except a filingfee, will determine their share of that 23 million or$25 million that is sitting in Virginia. 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 22 of 50 PageID# 2885
Berleth says Atlantic Wave funded consortium legal work, acknowledges speaking to Sadigh/client, and justifies expansion for employees unable to afford Virginia lawyers. He says termination is possible but objects to an inadequate fee reserve. He does not specifically answer every alleged threat in this exchange; no admission of those allegations inferred.
23HearingMarch 2, 2026yesterday afternoon when we were on the phone, me andMr. Berleth, we were trying to resolve these issues. The only thing he was saying to us, andalmost getting in a yelling match, was threatening myclient about, You will not see a cent if you don't goforward with me. Because I want to expand myreceivership, I want to get my hands on that20-something million dollars in Virginia, and I want tomake fees on all of those things. And if you don't dothat, I'll make sure that you guys get zero. Based on that, I believe what Ms. Myershas put in front of the Court. It's a very goodsolution. Thank you, Your Honor.MR. MAHENDRU: Your Honor, I --THE COURT: Hold on. Mr. Mahendru, justone second. Did you want to say something?MR. BERLETH: I do, Judge. I can't support or oppose Mr. Ardmore'smotion. And they have been asking me for months, Willyou agree to distribute the $873,000 for -- and I agree,Atlantic Wave has been supporting basically all of theattorney's fees for the consortium. I know that there's a lot of attorney'sfees; but they have been doing the heavy lifting on it, 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 24 of 50 PageID# 2887
46HearingMarch 2, 2026THE COURT: I can probably do somethingthis week. I just need to figure out what -- MR. BERLETH: Okay.THE COURT: Probably Thursday.MR. BERLETH: I'm not -- actually, thatwas the one day I was going to say I'm not available. Ihave to be in Dallas on Thursday, Judge. But I would like -- while we're on therecord, I am offering Mr. Ardmore a check for$873,639.75. And so I am tendering that to him, on therecord.THE COURT: What's -- where's your motion?MR. ARDMORE: Thank you, Your Honor.MR. BERLETH: It's in the docket.THE COURT: When was it filed?MR. BERLETH: Several months ago. InDecember, I believe.MR. ARDMORE: I'll find out.THE COURT: What's it entitled?MR. WALTON: Your Honor, it was filed onJanuary 6, 2026. It's called Plaintiffs' Second AmendedMotion for Distribution of Funds.THE COURT: Plaintiffs' Second AmendedMotion for Distribution of Funds. I don't see it. Is it the order -- 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 47 of 50 PageID# 2910
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
49HearingMarch 2, 2026STATE OF TEXAS COUNTY OF HARRIS I, Jennifer Gajevsky, Official Court Reporter in andfor the 129th District Court of Harris, State ofTexas, do hereby certify that the above andforegoing contains a true and correct transcriptionof all portions of evidence and other proceedingsrequested in writing by counsel for the parties tobe included in this volume of the Reporter's Recordin the above-styled and numbered cause, all of whichoccurred in open court or in chambers and werereported by me.I further certify that this Reporter's Record of theproceedings truly and correctly reflects theexhibits, if any, offered by the respective parties. /s/ Jennifer Gajevsky Jennifer Gajevsky, CSR Texas CSR 9250 Official Court Reporter 129th District Court Harris County, Texas 201 Caroline Houston, Texas 77002 Expiration: 2/2028 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 50 of 50 PageID# 2913
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
2HearingMarch 2, 2026THE COURT: The Court is on the record inCause No. 2024-48085, Atlantic Wave Holdings, LLC,versus Cyberlux Corporation.Will everyone, please, introducethemselves for the record.MS. MYERS: Elizabeth Myers, ThompsonCoburn, on behalf of defendants.MR. SADIGH: Good morning, Your Honor.James Sadigh, on behalf of plaintiff, Atlantic Wave.MR. ARDMORE: David Ardmore, on behalf ofAtlantic Wave and Secure Communities.MR. MAHENDRU: Ashish Mahendru, along withRobert Berleth for the receiver, Robert Berleth.MR. WALTON: Your Honor, David Walton onAtlantic Wave and Secure Community between. MR. BEALE: Brice Beale, on behalf ofClayton Services. MR. PRIDDY: Austin Priddy, on behalf ofIntervenor, Legalist SPV III, LP.THE COURT: Good morning, everybody. So we have a couple of things on thedocket this morning. How did you want to proceed?MR. MAHENDRU: Your Honor, if I may. Iwant to openly and transparently short-circuit theCourt's proceedings this morning because I am not 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 3 of 50 PageID# 2866
41HearingMarch 2, 2026settlement agreement that the parties have alreadysigned. And so, you know, we don't -- I don't disputethat we have agreed to that amount, but that is asettlement and it resolves all remaining issues in thisTexas action. The parties can go fight in Virginia.Those are excluded from the settlement.THE COURT: Okay. So --MR. BERLETH: It doesn't. You have threeintervenors right there. It doesn't resolve theirissues at all.THE COURT: Understood. So it doesn't sound like I have anyobjection to your interim payment. So I'm going to goahead and grant that.MR. ARDMORE: Thank you. Thank you,Your Honor.THE COURT: The issue of the effect of thesettlement agreement, I don't have it before me. And itlooks like there's issues with scheduling. So we'llneed to take that up at a later point. It sounds likethere's objections and we won't be able to resolve that.So the other issue is the motion towithdraw. Do you still want the Court to consider it,or do you want to hold off on it? 1 2 3 4 5 6 7 8 910111213141516171819202122232425 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 42 of 50 PageID# 2905
EXHIBIT 20 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 1 of 50 PageID# 2864
Agreement on a payment amount did not resolve what it legally extinguished. The court granted interim payment while explicitly reserving the unseen settlement effect, so neither global satisfaction nor receiver termination can be inferred.
Priddy expressly supports joint relief and preserving excess, qualifying any broad representation that all other creditors favour receiver expansion. His actual stated position must remain separate from the consortium narrative.
Receiver fee/expense estimates and court rounding are not an accounting: source funds, spending, claimed compensation and remaining balance need a ledger and judicial prove-up.
Complete supplied 50-page source reviewed at SHA-256 ff51a345fb59061a8b6084b2af31c8463e67a71d3a54af54e553794af0ad1213. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. All50 own pages fully read, including exhibit/docket stamp, full notice and settlement debate, both receiver and creditor positions, Priddy clarification, oral rulings and certificate. Own images checked at1,2,13,24,33,42,44,45,47,49,50 to verify source date, claimed charges, allegation attribution, exact invoice/tender figures, Legalist stance and limited relief. Other pages text-reviewed, not represented as visually checked.
EXHIBIT 20 Case 3:25-cv-00483-JAG Document 175-22 Filed 04/15/26 Page 1 of 50 PageID# 2864
CONNECT
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
Specifically named source propositions support the bounded distinction or question.
WEIGH
A score appears only when its components and change threshold are published.
The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.