This matter is before the Court on the Plaintiffs’ Motion to Compel and Expedite Discovery as to Temasek in Accordance with the District Court’s December 18, 2023 Order.

After a careful review of the motion, the pertinent portions of the record, and the Court being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that, on or before 2:00 p.m. on Tuesday, January 16, 2024, Defendants Temasek Holdings (Private) Limited and Temasek International USA LLC shall file their response to Plaintiffs’ Motion to Compel and Expedite Discovery as to Temasek in Accordance with the District Court’s December 18, 2023 Order (ECF No. 455).

It is further ORDERED AND ADJUDGED that the Plaintiffs’ motion is scheduled for hearing at 3:00 p.m. on Wednesday, January 17, 2024, in the 6th Floor Courtroom of the C. Clyde Atkins United States Courthouse, 301 N. Miami Avenue, Miami, FL 33128, in conjunction with other discovery matters previously scheduled for hearing.

It is further ORDERED AND ADJUDGED that the parties shall confer, prior to the January 17th hearing, to address the discovery disputes raised in the Plaintiffs’ motion in an effort to narrow and resolve any outstanding issues concerning the jurisdictional discovery requests that are the

Case 1:23-md-03076-KMM Document 459 Entered on FLSD Docket 01/10/2024 Page 2 of 2 subject of the motion.

This matter is before the Court on Defendant Erika Kullberg’s Motion for Protective Order, ECF No. 446, and the Plaintiffs’ motions to compel expedited discovery from Defendants Deltec Bank and Trust Company, Jean Chalopin, Erika Kullberg, Brian Jung, Creators Agency LLC, Jaspreet Singh, Sino Global Capital Holdings, LLC, and Sino Global Capital Limited, ECF Nos. 447-450.

After a careful review of the motions, the pertinent portions of the record, and the Court being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that, on or before 5:30 p.m. on Friday, January 12, 2024: • Plaintiffs shall file their response to Specially Appearing Defendant Erika Kullberg’s Motion for Protective Order (ECF No. 446); • Defendants Deltec Bank and Trust Company and Jean Chalopin shall file their response to Plaintiffs’ Motion to Compel and Expedite Discovery in Accordance with the District Court’s December 18, 2023 Order (ECF No. 447); • Defendants Erika Kullberg, Brian Jung, and Creators Agency LLC shall file their response to Plaintiffs’ Motion to Compel Expedited Discovery from Defendants Erika Kullberg, Brian Jung, and Creators Agency LLC (ECF No. 448); • Defendant Jaspreet Singh shall file his response to Plaintiffs’ Motion to Compel Expedited Discovery from Defendant Jaspreet Singh (ECF No. 449); • Defendants Sino Global Capital Holdings, LLC and Sino Global Capital Limited shall file their response to Plaintiffs’ Motion to Compel and Expedite Discovery as to Sino Global in Accordance with the District Court’s December 18, 2023 Order (ECF No. 450); Each response shall be no longer than five (5) pages, and the parties shall identify any discovery

It is further ORDERED AND ADJUDGED that the motions listed above are scheduled for hearing at 3:00 p.m. on Wednesday, January 17, 2024, in the 6th Floor Courtroom of the C. Clyde Atkins United States Courthouse, 301 N. Miami Avenue, Miami, FL 33128.

It is further ORDERED AND ADJUDGED that the Parties shall confer, prior to the January 17th hearing, to address the discovery disputes raised in the above-listed motions in an effort to narrow and resolve any outstanding issues concerning the discovery requests and efforts to schedule depositions concerning jurisdictional discovery that are the subject of the motions.

Given that Judge Moore has already granted limited jurisdictional discovery in this case as to Defendants involved in the above-listed motions,* the parties shall be prepared to complete any jurisdictional discovery that may be ordered at the January 17th hearing on or before the February 1, 2024 deadline established by Judge Moore for the completion of limited jurisdictional discovery.

