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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 21-2989-MDL-ALTONAGA/Torres
In re:
JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION
_________________________________/
APPLICATION OF RACHEL FURST FOR APPOINTMENT AS
PLAINTIFFS’ LIAISON COUNSEL
Pursuant to the Court’s Order (D.E. 209), entered April 19, 2021, undersigned attorney
Rachel Furst, of Grossman Roth Yaffa Cohen PA (“Grossman Roth”), hereby files this
application for appointment as Plaintiffs’ Liaison Counsel. If appointed, I will focus on
fulfilling the important role of Liaison Counsel and also seek to serve on the Steering
Committee, in an ex-officio capacity, with the same responsibilities as other members of the
Steering Committee.
As this Court has recognized in appointing liaison counsel in other matters, and is set forth
in the Manual for Complex Litigation, the role of liaison counsel involves serving as the primary
contact, along with lead counsel, with whom the Court may communicate regarding the
administration and management of the litigation, facilitating communications between counsel and
the Court, filing motions and other papers on behalf of Plaintiffs’ counsel, participating in
proceedings, receiving and distributing notices, orders, and other filings, and otherwise assisting
in the coordination of activities and positions. See Manual for Complex Litig. § 10.221 (4th ed.
2004). These cases especially will benefit from a diligent liaison counsel, given that more than
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sixty law firms have appeared, and the cases are likely to entail various tranches (or tracks), which
will require careful coordination and consistent communication among counsel and the Court.
I am willing and well-qualified to serve in this role. I am a partner with the law firm
Grossman Roth, where I have represented plaintiffs since 2013. Prior to this, and for nearly five
years, I was an associate in the commercial litigation department of White & Case LLP, and also
clerked for United States District Court Judge Ursula Ungaro in the Southern District of Florida.
I graduated magna cum laude from both Princeton University and the University of Florida, Levin
College of Law, and was an editor of the Florida Law Review. My curriculum vitae, listing
relevant experience and that of my firm will be filed separately as an exhibit. In short, I have
relevant class and MDL experience, have litigated on both sides of many of the claims at issue in
this case, and am a local attorney, well acquainted with the practices and rules of this District.1
Additionally, I have demonstrated a commitment to the cases and an ability to work
amicably with the many lawyers representing plaintiffs in these matters. Since joining this case,
as co-counsel on Cezana v. Robinhood Financial LLC, et al, No.1:21-cv-21315-CMA, I have
worked to assist in the coordination of counsel and in meeting the Courts’ deadlines. I participated
in each of the Plaintiffs’ attorneys’ conferences and the initial conference with defense counsel,
1 My experience representing parties in class actions and mass torts includes Allergan Biocell
Textured Breast Implant products liability litigation, Case No. 2:19-md-02921 (D. N.J.),
representing dozens of women with products liability claims for defective implants, Tershakovec
v. Ford Motor Co., Case No. 17-cv-21087 (S.D. Fla.), representing a putative class of car owners
alleging claims for statutory fraud and consumer protection, breaches of warranty, and unjust
enrichment against an automobile manufacturer, Vazquez v. Gen. Motors, LLC, Case No. 17-
22209-CIV (S.D. Fla.), representing a putative class of car owners alleging breaches of warranty
and consumer protection violations, Gevaerts v. TD Bank, N.A., Case No. 11:14-CV-20744-RLR
(S.D. Fla.), representing a class of investors with claims arising from a viatical life insurance
scheme, Bowe v. Pub. Storage, Case No. 1:14–cv–21559–UU (S.D. Fla.), representing a certified
class of consumers with RICO and consumer protection violations claims, and in In re: Pfizer
Prempro Products et al, Case No. 4:03-cv-01507, representing a defendant against products
liability and warranty claims.
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including by contributing advice on local preferences and rules. I filed and participated in drafting
the joint proposed agenda for the initial status conference (D.E. 145), filed the listing of cases,
parties, and claims to assist the Court (D.E. 200), and participated in the hearing on April 19.
Further, in advance of that hearing, through conference calls with Plaintiffs’ counsel, a consensus
was reached that I serve as liaison counsel on an interim basis for the purpose of compiling
leadership applications and otherwise liaising with the Court. Accordingly, at the hearing on April
19, several attorneys supported my service in this capacity and the Court designated me to
coordinate the filing of the leadership applications, which I have done. (D.E. 209).
Lastly, I have the full support of my firm. Grossman Roth enjoys a well-deserved
reputation for outstanding advocacy and my firm is committed to ensuring that I have the time and
resources to devote to this position. I also have the ability to draw upon the deep experience of
my partners, who collectively have over 200 years of experience in representing plaintiffs,
including in complex litigation and class actions, and who have been appointed to serve in
leadership positions in this District and elsewhere. Grossman Roth’s lawyers were on the
Plaintiffs’ Executive Committee in In re: Checking Account Overdraft Litigation, No. 1 :09-MD-
02036-JLK (S.D. Fla.) (“Overdraft Litigation”), and played a critical role is developing the legal
theories and the evidence that led to the recovery of more than $1 billion for Class members. We
served as co-chair of the Insurance Committee in the litigation arising out of the BP “Deepwater
Horizon” oil spill, as Liaison Counsel in In re: Air Crash Near Rio Grande, Puerto Rico on
December 3, 2008, MDL No. 2246 (S.D. Fla.), and on the Plaintiffs' Executive Committee in In
re: American Airlines Jamaica Crash, No. l 0-CV-20131 (S.D. Fla), and in In re Air Crash Near
Cali, Colombia on December 20, 1995, MDL No. 1125 (S.D. Fla.). Grossman Roth has worked
cooperatively with several of the firms involved in this litigation, and has an established track
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record of bringing lawyers together and working with other firms to successfully prosecute large
cases.
I am well suited for the role – I am able to work cooperatively and will facilitate the
administration and prosecution of these complex cases. I would be honored to continue to work
with the Court and appreciate the Court’s consideration.
Dated: April 26, 2021
Respectfully submitted,
By: /s/ Rachel Wagner Furst
Rachel Wagner Furst
Fla. Bar No. 45155
rwf@grossmanroth.com
GROSSMAN ROTH YAFFA COHEN, P.A.
2525 Ponce de Leon Blvd Ste 1150
Coral Gables, FL 33134-6040
Telephone: (305) 442-8666
Facsimile: (305) 285-1668
Co-counsel for Plaintiff Sagi Cezana
CERTIFICATE OF SERVICE
I hereby certify that on April 26, 2021, I electronically filed the forgoing with the Clerk of
the Court using CM/ECF. I also certify that the foregoing is being served this day on all counsel
of record in the manner specified, either via transmission of Notices of Electronic Filing generated
by CM/ECF or in some other authorized manner for those counsel who are not authorized to
receive Notices of Electronic Filing.
By: /s/ Rachel Wagner Furst
Rachel Wagner Furst
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