Cartwheel Robotics Bankruptcy Case Archive

UNITED STATES BANKRUPTCY COURTDISTRICT OF NEVADA In re:CARTWHEEL ROBOTICS INC.Debtor. Case No. 26-50278-HLB SWORN WRITTEN ACCOUNTING AND DECLARATION OF SCOTT LAVALLEY IN COMPLIANCE WITH COURT ORDERS ENTERED APRIL 27, 2026 ECF Nos. 36 & 37 I, Scott LaValley, declare under penalty of perjury that the following is true and correct to the best of my personal knowledge, information, and belief: I am the former Chief Executive Officer and President of Cartwheel Robotics Inc. (the “Debtor”). I submit this written accounting in response to and in compliance with the Court’s Order Granting Motion for Turnover of Bankruptcy Estate Property Pursuant to 11 U.S.C. § 542(e) (ECF No. 36) and the Order Granting Motion for Turnover of Bankruptcy Estate Property Pursuant to 11 U.S.C. § 542(a) (ECF No. 37), both entered on April 27, 2026. I do not currently have possession, custody, or control of any of the Debtor’s property, books, records, files, systems, source code, repositories, hardware, robotics systems, prototypes, software, cloud accounts, financial records, or other recorded information responsive to the Court’s orders. Prior to the commencement of this bankruptcy case, in or around December 2025, the Debtor had ceased operations, the premises had been surrendered or lost, and the Debtor’s assets were assigned to 6127 Reno Hwy, LLC or Autonomous Ops. For purposes of this declaration, I refer to the relevant transferee, secured creditor, landlord, or possessor of the premises and assets as the “Landlord.” Following that assignment and loss of the premises, I no longer had possession, custody, legal authority, or practical control over the Debtor’s assets, systems, records, or equipment. The Debtor’s technical infrastructure was not centralized with me alone. Access to source code, cloud systems, repositories, engineering files, computers, and development infrastructure was distributed among multiple former employees and technical personnel during the Debtor’s operations. As a result, any suggestion that I alone possessed, controlled, or had the exclusive ability to retrieve the Debtor’s technical assets or recorded information would be inaccurate. I have not used, transferred, exploited, commercialized, or provided Cartwheel Robotics intellectual property to Google, Google DeepMind, or any other current employer. To the extent any party has suggested that I am using Cartwheel Robotics intellectual property elsewhere, that suggestion is false. Pursuant to the specific requirements outlined in paragraph 3 of ECF No. 36 and paragraph 4 of ECF No. 37, I provide the following accounting. (a) Identification of Items Not in My Possession, Custody, or Control The items no longer in my possession, custody, or control include, without limitation:a. all tangible assets, hardware, robotics systems, prototypes, and component parts, including systems known as “YOGI” and “Speedy”;b. all computers, workstations, development hardware, lab equipment, tools, test fixtures, and related physical property;c. all intellectual property, software, source code, repositories, models, simulation files, controls code, AI/ML development materials, mechanical design files, electrical design files, CAD files, drawings, schematics, and related engineering materials;d. all books and records, including financial books, ledgers, bank records, vendor records, customer records, investor records, payroll records, cloud-based records, contracts, corporate records, and accounting information;e. all digital access credentials, administrative rights, cloud accounts, repository credentials, third-party platform access, and other digital access points previously used by the Debtor; andf. all other recorded information relating to the Debtor’s business, assets, liabilities, operations, technical development, or intellectual property. I do not currently have the practical ability or legal authority to retrieve or turn over the above property or recorded information from premises, systems, devices, accounts, repositories, or cloud services no longer under my control. (b) Current Location of Such Property and Recorded Information At the time of the assignment and loss of the premises, the bulk of the Debtor’s physical property, hardware, robotics systems, prototypes, tools, lab equipment, and any physical records left onsite were located at the commercial premises commonly known as 6127 Reno Hwy, Fallon, Nevada 89406. After the assignment and loss of access to the premises, which occurred months before the Court’s April 27, 2026 orders, I no longer had control over those physical items. I do not know whether all such items remain at that location, have been moved, have been sold, have been discarded, have been damaged, or have otherwise changed location. The Debtor’s digital property and recorded information were maintained across distributed systems, including cloud platforms, software repositories, company computers, employee-assigned devices, and other third-party services. Because I no longer have legal authority, administrative access, or practical control over those systems, I do not know the exact current location or status of all such digital property or recorded information. To the best of my knowledge, one company computer assigned to former employee Esteve Valls Mascaro was not returned after the Debtor ceased operations and is currently believed to be in Spain. I know that the computer in Mr. Mascaro’s possession contains the Debtor’s source code. I know that certain mechanical design files relating to the “YOGI” robotics system are stored in former employee Brian Roe’s personal cloud account or personal cloud storage environment. To my knowledge, Mr. Roe’s personal cloud storage contains the only existing copy of those specific files. I do not have access to or control over Mr. Roe’s personal cloud account, personal cloud storage environment, or those files. Former software engineers who worked directly on the Debtor’s codebase, controls software, AI/ML systems, repositories, and cloud infrastructure are likely to have more specific knowledge than I do regarding the location, structure, and prior access points for certain source code, software repositories, cloud systems, and engineering files. (c) Persons or Entities Having Possession, Custody, Control, or Knowledge The entity that took possession, custody, or control over the physical premises, physical assets, and digital access left at the premises was the Landlord. Following the assignment of assets and loss of the premises, the Debtor’s former employees may not have live access to company systems, and I do not know the present status of any such access. However, based on their roles, responsibilities, assigned equipment, and possession of certain materials during and after the Debtor’s operations, several former employees have relevant knowledge or possession regarding the Debtor’s systems, repositories, hardware, and engineering files. Specifically: a. Esteve Valls Mascaro, former AI software engineer, was assigned a company computer and worked on the Debtor’s AI/ML software systems. To my knowledge, Mr. Mascaro did not return that company computer after the Debtor ceased operations and remains in possession of it in Spain. I know that the computer in Mr. Mascaro’s possession contains the Debtor’s source code. Based on his role, Mr. Mascaro likely has specific knowledge regarding the Debtor’s source code repositories, AI/ML development materials, cloud-based engineering infrastructure, and related access points. I understand that Mr. Mascaro is now employed by Engineered Arts Ltd. and/or an affiliated entity (“EA”), which is a creditor in this bankruptcy case and, to the best of my knowledge, is developing similar humanoid robotics technology. b. Vinay Kamidi, former software/controls engineer, worked on the Debtor’s software and controls systems. Based on his role, Mr. Kamidi likely has knowledge of source code repositories, software architecture, controls code, cloud systems, development infrastructure, and related access points used by the Debtor during operations. I understand that Mr. Kamidi is now employed by Boston Dynamics, a company operating in the humanoid robotics field. c. Brian Roe, former mechanical engineer, worked on the Debtor’s mechanical design files and robotics hardware. As stated above, I know that Mr. Roe has certain Debtor mechanical design files relating to the “YOGI” robotics system stored in his personal cloud storage, which to my knowledge contains the only existing copy of those specific files. Based on his role, Mr. Roe likely has specific knowledge regarding the Debtor’s mechanical design files, CAD files, robotics hardware, and related engineering materials. I understand that Mr. Roe is now employed by Engineered Arts Ltd. and/or an affiliated entity (“EA”), which is a creditor in this bankruptcy case and, to the best of my knowledge, is developing similar humanoid robotics technology. I do not control EA, Boston Dynamics, Mr. Mascaro, Mr. Roe, Mr. Kamidi, their devices, accounts, private cloud storage, or any materials they possess. (d) Additional Context Regarding Interested Creditors, Potential Acquirers, Funding, Appraisal, and Asset-Control Discussions Prior to the bankruptcy filing, Engineered Arts Ltd. and related persons were not passive or unrelated parties with respect to Cartwheel’s assets. Engineered Arts had proposed or discussed an acquisition transaction or letter of intent involving Cartwheel Robotics. Nicolas Desmarais was, to my knowledge, the CEO of Engineered Arts and the CEO of AppDirect. Mr. Desmarais is also personally a creditor in this bankruptcy case, and Engineered Arts is a creditor in this bankruptcy case. After the Landlord had taken control of the Debtor’s assets and before the bankruptcy filing, Mr. Desmarais communicated with me regarding Engineered Arts’ proposed acquisition of Cartwheel, the likelihood of a bankruptcy proceeding, Gene/Nevada’s asserted position regarding the assets, and a proposed release/holdco structure. These communications occurred after I no longer had possession or control of the assets assigned to the Landlord. After the Landlord had taken control of the Debtor’s assets and before the bankruptcy filing, the Landlord had discussions with Engineered Arts and/or related creditor representatives regarding a potential assignment or release of the Debtor’s assets back into a transaction structure at or around the value of the Landlord’s secured debt. I understood that these discussions involved Gene Wong, Battle Born and/or other creditor representatives. My understanding was that the Landlord’s position was limited to satisfaction of its secured debt, and that the Landlord was willing to release or assign the assets if that secured debt was paid. That funded resolution did not occur. Before the Debtor reached insolvency, Cartwheel was actively attempting to raise a financing round to preserve the company, retain the team, continue development, and avoid a distressed outcome. The Debtor had obtained a term sheet for financing, but the round did not close. During that same period, Gene Wong/Reno Seed Fund-related interests communicated demands regarding governance, control, releases, or creditor treatment. Mr. Wong also stated in writing that he would “tank” or otherwise interfere with financing if his demands were not satisfied. This is relevant because Cartwheel had obtained a financing term sheet and was attempting to preserve the company, but the financing did not close, and the company then lost its team, development momentum, and going-concern value. To my