Zoladz submits Montague receivership claim — letter of 10 June 2025
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quotationattribution
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Read the anchor · page 5
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 5
Material Breaches of Consulting Agreement by Cyberlux
Cyberlux has materially breached multiple provisions of the 2023 Consulting
Agreement, depriving Montague of millions of dollars in rightfully earned compensation
while simultaneously failing to provide the transparency promised under the Agreement.
These breaches are not mere technical violations but represent a fundamental failure to
honor the contractual relationship that has been instrumental to Cyberlux's success.
Cyberlux’s Failure to Pay Commissions
Despite receiving approximately $38.7 million in payments during 2023 under the
Ukraine drone contract—a Commissionable Contract expressly identified in Schedule 2 of
the Agreement and subject to the 5% commission rate—Cyberlux has failed to pay
Montague any portion of the $1,935,000 in commissions due on these receipts. This
complete failure to pay commissions constitutes not only a material breach of Section 3.3
of the Agreement but also triggers the willful misconduct provisions of Section 3.3(c), as
the underpayment exceeds 10% of the amount payable (indeed, it represents a 100%
underpayment). Under the Agreement's terms, this gross underpayment subjects
Cyberlux to both interest charges at 1% per month and an additional penalty equal to 10%
of the underpayment amount.
Cyberlux’s Failure to Pay Consulting Fees From January 2025 through the Present
In addition to the commission obligations, Cyberlux has failed to pay the monthly
consulting fees required under Section 3.2 of the Agreement. Beginning with the January
2025 payment and continuing through the present, Cyberlux has failed to make six (6) of
the required monthly payments of $20,833.33. As of the date of this letter, the unpaid
consulting fees total $125,000 for the period January through June 2025, exclusive of
interest. This ongoing failure to pay base compensation represents a separate and
independent material breach of the Agreement.
Cyberlux’s Failure to Provide Required Statements
Compounding these payment failures, Cyberlux has breached its reporting
obligations under Section 3.3(a) of the Agreement by failing to provide monthly
statements detailing payments received under Commissionable Contracts. Despite the
clear requirement that such statements be provided within the first five business days of
each month, Montague has received no statements whatsoever regarding the substantial
payments Cyberlux has received under the Ukraine drone contract. This lack of
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Jason M. Zoladz writes for Montague Capital Partners LLC to receiver Robert Berleth in Atlantic Wave cause 2024-48085. The letter is dated 1
Jason M. Zoladz writes for Montague Capital Partners LLC to receiver Robert Berleth in Atlantic Wave cause 2024-48085. The letter is dated 10 June 2025 and stamped filed 11 June at 9:36 PM, envelope 101916709. A visible signature mark appears above Zoladz’s printed name. These dates distinguish correspondence from filing.
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
The letter requests acknowledgement and payment, recognises that certain receiver actions may need court approval, anticipates litigation so
The letter requests acknowledgement and payment, recognises that certain receiver actions may need court approval, anticipates litigation soon and requests preservation of relevant agreements, communications, payment records and financial material. A demand, anticipated suit or preservation request is not an entered judgment or proof that the suit was filed.
Read the anchor · page 6
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 6
transparency has forced Montague to rely on incomplete public information and thirdparty sources to determine the extent of amounts owed, thereby frustrating the
Agreement's provisions designed to ensure accurate and timely commission payments.
Montague’s Claims and Records Demands
Based on the foregoing breaches, Montague requests:
1. Payment of All Amounts Due: Cyberlux owes (a) $1,935,000 in unpaid
commissions on the approximately $38.7 million received during 2023, (b)
$193,500 representing the 10% penalty on such underpayment pursuant to Section
3.3(c), (c) accrued interest on the unpaid commission at 1% per month from the
date each payment was due, (d) $125,000 in unpaid monthly consulting fees for
January through June 2025, and (e) accrued interest on unpaid consulting fees at
1% per month from each payment's due date.
2. Commission on Pending HII Payment: Upon receipt of the $25,795,303.38
payment from HII referenced in the Receiver's correspondence, Cyberlux will owe
Montague the 5% commission due thereon ($1,289,765.17) within ten business
days. Cyberlux’s failure to timely pay this commission triggers the 10% penalty
provisions of Section 3.3(c).
