Unopposed MOTION to Continue Status Conference Set for October 12, 2023 by BAM MANAGEMENT US HOLDINGS INC., BAM TRADING SERVICES INC.. (Attachments: # (1) Text of Proposed Order)(McLucas, William)
Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
BINANCE HOLDINGS LIMITED,
BAM TRADING SERVICES INC.,
BAM MANAGEMENT US HOLDINGS INC.,
AND CHANGPENG ZHAO,
No. 1:23-cv-01599-ABJ-ZMF
Defendants.
UNOPPOSED MOTION FOR CONTINUANCE
Pursuant to Federal Rule of Civil Procedure 6(b) and LCvR 16.1(b), BAM Trading Service,
Inc. (“BAM Trading”) and BAM Management US Holdings Inc. (“BAM Management,” together
with BAM Trading, “BAM”), by and through BAM’s undersigned counsel, hereby respectfully
moves for a continuance until October 13, 2023 for the Court to hold a status conference, which is
currently set for October 12, 2023. In support of this Motion, BAM states as follows:
1.
On September 18, 2023, the Court held a discovery hearing. At that hearing, the
Court notified the parties that it was available on either October 12, 2023, or October 13, 2023,
and ordered that the parties to appear for a status conference on October 12, 2023, at 10:30 AM.
2.
On September 25, 2023, counsel for BAM became aware of a scheduling conflict
that would make it difficult for key members of BAM’s legal team to attend the conference on
October 12, 2023. Counsel for BAM would be available to attend the conference on the next day,
October 13, 2023.
3.
In accordance with LCvR 16.1(b), counsel for BAM promptly notified counsel for
the Securities and Exchange Commission (“SEC”) as soon as it became aware of the schedulingPage 2 conflict, and notified counsel for the SEC that it intended to file the instant Motion. The SEC does
not object to the requested adjournment of the conference to October 13, 2023.
4.
The requested continuance is made in good faith, and will not cause any delay or
prejudice. Furthermore, good cause exists for the requested continuance until October 13, 2023,
because the continuance would resolve the scheduling conflicts described above.
Accordingly, for good cause shown, BAM respectfully requests that this Honorable Court
grant this unopposed Motion, and continue the scheduling conference currently scheduled for
October 12, 2023, to October 13, 2023.
Dated: September 26,
Respectfully submitted,
/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
/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
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management Holdings
US Inc.
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
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management
Holdings US Inc.
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Case 1:23-cv-01599-ABJ-ZMF Document 121 Filed 09/26/23 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
BINANCE HOLDINGS LIMITED,
BAM TRADING SERVICES INC.,
BAM MANAGEMENT US HOLDINGS INC.,
AND CHANGPENG ZHAO,
No. 1:23-cv-01599-ABJ-ZMF
Defendants.
UNOPPOSED MOTION FOR CONTINUANCE
Pursuant to Federal Rule of Civil Procedure 6(b) and LCvR 16.1(b), BAM Trading Service,
Inc. (“BAM Trading”) and BAM Management US Holdings Inc. (“BAM Management,” together
with BAM Trading, “BAM”), by and through BAM’s undersigned counsel, hereby respectfully
moves for a continuance until October 13, 2023 for the Court to hold a status conference, which is
currently set for October 12, 2023. In support of this Motion, BAM states as follows:
1.
On September 18, 2023, the Court held a discovery hearing. At that hearing, the
Court notified the parties that it was available on either October 12, 2023, or October 13, 2023,
and ordered that the parties to appear for a status conference on October 12, 2023, at 10:30 AM.
2.
On September 25, 2023, counsel for BAM became aware of a scheduling conflict
that would make it difficult for key members of BAM’s legal team to attend the conference on
October 12, 2023. Counsel for BAM would be available to attend the conference on the next day,
October 13, 2023.
3.
In accordance with LCvR 16.1(b), counsel for BAM promptly notified counsel for
the Securities and Exchange Commission (“SEC”) as soon as it became aware of the scheduling
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Case 1:23-cv-01599-ABJ-ZMF Document 121 Filed 09/26/23 Page 2 of 2
conflict, and notified counsel for the SEC that it intended to file the instant Motion. The SEC does
not object to the requested adjournment of the conference to October 13, 2023.
4.
The requested continuance is made in good faith, and will not cause any delay or
prejudice. Furthermore, good cause exists for the requested continuance until October 13, 2023,
because the continuance would resolve the scheduling conflicts described above.
Accordingly, for good cause shown, BAM respectfully requests that this Honorable Court
grant this unopposed Motion, and continue the scheduling conference currently scheduled for
October 12, 2023, to October 13, 2023.
Dated: September 26, 2023
Respectfully submitted,
/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 20037
William.McLucas@wilmerhale.com
Matthew.Beville@wilmerhale.com
Matthew.Martens@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 10001
GCanellos@milbank.com
MLaroche@milbank.com
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management Holdings
US Inc.
Tiffany J. Smith (pro hac vice)
WILMER CUTLER PICKERING HALE
AND DORR LLP
7 World Trade Center
250 Greenwich Street
New York, NY 10007
Tiffany.Smith@wilmerhale.com
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management
Holdings US Inc.
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