Plaintiff Daniluk's Statement on Leadership of this MDL — In re January 2021 Short Squeeze Trading Litigation (Dkt. 241, S.D. Fla.)

Summary

Document 241 in Case 1:21-md-02989-CMA, entered on the FLSD docket April 26, 2021 and relating to all actions, is the two-page Plaintiff Daniluk's Statement on Leadership of this MDL. Plaintiff Daniluk recommends Jeffrey A. Klafter, Esq. as an interim co-lead counsel for this MDL with principal responsibility for the Robinhood tranche, citing counsel's work with Mr. Klafter for over 30 years. The statement says that the slate presented by Natalia Salas, Esq. includes able attorneys but that Ms. Salas lacks the experience and qualifications to be a lead in this MDL. The statement is dated April 26, 2021 and submitted by Green & Noblin, P.C. over the name of Robert S. Green, with Marshall Law Firm, for Plaintiff Joseph Daniluk.

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Case 1:21-md-02989-CMA Document 241 Entered on FLSD Docket 04/26/2021 Page 1 of 2




                                 UNITED STATES DISTRICT COURT
                                 SOUTHERN DISTRICT OF FLORIDA

                                 CASE NO. 21-2989-MDL-ALTONAGA


   In re:

   JANUARY 2021 SHORTSQUEEZE
   TRADING LITIGATION

   ___________________________________/

   This Document Relates to All Actions


                    PLAINTIFF DANILUK’S STATEMENT ON LEADERSHIP
                                    OF THIS MDL



            Counsel for Plaintiff Daniluk participated in conferences regarding the Plaintiff

   leadership of this MDL and has reviewed correspondence regarding two different proposals for

   lead counsel. Plaintiff Daniluk recommends Jeffrey A. Klafter, Esq. as an interim co-lead

   counsel for this MDL with principal responsibility for the Robinhood tranche. Mr. Klafter has

   the experience and qualifications to make an impact as lead counsel in this case. Counsel for
   Daniluk has known and worked with Mr. Klafter professionally for over 30 years, including

   litigating a complex securities class action almost to the start of trial – a case that then settled

   with a recovery of substantial sums for the class. Since then, Mr. Klafter has worked in and been

   a leader in a wide variety of intensely litigated class and complex litigation.

            Counsel for Daniluk has been representing Plaintiffs in class-action cases nationwide for

   over 30 years. See Exhibit A. We have successfully tried class cases to verdict in favor of

   plaintiffs and served in leadership in cases settled for $100 million and more. Id. We have

   stepped aside, as have other extremely distinguished and experienced counsel, in favor of Mr.

   Klafter because he represents the best opportunity for the members of the class to have their best

   cases presented to this Court.
Case 1:21-md-02989-CMA Document 241 Entered on FLSD Docket 04/26/2021 Page 2 of 2




          While the slate presented by Natalia Salas, Esq., includes able attorneys, Ms. Salas lacks

   the experience and qualifications to be a lead in this MDL. To my knowledge, Ms. Salas has

   never been appointed to a leadership position in a class action or, more importantly, participated

   in a class action case from start to finish – experience that we believe to be of critical importance

   to provide effective representation of the class. The counsel suggested for leadership of the

   antitrust tranche has little experience in that field compared to Mr. Saveri, and the experience of

   the third member of their slate appears to be primarily in opposing class certification, rather than

   running a case to obtain class certification.

          In conclusion, Plaintiff Daniluk recommends that the Court place this MDL, in part, in

   the highly qualified leadership of Mr. Klafter.

   Dated: April 26, 2021                           GREEN & NOBLIN, P.C.


                                                   By: /s/ Robert S. Green
                                                           Robert S. Green

                                                   James Robert Noblin
                                                   Evan M. Sumer
                                                   GREEN & NOBLIN, P.C.
                                                   2200 Larkspur Landing Circle, Suite 101
                                                   Larkspur, CA 94939
                                                   Telephone: (415) 477-6700
                                                   Facsimile: (415) 477-6710
                                                   Email: gnecf@classcounsel.com

                                                   Charles D. Marshall
                                                   MARSHALL LAW FIRM
                                                   2121 N. California Blvd., Suite 290
                                                   Walnut Creek, CA 94596
                                                   Telephone: (925) 575-7105
                                                   Facsimile: (9250 575-7105
                                                   Email: cdm@marshall-law-firm.com

                                                   Attorneys for Plaintiff,
                                                   JOSEPH DANILUK, on behalf of himself
                                                   and all others similarly situated


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