The legal firm representing Ira Kleiman, the brother of Dave Kleiman has today submitted an updated complaint in relation to the lawsuit against Craig Wright, who once claimed to be Satoshi Nakamoto, the unknown creator of Bitcoin.

The accusation of perjury is raised in response to Craig’s filed motion to dismiss the case, where he alleges he has “essentially no connection to Florida or W&K Info Defense Research LLC”, the joint venture between Craig and Dave created to mine Bitcoin.

It is noted that “Craig supported these assertions with a sworn declaration stating he was never a shareholder, member, agent, employee, or representative of W&K. He swore, under penalty of perjury under the laws of the United States, that he’s never exercised authority or control over W&K.”

It has come to light that Craig previously “submitted an affidavit to the Supreme Court of New South Wales where Craig affirmed that:

The shareholding of ‘W&K Info Defense LLC’ was:

1. Craig S. Wright 50.0%

2. David A. Kleiman 50.0%”

The above, clearly contradicting his sworn declaration in his motion filed to dismiss the case.

The amended complaint claims “Craig’s boldfaced misrepresentations and perjury before this Court constitute a continuation of his grand fraud to unlawfully take Plaintiff’s assets. Said differently, Craig’s latest fraud on this Florida court is simply one more action he’s taken in Florida to defraud Dave Kleiman’s estate and W&K.”

The full details of the perjury accusation in the amended complaint are as follows:

160. In Ira’s initial Complaint, as in this one, he alleged that (i) Craig and Dave

held some form of interests in a Florida LLC called W&K, that (ii) through this LLC, and otherwise, they mined over 1.1 million bitcoins and developed extremely valuable intellectual property, that (iii) after Dave died, Craig took unlawful possession of all the bitcoins the Florida LLC mined and intellectual property it created (along with the bitcoin and intellectual property they mined/developed together personally), that (iv) Craig then tried to “launder” this stolen intellectual property by defrauding the Australian courts into entering consent orders transferring clean title over W&K’s intellectual property to Craig;

and that (v) Craig needs to return the stolen property. 161. In response to this Complaint, Craig filed a motion to dismiss alleging he has essentially no connection to Florida or W&K. His motion stated Plaintiff’s jurisdictional allegations were “frivolous” and “sanctionable.” (ECF D.E. 12 at 36). Craig supported these assertions with a sworn declaration stating he was never a shareholder, member, agent, employee, or representative of W&K. (Ex. 29 ¶¶ 11–12). He swore, under penalty of perjury under the laws of the United States, that he’s never exercised authority or control over W&K. (Id. ¶ 13). 162. He perjured himself. 163. To procure his fraudulent Australian judgments, Craig submitted an affidavit to the Supreme Court of New South Wales where Craig affirmed that:

i. Craig S. Wright 50.0%

ii. David A. Kleiman 50.0%”

(Ex. 4 at 5). 164. Craig then doubled down on this ownership structure affirming further that

“W&K Info Defense LLC was an incorporated partnership. All shares are held jointly.” (Id.). He then affirmed that he called a “shareholders meeting” on August 16, 2013 at which only he and Jamie Wilson were present. (Id.). Craig affirmed he was the sole vote that nominated Jamie Wilson to act as a director “for purposes of consenting to orders and the company to be wound down.” (Id. at 5).27 165. These affidavit statements directly contradict his sworn statements to this

Court that (i) “I have never been a . . . shareholder . . . of W&K,” (ii) “I have never been a member of W&K,” and (iii) “I have never exercised authority or control over W&K . . .” (Ex. 29 ¶¶ 11–13). 166. But the perjury doesn’t end there. 167. Craig attached voluminous records to his Australian affidavit. These attachments evidence Craig signed as the “authorized representative” of W&K six (6) times (Ex. 4 at 56, 63, 70, 76, 83, 90), identified himself as W&K’s “lead researcher” twice (id. at 45–46), its “technical contact” six (6) times (id. 50, 57, 64, 71, 77, 84), affiliates himself with W&K’s Florida address as, e.g., his “mailing address” twelve (12) times (id. at 49, 56–57, 63–64, 70–71, 76–77, 83–84, 90), includes detailed descriptions of the computer programs and research Craig was attempting to get DHS to fund (id. at 50–94), and includes four (4) emails from DHS confirming Craig had uploaded various proposals on behalf of W&K attempting to secure funding (Id. at 40–43). Collectively, these documents clearly evidence Craig’s participation in operating W&K from Florida to solicit business from the United States DHS. 168. Obviously, these affidavit attachments are in direct conflict with Craig’s

sworn statements to this Court that (i) “I have never been a . . . employee, or representative of W&K,” (ii) “I have never been an agent of W&K,” (iii) “I have never . . . developed software for any purpose relating to a Florida business, including W&K,” (iv) “I have never advertised services in Florida,” (v) “I have never had an office in Florida,” and (vi) “I have never exercised authority or control over W&K . . .” (Ex. 29 ¶¶ 6, 8, 11- 13, 15). 169. As mentioned in ¶ 120, Craig also filed submitted two “Acknowledgment of

Liquidated Claim” filings in Australia where he signed as the “legal agent and representative” of W&K and as its “Director/ Australian Agent.” (Ex. 30). As set forth in ¶¶ 138–139 he also acted as the “director” of W&K when he had his agent put Coin-Exch, his company, as its director. These also directly conflict with his sworn testimony above. 170. Craig’s boldfaced misrepresentations and perjury before this Court constitute a continuation of his grand fraud to unlawfully take Plaintiffs’ assets. Said differently, Craig’s latest fraud on this Florida Court is simply one more action he’s taken in Florida to defraud Dave’s estate and W&K.

Exhibits 4 and 29 are available to view below: