SECURITIES AND EXCHANGE COMMISSION v. BINANCE HOLDINGS LIMITED et al Document 114: Motion to Compel, Attachment 14

District Of Columbia District Court
Case No. 1:23-cv-01599-ABJ-ZMF
Filed September 15, 2023

MOTION to Compel by SECURITIES AND EXCHANGE COMMISSION. (Attachments: # (1) Memorandum in Support, # (2) Declaration of Jennifer Farer in Support of SEC Motion to Compel, # (3) Exhibit 1, # (4) Exhibit 2, # (5) Exhibit 3, # (6) Exhibit 4, # (7) Exhibit 5, # (8) Exhibit 6, # (9) Exhibit 7, # (10) Exhibit 8, # (11) Exhibit 9, # (12) Exhibit 10, # (13) Exhibit 11, # (14) Exhibit 12, # (15) Exhibit 13, # (16) Exhibit 14, # (17) Exhibit 15, # (18) Exhibit 16, # (19) Exhibit 19, # (20) Exhibit 21, # (21) Exhibit 22, # (22) Exhibit 26, # (23) Exhibit 27, # (24) Exhibit 28, # (25) Text of Proposed Order)(zjm)

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Page 1 EXHIBIT 12

Page 2 From:
To:
Cc:
Subject:
Date:
Farer, Jennifer
McLucas, William; Scarlato, Matthew
Adler, Jeremy; Martens, Matthew T.; Beville, Matthew; Nasse, David; Tenreiro, Jorge; Murphy, J. Emmett
RE: Call
Thursday, August 3, 2023 11:58:00 AM
Bill,
We are free between 1:30-4:30 this afternoon.
In addition to the timing of the accounting, we would like to discuss the production of information
concerning Ceffu and the following statement from your July 31 letter: “You requested that BAM
provide additional information concerning the creation of the New Private and Administrative
Keys and security protocols related to them. As of the date of this letter, BAM has created new
cold wallets with New Private and Administrative Keys. The New Private and Administrative
Keys were created in consultation with Ceffu, and BAM submits that inquiries concerning how
Ceffu creates wallets should be directed to Ceffu.”
Please let us know when this afternoon works for you.
Thank you.
Jennifer L. Farer
U.S. Securities and Exchange Commission
100 F Street N.E. | Washington, D.C. From: McLucas, William
Sent: Thursday, August 3, 2023 10:25 AM
To: Farer, Jennifer ; Scarlato, Matthew
Cc: Adler, Jeremy ; Martens, Matthew T.
; Beville, Matthew
Subject: Call
CAUTION: This email originated from outside of the organization. Do not click links or open
attachments unless you recognize the sender and know the content is safe.
Jennifer, Matt,
Do you have 10 minutes this morning for a meet and confer call on a motion for a few more
days on the accounting that we need to file?
Thanks,
Bill
William R. McLucas | WilmerHale
2100 Pennsylvania Avenue NW

Page 3 Washington, DC 20037 USA
+1 202 663 6622 (t)
+1 202 663 6363 (f)
william.mclucas@wilmerhale.com
Please consider the environment before printing this email.
This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be
privileged. If you are not the intended recipient, please notify us immediately—by replying to this message or by sending an email to
postmaster@wilmerhale.com—and destroy all copies of this message and any attachments. Thank you.
For more information about WilmerHale, please visit us at http://www.wilmerhale.com.

PDF Page 1	PlainSite Cover Page

PDF Page 2	Case 1:23-cv-01599-ABJ-ZMF Document 114-14 Filed 09/15/23 Page 1 of 3 EXHIBIT 12

PDF Page 3	Case 1:23-cv-01599-ABJ-ZMF Document 114-14 Filed 09/15/23 Page 2 of 3 From: To: Cc: Subject: Date: Farer, Jennifer McLucas, William; Scarlato, Matthew Adler, Jeremy; Martens, Matthew T.; Beville, Matthew; Nasse, David; Tenreiro, Jorge; Murphy, J. Emmett RE: Call Thursday, August 3, 2023 11:58:00 AM Bill, We are free between 1:30-4:30 this afternoon. In addition to the timing of the accounting, we would like to discuss the production of information concerning Ceffu and the following statement from your July 31 letter: “You requested that BAM provide additional information concerning the creation of the New Private and Administrative Keys and security protocols related to them. As of the date of this letter, BAM has created new cold wallets with New Private and Administrative Keys. The New Private and Administrative Keys were created in consultation with Ceffu, and BAM submits that inquiries concerning how Ceffu creates wallets should be directed to Ceffu.” Please let us know when this afternoon works for you. Thank you. Jennifer L. Farer U.S. Securities and Exchange Commission 100 F Street N.E. \| Washington, D.C. 20549 From: McLucas, William Sent: Thursday, August 3, 2023 10:25 AM To: Farer, Jennifer ; Scarlato, Matthew Cc: Adler, Jeremy ; Martens, Matthew T. ; Beville, Matthew Subject: Call CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Jennifer, Matt, Do you have 10 minutes this morning for a meet and confer call on a motion for a few more days on the accounting that we need to file? Thanks, Bill William R. McLucas \| WilmerHale 2100 Pennsylvania Avenue NW

PDF Page 4	Case 1:23-cv-01599-ABJ-ZMF Document 114-14 Filed 09/15/23 Page 3 of 3 Washington, DC 20037 USA +1 202 663 6622 (t) +1 202 663 6363 (f) william.mclucas@wilmerhale.com Please consider the environment before printing this email. This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately—by replying to this message or by sending an email to postmaster@wilmerhale.com—and destroy all copies of this message and any attachments. Thank you. For more information about WilmerHale, please visit us at http://www.wilmerhale.com.


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