3. Provision of Monthly Statements: Please cause Cyberlux to provide all monthly
statements required under Section 3.3(a) from January 2023 through the present,
detailing all payments received under the Ukraine drone contract and any other
Commissionable Contracts.
4. Access to Books and Records: Pursuant to Section 3.3(c), Montague requests
access to all books and records of Cyberlux relating to Commissionable Contracts,
including but not limited to all invoices, payment records, correspondence with HII,
and banking records showing receipt of payments.
Montague understands that Cyberlux's receivership status will require Court
approval for certain actions. Montague will work constructively with you to ensure
Cyberlux’s obligations are satisfied in accordance with applicable law and court orders.
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
The final page closes the signed letter. The three referenced enclosures are separate from this eight-page physical file and must retain the
The final page closes the signed letter. The three referenced enclosures are separate from this eight-page physical file and must retain their own provenance when linked.
Read the anchor · page 8
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 8
I appreciate your attention to this matter and look forward to working with you to
maximize recoveries for all stakeholders. Please do not hesitate to contact me if you
require any additional information or documentation.
Very truly yours,
Jason M. Zoladz
JasonJolady UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Counsel describes Montague and Denis Kalenja as the driving force behind Cyberlux’s acquisitions, defence transition, Catalyst development,
Counsel describes Montague and Denis Kalenja as the driving force behind Cyberlux’s acquisitions, defence transition, Catalyst development, Datron integration, CE removal and sourcing the approximately $79 million HII contract. These are the claimant’s performance/causation assertions, not independent findings that Montague alone produced those outcomes.
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
The letter quotes the 2023 annual fee of $250,000 and commission rates of two per cent generally and five per cent for Ukraine-related sourc
The letter quotes the 2023 annual fee of $250,000 and commission rates of two per cent generally and five per cent for Ukraine-related sourced contracts, based on gross amounts payable. It refers to Schedule2 Order220/9169 of 21 September2022 for 1,000 units and the Jan5 memo’s increase to 2,000. The underlying government order is not supplied by quoting this contractual schedule.
Read the anchor · page 2
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 2
the commercial agreements that account for the overwhelming majority of Cyberlux’s
revenues to date. Highlights of Montague’s work on behalf of Cyberlux include:
- Formulating and leading Cyberlux’s transition from a small company focused on
lighting systems to legitimate defense subcontractor;
- Guiding Cyberlux’s acquisition of the (then-distressed) high-speed drone
manufacturer Catalyst Machineworks (“Catalyst”) and advising on Catalyst’s
transformation from drone-enthusiast company to the military/law-enforcement
drone manufacturing arm of Cyberlux;
- Leading, negotiating and closing on Cyberlux’s acquisition of Datron World
Communications, Inc. (“Datron”) and subsequently integrating Datron—and its
tactical military communications equipment manufacturing capabilities—into
Cyberlux; and
- Sourcing and negotiating the contract underlying Cyberlux’s most significant
revenue stream—Cyberlux’s $79M August 29, 2023 contract with Huntington Ingalls
Industries (“HII”) to deliver FlightEye Model K8 drones for use in Ukraine.
In exchange for Montague’s strategic business development services, work in
identifying and developing acquisitions, and assistance with sourcing, negotiating and
closing commercial contracts, Cyberlux agreed to pay Montague substantial fees and
commissions (detailed below) pursuant to the 2023 Consulting Agreement.
Relevant Terms of the 2023 Consulting Agreement
Section 3.2 of the Agreement provides:
As base compensation for the Services and the rights granted to Cyberlux in this
Agreement, Cyberlux shall pay Consultant a fixed fee of $250,000.00 (the “Fees”)
per annum, payable in equal monthly installments on the first business day of each
month, commencing January 3, 2023.
Section 3.3 of the Agreement states:
In addition to the Fees, Consultant shall be entitled to receive two percent (2%),
with the exception of any Ukraine-related commercial contracts for which the
Consultant shall be entited [sic] to five percent (5%),of the gross amounts payable
to Cyberlux (the “Commission”) under commercial contracts sourced by
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Counsel describes a two-year post-services commission period and natural term through 1 January2026, and quotes underpayment interest at one
Counsel describes a two-year post-services commission period and natural term through 1 January2026, and quotes underpayment interest at one per cent monthly and the contractual ten-per-cent premium for the specified underpayment threshold. The contract’s culpability wording is an agreed label, not a judicial finding in this letter.
