Unopposed MOTION to Continue 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.
UNOPPOSED MOTION FOR CONTINUANCE
Pursuant to Federal Rule of Civil Procedure 6(b) and LCvR 16.1(b), BAM Trading
Services, Inc. (“BAM Trading”) and BAM Management US Holdings Inc. (“BAM Management,”
together with BAM Trading, “BAM”), by and through BAM’s undersigned counsel, hereby
respectfully moves for a continuance until January 19, 2024 for the Court to hold a hearing on the
motions to dismiss the above captioned matter, which is currently set for January 18, 2023. In
support of this Motion, BAM states as follows:
1.
On October 24, 2023, the Court ordered the parties to appear for a hearing on the
motions to dismiss the above captioned matter on January 18, 2024, at 10:00 AM.
2.
Unfortunately, lead counsel for BAM is unavailable on the date selected by the
3.
In accordance with LCvR 16.1(b), counsel for BAM promptly notified counsel for
Court.
the Securities and Exchange Commission (“SEC”) as soon as it became aware of the scheduling
conflict. Counsel for BAM has conferred with counsel for Plaintiff and the other Defendants, andPage 2 all parties would be available to attend the conference on January 19, 2024. The SEC and the other
Defendants do not object to the requested continuance of the conference to January 19, 2024.
4.
The requested continuance is made in good faith, and will not cause any delay or
prejudice. Furthermore, good cause exists for the requested continuance until January 19, 2024,
because the continuance would resolve the scheduling conflicts described above.
Accordingly, for good cause shown, BAM respectfully requests that this Honorable Court
grant this unopposed Motion, and continue the hearing currently scheduled for January 18, 2024,
to January 19, 2024.
Dated: November 9,
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
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.
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-01599-ABJ-ZMF Document 173 Filed 11/09/23 Page 1 of 2
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.
UNOPPOSED MOTION FOR CONTINUANCE
Pursuant to Federal Rule of Civil Procedure 6(b) and LCvR 16.1(b), BAM Trading
Services, Inc. (“BAM Trading”) and BAM Management US Holdings Inc. (“BAM Management,”
together with BAM Trading, “BAM”), by and through BAM’s undersigned counsel, hereby
respectfully moves for a continuance until January 19, 2024 for the Court to hold a hearing on the
motions to dismiss the above captioned matter, which is currently set for January 18, 2023. In
support of this Motion, BAM states as follows:
1.
On October 24, 2023, the Court ordered the parties to appear for a hearing on the
motions to dismiss the above captioned matter on January 18, 2024, at 10:00 AM.
2.
Unfortunately, lead counsel for BAM is unavailable on the date selected by the
3.
In accordance with LCvR 16.1(b), counsel for BAM promptly notified counsel for
Court.
the Securities and Exchange Commission (“SEC”) as soon as it became aware of the scheduling
conflict. Counsel for BAM has conferred with counsel for Plaintiff and the other Defendants, and
PDF Page 3
Case 1:23-cv-01599-ABJ-ZMF Document 173 Filed 11/09/23 Page 2 of 2
all parties would be available to attend the conference on January 19, 2024. The SEC and the other
Defendants do not object to the requested continuance of the conference to January 19, 2024.
4.
The requested continuance is made in good faith, and will not cause any delay or
prejudice. Furthermore, good cause exists for the requested continuance until January 19, 2024,
because the continuance would resolve the scheduling conflicts described above.
Accordingly, for good cause shown, BAM respectfully requests that this Honorable Court
grant this unopposed Motion, and continue the hearing currently scheduled for January 18, 2024,
to January 19, 2024.
Dated: November 9, 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
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.
2
Back to 