knowledge, creditor and interested-party groups, including Gene Wong/Reno Seed Fund-related interests, Engineered Arts-related interests, and Battle Born-related interests, had the opportunity to participate in or support a funded path that would have preserved the Debtor’s team, development momentum, and going-concern value. That funding did not occur. Cartwheel initiated the independent appraisal before the bankruptcy filing. The appraisal was obtained on the advice of bankruptcy counsel as part of evaluating available options if funding fell through and a bankruptcy or other insolvency process became necessary. At that time, bankruptcy did not appear to be a viable company-preservation path because the Debtor had limited remaining cash, was insolvent, and the appraised value of the assets was substantially below the amount owed to secured creditors. The independent appraiser retained by Cartwheel emphasized that the Debtor’s intellectual property, standing alone and without the team, documentation, funding, and development momentum necessary to continue development, had limited standalone value. This was consistent with statements made by Engineered Arts during acquisition discussions, in which Engineered Arts repeatedly stated that Cartwheel had little or no value without the team. After the financing did not occur, the Debtor’s employees were already seeking other employment due to lack of funding, and I ultimately had to lay off the team before the employees departed on their own. Once the team was lost, the practical value of the Debtor’s early-stage technical assets was substantially impaired. I also believe it is important to distinguish the interests of Engineered Arts-related parties from the interests of Gene Wong/Reno Seed Fund-related parties. To my knowledge, those were separate interested parties with separate economic and strategic interests in Cartwheel, its assets, or control of the company. Engineered Arts had acquisition-related interest in Cartwheel’s assets and technology, while Gene Wong/Reno Seed Fund-related interests had investor, creditor, governance, and control-related interests. I understood the prepetition communications and conduct described above as reflecting separate but overlapping efforts by interested creditors, investors, and acquisition parties to obtain control over Cartwheel, its assets, or the disposition of its assets through releases, holdco structures, asset-control arrangements, distressed transactions, or bankruptcy-related processes, rather than supporting a funded solvent restart on terms I believed were consistent with my fiduciary duties. I did not agree to assign my equity, transfer corporate control, or make ownership decisions under threat of litigation or pressure. I believed that doing so would have been inconsistent with my fiduciary duties absent a fully funded, executable path that restored Cartwheel to solvency. (e) Description of Transfer, Including Date, Manner, Consideration, and Transferee The transfer or assignment of assets left at the premises occurred in or around December 2025, before the January 2026 communications described above, and before the March 19, 2026 filing of the involuntary bankruptcy petition. To the best of my knowledge, the transfer was made through a legal assignment of the Debtor’s assets to the Landlord, in connection with unpaid rent, secured obligations, enforcement of secured creditor rights, the loss of the commercial premises, or a combination of those circumstances. The consideration for the assignment was the satisfaction or partial satisfaction of secured debt owed by the Debtor, and was consistent with the appraised value. After the assignment and loss of the premises, I did not retain possession, custody, or control over the Debtor’s physical assets, digital systems, cloud accounts, repositories, records, or other property. With respect to former employees who retained company-assigned devices, software, source code, engineering files, design files, or other digital materials, I am not aware of any formal transfer authorizing those individuals to own or control such property. Rather, based on my present understanding, any such possession resulted from devices, files, copies, or cloud-based materials remaining with those individuals after the Debtor ceased operations. (f) Documents Supporting the Foregoing Because I no longer have access to the premises, cloud systems, company records, company computers, or the Debtor’s physical files, I do not currently possess the supporting documents and cannot identify all such documents with complete certainty. Documents supporting the assignment, secured creditor enforcement, transfer of assets, prepetition acquisition discussions, creditor communications, release proposals, holdco structures, asset-control discussions, potential bankruptcy strategy, funding efforts, appraiser comments, statements by Engineered Arts regarding the company’s value without the team, and the failure of a funded resolution may include assignment agreements, commercial lease agreements, eviction notices or related landlord enforcement documents, secured promissory notes, security agreements, publicly recorded Delaware Uniform Commercial Code financing statements, the independent appraisal retained by Cartwheel, financing correspondence, term sheets, investor communications, board communications, creditor communications, appraiser communications, valuation materials, and correspondence among me, Mr. Desmarais, Engineered Arts representatives, AppDirect representatives, the Landlord, Gene Wong, Reno Seed Fund-related parties, Battle Born-related parties, and/or other interested parties. Communications between Mr. Desmarais, Gene Wong, Reno Seed Fund-related parties, Engineered Arts-related parties, AppDirect-related parties, and/or other interested parties may contain relevant information regarding prepetition acquisition discussions, creditor coordination, proposed releases, holdco structures, asset-control discussions, potential bankruptcy strategy, threats to interfere with financing, and the failure of a funded resolution. I do not currently possess documentation regarding unreturned company hardware, private cloud storage, source code copies, engineering file copies, or other digital materials that remained with former employees after the Debtor ceased operations, other than my personal knowledge described above. Reservation Regarding Access and Ability to Comply I have provided this accounting based on my current personal knowledge and present ability to respond. I do not currently have possession, custody, control, legal authority, or administrative access sufficient to retrieve property or recorded information from the Landlord, the former premises, former employee devices, private cloud accounts, third-party platforms, software repositories, or any systems no longer under my control. To the extent the Chapter 7 trustee seeks additional information, property, or access, the persons and entities identified above are likely to have relevant possession, custody, control, access, knowledge, creditor interest, or strategic interest beyond what I currently possess. I remain willing to cooperate within the limits of my actual possession, custody, control, legal authority, and personal knowledge. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed on May 9, 2026. /s/ Scott LaValley

UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re:CARTWHEEL ROBOTICS, INC.,Debtor. Case No. 26-50278-HLBChapter 7 MOTION OF SECURED CREDITOR SCOTT LAVALLEY FOR PRODUCTION OF DOCUMENTS PURSUANT TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2004 Scott LaValley, representing himself pro se in his capacity as a secured creditor and party in interest in this Chapter 7 case, respectfully moves for entry of an order authorizing targeted production of documents pursuant to Federal Rule of Bankruptcy Procedure 2004. Movant seeks limited document discovery concerning communications among three groups: (1) Nevada Battle Born Growth Escalator, Inc. and its representatives, including Christine Guerci, Karsten Heise, and Kyle Ferguson; (2) Gene Wong, Reno Seed Fund / RSF Robotics I, the Wong Family Revocable Trust, and related investors; and (3) Engineered Arts, Nicolas Desmarais, and related representatives. The requested discovery concerns Cartwheel Robotics, Inc., Engineered Arts’ potential acquisition, investment, financing, or asset-purchase interest, Gene Wong’s anticipated involvement or alignment, any proposed investor roll-forward or participation in an Engineered Arts-related transaction, any actual or prospective buyer, bidder, acquirer, assignee, designee, or purchaser of Cartwheel assets, any proposed auction or “hold co” structure, creditor strategy, the timing of the involuntary bankruptcy petition, and matters that may have affected the value, disposition, or administration of the Debtor’s estate. Movant also seeks limited document discovery from ClickBio and Jessica Gagliano only to the extent ClickBio personnel, systems, records, email accounts, calendars, devices, or administrative support were used in connection with Gene Wong’s or RSF-related communications concerning Cartwheel. In support of this Motion, Movant states as follows: I. Relief Requested Movant seeks an order authorizing targeted production of documents pursuant to Federal Rule of Bankruptcy Procedure 2004 from Gene Wong, Reno Seed Fund / RSF Robotics I, the Wong Family Revocable Trust, Nevada Battle Born Growth Escalator, Inc., Engineered Arts, and related document custodians. Movant is not seeking oral examinations at this time. Movant reserves the right to request oral examinations later if document production shows that further examination is necessary. The requested document production is directed to communications and records concerning Cartwheel Robotics, Inc., Engineered Arts’ potential acquisition, investment, financing, or asset-purchase interest, Gene Wong’s anticipated involvement or alignment, any proposed investor roll-forward or participation in an Engineered Arts-related transaction, any actual or prospective buyer, bidder, acquirer, assignee, designee, or purchaser of Cartwheel assets, any proposed auction or “hold co” structure, creditor strategy, the timing of the involuntary bankruptcy petition, and matters that may have affected the value, disposition, or administration of the Debtor’s estate. The requested custodians include Gene Wong, Reno Seed Fund / RSF Robotics I, the Wong Family Revocable Trust, Nevada Battle Born Growth Escalator, Inc., Christine Guerci, Karsten Heise, Kyle Ferguson, Engineered Arts, Nicolas Desmarais, and, to the extent relevant, AppDirect, ClickBio, Jessica Gagliano, and/or their representatives. AppDirect is included only to the extent AppDirect personnel, systems, records, email accounts, or representatives were used in connection with communications concerning Cartwheel, Engineered Arts, Gene Wong, Nevada Battle Born Growth Escalator, Inc., or the matters described herein. ClickBio and Jessica Gagliano are included only to the extent they possess, control, or have knowledge of communications or records concerning Cartwheel, Engineered Arts, Nevada Battle Born Growth Escalator, Inc., Gene Wong, Reno Seed Fund, RSF Robotics I, the Wong Family Revocable Trust, or the involuntary petition. II. Background and Basis for Document Production On March 19, 2026, an involuntary Chapter 7 bankruptcy petition was filed against Cartwheel Robotics, Inc. by RSF Robotics I, the Wong Family Revocable Trust, and Nevada Battle Born Growth Escalator, Inc. Gene Wong is associated with RSF Robotics I and the Wong