BCB Cheyenne LLC v. MineOne Wyoming Data Center LLC — Entry #384: OPPOSITION to 368 Motion to Quash filed by Defendants MineOne Partners LLC, MineOne Wyoming Data Center LLC, Terra Crypto Inc

Case: BCB Cheyenne LLC v. MineOne Wyoming Data Center LLC wyd · 1:23-cv-00079

filed May 03, 2023

What this document is

Docket entry #384 · filed October 07, 2024

OPPOSITION to 368 Motion to Quash filed by Defendants MineOne Partners LLC, MineOne Wyoming Data Center LLC, Terra Crypto Inc. (Attachments: # 1 Exhibit A - Notice of Intent to Serve Subpoena, # 2 Exhibit B - Email Transmittal of Subpoena to JWJ Technology LLC, # 3 Exhibit C - 08-26-24 Letter to P Murphy re 08-22 Order, # 4 Exhibit D - 07-23-24 P. Murphy Deposition Schedule Ltr, # 5 Exhibit E - 08-16-24 P. Murphy Ltr to Judge Hambrick Excerpts, # 6 Exhibit F - 08-22-24 P. Murphy Ltr re Deposition Scheduling Conferral, # 7 Exhibit G - 07-25-24 - BCB Fourth Supplemental Rule 26 Disclosures) (Colbath, Paula) (Entered: 10/07/2024)

Who is involved

BCB Cheyenne LLC
Bit Origin Ltd
Bitmain Technologies Georgia Limited
Bitmain Technologies Holding Company
MineOne Partners LLC
MineOne Wyoming Data Center LLC
SonicHash LLC
Terra Crypto Inc

Why we have it

We follow this case because it names a company we track, although that company is not a party:

TeraWulf: its name “TeraWulf” appears in a filing in this case.
…7/14/2023 Meten Holding 200 S19J PRO $400,000 7/18/23 TeraWulf (WULF) 18,500 S19J XP $75,400,000 10/6/2023 Iris…
CleanSpark: its subsidiary “CSRE Properties Wyoming, LLC” appears in a filing in this case.
…Center LLC, CleanSpark, Inc., and CSRE Properties Wyoming, LLC, (a wholly owned subsidiary of…

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Case 1:23-cv-00079-ABJ Document 384-7 Filed 10/07/24 Page 1 of 48

EXHIBIT G

Case 1:23-cv-00079-ABJ Document 384-7 Filed 10/07/24 Page 2 of 48

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: [email protected]
[email protected]

Attorneys for Plaintiff BCB Cheyenne LLC
d/b/a Bison Blockchain

IN THE UNITED STATES DISTRICT COURT
FOR DISTRICT OF WYOMING

BCB CHEYENNE LLC d/b/a BISON )
BLOCKCHAIN, a Wyoming limited liability )
company, )
Plaintiff, )
v. )
)
MINEONE WYOMING DATA CENTER )
LLC, a Delaware limited liability company; )
MINEONE PARTNERS LLC, a Delaware )
limited liability company; TERRA CRYPTO, )
Civil Action No. 23-CV-79-ABJ
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. )

BCB CHEYENNE LLC d/b/a BISON BLOCKCHAIN’S FOURTH SUPPLEMENTAL
RULE 26 DISCOVERY DISCLOSURES

COMES NOW Plaintiff BCB Cheyenne LLC d/b/a Bison Blockchain (“BCB”), through

its counsel, Patrick J. Murphy and Scott C. Murray of WILLIAMS, PORTER, DAY & NEVILLE, PC,

Case 1:23-cv-00079-ABJ Document 384-7 Filed 10/07/24 Page 3 of 48

and pursuant to Fed. R. Civ. P. 26(a)(1)(A), hereby provides the following second supplemental

disclosures:

PLAINTIFF'S DISCLAIMER: The following second supplemental disclosures are

provided in compliance with Fed. R. Civ. P. 26(a)(1)(A). Compliance with the rule requires the

disclosure of individuals likely to have discoverable information that BCB may use to support its

claims or defenses, and the disclosure of documents that BCB may use to support its claims or

defenses. While BCB has, in its investigation, discovered the names of witnesses and documents

set forth below, it is not listing them as witnesses or exhibits to be introduced at the trial of this

matter. Rather, BCB is simply complying with the requirements of Rule 26(a)(1)(A) in a good

faith disclosure of potential witnesses and exhibits. BCB reserves the right to contest the relevancy

and admissibility of the disclosed individuals and documents, if necessary, based upon further

discovery in this case.

(i). The name and, if known, the address and telephone number of each individual
likely to have discoverable information – along with the subjects of that information – that
the disclosing party may use to support its claims or defenses, unless the use would be solely
for impeachment.

BCB identifies the following persons with relevant knowledge of the facts and

circumstances of the events which are the subject of this lawsuit.

1. Michael D. Murphy, CPA
MEMBER, BCB CHEYENNE LLC
c/o Patrick J. Murphy and Scott C. Murray
159 N Wolcott St # 400
Casper, WY 82601
PH: 307-265-0700

Michael Murphy has knowledge of all the salient liability and damages issues in this case. He has

knowledge of all of the factual allegations in Plaintiff’s First Amended Complaint, Plaintiff’s

Answer to Defendants’ First, Second and Third Counter-Claims, and he understands and primarily

Case 1:23-cv-00079-ABJ Document 384-7 Filed 10/07/24 Page 4 of 48

authored the Plaintiff’s damages analysis and computation below. Michael Murphy has extensive

knowledge of power pricing for Bitcoin mining and the negotiations with Black Hills Energy

including the Request for Proposal (“RFP”) and BCIS Agreement. Mr. Murphy has extensive

knowledge of negotiations with MineOne Wyoming Data Center LLC (“MineOne Wyoming”)

and Terra Crypto Inc. (“Terra”), leading to the written agreements/contracts between BCB and

each of those individual entities. Mr. Murphy also has knowledge involving the following:

● The events surrounding and involving MineOne Wyoming and Terra breaching their

respective agreements with BCB.

