MOTION for Extension of Time to Serve Verified Written Accounting 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)
Defendants.
BAM TRADING SERVICES INC. AND BAM MANAGEMENT US HOLDINGS, INC.’S
MOTION TO EXTEND DEADLINE FOR VERIFIED WRITTEN ACCOUNTING
BAM Trading Services Inc. (“BAM Trading”) and BAM Management US Holdings Inc.
(“BAM Management,” and collectively “BAM”) respectfully move the Court to extend the
deadline for BAM to serve upon the Securities and Exchange Commission (the “Commission”) a
verified written accounting pursuant to Section IV of the Consent Order dated June 17, 2023 (the
“Consent Order”) [Dkt. No. 71] to Monday, August 7, 2023.
The Consent Order required BAM to “serve upon the Commission a verified written
accounting” “on or before 45 days from the date the Court issues [the] Consent Order.” As a result,
BAM was required to serve upon the Commission a verified written accounting on or before
Tuesday, August 1, 2023. BAM has made every effort to comply with this provision of the
Consent Order. However, given the volume of information that BAM is required to verify as part
of the written accounting, BAM was unable to complete the quality control work necessary to
verify the contents of the written accounting by the deadline contained in the Consent Order. BAM
is working diligently to complete this quality control work promptly. In order to allow BAM toPage 2 complete this work and ensure the accuracy of the information contained in the verified written
accounting, BAM respectfully requests that the Court extend the deadline for BAM to serve the
verified written accounting until Monday, August 7, 2023. This is BAM’s first request to extend
the deadline to serve a verified written accounting pursuant to Section IV of the Consent Order.
BAM has conferred with the Commission, and the Commission does not oppose this
motion.
Dated: August 3,
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
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Case 1:23-cv-01599-ABJ Document 94 Filed 08/03/23 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)
Defendants.
BAM TRADING SERVICES INC. AND BAM MANAGEMENT US HOLDINGS, INC.’S
MOTION TO EXTEND DEADLINE FOR VERIFIED WRITTEN ACCOUNTING
BAM Trading Services Inc. (“BAM Trading”) and BAM Management US Holdings Inc.
(“BAM Management,” and collectively “BAM”) respectfully move the Court to extend the
deadline for BAM to serve upon the Securities and Exchange Commission (the “Commission”) a
verified written accounting pursuant to Section IV of the Consent Order dated June 17, 2023 (the
“Consent Order”) [Dkt. No. 71] to Monday, August 7, 2023.
The Consent Order required BAM to “serve upon the Commission a verified written
accounting” “on or before 45 days from the date the Court issues [the] Consent Order.” As a result,
BAM was required to serve upon the Commission a verified written accounting on or before
Tuesday, August 1, 2023. BAM has made every effort to comply with this provision of the
Consent Order. However, given the volume of information that BAM is required to verify as part
of the written accounting, BAM was unable to complete the quality control work necessary to
verify the contents of the written accounting by the deadline contained in the Consent Order. BAM
is working diligently to complete this quality control work promptly. In order to allow BAM to
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Case 1:23-cv-01599-ABJ Document 94 Filed 08/03/23 Page 2 of 2
complete this work and ensure the accuracy of the information contained in the verified written
accounting, BAM respectfully requests that the Court extend the deadline for BAM to serve the
verified written accounting until Monday, August 7, 2023. This is BAM’s first request to extend
the deadline to serve a verified written accounting pursuant to Section IV of the Consent Order.
BAM has conferred with the Commission, and the Commission does not oppose this
motion.
Dated: August 3, 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
2
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