Receiver request to add eight creditor matters in series
Original sourceSigned motion seeking expanded collection authority and fee treatment; allegations and proposed sequence not a court-approved distribution.
Metadata only
The original file isn’t published in this edition.
The record remains visible so the reader can see that it exists without mistaking metadata for access to the underlying document.
SHA-256 09d65999d17c4fdec498…0 pages · 256 KB
DISTILLATES
What the source contains
Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
quotationattribution
Receiver concedes his fee is only presumptive and must still be proven at final disbursement.
Read the anchor · page 5
Page 4 of 6
citizen of Texas, and also generally recognize the class of unp aid
employees from Cyberlux’s Spring, Texas facility. They seek
$2,676,378.58. They jointly are plaintiffs in Cause No.
4:2025cv02770, Tucker, et. al v. Cyberlux Corp. in the United States
Federal District Court, Southern District of Texas- Houston Division;
(g) The ARG Group, LLC ( “The ARG Group” ) is an North Carolina
limited liability company with its principal place of business a
registered office at 231 Sloop Point Loop Rd, Hampstead, NC 28443.
The ARG Group has pending litigation seeking $13,500,000 for the
Disputed Funds, Cause No. 25CV004246-310, styled The ARG Group
v. Cyberlux Corp, et. al., in the General Court of Justice, Superior
Court Division, in Wake County, North Carolina; and
(h) Third Generation Development, L.P., ( “Third Generation” ) is a
Texas li mited partnership with its principal place of business in
Spring, Texas. Third Generation is the landlord for the Spring, Texas
manufacturing facility owed back rent and facing significant cleanup
costs, estimated at $342,478.34.
8. The Receiver requests supplement of the Receivership Order dated May
22, 2025 and to add the above-listed judgments and cause numbers for collection
in this receivership.
III. Receiver’s Fee Structure
9. Due to the complex nature of this collection, requiring years of litigation
experience as a receiver, the tenacity and veracity with which Cyberlux has
attacked both the receivership and the Receiver personally, expert skill in
department of defense work, multiple applicable state and federal laws, and
considerable expenses paid by the Receiver in this case, the parties have agreed to
the presumptive Receiver’s fees as previously ordered by this Court. The Bergron
factors only speak to the effectiveness of receivership, and do not require a lodestar
application for fees. This is only a presumptive fee, and must still be proven at the
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 5 of 7 PageID# 2811
observationobservation
Proposed list$27,340,291.29 versus expectedcorpus$25,795,303.38; not an allowed-claims schedule.
Read the anchor · page 2
CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT
and SECURE COMMUNITY, LLC., §
Plaintiffs, Judgment-Creditors, §
§
v. § 129TH JUDICIAL COURT
§
CYBERLUX CORPORATION and §
MARK D. SCHMIDT, individually, § IN AND FOR
Defendants, Judgment-Debtors. § HARRIS COUNTY, TEXAS
MOTION TO SUPPLEMENT RECEIVERSHIP
COMES NOW, the Receiver ROBERT BERLETH , as Receiver for
CYBERLUX CORPORATION and MARK D. SCHMIDT respectfully requests an
order supplementing the original order appointing receiver in this Motion to
Supplement Receivership, and for good cause shows the following:
I. Procedural History
1. Mr. Berleth was appointed Receiver by the Court over Judgment Debtors
CYBERLUX CORPORATION (“Cyberlux”) to collect a judgment owed to
ATLANTIC WAVE HOLDINGS, LLC in an Order Appointing Receiver (“OAR”).
The Receiver has now worked diligently on this case , nearly 24/7 since his
appointment. There have literally been hundreds of pages filed by Cyberlux.
2. Soon after his appointment, the Receiver was contacted by multiple
debtors of Cyberlux.
3. On June 24, 2025, HII Mission Technologies Corporation (“HII”) filed an
Interpleader action, cause no. 3:25 -cv-483, styled HII Mission Tech. Corp. v.
Cyberlux, et. al. in the Federal District Court of the Eastern District of Virginia -
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 2 of 7 PageID# 2808
claimallegation
EDVA175-15 filed15April2026 reproduces HarrisCounty2024-48085 motion to supplement22May2025receivership. Signature images of TristianHarris
EDVA175-15 filed15April2026 reproduces HarrisCounty2024-48085 motion to supplement22May2025receivership. Signature images of TristianHarris appear onmotion and certificate dated29August2025; no Texas filing stamp or grant order supplied.
Read the anchor · page 1
EXHIBIT 13
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 1 of 7 PageID# 2807
claimallegation
Receiver RobertBerleth describes nearly24/7work, HII interpleader24June2025, expected$25,795,303.38corpus, approximately$300,000HIIlegalfees
Receiver RobertBerleth describes nearly24/7work, HII interpleader24June2025, expected$25,795,303.38corpus, approximately$300,000HIIlegalfees and predicted surplus. Claims Cyberlux seeks to abscond are advocacy, not findings.
Read the anchor · page 2
CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT
and SECURE COMMUNITY, LLC., §
Plaintiffs, Judgment-Creditors, §
§
v. § 129TH JUDICIAL COURT
§
CYBERLUX CORPORATION and §
MARK D. SCHMIDT, individually, § IN AND FOR
Defendants, Judgment-Debtors. § HARRIS COUNTY, TEXAS
MOTION TO SUPPLEMENT RECEIVERSHIP
COMES NOW, the Receiver ROBERT BERLETH , as Receiver for
CYBERLUX CORPORATION and MARK D. SCHMIDT respectfully requests an
order supplementing the original order appointing receiver in this Motion to
Supplement Receivership, and for good cause shows the following:
I. Procedural History
1. Mr. Berleth was appointed Receiver by the Court over Judgment Debtors
CYBERLUX CORPORATION (“Cyberlux”) to collect a judgment owed to
ATLANTIC WAVE HOLDINGS, LLC in an Order Appointing Receiver (“OAR”).
The Receiver has now worked diligently on this case , nearly 24/7 since his
appointment. There have literally been hundreds of pages filed by Cyberlux.
2. Soon after his appointment, the Receiver was contacted by multiple
debtors of Cyberlux.
