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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
WRITTEN DISCLOSURES FOR PLAINTIFFS’
LEADERSHIP APPLICANT NATALIA M. SALAS
Pursuant to this Honorable Court’s May 5, 2021 Order [ECF No. 286], applicant for
Plaintiffs’ leadership Natalia M. Salas, Esq. hereby submits the following written disclosures:
1. Do you represent any present parties or claimants in this litigation whom you have
represented in any other capacity or in any other court (either currently or within the past
3 years)? If so, please describe.
Response:
No
2. Do you have any financial interest or financial relationship, including but not limited to
as an investor, officer, director, employee, or contractor, in or with any party or
client/claimant involved in this MDL (other than a written retainer or engagement
agreement for a client in these consolidated actions)? If so, please describe.
Response:
No
3. Do you have any financial interest (direct or indirect) in any Short Squeeze claims or
lawsuits filed or registered by any other counsel in this MDL, other than the co- counsel
relationships disclosed in the case chart (see [ECF No. 200-1])? If so, please describe.
Response:
No
4. Do you have any personal relationship (including but not limited to familial or
financial/business) with any party, client, claimant, counsel, or vendor involved in this
MDL? If so, please describe.
Response:
No
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5. Do you or your firm have any financing that is contingent upon this litigation? If yes, the
following questions shall be answered:
Does the litigation funder have any control (direct or indirect, actual or apparent or
implied) over the decision to file or the content of any motions or briefs, or any input
into the decision to accept a settlement offer?
Does the financing (1) create any conflict of interest for counsel, (2) undermine
counsel’s obligation of vigorous advocacy, (3) affect counsel’s independent
judgment, (4) give to the lender any control over litigation strategy or settlement
decisions (as to either the common benefit work done by counsel or work for individual
retained clients), or (5) affect party control of settlement?
Response:
No
6. The applicant shall disclose any other relationship or fact that he or she believes, if known,
would be material to the Court with respect to either an actual conflict of interest or the
appearance of a conflict of interest that the applicant has not already disclosed to the
Court.
Response:
None
Dated: May 14, 2021
Respectfully submitted,
/s/ Natalia M. Salas
Natalia M. Salas
Florida Bar No.: 44895
James L. Ferraro
Florida Bar No.: 381659
James L. Ferraro, Jr.
Florida Bar No.: 107494
THE FERRARO LAW FIRM, P.A.
600 Brickell Avenue, 38th Floor
Miami, Florida 33131
Telephone: (305) 375-0111
Facsimile: (305) 379-6222
Email: nms@ferrarolaw.com
jlf@ferrarolaw.com
jjr@ferrarolaw.com
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AND
Sean A. Burstyn
New York Bar No. 5533120
BURSTYN LAW FIRM PLLC
355 Lexington Avenue, Floor 8
New York, NY 10017
Telephone: (917) 810-8450
Email: sean.burstyn@burstynlaw.com
Counsel for Plaintiffs Juncadella, et al.
CERTIFICATE OF SERVICE
I hereby certify that on May 14, 2021, I electronically filed the forgoing document with the
Clerk of the Court using the electronic case filing system (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/ Natalia M. Salas
Natalia M. Salas, Esq.
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