Declaration of Anupama K. Reddy in Support of Cheng Plaintiffs' Motion to Appoint Joseph R. Saveri as Interim Lead Counsel — In re January 2021 Short Squeeze Trading Litigation (Dkt. 252-5, S.D. Fla.)

Summary

A Declaration of Anupama K. Reddy 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 252-5, 4 pages), in the U.S. District Court for the Southern District of Florida, entered April 26, 2021. Anupama K. Reddy, an associate at Joseph Saveri Law Firm, LLP who clerked for the California Department of Justice Office of the Attorney General, Antitrust Section, describes being one of the principal drafters of the Cheng complaint filed February 1, 2021 in the Northern District of California. The declaration says the firm has investigated the facts since the January 28, 2021 trading restrictions, that no promises of work were made in calls with other plaintiffs, and is dated April 26, 2021 at San Francisco.

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Date: 2021-04-26

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“Declaration of Anupama K. Reddy in Support of Cheng Plaintiffs' Motion to Appoint Joseph R. Saveri as Interim Lead… (Dkt. 252-5).” Original at archive.org, dated 2021-04-26. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-04-26-cheng-v-ally-financial-inc-no-21-cv-00781/, SHA-256 550c93222db7de98d47132a89950614ef297ee71fd64abfa5ae3247b71bc484c.

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Case 1:21-md-02989-CMA Document 252-5 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 ANUPAMA K. REDDY
IN SUPPORT OF CHENG PLAINTIFFS’MOTION TO APPOINT
JOSEPH R. SAVERI AS INTERIM LEAD COUNSEL

I, Anupama K. Reddy, 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 graduated from Symbiosis Law School, India, with a bachelor’s degree in

business and law (B.B.A. LL.B.) in 2014. I am admitted to the Bar Council of India, Maharashtra

& Goa. I practiced transactional law in India for two years. I immigrated to the United States in

2016. I graduated from the University of California Berkeley School of Law in 2017 with an

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LL.M. and specialization in Law and Technology. Upon my graduation from law school, I

worked as a law clerk for the California Department of Justice Office of the Attorney General,

Antitrust Section, in San Francisco, California from 2017-2018. In 2019, I joined JSLF where my

practice focuses on antitrust class action litigation. 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, my colleague, Christopher K.L. Young 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 case 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/ Anupama K. Reddy ____
Anupama K. Reddy

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