NOTICE of Filing Index Exhibits by SECURITIES AND EXCHANGE COMMISSION re [26] Memorandum (Attachments: # (1) Attachment A - Memorandum Exhibit Index)(Scarlato, Matthew)
Page 1 INDEX OF EXHIBITS TO PLAINTIFF’ MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR EMERGENCY RELIEF (Dkt. No. 26)
EX. NO. DESCRIPTION
A
Declaration of Colby Steele dated June 6, A-
Binance Holdings Limited, Certificate of Incumbency dated February 12,
A-
Webcapture created on June 5, 2023 of Binance blog entitled “From Burgers to Bitcoin: How
CZ Built a Leading Crypto Exchange in Just 180 Days,” dated November 24, 2020.
A-
Webcapture created on June 5, 2023 of the Binance website page entitled “Binance Country
Selector”
A-
BAM Trading Services Inc. Organizational Chart (BTS00462320)
A-
Webcapture created on June 5, 2023 of a Binance blog entitled “Binance.US Launches in
Two New U.S. Territories,” dated December 5, 2022.
A-
BAM Management US Holdings Inc. Organizational Chart dated February 27,
A-
Letter from counsel for BAM Trading dated February 1, 2023 (BTS00831965)
A-
Fintech Certification of Beneficial Ownership (SEC-SGB-E-00222398)
A-
Binance Holdings Organizational and Beneficial Ownership Chart (BHL-SECBUSD00000001-2)
A-
Webcapture of a Binance website entitled “What is BNB?.”
A-
BNB Whitepaper dated June 16, 2017 (BHL-SEC-BUSD-0000003)
A-
Webcapture a Binance website entitled “The Binance.com ICO Experience, Lessons and
Advice.”
A-
Webcapture of a Binance website entitled “14th BNB Burn – Quarterly Highlights and
Insights from CZ.”
A-
Webcapture of a Binance website entitled “How to Use BNB to Pay for Fees and Earn 25%
Discount.”
A-
Webcapture of a Reddit “ask me anything” event.
A-
Webcapture of a Binance website entitled “BNB Price Prediction.”
A-
Webcapture of a Binance entitled “Binance Labs to Invest in 7 Projects From the MVB
Accelerator Program Co-led by BNB Chain.”
A-
Webcapture of a Coincodex webpage entitled “Binance Coin (BNB) Exchanges.”
A-
Offer of Employment dated May 8, 2019 (CC000333412)
A-
“Binance First Year in Review” dated July 19, 2018 (BHL-SEC-BUSD-0002022)
A-
Binance Chat Messages dated June 7, 2019 (BHL-SEC_BUSD-0054597)
A-
August 2019 Binance Financial Reporting Package (BHL-BUSD-SEC-0214986)
A-
Webcapture of the Binance.com website
A-
Webcapture of a Binance website entitled “FAQ” Page 2 INDEX OF EXHIBITS TO PLAINTIFF’ MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR EMERGENCY RELIEF (Dkt. No. 26)
A-
Webcapture of a May 8, 2019 “AMA” with Changpeng Zhao.
A-
Binance chat messages dated December 31, 2020 with Mandarin to English translations
(BHL-SEC-BUSD-0311735)
A-
Internal Binance chat dated June 8, 2019 (BHL-SEC-BUSD-0054606)
A-
Spreadsheet excerpt entitled “BAM Market Makers” (BTS000005523)
A-
Document entitled “Group Structure” (BHL-SEC-BUSD-0289617)
A-
Webcapture of a Binance website entitled “Binance Beginners Guide.”
A-
Webcapture of a Binance webpage entitled “How and why assets move between Binance
wallets.”
A-
Webcapture of a Binance website entitled “How to withdraw fiat currency from Binance via
Advcash.”
A-
Webcapture SEC staff of a Binance website entitled “Centralized crypto exchanges recorded
$14 trillion in trading volume this year.”
