GONZALEZ v. BAM TRADING SERVICES, INC. et al
| DAVID GONZALEZ |
| BINANCE HOLDINGS, LTD, XYZ CORP, INC. 1-100, CHANGPENG ZHAO, JOHN DOES 1-100 and BAM TRADING SERVICES, INC. |
| 2:2024cv08521 |
| August 18, 2024 |
| US District Court for the District of New Jersey |
| Brian R Martinotti |
| Cathy L Waldor |
| Racketeer/Corrupt Organization |
| 18 U.S.C. § 1964 Racketeering (RICO) Act |
| Plaintiff |
Docket Report
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This docket was last retrieved on October 28, 2024. A more recent docket listing may be available from PACER.
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Filing 46
TEXT ORDER: The Court has carefully considered the parties' recent submissions. (ECF Nos. #36 , #43 , and #45 ). For good cause shown, Defendants' motion, (ECF No. #36 ), is GRANTED. Defendants shall file any responses to the Complaint within 30 days of the District Court's resolution of Plaintiff's preliminary injunction application. So Ordered by Magistrate Judge Cathy L. Waldor on 10/10/24. (tjd)
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Filing 45
REPLY to Response to Motion filed by BAM TRADING SERVICES, INC., BINANCE HOLDINGS, LTD, CHANGPENG ZHAO re #36 MOTION for Extension of Time to File Answer re #1 Complaint (Staltari, Anthony)
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Filing 44
Corporate Disclosure Statement by BAM TRADING SERVICES, INC. identifying BAM Management US Holdings, Inc. as Corporate Parent.. (DONOVAN, KERRY)
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Filing 43
BRIEF in Opposition filed by All Plaintiffs re #36 MOTION for Extension of Time to File Answer re #1 Complaint (Attachments: #1 Declaration Dec of Counsel, #2 Exhibit Ex A Consent Order)(WARNER, ERIC)
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Filing 42
Notice of Request by Pro Hac Vice Avi Perry to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-15720791.) (Staltari, Anthony)
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Filing 41
Notice of Request by Pro Hac Vice Michael A. Linneman to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-15720743.) (Staltari, Anthony)
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Filing 40
Notice of Request by Pro Hac Vice Brenna Ledvora to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-15720732.) (Staltari, Anthony)
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Filing 39
Notice of Request by Pro Hac Vice Peter H. Fountain to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-15720614.) (Staltari, Anthony)
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Filing 38
TEXT ORDER: The Court hereby amends its prior Order, (ECF No. 37), to note that, as 10/14/24 is a Court holiday, Plaintiff's opposition to Defendants' motion for an extension of time is due 10/15/24. So Ordered by Magistrate Judge Cathy L. Waldor on 10/7/24. (tjd)
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Filing 37
TEXT ORDER: Plaintiff shall file any opposition to Defendants' motion for an extension of time, (ECF No. #36 ), on or before 10/14/24. So Ordered by Magistrate Judge Cathy L. Waldor on 10/7/24. (tjd)
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Set Deadlines as to #36 MOTION for Extension of Time to File Answer re #1 Complaint . Motion set for 11/4/2024 before Judge Brian R. Martinotti. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (sm)
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Pro Hac Vice counsel, AVI PERRY, MICHAEL A. LINNEMAN, BRENNA LEDVORA and PETER H. FOUNTAIN, has been added to receive Notices of Electronic Filing. Pursuant to L.Civ.R. 101.1, only local counsel are entitled to sign and file papers, enter appearances and receive payments on judgments, decrees or orders. (sm)
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Filing 36
MOTION for Extension of Time to File Answer re #1 Complaint by BAM TRADING SERVICES, INC., BINANCE HOLDINGS, LTD, CHANGPENG ZHAO. (Attachments: #1 Memorandum, #2 Declaration, #3 Exhibit 1 to Declaration, #4 Text of Proposed Order)(Staltari, Anthony)