Family Revocable Trust. Nevada Battle Born Growth Escalator, Inc. is also a petitioning creditor, and Christine Guerci, Karsten Heise, and Kyle Ferguson appear to have acted as representatives of Nevada Battle Born Growth Escalator, Inc. in matters relevant to Cartwheel. Nicolas Desmarais is associated with Engineered Arts. Engineered Arts had previously expressed interest in a potential acquisition, investment, financing, asset purchase, employment-related transaction, or other strategic transaction involving Cartwheel, its technology, and/or its assets. Movant understands that Gene Wong may have used ClickBio personnel, systems, records, email accounts, calendars, devices, or administrative support in connection with Reno Seed Fund / RSF-related business. Movant further understands that Jessica Gagliano may have provided administrative or operational support to Mr. Wong in connection with such matters. Movant does not assert that ClickBio or Jessica Gagliano were parties to any transaction involving Cartwheel. Rather, Movant seeks document production from them only to the extent they possess or control records reflecting Gene Wong’s or RSF-related communications concerning Cartwheel. Movant is a secured creditor of the Debtor and has filed a proof of claim asserting a perfected secured claim against the Debtor’s estate. Federal Rule of Bankruptcy Procedure 2004 permits the Court, on motion of a party in interest, to order examination of any entity concerning the acts, conduct, property, liabilities, and financial condition of the debtor, and any matter that may affect administration of the estate. The requested document production concerns matters that may affect administration of the estate, including estate value, the disposition of Cartwheel’s assets, potential estate claims, creditor conduct, potential acquirer conduct, the circumstances leading to the involuntary bankruptcy filing, potential buyers or bidders, the timing of the petition, and communications with any potential acquirer or strategic counterparty. Movant does not seek this discovery for harassment, delay, or to conduct discovery in any pending adversary proceeding. Movant does not seek to usurp the Chapter 7 Trustee’s authority over estate claims or estate administration, but seeks limited document production from non-Debtor parties who appear to possess material information concerning estate value, potential transactions, creditor communications, and events leading to the involuntary petition. III. Factual Basis for Requested Document Production In December 2025, Engineered Arts and/or its representatives engaged in communications with Movant concerning both potential employment and a potential transaction involving Cartwheel’s assets. On or about December 22, 2025, Nicolas Desmarais stated in an email that the parties would “try and tie” Movant’s proposed sign-on bonus “to the acquisition of the assets.” In the same communication, Mr. Desmarais stated in substance that, if Engineered Arts acquired the assets, the upfront cash investment would cover outstanding debts and “serve the same purpose as bonus.” On or about December 23, 2025, Movant responded that acquisition was the preferred path, but clarified that the sign-on bonus would serve only as a personal fallback and was not indicative of the potential price to purchase Cartwheel’s assets. Movant further stated that any purchase of the assets would need to be negotiated between Engineered Arts and the secured creditor then exercising control over the assets. A true and correct copy of the relevant December 2025 email thread is attached hereto as Exhibit A. In mid-January 2026, Movant was attempting to negotiate a comprehensive global resolution that would resolve secured obligations, address the landlord position, avoid partial or sequential execution risk, and potentially allow Cartwheel’s assets to be returned to the company through a single coordinated closing. On or about January 14, 2026, Movant emailed Mr. Desmarais regarding a possible global resolution structure. The framework contemplated, among other things, Engineered Arts setting a call with Gene Wong, alignment in principle on a global resolution, escrow funding, release documentation, assignment of assets back to Cartwheel, and governance and equity changes becoming effective at a single closing moment. Movant also stated that any employment arrangement would remain arm’s-length and independent from the settlement economics, and that simultaneous effectiveness was intended to avoid interim risk and ambiguity, not because employment was consideration for the settlement. On or about January 15, 2026, Mr. Desmarais responded: “Let’s chat tomorrow to align on these mechanics. I think Gene will be aligned. He wants a call asap as well.” A true and correct copy of the relevant January 14–15, 2026 email thread is attached hereto as Exhibit B. On or about January 20, 2026, Mr. Desmarais sent Movant a communication concerning Cartwheel’s situation, a potential bankruptcy process, an “auction of all assets,” counsel’s view concerning “Gene and Nevada,” a possible holding-company or “hold co” structure, and Gene Wong’s desire to speak. A true and correct copy of the relevant January 18–20, 2026 email thread is attached hereto as Exhibit C. The emails attached as Exhibits A, B, and C are limited communications from Movant’s personal Gmail account. Movant does not attach these emails to suggest that he has access to Cartwheel’s corporate email accounts, records, systems, files, financial records, or other company-controlled information. Movant does not presently have possession, custody, or control of Cartwheel’s corporate records or systems. These communications raise questions regarding the nature and extent of communications among Mr. Desmarais, Engineered Arts, Gene Wong, Reno Seed Fund, Nevada Battle Born Growth Escalator, Inc., Christine Guerci, Karsten Heise, Kyle Ferguson, and/or other creditor representatives concerning Cartwheel’s assets, a possible global resolution, acquisition strategy, governance changes, creditor alignment, potential bankruptcy process, auction process, “hold co” structure, and potential estate value. Movant further understands that discussions occurred concerning whether Gene Wong and/or investors associated with him might roll forward, convert, exchange, contribute, assign, or otherwise transfer Cartwheel-related investment interests, claims, or other economic interests into Engineered Arts or an Engineered Arts-related transaction, capitalization, acquisition, or financing structure. Movant does not presently know the full extent of those discussions, whether any such roll-forward or investor-participation structure was proposed or agreed, why it did or did not proceed, or whether any dispute, loss of trust, or breakdown in discussions between Mr. Desmarais and Mr. Wong affected Engineered Arts’ position regarding Cartwheel. Movant is also aware of late-January 2026 communications involving creditor representatives, including representatives of Nevada Battle Born Growth Escalator, Inc., Gene Wong / Reno Seed Fund-related interests, and Engineered Arts, that raised questions regarding creditor goals, Engineered Arts’ potential role, possible acquisition-related interests, and communications between Engineered Arts and Gene Wong. Movant further seeks production sufficient to determine whether any creditor, investor, potential acquirer, or representative had identified, contacted, lined up, coordinated with, or otherwise discussed any actual or prospective buyer, bidder, acquirer, investor, assignee, designee, purchaser, or recipient of Cartwheel’s assets, technology, intellectual property, equipment, source code, data, customer opportunities, or business prospects before or after the involuntary petition. Movant also seeks discovery concerning the timing of the involuntary petition. If the Debtor’s assets had substantial value, and if the petitioning creditors believed bankruptcy was necessary to preserve or realize that value, the delay between the January 2026 creditor communications and the March 19, 2026 involuntary petition raises estate-relevant questions. Discovery is necessary to determine why the petition was filed when it was, what alternatives were considered during the intervening period, whether any buyer, bidder, auction, hold-co, roll-forward, asset-disposition, litigation, or discovery strategy was being evaluated, and whether the delay affected estate value. Movant publicly announced his employment with Google on or about March 9, 2026. Three days later, on March 19, 2026, RSF Robotics I, the Wong Family Revocable Trust, and Nevada Battle Born Growth Escalator, Inc. filed the involuntary Chapter 7 petition against Cartwheel. Movant does not assert by this Motion that the timing was improper, but the close timing raises estate-relevant questions regarding what communications occurred before filing, why the petition was filed when it was, whether alternatives were considered, whether the timing was influenced by litigation strategy, discovery strategy, buyer or bidder strategy, asset-disposition strategy, funding alternatives, or Movant’s employment transition, and whether any delay affected estate value. Because certain communications involving Debtor’s counsel may implicate Cartwheel’s attorney-client privilege, Movant does not rely on privileged communications for the relief requested in this Motion. Instead, Movant seeks Rule 2004 document production from the relevant non-Debtor parties to determine the underlying facts directly from the parties who possess them. Movant understands that Kyle Ferguson may possess material information concerning Cartwheel’s funding efforts, including communications regarding whether Nevada Battle Born Growth Escalator, Inc. would participate in additional funding or a final financing/resolution effort before the involuntary petition. Because the relevant communications may have occurred outside the limited email threads currently available to Movant through his personal Gmail account, and because Movant does not presently have possession, custody, or control of Cartwheel’s corporate records, email accounts, systems, files, financial records, or other company-controlled information, Rule 2004 document production from non-Debtor parties is necessary to determine the full scope of communications among the relevant parties. The requested document production is necessary to determine what communications occurred, what Gene Wong was told, what Mr. Wong communicated to Engineered Arts, whether any petitioning creditor supported, opposed, conditioned, or redirected a possible transaction, whether Nevada Battle Born Growth Escalator, Inc. or its representatives participated in or were aware of such communications, whether any investor roll-forward or Engineered Arts-related capitalization structure was discussed, whether any buyer, bidder, acquirer, investor, assignee, designee, purchaser, or recipient had been identified or coordinated with, why the involuntary petition was filed when it was, and whether any such communications or timing decisions affected estate value, creditor recoveries, or potential estate claims. IV. Need for Prompt Document Production Movant files this Motion at this time because the requested discovery concerns issues likely to affect administration of the estate at the outset of this Chapter 7 case, including estate value, potential claims, creditor conduct, the circumstances surrounding the involuntary petition, and prepetition communications with a potential acquirer, bidder, or strategic counterparty. The current case posture