SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by BAM MANAGEMENT US HOLDINGS INC., BAM TRADING SERVICES INC.(This document is SEALED and only available to authorized persons.) (Attachments: # (1) Text of Proposed Order, # (2) Opposition, # (3) Exhibit 1, # (4) Exhibit 2, # (5) Exhibit 3, # (6) Exhibit 4, # (7) Exhibit 5, # (8) Exhibit 6, # (9) Exhibit 7, # (10) Exhibit 8)(McLucas, William) Modified event title on 9/12/2023 (znmw). Modified on 10/6/2023 to unseal exhibits pursuant to Minute Order filed on 10/03/2023 (zjm).
Page 1 EXHIBIT 8Page 2 Matthew Beville
+1 202 663 6255 (t)
+1 202 663 6363 (f)
matthew.beville@wilmerhale.com
August 28, VIA EMAIL AND SECURE FILE TRANSFER
Jennifer L. Farer
Matthew F. Scarlato
Senior Trial Counsel
Division of Enforcement
U.S. Securities and Exchange Commission
100 F. Street, NE
Washington, DC Re:
Binance Holdings Limited, et al. v. SEC, No. 23 Civ. 1599 (ABJ)
Dear Ms. Farer and Mr. Scarlato:
We write on behalf of BAM Trading Services Inc. (“BAM Trading”) and BAM
Management US Holdings Inc. (“BAM Management” and collectively, “BAM”) to provide a
document in further response to the SEC’s First Set of Requests for Production of Documents and
Inspection (the “RFPs”) to BAM, and in response to Mr. Scarlato’s August 24, 2023 email
requesting “the letter that Mr. Fernandez testified FGMK received from BAM on August 18,
2023.” Enclosed please find a document bearing Bates numbers BAM_SEC_LIT_through BAM_SEC_LIT_00004995. The document is a copy of the letter referenced in Mr.
Scarlato’s August 24, 2023 email, which BAM is producing in response to requests 6, 9 and 22 of
the RFPs.
Sincerely,
/s/ Matthew Beville
Matthew Beville
EnclosurePage 3 Exhibit A
Bates Range
Request No.
BAM_SEC_LIT_00004663 through
BAM_SEC_LIT_
6, 9, 22
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-01599-ABJ-ZMF Document 107-10 Filed 09/11/23 Page 1 of 3
EXHIBIT 8
PDF Page 3
Case 1:23-cv-01599-ABJ-ZMF Document 107-10 Filed 09/11/23 Page 2 of 3
Matthew Beville
+1 202 663 6255 (t)
+1 202 663 6363 (f)
matthew.beville@wilmerhale.com
August 28, 2023
VIA EMAIL AND SECURE FILE TRANSFER
Jennifer L. Farer
Matthew F. Scarlato
Senior Trial Counsel
Division of Enforcement
U.S. Securities and Exchange Commission
100 F. Street, NE
Washington, DC 20549
Re:
Binance Holdings Limited, et al. v. SEC, No. 23 Civ. 1599 (ABJ)
Dear Ms. Farer and Mr. Scarlato:
We write on behalf of BAM Trading Services Inc. (“BAM Trading”) and BAM
Management US Holdings Inc. (“BAM Management” and collectively, “BAM”) to provide a
document in further response to the SEC’s First Set of Requests for Production of Documents and
Inspection (the “RFPs”) to BAM, and in response to Mr. Scarlato’s August 24, 2023 email
requesting “the letter that Mr. Fernandez testified FGMK received from BAM on August 18,
2023.” Enclosed please find a document bearing Bates numbers BAM_SEC_LIT_00004990
through BAM_SEC_LIT_00004995. The document is a copy of the letter referenced in Mr.
Scarlato’s August 24, 2023 email, which BAM is producing in response to requests 6, 9 and 22 of
the RFPs.
Sincerely,
/s/ Matthew Beville
Matthew Beville
Enclosure
PDF Page 4
Case 1:23-cv-01599-ABJ-ZMF Document 107-10 Filed 09/11/23 Page 3 of 3
Exhibit A
Bates Range
Request No.
BAM_SEC_LIT_00004663 through
BAM_SEC_LIT_00004668
6, 9, 22
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