CURTIN

IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

JAMES CURTIN, )

)

Plaintiff, )

)

v. ) 1:25CV782

)

CHUCK WATTS, et al., )

)

Defendants. )

MEMORANDUM OPINION AND ORDER

THOMAS D. SCHROEDER, District Judge.

In this case, Plaintiff James Curtin, who proceeds pro se,

asserts claims against Defendants Chuck Watts (“Watts”), his law

firm, Watts Law PLC (“Watts Law”)1, Cyberlux Corporation

(“Cyberlux”), and HII Mission Technologies Corporation (“HII”),

alleging various acts of misconduct relating to federal defense

contracts, as well as a conspiracy to retaliate against Curtin for

exposing the alleged misconduct on his blog. Before the court are

motions by Defendants HII (Doc. 20), Watts (Doc. 32), and Cyberlux

(Doc. 44) to dismiss the claims against them in the amended

complaint (Doc. 7)(the “complaint”) pursuant to Federal Rules of

Civil Procedure 12(b)(1) and (6). All three motions are fully

briefed and ready for decision. (Docs. 21, 29, 34; Docs. 32, 35,

40; Docs. 45, 48, 51.) For the reasons set forth below, the

1 The complaint does not allege any conduct by Watts Law separate from

Watts. Therefore, the court will construe Watts’s pro se motion to

dismiss (Doc. 32) as a motion on behalf of both Watts and Watts Law.

motions will be granted and the complaint dismissed.

I. BACKGROUND

The well-pleaded allegations in the complaint, viewed in the

light most favorable to Curtin as the non-moving party, show the

following:

Curtin is the owner and principal of Carotank Road Holdings

Inc, a Virginia corporation engaged in consulting and technology

development, as well as an author publishing under the pen name

“Jackson Holt.” (Doc. 7 at 6.) In 2023, executives of Defendant

Cyberlux approached Curtin “for joint ventures and technical

partnerships involving one of [Curtin’s] clients.” (Id. at 10.)

While conducting diligence on Cyberlux for his client, Curtin

uncovered “legal, regulatory, and financial red flags including

judgments, liens, lawsuits, and questionable public

representations.” (Id.) Curtin communicated his findings to his

client as well as Cyberlux executive Bill Maadarani and Cyberlux

principal Denis Kalenja.2 (Id.) In November 2024, Curtin began

publishing a series of articles under his “Jackson Holt” alias,

accusing Cyberlux of “compliance irregularities” and misuse of

foreign military financing (“FMF”) funds. (Id. at 8.)

Curtin alleges that he “observed an individual photographing

him” On May 10, 2025, around the same time that he received a

2 Neither Kalenja nor Maadarani is named as a Defendant in the present

action.

message from Maadarani. (Id. at 11.) On May 27, 2025, an anonymous

X (formerly Twitter) account published tweets “doxxing and

harassing [Curtin] and his family” as well as “referencing

investigators”, once again around the same time that he received

a message from Maadarani. (Id.) In June 2025, Maadarani contacted

one of Curtin’s clients. (Id.) Curtin alleges without elaboration

that in May 2025 and June 2025, “[m]ultiple partners withdrew from

negotiations or cancelled deals [presumably with Curtin’s company]

tied to the harassment campaign [against him].” (Id.)

Based on the foregoing, Curtin asserts claims against

Defendants Cyberlux, Watts, and Watts Law for “tortious

interference with business expectancy” (Count 1) and civil

conspiracy (Count 2), claims against all Defendants for “breach of

fiduciary duty/misuse of public office” (Count 3), and claims

against HII and Cyberlux for negligent supervision (Count 4).

II. ANALYSIS

Federal Rule of Civil Procedure 8(a)(2) provides that a

complaint must contain “a short and plain statement of the claim

showing that the pleader is entitled to relief.” Fed. R. Civ. P.

(8)(a)(2). Under Federal Rule of Civil Procedure 12(b)(6), “a

complaint must contain sufficient factual matter . . . to ‘state

a claim to relief that is plausible on its face.’” Ashcroft v.

Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp.

v. Twombly, 550 U.S. 544, 570, (2007)). A claim is plausible “when

the plaintiff pleads factual content that allows the court to draw

the reasonable inference that the defendant is liable for the

misconduct alleged.” Id. In considering a Rule 12(b)(6) motion,

a court “must accept as true all of the factual allegations

contained in the complaint,” Erickson v. Pardus, 551 U.S. 89, 94

(2007) (per curiam), and all reasonable inferences must be drawn

in the plaintiff’s favor, Ibarra v. United States, 120 F.3d 472,

474 (4th Cir. 1997). However, mere legal conclusions are not

accepted as true, and “[t]hreadbare recitals of the elements of a

cause of action, supported by mere conclusory statements, do not

suffice.” Iqbal, 556 U.S. at 678.

“[D]etermining whether a complaint states a plausible claim

for relief is a ‘context-specific task.’ ” Langford v. Joyner, 62

F.4th 122, 126 (4th Cir. 2023) (quoting Iqbal, 556 U.S. at 679).

There is no categorical rule that a complaint cannot make

allegations collectively against multiple defendants. Id.

However, if a plaintiff employs a “global manner of pleading,” he

must still allege “sufficient facts to allow the court to infer

liability as to each defendant.” Id. (internal citations omitted).

Defendants have identified myriad problems with Curtin’s

lawsuit. Relevant to the motions to dismiss, Curtin’s complaint

fails to state a claim because the federal statutory violations he

alleges do not give rise to a private right of action, he has not

alleged any legally cognizable duty that the Defendants breached,

and his claims are not otherwise cognizable under Virginia law.

A. No Federal Private Right of Action

HII, Cyberlux, and Watts all argue that Curtin’s claims rest

on federal statutes that do not create a private right of action.3

(Doc. 21 at 8-9; Doc. 45 at 11-15; Doc. 32 at 2-3.) In Count 1,

Curtin alleges that Defendants Watts and Cyberlux violated 18

U.S.C. §§ 2261A, 875(c)¸and 1030 in a way that interfered with his

“business expectancy.” (Doc. 7 at 15.) In Count 2, he alleges

that Watts and Cyberlux conspired to commit violations of 18 U.S.C.

§§ 1343, 2261A, 875(c), and 1512. (Id. at 17.) In Count 3, he

alleges that all Defendants breached “fiduciary duties” in ways

that implicate 41 U.S.C. § 4712 and 18 U.S.C. §§ 1001 and 1343 as

well as unspecified “provisions of the [Federal Acquisition

Regulations (“FAR”)], [Defense Federal Acquisition Regulations

Supplement (“DFARS”)], and [International Traffic in Arms

Regulations (“ITAR”)] governing the allowability of costs, ethical

conduct, and contractor responsibility.” (Id. at 22.). In Count

4, he likewise alleges that HII and Cyberlux were negligent in

their supervision of Watts in ways that implicate 41 U.S.C. § 4712,

18 U.S.C. §§ 1343 and 1512, and “applicable FAR, DFARS, and ITAR

provisions.” (Id. at 24.)

3 HII and Cyberlux also argue that this deficiency deprives the court of

subject matter jurisdiction as to Counts 3 and 4. (See Doc. 45 at 13-

15.) However, a statute may support federal question jurisdiction

without creating a private right of action. See Grable & Sons Metal

Products, Inc. v. Darue Engineering & Mfg., 545 U.S. 308, 317 (2005).

As Cyberlux notes, none of these federal statutes or

regulations provides a right of action for plaintiffs in Curtin’s

position. (Doc. 45 at 11.) As for Defendants’ alleged violations

of FAR, DFARS, and ITAR, these cannot provide a private right of

action unsupported by statute. See Alexander v. Sandoval, 532

U.S. 275, 291 (2001)(“Language in a regulation may invoke a private

right of action that Congress through statutory text created, but

it may not create a right that Congress has not.”). Curtin’s

complaint does not identify which specific regulatory provisions

Defendants allegedly violated, much less any underlying statutes

that would authorize him to bring a private suit. As for the

alleged violations of 18 U.S.C. §§ 2261A, 875(c), 1343, and 1001,

these are all criminal statues whose enforcement “has been

entrusted exclusively to the federal government.” State of Ga. v.

Pennsylvania R. Co., 324 U.S. 439, 447 (1945).