THE UNDERSIGNED MAGISTRATE JUDGE, to whom the above-styled case has been assigned, hereby recuses herself and refers the matter to the Clerk of Court for reassignment pursuant to 28 U.S.C. § 455(b)(4).

DONE AND ORDERED in Chambers at Miami, Florida this 27th day of December, 2023.

Case 1:23-md-03076-KMM Document 439 Entered on FLSD Docket 12/28/2023 Page 2 of 2 In accordance with the Local Rules for the Southern District of Florida, providing for the random and equal allotment of cases, this cause will be reassigned to the calendar of Eduardo I. Sanchez __________________________________________________.

Copies of this Order shall be served on all pending parties of record.

following case number and designation: 28th December BY ORDER OF THE COURT this ____ day of ______________, 2023, in Miami, Florida.

1 Specifically, Plaintiffs seek jurisdictional discovery as to Stephen Curry, Golden State Warriors LLC, Solomid Corporation, Naomi Osaka, Udonis Haslem, Lawrence Gene David, Andre Jikh, Jeremy LeFebvre, Graham Stephan, Jaspreet Singh, Erika Kullberg, Brian Jung, Creators Agency LLC, SoftBank Group Corp., SoftBank Investment Advisers (UK) Limited, SoftBank Global Advisers Limited, Temasek Holdings (Private) Limited, Temasek International USA LLC, Sino Global Capital Holdings LLC, Farmington State Bank d/b/a Moonstone Bank (“Moonstone”), Deltec Bank and Trust Company Limited, and Jean Chalopin.

For the purposes of this Order, the Court refers to these individuals and entities collectively as “Defendants.” Case 1:23-md-03076-KMM Document 422 Entered on FLSD Docket 12/18/2023 Page 2 of 6

Therein, the Court directed the Parties to resolve all issues related to personal jurisdiction, instructed Plaintiffs to file consolidated amended complaints, and crafted deadlines for responsive pleadings.

To streamline the efficiency of these proceedings, the Court issued a paperless order setting forth the procedures by which the Defendants could file motions to dismiss.

Now, the motions to dismiss for each Administrative Class Action Complaint are fully briefed and discovery remains stayed.

Case 1:23-md-03076-KMM Document 858 Entered on FLSD Docket 03/19/25 21:20:27 Page 2 of 4 Over Moonstone’s opposition, Plaintiffs’ Motion to Amend was granted, and on

P. 12(b)(6), noting that the limited allegations that were added regarding Moonstone in Plaintiffs’ Amendment did not cure any of the fatal defects that were raised in Moonstone’s initial Motion to Dismiss.

Ala. June 28, 2022) (noting that under Rule 6(b), courts are given “extensive flexibility to modify the fixed time periods found throughout the rules”).

that the Motion to Strike is denied, and the Opposition is permitted to stay in effect, Moonstone will then timely submit its reply brief within twenty (20) days of that decision.

Inversely, if the Motion to Strike is granted, Plaintiffs will have to file a new Opposition, to which Moonstone will timely reply.

Temasek International employees Pradyumna Agrawal and Antony Lewis served on FTX’s Advisory Board, which met quarterly, and advised on matters including the publicity campaign and FTX Derivatives strategy, both of which were based in Miami.

financial reports;5 through its maintenance of interlocking directorates and loci of control;6 and by holding out its leadership board as one entity, called “OneTemasek.” ECF 783, ¶ 31.7 Plaintiffs’ prima facie case for jurisdiction over the Objectors makes relevant discovery into those Objectors’ agency relationships with the other Defendants.

Ct. App. 2018) (section 48.181, authorizes substitute service on nonresident defendants doing business in Florida where the cause of action arises from 10 Temasek Objectors assert that Magistrate Judge Sanchez “rejected nearly every single one of Plaintiffs … RFPs,” but that is not true.