3. On June 24, 2025, HII Mission Technologies Corporation (“HII”) filed an
Interpleader action, cause no. 3:25 -cv-483, styled HII Mission Tech. Corp. v.
Cyberlux, et. al. in the Federal District Court of the Eastern District of Virginia -
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 2 of 7 PageID# 2808
Proposed series:a IRSliens$582,800.38;b SecureCommunity pendingCL24-003910$8,660,739.10;c CaudlejudgmentCL23-07422$9,392.50;d Aerotek24CV034906-910$344,227.25;e ThinAir1:25-cv-00805$1,224,275.14;f PhillipR.Tucker/NeillWhitely/employees4:2025cv02770$2,676,378.58;g ARGpending25CV004246-310$13,500,000;h ThirdGenerationlandlordestimate$342,478.34. Different source labels distinguish liens, judgments, pendingclaims and estimates.
Read the anchor · page 4
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to supplement the OAR to add the additional Judgments in the following series1 to
the current receivership:
(a) United States Department of Treasury, part of t he United States of
America (“United States”) is named as a party defendant pursuant
to 28 U.S.C. § 2410 as it may claim an interest in the Disputed Funds
(as defined below) by virtue of federal tax liens asserted by the
Internal Revenue Service ( “IRS”) against Cyberlux’s property
interests. The IRS holds liens against Cyberlux in the amount of
$582,800.38;
(b) Secure Community, LLC, ( “Secure Community” ) is a Virginia
limited liability company with its principal place of business in
Richmond, Virginia. Secure Community is in active litigation against
Cyberlux, claiming $8,660,739.10 in Virginia court Cause No. CL-24-
003910, styled Atlantic Waves Holdings, LLC v. Cyberlux
Corporation, et. al. , in the Circuit Court of the City of Richmond,
Virginia;
(c) Caudle & Caudle, P.C. ( “Caudle”) is a judgment creditor for
$9,392.50 against Cyberlux for legal services performed, with an
address of 1910 Byrd Avenue, Ste. 118, Richmond, Virginia 23230,
Cause No. CL23-07422, in the Circuit Court of the City of Richmond,
Virginia;
(d) Aerotek, Inc. Aerotek, Inc. ( “Aerotek”) is a Maryland stock
corporation authorized to do business in Virginia, with its principal
place of business in Hanover, Maryland. Aerotek is a judgment
creditor for $344,227.25, in Cause No. 24CV034906-910, styled
Aerotek, Inc. v. Cyberlux Corporation, et. al. in the General Court of
Justice, Superior Court Division, in Wake County, North Carolina;
(e) Thin Air Gear, LLC, ( “Thin Air” ) is a Nevada limited liability
company with its principal place of business in Colorado Springs,
Colorado, and is a judgment creditor for $1,224,275.14 in United
States Federal District Court of Colorado, Cause No. 1:25-cv-00805,
styled Thin Air Gear, LLC v. Cyberlux Corporation et al.,
(f) Phillip R. Tucker (“Tucker”) is a natural person and an adult citizen
of Texas. Neill Whitely (“Whiteley”) is a natural person and an adult
1 “Series” means that the first judgment is to be paid in full prior to moving to the
next. The Receiver should collect his fee on each judgment paid as they resolve.
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 4 of 7 PageID# 2810
claimallegation
Footnote defines series as full payment of each judgment before next, with receiver fee collected on each. Prayer asks court to supplement o
Footnote defines series as full payment of each judgment before next, with receiver fee collected on each. Prayer asks court to supplement original order for all eight; source does not establish lawful priority, allowed amounts or that proposed order was entered.
Read the anchor · page 4
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to supplement the OAR to add the additional Judgments in the following series1 to
the current receivership:
(a) United States Department of Treasury, part of t he United States of
America (“United States”) is named as a party defendant pursuant
to 28 U.S.C. § 2410 as it may claim an interest in the Disputed Funds
(as defined below) by virtue of federal tax liens asserted by the
Internal Revenue Service ( “IRS”) against Cyberlux’s property
interests. The IRS holds liens against Cyberlux in the amount of
$582,800.38;
(b) Secure Community, LLC, ( “Secure Community” ) is a Virginia
limited liability company with its principal place of business in
Richmond, Virginia. Secure Community is in active litigation against
Cyberlux, claiming $8,660,739.10 in Virginia court Cause No. CL-24-
003910, styled Atlantic Waves Holdings, LLC v. Cyberlux
Corporation, et. al. , in the Circuit Court of the City of Richmond,
Virginia;
(c) Caudle & Caudle, P.C. ( “Caudle”) is a judgment creditor for
$9,392.50 against Cyberlux for legal services performed, with an
address of 1910 Byrd Avenue, Ste. 118, Richmond, Virginia 23230,
Cause No. CL23-07422, in the Circuit Court of the City of Richmond,
Virginia;
(d) Aerotek, Inc. Aerotek, Inc. ( “Aerotek”) is a Maryland stock
corporation authorized to do business in Virginia, with its principal
place of business in Hanover, Maryland. Aerotek is a judgment
creditor for $344,227.25, in Cause No. 24CV034906-910, styled
Aerotek, Inc. v. Cyberlux Corporation, et. al. in the General Court of
Justice, Superior Court Division, in Wake County, North Carolina;
(e) Thin Air Gear, LLC, ( “Thin Air” ) is a Nevada limited liability
company with its principal place of business in Colorado Springs,
Colorado, and is a judgment creditor for $1,224,275.14 in United
States Federal District Court of Colorado, Cause No. 1:25-cv-00805,
styled Thin Air Gear, LLC v. Cyberlux Corporation et al.,
(f) Phillip R. Tucker (“Tucker”) is a natural person and an adult citizen
of Texas. Neill Whitely (“Whiteley”) is a natural person and an adult
1 “Series” means that the first judgment is to be paid in full prior to moving to the
next. The Receiver should collect his fee on each judgment paid as they resolve.
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 4 of 7 PageID# 2810
claimallegation
Receiver argues presumptive fees justified by complexity, skill and resistance, claims lodestar not required, but expressly says fee remains
Receiver argues presumptive fees justified by complexity, skill and resistance, claims lodestar not required, but expressly says fee remains to be proven at final disbursement under Bergeron/Moyer/Rohrmoos requirements. No fee amount or invoice schedule attached.
