MOTION for Extension of Time to Respond to Orders to Show Cause 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-ZMF
Defendants.
REQUEST FOR EXTENSION OF TIME TO RESPOND
TO ORDERS TO SHOW CAUSE
Defendants BAM Trading Services Inc. and BAM Management US Holdings Inc.
(collectively, “BAM”) respectfully move the Court for an extension of the deadline for
Defendants to file their position for maintaining all presently sealed or redacted documents
relating to the SEC’s Motion to Compel in their sealed or redacted form and to show cause to
seal or redact any documents relating to the SEC’s Reply in Support of Motion to Compel to
Wednesday, September 27, 2023.
On September 14, 2023, the Securities and Exchange Commission (“SEC”) filed a
Motion to Unseal or, in the Alternative, to Withdraw its Motion to Seal that was filed at Dkt. No.
102 (“Motion to Unseal”) [Dkt. No. 110]. On September 15, 2023, the Court issued an Order
granting the SEC’s Motion to Unseal and ordering Defendants to show cause to maintain all
presently sealed or redacted documents relating to the SEC’s Motion to Compel in their sealed or
redacted form by September 22, 2023 [Dkt. No. 111]. On September 18, 2023, the SEC filed aPage 2 Sealed Motion for Leave to File Documents Under Seal in connection with its filing of its Reply
in Support of Its Motion to Compel (“Sealing Motion”) [Dkt. No. 112]. On September 18, 2023,
the Court granted the SEC’s Sealing Motion and ordered Defendants to show cause to seal or
redact any documents relating to the SEC’s Reply in Support of Motion to Compel by September
22, 2023 [Dkt. No. 115].
The parties, including Defendants Binance Holdings Limited and Changpeng Zhao, are
continuing to meet and confer regarding which materials should be maintained under seal in
connection with the SEC’s filings. In order to allow sufficient time for the parties to confer,
BAM respectfully requests an extension of the deadline to the Court’s orders to show cause to
Wednesday, September 27, 2023. This is BAM’s first request for an extension of this deadline.
BAM has conferred with the SEC concerning this request, and the SEC does not object.
In addition, BAM intends to file a motion to amend its previous Motion to Seal [Dkt. No.
107], to unseal certain documents or portions thereof that it previously requested that the Court
maintain under seal. BAM respectfully requests that the Court not take any action on that
motion at this time so that BAM may file such motion to amend. Page 3 Dated: September 22,
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
Andrew M. Leblanc (D.C. Bar #479445)
MILBANK LLP
1850 K Street, NW, Suite Washington, D.C. ALeblanc@milbank.com
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
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
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management Holdings
US Inc.
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management
Holdings US Inc.
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-01599-ABJ-ZMF Document 119 Filed 09/22/23 Page 1 of 3
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-ZMF
Defendants.
REQUEST FOR EXTENSION OF TIME TO RESPOND
TO ORDERS TO SHOW CAUSE
Defendants BAM Trading Services Inc. and BAM Management US Holdings Inc.
(collectively, “BAM”) respectfully move the Court for an extension of the deadline for
Defendants to file their position for maintaining all presently sealed or redacted documents
relating to the SEC’s Motion to Compel in their sealed or redacted form and to show cause to
seal or redact any documents relating to the SEC’s Reply in Support of Motion to Compel to
Wednesday, September 27, 2023.
On September 14, 2023, the Securities and Exchange Commission (“SEC”) filed a
Motion to Unseal or, in the Alternative, to Withdraw its Motion to Seal that was filed at Dkt. No.
102 (“Motion to Unseal”) [Dkt. No. 110]. On September 15, 2023, the Court issued an Order
granting the SEC’s Motion to Unseal and ordering Defendants to show cause to maintain all
presently sealed or redacted documents relating to the SEC’s Motion to Compel in their sealed or
redacted form by September 22, 2023 [Dkt. No. 111]. On September 18, 2023, the SEC filed a
PDF Page 3
Case 1:23-cv-01599-ABJ-ZMF Document 119 Filed 09/22/23 Page 2 of 3
Sealed Motion for Leave to File Documents Under Seal in connection with its filing of its Reply
in Support of Its Motion to Compel (“Sealing Motion”) [Dkt. No. 112]. On September 18, 2023,
the Court granted the SEC’s Sealing Motion and ordered Defendants to show cause to seal or
redact any documents relating to the SEC’s Reply in Support of Motion to Compel by September
22, 2023 [Dkt. No. 115].
The parties, including Defendants Binance Holdings Limited and Changpeng Zhao, are
continuing to meet and confer regarding which materials should be maintained under seal in
connection with the SEC’s filings. In order to allow sufficient time for the parties to confer,
BAM respectfully requests an extension of the deadline to the Court’s orders to show cause to
Wednesday, September 27, 2023. This is BAM’s first request for an extension of this deadline.
BAM has conferred with the SEC concerning this request, and the SEC does not object.
In addition, BAM intends to file a motion to amend its previous Motion to Seal [Dkt. No.
107], to unseal certain documents or portions thereof that it previously requested that the Court
maintain under seal. BAM respectfully requests that the Court not take any action on that
motion at this time so that BAM may file such motion to amend.
2
PDF Page 4
Case 1:23-cv-01599-ABJ-ZMF Document 119 Filed 09/22/23 Page 3 of 3
Dated: September 22, 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
Andrew M. Leblanc (D.C. Bar #479445)
MILBANK LLP
1850 K Street, NW, Suite 1100
Washington, D.C. 20003
ALeblanc@milbank.com
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
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
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management Holdings
US Inc.
Attorneys for Defendants BAM Trading
Services Inc. and BAM Management
Holdings US Inc.
3
Back to 
