Case 1:23-cv-00079-ABJ Document 386 Filed 10/15/24 Page 1 of 3 Patrick J. Murphy, WSB No. 5-1779 Scott C. Murray, WSB No. 7-4896 WILLIAMS, PORTER, DAY & NEVILLE, P.C. 159 N. Wolcott, Ste. 400 P.O. Box 10700 (82602) Casper, WY 82601 Email: pmurphy@wpdn.net smurray@wpdn.net Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF WYOMING BCB CHEYENNE LLC d/b/a BISON ) BLOCKCHAIN, a Wyoming limited liability ) Company, . ) ) Plaintiff, ) ) v. ) Civil No. 23-CV-79 ) MINEONE WYOMING DATA CENTER, ) LLC, a Delaware limited liability company; ) MINEONE PARTNERS LLC, a Delaware ) limited liability company; TERRA CRYPTO ) INC., a Delaware corporation; BIT ORIGIN, ) LTD, a Cayman Island Company; ) SONICHASH LLC, a Delaware limited ) liability company; BITMAIN ) TECHNOLOGIES HOLDING COMPANY, ) A Cayman Island Company; BITMAIN ) TECHNOLOGIES GEORGIA LIMITED, ) a Georgia corporation; and JOHN DOES 1-18, ) related persons and companies who control ) or direct some or all of the named Defendants, ) ) Defendants. ) JOINT AND STIPULATED MOTION TO DISTRIBUTE ALL OF THE ATTACHED FUNDS AND ACCRUED INTEREST BEING HELD BY THE CLERK OF THE DISTRICT COURT PURSUANT TO THIS COURT’S AMENDED PREJUDGMENT WRITS OF ATTACHMENT AND GARNISHMENT COME NOW all the remaining Parties, Plaintiff BCB Cheyenne LLC and Defendants Case 1:23-cv-00079-ABJ Document 386 Filed 10/15/24 Page 2 of 3 MineOne Wyoming Data Center, LLC, Terra Crypto Inc., MineOne Partners, LLC, Bit Origin, Ltd., and SonicHash, LLC, through their respective counsel, and hereby stipulate, agree and jointly move the Court for its immediate Order directing the Clerk of the District Court to distribute all of the attached funds being held and invested by the Clerk of the District Court, together with all of the accrued interest on those attached funds, as follows: 1. The Parties have now settled all of their claims and counterclaims and will soon file with the Court their Stipulation of Dismissal with Prejudice and a [proposed] Order of Dismissal with Prejudice. The Parties have also signed a written Settlement Agreement and Mutual Releases (“Settlement Agreement”). 2. Pursuant to their Settlement Agreement, of the $15,277,292.79 in attached funds held in the Court’s Registry, MineOne Wyoming Data Center LLC is to receive $11,177,292.79 of the attached funds being held and invested by the Clerk of the District Court, and BCB Cheyenne LLC is to receive $4,100,000.00 of the attached funds being held and invested by the Clerk of the District Court. 3. Further, and also pursuant to the Parties’ Settlement Agreement, any remaining balance held in the Court’s Registry after the distributions above shall be used to satisfy any interest and/or fees owing to the Court, and any balance remaining after satisfying any interest and/or fees owing to the Court shall be distributed to MineOne Wyoming Data Center LLC. 4. The Parties now agree, stipulate, and jointly move this Court that it now review, sign, and enter the attached [proposed] ORDER DIRECTING THE CLERK OF THE DISTRICT COURT TO DISTRIBUTE ALL OF THE ATTACHED FUNDS AND ACCRUED INTEREST BEING HELD BY THE CLERK OF THE DISTRICT COURT PURSUANT TO THIS COURT’S AMENDED PREJUDGMENT WRITS OF ATTACHMENT AND GARNISHMENT . 1 Case 1:23-cv-00079-ABJ Document 386 Filed 10/15/24 Page 3 of 3 DATED this 15th day of October, 2024. BCB Cheyenne LLC d/b/a Bison MineOne Wyoming Data Center LLC, Blockchain Terra Crypto Inc., and MineOne Partners LLC Plaintiff Defendants By: Paula K. Colbath, Pro Hac Vice By: /s/ Patrick J. Murphy Paula K. Colbath Patrick J. Murphy (WSB No. 5-1779) LOEB & LOEB LLP Williams, Porter, Day & Neville, PC 345 Park Avenue 159 N Wolcott St. Suite 400 New York, NY 10154 Casper, WY 82601 Ph.: (212) 407-4905 Ph: (307) 265-0700 E-mail: pcolbath@loeb.com E-mail: pmurphy@wpdn.net Bit Origin, Ltd. and SonicHash, LLC Defendants By: Marc S. Gottlieb, Pro Hac Vice Marc S. Gottlieb ORTOLI ROSENSTADT, LLP 366 Madison Avenue, 3rd Floor New York, NY 10017 msg@orllp.legal 2