Read the anchor · page 5
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citizen of Texas, and also generally recognize the class of unp aid
employees from Cyberlux’s Spring, Texas facility. They seek
$2,676,378.58. They jointly are plaintiffs in Cause No.
4:2025cv02770, Tucker, et. al v. Cyberlux Corp. in the United States
Federal District Court, Southern District of Texas- Houston Division;
(g) The ARG Group, LLC ( “The ARG Group” ) is an North Carolina
limited liability company with its principal place of business a
registered office at 231 Sloop Point Loop Rd, Hampstead, NC 28443.
The ARG Group has pending litigation seeking $13,500,000 for the
Disputed Funds, Cause No. 25CV004246-310, styled The ARG Group
v. Cyberlux Corp, et. al., in the General Court of Justice, Superior
Court Division, in Wake County, North Carolina; and
(h) Third Generation Development, L.P., ( “Third Generation” ) is a
Texas li mited partnership with its principal place of business in
Spring, Texas. Third Generation is the landlord for the Spring, Texas
manufacturing facility owed back rent and facing significant cleanup
costs, estimated at $342,478.34.
8. The Receiver requests supplement of the Receivership Order dated May
22, 2025 and to add the above-listed judgments and cause numbers for collection
in this receivership.
III. Receiver’s Fee Structure
9. Due to the complex nature of this collection, requiring years of litigation
experience as a receiver, the tenacity and veracity with which Cyberlux has
attacked both the receivership and the Receiver personally, expert skill in
department of defense work, multiple applicable state and federal laws, and
considerable expenses paid by the Receiver in this case, the parties have agreed to
the presumptive Receiver’s fees as previously ordered by this Court. The Bergron
factors only speak to the effectiveness of receivership, and do not require a lodestar
application for fees. This is only a presumptive fee, and must still be proven at the
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 5 of 7 PageID# 2811
claimallegation
Harris certificate states service29August2025 onallcounsel by listed modalities; creditorGrady and debtorPennetti identified viaTexasE-file.
Harris certificate states service29August2025 onallcounsel by listed modalities; creditorGrady and debtorPennetti identified viaTexasE-file. No actual electronic receipt supplied.
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CERTIFICATE OF SERVICE
I hereby certify that on Friday, August 29, 2025 , a true and correct copy of the
above and foregoing was forwarded to all counsel of record via certified mail,
return receipt requested, regular mail, e-mail and/or facsimile. Electronic records
were also forwarded in accordance with local rules through the E -file or CM/ECF
system.
Counsel for Creditor Via Texas E-file
Atlantic Wave Holdings, LLC
Shawn M. Grady
SBN 24076411
shawn@gradycollectionlaw.com
2100 West Loop South, Ste. 805
Houston, Texas 77027
Counsel for Debtor, Via Texas E-file
Cyberlux Corporation
Alexander J. Pennetti
State Bar No. 24110208
THOMPSON COBURN LLP
2100 Ross Avenue, Suite 3200
Dallas, Texas 75201
_________________________
Tristian L. Harris
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 7 of 7 PageID# 2813Own image supplement: blue TristianHarris signature appears on certificate.
entityobservation
ROBERT BERLETH
Read the anchor · page 2
CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT
and SECURE COMMUNITY, LLC., §
Plaintiffs, Judgment-Creditors, §
§
v. § 129TH JUDICIAL COURT
§
CYBERLUX CORPORATION and §
MARK D. SCHMIDT, individually, § IN AND FOR
Defendants, Judgment-Debtors. § HARRIS COUNTY, TEXAS
MOTION TO SUPPLEMENT RECEIVERSHIP
COMES NOW, the Receiver ROBERT BERLETH , as Receiver for
CYBERLUX CORPORATION and MARK D. SCHMIDT respectfully requests an
order supplementing the original order appointing receiver in this Motion to
Supplement Receivership, and for good cause shows the following:
I. Procedural History
1. Mr. Berleth was appointed Receiver by the Court over Judgment Debtors
CYBERLUX CORPORATION (“Cyberlux”) to collect a judgment owed to
ATLANTIC WAVE HOLDINGS, LLC in an Order Appointing Receiver (“OAR”).
The Receiver has now worked diligently on this case , nearly 24/7 since his
appointment. There have literally been hundreds of pages filed by Cyberlux.
2. Soon after his appointment, the Receiver was contacted by multiple
debtors of Cyberlux.
3. On June 24, 2025, HII Mission Technologies Corporation (“HII”) filed an
Interpleader action, cause no. 3:25 -cv-483, styled HII Mission Tech. Corp. v.
Cyberlux, et. al. in the Federal District Court of the Eastern District of Virginia -
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 2 of 7 PageID# 2808
entityobservation
The ARG Group, LLC
Read the anchor · page 5
Page 4 of 6
citizen of Texas, and also generally recognize the class of unp aid
employees from Cyberlux’s Spring, Texas facility. They seek
$2,676,378.58. They jointly are plaintiffs in Cause No.
4:2025cv02770, Tucker, et. al v. Cyberlux Corp. in the United States
Federal District Court, Southern District of Texas- Houston Division;
(g) The ARG Group, LLC ( “The ARG Group” ) is an North Carolina
limited liability company with its principal place of business a
registered office at 231 Sloop Point Loop Rd, Hampstead, NC 28443.
The ARG Group has pending litigation seeking $13,500,000 for the
Disputed Funds, Cause No. 25CV004246-310, styled The ARG Group
v. Cyberlux Corp, et. al., in the General Court of Justice, Superior
Court Division, in Wake County, North Carolina; and
(h) Third Generation Development, L.P., ( “Third Generation” ) is a
Texas li mited partnership with its principal place of business in
Spring, Texas. Third Generation is the landlord for the Spring, Texas
manufacturing facility owed back rent and facing significant cleanup
costs, estimated at $342,478.34.
8. The Receiver requests supplement of the Receivership Order dated May
22, 2025 and to add the above-listed judgments and cause numbers for collection
in this receivership.
