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…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 05, 2026. Federal court filings are public records.
Document text
6 page(s), 8,566 characters, converted from the PDF's text layer · plain text.
Full text
Case 1:23-cv-00079-ABJ Document 384-3 Filed 10/07/24 Page 1 of 6
EXHIBIT C
Case 1:23-cv-00079-ABJ Document 384-3 Filed 10/07/24 Page 2 of 6
PAULA K. COLBATH
Partner
345 Park Avenue Direct 212.407.4905
New York, NY 10154 Main 212.407.4000
Fax 212.407.4990
[email protected]
Via email ([email protected]) and First Class
Mail
August 26, 2024
Patrick Murphy, Esq.
Williams, Porter, Day and Neville, P.C.
159 N Wolcott St., Suite 400
Casper, WY 82601
Re: BCB v MineOne Wyoming Data Center LLC et al. – August 22, 2024 Order
Dear Patrick:
As you know, we, along with our co-counsel Hathaway & Kunz, LLP, represent Defendants
MineOne Wyoming Data Center, LLC (“MineOne”), MineOne Partners, LLC, and Terra Crypto
Inc. (collectively, the “MineOne Defendants”).
We write pursuant to the Court’s August 22, 2024 Order (ECF No. 322) to provide the following
information regarding Chong “Lucas” Wang and Huali “Wiley” Zhang:
Chong “Lucas” Wang
As we have advised you for months, Mr. Wang is not an officer, member, employee and/or director
of any of the MineOne Defendants. Mr. Wang does not own individually any interest in a MineOne
Defendant, nor does he have any decision making authority over any of the MineOne Defendants.
According to public filings filed with Defendant Bit Origin Ltd. with the Securities Exchange
Commission, Mr. Wang was previously the Chief Executive Officer of Defendant Bit Origin Ltd.,
which we understand to be a public company which trades on NASDAQ under the ticker symbol
BTOG. Our clients have confirmed to us that Mr. Wang never visited the digital currency mining
facilities that are the subject of this action.
Mr. Wang’s last known address (from Bit Origin Ltd.’s public filings) is:
Room 1802, Building 1,
Renheng Tang Yue Wan, Binhe Road,
High-Tech District, Suzhou City, Jiangsu Province, China
Huali “Wiley” Zhang
Mr. Zhang is associated with JWJ Technology LLC (“JWJ”), an independent vendor experienced
in building digital currency mining facilities such as the facilities at issue in this action. JWJ was
retained to assist BCB Cheyenne LLC (“BCB”) in completing construction of the North Range
facility (which experienced significant cost overruns and construction delays). Also, after BCB
Los Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com
For the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability partnership.
Case 1:23-cv-00079-ABJ Document 384-3 Filed 10/07/24 Page 3 of 6
Patrick Murphy, Esq.
August 26, 2024
Page 2
walked off the job in March 2023, JWJ assumed additional responsibilities at the digital currency
mining facilities at issue in this case.
MineOne Data’s work with JWJ ended when President Biden signed his May 13, 2024 Order
requiring the MineOne Defendants to divest from the North Range property and remove all of the
infrastructure and miners thereon.
Mr. Zhang’s last known address (taken from an invoice issued by JWJ in connection with the
digital currency mining project, a copy of which is attached hereto) is:
JWJ Technology LLC
614 N DuPont Hwy, Suite 210
Dover, Delaware 19901
Sincerely,
Paula K. Colbath
Partner
cc: Sean Larson, Esq.
Marc Gottlieb, Esq.
Meggan Hathaway, Esq.
Marc Feinstein, Esq.
Khale Lenhart, Esq.
Enclosure
Case
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Message
From: Ii Iris [[email protected]]
on behalf of Ii Iris <[email protected]> [[email protected]]
Sent: 1/19/2023 10:26:59 AM
To: Michael Murphy [[email protected]]
CC: Neil Phippen [[email protected]]; Emory Patterson [[email protected]]; Alice Shan [[email protected]]; Ii Iris
[[email protected]]; Ziyao Shao [[email protected]]; [email protected]; [email protected];
Jiaming Li [[email protected]]; Info@MineOne [[email protected]]
Subject: FW: payments for Friday 01/06/2023
Attachments: lsxwdnKsbmkuaTXyrHtIFRIbXBvcmFyeSB3b3JrZXJzIHBheSBzaGVldCgxKS54; JWJ invoice-20230115-14240.pdf
I-li Michael,
This invoice is for the labor cost of temporary workers which should be deducted from the bill of
Cegen. The timesheet attached.
Any questions, please let us know. Thank you.
With Regards
Iris
CONFIDENTIAL MINEONE0013710
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DOCUMENT PRODUCED IN NATIVE FORMAT
CONFIDENTIAL MINEONE0013711
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JWJ Technology LLC
614 N DuPont Hwy, Suite 210
Dover, Delaware 19901
2023010101
MineOne Wyoming Data Center 1 t1s. 1111: 2023/01/15
Due Upon Receipt
QTY DESCRIPTION
Labor cost 2022.12.15-2023.1.15
time sheet attached 14,240.00
Z4i] Iii]
TERMS O CONDITIONS
t1
' Payment is Due Upon Receipt
CONFIDENTIAL MINEONE0013712