Read the anchor · page 3
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 3
Consultant, including, without limitation, the proceeds of joint ventures, licenses
and software as service agreements (collectively, the “Commissionable
Contracts”). Commissionable Contracts, including designated lines of business,
work orders, and similar in effect on the date hereof are listed on Schedule 2
hereto.
(emphasis added).
Schedule 2 of the Agreement provides:
The following are Commissionable Contracts and/or work orders in effect as
of January 1, 2023.
- That certain line of business related to the sale of tactical drones from time to
time for use by the Ministry of Defense of Ukraine, including without limitation,
Order no. 220/9169 dated September 21, 2022 for 1,000 tactical drones type
FlightEye KOA031831, plus training, service and maintenance for use by Ministry
of Defense of Ukraine.
And the January 5, 2023 Memorandum states (in relevant part):
The Agreement cited in Schedule 2, that certain Order no. 220/9169 dated
September 21, 2022 for 1,000 tactical drones type FlightEye KOA031831. The
Parties desire to memorialize that such order was subsequently increased to 2,000
units, as to which 5% commission is payable pursuant to the Agreement.
Montague is entitled to receive commissions “for two years after the termination of
the provision of Services under [the] Agreement” (see Section 3.3(a)) and the Agreement
does not terminate naturally until January 1, 2026 (see Section 2: “the term of this
Agreement . . . shall continue for a period of three years or until earlier terminated by
either party”).
Those terms—Section 3.2, Section 3.3, Schedule 2, and the excerpted portion of
the Memorandum—form the primary basis for Montague’s claims for amounts payable and
owing by Cyberlux under the 2023 Consulting Agreement.
Further, Montague is entitled to additional penalty payments, and interest
payments, on unpaid commissions. Specifically, Section 3.3(c) provides:
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Section3.5 is quoted as starting one-per-cent interest fifteen days after a due date, subject to the commission provision. Monthly statement
Section3.5 is quoted as starting one-per-cent interest fifteen days after a due date, subject to the commission provision. Monthly statements and access to commission books are also invoked. The overlapping clauses require a consistent calculation, not addition of two automatic monthly charges.
Read the anchor · page 4
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 4
In respect of any underpayment of Commission, Cyberlux will pay interest on such
underpayment at a rate of one percent (1%) per month; provided that if any
payment in respect of any Commissionable Contract is underpaid by an amount in
excess of ten percent (10%) of the amount payable thereunder in any month, the
Parties agree that such underpayment represents willful misconduct or gross
negligence on the part of Cyberlux, and must be cured within ten (10) business
days with an additional payment premium of an amount equal to ten (10) percent
of the underpayment amount.
Moreover, Section 3.5 provides:
Consultant shall have the right to charge interest on any unpaid Fees, Commission
and expenses at the rate of one percent (1.0%) per month, commencing 15 days
after the due date thereof, subject to the additional amount in respect of
underpaid Commission set forth in Section 3.3 above.
In addition to the fees and commissions due under the 2023 Consulting
Agreement, Montague is entitled to receive monthly statements (see Section 3.3(a):
“Cyberlux will, within the first five (5) business days of each month provide Consultant with
a statement of all payments made under Commissionable Contracts in the prior month”)
and “have access to the books and records of Cyberlux in respect of all Commissionable
Contracts in order to review and confirm the amounts payable as Commission.” (See
Section 3.3(c).)
Payments to Cyberlux Under the Ukraine-related Commissionable Contract
As you know, on or about August 29, 2023, Cyberlux entered into a contract with
HII to deliver FlightEye Model K8 drones for use by the Ministry of Defense of Ukraine.
That contract, with an initial total value of approximately $79 million, represents the
culmination of Montague's strategic efforts to position Cyberlux as a key supplier in the
defense sector. Based on information available to Montague, including Cyberlux's public
financial disclosures, Cyberlux received approximately $38.7 million in payments under
this contract during 2023. Furthermore, according to your June 4, 2025 correspondence,
HII is expected to make an additional payment of $25,795,303.38 to Cyberlux in the near
term. These payments are subject to Montague's entitlement to commissions at the
contractual rate of 5% under the 2023 Consulting Agreement.