III. Receiver’s Fee Structure
9. Due to the complex nature of this collection, requiring years of litigation
experience as a receiver, the tenacity and veracity with which Cyberlux has
attacked both the receivership and the Receiver personally, expert skill in
department of defense work, multiple applicable state and federal laws, and
considerable expenses paid by the Receiver in this case, the parties have agreed to
the presumptive Receiver’s fees as previously ordered by this Court. The Bergron
factors only speak to the effectiveness of receivership, and do not require a lodestar
application for fees. This is only a presumptive fee, and must still be proven at the
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 5 of 7 PageID# 2811
entityobservation
Third Generation Development, L.P.
Read the anchor · page 5
Page 4 of 6
citizen of Texas, and also generally recognize the class of unp aid
employees from Cyberlux’s Spring, Texas facility. They seek
$2,676,378.58. They jointly are plaintiffs in Cause No.
4:2025cv02770, Tucker, et. al v. Cyberlux Corp. in the United States
Federal District Court, Southern District of Texas- Houston Division;
(g) The ARG Group, LLC ( “The ARG Group” ) is an North Carolina
limited liability company with its principal place of business a
registered office at 231 Sloop Point Loop Rd, Hampstead, NC 28443.
The ARG Group has pending litigation seeking $13,500,000 for the
Disputed Funds, Cause No. 25CV004246-310, styled The ARG Group
v. Cyberlux Corp, et. al., in the General Court of Justice, Superior
Court Division, in Wake County, North Carolina; and
(h) Third Generation Development, L.P., ( “Third Generation” ) is a
Texas li mited partnership with its principal place of business in
Spring, Texas. Third Generation is the landlord for the Spring, Texas
manufacturing facility owed back rent and facing significant cleanup
costs, estimated at $342,478.34.
8. The Receiver requests supplement of the Receivership Order dated May
22, 2025 and to add the above-listed judgments and cause numbers for collection
in this receivership.
III. Receiver’s Fee Structure
9. Due to the complex nature of this collection, requiring years of litigation
experience as a receiver, the tenacity and veracity with which Cyberlux has
attacked both the receivership and the Receiver personally, expert skill in
department of defense work, multiple applicable state and federal laws, and
considerable expenses paid by the Receiver in this case, the parties have agreed to
the presumptive Receiver’s fees as previously ordered by this Court. The Bergron
factors only speak to the effectiveness of receivership, and do not require a lodestar
application for fees. This is only a presumptive fee, and must still be proven at the
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 5 of 7 PageID# 2811
entityobservation
Tristian L. Harris
Read the anchor · page 6
Page 5 of 6
final disbursement in accordance with meeting the Bergeron and Moyer elements
and Rohrmoos Venture requirements.
IV. Prayer
WHEREFORE, PREMISES CONSIDERED, Receiver, Robert Berleth,
respectfully requests that the Court enter an order supplementing the judgment
from the above-listed cause numbers at ¶7, a-h, into this Receivership, and for any
other relief at law or equity, general or specific to which they are justly entitled.
Respectfully submitted by:
_________________________
BERLETH & ASSOCIATES, PLLC
Robert W. Berleth
Texas Bar # 24091860
SDOT #: 3062288
E-mail: rberleth@berlethlaw.com
Tristian L. Harris
Texas Bar # 24134449
SDOT #: 3848849
E-mail: tharris@berlethlaw.com
9950 Cypresswood Dr. Suite 200
Houston, Texas 77070
Tele: 713-588-6900
APPOINTED RECEIVER
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 6 of 7 PageID# 2812Own image supplement: blue TristianHarris signature appears on motion signature line.
entityobservation
CYBERLUX CORPORATION
Read the anchor · page 2
CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT
and SECURE COMMUNITY, LLC., §
Plaintiffs, Judgment-Creditors, §
§
v. § 129TH JUDICIAL COURT
§
CYBERLUX CORPORATION and §
MARK D. SCHMIDT, individually, § IN AND FOR
Defendants, Judgment-Debtors. § HARRIS COUNTY, TEXAS
MOTION TO SUPPLEMENT RECEIVERSHIP
COMES NOW, the Receiver ROBERT BERLETH , as Receiver for
CYBERLUX CORPORATION and MARK D. SCHMIDT respectfully requests an
order supplementing the original order appointing receiver in this Motion to
Supplement Receivership, and for good cause shows the following:
I. Procedural History
1. Mr. Berleth was appointed Receiver by the Court over Judgment Debtors
CYBERLUX CORPORATION (“Cyberlux”) to collect a judgment owed to
ATLANTIC WAVE HOLDINGS, LLC in an Order Appointing Receiver (“OAR”).
The Receiver has now worked diligently on this case , nearly 24/7 since his
appointment. There have literally been hundreds of pages filed by Cyberlux.
2. Soon after his appointment, the Receiver was contacted by multiple
debtors of Cyberlux.
3. On June 24, 2025, HII Mission Technologies Corporation (“HII”) filed an
Interpleader action, cause no. 3:25 -cv-483, styled HII Mission Tech. Corp. v.
Cyberlux, et. al. in the Federal District Court of the Eastern District of Virginia -
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 2 of 7 PageID# 2808
entityobservation
MARK D. SCHMIDT
Read the anchor · page 2
CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, LLC § IN THE DISTRICT COURT
and SECURE COMMUNITY, LLC., §
Plaintiffs, Judgment-Creditors, §
§
v. § 129TH JUDICIAL COURT
§
CYBERLUX CORPORATION and §
MARK D. SCHMIDT, individually, § IN AND FOR
Defendants, Judgment-Debtors. § HARRIS COUNTY, TEXAS
MOTION TO SUPPLEMENT RECEIVERSHIP
COMES NOW, the Receiver ROBERT BERLETH , as Receiver for
CYBERLUX CORPORATION and MARK D. SCHMIDT respectfully requests an
order supplementing the original order appointing receiver in this Motion to
Supplement Receivership, and for good cause shows the following:
I. Procedural History
1. Mr. Berleth was appointed Receiver by the Court over Judgment Debtors
CYBERLUX CORPORATION (“Cyberlux”) to collect a judgment owed to
ATLANTIC WAVE HOLDINGS, LLC in an Order Appointing Receiver (“OAR”).
The Receiver has now worked diligently on this case , nearly 24/7 since his
appointment. There have literally been hundreds of pages filed by Cyberlux.