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#36 MOTION for Extension of Time to File Answer re #1 Complaint REFERRED to Cathy L. Waldor. (lr, )
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Filing 47
SUMMONS Returned Executed by DAVID GONZALEZ. CHANGPENG ZHAO served on 9/23/2024 via US Marshals, answer due 10/15/2024. (sm)
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Filing 35
Letter from Eric J. Warner, Esq. re #34 Affidavit of Service. (WARNER, ERIC)
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Filing 34
AFFIDAVIT of Service for Order to Show Cause, Verified Complaint, Brief, Declaration of Counsel with Exhibits & Court Orders served on Changpeng Zhao on 09/23/2024, filed by DAVID GONZALEZ. (WARNER, ERIC)
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Filing 33
BRIEF Reply to Opposition (Attachments: #1 Declaration Reply Declaration of Counsel, #2 Exhibit Ex 1 Crypto Trace Report, #3 Exhibit Ex 2 DOJ Press Release, #4 Exhibit Ex 3 Unpublished Case, #5 Exhibit Ex 4 Unpublished Case, #6 Exhibit Ex 5 Unpublished Case, #7 Exhibit Ex 6 Unpublished Case, #8 Exhibit Ex 7 Unpublished Case)(WARNER, ERIC)
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Filing 32
BRIEF by BAM Trading Services, Inc. in Opposition to Plaintiff's Motion for a Preliminary Injunction (Attachments: #1 Declaration of Christopher Blodgett, #2 Exhibit 1)(DONOVAN, KERRY)
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Filing 31
BRIEF in Opposition to Plaintiff's Motion for a Preliminary Injunction (Attachments: #1 Declaration of Alejandro Alor, #2 Declaration of Charles Michael, #3 Exhibit 1 - BHL Plea Agreement, #4 Exhibit 2 - Zhao/BAM Agreement)(Staltari, Anthony)
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Filing 30
ORDER granting pro hac vice admission of Charles A. Michael, Andrew Adams, Brendan Hammond and B. Gammon Fain. Signed by Magistrate Judge Cathy L. Waldor on 9/6/2024. (sm)
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Filing 29
ORDER granting #26 Motion for Leave to Appear Pro Hac Vice of Avi Perry, Peter H. Fountain, Michael A. Linneman and Brenna Ledvora. Signed by Magistrate Judge Cathy L. Waldor on 9/6/2024. (sm)
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Filing 28
Exhibit to #27 Letter, Declaration of James L. Brochin by BINANCE HOLDINGS, LTD. (BROCHIN, JAMES)
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Filing 27
Letter from James L. Brochin regarding pro hac vice application on consent. (Attachments: #1 Declaration of Charles A. Michael, #2 Declaration of Andrew Adams, #3 Declaration Brendan Hammond, #4 Declaration B. Gammon Fain, #5 Text of Proposed Order)(BROCHIN, JAMES)
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#26 MOTION for Leave to Appear Pro Hac Vice REFERRED to Cathy L. Waldor. (lr, )
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Set Deadlines as to #26 MOTION for Leave to Appear Pro Hac Vice . Motion set for 10/7/2024 before Magistrate Judge Cathy L. Waldor. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (sm)
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Pro Hac Vice counsel, DANIEL T. STABILE, GEORGE E. MASTORIS, THANIA CHARMANI and GABRIELA A. PLASENCIA, has been added to receive Notices of Electronic Filing. Pursuant to L.Civ.R. 101.1, only local counsel are entitled to sign and file papers, enter appearances and receive payments on judgments, decrees or orders. (sm)
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Filing 26
MOTION for Leave to Appear Pro Hac Vice by CHANGPENG ZHAO. (Attachments: #1 Declaration of Anthony J. Staltari, #2 Declaration of Avi Perry, #3 Declaration of Peter H. Fountain, #4 Declaration of Michael A. Linneman, #5 Declaration of Brenna Ledvora, #6 Text of Proposed Order)(Staltari, Anthony)
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Filing 25
NOTICE of Appearance by Anthony J. Staltari on behalf of CHANGPENG ZHAO (Staltari, Anthony)