A-
“Binance US Entry: Risks and Strategies” (BHL-SEC-BUSD-0235533)
A-
“Binance US Entry: Proposed Implementation” (BHL-SEC-BUSD-0235541)
A-
Binance chat messages dated October 18, 2018 (BHL-SEC-BUSD-0036086)
A-
Excerpt from an internal Binance chat dated December 24, 2018 (BHL-SEC-BUSD-0036504)
A-
Certified translation of a June 25, 2019 recording (BHL-SEC-BUSD-0235662)
A-
Binance chat messages dated July 15, 2020, (BHL-SEC-BUSD-0235733)
A-
Binance chat messages dated October 7, 2020 (BHL-SEC-BUSD-0391007)
A-
Binance chat messages dated June 14, 2019 (CC000406022)
A-
BAM Trading Services Inc. Organizational Chart (BTS00462320)
A-
Webcapture of a Binance webpage titled “BAM Platform Trading Rules.”
A-
Chat messages dated July 29, 2019 (CC000407016)
A-
Chat messages dated July 24, 2009 (CC000407003)
A-
“Master Service Agreement” dated January 7, 2020 (BTS00039026)
A-
“Software License Agreement” dated January 7, 2020 (BTS00039043)
A-
“Binance.US Terms of Use” (BTS00831451)
A-
Letter from counsel for BAM Trading to Kathleen Hitchins dated June 11, (BTS00033433)
A-
Accounts Spreadsheet (SEC-Primetrust-E-0013680)
A-
Letter from counsel for BAM Trading to Kathleen Hitchins dated July 9, (BTS00042025) Page 3 INDEX OF EXHIBITS TO PLAINTIFF’ MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR EMERGENCY RELIEF (Dkt. No. 26)
A-
“BAM Trading Services Inc. Financial Statements and Independent Auditor’s Report” dated
December 31, 2022 (BTS00833798)
A-
“Binance.US Seed Round Pitch Deck” (BTS00833689)
A-
Chat messages dated August 29, 2019 (CC000272028)
A-
Chat messages dated May 29, 2020 (CC000391390)
A-
Spreadsheet entitled “BAM Market Makers” Excerpt
A-
“Binance.US Institutional Onboarding Application” for Merit Peak (BHL-SEC-BUSD0221710)
A-
“Binance.US Institutional Onboarding Application” for Sigma Chain (SEC-PrimeTrust-E0011951)
A-
Letter to from counsel for BAM Trading Services Inc. to Kathleen Hitchens dated January 27,
2023 (BTS00831945)
A-
“BAM Management US Holdings Inc. Shareholder Resolution to Appoint Directors dated
November 25, 2019 (BTS00044531)
A-
“BAM Trading Services Inc. Shareholder Resolution to Appoint Directors dated November
25, 2019 (BTS00044533)
A-
Document dated January 6, 2020 (CC000270182)
A-
Chat messages dated October 13, 2020 (CC00650405)
A-
Chat messages dated November 7, 2019 (CC000274048)
A-
BAM Trading Services Inc. Balance Sheet as of December 31, 2019 (BTS00509917)
A-
Chat messages dated December 24, 2020 (CC000289050)
A-
PrimeTrust Account Spreadsheet (SEC-Primetrust-E-0013680)
A-
Letter from counsel for BAM Trading to Jorge Tenreiro dated May 26,
A-
Letter from counsel for BAM Trading to Jennifer Farer dated June 2,
A-
“Wallet Custody Agreement” dated January 7, 2020 (BHL-SEC-BUSD-0203506)
A-
Letter from BAM Trading to Binance Holdings dated March 9, 2020 (BTS00530989)
A-
Letter from BAM Trading to Armanino LLP dated March 31,
A-
Letter and May 6, 2022, report to BAM Management US Holdings Inc. from Armanino LLP
dated May 20, 2022 (Armanino-BAM-000149)
A-
“BAM Trading Services Financial Statements and Independent Auditor’s Report” dated
December 31, 2022 (BTS00833798)
A-
“BAM Management US Holdings Inc. Consolidated Financial Statements dated December
31, 2019 (BTS00031479) Page 4 INDEX OF EXHIBITS TO PLAINTIFF’ MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR EMERGENCY RELIEF (Dkt. No. 26)
A-