Here Plaintiffs have alleged and can establish that there is no meaningful corporate differentiation between the Sino Global Capital entities – they are all owned and controlled by Matthew Graham, share the same general counsel, directors and officers, and the same addresses and web sites.

Sino Global Capital Limited is a small crypto investment firm owned and operated by Matthew Graham, a U.S. citizen, with no publicized address or corporate headquarters on its Case 1:23-md-03076-KMM Document 854 Entered on FLSD Docket 03/07/2025 Page 10 of 12

Thus, when asked to grant a method of service on a foreign defendant, the Court has broad discretion to do so so long as the plan does not violate international agreement and is calculated to give notice.

P. 1 (“[The Federal Rules of Civil Procedure] should be construed, administered, and employed by the court and the parties to secure the just., speedy, and inexpensive determination of every action and proceeding.”); Fed. R. Civ.

The cases upon which Temasek most relies to argue that the Court cannot grant alternate service are factually distinct because, unlike here, due process was a concern—defendants had not yet appeared in the litigation in neither Signify nor Castaneda4.

Fla. Sept. 14, 2015)); • where international courier to foreign defendants’ known personal and corporate addresses, as well as email and U.S. mail to their Florida counsel, would constitute sufficient notice (e.g., Fru Veg Mktg., 896 F. Supp.

Plaintiffs respectfully request that this Court grant its proposed service plan, which comports with due process, does not violate international agreement, and serves the needs of the case given the facts at hand in this complex litigation.

None of the new, irrelevant factual allegations about any Temasek or Sino entity addresses the FAC’s many deficiencies.

None of its twenty-two counts identifies conduct by any of the individual MNVCs, instead lumping them together and then incorporating the entirety of the SAC’s allegations.

None of the MNVCs owned more than a small minority stake in FTX.

On November 15, 2024, Plaintiffs filed the Amended Complaint, which is 112 pages, excluding exhibits, contains 318 paragraphs, and asserts six causes of action against Moonstone

1 The Court’s prior Order permitted Defendants “to file jointly one 12(b)(6) motion and memorandum of law of up to 40 pages” [ECF No. 216]; out of an abundance of caution, Moonstone does not assume the 40-page limitation applies here.

Moonstone notes that other defendants involved in this multi-district litigation have sought and received similar relief for responsive filings.

Case 1:23-md-03076-KMM Document 810 Entered on FLSD Docket 01/10/2025 Page 2 of 3 for civil conspiracy, aiding and abetting fraud and breaches of fiduciary duty, and violations of the RICO Act.

Moonstone was previously granted an unopposed extension of time to respond to the Amended Complaint, such that Moonstone’s response is currently due on January 15, 2025.

UPON CONSIDERATION of the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that:

Any other actions filed, whether filed directly in the United States District Court for the Southern District of Florida or in any other United States District Court (whether by original filing or removal), that are related to this litigation (that is, civil actions seeking damages arising from the collapse of the FTX Cryptocurrency Exchange) are hereby consolidated into one action (the “Consolidated Action”) for all pre-trial purposes pursuant to Rule 42 of the Federal Rules of Civil Procedure.

The purpose of the following instructions is to reduce the time and expense of duplicate filings of documents through the use of a master case, while at the same time not congesting the master case with miscellaneous papers and orders that are of interest only to the parties directly affected by them.

Attorneys admitted to practice and in good standing of the bar of any United States District Court will be admitted to practice in this litigation upon the filing of a Notice of Appearance in (1) the master case and (2) the particular action(s) in which they seek to appear.

