Case 9:18-cv-80176-BB Document 228 Entered on FLSD Docket 06/26/2019 Page 1 of 2

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

IRA KLEIMAN, as personal representative of

the estate of David Kleiman, and W&K INFO
DEFENSE RESEARCH, LLC

plaintiffs,
v. Case No. 9:18-cv-80176 (BB/BR)

CRAIG WRIGHT,

defendant.
_____________________________________/

DR. WRIGHT’S NOTICE OF

INTENTION TO CALL WITNESSES AT THE JUNE 28, 2019 HEARING

Dr. Wright provides notice that he intends to call the following witnesses at the

the evidentiary hearing scheduled for 9:00 am on June 28, 2019, at the Paul G. Rogers Federal

Building, 701 Clematis Street, West Palm Beach, Florida.

1. Brett Roberson. Dr. Wright intends to call Mr. Roberson to testify as an expert

witness regarding digital forensics and PGP signatures. Mr. Roberson has extensive knowledge

and expertise related to digital forensics and PGP signatures, and his CV is attached as Exhibit 1.

2. Kevin Madura. Dr. Wright intends to call Mr. Madura to testify as an expert

witness regarding cryptography, cryptocurrencies, and the blockchain. Mr. Madura has extensive

knowledge and expertise related to cryptography, cryptocurrencies, and the blockchain, and his

CV is attached as Exhibit 2.

3. Steve Shadders. Mr. Shadders is the Chief Technology Officer of nChain. He will

be testifying as a fact witness.

4. Craig Wright. Dr. Wright will be testifying as a fact witness.

Case 9:18-cv-80176-BB Document 228 Entered on FLSD Docket 06/26/2019 Page 2 of 2

Respectfully submitted,

Attorneys for Dr. Craig Wright

RIVERO MESTRE LLP

2525 Ponce de Leon Boulevard, Suite 1000
Miami, Florida 33134
Telephone: (305) 445-2500
Fax: (305) 445-2505
Email: arivero@riveromestre.com
Email: jmestre@riveromestre.com
Email: arolnick@riveromestre.com
Email: zmarkoe@riveromestre.com
Email: receptionist@riveromestre.com

By: s/ Andres Rivero

ANDRES RIVERO
Florida Bar No. 613819
ALAN H. ROLNICK
Florida Bar No. 715085
AMANDA MCGOVERN
Florida Bar No. 964263
ZAHARAH MARKOE
Florida Bar No. 504734

CERTIFICATE OF SERVICE

I certify that on June 26, 2019, I electronically filed this document with the Clerk of the
Court using CM/ECF. I also certify that this document is being served today on all counsel of
record either by transmission of Notices of Electronic Filing generated by CM/ECF or by U.S.
Mail.

/s/ Andres Rivero_______

Andres Rivero

2
Case 9:18-cv-80176-BB Document 228-1 Entered on FLSD Docket 06/26/2019 Page 1 of 2

CURRICULUM VITAE
OF
Brett A. Roberson
Texas Licensed Qualified Manager &
Private Investigator # 816698

POSITION Director, AlixPartners, LLP, Dallas, Texas

EDUCATION B.A. in Business Administration and International Studies, Abilene

Christian University

PROFESSIONAL Mr. Roberson has more than nineteen years of experience in

HISTORY information technology and as a forensic investigator and manager.
Beginning in 2005, he has continuously provided computer forensic
consulting and electronic discovery services for many matters. Mr.
Roberson has a wide range of experience with information
technology infrastructure and security, forensic acquisition and
forensic analysis, including computer tampering, contractual disputes,
employment matters, network intrusions, intellectual property theft,
and fraud.

PROFESSIONAL Mr. Roberson has extensive experience providing design and

EXPERIENCE installation of information technology infrastructures and network
security administration. He has provided technical expertise in
criminal and civil investigations. As a Director for a global
consulting firm, Mr. Roberson has been tasked with development of
policies and procedures, case management, quality control
workflows and resource allocation.

RANGE OF Mr. Roberson has performed a variety of services related to computer

EXPERIENCE forensics and investigations. A sample of these includes:
Computer forensics investigations
Detection of intellectual property theft
Analysis of a computer user's actions over specific time periods
Recovery of deleted files
Defensible forensic collection of ESI
Filtering and searching for responsive documents and the de-
duplication of mass ESI
Client site assessment of ESI, assistance with identification of
items potentially responsive to eDiscovery obligations
Remote forensic imaging and analysis

2101 Cedar Springs Road | Suite 1100 | Dallas, TX | 75201 | 214.647.7500 | 214.647.7501 fax | www.alixpartners.com
Case 9:18-cv-80176-BB Document 228-1 Entered on FLSD Docket 06/26/2019 Page 2 of 2

Brett A. Roberson
PAGE 2

ACCREDITATIONS EnCase® Certified Examiner (EnCE), Guidance Software –

AND LICENSES Recertification in Process
CCE Certification in Process
Licensed Private Investigator, Qualifying Manager - Computer Forensics,
State of Texas (ALIXPARTNERS FORENSIC SERVICES, LLC -
License #A14892)
 