“BAM Management US Holdings Inc.” Communication with Those Charged with
Governance” dated December 31, 2021 (Armanino-BAM-000136)
A-
Wells Submission of Binance Holdings dated March 15,
A-
Letter to from counsel for Binance Holding and Zhao to Jorge Tenreiro dated June 4,
A-
E-mail from Jorge Tenreiro to counsel for BAM Trading Services Inc. dated May 24,
A-
Letter from Jennifer Farer to counsel for BAM Trading dated May 30,
A-
Letter from counsel for BAM Trading to Jennifer Farer dated June 1,
A-
Chart of Key Shard Voting Record – May 2023 to June 2, 2023 (BTS00833858)
A-
Excerpt of transcript of SEC testimony of Brian Brooks on December 13, 2021 (AMENDED)
A-
“Binance.US Digital Asset & Custody Operations Policy” dated May 15, (BTS000833836)
A-
Letter from counsel for Binance Holdings Limited to Jennifer Farer dated June 1,
A-
Excerpt of transcript of SEC testimony of Catherine Coley on January 27,
A-
Excerpt of transcript of SEC testimony of Jamie Hinz on September 10,
A-
“BAM Management US Holdings Inc. Communication of Significant Deficiencies and
Material Weaknesses in Internal Controls and Other Matters” dated December 31, (Armanino-BAM-000057)
A-
“BAM Management US Holdings Inc. Communication of Significant Deficiencies and
Material Weaknesses in Internal Controls and Other Matters” dated December 31, Armanino-BAM-
B
Declaration of Sachin Verma with attachments dated June 5,
C
Second Declaration of Sachin Verma with attachments dated June 5,
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-01599-ABJ Document 27-1 Filed 06/08/23 Page 1 of 4
INDEX OF EXHIBITS TO PLAINTIFF’ MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR EMERGENCY RELIEF (Dkt. No. 26)
EX. NO. DESCRIPTION
A
Declaration of Colby Steele dated June 6, 2023
A-1
Binance Holdings Limited, Certificate of Incumbency dated February 12, 2020
A-2
Webcapture created on June 5, 2023 of Binance blog entitled “From Burgers to Bitcoin: How
CZ Built a Leading Crypto Exchange in Just 180 Days,” dated November 24, 2020.
A-3
Webcapture created on June 5, 2023 of the Binance website page entitled “Binance Country
Selector”
A-4
BAM Trading Services Inc. Organizational Chart (BTS00462320)
A-5
Webcapture created on June 5, 2023 of a Binance blog entitled “Binance.US Launches in
Two New U.S. Territories,” dated December 5, 2022.
A-6
BAM Management US Holdings Inc. Organizational Chart dated February 27, 2019
A-7
Letter from counsel for BAM Trading dated February 1, 2023 (BTS00831965)
A-8
Fintech Certification of Beneficial Ownership (SEC-SGB-E-00222398)
A-9
Binance Holdings Organizational and Beneficial Ownership Chart (BHL-SECBUSD00000001-2)
A-10
Webcapture of a Binance website entitled “What is BNB?.”
A-11
BNB Whitepaper dated June 16, 2017 (BHL-SEC-BUSD-0000003)
A-12
Webcapture a Binance website entitled “The Binance.com ICO Experience, Lessons and
Advice.”
A-13
Webcapture of a Binance website entitled “14th BNB Burn – Quarterly Highlights and
Insights from CZ.”
A-14
Webcapture of a Binance website entitled “How to Use BNB to Pay for Fees and Earn 25%
Discount.”
A-15
Webcapture of a Reddit “ask me anything” event.
A-16
Webcapture of a Binance website entitled “BNB Price Prediction.”
A-17
Webcapture of a Binance entitled “Binance Labs to Invest in 7 Projects From the MVB
Accelerator Program Co-led by BNB Chain.”
A-18
Webcapture of a Coincodex webpage entitled “Binance Coin (BNB) Exchanges.”
