Declaration of Catherine K. Smith in Support of Cheng Plaintiffs' Motion to Appoint Joseph R. Saveri as Interim Lead Counsel — In re January 2021 Short Squeeze Trading Litigation (Dkt. 252-7, S.D. Fla.)

Summary

A Declaration of Catherine K. Smith 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 252-7, 3 pages), in the U.S. District Court for the Southern District of Florida, entered April 26, 2021. Catherine K. Smith of Gustafson Gluek PLLC, counsel for Plaintiff Julie Fox, describes experience in antitrust class actions and says the Cheng complaint was one of the first alleging antitrust claims and served as a model for the complaint Smith's firm filed. Smith describes working with JSLF in In re Juul Labs, Inc. Antitrust Litigation, where JSLF is lead counsel, and the declaration is dated April 26, 2021 at Minneapolis, MN.

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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
____________________________________/
THIS DOCUMENT RELATES TO: ALL ACTIONS

DECLARATION OF CATHERINE K. SMITH
 IN SUPPORT OF CHENG PLAINTIFFS’MOTION TO APPOINT
JOSEPH R. SAVERI AS INTERIM LEAD COUNSEL

I, Catherine K. Smith, declare as follows:
1.
I am a member of the firm of Gustafson Gluek PLLC. My firm serves as counsel
for Plaintiff Julie Fox in this litigation. I submit this declaration in support of Cheng Plaintiffs’
Motion to Appoint Joseph R. Saveri as Interim Lead Counsel. I make this declaration based on
my own personal knowledge, and if called as a witness, I could and would competently testify to
the matters stated herein. I make this Declaration pursuant to 28 U.S.C. § 1746.
2.
I have extensive experience prosecuting antitrust class actions and other complex
litigation. I have served on leadership committees and have participated in all phases of the
prosecution of these cases. See, e.g., Greater Chautauqua Federal Credit Union v. KMart Corp. et
al., 15-cv-02228 (N.D. Ill.) (appointed to plaintiffs’ steering committee); In re TFT-LCD (Flat
Panel) Antitrust Litig., MDL No. 07-1827 (N.D. Cal.) (solely responsible for managing Korean
review team and member of the Trial Team); In re Cathode Ray Tube Antitrust Litig., 07-cv-05944
(N.D. Cal.) (same); In re Lithium Ion Batteries, 4:13-md-02420 (N.D. Cal.) (solely responsible for
managing Korean review team and discovery issues); In re Aspartame Antitrust Litig., 06-CV-1732
Case 1:21-md-02989-CMA   Document 252-7   Entered on FLSD Docket 04/26/2021   Page 1 of 3

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(E.D. Pa) (managed foreign language review). Having served in leadership roles, and having
served at the direction of others, I understand the importance of efficiency, transparency, and
collaboration in achieving redress for our clients.
3.
The Cheng complaint was one of the first complaints filed alleging antitrust claims
and served as a model for the complaint my firm filed.
4.
I serve as a member of the litigation team representing direct purchaser plaintiffs
in In re Juul Labs, Inc. Antitrust Litigation, Case No. 3:20-cv-02345-WHO (N.D. Cal.) (“Juul
Antitrust”). Joseph Saveri Law Firm, LLP (“JSLF”) is appointed lead counsel in Juul Antitrust.
In setting up the litigation team, Joseph Saveri and JSLF prioritized the creation of a diverse and
inclusive team to work on the case.
5.
Joseph Saveri and JSLF have run the Juul Antitrust case efficiently and have been
inclusive of others in making assignments. JSLF has assigned work in alignment with the skills
and experience level of attorneys and has instituted efficient procedures for reporting time and
expenses incurred by attorneys.
6.
Having worked with Joseph Saveri and JSLF in another complex case, my firm
and I believe they would be an excellent choice to lead In re January 2021 Short Squeeze Trading
Litigation (MDL No. 2989).
7.
JSLF has made no promises nor accommodations to my firm in exchange for my
support for their appointment. I trust that, if the Court appoints JSLF, that work would be
assigned efficiently, and I hope to work with them in this matter.

Case 1:21-md-02989-CMA   Document 252-7   Entered on FLSD Docket 04/26/2021   Page 2 of 3

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I declare under penalty of perjury that the foregoing statements are true and correct,
executed on April 26, 2021 at Minneapolis, MN.

/s/ Catherine K. Smith

    Catherine K. Smith

Case 1:21-md-02989-CMA   Document 252-7   Entered on FLSD Docket 04/26/2021   Page 3 of 3

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