As discussed in the initial conference, the following initial schedule is so ordered: • All issues related to personal jurisdiction shall be resolved and the Parties shall inform the Court of such resolution within 14 days of the date of this Order; • The Sports and Entertainment Defendants shall file a motion to stay discovery within 21 days of the date of this Order; • All other Defendants shall file any motion to stay discovery within 21 days of being served with discovery; • Plaintiffs shall file consolidated amended complaints within 45 days of the date of this Order; • Thereafter, Defendants shall have 45 days from the filing of the amended complaints to file any responses to the amended complaints; • Plaintiffs’ Proposed Leadership Structure, (ECF No. 59-1), is hereby ADOPTED and INCORPORATED BY REFERENCE in this Order; Case 1:23-md-03076-KMM Document 61 Entered on FLSD Docket 06/21/2023 Page 5 of 5 • The status conference scheduled for June 27, 2023, is hereby cancelled.

UPON CONSIDERATION of the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that:

Any other actions filed, whether filed directly in the United States District Court for the Southern District of Florida or in any other United States District Court (whether by original filing or removal), that are related to this litigation (that is, civil actions seeking damages arising from the collapse of the FTX Cryptocurrency Exchange) are hereby consolidated into one action (the “Consolidated Action”) for all pre-trial purposes pursuant to Rule 42 of the Federal Rules of Civil Procedure.

The purpose of the following instructions is to reduce the time and expense of duplicate filings of documents through the use of a master case, while at the same time not congesting the master case with miscellaneous papers and orders that are of interest only to the parties directly affected by them.

Attorneys admitted to practice and in good standing of the bar of any United States District Court will be admitted to practice in this litigation upon the filing of a Notice of Appearance in (1) the master case and (2) the particular action(s) in which they seek to appear.

As discussed in the initial conference, the following initial schedule is so ordered: • All issues related to personal jurisdiction shall be resolved and the Parties shall inform the Court of such resolution within 14 days of the date of this Order; • The Sports and Entertainment Defendants shall file a motion to stay discovery within 21 days of the date of this Order; • All other Defendants shall file any motion to stay discovery within 21 days of being served with discovery; • Plaintiffs shall file consolidated amended complaints within 45 days of the date of this Order; • Thereafter, Defendants shall have 45 days from the filing of the amended complaints to file any responses to the amended complaints; • Plaintiffs’ Proposed Leadership Structure, (ECF No. 59-1), is hereby ADOPTED and INCORPORATED BY REFERENCE in this Order; Case 1:23-cv-20439-KMM Document 52 Entered on FLSD Docket 09/13/2023 Page 5 of 5 • The status conference scheduled for June 27, 2023, is hereby cancelled.

UPON CONSIDERATION of the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that:

Any other actions filed, whether filed directly in the United States District Court for the Southern District of Florida or in any other United States District Court (whether by original filing or removal), that are related to this litigation (that is, civil actions seeking damages arising from the collapse of the FTX Cryptocurrency Exchange) are hereby consolidated into one action (the “Consolidated Action”) for all pre-trial purposes pursuant to Rule 42 of the Federal Rules of Civil Procedure.

The purpose of the following instructions is to reduce the time and expense of duplicate filings of documents through the use of a master case, while at the same time not congesting the master case with miscellaneous papers and orders that are of interest only to the parties directly affected by them.

Attorneys admitted to practice and in good standing of the bar of any United States District Court will be admitted to practice in this litigation upon the filing of a Notice of Appearance in (1) the master case and (2) the particular action(s) in which they seek to appear.

As discussed in the initial conference, the following initial schedule is so ordered: • All issues related to personal jurisdiction shall be resolved and the Parties shall inform the Court of such resolution within 14 days of the date of this Order; • The Sports and Entertainment Defendants shall file a motion to stay discovery within 21 days of the date of this Order; • All other Defendants shall file any motion to stay discovery within 21 days of being served with discovery; • Plaintiffs shall file consolidated amended complaints within 45 days of the date of this Order; • Thereafter, Defendants shall have 45 days from the filing of the amended complaints to file any responses to the amended complaints; • Plaintiffs’ Proposed Leadership Structure, (ECF No. 59-1), is hereby ADOPTED and INCORPORATED BY REFERENCE in this Order; Case 1:22-cv-23753-KMM Document 228 Entered on FLSD Docket 09/13/2023 Page 5 of 5 • The status conference scheduled for June 27, 2023, is hereby cancelled.

