MOTION for Order Directing Counsel for Plaintiff to Comply with Applicable Rules of Conduct by BAM MANAGEMENT US HOLDINGS INC., BAM TRADING SERVICES INC.. (Attachments: # (1) Declaration of Adam J. Fee, # (2) Exhibit 1 - Transcript, # (3) Exhibit 2 - SEC Press Release, # (4) Text of Proposed Order)(Canellos, George)
Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
Civil Action No. 1-23-cv-01599-ABJ
BINANCE HOLDINGS LIMITED, BAM
TRADING SERVICES INC., BAM
MANAGEMENT US HOLDINGS INC., AND
CHANGPENG ZHAO,
Defendants.
DECLARATION OF ADAM J. FEE
Adam J. Fee, pursuant to 28 U.S.C. § 1746, declares as follows:
1.
I am a member of the law firm Milbank LLP, counsel to Defendants BAM Trading
Services Inc. (“BAM Trading”) and BAM Management US Holdings Inc. (collectively with
BAM Trading, “BAM”). I submit this declaration in support of Defendants BAM, Binance
Holdings Limited, and Changpeng Zhao’s Motion for an Order Directing Counsel for Plaintiff
Securities and Exchange Commission to Comply with Applicable Rules of Conduct.
2.
I have personal knowledge of the matters set forth in this declaration, and, if called
as a witness, I could and would competently testify under oath to the facts stated herein.
3.
Attached as Exhibit 1 is a true and correct copy of a press release titled, “SEC
Secures Emergency Relief to Protect Binance.US Customers’ Assets,” issued by the SEC on June
17, 2023.
4.
Attached as Exhibit 2 is a true and correct copy of the transcript of the hearing held
before Judge Amy Berman Jackson on June 13, 2023 in the above-referenced matter.Page 2
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Case 1:23-cv-01599-ABJ Document 74-1 Filed 06/21/23 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
Civil Action No. 1-23-cv-01599-ABJ
BINANCE HOLDINGS LIMITED, BAM
TRADING SERVICES INC., BAM
MANAGEMENT US HOLDINGS INC., AND
CHANGPENG ZHAO,
Defendants.
DECLARATION OF ADAM J. FEE
Adam J. Fee, pursuant to 28 U.S.C. § 1746, declares as follows:
1.
I am a member of the law firm Milbank LLP, counsel to Defendants BAM Trading
Services Inc. (“BAM Trading”) and BAM Management US Holdings Inc. (collectively with
BAM Trading, “BAM”). I submit this declaration in support of Defendants BAM, Binance
Holdings Limited, and Changpeng Zhao’s Motion for an Order Directing Counsel for Plaintiff
Securities and Exchange Commission to Comply with Applicable Rules of Conduct.
2.
I have personal knowledge of the matters set forth in this declaration, and, if called
as a witness, I could and would competently testify under oath to the facts stated herein.
3.
Attached as Exhibit 1 is a true and correct copy of a press release titled, “SEC
Secures Emergency Relief to Protect Binance.US Customers’ Assets,” issued by the SEC on June
17, 2023.
4.
Attached as Exhibit 2 is a true and correct copy of the transcript of the hearing held
before Judge Amy Berman Jackson on June 13, 2023 in the above-referenced matter.
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Case 1:23-cv-01599-ABJ Document 74-1 Filed 06/21/23 Page 2 of 2
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