Written Disclosures of Lead Counsel Applicant Dennis S. Ellis Pursuant to Dkt. No. 286 — In re January 2021 Short Squeeze Trading Litigation (Dkt. 297, S.D. Fla.)

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Written Disclosures of Lead Counsel Applicant Dennis S. Ellis Pursuant to Dkt. No. 286 (Document 297) in In re January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA (Case No. 21-2989-MDL-ALTONAGA/Torres), in the U.S. District Court for the Southern District of Florida, entered on the FLSD docket May 14, 2021. Browne George Ross O'Brien Annaguey & Ellis LLP, through its partner Dennis S. Ellis, counsel for Robert Days in Days v. Robinhood Markets, Inc. et al., Case No. 1:21-cv-21310-CMA, answers the Court's May 5, 2021 disclosure questions for interim lead counsel applicants. The responses are No to each question on other representations, financial interests and personal relationships, "setting aside Mr. Ellis's partnership with his co-counsel at BGR"; the three-page filing is signed /s/ Dennis S. Ellis with a May 14, 2021 certificate of service by Matthew L. Venezia.

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1817272.1
1

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 OF LEAD COUNSEL APPLICANT DENNIS S. ELLIS
PURSUANT TO DKT. NO. 286
Browne George Ross O’Brien Annaguey & Ellis LLP (“BGR”), by and through its
partner Dennis S. Ellis, counsel for Robert Days in Days v. Robinhood Markets, Inc. et al., Case
No. 1:21-cv-21310-CMA, and applicant for an interim lead counsel position in this MDL, hereby
makes the following written disclosures pursuant to this Court’s Order of May 5, 2021 (Dkt. No.
286).
WRITTEN DISCLOSURES

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.

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.

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.
Case 1:21-md-02989-CMA   Document 297   Entered on FLSD Docket 05/14/2021   Page 1 of 3

1817272.1
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Response:  No.

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, setting aside Mr. Ellis’s partnership with his co-counsel at BGR.

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.

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

/s/ Dennis S. Ellis

DENNIS S. ELLIS
KATHERINE F. MURRAY
CARL ALAN ROTH
MATTHEW L. VENEZIA
BROWN GEORGE ROSS
O’BRIEN ANNAGUEY & ELLIS LLP
2121 Avenue of the Stars, Suite 2800
Los Angeles, California 90067
Telephone:
(310) 274-7100
Facsimile:
(310) 275-5697

Attorneys for Plaintiff Robert Days
Case 1:21-md-02989-CMA   Document 297   Entered on FLSD Docket 05/14/2021   Page 2 of 3

1817272.1
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CERTIFICATE OF SERVICE
I hereby certify that on May 14, 2021, a true and correct copy of the foregoing document
was served on all counsel of record by the CM/ECF system.
Date:  May 14, 2021
/s/Matthew L. Venezia
Matthew L. Venezia

Case 1:21-md-02989-CMA   Document 297   Entered on FLSD Docket 05/14/2021   Page 3 of 3

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