SECURITIES AND EXCHANGE COMMISSION v. BINANCE HOLDINGS LIMITED et al Document 104: stipulation

District Of Columbia District Court
Case No. 1:23-cv-01599-ABJ-ZMF
Filed September 5, 2023

STIPULATION and Proposed Order re Motion for Protective Order and Motion to Compel Briefing Schedule by BAM MANAGEMENT US HOLDINGS INC., BAM TRADING SERVICES INC.. (Canellos, George)

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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.
JOINT STIPULATION AND [PROPOSED] ORDER
WHEREAS, on August 14, 2023, Defendants BAM Trading Services Inc. and BAM
Management US Holdings Inc. (collectively, “BAM”) filed a motion for a protective order (the
“Motion for a Protective Order”).
WHEREAS, on August 28, 2023, Plaintiff Securities and Exchange Commission (“SEC”)
filed an opposition to the Motion for a Protective Order (the “Opposition”) and a motion to compel
and for other relief (the “Motion to Compel”).
WHEREAS, pursuant to Local Civil Rule 7(d) of the United States District Court for the
District of Columbia, BAM’s reply to the Opposition would be due on September 5, 2023, and,
pursuant to Local Civil Rule 7(b) of the United States District Court for the District of Columbia,
BAM’s opposition to the Motion to Compel would be due on September 11, 2023.
WHEREAS, the parties agree that the interest of efficiency and judicial economy would
be served by allowing BAM to file its reply to the Opposition and opposition to the Motion to
Compel as a single memorandum.
Page 2 THEREFORE, IT IS HEREBY STIPULATED AND AGREED that:
1. BAM shall file its reply to the Opposition and opposition to the Motion to Compel as
a single memorandum not to exceed 45 pages on September 11, 2023.
Dated: September 5,
Respectfully submitted,
/s/ David A. Nasse
Matthew Scarlato (D.C. Bar No. 484124)
Jennifer L. Farer (D.C. Bar No. 1013915)
J. Emmett Murphy
David A. Nasse (D.C. Bar No. 1002567)
Jorge G. Tenreiro
SECURITIES AND EXCHANGE
COMMISSION
scalatom@sec.gov
farerj@sec.gov
murphyJoh@sec.gov
nassed@sec.gov
tenreiroj@sec.gov
/s/ William R. McLucas
William R. McLucas (pro hac vice)
Matthew T. Martens (D.C. Bar #1019099)
Matthew Beville (pro hac vice)
WILMER CUTLER PICKERING HALE AND
DORR LLP
2100 Pennsylvania Avenue NW
Washington, DC William.McLucas@wilmerhale.com
Matthew.Beville@wilmerhale.com
Matthew.Martens@wilmerhale.com
Attorneys for Plaintiff
Tiffany J. Smith (pro hac vice)
WILMER CUTLER PICKERING HALE AND
DORR LLP
7 World Trade Center
250 Greenwich Street
New York, NY Tiffany.Smith@wilmerhale.com
/s/ George S. Canellos
George S. Canellos (pro hac vice)
Matthew J. Laroche (pro hac vice)
MILBANK LLP
55 Hudson Yards
New York, NY GCanellos@milbank.com
MLaroche@milbank.com
SO ORDERED:
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management Holdings
US Inc.
HON. AMY BERMAN JACKSON
UNITED STATES DISTRICT JUDGE
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