2. Soon after his appointment, the Receiver was contacted by multiple
debtors of Cyberlux.
3. On June 24, 2025, HII Mission Technologies Corporation (“HII”) filed an
Interpleader action, cause no. 3:25 -cv-483, styled HII Mission Tech. Corp. v.
Cyberlux, et. al. in the Federal District Court of the Eastern District of Virginia -
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 2 of 7 PageID# 2808
entityobservation
Secure Community, LLC
Read the anchor · page 4
Page 3 of 6
to supplement the OAR to add the additional Judgments in the following series1 to
the current receivership:
(a) United States Department of Treasury, part of t he United States of
America (“United States”) is named as a party defendant pursuant
to 28 U.S.C. § 2410 as it may claim an interest in the Disputed Funds
(as defined below) by virtue of federal tax liens asserted by the
Internal Revenue Service ( “IRS”) against Cyberlux’s property
interests. The IRS holds liens against Cyberlux in the amount of
$582,800.38;
(b) Secure Community, LLC, ( “Secure Community” ) is a Virginia
limited liability company with its principal place of business in
Richmond, Virginia. Secure Community is in active litigation against
Cyberlux, claiming $8,660,739.10 in Virginia court Cause No. CL-24-
003910, styled Atlantic Waves Holdings, LLC v. Cyberlux
Corporation, et. al. , in the Circuit Court of the City of Richmond,
Virginia;
(c) Caudle & Caudle, P.C. ( “Caudle”) is a judgment creditor for
$9,392.50 against Cyberlux for legal services performed, with an
address of 1910 Byrd Avenue, Ste. 118, Richmond, Virginia 23230,
Cause No. CL23-07422, in the Circuit Court of the City of Richmond,
Virginia;
(d) Aerotek, Inc. Aerotek, Inc. ( “Aerotek”) is a Maryland stock
corporation authorized to do business in Virginia, with its principal
place of business in Hanover, Maryland. Aerotek is a judgment
creditor for $344,227.25, in Cause No. 24CV034906-910, styled
Aerotek, Inc. v. Cyberlux Corporation, et. al. in the General Court of
Justice, Superior Court Division, in Wake County, North Carolina;
(e) Thin Air Gear, LLC, ( “Thin Air” ) is a Nevada limited liability
company with its principal place of business in Colorado Springs,
Colorado, and is a judgment creditor for $1,224,275.14 in United
States Federal District Court of Colorado, Cause No. 1:25-cv-00805,
styled Thin Air Gear, LLC v. Cyberlux Corporation et al.,
(f) Phillip R. Tucker (“Tucker”) is a natural person and an adult citizen
of Texas. Neill Whitely (“Whiteley”) is a natural person and an adult
1 “Series” means that the first judgment is to be paid in full prior to moving to the
next. The Receiver should collect his fee on each judgment paid as they resolve.
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 4 of 7 PageID# 2810
entityobservation
Caudle & Caudle, P.C.
Read the anchor · page 4
Page 3 of 6
to supplement the OAR to add the additional Judgments in the following series1 to
the current receivership:
(a) United States Department of Treasury, part of t he United States of
America (“United States”) is named as a party defendant pursuant
to 28 U.S.C. § 2410 as it may claim an interest in the Disputed Funds
(as defined below) by virtue of federal tax liens asserted by the
Internal Revenue Service ( “IRS”) against Cyberlux’s property
interests. The IRS holds liens against Cyberlux in the amount of
$582,800.38;
(b) Secure Community, LLC, ( “Secure Community” ) is a Virginia
limited liability company with its principal place of business in
Richmond, Virginia. Secure Community is in active litigation against
Cyberlux, claiming $8,660,739.10 in Virginia court Cause No. CL-24-
003910, styled Atlantic Waves Holdings, LLC v. Cyberlux
Corporation, et. al. , in the Circuit Court of the City of Richmond,
Virginia;
(c) Caudle & Caudle, P.C. ( “Caudle”) is a judgment creditor for
$9,392.50 against Cyberlux for legal services performed, with an
address of 1910 Byrd Avenue, Ste. 118, Richmond, Virginia 23230,
Cause No. CL23-07422, in the Circuit Court of the City of Richmond,
Virginia;
(d) Aerotek, Inc. Aerotek, Inc. ( “Aerotek”) is a Maryland stock
corporation authorized to do business in Virginia, with its principal
place of business in Hanover, Maryland. Aerotek is a judgment
creditor for $344,227.25, in Cause No. 24CV034906-910, styled
Aerotek, Inc. v. Cyberlux Corporation, et. al. in the General Court of
Justice, Superior Court Division, in Wake County, North Carolina;
(e) Thin Air Gear, LLC, ( “Thin Air” ) is a Nevada limited liability
company with its principal place of business in Colorado Springs,
Colorado, and is a judgment creditor for $1,224,275.14 in United
States Federal District Court of Colorado, Cause No. 1:25-cv-00805,
styled Thin Air Gear, LLC v. Cyberlux Corporation et al.,
(f) Phillip R. Tucker (“Tucker”) is a natural person and an adult citizen
of Texas. Neill Whitely (“Whiteley”) is a natural person and an adult
1 “Series” means that the first judgment is to be paid in full prior to moving to the
next. The Receiver should collect his fee on each judgment paid as they resolve.
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 4 of 7 PageID# 2810
entityobservation
Aerotek, Inc.