Only two of the federal statutes cited by Curtin contain any

private right of action. First, the Computer Fraud and Abuse Act,

18 U.S.C. § 1030 (the “CFAA”), creates a limited civil cause of

action, but the plaintiff must plead a qualifying loss “by reason

of a violation of this section.” See 18 U.S.C. § 1030(g). But as

Cyberlux notes, Curtin has not alleged any particular violation of

§ 1030. (Doc. 45 at 12.) Second, 41 U.S.C. § 4172 provides a cause

of action for employees of government contractors, subcontractors,

grantees, subgrantees, or personal service contractors who have

suffered retaliation for protected disclosures and exhausted

administrative remedies. See 41 U.S.C. § 4172(a) and (c)(2).

Curtin represents in his brief that he filed whistleblower

disclosures with the General Services Administration and

Department of Defense in 2024, and that 210 days have elapsed

without a determination, which he contends “satisf[ies] the

exhaustion requirement under 41 U.S.C. § 4712.” (Doc. 48 at 11.)

But as Cyberlux points out, Curtin does not allege that he is or

ever was an employee of any Defendant, and thus the anti-

retaliation protections of § 4712 simply do not apply to him.

(Doc. 45 at 14.)

In sum, Defendants are correct that none of the federal

statutes or regulations in the complaint provides Curtin with a

private right of action for his claims. Thus, Defendants’ motion

to dismiss these claims will be granted.

B. Failure to State a Claim under Virginia Law

The court next considers whether Curtin has stated a claim

under applicable state law. “A federal court sitting in diversity

is required to apply the substantive law of the forum state,

including its choice-of-law rules.” Francis v. Allstate Ins. Co.,

709 F.3d 362, 369 (4th Cir. 2013). The Supreme Court of North

Carolina’s “jurisprudence favors the use of the lex loci test in

cases involving tort or tort-like claims.” SciGrip, Inc. v. Osae,

838 S.E.2d 334, 343 (N.C. 2020). Pursuant to the lex loci test,

the court should apply the substantive law of the state “where the

injury or harm was sustained or

suffered.” Id. (quoting Harco Nat’l Ins. Co. v. Grant Thornton

LLP, 698 S.E.2d 719, 724 (N.C. Ct. App. 2010)). HII and Cyberlux

both contend, and Curtin does not dispute, that Curtin suffered

his alleged injuries in Virginia, where his company is located.

(Doc. 21 at 12-13; Doc. 45 at 9 n.8; see Doc. 7 at 4-6.) Thus,

Virginia substantive law governs his claims.

1. Tortious Interference (Count 1)

Watts argues that Count 1 fails to state a claim because the

complaint fails to allege that he engaged in any conduct that would

be actionable in Virginia under a recognized theory of tort

liability. (Doc. 32 at 4-5.) Meanwhile, Cyberlux argues that

Carotank Road Holdings, Inc., and not Curtin, is the true party in

interest for this claim.4 (Doc. 45 at 2.) Responding to Watts,

Curtin argues that unspecified Cyberlux officers “circulated false

espionage claims and disclosed [his] private information,” and

that this occurred “while Watts directed legal affairs,” which he

contends is sufficient conduct to support tort liability. (Doc.

35 at 16.) To Cyberlux, Curtin responds that he is willing to

stipulate to the joinder of Carotank Road Holdings, Inc., but only

4 Curtin’s complaint and accompanying declaration do indeed suggest that

Carotank Road Holdings, Inc., is the true party in interest for any claim

pertaining to Curtin’s “business.” (See Doc. 7 at 6; Doc. 7-1.) The

court need not reach this issue, however, because the claim suffers from

more fundamental defects.

if certain Cyberlux shareholders will consent to be joined in their

individual capacities because they “are the company’s largest

Series B shareholders, control insiders, and beneficiaries of the

conduct at issue.” (Doc. 48 at 2.)

In Virginia, the elements of a prima facie case of tortious

interference with business expectancy are (1) the existence of a

valid business expectancy; (2) knowledge of the expectancy on the

part of the interferer; (3) intentional interference inducing or

causing a breach or termination of the relationship or expectancy;

and (4) resultant damage to the party whose relationship or

expectancy has been disrupted. Dunlap v. Cottman Transmission

Systems, LLC, 754 S.E.2d 313, 318, (Va. 2014). Defendants argue

that Curtin’s allegations fail to state a plausible claim. (Doc.

45 at 5-9; Doc. 32 at 4-5.)

