“Pimbley will testify to his opinion, based on data extracted from FTX’s database, that: (i) usage by Alameda Research of its line of credit fluctuated between approximately $1 billion and $3 billion between October 2021 and September of 2022 and decreased for a substantial portion of June 2022; and (ii) the majority of balances for non-Alameda, non-FTX users (i.e., accounts excluding Alameda’s accounts and FTX’s own accounts) are concentrated in just four coins (USD, BTC, ETH, and USDT) relative to the hundreds of coins defined within the FTX database, and more than 75% of non-Alameda, non-FTX balances arise from accounts that have spot margin enabled, spot margin lending enabled, or show futures activity,” the filing said.
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