A-19
Offer of Employment dated May 8, 2019 (CC000333412)
A-20
“Binance First Year in Review” dated July 19, 2018 (BHL-SEC-BUSD-0002022)
A-21
Binance Chat Messages dated June 7, 2019 (BHL-SEC_BUSD-0054597)
A-22
August 2019 Binance Financial Reporting Package (BHL-BUSD-SEC-0214986)
A-23
Webcapture of the Binance.com website
A-24
Webcapture of a Binance website entitled “FAQ”
1
PDF Page 3
Case 1:23-cv-01599-ABJ Document 27-1 Filed 06/08/23 Page 2 of 4
INDEX OF EXHIBITS TO PLAINTIFF’ MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR EMERGENCY RELIEF (Dkt. No. 26)
A-25
Webcapture of a May 8, 2019 “AMA” with Changpeng Zhao.
A-26
Binance chat messages dated December 31, 2020 with Mandarin to English translations
(BHL-SEC-BUSD-0311735)
A-27
Internal Binance chat dated June 8, 2019 (BHL-SEC-BUSD-0054606)
A-28
Spreadsheet excerpt entitled “BAM Market Makers” (BTS000005523)
A-29
Document entitled “Group Structure” (BHL-SEC-BUSD-0289617)
A-30
Webcapture of a Binance website entitled “Binance Beginners Guide.”
A-31
Webcapture of a Binance webpage entitled “How and why assets move between Binance
wallets.”
A-32
Webcapture of a Binance website entitled “How to withdraw fiat currency from Binance via
Advcash.”
A-33
Webcapture SEC staff of a Binance website entitled “Centralized crypto exchanges recorded
$14 trillion in trading volume this year.”
A-34
“Binance US Entry: Risks and Strategies” (BHL-SEC-BUSD-0235533)
A-35
“Binance US Entry: Proposed Implementation” (BHL-SEC-BUSD-0235541)
A-36
Binance chat messages dated October 18, 2018 (BHL-SEC-BUSD-0036086)
A-37
Excerpt from an internal Binance chat dated December 24, 2018 (BHL-SEC-BUSD-0036504)
A-38
Certified translation of a June 25, 2019 recording (BHL-SEC-BUSD-0235662)
A-39
Binance chat messages dated July 15, 2020, (BHL-SEC-BUSD-0235733)
A-40
Binance chat messages dated October 7, 2020 (BHL-SEC-BUSD-0391007)
A-41
Binance chat messages dated June 14, 2019 (CC000406022)
A-42
BAM Trading Services Inc. Organizational Chart (BTS00462320)
A-43
Webcapture of a Binance webpage titled “BAM Platform Trading Rules.”
A-44
Chat messages dated July 29, 2019 (CC000407016)
A-45
Chat messages dated July 24, 2009 (CC000407003)
A-46
“Master Service Agreement” dated January 7, 2020 (BTS00039026)
A-47
“Software License Agreement” dated January 7, 2020 (BTS00039043)
A-48
“Binance.US Terms of Use” (BTS00831451)
A-49
Letter from counsel for BAM Trading to Kathleen Hitchins dated June 11, 2021
(BTS00033433)
A-50
Accounts Spreadsheet (SEC-Primetrust-E-0013680)
A-51
Letter from counsel for BAM Trading to Kathleen Hitchins dated July 9, 2021
(BTS00042025)
2
PDF Page 4
Case 1:23-cv-01599-ABJ Document 27-1 Filed 06/08/23 Page 3 of 4
INDEX OF EXHIBITS TO PLAINTIFF’ MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR EMERGENCY RELIEF (Dkt. No. 26)
A-52
“BAM Trading Services Inc. Financial Statements and Independent Auditor’s Report” dated
December 31, 2022 (BTS00833798)
A-53
“Binance.US Seed Round Pitch Deck” (BTS00833689)
A-54
Chat messages dated August 29, 2019 (CC000272028)
A-55
Chat messages dated May 29, 2020 (CC000391390)
A-56
Spreadsheet entitled “BAM Market Makers” Excerpt
A-57
“Binance.US Institutional Onboarding Application” for Merit Peak (BHL-SEC-BUSD0221710)
A-58