Case 1:23-md-03076-KMM Document 772 Entered on FLSD Docket 11/12/2024 Page 2 of 4 Lead Plaintiff, Nir Lahav (“Lead Plaintiff”), on behalf of himself and all others similarly situated (including but not limited to the named plaintiffs in the other actions within this MDL and their Classes), hereby moves for leave to file the attached Sur-Reply Brief in response to Defendants BAM Trading Services Inc. and BAM Management US Holdings Inc. (collectively “Binance US Defendants”) Reply (Dkt. 769) in support of its Motion to Dismiss (Dkt. 708).

In their Reply Memorandum, Binance US Defendants assert that Lead Plaintiff does not meaningfully contest the UCL claim and has abandoned it.

Contrary to their assertion, Lead Plaintiff incorporates by reference its opposition, on similar issues, to the motion filed by co-defendants, CZ and Binance.

Further, Sections II and IV (Dkt. 745) include additional arguments that apply equally to the UCL claims.

Lead Plaintiff seeks leave to submit a short Sur-Reply brief for the limited purpose of addressing the assertion regarding waived or abandoned arguments.

But they all rest on the same core set of facts concerning the alleged fraud that led to FTX’s collapse and, in particular, revolve around the conduct of FTX’s Samuel Bankman-Fried, the relationship with another Bankman-Fried company known as Alameda Research, and Alameda’s Caroline Ellison.

Additionally, at oral argument, movants conceded that centralization of these claims is not warranted given the closure- related issues unique to those entities.5 Based on this record, we do not intend to include the claims against Signature Bank and the Silvergate Bank defendants.6 On the basis of the papers filed and the hearing session held, we find that the actions on Schedule A involve common questions of fact, and centralization will serve the convenience of the parties and witnesses and promote the just and efficient conduct of this litigation.

Centralization will eliminate duplicative discovery; prevent inconsistent pretrial rulings, especially with respect to class certification and Daubert motions; and conserve the resources of the parties, their counsel and the judiciary.

5 For example, plaintiffs in Statistica Capital v. Signature Bank are subject to an exhaustion of administrative remedies requirement under the Financial Institutions Reform, Recovery and Enforcement Act because of the FDIC receivership, and that action thus has been stayed.

Karen K. Caldwell Chair Nathaniel M. Gorton David C. Norton Dale A. Kimball Matthew F. Kennelly Roger T. Benitez Madeline Cox Arleo

But they all rest on the same core set of facts concerning the alleged fraud that led to FTX’s collapse and, in particular, revolve around the conduct of FTX’s Samuel Bankman-Fried, the relationship with another Bankman-Fried company known as Alameda Research, and Alameda’s Caroline Ellison.

Additionally, at oral argument, movants conceded that centralization of these claims is not warranted given the closure- related issues unique to those entities.5 Based on this record, we do not intend to include the claims against Signature Bank and the Silvergate Bank defendants.6 On the basis of the papers filed and the hearing session held, we find that the actions on Schedule A involve common questions of fact, and centralization will serve the convenience of the parties and witnesses and promote the just and efficient conduct of this litigation.

Centralization will eliminate duplicative discovery; prevent inconsistent pretrial rulings, especially with respect to class certification and Daubert motions; and conserve the resources of the parties, their counsel and the judiciary.

5 For example, plaintiffs in Statistica Capital v. Signature Bank are subject to an exhaustion of administrative remedies requirement under the Financial Institutions Reform, Recovery and Enforcement Act because of the FDIC receivership, and that action thus has been stayed.

Karen K. Caldwell Chair Nathaniel M. Gorton David C. Norton Dale A. Kimball Matthew F. Kennelly Roger T. Benitez Madeline Cox Arleo