Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
__________________________________________
SECURITIES AND EXCHANGE
)
COMMISSION,
)
)
Plaintiff,
)
)
v.
)
No. 1:23-cv-)
BINANCE HOLDINGS LIMITED,
)
BAM TRADING SERVICES INC.,
)
BAM MANAGEMENT US HOLDINGS
)
INC., AND CHANGPENG ZHAO,
)
)
Defendants.
)
__________________________________________)
PLAINTIFF’S ERRATA REGARDING ITS MEMORANDUM
OF LAW IN SUPPORT OF ITS EMERGENCY MOTION FOR A TEMPORARY
RESTRAINING ORDER FREEZING ASSETS, GRANTING OTHER RELIEF,
AND ORDER TO SHOW CAUSE WHY RELIEF SHOULD NOT CONTINUE
Plaintiff Securities and Exchange Commission (“SEC”) respectfully submits this Errata
to the SEC’s Memorandum Of Law In Support Of Its Emergency Motion For A Temporary
Restraining Order Freezing Assets, Granting Other Relief, And Order To Show Cause Why
Relief Should Not Continue (“Memorandum”), Dkt. No. 26., reflecting typographical and
citation corrections that were identified during the review and preparation of the index of
exhibits requested by the Court. This Errata contains the following attachments:
•
Attachment A: The Errata to the Memorandum;
•
Attachment B: A corrected version of the Memorandum;
•
Attachment C: A redlined version of the Memorandum reflecting the
corrections; andPage 2 •
Attachment D: An amended version of Exhibit A-83 to the Memorandum that
includes additional pages cited in the Memorandum that were not contained in
the original Exhibit A-83.
The corrected version of the Memorandum should be used as the operative
Memorandum.
Dated: June 8, Washington, D.C.
By:
/s/ Matthew Scarlato
Matthew Scarlato (D.C. Bar No. 484124)
Jennifer L. Farer (D.C. Bar No. 1013915)
J. Emmett Murphy*
U.S. SECURITIES AND EXCHANGE
COMMISSION
100 F Street N.E.
Washington, D.C. Phone:
(202) 551-3749 (Scarlato)
(202) 551-5072 (Farer)
(212) 336-0078 (Murphy)
Emails:
scarlatom@sec.gov
farerj@sec.gov
murphyJoh@sec.gov
Attorneys for the Plaintiff
*Government attorney certification pursuant to
Local Rule 83.2(d) pending
Of Counsel:
Jorge G. Tenreiro
David L. Hirsch
David A. Nasse
Michael Baker
Kathleen Hitchins
Donna Norman
Colby Steele
Martin Zerwitz
SECURITIES AND EXCHANGE
COMMISSION
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-01599-ABJ Document 29 Filed 06/08/23 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
__________________________________________
SECURITIES AND EXCHANGE
)
COMMISSION,
)
)
Plaintiff,
)
)
v.
)
No. 1:23-cv-01599
)
BINANCE HOLDINGS LIMITED,
)
BAM TRADING SERVICES INC.,
)
BAM MANAGEMENT US HOLDINGS
)
INC., AND CHANGPENG ZHAO,
)
)
Defendants.
)
__________________________________________)
PLAINTIFF’S ERRATA REGARDING ITS MEMORANDUM
OF LAW IN SUPPORT OF ITS EMERGENCY MOTION FOR A TEMPORARY
RESTRAINING ORDER FREEZING ASSETS, GRANTING OTHER RELIEF,
AND ORDER TO SHOW CAUSE WHY RELIEF SHOULD NOT CONTINUE
Plaintiff Securities and Exchange Commission (“SEC”) respectfully submits this Errata
to the SEC’s Memorandum Of Law In Support Of Its Emergency Motion For A Temporary
Restraining Order Freezing Assets, Granting Other Relief, And Order To Show Cause Why
Relief Should Not Continue (“Memorandum”), Dkt. No. 26., reflecting typographical and
citation corrections that were identified during the review and preparation of the index of
exhibits requested by the Court. This Errata contains the following attachments:
•
Attachment A: The Errata to the Memorandum;
•
Attachment B: A corrected version of the Memorandum;
•
Attachment C: A redlined version of the Memorandum reflecting the
corrections; and
PDF Page 3
Case 1:23-cv-01599-ABJ Document 29 Filed 06/08/23 Page 2 of 2
•
Attachment D: An amended version of Exhibit A-83 to the Memorandum that
includes additional pages cited in the Memorandum that were not contained in
the original Exhibit A-83.
The corrected version of the Memorandum should be used as the operative
Memorandum.
Dated: June 8, 2023
Washington, D.C.
By:
/s/ Matthew Scarlato
Matthew Scarlato (D.C. Bar No. 484124)
Jennifer L. Farer (D.C. Bar No. 1013915)
J. Emmett Murphy*
U.S. SECURITIES AND EXCHANGE
COMMISSION
100 F Street N.E.
Washington, D.C. 20549
Phone:
(202) 551-3749 (Scarlato)
(202) 551-5072 (Farer)
(212) 336-0078 (Murphy)
Emails:
scarlatom@sec.gov
farerj@sec.gov
murphyJoh@sec.gov
Attorneys for the Plaintiff
*Government attorney certification pursuant to
Local Rule 83.2(d) pending
Of Counsel:
Jorge G. Tenreiro
David L. Hirsch
David A. Nasse
Michael Baker
Kathleen Hitchins
Donna Norman
Colby Steele
Martin Zerwitz
SECURITIES AND EXCHANGE
COMMISSION
2
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