appears focused on identifying assets, records, schedules, and persons with knowledge of the Debtor’s affairs. The communications described above suggest that additional parties may possess material information concerning the Debtor’s assets, potential transactions, asset valuation, creditor strategy, acquisition-related communications, investor roll-forward discussions, funding/resolution efforts, possible buyers or bidders, timing of the petition, and events leading to the involuntary petition. Prompt document production is appropriate so that the Chapter 7 Trustee and parties in interest may evaluate the estate with a more complete record and determine whether potential estate claims, recoveries, objections, or further investigation may be warranted. Movant does not ask the Court to determine the merits of any potential claim through this Motion. Movant seeks only to obtain documents sufficient to determine what occurred and whether further action by the Trustee or parties in interest may be warranted. V. Requested Document Production Movant requests production of the following documents and communications from Gene Wong, Reno Seed Fund / RSF Robotics I, the Wong Family Revocable Trust, Nevada Battle Born Growth Escalator, Inc., Christine Guerci, Karsten Heise, Kyle Ferguson, Nicolas Desmarais, Engineered Arts, ClickBio to the extent relevant, Jessica Gagliano to the extent relevant, AppDirect to the extent relevant, and/or their representatives: a. All communications concerning Cartwheel Robotics, Inc. between or among Gene Wong, Reno Seed Fund, RSF Robotics I, the Wong Family Revocable Trust, Nevada Battle Born Growth Escalator, Inc., Christine Guerci, Karsten Heise, Kyle Ferguson, Engineered Arts, Nicolas Desmarais, John Pharr, Susan Court, Brendan Burke, Empower Industries, Joe Mardini, ClickBio to the extent relevant, Jessica Gagliano to the extent relevant, AppDirect to the extent relevant, or their representatives. b. All communications between or among any representatives of Nevada Battle Born Growth Escalator, Inc., including Christine Guerci, Karsten Heise, and Kyle Ferguson; Gene Wong, Reno Seed Fund, RSF Robotics I, the Wong Family Revocable Trust, or any related investors; and Engineered Arts, Nicolas Desmarais, Brendan Burke, or their representatives concerning Cartwheel’s assets, potential acquisition or investment activity, creditor strategy, any auction, any “hold co,” any investor roll-forward, any asset disposition, or the involuntary bankruptcy petition. c. All communications concerning any proposed acquisition, investment, financing, asset purchase, licensing transaction, strategic transaction, auction, “hold co” structure, employment-related transaction, investor roll-forward, claim conversion, equity exchange, capitalization structure, or other transaction involving Cartwheel and Engineered Arts. d. All communications concerning any relationship between Scott LaValley’s proposed employment, compensation, sign-on bonus, employment start date, consulting arrangement, or other personal consideration and any acquisition, transfer, purchase, auction, or disposition of Cartwheel Robotics’ assets. e. All communications concerning the January 14–15, 2026 proposed global resolution, including any call or proposed call between Engineered Arts and Gene Wong, and Mr. Desmarais’s statement that “Gene will be aligned” and “wants a call asap.” f. All documents and communications concerning any proposal, discussion, or understanding that Gene Wong, Reno Seed Fund, RSF Robotics I, the Wong Family Revocable Trust, or any related investors would roll forward, convert, exchange, contribute, assign, or otherwise transfer any Cartwheel-related investment, claim, or interest into Engineered Arts or any Engineered Arts-related transaction, capitalization, acquisition, or financing structure. g. All documents and communications concerning any dispute, loss of trust, recording of communications, consent to recording, alleged misrepresentation, or other breakdown in discussions between Gene Wong and Nicolas Desmarais relating to Cartwheel, Engineered Arts, Cartwheel investors, or any proposed transaction. h. All communications concerning any proposed bankruptcy process, involuntary bankruptcy petition, auction process, asset disposition, “hold co,” asset transfer, foreclosure, secured creditor process, or liquidation involving Cartwheel. i. All communications concerning Cartwheel’s governance, board composition, investor rights, veto rights, corporate authority, financing approvals, creditor claims, secured claims, liens, foreclosure, insolvency, or bankruptcy risk. j. All communications concerning Cartwheel’s valuation, assets, intellectual property, technology, employees, contracts, customer opportunities, business prospects, or potential transaction value. k. All communications concerning Nevada Battle Born Growth Escalator, Inc.’s position, including communications involving Christine Guerci, Karsten Heise, Kyle Ferguson, or other Battle Born representatives, regarding Cartwheel assets, creditor strategy, liquidation, auction, recovery, acquisition, asset preservation, asset valuation, additional funding, bridge financing, global resolution, or the involuntary bankruptcy petition. l. All documents concerning the January 18–20, 2026 email thread attached as Exhibit C, including drafts, replies, forwarded messages, internal discussions, related text messages, attachments, and communications concerning any statements that bankruptcy would likely result in an “auction of all assets,” that assets could be placed into a “hold co,” that “Gene and Nevada” had a position concerning the assets, or that Gene Wong wanted to speak. m. All documents concerning any evaluation by Engineered Arts of Cartwheel’s assets, intellectual property, technology, employees, business prospects, or acquisition value. n. All documents and communications concerning any request, proposal, or discussion that Nevada Battle Born Growth Escalator, Inc. participate in Cartwheel’s final funding round, bridge financing, global resolution, rescue financing, or other funding/resolution effort before the involuntary petition. o. All documents and communications in the possession, custody, or control of ClickBio, Jessica Gagliano, or any person providing administrative or operational support to Gene Wong concerning Cartwheel, Engineered Arts, Nevada Battle Born Growth Escalator, Inc., Reno Seed Fund, RSF Robotics I, the Wong Family Revocable Trust, any proposed transaction, any creditor strategy, or the involuntary bankruptcy petition. p. All calendar entries, meeting invitations, call notes, call logs, text messages, messaging-app communications, notes, task lists, document-sharing records, or scheduling communications maintained by ClickBio, Jessica Gagliano, or any person providing support to Gene Wong concerning Cartwheel, Engineered Arts, Nevada Battle Born Growth Escalator, Inc., Reno Seed Fund, RSF Robotics I, the Wong Family Revocable Trust, or the involuntary bankruptcy petition. q. All documents and communications concerning any actual or prospective buyer, bidder, acquirer, investor, assignee, designee, stalking-horse bidder, purchaser, or other recipient of Cartwheel’s assets, technology, intellectual property, equipment, source code, data, customer opportunities, or business prospects. r. All documents and communications concerning any plan, proposal, strategy, or discussion to acquire, transfer, assign, auction, purchase, credit bid, foreclose upon, control, preserve, market, package, or dispose of Cartwheel’s assets through bankruptcy, foreclosure, Article 9 process, auction, hold-co structure, creditor process, or other transaction structure. s. All documents and communications concerning any buyer, bidder, acquirer, investor, or strategic counterparty identified, contacted, introduced, solicited, evaluated, or discussed by Gene Wong, Reno Seed Fund, RSF Robotics I, the Wong Family Revocable Trust, Nevada Battle Born Growth Escalator, Inc., Christine Guerci, Karsten Heise, Kyle Ferguson, Engineered Arts, Nicolas Desmarais, ClickBio, Jessica Gagliano, or any of their representatives. t. All documents and communications concerning any agreement, understanding, side agreement, economic participation, referral, finder arrangement, success fee, equity participation, debt roll-forward, claim conversion, credit bid, assignment, release, indemnity, or other consideration connected to any sale, auction, transfer, acquisition, or disposition of Cartwheel assets. u. All documents and communications concerning the timing of the involuntary Chapter 7 petition, including any decision to delay, defer, accelerate, prepare, fund, support, or file the petition. v. All documents and communications concerning any reason for filing the involuntary Chapter 7 petition on or about March 19, 2026 rather than earlier, including communications concerning asset value, asset preservation, asset disposition, creditor strategy, litigation strategy, discovery strategy, buyer or bidder strategy, auction planning, hold-co structure, settlement discussions, funding alternatives, or potential estate recoveries. w. All documents and communications concerning whether delay in filing the involuntary petition affected the value, preservation, location, accessibility, recoverability, marketability, or disposition of Cartwheel’s assets, records, intellectual property, technology, equipment, accounts, credentials, or business opportunities. x. All documents and communications concerning Movant’s public employment announcement, employment transition, availability, or perceived ability to access, produce, preserve, or control Cartwheel records or assets, to the extent such matters related to the timing, preparation, filing, or strategy of the involuntary petition. y. All documents and communications concerning the decision to file, support, fund, coordinate, or participate in the involuntary Chapter 7 petition filed against Cartwheel. z. All documents and communications concerning Cartwheel records, documents, accounts, credentials, assets, asset locations, asset control, asset preservation, asset valuation, or asset disposition. The requested production should cover the period from December 1, 2025 through the present. VI. Relevance to the Estate The requested document production is directly relevant to estate administration because it may reveal whether: a. Cartwheel lost a potential acquisition, investment, financing, or other transaction; b. communications by creditors, investors, potential acquirers, or their representatives impaired estate value; c. estate assets were targeted, devalued, or positioned for acquisition through a creditor, bankruptcy, auction, “hold co,” investor roll-forward, credit bid, buyer designation, or other transaction structure; d. the timing of the involuntary petition affected estate value, preservation, accessibility, marketability, or recoverability of assets or records; e. any creditor, potential acquirer, or third party acted in a manner that gave rise to claims belonging to the estate; f. the Chapter 7 Trustee should investigate or pursue potential claims; g. the value of Cartwheel’s intellectual property, technology, assets, and business prospects was affected by prepetition conduct; h. the involuntary bankruptcy process was used, coordinated, or influenced in a manner relevant to administration of the estate; and i. parties other than Movant possess material information concerning assets, records, transactions, valuation, creditor strategy, timing, and estate administration. Movant does not ask the Court to decide these issues in this