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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 OF RACHEL W. FURST,
APPLICANT FOR PLAINTIFFS’ LEADERSHIP
Pursuant to the Court’s Order [ECF No. 286] entered May 5, 2021, the undersigned
attorney, Rachel Wagner Furst, submits the following responses to the Court’s questions outlined
therein:
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
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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
5.
Do you or your firm have any financing that is contingent upon this litigation? If yes, the
following questions shall be answered:
a.
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?
b.
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/ Rachel Wagner Furst
Rachel Wagner Furst
Fla. Bar No. 45155
rwf@grossmanroth.com
GROSSMAN ROTH YAFFA COHEN, P.A.
2525 Ponce de Leon Blvd., Ste 1150
Coral Gables, FL 33134-6040
Telephone: (305) 442-8666
Facsimile: (305) 285-1668
Co-counsel for Plaintiff Sagi Cezana
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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 electronically filed with the Clerk of the Court using CM/ECF. I also certify the foregoing
document is being served this day on all counsel of record in the manner specified via transmission
of Notices of Electronic Filing generated by CM/ECF.
By: /s/ Rachel Wagner Furst
Rachel Wagner Furst
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