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
Upon consideration of Defendants BAM Trading Services Inc. and BAM Management US
Holdings Inc.’s (together, “BAM”) Motion for a Protective Order (the “Motion”), IT IS HEREBY
ORDERED THAT:
1.
The Motion is granted in its entirety.
2.
Plaintiff Securities and Exchange Commission’s request that BAM produce “all
communications” responsive to requests in the SEC’s First Set of Requests for Production of
Documents and Inspection to BAM, dated June 23, 2023, for BAM employees noticed for
depositions by the SEC is quashed.
3.
The SEC is precluded from deposing Brian Shroder, BAM’s Chief Executive
Officer, and Jasmine Lee, BAM’s Chief Financial Officer, pursuant to the Consent Order.Page 2 4.
During depositions pursuant to the Consent Order (Dkt. 71), the SEC may not
question witnesses concerning topics outside the scope of the Consent Order, which would include
inquiries concerning BAM’s historical asset custody practices or the merits of this case.
HON. AMY BERMAN JACKSON
UNITED STATES DISTRICT JUDGE
Dated:
SERVE: ALL COUNSEL OF RECORD
-2-
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Case 1:23-cv-01599-ABJ Document 95-11 Filed 08/14/23 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
Upon consideration of Defendants BAM Trading Services Inc. and BAM Management US
Holdings Inc.’s (together, “BAM”) Motion for a Protective Order (the “Motion”), IT IS HEREBY
ORDERED THAT:
1.
The Motion is granted in its entirety.
2.
Plaintiff Securities and Exchange Commission’s request that BAM produce “all
communications” responsive to requests in the SEC’s First Set of Requests for Production of
Documents and Inspection to BAM, dated June 23, 2023, for BAM employees noticed for
depositions by the SEC is quashed.
3.
The SEC is precluded from deposing Brian Shroder, BAM’s Chief Executive
Officer, and Jasmine Lee, BAM’s Chief Financial Officer, pursuant to the Consent Order.
PDF Page 3
Case 1:23-cv-01599-ABJ Document 95-11 Filed 08/14/23 Page 2 of 2
4.
During depositions pursuant to the Consent Order (Dkt. 71), the SEC may not
question witnesses concerning topics outside the scope of the Consent Order, which would include
inquiries concerning BAM’s historical asset custody practices or the merits of this case.
HON. AMY BERMAN JACKSON
UNITED STATES DISTRICT JUDGE
Dated:
SERVE: ALL COUNSEL OF RECORD
-2-
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