Motion. Movant seeks only the ability to obtain documents sufficient to determine what occurred and whether further action by the Trustee or parties in interest may be warranted. VII. Reservation of Rights Movant does not assert by this Motion that Gene Wong, Reno Seed Fund, Nevada Battle Born Growth Escalator, Inc., Christine Guerci, Karsten Heise, Kyle Ferguson, ClickBio, Jessica Gagliano, Engineered Arts, Nicolas Desmarais, or any other party definitively caused Engineered Arts not to proceed with a transaction or had any pre-arranged buyer or asset-disposition strategy. Rather, Movant seeks limited document production to determine what communications occurred, whether those communications affected Engineered Arts’ position or any potential transaction, whether estate value was impaired, whether any prospective buyer or asset-disposition structure existed, why the involuntary petition was filed when it was, whether timing affected estate value, and whether the estate may have claims or rights that should be investigated by the Chapter 7 Trustee. Nothing in this Motion or the attached exhibits should be construed as a representation that Movant has possession, custody, or control of Cartwheel’s corporate email accounts, records, systems, files, financial records, assets, or other company-controlled information. The attached exhibits consist only of limited communications available to Movant through his personal Gmail account. Nothing in this Motion should be construed as waiving any rights, claims, defenses, privileges, objections, or arguments of Movant, the Debtor, the estate, the Chapter 7 Trustee, or any other party in interest. VIII. Conclusion WHEREFORE, Movant respectfully requests that the Court enter an order: Authorizing document production pursuant to Federal Rule of Bankruptcy Procedure 2004 from Gene Wong, Reno Seed Fund / RSF Robotics I, the Wong Family Revocable Trust, Nevada Battle Born Growth Escalator, Inc., Christine Guerci, Karsten Heise, Kyle Ferguson, Nicolas Desmarais, Engineered Arts, ClickBio to the extent relevant, Jessica Gagliano to the extent relevant, AppDirect to the extent relevant, and/or their representatives; Permitting subpoenas as necessary under Federal Rule of Bankruptcy Procedure 9016 and Federal Rule of Civil Procedure 45; Directing that responsive documents be produced by a reasonable date set by subpoena, agreement of the parties, or further order of the Court; Providing that no oral examinations are authorized by this Motion at this time, without prejudice to Movant seeking further relief by separate motion if oral examinations later become necessary; and Granting such other and further relief as the Court deems just and proper. Dated: May 11, 2026 Scott LaValley, Pro SeSecured Creditor and Party in Interest5586 Rivers Edge DriveFallon, NV 89406lavalley.scott@gmail.com EXHIBIT A December 18, 2025–January 9, 2026 Email Thread Regarding Engineered Arts Offer Letter, Sign-On Bonus, and Potential Acquisition of Cartwheel Assets EXHIBIT B January 14–15, 2026 Email Thread Regarding Proposed Global Resolution and Gene Wong Alignment EXHIBIT C January 18–20, 2026 Email Thread Regarding Funded Resolution, Bankruptcy, Auction of Assets, “Gene and Nevada,” and Proposed Hold-Co Structure

UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: CARTWHEEL ROBOTICS INC., Debtor. Case No. 26-50278-hlb Chapter 7 LIMITED SUPPLEMENTAL RESPONSE OF SCOTT LAVALLEY, INDIVIDUALLY AND AS CREDITOR / PARTY IN INTEREST, TO PETITIONING CREDITORS’ JOINDER AND RESPONSE [ECF NO. 68] Scott LaValley, appearing pro se in his individual capacity only and as a creditor and party in interest, submits this limited supplemental response to Petitioning Creditors’ Joinder and Response [ECF No. 68]. Mr. LaValley does not submit this response on behalf of Cartwheel Robotics Inc. Mr. LaValley does not purport to represent the Debtor. This response is submitted solely because Petitioning Creditors’ Joinder makes personal allegations concerning Mr. LaValley, relies selectively on prior filings and testimony, seeks relief affecting Mr. LaValley and other non-debtor individuals, and attempts to convert a practical records-access issue into an unsupported personal credibility attack. Mr. LaValley has already filed an opposition to the Trustee’s Motion [ECF No. 65]. That opposition remains Mr. LaValley’s position. Mr. LaValley does not repeat that opposition here except as necessary to address new matters, characterizations, and insinuations raised by Petitioning Creditors’ Joinder. I. INTRODUCTION The Trustee’s underlying motion is narrow. The Trustee seeks designation of a responsible person under Federal Rule of Bankruptcy Procedure 9001(b)(5) because the Debtor is a corporation, schedules have not been filed, and the Trustee needs information to administer the estate. The Trustee’s motion asserts that Mr. LaValley was the Debtor’s president and person in control and therefore “best situated” to provide information, file schedules, and appear at the § 341 meeting. Mr. LaValley understands the Trustee’s need for information and does not oppose reasonable cooperation. Mr. LaValley appeared at the § 341 meeting, answered questions under oath from personal knowledge, identified potential sources and custodians of information, and remains willing to cooperate within the limits of his actual possession, custody, control, access, legal authority, and personal knowledge. The problem is Petitioning Creditors’ attempt to transform the Trustee’s procedural request into a personal attack. Petitioning Creditors’ Joinder does not solve the records problem. It attempts to weaponize it. The Joinder accuses Mr. LaValley of “feign[ing]” lack of knowledge, cites a public docket website as though public access to court filings proves control of corporate records, and selectively emphasizes family / landlord / UCC issues while ignoring the broader record showing distributed records, dispersed employees, cloud-based systems, assigned assets, lapsed access, former technical personnel, creditor-held information, and more than six months of elapsed time. That characterization is misleading. This is not a case where one former officer sits on complete books and records and refuses to produce them. This is a case where a robotics startup ceased operations months ago, assets were assigned, the team dispersed, digital infrastructure was distributed across cloud systems and former employees, preservation required funding, and practical technical value depended heavily on former technical personnel, documentation, cloud systems, repositories, and development context. The Court should reject Petitioning Creditors’ effort to recast Mr. LaValley’s lack of present access as bad faith. II. THE § 341 TRANSCRIPT DOES NOT SUPPORT PETITIONING CREDITORS’ “FEIGNED LACK OF KNOWLEDGE” ACCUSATION Petitioning Creditors’ accusation that Mr. LaValley “feigned” lack of knowledge is not supported by the § 341 transcript. The transcript reflects that Mr. LaValley appeared, was sworn, answered questions from personal knowledge, identified the documents he had reviewed, and explained at the outset that he did not intend to file schedules because he did not have access to records or information. The transcript does not show a refusal to cooperate. It shows a former officer answering from memory after operations had ceased, records were no longer accessible to him, and relevant information was spread among multiple people, entities, systems, professionals, cloud tools, former employees, investors, creditors, and technical custodians. Mr. LaValley did not simply deny knowledge. He identified categories of records, systems, custodians, and technical personnel likely to have relevant information. For example, Mr. LaValley testified that: Corporate, ownership, and governance records 1. Cartwheel was founded by Mr. LaValley and Samantha Conway; 2. ownership later changed as shares were issued to employees and vendors; 3. Cartwheel maintained capitalization tables or shareholder records; 4. Mr. LaValley believed Carta was used for capitalization-table or shareholder records; 5. Cartwheel had a board of directors at various times; 6. formal board meetings were held; 7. board minutes were maintained; 8. corporate counsel maintained the board minutes; 9. Cartwheel used multiple corporate counsel over time, including Craig Macy, Holland & Hart, Fenwick & West, and later Eric Sternberger’s firm; Financing and governance documents 10. the company’s financing was taken under a convertible note; 11. Craig Macy prepared the convertible note; 12. Craig Macy also represented Reno Seed Fund; 13. Mr. LaValley testified that Craig Macy represented both the investor and the company; 14. the convertible note may have included approval requirements for purchases over a threshold amount, although Mr. LaValley did not have the exact language in front of him; Accounting, payroll, tax, and banking records 15. QuickBooks was likely used for accounting, likely the online version, but Mr. LaValley personally “never touched it”; 16. Samantha Conway maintained the financial records and, to Mr. LaValley’s understanding, would have held the relevant QuickBooks credentials; 17. accountants or CPAs may have relevant tax and bookkeeping information; 18. Cartwheel filed tax returns; 19. Cartwheel filed, or likely needed to file, state tax returns in states where employees resided; 20. Gusto likely handled payroll, W-2s, and payroll-tax processes; 21. Samantha Conway processed payroll; 22. Samantha Conway likely had information concerning bank-account access, banking credentials, payroll, insurance, and other day-to-day operational records; 23. the company maintained bank accounts, likely including Bank of America accounts, and may have had multiple accounts; 24. company credit-card accounts existed; 25. Mr. LaValley personally guaranteed certain company credit obligations; Possession, premises, records, and assets 26. by December 2025, Cartwheel had ceased active operations after running out of money; 27. the wind-down was described as a “free-for-all” because there was no money and no support to keep the doors open; 28. Cartwheel no longer occupied or controlled the premises; 29. keys and access were turned over; 30. to Mr. LaValley’s understanding, the company’s assets and records were handed over or assigned to the secured creditor / landlord; 31. physical assets remaining at the premises included mechanical parts, prototype parts, scopes, power supplies, computers, machine equipment, tooling, and related equipment; 32. leased vehicles and other assets were also assigned to the secured creditor, to Mr. LaValley’s understanding; Technical systems, source code, and engineering materials 33. Cartwheel was a robotics company developing a technology stack, not a finished consumer product; 34. Cartwheel developed actuation technology and a humanoid robot prototype; 35. the robot was never completed; 36. the work remained in an R&D-stage condition; 37. various elements functioned, including an actuator, a leg, a lower body, and an upper body, but there was never a fully working humanoid robot; 38. the company lacked complete technical documentation because it was operating quickly with limited resources; 39. GitHub was used for source-code repositories; 40. Vinay administered GitHub; 41. Esteve may have been a GitHub administrator; 42. additional employees or contractors may also have had technical administrative access; 43. the company was “running super scrappy,” with records and access distributed across people, systems, and cloud-based tools; 44. invention-assignment and confidentiality agreements existed, and