Jeffrey A. Klafter's Written Disclosures in Further Support of His Application for Appointment as an Interim Lead Counsel — In re January 2021 Short Squeeze Trading Litigation (Dkt. 290, S.D. Fla.)

Summary

Jeffrey A. Klafter's (Klafter Lesser LLP) Written Disclosures in Further Support of His Application for Appointment as an 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), in the Southern District of Florida, dated May 11, 2021 as Document 290 (2 pages) under the Court's May 5, 2021 Order (ECF No. 286). Klafter states that the only parties presently represented in this litigation are Plaintiffs Patryk Krasowski and Nick Parker, and that neither Klafter nor the firm has any financial interest or relationship with a party, any financial interest in other Short Squeeze claims beyond the case chart [ECF No. 200-1]. The disclosures add that no financing contingent on the litigation has been or will be obtained and that no fact material to the Court is known.

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Case 1:21-md-02989-CMA Document 290 Entered on FLSD Docket 05/11/2021 Page 1 of 2




                              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

    JEFFREY A. KLAFTER’S WRITTEN DISCLOSURES IN FURTHER SUPPORT OF
      HIS APPLICATION FOR APPOINTMENT AS AN INTERIM LEAD COUNSEL


            Pursuant to the Court’s May 5, 2021 Order (ECF No. 286) requiring each applicant for a

   leadership position in the MDL to provide written responses to certain questions, Jeffrey A.

   Klafter (“Applicant”) hereby responds as follows:

   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.

       The only parties or claimants Applicant presently represents in this litigation are Plaintiffs
       Patryk Krasowski and Nick Parker. Neither Applicant nor his Firm currently represent either
       individual in any other capacity or in any other court nor has Applicant or his firm ever
       represented either individual.

   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 for a client in these consolidated actions)? If so, please
      describe.

       Neither Applicant nor his Firm have any such financial interest or financial relationship.

   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.

       Neither Applicant nor his Firm have any such financial interest.
Case 1:21-md-02989-CMA Document 290 Entered on FLSD Docket 05/11/2021 Page 2 of 2




   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.

      Neither Applicant nor his Firm have any such personal relationship.

   5. Do you or your firm have any financing that it contingent upon this litigation?

      Neither Applicant nor his Firm have obtained or intend to obtain any financing that is
      contingent upon this litigation.

   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.

      Applicant does not have any relationship, and is not aware of any fact, that would constitute
      an actual conflict of interest or the appearance of a conflict of interest concerning this MDL.


   Dated: May 11, 2021                           Respectfully submitted,

                                                 KLAFTER LESSER LLP

                                                 /s/Jeffrey A. Klafter
                                                 Jeffrey A. Klafter
                                                 Amir Alimehri
                                                 2 International Drive, Suite 350
                                                 Rye Brook, NY 10573
                                                 Telephone: (914) 934-9200
                                                 Email: jak@klafterlesser.com
                                                 amir.alimehri@klafterlesser.com



                                  CERTIFICATE OF SERVICE

       I hereby certify that the foregoing document was served on all counsel of record by the
   CM/ECF system today.


   Dated: May 11, 2021                          /s/Jeffrey A. Klafter




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