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
On information available to Montague, including public material, the letter states Cyberlux received approximately $38.7 million in2023 and
On information available to Montague, including public material, the letter states Cyberlux received approximately $38.7 million in2023 and expects another $25,795,303.38 based on the receiver’s June4 correspondence. The latter payment is prospective in this source.
Read the anchor · page 4
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 4
In respect of any underpayment of Commission, Cyberlux will pay interest on such
underpayment at a rate of one percent (1%) per month; provided that if any
payment in respect of any Commissionable Contract is underpaid by an amount in
excess of ten percent (10%) of the amount payable thereunder in any month, the
Parties agree that such underpayment represents willful misconduct or gross
negligence on the part of Cyberlux, and must be cured within ten (10) business
days with an additional payment premium of an amount equal to ten (10) percent
of the underpayment amount.
Moreover, Section 3.5 provides:
Consultant shall have the right to charge interest on any unpaid Fees, Commission
and expenses at the rate of one percent (1.0%) per month, commencing 15 days
after the due date thereof, subject to the additional amount in respect of
underpaid Commission set forth in Section 3.3 above.
In addition to the fees and commissions due under the 2023 Consulting
Agreement, Montague is entitled to receive monthly statements (see Section 3.3(a):
“Cyberlux will, within the first five (5) business days of each month provide Consultant with
a statement of all payments made under Commissionable Contracts in the prior month”)
and “have access to the books and records of Cyberlux in respect of all Commissionable
Contracts in order to review and confirm the amounts payable as Commission.” (See
Section 3.3(c).)
Payments to Cyberlux Under the Ukraine-related Commissionable Contract
As you know, on or about August 29, 2023, Cyberlux entered into a contract with
HII to deliver FlightEye Model K8 drones for use by the Ministry of Defense of Ukraine.
That contract, with an initial total value of approximately $79 million, represents the
culmination of Montague's strategic efforts to position Cyberlux as a key supplier in the
defense sector. Based on information available to Montague, including Cyberlux's public
financial disclosures, Cyberlux received approximately $38.7 million in payments under
this contract during 2023. Furthermore, according to your June 4, 2025 correspondence,
HII is expected to make an additional payment of $25,795,303.38 to Cyberlux in the near
term. These payments are subject to Montague's entitlement to commissions at the
contractual rate of 5% under the 2023 Consulting Agreement.
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
The asserted current demand is $1,935,000 unpaid commission on $38.7 million, a $193,500 premium and $125,000 fees for January–June2025, bef
The asserted current demand is $1,935,000 unpaid commission on $38.7 million, a $193,500 premium and $125,000 fees for January–June2025, before interest. Six printed monthly fees of $20,833.33 sum to $124,999.98; $125,000 reflects exact half-year proration of the annual fee. Claimed underpayment and actual net debt require a ledger.
Read the anchor · page 5
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 5
Material Breaches of Consulting Agreement by Cyberlux
Cyberlux has materially breached multiple provisions of the 2023 Consulting
Agreement, depriving Montague of millions of dollars in rightfully earned compensation
while simultaneously failing to provide the transparency promised under the Agreement.
These breaches are not mere technical violations but represent a fundamental failure to
honor the contractual relationship that has been instrumental to Cyberlux's success.
Cyberlux’s Failure to Pay Commissions
Despite receiving approximately $38.7 million in payments during 2023 under the
Ukraine drone contract—a Commissionable Contract expressly identified in Schedule 2 of
the Agreement and subject to the 5% commission rate—Cyberlux has failed to pay
Montague any portion of the $1,935,000 in commissions due on these receipts. This
complete failure to pay commissions constitutes not only a material breach of Section 3.3
of the Agreement but also triggers the willful misconduct provisions of Section 3.3(c), as
the underpayment exceeds 10% of the amount payable (indeed, it represents a 100%
underpayment). Under the Agreement's terms, this gross underpayment subjects
Cyberlux to both interest charges at 1% per month and an additional penalty equal to 10%
of the underpayment amount.