● MineOne Wyoming and Terra being alter egos of one another and of Bit Origin LTD

(“Bit Origin”), MineOne Partners LLC (“MineOne Partners”), and SonicHash LLC

(“SonicHash”).

● BCB’s contractual performance for both MineOne Wyoming and Terra:

○ Supporting and managing the land acquisition for the Facilities by MineOne

Wyoming (including all local Wyoming legal and other required support)

○ Obtaining all permits and licenses, including construction permits for buildings and

the Facilities’ electric infrastructure, environmental licenses and permits,

operations permits and licenses (including legal and other) required or

recommended to comply with applicable law and regulation.

○ Supporting and managing the execution of the power purchase arrangements by

MineOne Wyoming.

○ All other reasonable related activities within its control to enable MineOne

Wyoming and other users of the Facilities to conduct digital currency mining

Case 1:23-cv-00079-ABJ Document 384-7 Filed 10/07/24 Page 5 of 48

activities in a proper and timely manner to ensure that CFCO occurs not later than

31 October 2022.

○ Ensuring that all improvements are developed in accordance with the approved

construction and engineering documents and all employees, contractors, or

Subcontractors (if any) (as provided for below) carry standard general liability and

workman’s compensation insurance.

○ Project management and services to support MineOne Wyoming responsibilities as

specified in the Budget as and when the same fall due.

● The contractual obligations and responsibilities of Defendants’ contractors, and

Defendants’ contractors’ failures to perform their contractual obligations and

responsibilities to Defendants, all of which led to delays in the project timeline,

including but not limited to:

○ The multiple failures of CEGEN Green Energy Ltd (“CEGEN”) not timely

completing the modular data centers it was contracted to provide, not staying within

the agreed-to budget, and not paying its subcontractors;

○ Shermco Industries, Inc (“Shermco”) not timely completing site electrical work,

not fulfilling its construction management obligations, and several engineering

errors;

○ Cheyenne Light, Fuel and Power Company (“CLFP”), a subsidiary of Black Hills

Corporation, not completing its facilities to provide all the electric power to the

North Range site on the contractually agreed-to timeline.

● The events and facts involving Defendants’ circumvention and interference in

Plaintiff’s obligations, including but not limited to, redirecting labor resources and

Case 1:23-cv-00079-ABJ Document 384-7 Filed 10/07/24 Page 6 of 48

established scopes of work; interrupting regular and planned subcontractor and vendor

meetings; changing of approved and/or industry standard means and methods of

construction; receipt, handling, storage, and security of miners for the facility; hiring

of labor and other resources for racking and stacking miners in data centers; network

configuration and design; and overall commencement of mining operations.

● Other entities, factors, and events that occurred outside of Plaintiff's control which led

to delays of the project timeline, including but not limited to:

○ The oversight and failure of Laramie County Planning and Development (“LCPD”)

and Laramie County Department of Buildings (“LCDOB”) to recognize and engage

with the Cheyenne Board of Public Utilities (“BOPU”) relating to an existing

waterline on the North Range property that was properly reflected on the relevant

engineering permit documents during the permitting process that cause project

delays to site improvements, data center construction, and overall delivery of the

project.

○ Weather Delays and inclement weather that resulted in delays and other

interruptions in progress due to causing dangerous working conditions, including

but not limited to, extreme cold, extreme wind, and/or other extreme weather

conditions experienced during construction that posed life safety and other health

hazards.

○ Defendants' Funding and Liquidity

● The events and facts involving Bitmain’s contractual interference and Defendants’

actions to remove BCB from the North Range and Campstool bitcoin mining

sites/projects.

Case 1:23-cv-00079-ABJ Document 384-7 Filed 10/07/24 Page 7 of 48

2. Emory Patterson, IV
MEMBER, BCB CHEYENNE LLC
c/o Patrick J. Murphy and Scott C. Murray
159 N Wolcott St # 400
Casper, WY 82601
PH: 307-265-0700

Emory Patterson has knowledge of many factual allegations in Plaintiff’s First Amended

Complaint, Plaintiff’s Answer to Defendants’ First, Second and Third Counter-Claims, and he

understands the contractual roles and obligations of agreements between Plaintiff and Defendants,

and between Defendants and their contractors and/or vendors (CEGEN, Shermco, Systems-MEC,

CCO Interiors, INMAN ROOFING, Rocky Mountain Sand & Gravel, Alco Fencing, Greeley Lock

& Key, Iron Creek Construction, Petro-Pier, Terracon Consultants, Automation Electronics, Steil

Surveying, LOVAS Engineering, and Wyott Capital Group). Emory Patterson has knowledge of

the negotiations with Black Hills Energy. Mr. Patterson has knowledge of negotiations with

MineOne Wyoming and Terra, leading to the written agreements/contracts between BCB and each

of those individual entities. Emory Patterson also has knowledge involving the following:

● The events and facts involving MineOne Wyoming and Terra breaching their

respective agreements with BCB.

● MineOne Wyoming and Terra being alter egos of one another and of Bit Origin,

MineOne Partners, and SonicHash.

● BCB’s contractual performance for both MineOne Wyoming and Terra:

○ Supporting and managing the land acquisition for the Facilities by MineOne

Wyoming (including all local Wyoming legal and other required support)

○ Obtaining all permits and licenses, including construction permits for buildings and

the Facilities’ electric infrastructure, environmental licenses and permits,

Case 1:23-cv-00079-ABJ Document 384-7 Filed 10/07/24 Page 8 of 48