Read the anchor · page 4
Page 3 of 6
to supplement the OAR to add the additional Judgments in the following series1 to
the current receivership:
(a) United States Department of Treasury, part of t he United States of
America (“United States”) is named as a party defendant pursuant
to 28 U.S.C. § 2410 as it may claim an interest in the Disputed Funds
(as defined below) by virtue of federal tax liens asserted by the
Internal Revenue Service ( “IRS”) against Cyberlux’s property
interests. The IRS holds liens against Cyberlux in the amount of
$582,800.38;
(b) Secure Community, LLC, ( “Secure Community” ) is a Virginia
limited liability company with its principal place of business in
Richmond, Virginia. Secure Community is in active litigation against
Cyberlux, claiming $8,660,739.10 in Virginia court Cause No. CL-24-
003910, styled Atlantic Waves Holdings, LLC v. Cyberlux
Corporation, et. al. , in the Circuit Court of the City of Richmond,
Virginia;
(c) Caudle & Caudle, P.C. ( “Caudle”) is a judgment creditor for
$9,392.50 against Cyberlux for legal services performed, with an
address of 1910 Byrd Avenue, Ste. 118, Richmond, Virginia 23230,
Cause No. CL23-07422, in the Circuit Court of the City of Richmond,
Virginia;
(d) Aerotek, Inc. Aerotek, Inc. ( “Aerotek”) is a Maryland stock
corporation authorized to do business in Virginia, with its principal
place of business in Hanover, Maryland. Aerotek is a judgment
creditor for $344,227.25, in Cause No. 24CV034906-910, styled
Aerotek, Inc. v. Cyberlux Corporation, et. al. in the General Court of
Justice, Superior Court Division, in Wake County, North Carolina;
(e) Thin Air Gear, LLC, ( “Thin Air” ) is a Nevada limited liability
company with its principal place of business in Colorado Springs,
Colorado, and is a judgment creditor for $1,224,275.14 in United
States Federal District Court of Colorado, Cause No. 1:25-cv-00805,
styled Thin Air Gear, LLC v. Cyberlux Corporation et al.,
(f) Phillip R. Tucker (“Tucker”) is a natural person and an adult citizen
of Texas. Neill Whitely (“Whiteley”) is a natural person and an adult
1 “Series” means that the first judgment is to be paid in full prior to moving to the
next. The Receiver should collect his fee on each judgment paid as they resolve.
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 4 of 7 PageID# 2810
entityobservation
Thin Air Gear, LLC
Read the anchor · page 4
Page 3 of 6
to supplement the OAR to add the additional Judgments in the following series1 to
the current receivership:
(a) United States Department of Treasury, part of t he United States of
America (“United States”) is named as a party defendant pursuant
to 28 U.S.C. § 2410 as it may claim an interest in the Disputed Funds
(as defined below) by virtue of federal tax liens asserted by the
Internal Revenue Service ( “IRS”) against Cyberlux’s property
interests. The IRS holds liens against Cyberlux in the amount of
$582,800.38;
(b) Secure Community, LLC, ( “Secure Community” ) is a Virginia
limited liability company with its principal place of business in
Richmond, Virginia. Secure Community is in active litigation against
Cyberlux, claiming $8,660,739.10 in Virginia court Cause No. CL-24-
003910, styled Atlantic Waves Holdings, LLC v. Cyberlux
Corporation, et. al. , in the Circuit Court of the City of Richmond,
Virginia;
(c) Caudle & Caudle, P.C. ( “Caudle”) is a judgment creditor for
$9,392.50 against Cyberlux for legal services performed, with an
address of 1910 Byrd Avenue, Ste. 118, Richmond, Virginia 23230,
Cause No. CL23-07422, in the Circuit Court of the City of Richmond,
Virginia;
(d) Aerotek, Inc. Aerotek, Inc. ( “Aerotek”) is a Maryland stock
corporation authorized to do business in Virginia, with its principal
place of business in Hanover, Maryland. Aerotek is a judgment
creditor for $344,227.25, in Cause No. 24CV034906-910, styled
Aerotek, Inc. v. Cyberlux Corporation, et. al. in the General Court of
Justice, Superior Court Division, in Wake County, North Carolina;
(e) Thin Air Gear, LLC, ( “Thin Air” ) is a Nevada limited liability
company with its principal place of business in Colorado Springs,
Colorado, and is a judgment creditor for $1,224,275.14 in United
States Federal District Court of Colorado, Cause No. 1:25-cv-00805,
styled Thin Air Gear, LLC v. Cyberlux Corporation et al.,
(f) Phillip R. Tucker (“Tucker”) is a natural person and an adult citizen
of Texas. Neill Whitely (“Whiteley”) is a natural person and an adult
1 “Series” means that the first judgment is to be paid in full prior to moving to the
next. The Receiver should collect his fee on each judgment paid as they resolve.
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 4 of 7 PageID# 2810
entityobservation
Phillip R. Tucker
Read the anchor · page 4
Page 3 of 6
to supplement the OAR to add the additional Judgments in the following series1 to
the current receivership:
(a) United States Department of Treasury, part of t he United States of
America (“United States”) is named as a party defendant pursuant
to 28 U.S.C. § 2410 as it may claim an interest in the Disputed Funds
(as defined below) by virtue of federal tax liens asserted by the
Internal Revenue Service ( “IRS”) against Cyberlux’s property
interests. The IRS holds liens against Cyberlux in the amount of
$582,800.38;
(b) Secure Community, LLC, ( “Secure Community” ) is a Virginia
limited liability company with its principal place of business in
Richmond, Virginia. Secure Community is in active litigation against
Cyberlux, claiming $8,660,739.10 in Virginia court Cause No. CL-24-
003910, styled Atlantic Waves Holdings, LLC v. Cyberlux
Corporation, et. al. , in the Circuit Court of the City of Richmond,
Virginia;
(c) Caudle & Caudle, P.C. ( “Caudle”) is a judgment creditor for
$9,392.50 against Cyberlux for legal services performed, with an
address of 1910 Byrd Avenue, Ste. 118, Richmond, Virginia 23230,
Cause No. CL23-07422, in the Circuit Court of the City of Richmond,
Virginia;
(d) Aerotek, Inc. Aerotek, Inc. ( “Aerotek”) is a Maryland stock
corporation authorized to do business in Virginia, with its principal
place of business in Hanover, Maryland. Aerotek is a judgment
creditor for $344,227.25, in Cause No. 24CV034906-910, styled
Aerotek, Inc. v. Cyberlux Corporation, et. al. in the General Court of
Justice, Superior Court Division, in Wake County, North Carolina;
(e) Thin Air Gear, LLC, ( “Thin Air” ) is a Nevada limited liability
company with its principal place of business in Colorado Springs,
Colorado, and is a judgment creditor for $1,224,275.14 in United
States Federal District Court of Colorado, Cause No. 1:25-cv-00805,
styled Thin Air Gear, LLC v. Cyberlux Corporation et al.,
(f) Phillip R. Tucker (“Tucker”) is a natural person and an adult citizen
of Texas. Neill Whitely (“Whiteley”) is a natural person and an adult
1 “Series” means that the first judgment is to be paid in full prior to moving to the
next. The Receiver should collect his fee on each judgment paid as they resolve.