Cyberlux’s Failure to Pay Consulting Fees From January 2025 through the Present
In addition to the commission obligations, Cyberlux has failed to pay the monthly
consulting fees required under Section 3.2 of the Agreement. Beginning with the January
2025 payment and continuing through the present, Cyberlux has failed to make six (6) of
the required monthly payments of $20,833.33. As of the date of this letter, the unpaid
consulting fees total $125,000 for the period January through June 2025, exclusive of
interest. This ongoing failure to pay base compensation represents a separate and
independent material breach of the Agreement.
Cyberlux’s Failure to Provide Required Statements
Compounding these payment failures, Cyberlux has breached its reporting
obligations under Section 3.3(a) of the Agreement by failing to provide monthly
statements detailing payments received under Commissionable Contracts. Despite the
clear requirement that such statements be provided within the first five business days of
each month, Montague has received no statements whatsoever regarding the substantial
payments Cyberlux has received under the Ukraine drone contract. This lack of
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Counsel says monthly statements have not been provided and that incomplete public information and third-party sources were therefore used. H
Counsel says monthly statements have not been provided and that incomplete public information and third-party sources were therefore used. He seeks all statements from January2023 onward and contract/payment records including HII invoices and bank information. The admitted information limit qualifies the monetary assertions.
Read the anchor · page 5
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 5
Material Breaches of Consulting Agreement by Cyberlux
Cyberlux has materially breached multiple provisions of the 2023 Consulting
Agreement, depriving Montague of millions of dollars in rightfully earned compensation
while simultaneously failing to provide the transparency promised under the Agreement.
These breaches are not mere technical violations but represent a fundamental failure to
honor the contractual relationship that has been instrumental to Cyberlux's success.
Cyberlux’s Failure to Pay Commissions
Despite receiving approximately $38.7 million in payments during 2023 under the
Ukraine drone contract—a Commissionable Contract expressly identified in Schedule 2 of
the Agreement and subject to the 5% commission rate—Cyberlux has failed to pay
Montague any portion of the $1,935,000 in commissions due on these receipts. This
complete failure to pay commissions constitutes not only a material breach of Section 3.3
of the Agreement but also triggers the willful misconduct provisions of Section 3.3(c), as
the underpayment exceeds 10% of the amount payable (indeed, it represents a 100%
underpayment). Under the Agreement's terms, this gross underpayment subjects
Cyberlux to both interest charges at 1% per month and an additional penalty equal to 10%
of the underpayment amount.
Cyberlux’s Failure to Pay Consulting Fees From January 2025 through the Present
In addition to the commission obligations, Cyberlux has failed to pay the monthly
consulting fees required under Section 3.2 of the Agreement. Beginning with the January
2025 payment and continuing through the present, Cyberlux has failed to make six (6) of
the required monthly payments of $20,833.33. As of the date of this letter, the unpaid
consulting fees total $125,000 for the period January through June 2025, exclusive of
interest. This ongoing failure to pay base compensation represents a separate and
independent material breach of the Agreement.
Cyberlux’s Failure to Provide Required Statements
Compounding these payment failures, Cyberlux has breached its reporting
obligations under Section 3.3(a) of the Agreement by failing to provide monthly
statements detailing payments received under Commissionable Contracts. Despite the
clear requirement that such statements be provided within the first five business days of
each month, Montague has received no statements whatsoever regarding the substantial
payments Cyberlux has received under the Ukraine drone contract. This lack of
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Upon receipt of the prospective $25,795,303.38 payment, the letter claims a further $1,289,765.17 commission within ten business days, with
Upon receipt of the prospective $25,795,303.38 payment, the letter claims a further $1,289,765.17 commission within ten business days, with an additional premium only if later triggered. The combined $3,543,265.17 includes this future component. The $3,418,265.17 commission-related subtotal includes the $193,500 premium and is not pure five-per-cent commission.
Read the anchor · page 6
Letter to Honorable Receiver Robert Berleth
June 10, 2025
Page 6
transparency has forced Montague to rely on incomplete public information and thirdparty sources to determine the extent of amounts owed, thereby frustrating the
Agreement's provisions designed to ensure accurate and timely commission payments.