“Binance.US Institutional Onboarding Application” for Sigma Chain (SEC-PrimeTrust-E0011951)
A-59
Letter to from counsel for BAM Trading Services Inc. to Kathleen Hitchens dated January 27,
2023 (BTS00831945)
A-60
“BAM Management US Holdings Inc. Shareholder Resolution to Appoint Directors dated
November 25, 2019 (BTS00044531)
A-61
“BAM Trading Services Inc. Shareholder Resolution to Appoint Directors dated November
25, 2019 (BTS00044533)
A-62
Document dated January 6, 2020 (CC000270182)
A-63
Chat messages dated October 13, 2020 (CC00650405)
A-64
Chat messages dated November 7, 2019 (CC000274048)
A-65
BAM Trading Services Inc. Balance Sheet as of December 31, 2019 (BTS00509917)
A-66
Chat messages dated December 24, 2020 (CC000289050)
A-67
PrimeTrust Account Spreadsheet (SEC-Primetrust-E-0013680)
A-68
Letter from counsel for BAM Trading to Jorge Tenreiro dated May 26, 2023
A-69
Letter from counsel for BAM Trading to Jennifer Farer dated June 2, 2023
A-70
“Wallet Custody Agreement” dated January 7, 2020 (BHL-SEC-BUSD-0203506)
A-71
Letter from BAM Trading to Binance Holdings dated March 9, 2020 (BTS00530989)
A-72
Letter from BAM Trading to Armanino LLP dated March 31, 2021
A-73
Letter and May 6, 2022, report to BAM Management US Holdings Inc. from Armanino LLP
dated May 20, 2022 (Armanino-BAM-000149)
A-74
“BAM Trading Services Financial Statements and Independent Auditor’s Report” dated
December 31, 2022 (BTS00833798)
A-75
“BAM Management US Holdings Inc. Consolidated Financial Statements dated December
31, 2019 (BTS00031479)
3
PDF Page 5
Case 1:23-cv-01599-ABJ Document 27-1 Filed 06/08/23 Page 4 of 4
INDEX OF EXHIBITS TO PLAINTIFF’ MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR EMERGENCY RELIEF (Dkt. No. 26)
A-76
“BAM Management US Holdings Inc.” Communication with Those Charged with
Governance” dated December 31, 2021 (Armanino-BAM-000136)
A-77
Wells Submission of Binance Holdings dated March 15, 2023
A-78
Letter to from counsel for Binance Holding and Zhao to Jorge Tenreiro dated June 4, 2023
A-79
E-mail from Jorge Tenreiro to counsel for BAM Trading Services Inc. dated May 24, 2023
A-80
Letter from Jennifer Farer to counsel for BAM Trading dated May 30, 2023
A-81
Letter from counsel for BAM Trading to Jennifer Farer dated June 1, 2023
A-82
Chart of Key Shard Voting Record – May 2023 to June 2, 2023 (BTS00833858)
A-83
Excerpt of transcript of SEC testimony of Brian Brooks on December 13, 2021 (AMENDED)
A-84
“Binance.US Digital Asset & Custody Operations Policy” dated May 15, 2023
(BTS000833836)
A-85
Letter from counsel for Binance Holdings Limited to Jennifer Farer dated June 1, 2023
A-86
Excerpt of transcript of SEC testimony of Catherine Coley on January 27, 2022
A-87
Excerpt of transcript of SEC testimony of Jamie Hinz on September 10, 2021
A-88
“BAM Management US Holdings Inc. Communication of Significant Deficiencies and
Material Weaknesses in Internal Controls and Other Matters” dated December 31, 2019
(Armanino-BAM-000057)
A-89
“BAM Management US Holdings Inc. Communication of Significant Deficiencies and
Material Weaknesses in Internal Controls and Other Matters” dated December 31, 2021
Armanino-BAM-000131
B
Declaration of Sachin Verma with attachments dated June 5, 2016
C
Second Declaration of Sachin Verma with attachments dated June 5, 2016
4
Back to 