past attorneys or the secured creditor likely had them; Valuation and practical reconstructability 45. a third-party appraisal was conducted in December 2025 while Cartwheel was pursuing financing and other options; 46. the appraiser evaluated the company / assets on site; 47. the appraised asset value was below $100,000 and likely between $50,000 and $100,000; 48. the appraiser stated that without proper documentation and without the team to support the software, the software had no value; Funding, runway, and creditor / investor knowledge 49. Cartwheel ran out of money in December 2025 after forecasting a cash crisis earlier; 50. investors were aware of the runway problem; 51. Cartwheel provided forecasts almost weekly to Gene Wong at his request; 52. Gene Wong had notice from almost the day he invested as to when the company would run out of money; 53. Cartwheel repeatedly raised small rounds or rolling funding as it approached running out of money; 54. Cartwheel laid off the team and ended contracts as cost-cutting measures; Acquisition and third-party transaction context 55. Engineered Arts, AppDirect, and Nick Desmarais were interested in acquiring Cartwheel; 56. discussions with Nick Desmarais occurred in the context of a global wind-down or possible transaction; 57. Mr. LaValley testified that Gene Wong, Battle Born, and others were in discussions with Nick Desmarais; 58. Mr. LaValley did not know what the landlord would accept to satisfy its debt and directed Nick Desmarais and his team to speak directly with the landlord; Personal email and preservation 59. Mr. LaValley testified that he did not regularly use his personal Gmail account for Cartwheel business; 60. Mr. LaValley testified that he did not use other non-Cartwheel email accounts for Cartwheel business; 61. Mr. LaValley identified one privileged email with corporate counsel in his personal Gmail account; 62. Petitioning Creditors’ counsel then demanded that Mr. LaValley preserve his Gmail account because litigation was anticipated. Those answers are not evidence of feigned ignorance. They are evidence that Mr. LaValley answered from personal knowledge, identified the limits of his access, and identified the persons, systems, professionals, records, and technical custodians likely to have relevant information. The transcript shows that Mr. LaValley was not withholding a complete set of records. He was identifying a distributed records environment. The proper response to that situation is targeted discovery from actual custodians and participants, not an adverse inference that Mr. LaValley “feigned” lack of knowledge. That record is inconsistent with Petitioning Creditors’ narrative. Mr. LaValley did not “feign” ignorance. He identified the limits of his present access, answered from memory where he could, and identified the people, systems, counsel, creditors, investors, former employees, and technical personnel likely to have relevant records or knowledge. III. PETITIONING CREDITORS’ JOINDER CONFIRMS THIS IS NOT A ONE-PERSON RECORDS ISSUE Petitioning Creditors’ Joinder confirms the central practical point in Mr. LaValley’s opposition and sworn accounting: relevant information, records, access, and control are not alleged to reside with Mr. LaValley alone. Petitioning Creditors ask the Court to consider designating Samantha Conway and Bill LaValley, asserting that Ms. Conway held officer and operational roles and that Bill LaValley may have possession, custody, control, or knowledge concerning Debtor assets and books and records. Whether those assertions are correct, overstated, or disputed, they confirm that Petitioning Creditors themselves recognize that relevant knowledge and control may reside with persons other than Mr. LaValley. That acknowledgment matters. Petitioning Creditors cannot fairly argue both that other people may have relevant possession, control, or knowledge and that Mr. LaValley alone should bear responsibility for reconstructing the Debtor’s records. The combined record shows that the Debtor’s books, records, systems, assets, technical materials, and institutional knowledge were distributed across multiple people, entities, devices, cloud services, repositories, counsel, former employees, and third-party platforms. That record undercuts any attempt to require Mr. LaValley alone to reconstruct and certify the Debtor’s schedules and statements from memory or incomplete information. Any order should therefore be tailored to actual possession, actual custody, actual control, actual access, actual legal authority, and actual personal knowledge — not former title, speculation, or adverse inference. IV. LEGAL OWNERSHIP IS NOT THE SAME THING AS PRACTICAL TECHNICAL RECONSTRUCTABILITY Petitioning Creditors acknowledge that other people may have relevant information, but they focus on the people who support their preferred insider / family narrative. They largely ignore the people most relevant to any practical reconstruction of value associated with Cartwheel’s former technical materials and assigned intellectual-property assets. Mr. LaValley’s sworn accounting identifies former employees and technical personnel with knowledge of the Debtor’s source code, cloud systems, repositories, AI / ML materials, controls software, CAD files, mechanical design files, devices, and development infrastructure. Specifically, Mr. LaValley identified Esteve Valls Mascaro, Brian Roe, and Vinay Kamidi as former employees with likely possession, knowledge, or context relevant to the Debtor’s software, controls, AI / ML systems, source-code repositories, cloud infrastructure, YOGI mechanical design files, CAD files, and engineering materials. This distinction matters because legal title to technical assets is not the same thing as practical ability to reconstruct value. The point is not to suggest that the intellectual property was not assigned. Mr. LaValley’s position has been that the Debtor’s remaining assets were assigned to the Landlord / secured creditor in or around December 2025. The point is different: regardless of whether those assets are owned by the Landlord, claimed by the estate, treated as collateral, or evaluated for estate-value purposes, any effort to identify, understand, reconstruct, or monetize technical value would require the former engineering team, technical personnel, repositories, CAD files, source-code history, cloud systems, documentation, hardware context, and development knowledge. Mr. LaValley cannot reconstruct that technical value alone from memory. The Debtor’s technical materials were not a self-contained, turnkey asset. The issue is not merely who received legal assignment of assets. The issue is who has the knowledge, access history, copies, credentials history, repository knowledge, cloud-architecture knowledge, and technical context necessary to identify, access, extract, organize, reconstruct, evaluate, or monetize any remaining technical value. Mr. LaValley’s sworn accounting states that the independent appraiser emphasized that the Debtor’s IP had limited standalone value without the team, documentation, funding, and development momentum necessary to continue development. The sworn accounting further states that this was consistent with Engineered Arts’ repeated statements during acquisition discussions that Cartwheel had little or no value without the team. Petitioning Creditors cannot fairly acknowledge that other people may have relevant information while ignoring the people with the actual technical ability to help identify, access, understand, and reconstruct any remaining value associated with Cartwheel’s former technical materials and assigned intellectual-property assets. V. PETITIONING CREDITORS’ CLAIMED CONCERN FOR ESTATE VALUE IS UNDERMINED BY THEIR FAILURE TO ADDRESS THE TECHNICAL CUSTODIANS MOST RELEVANT TO IP RECONSTRUCTION Petitioning Creditors claim concern regarding estate value, but their Joinder focuses on Mr. LaValley, his family, and a public docket website while largely ignoring the people most directly relevant to any practical reconstruction of value associated with Cartwheel’s former technical materials and assigned assets. Mr. LaValley’s sworn accounting identifies former AI software engineer Esteve Valls Mascaro as a person who, to Mr. LaValley’s knowledge, retained a company computer in Spain containing the Debtor’s source code and is now employed by Engineered Arts Ltd. and / or an affiliated entity. The same sworn accounting identifies former mechanical engineer Brian Roe as a person who, to Mr. LaValley’s knowledge, has certain YOGI mechanical design files stored in personal cloud storage, which may contain the only existing copy of those specific files, and is now employed by Engineered Arts Ltd. and / or an affiliated entity. These facts matter because Engineered Arts is an investor and interested party that previously engaged in acquisition-related discussions involving Cartwheel and, to Mr. LaValley’s knowledge, develops similar humanoid robotics technology. Whether or not Engineered Arts is presently a formal creditor in this bankruptcy case, the connection between former Cartwheel technical personnel, retained Cartwheel technical materials, and an investor / potential acquirer operating in a related field is directly relevant to estate value, collateral value, and technical reconstruction. If Petitioning Creditors’ true focus is estate value, then the inquiry should include the former technical personnel, devices, cloud storage, repositories, source code, CAD files, engineering files, and Engineered Arts-related custodians necessary to determine what technical materials exist, what was assigned, what copies or access history may remain, and whether any practical value associated with the assigned assets can be reconstructed or evaluated. Petitioning Creditors’ Joinder does not meaningfully engage with those issues. Instead, it attempts to frame Mr. LaValley’s limited present access and public transparency as evidence of bad faith. Petitioning Creditors cannot credibly claim that estate value is their central concern while ignoring sworn disclosures that former Cartwheel technical personnel now associated with an investor, potential acquirer, and robotics company operating in a related field may possess source code, unique design files, and technical knowledge necessary to reconstruct or evaluate any remaining technical value. VI. PETITIONING CREDITORS CANNOT CLAIM CONCERN FOR ESTATE VALUE WHILE IGNORING THE TIME-SENSITIVE NATURE OF VALUE PRESERVATION Petitioning Creditors now invoke concern for estate value while ignoring the practical reality that value preservation required timely funding, team continuity, system preservation, and technical reconstruction support. Cartwheel’s value was not a static pile of assets that could sit untouched for months and remain equally recoverable. It was an early-stage robotics company whose value depended heavily on its team, documentation, cloud systems, repositories, development momentum, and technical personnel. Mr. LaValley’s sworn accounting states that creditor and interested-party groups, including Gene Wong / Reno Seed Fund-related interests, Engineered Arts-related interests, and Battle Born-related interests, had the opportunity to participate in or support a funded path that would have preserved the Debtor’s team, development momentum, and going-concern value. That funding did not occur. The same sworn accounting states that the independent appraiser emphasized that the Debtor’s intellectual property had limited standalone value without the team, documentation, funding, and development momentum necessary to continue