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Filing 24
CONSENT ORDER EXTENDING SCHEDULE FOR MOTION FOR PRELIMINARY INJUNCTION that the date by which all Defendants shall respond to Plaintiff's Motion for Preliminary Injunction is extended to 9/13/2024; Plaintiff shall file any Reply in Further Support of Its Motion for a Preliminary Injunction is extended to 9/20/2024. Signed by Judge Brian R. Martinotti on 9/5/2024. (sm)
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Filing 23
Notice of Request by Pro Hac Vice Gabriela A. Plasencia to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-15639091.) (DONOVAN, KERRY)
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Filing 22
Notice of Request by Pro Hac Vice Thania (Athanasia) Charmani to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-15639067.) (DONOVAN, KERRY)
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Filing 21
Notice of Request by Pro Hac Vice George E. Mastoris to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-15639047.) (DONOVAN, KERRY)
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Filing 20
Notice of Request by Pro Hac Vice Daniel T. Stabile to receive Notices of Electronic Filings. ( Pro Hac Vice fee $ 250 receipt number ANJDC-15639030.) (DONOVAN, KERRY)
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Filing 19
Letter from James L. Brochin to Hon. Brian Martinotti to request on consent an extension of time to respond to Plaintiff's Motion for Preliminary Injunction re #2 MOTION for Preliminary Injunction , #4 Order on Motion for Preliminary Injunction,,,. (Attachments: #1 Text of Proposed Order)(BROCHIN, JAMES)
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Filing 18
NOTICE of Appearance by JAMES L. BROCHIN on behalf of BINANCE HOLDINGS, LTD (BROCHIN, JAMES)
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Filing 17
CONSENT ORDER EXTENDING TIME FOR DEFENDANT BAM TRADING SERVICES, INC. TO RESPOND TO PLAINTIFF DAVID GONZALEZ'S MOTION FOR PRELIMINARY INJUNCTION that the date by which BAM shall respond to Plaintiff David Gonzalez's Motion forPreliminary Injunction is hereby extended from September 3, 2024 to September 6, 2024. Signed by Judge Brian R. Martinotti on 8/30/2024. (sm)
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Filing 16
Letter from Kerry C. Donovan to Hon. Brian Martinotti to request on consent an extension of time to respond to Plaintiff's Motion for Preliminary Injunction re #2 MOTION for Preliminary Injunction , #4 Order on Motion for Preliminary Injunction,,,. (Attachments: #1 Text of Proposed Order)(DONOVAN, KERRY)
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Filing 15
ORDER FOR ADMISSION PRO HAC VICE OF DANIEL T. STABILE, ESQ., GEORGE E. MASTORIS, ESQ., THANIA (ATHANASIA) CHARMANI, ESQ., AND GABRIELA A. PLASENCIA, ESQ. Signed by Magistrate Judge Cathy L. Waldor on 8/28/2024. (sm) Modified on 8/29/2024 (sm).
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Filing 14
Letter from Kerry C. Donovan to Hon. Cathy L. Waldor regarding pro hac vice application on consent. (Attachments: #1 Declaration of Kerry C. Donovan, #2 Declaration of Daniel T. Stabile, #3 Declaration of George E. Mastoris, #4 Declaration of Thania (Athanasia) Charmani, #5 Declaration of Gabriela A. Plasencia, #6 Text of Proposed Order)(DONOVAN, KERRY)
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Filing 13
NOTICE of Appearance by KERRY C DONOVAN on behalf of BAM TRADING SERVICES, INC. (DONOVAN, KERRY)
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Filing 12
AFFIDAVIT of Service for Affidavit of Service served on CHANGPENG ZHAO on 08/21/2024, filed by DAVID GONZALEZ. (WARNER, ERIC)
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Filing 11
AFFIDAVIT of Service for Affidavit of Service served on CHANGPENG ZHAO on 08/19/2024, filed by DAVID GONZALEZ. (WARNER, ERIC)
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Filing 10