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 4 of 7 PageID# 2810
entityobservation
Neill Whitely
Read the anchor · page 4
Page 3 of 6
to supplement the OAR to add the additional Judgments in the following series1 to
the current receivership:
(a) United States Department of Treasury, part of t he United States of
America (“United States”) is named as a party defendant pursuant
to 28 U.S.C. § 2410 as it may claim an interest in the Disputed Funds
(as defined below) by virtue of federal tax liens asserted by the
Internal Revenue Service ( “IRS”) against Cyberlux’s property
interests. The IRS holds liens against Cyberlux in the amount of
$582,800.38;
(b) Secure Community, LLC, ( “Secure Community” ) is a Virginia
limited liability company with its principal place of business in
Richmond, Virginia. Secure Community is in active litigation against
Cyberlux, claiming $8,660,739.10 in Virginia court Cause No. CL-24-
003910, styled Atlantic Waves Holdings, LLC v. Cyberlux
Corporation, et. al. , in the Circuit Court of the City of Richmond,
Virginia;
(c) Caudle & Caudle, P.C. ( “Caudle”) is a judgment creditor for
$9,392.50 against Cyberlux for legal services performed, with an
address of 1910 Byrd Avenue, Ste. 118, Richmond, Virginia 23230,
Cause No. CL23-07422, in the Circuit Court of the City of Richmond,
Virginia;
(d) Aerotek, Inc. Aerotek, Inc. ( “Aerotek”) is a Maryland stock
corporation authorized to do business in Virginia, with its principal
place of business in Hanover, Maryland. Aerotek is a judgment
creditor for $344,227.25, in Cause No. 24CV034906-910, styled
Aerotek, Inc. v. Cyberlux Corporation, et. al. in the General Court of
Justice, Superior Court Division, in Wake County, North Carolina;
(e) Thin Air Gear, LLC, ( “Thin Air” ) is a Nevada limited liability
company with its principal place of business in Colorado Springs,
Colorado, and is a judgment creditor for $1,224,275.14 in United
States Federal District Court of Colorado, Cause No. 1:25-cv-00805,
styled Thin Air Gear, LLC v. Cyberlux Corporation et al.,
(f) Phillip R. Tucker (“Tucker”) is a natural person and an adult citizen
of Texas. Neill Whitely (“Whiteley”) is a natural person and an adult
1 “Series” means that the first judgment is to be paid in full prior to moving to the
next. The Receiver should collect his fee on each judgment paid as they resolve.
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 4 of 7 PageID# 2810
eventattribution
Signed certificate states service; receipt not supplied.
Read the anchor · page 7
Page 6 of 6
CERTIFICATE OF SERVICE
I hereby certify that on Friday, August 29, 2025 , a true and correct copy of the
above and foregoing was forwarded to all counsel of record via certified mail,
return receipt requested, regular mail, e-mail and/or facsimile. Electronic records
were also forwarded in accordance with local rules through the E -file or CM/ECF
system.
Counsel for Creditor Via Texas E-file
Atlantic Wave Holdings, LLC
Shawn M. Grady
SBN 24076411
shawn@gradycollectionlaw.com
2100 West Loop South, Ste. 805
Houston, Texas 77027
Counsel for Debtor, Via Texas E-file
Cyberlux Corporation
Alexander J. Pennetti
State Bar No. 24110208
THOMPSON COBURN LLP
2100 Ross Avenue, Suite 3200
Dallas, Texas 75201
_________________________
Tristian L. Harris
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 7 of 7 PageID# 2813Own image supplement: blue TristianHarris signature appears on certificate.
eventattribution
EDVA175-15filed.
Read the anchor · page 1
EXHIBIT 13
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 1 of 7 PageID# 2807
inferenceinference
Eight listed amounts sum$27,340,291.29, exceeding expected$25,795,303.38 by$1,544,987.91 before receiver fees or other claims. Thus predicte
Eight listed amounts sum$27,340,291.29, exceeding expected$25,795,303.38 by$1,544,987.91 before receiver fees or other claims. Thus predicted surplus is not enough to pay all listed amounts at face value; mixed claim validity and priority remain unresolved.
otherattribution
Complete supplied 7-page source reviewed at SHA-256 09d65999d17c4fdec498b923f78b64e564afa4ea39d59699f777d62e9502ec56. Source assertions, ori
Complete supplied 7-page source reviewed at SHA-256 09d65999d17c4fdec498b923f78b64e564afa4ea39d59699f777d62e9502ec56. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Own exact SHA256 09d65999d17c4fdec498b923f78b64e564afa4ea39d59699f777d62e9502ec56 verified; complete own-source text and all rendered pages read. Page-level corrections explicitly attributed; no absent document or performed act inferred.
Read the anchor · page 1
EXHIBIT 13
Case 3:25-cv-00483-JAG Document 175-15 Filed 04/15/26 Page 1 of 7 PageID# 2807
questionquestion
Which listed matters have enforceable judgments, allowed amounts and priority, and what order approved adding them or the proposed series?
questionquestion
What final fee proof and net available corpus support proposed distributions after costs and competing claims?
distillateobservation
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Proposed series:a IRSliens$582,800.38;b SecureCommunity pendingCL24-003910$8,660,739.10;c CaudlejudgmentCL23-07422$9,392.50;d Aerotek24CV034906-910$344,227.25;e ThinAir1:25-cv-00805$1,224,275.14;f PhillipR.Tucker/NeillWhitely/employees4:2025cv02770$2,676,378.58;g ARGpending25CV004246-310$13,500,000;h ThirdGenerationlandlordestimate$342,478.34. Different source labels distinguish liens, judgments, pendingclaims and estimates.supportsAssessment rows in displayed order: tax940, period2023-12-31, assessed2024-02-26, refile-by2034-03-28, balance254.70; tax941, period2010-06-30, assessed2013-05-13, refile-by2033-06-12, balance46023.00; tax941, period2010-12-31, assessed2011-04-11, refile-by2031-05-11, balance[blank]; tax941, period2010-12-31, assessed2012-09-10, refile-by2032-10-10, balance178708.29; tax941, period2012-12-31, assessed2013-04-01, refile-by2033-05-01, balance334730.87. Printed total $559716.86. A blank row balance is preserved as blank, not zero or a second copy of adjacent amount.
