Case 1:23-cv-03346-GHW            Document 51        Filed 03/04/24        Page 1 of 2


UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK


BIN LI, Individually and On Behalf of All Others Similarly
Situated,
                                       Plaintiff,
                                                                      No. 23 Civ. 03346 (GHW)
                                 v.

EQONEX LIMITED, BINANCE GROUP, BIFINITY
UAB, JONATHAN FARNELL, DANIEL LING, ALMIRA
CEMMELL, YU HELEN HAI, and ZHAO CHANGPENG,
                                       Defendants.


               SUPPLEMENTARY DECLARATION OF VICTORIA H. YUHAS

          I, Victoria H. Yuhas, at 32 Old Slip, New York, NY 10005, state:

     1.   I am an associate at Cahill Gordon & Reindel LLP, attorneys for Defendants Binance

Group, 1 Bifinity UAB, Jonathan Farnell, Daniel Ling, Almira Cemmell, Yu Helen Hai, and

Changpeng Zhao (collectively, the “Defendants”) in the above-captioned action, and am

authorized to practice law in this Court. I submit this declaration in support of the Defendants’

March 4, 2024 reply memorandum of law in support of Defendants’ motion to dismiss the

Complaint. 2

     2.   Attached hereto as Exhibit 1 is a true and correct copy of Eqonex’s November 15, 2022

Form 6-K filed with the SEC on the same day and available on the SEC’s online filing system,

EDGAR.


1
    Defendants expressly deny the existence of an entity known as “Binance Group.”
2
 Capitalized terms used herein have the meaning assigned to them in the Defendants’ January 12, 2024
memorandum of law (ECF No. 47) or, if not defined therein, in the Amended Class Action Complaint (ECF
No. 39).


      Case 1:23-cv-03346-GHW           Document 51       Filed 03/04/24      Page 2 of 2


  I declare under penalty of perjury that the foregoing is true and correct. Executed on this 4th

day of March 2024.

                                                         /s Victoria H. Yuhas
                                                           Victoria H. Yuhas