development. That context matters. Petitioning Creditors should not be permitted to allow time to pass, fail to support a funded preservation path, and then use the resulting loss of access, loss of team continuity, loss of system continuity, and degradation of practical reconstructability as a basis to accuse Mr. LaValley of bad faith or “feign[ing]” lack of knowledge. Estate value was not preserved by accusation. It required funding, action, and technical continuity. If Petitioning Creditors were genuinely focused on preserving estate value, the relevant question is not only what Mr. LaValley remembers more than six months later. It is why the persons and entities with funding capacity, creditor leverage, diligence materials, acquisition interest, technical personnel, and asset-control knowledge did not timely support preservation of the team, systems, and records necessary to maintain that value. VII. THE PASSAGE OF MORE THAN SIX MONTHS AND LOSS OF ACCESS ARE MATERIAL FACTS Petitioning Creditors’ Joinder treats this case as though Mr. LaValley is currently operating the Debtor with live access to its systems, records, employees, premises, and property. That is not the factual record. By the time of the Trustee’s motion and Petitioning Creditors’ Joinder, more than six months had passed since the Debtor ceased operations, lost or surrendered its premises, laid off its team, and no longer had normal operating access to its systems, records, equipment, employees, and assets. Mr. LaValley’s sworn accounting explains that the Debtor’s assets were assigned to the Landlord in or around December 2025, before the bankruptcy petition was filed, and that after that assignment and loss of premises Mr. LaValley no longer had possession, custody, legal authority, or practical control over the Debtor’s assets, systems, records, or equipment. That passage of time is not incidental. It materially affects what Mr. LaValley can know, retrieve, verify, reconstruct, or certify today. Former employees have moved on. Some devices and files may remain with former employees or in personal cloud storage. Company systems, subscriptions, repositories, administrative access, bank records, accounting records, cloud services, and other digital access points may have changed, lapsed, expired, been disabled, or become inaccessible. Physical property may have remained at the premises, been moved, sold, damaged, discarded, or otherwise changed location without Mr. LaValley’s knowledge or control. Six months later, memory is not a substitute for books and records, and prior title is not a substitute for present access. Petitioning Creditors’ accusation that Mr. LaValley “feigned” lack of knowledge ignores this practical reality. Mr. LaValley did not testify from the position of a current operator with active access to a functioning business. He testified as a former officer of a company that had ceased operations months earlier, after the team dispersed, the premises were lost, and access to assets, records, systems, and personnel was no longer centralized with him. VIII. PRESERVING A COMPLEX ROBOTICS COMPANY’S DIGITAL ENVIRONMENT REQUIRED MONEY, ACCESS, PERSONNEL, AND ADMINISTRATION Petitioning Creditors also ignore a practical preservation issue. Cartwheel’s records and technical materials were not static paper records in one place. They existed across physical equipment, company computers, employee-assigned devices, cloud services, software repositories, SaaS tools, accounting systems, email systems, engineering platforms, and third-party services. The Debtor’s remaining assets were assigned to the Landlord in or around December 2025. But assignment of assets is different from practical ability to identify, access, preserve, extract, organize, reconstruct, or monetize technical materials months later. Even where assets were assigned, preserving a robotics company’s full technical and business environment required ongoing funding, administrative access, credentials, subscriptions, cloud services, repositories, software tools, accounting systems, email systems, former employee cooperation, and technical personnel. A failed robotics company’s digital and technical environment does not preserve itself. Maintaining repositories, engineering software, cloud accounts, email systems, SaaS subscriptions, accounting platforms, source-code access, CAD storage, AI / ML development materials, and related access points required money and active administration. Once the company had no operating cash, no continuing team, and no funded path, those systems could lapse, expire, be disabled, or become practically unavailable. That reality should not be recast as Mr. LaValley “feign[ing]” lack of knowledge. IX. PETITIONING CREDITORS’ ATTEMPT TO TURN TRANSPARENCY INTO BAD FAITH SHOULD BE REJECTED Petitioning Creditors criticize Mr. LaValley for creating a public website tracking this case. That argument should be rejected. The website concerns public court filings. It does not contain or establish access to Debtor books and records, accounting systems, bank records, source-code repositories, cloud systems, payroll systems, engineering files, corporate records, physical premises, robotics hardware, or other estate property. Public docket access is not debtor-record control. More importantly, Petitioning Creditors’ criticism reveals the selective nature of their Joinder. Mr. LaValley made the public record more accessible and filed a sworn written accounting identifying potential custodians and sources of Debtor property and information. Petitioning Creditors do not meaningfully engage with that accounting. Instead, they use transparency itself as a basis to attack Mr. LaValley’s credibility. Petitioning Creditors’ use of Mr. LaValley’s public LinkedIn post and public docket website is telling. The exhibit does not show that Mr. LaValley possesses Debtor books, accounting systems, bank records, cloud accounts, source code, repositories, engineering files, payroll records, corporate records, premises, or assets. It shows only that Mr. LaValley made public bankruptcy filings easier for others to access and understand. The Court should not permit a party to weaponize a pro se creditor’s effort to make public filings accessible as supposed evidence of concealment, evasion, or control over records that are not in his possession. If Petitioning Creditors believe the public record is incomplete, the answer is not to attack the person who made it accessible. The answer is to pursue records from the actual custodians and participants identified in Mr. LaValley’s sworn accounting. X. PETITIONING CREDITORS’ INSINUATIONS REGARDING INSIDER FUNDING OMIT THE DILIGENCE AND FINANCING CONTEXT Petitioning Creditors attempt to draw adverse inferences from insider loans, secured notes, and UCC filings, suggesting that those transactions were “coincidental” or “questionable.” Those issues are not properly resolved through rhetoric in a Rule 9001(b)(5) designation motion. Petitioning Creditors’ insinuation that insider funding was unnecessary or suspicious omits the broader diligence and financing context. Mr. LaValley advanced funds while Cartwheel was in diligence with Gene Wong / RSF-related interests. That diligence process extended for approximately six months, during which funding did not arrive and additional diligence requests continued. As that process dragged on, the company’s cash position worsened, creating the need for emergency insider funding to support payroll and operations. Petitioning Creditors cannot fairly omit the prolonged diligence process, question the company’s need for money, and then characterize the resulting insider advances as suspicious. Nor should Petitioning Creditors’ insinuations be resolved by asking Mr. LaValley to reconstruct complex financing transactions from memory. The timing, purpose, documentation, and perfection of the notes and security interests are matters reflected, if at all, in transaction documents, bank records, payroll records, board / company communications, financing communications, UCC records, and communications with counsel and other transaction participants. If Petitioning Creditors or the Trustee wish to investigate the timing, purpose, documentation, validity, or effect of any secured notes or UCC filings, that inquiry should proceed through documents and witnesses with relevant knowledge — not through adverse inferences in a Rule 9001(b)(5) designation dispute. XI. PETITIONING CREDITORS AND RELATED PARTIES POSSESS OR LIKELY POSSESS SUBSTANTIAL RELEVANT INFORMATION Petitioning Creditors’ Joinder ignores that Gene Wong / RSF-related parties possess or likely possess substantial relevant information concerning the very matters Petitioning Creditors now characterize as suspicious. Petitioning Creditors question the timing and purpose of financing, secured notes, UCC filings, insider funding, and the Debtor’s need for funds. But Gene Wong / RSF-related parties were not outsiders to those issues. Mr. LaValley knows that Gene Wong / RSF-related parties possess at least the convertible note documents and related investor materials. Mr. Wong / RSF-related parties also received board packages, financial reports, runway forecasts, pitch decks, investor updates, diligence communications, financing correspondence, and governance-related communications concerning Cartwheel’s cash position, financing needs, and governance disputes. That is particularly important because Mr. LaValley testified at the § 341 meeting that investors were aware of the runway problem, that Cartwheel provided forecasts almost weekly to Gene Wong at his request, and that Mr. Wong had notice from almost the day he invested as to when the company would run out of money. Petitioning Creditors’ insinuations concerning insider funding are also selective. At the § 341 meeting, Mr. LaValley did not recall the name of one of the accounting professionals associated with the company. Upon further recollection, Mr. LaValley recalls that Deane Albright was an investor in Cartwheel and later served as the company’s CPA after being recommended by Mr. Wong. Mr. Albright therefore likely possesses or has access to substantial financial information, accounting records, tax returns, work papers, and related financial materials. This matters because Petitioning Creditors attempt to portray founder / insider advances and security interests as inherently suspicious while ignoring that investor-side participants and their recommended advisors had access to financial information, participated in financing discussions, and may possess records concerning the company’s cash position, accounting records, tax records, use of funds, and need for emergency financing. Mr. LaValley also understands that Gene Wong and Deane Albright later discussed or floated the idea of providing the company, shortly after their initial investment, a secured loan at approximately 10% interest to pay down credit-card debt. Mr. LaValley offers this point not to ask the Court to decide any disputed financing issue here, but to show why Petitioning Creditors’ insinuations are selective and why the relevant inquiry must be document-based. If Petitioning Creditors contend that secured insider or related-party funding was suspicious, then the inquiry should include all communications and participants concerning secured financing concepts, including those involving Gene Wong / RSF-related parties and their recommended advisors. Petitioning Creditors cannot use gaps in Mr. LaValley’s present access or memory as evidence of bad faith while ignoring the convertible note documents, investor materials, board packages, financial