Exhibit D

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Expert Witness Resume of

Donald Ellsworth

Special Agent, IRS-Criminal Investigation

IRS-CI Positions Held Dates

Special Agent, GS-1811-13 May 2005 – current

Special Agent, GS-1811-12 January 2004

Special Agent, GS-1811-11 January 2003

Special Agent, GS-1811-09 January 2002

Relevant Assignments

Undercover agent

Instructor, Bitcoin/Darknet training

Instructor, Money Laundering

OCDETF Case Agent

Darknet Workgroup founding member

Darknet/Bitcoin investigative Experience

As a special agent, I have been the case agent on multiple Darknet and Bitcoin 

related cases. These cases have been multi-jurisdictional and prosecuted in the 

District of Arizona and Washington DC. Darknet and bitcoin related 

investigations are a relatively new type of investigation which required extensive 

research on how to acquire and use bitcoin on the darknet marketplaces. 

As an undercover agent:

• Created multiple profiles on various darknet marketplaces.

• Purchased goods and services from darknet vendors using bitcoin.

• Learned how to use the encrypted communications commonly used 

on the darknet, i.e. Tor, Tails, Jabber, Privnote.

• Learned how to create and utilize bitcoin wallets and open bitcoin 

exchange accounts. 

• Purchased bitcoin from peer-to-peer exchangers.

As a case agent:

• Identified peer-to-peer bitcoin exchanger targets.

• Identified Darknet vendors on multiple marketplaces.

• Traced bitcoin transactions between darknet vendors and bitcoin 

exchangers.

• Testified before a Grand Jury regarding the criminality of peer-topeer exchanging of bitcoin.

• Coordinated with foreign governments to secure evidence related to 

Darknet/Bitcoin investigations. 

As a special agent, I have been the case agent for a variety of multi-jurisdictional 

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IRS-CI co-sponsored OCDETF and narcotics money laundering investigations 

with the targets being darknet vendors using bitcoin. As a founding member of 

the Arizona darknet/bitcoin team, I have conducted long term and short term 

darknet/bitcoin related investigations. 

As a special agent, I have investigated the money laundering aspects of criminals 

using bitcoin. I have had training on U.S. Money Laundering and Bank Secrecy 

laws and how the movement of illegal proceeds in the form of bitcoin applies to 

these laws. 

I have assisted as project coordinator for cyber-crime and underground 

economies for the IRS-CI Phoenix field office. As a cyber-crime project 

coordinator I have developed and investigated multiple cases initiated through 

the project.

Darknet/Bitcoin Training Assignments

As a keynote speaker, I have conducted training for federal, state and local law 

enforcement investigators and prosecutors in the field of Darknet/Bitcoin 

investigation and financial investigative techniques. I have presented to federal 

judges on multiple occasions about the criminality of bitcoin and the darknet. I 

have also traveled to foreign countries and provided training on this subject to 

government officials in those countries. 

Event Date

Office of National Drug Control Policy, White 

House, Washington DC 02/2018

Federal Bar Association w/ Federal Judges 

seminar, Tucson, AZ 02/2018

Brazil Government Officials, Sao Paulo and 

Brasilia, Brazil 11/2017

Arizona Federal Magistrates Conference, 

Scottsdale, AZ 09/2017

AZ Attorney General's office Darknet/Bitcoin 

training, Phoenix,AZ 08/2017

HIDTA Darknet/Bitcoin seminar, Phoenix, AZ 06/2017

Southwest Border Money Laundering Conf, 

Phoenix, AZ 06/2017

New Mexico congressional delegation, 

Albuquerque, NM 03/2017

Royal Canadian Mounted Police, Vancouver, 

Canada 03/2017

In addition to the training I have given above, I have provided training on multiple 

occasions to IRS-CI undercover agents on the mechanics of the darknet and 

purchasing and use of bitcoin. I have also spoken at multiple trainings for smaller 

groups of Federal, State, and local law enforcement officers in the area of 

Darknet/Bitcoin related investigations.

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Awards Date

IRS- CI Performance Award 2017

IRS- CI Performance Award 2016

IRS- CI Performance Award 2015

IRS- CI Performance Award 2014

IRS- CI Performance Award 2013

IRS- CI Performance Award 2012

IRS- CI Performance Award 2011

IRS- CI Performance Award 2010

IRS- CI Performance Award 2009

Education and Training

Internal Revenue Service, Criminal Investigation – over 16 years a special agent

Ongoing training classes on current laws, policies and procedures: Bank Secrecy 

Act Workshops, Money Laundering Seminars, numerous financial investigative 

techniques seminars and conferences.

Darknet/Bitcoin related training:

o DEFCON 2017 – hacking and cyber crime – Las Vegas, NV 

July 31st – August 1st, 2017

o Private bitcoin tracing training – Chainalysis – New York City, NY 

October 20th, 2016

o DEFCON 2016 – hacking, and cyber crime – Las Vegas, NV 

August 4th – 5th, 2016

o IOC-2- Darkweb threat and virtual currency seminar – Washington DC, WA 

January 6th-7th, 2016

o IRS Cybercrime Investigative tools and the Dark Web – Webinar

October 21st, 2015

o Monthly IRS cyber coordinator training – conference calls

Bachelor of Science, Business, Northern Arizona University, 1999 

Masters of Business Administration, Finance, Utah State University, 2001

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