Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
__________________________________________
)
SECURITIES AND EXCHANGE
)
COMMISSION,
)
)
Plaintiff,
)
)
v.
)
No. 1:23-cv-01599-ABJ-ZMF
)
BINANCE HOLDINGS LIMITED,
)
BAM TRADING SERVICES INC.,
)
BAM MANAGEMENT US HOLDINGS
)
INC., AND CHANGPENG ZHAO,
)
)
Defendants.
)
__________________________________________)
PLAINTIFF SECURITIES AND EXCHANGE
COMMISSION’S MOTION TO COMPEL AND FOR OTHER RELIEF
Pursuant to Rule 37(a)(3)(B) of the Federal Rules of Civil Procedure, Plaintiff Securities
and Exchange Commission (“SEC”) respectfully moves this Court to compel Defendants BAM
Trading Services Inc. and BAM Management US Holdings Inc. (collectively, “BAM”) to
produce discovery and related relief in accordance with the proposed order attached hereto. The
grounds for the SEC’s Motion are set forth in the SEC’s supporting memorandum and
accompanying exhibits that are attached hereto. The SEC’s memorandum also contains the
SEC’s opposition to BAM’s related motion for a protective order, Dkt. No. 95.
Pursuant to Local Civil Rule 7(m), the SEC states that counsel for BAM has informed the
SEC that it opposes this Motion.Page 2 Dated: August 28,
Respectfully submitted,
/s/Jennifer L. Farer
Matthew Scarlato (D.C. Bar No. 484124)
Jennifer L. Farer (D.C. Bar No. 1013915)
J. Emmett Murphy
David A. Nasse (D.C. Bar No. 1002567)
Jorge G. Tenreiro
SECURITIES AND EXCHANGE COMMISSION
(202) 551-5072 (Farer)
farerj@sec.gov
Attorneys for Plaintiff
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-01599-ABJ-ZMF Document 114 Filed 09/15/23 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-ZMF
)
BINANCE HOLDINGS LIMITED,
)
BAM TRADING SERVICES INC.,
)
BAM MANAGEMENT US HOLDINGS
)
INC., AND CHANGPENG ZHAO,
)
)
Defendants.
)
__________________________________________)
PLAINTIFF SECURITIES AND EXCHANGE
COMMISSION’S MOTION TO COMPEL AND FOR OTHER RELIEF
Pursuant to Rule 37(a)(3)(B) of the Federal Rules of Civil Procedure, Plaintiff Securities
and Exchange Commission (“SEC”) respectfully moves this Court to compel Defendants BAM
Trading Services Inc. and BAM Management US Holdings Inc. (collectively, “BAM”) to
produce discovery and related relief in accordance with the proposed order attached hereto. The
grounds for the SEC’s Motion are set forth in the SEC’s supporting memorandum and
accompanying exhibits that are attached hereto. The SEC’s memorandum also contains the
SEC’s opposition to BAM’s related motion for a protective order, Dkt. No. 95.
Pursuant to Local Civil Rule 7(m), the SEC states that counsel for BAM has informed the
SEC that it opposes this Motion.
PDF Page 3
Case 1:23-cv-01599-ABJ-ZMF Document 114 Filed 09/15/23 Page 2 of 2
Dated: August 28, 2023
Respectfully submitted,
/s/Jennifer L. Farer
Matthew Scarlato (D.C. Bar No. 484124)
Jennifer L. Farer (D.C. Bar No. 1013915)
J. Emmett Murphy
David A. Nasse (D.C. Bar No. 1002567)
Jorge G. Tenreiro
SECURITIES AND EXCHANGE COMMISSION
(202) 551-5072 (Farer)
farerj@sec.gov
Attorneys for Plaintiff
2
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