IRS aggregate582800.38equals notices39+41+43(2220.28+20863.24+559716.86); same underlying notices, not independent corroboration or current payoff.
Receiver RobertBerleth describes nearly24/7work, HII interpleader24June2025, expected$25,795,303.38corpus, approximately$300,000HIIlegalfees and predicted surplus. Claims Cyberlux seeks to abscond are advocacy, not findings.supportsWhat final fee proof and net available corpus support proposed distributions after costs and competing claims?
Specifically named source propositions support the bounded distinction or question.
Footnote defines series as full payment of each judgment before next, with receiver fee collected on each. Prayer asks court to supplement original order for all eight; source does not establish lawful priority, allowed amounts or that proposed order was entered.supportsWhich listed matters have enforceable judgments, allowed amounts and priority, and what order approved adding them or the proposed series?
Specifically named source propositions support the bounded distinction or question.
Proposed series:a IRSliens$582,800.38;b SecureCommunity pendingCL24-003910$8,660,739.10;c CaudlejudgmentCL23-07422$9,392.50;d Aerotek24CV034906-910$344,227.25;e ThinAir1:25-cv-00805$1,224,275.14;f PhillipR.Tucker/NeillWhitely/employees4:2025cv02770$2,676,378.58;g ARGpending25CV004246-310$13,500,000;h ThirdGenerationlandlordestimate$342,478.34. Different source labels distinguish liens, judgments, pendingclaims and estimates.supportsWhat does the supplementation motion establish?
Specifically named source propositions support the bounded distinction or question.
Eight listed amounts sum$27,340,291.29, exceeding expected$25,795,303.38 by$1,544,987.91 before receiver fees or other claims. Thus predicted surplus is not enough to pay all listed amounts at face value; mixed claim validity and priority remain unresolved.supportsWhat final fee proof and net available corpus support proposed distributions after costs and competing claims?
Specifically named source propositions support the bounded distinction or question.
Receiver argues presumptive fees justified by complexity, skill and resistance, claims lodestar not required, but expressly says fee remains to be proven at final disbursement under Bergeron/Moyer/Rohrmoos requirements. No fee amount or invoice schedule attached.supportsWhat final fee proof and net available corpus support proposed distributions after costs and competing claims?
Specifically named source propositions support the bounded distinction or question.
Footnote defines series as full payment of each judgment before next, with receiver fee collected on each. Prayer asks court to supplement original order for all eight; source does not establish lawful priority, allowed amounts or that proposed order was entered.supportsWhat does the supplementation motion establish?
Specifically named source propositions support the bounded distinction or question.
Receiver RobertBerleth describes nearly24/7work, HII interpleader24June2025, expected$25,795,303.38corpus, approximately$300,000HIIlegalfees and predicted surplus. Claims Cyberlux seeks to abscond are advocacy, not findings.supportsEight listed amounts sum$27,340,291.29, exceeding expected$25,795,303.38 by$1,544,987.91 before receiver fees or other claims. Thus predicted surplus is not enough to pay all listed amounts at face value; mixed claim validity and priority remain unresolved.
Specifically named source propositions support the bounded distinction or question.
Proposed series:a IRSliens$582,800.38;b SecureCommunity pendingCL24-003910$8,660,739.10;c CaudlejudgmentCL23-07422$9,392.50;d Aerotek24CV034906-910$344,227.25;e ThinAir1:25-cv-00805$1,224,275.14;f PhillipR.Tucker/NeillWhitely/employees4:2025cv02770$2,676,378.58;g ARGpending25CV004246-310$13,500,000;h ThirdGenerationlandlordestimate$342,478.34. Different source labels distinguish liens, judgments, pendingclaims and estimates.supportsWhich listed matters have enforceable judgments, allowed amounts and priority, and what order approved adding them or the proposed series?
Specifically named source propositions support the bounded distinction or question.
Footnote defines series as full payment of each judgment before next, with receiver fee collected on each. Prayer asks court to supplement original order for all eight; source does not establish lawful priority, allowed amounts or that proposed order was entered.supportsEight listed amounts sum$27,340,291.29, exceeding expected$25,795,303.38 by$1,544,987.91 before receiver fees or other claims. Thus predicted surplus is not enough to pay all listed amounts at face value; mixed claim validity and priority remain unresolved.
Specifically named source propositions support the bounded distinction or question.
Proposed series:a IRSliens$582,800.38;b SecureCommunity pendingCL24-003910$8,660,739.10;c CaudlejudgmentCL23-07422$9,392.50;d Aerotek24CV034906-910$344,227.25;e ThinAir1:25-cv-00805$1,224,275.14;f PhillipR.Tucker/NeillWhitely/employees4:2025cv02770$2,676,378.58;g ARGpending25CV004246-310$13,500,000;h ThirdGenerationlandlordestimate$342,478.34. Different source labels distinguish liens, judgments, pendingclaims and estimates.supportsEight listed amounts sum$27,340,291.29, exceeding expected$25,795,303.38 by$1,544,987.91 before receiver fees or other claims. Thus predicted surplus is not enough to pay all listed amounts at face value; mixed claim validity and priority remain unresolved.
Specifically named source propositions support the bounded distinction or question.
Eight listed amounts sum$27,340,291.29, exceeding expected$25,795,303.38 by$1,544,987.91 before receiver fees or other claims. Thus predicted surplus is not enough to pay all listed amounts at face value; mixed claim validity and priority remain unresolved.supportsWhat does the supplementation motion establish?
Specifically named source propositions support the bounded distinction or question.
Receiver RobertBerleth describes nearly24/7work, HII interpleader24June2025, expected$25,795,303.38corpus, approximately$300,000HIIlegalfees and predicted surplus. Claims Cyberlux seeks to abscond are advocacy, not findings.supportsWhat does the supplementation motion establish?
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.