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.
No. 1:23-cv-01599 (ABJ)
BINANCE HOLDINGS LIMITED,
BAM TRADING SERVICES INC.,
BAM MANAGEMENT US HOLDINGS, INC.,
AND CHANGPENG ZHAO,
Defendants.
[PROPOSED] ORDER
Plaintiff Securities and Exchange Commission is directed to comply with all applicable
rules of conduct concerning extrajudicial statements, including Rule 3.6 of the District of
Columbia Rules of Professional Conduct.
SO ORDERED.
Dated this ____ day of _________,
HON. AMY BERMAN JACKSON
UNITED STATES DISTRICT JUDGEPage 2 SERVE:
Jorge G. Tenreiro, Esq.
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. Counsel for the Plaintiff
William McLucas, Esq.
Wilmer Cutler Pickering Hale and Dorr LLP
2100 Pennsylvania Avenue NW
Washington, D.C. George Canellos, Esq.
Milbank LLP
55 Hudson Yards
New York, NY Counsel for BAM Trading Services Inc. and
BAM Management US Holdings Inc.
Richard Grime, Esq.
Gibson, Dunn & Crutcher LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. Counsel for Binance Holdings Limited
Douglas Yatter, Esq.
Latham & Watkins LLP
1271 Avenue of the Americas
New York, NY Counsel for Changpeng Zhao
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Case 1:23-cv-01599-ABJ Document 74-4 Filed 06/21/23 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
No. 1:23-cv-01599 (ABJ)
BINANCE HOLDINGS LIMITED,
BAM TRADING SERVICES INC.,
BAM MANAGEMENT US HOLDINGS, INC.,
AND CHANGPENG ZHAO,
Defendants.
[PROPOSED] ORDER
Plaintiff Securities and Exchange Commission is directed to comply with all applicable
rules of conduct concerning extrajudicial statements, including Rule 3.6 of the District of
Columbia Rules of Professional Conduct.
SO ORDERED.
Dated this ____ day of _________, 2023
HON. AMY BERMAN JACKSON
UNITED STATES DISTRICT JUDGE
PDF Page 3
Case 1:23-cv-01599-ABJ Document 74-4 Filed 06/21/23 Page 2 of 2
SERVE:
Jorge G. Tenreiro, Esq.
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Counsel for the Plaintiff
William McLucas, Esq.
Wilmer Cutler Pickering Hale and Dorr LLP
2100 Pennsylvania Avenue NW
Washington, D.C. 20037
George Canellos, Esq.
Milbank LLP
55 Hudson Yards
New York, NY 10001
Counsel for BAM Trading Services Inc. and
BAM Management US Holdings Inc.
Richard Grime, Esq.
Gibson, Dunn & Crutcher LLP
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036
Counsel for Binance Holdings Limited
Douglas Yatter, Esq.
Latham & Watkins LLP
1271 Avenue of the Americas
New York, NY 10020
Counsel for Changpeng Zhao
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