Here, Defendants are correct. While a complaint need not

make out a prima facie case, it must still “allege facts to satisfy

the elements of a cause of action.” McCleary-Evans v. Md. Dep't

of Transp., 780 F.3d 582, 585 (4th Cir. 2015). A “formulaic

recitation” of the necessary elements does not suffice to render

a claim plausible. Id. (quoting Iqbal, 556 U.S. at 678–79).

Here, the complaint fails to state a plausible claim of intentional

interference. It alleges generally that “Defendants,” acting

“individually and in concert,” committed the following acts of

interference:

(a) Public “doxxing” of [Curtin] by releasing personal

identifying information without consent;

(b) Retaliatory statements;

(c) Direct, inappropriate contact by Cyberlux officer

Bill Maadarani with one of [Curtin’s] clients, intended

to disrupt that business relationship;

(d) False accusations and reputational attacks

communicated to third parties with the intent and

knowledge they would damage [Curtin’s] credibility;

[and]

(e) Threats, both explicit and implicit, designed to

deter third parties from associating with [Curtin.]

(Doc. 7 at 14.) Because Curtin employs a “global manner of

pleading,” he must allege “sufficient facts to allow the court to

infer liability as to each defendant.” Langford, 62 F.4th at 126.

The only conduct attributed to a specific Defendant is the

“[d]irect, inappropriate contact” between Cyberlux officer

Maadarani and one of the clients of Curtin’s business (which is

not a party). But the record is devoid of any facts to support

the conclusory allegations that this conduct was “inappropriate”

or “intended to disrupt [Curtin’s] business relationship.” On the

contrary, the screenshot of the communication (Doc. 7-12), which

Curtin attached to his complaint,5 shows that Maadarani was merely

asking if the client (with whom he was evidently already

acquainted) knew why Curtin had been posting anonymous criticisms

5 In evaluating a motion to dismiss, the court may consider documents

attached to the complaint without converting the motion to one for

summary judgment. Fed. R. Civ .P. 10(c); see Philips v. Pitt Cty. Mem’l

Hosp., 572 F.3d 176, 180 (4th Cir. 2009).

of Maadarani as “Jackson Holt,” and noting his intention to seek

legal advice regarding the posts. (See id. at 2.) It does not,

contrary to Curtin’s allegation, contain anything that could be

described as a “veiled threat.” (Doc. 7 at 11.)

Because Curtin’s allegations fail to set forth specific facts

to support a claim of interference by any Defendant, Count 1 fails

to plausibly state a claim against any specific Defendant and will

be dismissed without prejudice.

2. Civil Conspiracy (Count 2)

Cyberlux argues that Curtin has failed to state a claim for

civil conspiracy because he offers only a conclusory allegation

that the Defendants conspired for purpose of “[i]njuring Plaintiff

in his business, reputation, and creative work.” (Doc. 45 at 9-

10; see Doc. 7 at 16.) Curtin does not respond to this argument.

In Virginia, civil conspiracy is a statutory claim that arises

when “two or more persons . . . combine, associate, agree, mutually

undertake or concert together . . . for the purpose of willfully

and maliciously injuring another in his reputation, trade,

business or profession by any means whatever.” Va. Stat. Ann.

§§ 18.2-499 and 18.2-500; see Simmons v. Miller, 544 S.E.2d 666,

676-77 (Va. 2001.) “To recover in a civil conspiracy action both

under the common law and under Virginia Code § 18.2-499, a

plaintiff must establish that at least one member of the

conspiracy, in agreement with another member, committed an act

that was itself wrongful or tortious, and that such act damaged

the plaintiff.” L-3 Commc'ns Corp. v. Serco, Inc., 926 F.3d 85,

92 (4th Cir. 2019) (citing Gelber v. Glock, 800 S.E.2d 800, 821

(Va. 2017)). For a statutory business conspiracy claim, a

plaintiff must also plausibly allege legal malice, or that one of

the conspiracy's purposes was to injure “Plaintiff's reputation,

trade, or business.” Schlegel v. Bank of America, N.A., 505 F.

Supp. 2d 321, 326 (W.D. Va. 2007) (citing Simmons, 544 S.E.2d at

677).