Montague’s Claims and Records Demands
Based on the foregoing breaches, Montague requests:
1. Payment of All Amounts Due: Cyberlux owes (a) $1,935,000 in unpaid
commissions on the approximately $38.7 million received during 2023, (b)
$193,500 representing the 10% penalty on such underpayment pursuant to Section
3.3(c), (c) accrued interest on the unpaid commission at 1% per month from the
date each payment was due, (d) $125,000 in unpaid monthly consulting fees for
January through June 2025, and (e) accrued interest on unpaid consulting fees at
1% per month from each payment's due date.
2. Commission on Pending HII Payment: Upon receipt of the $25,795,303.38
payment from HII referenced in the Receiver's correspondence, Cyberlux will owe
Montague the 5% commission due thereon ($1,289,765.17) within ten business
days. Cyberlux’s failure to timely pay this commission triggers the 10% penalty
provisions of Section 3.3(c).
3. Provision of Monthly Statements: Please cause Cyberlux to provide all monthly
statements required under Section 3.3(a) from January 2023 through the present,
detailing all payments received under the Ukraine drone contract and any other
Commissionable Contracts.
4. Access to Books and Records: Pursuant to Section 3.3(c), Montague requests
access to all books and records of Cyberlux relating to Commissionable Contracts,
including but not limited to all invoices, payment records, correspondence with HII,
and banking records showing receipt of payments.
Montague understands that Cyberlux's receivership status will require Court
approval for certain actions. Montague will work constructively with you to ensure
Cyberlux’s obligations are satisfied in accordance with applicable law and court orders.
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Jason M. Zoladz
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Robert Berleth
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Montague
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Cyberlux
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Denis Kalenja
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
eventattribution
Zoladz’s claim letter is dated 10 June2025.
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
eventattribution
Clerk stamp records filing at9:36PM.
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
inferenceinference
The headline demand combines current alleged underpayments, a premium and a contingent future commission. It cannot be used as proof that th
The headline demand combines current alleged underpayments, a premium and a contingent future commission. It cannot be used as proof that the entire sum was already due or that all underlying receipts had occurred.
otherattribution
Complete supplied 8-page source reviewed at SHA-256 2c547c77346b7002d3c1d7dd8049ddbd1b7ef1a21d744bedf5280dae6683e47f. Source assertions, ori
Complete supplied 8-page source reviewed at SHA-256 2c547c77346b7002d3c1d7dd8049ddbd1b7ef1a21d744bedf5280dae6683e47f. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. No unexamined later court outcome is inferred.
Read the anchor · page 1
June 10, 2025
VIA E-MAIL
Robert Berleth
Appointed Receiver
Berleth & Associates, PLLC
9950 Cypresswood Dr., Suite 200
Houston, TX 77070
rberleth@berlethlaw.com
Re: Montague Capital Partners, LLC - Proof of Claim in Cyberlux Corporation
Receivership in Connection with Atlantic Wave Holdings, LLC, et al. v. Cyberlux
Corporation, et al., Cause No. 2024-48085, 129th Judicial District Court of Harris
County, Texas
Dear Honorable Receiver Robert Berleth:
I represent Montague Capital Partners, LLC (“Montague”) in connection with
amounts due under the January 1, 2023 Amended and Restated Consulting Agreement
(“Agreement”), and associated January 5, 2023 Memorandum (“Memorandum”)
(collectively, the “2023 Consulting Agreement”), between Montague and Cyberlux
Corporation (“Cyberlux”). I write to submit documentation of Montague’s claims against
Cyberlux Corporation in the above-referenced receivership proceedings.
Background
Montague’s Work on Behalf of Cyberlux
Montague and Cyberlux have maintained a close working relationship since 2019,
formalized in the original January 1, 2019 Consulting Agreement (Encl. 1) and
subsequently amended and restated via the 2023 Consulting Agreement (Encls. 2 & 3).
