Declaration of Christopher K.L. Young in Support of Cheng Plaintiffs' Motion to Appoint Joseph R. Saveri as Interim Lead Counsel — In re January 2021 Short Squeeze Trading Litigation (Dkt. 252-6, S.D. Fla.)

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A Declaration of Christopher K.L. Young in Support of Cheng Plaintiffs' Motion to Appoint Joseph R. Saveri as Interim Lead Counsel in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA (Case No. 21-2989-MDL-ALTONAGA/Torres, Document 252-6, 4 pages), in the Southern District of Florida, entered April 26, 2021. Christopher K.L. Young, an associate at Joseph Saveri Law Firm, LLP and counsel for Shane Cheng and Terell Sterling in Cheng v. Ally Financial Inc., No. 21-cv-00781, describes being one of the principal drafters of the Cheng complaint filed February 1, 2021 in the Northern District of California. The declaration calls that complaint among the first to allege antitrust causes of action, says no promises of work or bargains for support were made in calls with other plaintiffs, and is dated April 26, 2021 at San Francisco.

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Case 1:21-md-02989-CMA Document 252-6 Entered on FLSD Docket 04/26/2021 Page 1 of 4




                                UNITED STATES DISTRICT COURT
                                SOUTHERN DISTRICT OF FLORIDA

                            CASE NO. 21-2989-MDL-ALTONAGA/Torres

    IN RE:

    JANUARY 2021 SHORT SQUEEZE
    TRADING LITIGATION
    ____________________________________/
    THIS DOCUMENT RELATES TO: ALL ACTIONS


                      DECLARATION OF CHRISTOPHER K.L. YOUNG
                IN SUPPORT OF CHENG PLAINTIFFS’MOTION TO APPOINT
                     JOSEPH R. SAVERI AS INTERIM LEAD COUNSEL


    I, Christopher K.L. Young, declare as follows:

           1.      I am an attorney licensed to practice law in California. I am an associate with the

    law firm of Joseph Saveri Law Firm, LLP (“JSLF”), counsel of record for Plaintiffs Shane Cheng

    and Terell Sterling (the “Cheng Plaintiffs”) in Cheng v. Ally Financial Inc., No. 21-cv-00781

    (N.D. Cal.), one of the cases that has since been centralized before this Court. I have worked on

    this case since its inception. I have personal knowledge of the facts set forth herein and, if called

    as a witness, could and would testify competently to them. I make this declaration in support of

    Cheng Plaintiffs’ Motion to Appoint Joseph R. Saveri as Interim Lead Counsel. If called to testify

    as a witness in this case, I could and would testify competently to the following. I make this

    declaration pursuant to 28 U.S.C. § 1746.

           2.      I am a 2017 graduate of the UCLA School of Law with a specialization in

    International and Comparative Law. I was admitted to the California bar in 2017. Upon my

    graduation from law school, I worked as a post-bar fellow for the Los Angeles County Public




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    Defender’s Office. In 2018, I began clerking for Associate Justice Lamar W. Baker of Division

    Five, Second Appellate District of the California Court of Appeals, where I worked on appeals

    touching nearly all aspects of civil and criminal law. In 2019, I joined JSLF where my practice

    focuses on antitrust class actions and where I have handled all phases of civil litigation including

    trial.

             3.    I and other members of JSLF have carefully and diligently investigated facts in this

    matter since the restrictions of trading imposed on securities on January 28, 2021. This

    investigation included analysis of stock prices, short interests, the relevant market, and the

    relevant market participants. JSLF’s investigation is ongoing and continues to reveal as of yet

    undiscovered facts.

             4.    I was one of the principal drafters of the Cheng Plaintiffs’ initial complaint (the

    “Complaint”), filed in the Northern District of California on February 1, 2021. The Complaint

    was among the first to allege antitrust causes of action and, even after the passage of time,

    remains the most detailed and particularized Short Squeeze complaint thus filed.

             5.    As a result of our investigation, I and other members of the JSLF team recognized

    important evidence of communications such as phone calls or social media posts leading up to the

    January 28, 2021 trading restrictions that may be in the possession or control of nonparties and

    that this evidence may be destroyed in the ordinary course due to regular data retention policies,

    e.g., call records are regularly destroyed by phone carriers within twelve months. On February

    22, 2021, I wrote to sixteen phone carriers and social media companies to request that they

    suspend data destruction policies and to preserve potentially relevant evidence.




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           6.      Recognizing the quantity of Short Squeeze complaints that were being filed across

    the United States, JSLF determined the cases may be appropriately centralized by the Judicial

    Panel on Multidistrict Litigation (“JPML”). I and other members of JSLF reviewed each and

    every complaint to determine which were appropriate to suggest to the JPML for centralization.

    On February 5, 2021, JSLF filed the motion for centralization before the JPML. In re Jan. 2021

    Short Squeeze Trading Litig., MDL No. 2989 (J.P.M.L. Feb. 5, 2021) ECF No. 1. Consistent with

    JPML procedures, I and other members of JSLF served a service packet comprised of thousands

    of pages on over 100 entities, including each defendant, each Short Squeeze plaintiff, and to each

    district court in which a Short Squeeze action was filed.

           7.      On April 1, 2021, the JPML centralized and transferred the Short Squeeze Actions

    to this Court for pretrial purposes. MDL ECF No. 1.

           8.      I and other members of JSLF, recognizing the need for organization given the 50-

    plus complaints, causes of action and parties involved, organized the claims into three groups by

    claims and common issues—a proposal that was adopted by all plaintiffs and defendants at meet

    and confers and ultimately presented to the Court at the April 19, 2021 initial status conference.

           9.      On April 19, 2021, the Court held an initial status conference wherein the Court

    set forth procedures for the appointment of lead counsel and organization and structure of

    counsel. MDL ECF No. 209.

           10.     Consistent with the Court’s order, I and other members of JSLF conferred

    extensively with other Short Squeeze plaintiffs, both in large calls and small. I and other members

    of JSLF did not make any promises of work nor any bargains for support at these calls. While




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    these calls and conferences were cordial, productive and in good faith, the parties were unable to

    reach consensus.

           I declare under the penalty of perjury that the foregoing is true and correct, executed on

    April 26, 2021 at San Francisco, California.



                                                         /s/ Christopher K.L. Young
                                                         Christopher K.L. Young




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