The Federal Rules of Civil Procedure govern the requirements

for pleading “in all civil actions and proceedings in the United

States district courts.” Fed. R. Civ. P. 1; see Iqbal, 556 U.S.

at 684. Rule 9(b) provides that “[m]alice, intent, knowledge, and

other conditions of a person's mind may be alleged generally.”

Fed. R. Civ. P. 9(b). However, because a civil conspiracy claim

in Virginia requires proof of some underlying unlawful conduct, a

plaintiff must still adequately plead the underlying act or acts.

Aimbridge Hospitality, LLC v. Provident Group – Radford

Properties, LLC, No. 7:24-cv-00262, 2024 WL 3534150, at *8 (W.D.

Va. July 24, 2024). Here, the complaint fails to allege sufficient

facts to make plausible that any Defendant committed a wrongful or

tortious act in furtherance of the conspiracy. It alleges that

undifferentiated “Defendants” engaged in various acts in

furtherance of the conspiracy, but the only act attributed to a

specific Defendant is the same communication from Count 1 between

Cyberlux’s Maadarani and the “client” of Curtin’s business. (Doc.

7 at 16-17.) As discussed above, this communication is innocuous

on its face. It is not a wrongful or tortious act that can support

the civil conspiracy claim. Thus, Defendants’ motion will be

granted and Count 2 will be dismissed without prejudice.

3. Breach of Fiduciary Duty (Count 3)

HII, Watts, and Cyberlux all argue that Count 3 must be

dismissed because Curtin does not allege that Defendants owed any

fiduciary duty to him specifically. (Doc. 21 at 14-15; Doc. 32 at

3; Doc. 45 at 10.) In response, Curtin reiterates that Defendants

had a general duty to comply with federal laws and regulations.

(Doc. 29 at 8-9.)

To state a plausible breach of fiduciary duty claim under

Virginia law, a plaintiff must allege facts to show (1) the

existence of a fiduciary duty, (2) the breach of that duty, and

(3) resulting damages. Carstensen v. Chrisland Corp., 442 S.E.2d

660, 666–67 (Va. 1994); Broadhead v. Watterson, No. 5:15-cv-00020,

2016 WL 742127, at *6 (W.D. Va. Feb. 24, 2016) (applying Virginia

law). Here, the complaint alleges that Defendants breached duties

owing to “the public,” “the U.S. government,” and “foreseeable

persons impacted by non-compliance” with various federal and state

laws and regulations. (Doc. 7 at 18-22.) As Cyberlux notes, none

of these allegations describes a fiduciary duty owed to Curtin.

(Doc. 45 at 10.) Thus, Count 3 fails to state a claim under

Virginia law, and it will be dismissed.

4. Negligent Supervision (Count 4)

As HII and Cyberlux both note, Virginia courts do not

recognize an independent cause of action for negligent

supervision. See Elrod v. Busch Entertainment Corp., Nos.

4:09cv164, 4:09cv165, 4:09cv166, 2010 WL 5620918, at *6 (E.D. Va.

Dec. 14, 2010) (collecting cases), report and recommendation

adopted 2011 WL 166636 (E.D. Va. Jan 19, 2011). Curtin appears to

concede this, as his briefs in opposition do not address the

negligent supervision claim in Count 4. It will thus be dismissed.

C. Rule 11(b) and Fabrication of Legal Authority

Finally, Curtin points to reprimands issued against Cyberlux

in other litigation, specifically an order to pay attorneys’ fees

and a show-cause order for fabricating or misrepresenting legal

authorities. (Doc. 48 at 9.) He contends that Cyberlux has

engaged in a “persistent pattern of deception and obstruction”

that undermines Cyberlux's argument that the complaint’s “well-

documented facts” are implausible. (Id.)

There is a certain irony in all of this. Curtin’s brief

contains fabricated quotations that directly contradict the actual

holdings of the cited cases – the same misconduct he invokes to

discredit Cyberlux. Cyberlux’s conduct has already been addressed

by those courts.6 Meanwhile, this court must address Curtin’s

conduct in the present case.

Curtin represents that in Sinochem International Co. Ltd. v.

Malaysia International Shipping Corp., 549 U.S. 422, 430 (2007),

the United States Supreme Court held that “[a] court lacking

jurisdiction . . . must dismiss, it cannot transfer.” (See Doc.