Montague, and its Managing Partner, Denis Kalenja, was the driving force behind
Cyberlux’s most important acquisitions and was responsible for sourcing and negotiating
Law Offices of Jason M. Zoladz
+1-917-698-9995 jason@zoladzlaw.com P.O. Box 26954, Los Angeles, California 90026
6/11/2025 9:36 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101916709
By: Shanelle Taylor
Filed: 6/11/2025 9:36 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
questionquestion
What actual bank receipts, statements, credits and payment records establish the commission base and net unpaid balance?
questionquestion
How are interest commencement and overlapping clauses reconciled, and what receipt triggers the future commission?
questionquestion
What executed instruments, service records and termination notices establish the asserted sourcing entitlement and applicable tail?
questionquestion
What filed proceedings or receiver/court dispositions followed this demand?
distillateallegation
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Upon receipt of the prospective $25,795,303.38 payment, the letter claims a further $1,289,765.17 commission within ten business days, with an additional premium only if later triggered. The combined $3,543,265.17 includes this future component. The $3,418,265.17 commission-related subtotal includes the $193,500 premium and is not pure five-per-cent commission.referencesThe current asserted components are $1,935,000 commission, $193,500 premium and $125,000 fees, totalling $2,253,500 before interest. Another $1,289,765.17 is claimed within ten business days after receipt of the prospective HII payment, with a further premium only on a later qualifying failure. The headline $3,543,265.17 includes this future component.
Both sources combine current alleged2253500 with prospective1289765.17; common claimant repetition does not prove receipt.
The claimant acknowledges reliance on incomplete public information and third-party sources because it says statements were withheld.referencesMontague says it relies on incomplete public information and third-party sources without the requested statements.
Both acknowledge incomplete public information and missing statements; common limitation preserved.
The letter quotes the 2023 annual fee of $250,000 and commission rates of two per cent generally and five per cent for Ukraine-related sourced contracts, based on gross amounts payable. It refers to Schedule2 Order220/9169 of 21 September2022 for 1,000 units and the Jan5 memo’s increase to 2,000. The underlying government order is not supplied by quoting this contractual schedule.referencesSection 3.3 grants two per cent of gross amounts payable under sourced commercial contracts, except five per cent for Ukraine-related contracts; joint ventures, licences and software-as-service arrangements are included. Listed contracts and subsequently sourced relationships/work orders fall within the described mechanism. Statements and commission payments are due in the first five business days of each month, with a stated two-year post-service period.
Demand cites the contractual commission mechanism; actual performance/receipts remain separate.
The letter quotes the 2023 annual fee of $250,000 and commission rates of two per cent generally and five per cent for Ukraine-related sourced contracts, based on gross amounts payable. It refers to Schedule2 Order220/9169 of 21 September2022 for 1,000 units and the Jan5 memo’s increase to 2,000. The underlying government order is not supplied by quoting this contractual schedule.supportsWhat executed instruments, service records and termination notices establish the asserted sourcing entitlement and applicable tail?
Specifically named source propositions support the bounded distinction or question.
The asserted current demand is $1,935,000 unpaid commission on $38.7 million, a $193,500 premium and $125,000 fees for January–June2025, before interest. Six printed monthly fees of $20,833.33 sum to $124,999.98; $125,000 reflects exact half-year proration of the annual fee. Claimed underpayment and actual net debt require a ledger.supportsWhat actual bank receipts, statements, credits and payment records establish the commission base and net unpaid balance?
Specifically named source propositions support the bounded distinction or question.
On information available to Montague, including public material, the letter states Cyberlux received approximately $38.7 million in2023 and expects another $25,795,303.38 based on the receiver’s June4 correspondence. The latter payment is prospective in this source.supportsThe headline demand combines current alleged underpayments, a premium and a contingent future commission. It cannot be used as proof that the entire sum was already due or that all underlying receipts had occurred.
Specifically named source propositions support the bounded distinction or question.
The letter requests acknowledgement and payment, recognises that certain receiver actions may need court approval, anticipates litigation soon and requests preservation of relevant agreements, communications, payment records and financial material. A demand, anticipated suit or preservation request is not an entered judgment or proof that the suit was filed.supportsWhat filed proceedings or receiver/court dispositions followed this demand?
Specifically named source propositions support the bounded distinction or question.
The asserted current demand is $1,935,000 unpaid commission on $38.7 million, a $193,500 premium and $125,000 fees for January–June2025, before interest. Six printed monthly fees of $20,833.33 sum to $124,999.98; $125,000 reflects exact half-year proration of the annual fee. Claimed underpayment and actual net debt require a ledger.supportsWas the entire $3,543,265.17 based on money already received?
Specifically named source propositions support the bounded distinction or question.