AFFIDAVIT of Service for Affidavit of Service served on Binance Holdings on 08/21/2024, filed by DAVID GONZALEZ. (WARNER, ERIC)
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Filing 9
Letter from Eric J. Warner, Esq. re #1 Complaint. (Attachments: #1 Exhibit Exhibit A to the Verified Complaint)(WARNER, ERIC)
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Filing 8
AFFIDAVIT of Service for Orders served on Agent on 08/20/2024, filed by DAVID GONZALEZ. (WARNER, ERIC)
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Filing 7
AFFIDAVIT of Service for ORDERS, MEMORANDUM OF LAW, DECLARATION, CIVIL COVER SHEET, VERIFIED COMPLAINT, EXHIBITS served on Agent on 08/21/2024, filed by DAVID GONZALEZ. (WARNER, ERIC)
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Filing 6
AFFIDAVIT of Service for OTSC, Verified Complaint, Dec of Counsel with Exhibits, Briefs served on Agent on 08/19/2024, filed by DAVID GONZALEZ. (WARNER, ERIC)
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Filing 5
AFFIDAVIT of Service for OTSC, Complaint, Brief, Dec of Counsel with Exhibits served on Agent on 08/19/2024, filed by DAVID GONZALEZ. (WARNER, ERIC)
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RESET Deadlines as to #2 MOTION for Preliminary Injunction . Motion Reset for 9/16/2024 before Judge Brian R. Martinotti. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (eaj)
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Set Deadlines as to #2 MOTION for Preliminary Injunction . Motion set for 9/16/2024 before Judge Harold A. Ackerman. Unless otherwise directed by the Court, this motion will be decided on the papers and no appearances are required. Note that this is an automatically generated message from the Clerk`s Office and does not supersede any previous or subsequent orders from the Court. (sm)
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Filing 4
MEMORANDUM ORDER that Plaintiff's emergent application for a TRO #2 is DENIED; that Plaintiff's Motion for Preliminary Injunction #2 shall be set forSeptember 16, 2024 and heard in due course; that by 12:00 p.m. ET on August 23, 2024, Plaintiff shall personally serve all Defendants with a copy of his motion papers and a copy of this Order; that Defendants shall respond to Plaintiff's Motion for Preliminary Injunction by September 3, 2024; that Plaintiff shall file any reply in further support of his Motion for Preliminary Injunction by September 9, 2024; that after receiving the parties' submissions on Plaintiff's Motion for Preliminary Injunction, the Court, if it deems necessary, will schedule an in-person status conference for this action on a date to be determined. Signed by Judge Brian R. Martinotti on 8/19/2024. (sm)
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Case assigned to Judge Brian R. Martinotti and Magistrate Judge Cathy L. Waldor. (jr)
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Filing 3
Proposed Order FOR ORDER TO SHOW CAUSE by DAVID GONZALEZ. (WARNER, ERIC)
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Filing 2
MOTION for Preliminary Injunction by DAVID GONZALEZ. (Attachments: #1 Brief BRIEF IN SUPPORT OF ORDER TO SHOW CAUSE, #2 Declaration DECLARATION OF COUNSEL IN SUPPORT OF ORDER TO SHOW CAUSE, #3 Exhibit EXHIBIT 1 Andrews v. Holloway, 95-cv-1047, #4 Exhibit EXHIBIT 2 Ciser v. Nestle Waters North Am., Inc., No. 13-4509, #5 Exhibit EXHIBIT 3 FTC v. Nat'l Invention Servs., 97-cv-3459, #6 Exhibit EXHIBIT 4 Kleinman v. Wright, 18-CV-80176, #7 Exhibit EXHIBIT 5 Mendelsohn, Drucker, & Assocs., P.C. v. Titan Atlas Mfg., 12-cv-0453, #8 Exhibit EXHIBIT 6 Zaftr Inc. v. Lawrence, No. CV 21-2177, #9 Exhibit EXHIBIT 7 U.S. Off. of Gov't Ethics, LA-22-05, #10 Exhibit EXHBIT 8 Exec. Order No. 14,067)(WARNER, ERIC) Modified on 8/20/2024 (sm).
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Filing 1
COMPLAINT against All Defendants ( Filing and Admin fee $ 405 receipt number ANJDC-15596924) with JURY DEMAND, filed by DAVID GONZALEZ.(WARNER, ERIC)
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