29 at 7.) This quotation is a fabrication. On the contrary, the

court in Sinochem reaffirmed that a case may be transferred

“whether the court in which it was filed had personal jurisdiction

over the defendants or not.” 549 U.S. at 430 (quoting Goldlawr,

Inc. v. Heiman, 369 U.S. 463, 466 (1962)). Similarly, in

Christianson v. Colt Industries Operating Corp., 486 U.S. 800, 817

(1988), the Supreme Court never stated that a transferee court

“should not revisit a jurisdictional ruling made by a coordinate

court unless it is clearly erroneous,” as Curtin represents. (See

Doc. 29 at 7.) Rather, it noted that a court “has the power to

revisit prior decisions of its own or of a coordinate court in any

circumstance, although as a rule courts should be loathe to do so

in the absence of extraordinary circumstances such as where the

initial decision was ‘clearly erroneous and would work a manifest

injustice.’” Christianson, 486 U.S. at 817 (quoting Arizona v.

6 See Atlantic Wave Holdings, LLC v. Cyberlux Corporation, No. 25-1689,

2025 WL 3493221 (S.D. Tex. May 14, 2025); HII Mission Technologies Corp.

v. Cyberlux Corp., No. 3:25-cv-483-JAG, Doc. 118 (E.D. Va. December 15,

2025).

California, 460 U.S. 605, 618, n.8 (1983)).

All litigants, whether pro se or represented, are bound by

the Federal Rules of Civil Procedure. See, e.g., McNeil v. United

States, 508 U.S. 106, 113, (1993); Hansan v. Fairfax Cty. Sch.

Bd., 405 F. App'x 793, 794 (4th Cir. 2010) (per curiam).

Rule 11(b)(2) states that by signing a filing, an attorney or

unrepresented party certifies that, to the best of his knowledge

and after a reasonable inquiry, “the claims, defenses, and other

legal contentions are warranted by existing law or by a

nonfrivolous argument for extending, modifying, or reversing

existing law or for establishing new law.” The rule permits courts

to sanction litigants for citations to non-existent case law,

misrepresentations of case law, or frivolous legal arguments,

regardless of the filer’s pro se status. See, e.g., Ferris v.

Amazon.com Services, LLC, 778 F. Supp. 3d 879, 881-82 (N.D. Miss.

2025) (ordering a pro se plaintiff to pay the defendant’s costs

incurred in responding to fabricated citations). “Courts across

the country have issued sanctions against attorneys and pro se

parties for submitting fictitious case citations, fictitious

quotations, and related misrepresentations to the court.” United

States v. Hayes, 763 F. Supp. 3d 1054, 1071 (E.D. Cal. 2025)

(collecting cases) (emphasis added).

It is not clear whether Curtin’s complaint and briefs are the

product of artificial intelligence. To be sure, this court has

seen an uptick in the use of artificial intelligence in complaints

and briefs, especially by pro se filers. Whether or not Curtin

used such tools, he is admonished that every filer, including a

pro se filer, is “obligated to read the legal authority he intends

to rely upon, confirm its existence and validity, and confirm that

it supports his legal contentions, before citing to that authority

in any submission to this Court.” Allen v. Western Governors

University, No. 2:25-cv-00325-RFB-NJK, 2026 WL 893368, at *1 (D.

Nev. Mar. 31, 2026). Obviously, Curtin did not do that. Curtin

is thus warned that any future filings containing fabricated legal

authority may result in sanctions under Rule 11.

III. CONCLUSION

For the reasons stated, therefore,

IT IS ORDERED that Defendant HII’s motion to dismiss (Doc.

20) is GRANTED, Defendant Watts’s motion to dismiss (Doc. 32) is

GRANTED as to both Defendant Watts and co-Defendant Watts Law, and

Defendant Cyberlux’s motion to dismiss (Doc. 44) is GRANTED, and

the complaint is dismissed: all claims founded on violation of

statutes for which the court has held there is no private right of

action are DISMISSED WITH PREJUDICE, Counts 3 and 4 are DISMISSED

WITH PREJUDICE, and the remaining claims in Counts 1 and 2 are

DISMISSED WITHOUT PREJUDICE.

Curtin is hereby WARNED that any future filings containing

fabricated legal authority may result in sanctions under Rule 11.

/s/ Thomas D. Schroeder

United States District Judge

May 20, 2026