Section3.5 is quoted as starting one-per-cent interest fifteen days after a due date, subject to the commission provision. Monthly statements and access to commission books are also invoked. The overlapping clauses require a consistent calculation, not addition of two automatic monthly charges.supportsHow are interest commencement and overlapping clauses reconciled, and what receipt triggers the future commission?
Specifically named source propositions support the bounded distinction or question.
Counsel describes a two-year post-services commission period and natural term through 1 January2026, and quotes underpayment interest at one per cent monthly and the contractual ten-per-cent premium for the specified underpayment threshold. The contract’s culpability wording is an agreed label, not a judicial finding in this letter.supportsWhat executed instruments, service records and termination notices establish the asserted sourcing entitlement and applicable tail?
Specifically named source propositions support the bounded distinction or question.
Counsel says monthly statements have not been provided and that incomplete public information and third-party sources were therefore used. He seeks all statements from January2023 onward and contract/payment records including HII invoices and bank information. The admitted information limit qualifies the monetary assertions.supportsWhat actual bank receipts, statements, credits and payment records establish the commission base and net unpaid balance?
Specifically named source propositions support the bounded distinction or question.
The asserted current demand is $1,935,000 unpaid commission on $38.7 million, a $193,500 premium and $125,000 fees for January–June2025, before interest. Six printed monthly fees of $20,833.33 sum to $124,999.98; $125,000 reflects exact half-year proration of the annual fee. Claimed underpayment and actual net debt require a ledger.supportsThe headline demand combines current alleged underpayments, a premium and a contingent future commission. It cannot be used as proof that the entire sum was already due or that all underlying receipts had occurred.
Specifically named source propositions support the bounded distinction or question.
On information available to Montague, including public material, the letter states Cyberlux received approximately $38.7 million in2023 and expects another $25,795,303.38 based on the receiver’s June4 correspondence. The latter payment is prospective in this source.supportsWhat actual bank receipts, statements, credits and payment records establish the commission base and net unpaid balance?
Specifically named source propositions support the bounded distinction or question.
Counsel describes a two-year post-services commission period and natural term through 1 January2026, and quotes underpayment interest at one per cent monthly and the contractual ten-per-cent premium for the specified underpayment threshold. The contract’s culpability wording is an agreed label, not a judicial finding in this letter.supportsHow are interest commencement and overlapping clauses reconciled, and what receipt triggers the future commission?
Specifically named source propositions support the bounded distinction or question.
Upon receipt of the prospective $25,795,303.38 payment, the letter claims a further $1,289,765.17 commission within ten business days, with an additional premium only if later triggered. The combined $3,543,265.17 includes this future component. The $3,418,265.17 commission-related subtotal includes the $193,500 premium and is not pure five-per-cent commission.supportsHow are interest commencement and overlapping clauses reconciled, and what receipt triggers the future commission?
Specifically named source propositions support the bounded distinction or question.
Upon receipt of the prospective $25,795,303.38 payment, the letter claims a further $1,289,765.17 commission within ten business days, with an additional premium only if later triggered. The combined $3,543,265.17 includes this future component. The $3,418,265.17 commission-related subtotal includes the $193,500 premium and is not pure five-per-cent commission.supportsThe headline demand combines current alleged underpayments, a premium and a contingent future commission. It cannot be used as proof that the entire sum was already due or that all underlying receipts had occurred.
Specifically named source propositions support the bounded distinction or question.
Counsel describes Montague and Denis Kalenja as the driving force behind Cyberlux’s acquisitions, defence transition, Catalyst development, Datron integration, CE removal and sourcing the approximately $79 million HII contract. These are the claimant’s performance/causation assertions, not independent findings that Montague alone produced those outcomes.supportsWhat executed instruments, service records and termination notices establish the asserted sourcing entitlement and applicable tail?
Specifically named source propositions support the bounded distinction or question.
Upon receipt of the prospective $25,795,303.38 payment, the letter claims a further $1,289,765.17 commission within ten business days, with an additional premium only if later triggered. The combined $3,543,265.17 includes this future component. The $3,418,265.17 commission-related subtotal includes the $193,500 premium and is not pure five-per-cent commission.supportsWas the entire $3,543,265.17 based on money already received?
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.