reports, runway forecasts, pitch decks, financing updates, diligence materials, accounting records, tax records, CPA work papers, and counsel communications held by or available from Gene Wong / RSF-related parties, Mr. Albright, and other transaction participants. XII. DISPUTED FINANCING-DOCUMENT ISSUES TRACE BACK TO THE FIRST CONVERTIBLE NOTE FINANCING AND CONFLICTED COUNSEL Petitioning Creditors’ insinuations regarding secured notes, UCC filings, governance rights, and control cannot be fairly evaluated without the financing-document history that gave rise to the dispute. The first financing round — the convertible note financing — is central to the events that led to this bankruptcy. In Mr. LaValley’s view, the first convertible note financing and the conflicted document structure surrounding it are central to why Cartwheel ultimately became trapped in a governance and financing dispute that ended in bankruptcy. Petitioning Creditors should not be permitted to discuss that financing history selectively. Gene Wong / RSF-related parties possess or likely possess substantial contemporaneous information concerning the first convertible note financing, the related governance / control dispute, the parties’ understanding of the financing structure, and the events that followed. Mr. Wong / RSF-related parties received investor materials, board packages, financial reports, runway forecasts, pitch decks, financing updates, and communications concerning Cartwheel’s cash position and governance. That first financing created the financing and governance structure that later became the subject of disputes over control, protective provisions, investor rights, noteholder rights, and the parties’ respective understanding of Cartwheel’s governance. Petitioning Creditors’ Joinder attempts to draw adverse inferences from later secured-note and UCC matters while ignoring the earlier document structure, counsel-related issues, and contemporaneous information held by Gene Wong / RSF-related parties. Mr. LaValley understands that Craig Macy, who was acting as Cartwheel’s corporate counsel, prepared or was involved in preparing relevant financing, secured-note, and governance documents. Mr. LaValley further understands that Mr. Macy also represented or had a conflicting relationship with Gene Wong / RSF-related interests, and Mr. LaValley is aware of no written conflict waiver authorizing counsel to represent Cartwheel while also representing or advancing potentially adverse Gene Wong / RSF-related interests in connection with the relevant financing documents. To Mr. LaValley’s knowledge, Gene Wong was not personally involved in drafting the secured notes. But Gene Wong / RSF-related parties possess or likely possess substantial documents and communications concerning the financing, diligence, governance, board reporting, financial condition, and later disputes arising from those documents. The point is narrower: Petitioning Creditors’ insinuations concern lawyer-drafted financing documents whose origin, drafting, conflict-waiver status, approvals, and relationship to the first convertible note financing are document-based issues. Those issues should be investigated through appropriate discovery, not used as adverse inferences against Mr. LaValley in a Rule 9001(b)(5) designation motion. Petitioning Creditors cannot fairly attack lawyer-drafted financing documents while ignoring the lawyer who drafted them, the alleged conflict under which they were drafted, the absence of a conflict waiver, and the document history that created the governance and creditor-rights dispute in the first place. To the extent Petitioning Creditors now question the timing, validity, purpose, or effect of secured notes, UCC filings, governance documents, protective provisions, or creditor rights, the relevant inquiry should include the counsel who prepared the documents, the transaction files, communications concerning the financing structure, drafts, term sheets, closing materials, board or stockholder approvals, and the parties’ communications regarding what rights were being created. Those issues are not properly resolved through insinuation in a Rule 9001(b)(5) designation motion. They do not establish that Mr. LaValley presently has possession, custody, control, access, or legal authority over Debtor records or property, nor do they justify requiring him to reconstruct schedules or disputed financing history from memory more than six months after operations ceased. XIII. PETITIONING CREDITORS’ JOINDER CONFIRMS THE IMPORTANCE OF MR. LAVALLEY’S PENDING RULE 2004 REQUEST Petitioning Creditors’ Joinder confirms the importance of Mr. LaValley’s pending Rule 2004 request. Petitioning Creditors raise issues concerning asset control, records, secured notes, UCC filings, value, potential custodians, and alleged gaps in Mr. LaValley’s knowledge. Those issues cannot be fairly resolved by requiring Mr. LaValley to reconstruct records from memory. They require documents and information from the persons and entities who actually possess, control, created, reviewed, received, or retained relevant records. Mr. LaValley has already sought targeted Rule 2004 discovery because the relevant facts are distributed among actual custodians and participants. Petitioning Creditors’ own Joinder reinforces that point. If the estate’s goal is to understand records, assets, collateral value, technical materials, asset disposition, and potential recoverable value, the inquiry must reach the persons and entities with actual documents, technical knowledge, asset-control information, financial records, creditor communications, and transaction history. Mr. LaValley has identified potential custodians and sources of information, including former employees, technical personnel, creditor / investor parties, acquisition-related parties, counsel, accountants, and others. Petitioning Creditors should not be permitted to ignore actual custodians while simultaneously attacking Mr. LaValley for not possessing or reconstructing records, files, systems, or technical materials he does not control. Mr. LaValley does not dispute that a Chapter 7 trustee may examine issues concerning collateral, valuation, perfection, priority, transfers, and any potential equity cushion for the estate. That is precisely why the inquiry should be document-based and directed to actual custodians and transaction participants. Those issues require lien documents, UCC records, secured-note documents, valuation materials, transfer documents, bank records, payroll records, counsel files, creditor communications, technical-custodian records, CPA records, tax records, accounting records, and former-employee knowledge. They should not be converted into adverse inferences against Mr. LaValley in a Rule 9001(b)(5) designation dispute. The pending designation issue should therefore be handled through a tailored order limited to Mr. LaValley’s actual possession, custody, control, access, legal authority, and personal knowledge. Mr. LaValley’s pending Rule 2004 request remains important because it is directed toward the broader record needed to understand what occurred and where relevant records and value-related information actually reside. XIV. RULE 9001(b)(5) DESIGNATION SHOULD NOT BE USED TO ADJUDICATE FIDUCIARY-DUTY ACCUSATIONS OR PERSONAL LIABILITY Petitioning Creditors’ Joinder includes accusations and insinuations concerning fiduciary duties, potential personal liability, and D&O insurance. Those issues are not properly adjudicated through the pending designation motion. Rule 9001(b)(5) designation is procedural. It may identify a person to appear, answer questions, cooperate, or perform debtor-related acts for a corporate debtor. It should not be used to adjudicate personal liability, fiduciary-duty claims, or alleged wrongdoing. Any such claims would require a separate pleading, evidence, defenses, and due process. Mr. LaValley can answer questions truthfully from personal knowledge. He can identify potential sources and custodians. He can cooperate within the limits of his actual possession, custody, control, access, legal authority, and knowledge. But he should not be deemed to have breached fiduciary duties merely because he cannot retrieve or certify records that are not in his possession or control. XV. ANY ORDER SHOULD BE OPERATIONAL, NOT PUNITIVE If the Court enters any order concerning Mr. LaValley, the order should be carefully limited to what Mr. LaValley can actually do. Mr. LaValley respectfully submits that any order should state that he is required only to: 1. appear and answer questions truthfully from personal knowledge; 2. identify, to the extent known, possible sources and custodians of Debtor records, property, systems, files, and information; 3. cooperate reasonably with the Trustee’s efforts to obtain records from actual custodians or third parties; and 4. produce any nonprivileged Debtor property or records actually in his possession, custody, or control, if any. Any order should also make clear that Mr. LaValley is not required to: 1. recreate schedules or statements from memory or speculation; 2. certify the accuracy of schedules prepared without access to underlying Debtor records; 3. produce records, systems, devices, source code, files, cloud accounts, or property outside his possession, custody, or control; 4. obtain materials from third parties over whom he has no legal authority; 5. perform uncompensated forensic accounting, bookkeeping, technical reconstruction, or schedule-preparation work from incomplete information; or 6. act as counsel for the Debtor. XVI. CONCLUSION Petitioning Creditors’ Joinder does not solve the records problem. It attempts to weaponize it. The § 341 transcript does not support Petitioning Creditors’ claim that Mr. LaValley “feigned” lack of knowledge. It shows that Mr. LaValley appeared, answered questions, identified limits on his access, identified potential custodians and sources of information, and remained willing to cooperate within the limits of his actual possession, custody, control, access, legal authority, and personal knowledge. Petitioning Creditors’ own Joinder confirms that this is not a one-person records issue. Their Joinder identifies other people they claim may have relevant information or control, while ignoring the former employees and technical personnel most likely to be necessary for any practical reconstruction of technical value. Petitioning Creditors also ignore their own possession or likely possession of substantial convertible-note documents, investor materials, board packages, financial reports, runway forecasts, pitch decks, financing updates, diligence materials, governance communications, accounting records, tax records, and creditor communications relevant to the issues they now characterize as suspicious. Petitioning Creditors should not be permitted to let time pass, fail to support a funded preservation path, ignore the technical custodians most relevant to value reconstruction, criticize public transparency, and then convert the resulting loss of access, team continuity, system continuity, and reconstructability into a personal credibility attack against Mr. LaValley. For the reasons stated above and in Mr. LaValley’s prior opposition [ECF No. 65], any order should be limited to what Mr. LaValley can actually do and should not require him to recreate, certify, retrieve, or produce records and property outside his possession, custody, control, access, or legal authority. DATED: May 28, 2026. Respectfully submitted, Scott LaValley Appearing pro se, individually and as creditor / party in interest lavalley.scott@gmail.com