ADDITIONAL
TRAINING AND Magnet Axiom Investigations
EDUCATION Apple iOS Mobile Forensics, Blackbag Technologies
Intermediate Apple OSX Hardware and Software Forensics – Blackbag
Technologies
EnCase NTFS, Guidance Software
CISSP Training and Certification (Does Not Possess Cert Post-Expiry)
EnCase Advanced Internet & Email Examinations, Guidance Software
EnCase Internet & Email Examinations, Guidance Software
EnCase Intermediate Computer Forensics, Guidance Software
EnCase Level 1 Computer Forensics, Guidance Software
Interrogation and Elicitation Techniques, BIA
Private Investigations Skip Tracing, Surveillance and Interrogation and
Elicitation Techniques, PIEducation
Intermediate Microsoft SQL Training - LearningTree

2101 Cedar Springs Road | Suite 1100 | Dallas, TX | 75201 | 214.647.7500 | 214.647.7501 fax | www.alixpartners.com
Case 9:18-cv-80176-BB Document 228-2 Entered on FLSD Docket 06/26/2019 Page 1 of 2

KEVIN MADURA
Washington, DC | 242-665-2990 | kmadura@alixpartners.com

EDUCATION
University of Maryland
Bachelor of Science, Computer Science; Minor in Leadership Studies 2010-2014
Awards: Corporate Scholars Scholarship, Order of Omega

Georgetown University
Master of Professional Studies, Technology Management 2015-2017
Capstone: “Smart Traffic: Controlling Congestion with Technology”

RELATED EXPERIENCE
IBM
Cybersecurity Consultant - Cryptography SME 2014 - 2018
Provided subject matter expertise in areas of cryptography, secure coding, and vulnerability
management for entities within the Department of Defense.

Deployed technical solution to verify identity of soldiers using Common Access Cards (CAC) using
cryptographic primitives such as SHA256 and public key cryptography,in alignment with NIST 800-53.

Hosted “lunch & learns” to educate colleagues on secure coding methodologies and case studies.

IBM
Blockchain Identity Expert: Federal Agency 2017
Primary architect of enterprise identity solution based on blockchain technology, which included
validating the proper use of cryptography and secure coding methodology.

IBM
Blockchain Programmer: USPS 2017 - 2018
Led development of blockchain implementation and smart contract coding for government
blockchain pilot programs.

AlixPartners
Vice President, Cybersecurity Practice 2018 -
Advise clients on cybersecurity matters, ranging from technical implementation issues to executive
risk management functions.

Performed forensic investigation for mobile application development company to determine

exposure of malicious code and vulnerable software development kits.

Member of blockchain industry team tasked with exploring applications of distributed ledger
technology for enterprise clients, implementing cryptocurrency coins, and proper management of
Bitcoin wallets.

CERTIFICATIONS
Certified Ethical Hacker
Credential ID ECC39758882107 2018

CONFERENCE PRESENTATIONS
Armed Forces Communications and Electronics Association
Cybersecurity in the World of Blockchain and Cryptocurrency 2018
A discussion on the applicability of implementing blockchain technology, based on Bitcoin, for use
within the US military.

AlixPartners
Procurement Forum 2018
Explained the potential application of blockchain technology in a business setting to procurement
executives at an event hosted by AlixPartners.
Case 9:18-cv-80176-BB Document 228-2 Entered on FLSD Docket 06/26/2019 Page 2 of 2
KEVIN MADURA PAGE 2

Center for Professional Education

Managing Cyber Risk 2018
Hosted a session focused on managing cyber risks with emerging technologies such as blockchain
and cryptocurrencies.

Center for Professional Education

Blockchain & Cryptocurrencies 2019
A presentation detailing the inner workings of blockchain technology and how Bitcoin spawned
thousands of alternative cryptocurrencies.

PUBLICATIONS AND PAPERS

CVE-2009-0499
Discovered a computer vulnerability described as a “cross-site request forgery (CSRF) vulnerability in
the Moodle forum software that allows remote attackers to delete or modify data.” 2009

Blockchain 101: What is it?

Online Article 2017

How Cybersecurity Risk is Disrupting the M&A Landscape

AlixPartners 2019

AWARDS
Corporate Scholars Scholarship 2013
IBM Manager’s Choice Award (14) 2016 – 2017
IBM Global Business Services Excellence Award 2017

MEMBERSHIPS
Armed Forces Communications and Electronics Association (Inactive)
EC-Council
Washington DC Cyber Security for Control Systems

TECHNICAL SKILLS
Computer programming languages (C, C#, Go, Java, Bash, Python, Javascript, PHP, Ruby)
Computer systems (Linux, Windows, Mac OS)
Applied cryptography
Blockchain analysis
Secure application coding techniques
Vulnerability detection
Computer network security
System administration

LANGUAGES
English– native language