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A [Proposed] Order Appointing Lead Plaintiff and Approving Selection of Lead Counsel (Document 366-6) 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 July 27, 2021. The two-page proposed order recites that under the PSLRA, 15 U.S.C. § 78u-4(a)(3)(A)(i), a notice issued May 28, 2021 gave potential class members 60 days to move to serve as lead plaintiff, and that on July 27, 2021 Movant Blue Laine-Beveridge moved to be appointed Lead Plaintiff with The Rosen Law Firm as Lead Counsel. It would appoint Movant as Lead Plaintiff under Section 21D(a)(3)(B) of the Exchange Act, approve Rosen Law as Lead Counsel, and leaves the date and the signature line for Hon. Cecilia M. Altonaga blank.

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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

[PROPOSED] ORDER APPOINTING LEAD PLAINTIFF AND APPROVING
SELECTION OF LEAD COUNSEL

WHEREAS, pursuant to the Private Securities Litigation Reform Act of 1995
(“PSLRA”), the lead plaintiff has the sole authority to bring claims under the federal securities
laws;
WHEREAS, pursuant to the PSLRA, 15 U.S.C. § 78u-4(a)(3)(A)(i), on May 28, 2021 a
notice was issued to potential class members informing them of the action and their right to
move to serve as lead plaintiff within 60 days of the date of the issuance of said notice;
WHEREAS, on July 27, 2021, Movant Blue Laine-Beveridge (“Movant”), moved the
Court to: (1) be appointed as Lead Plaintiff; and (2) approve Movant’s selection of The Rosen
Law Firm, P.A. (“Rosen Law”) as Lead Counsel;
WHEREAS, the PSLRA, provides, inter alia, that the most-adequate plaintiff to serve as
lead plaintiff is the movant that has either filed a complaint or has made a motion in response to
a notice and has the largest financial interest in the relief sought by the Class and satisfied the
requirement of Fed. R. Civ. P. 23; and
Case 1:21-md-02989-CMA   Document 366-6   Entered on FLSD Docket 07/27/2021   Page 1 of 2

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WHEREAS, the Court finding that Movant has the largest financial interest in this action
and prima facie satisfies the typicality and adequacy requirements of Fed. R. Civ. P. 23. See 15
U.S.C. § 78u-4(a)(3)(B)(iii)(I);
IT IS HEREBY ORDERED THAT:
APPOINTMENT OF LEAD PLAINTIFF AND LEAD COUNSEL
1.
Pursuant to Section 21D(a)(3)(B) of the Exchange Act, 15 U.S.C. §78u-(a)(3)(B),
Movant is appointed as Lead Plaintiff for the class as Movant has the largest financial interest in
this litigation and otherwise satisfy the requirements of Fed. R. Civ. P. 23.
2.
Pursuant to the PSLRA, Movant has sole authority to bring claims in the
multidistrict litigation under the federal securities laws.
3.
Movant’s choice of counsel is approved, and accordingly, Rosen Law is
appointed Lead Counsel.
4.
Lead Counsel, after being appointed by the Court, shall manage the prosecution of
this litigation for claims under the federal securities laws. Lead Counsel is to avoid duplicative or
unproductive activities and is hereby vested by the Court with the responsibilities that include,
without limitation, the following: (1) to prepare all pleadings; (2) to direct and coordinate the
briefing and arguing of motions in accordance with the schedules set by the orders and rules of
this Court; (3) to initiate and direct discovery; (4) to prepare the case for trial; and (5) to engage
in settlement negotiations on behalf of Lead Plaintiffs and the Class.

SO ORDERED:

Dated  ___________, 2021

____________________________________

HON. CECILIA M. ALTONAGA

UNITED STATES DISTRICT JUDGE
Case 1:21-md-02989-CMA   Document 366-6   Entered on FLSD Docket 07/27/2021   Page 2 of 2

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