Stipulated Protective Order — In re January 2021 Short Squeeze Trading Litigation (Document 328-1)
Summary
A Stipulated Protective Order 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 June 29, 2021 as Document 328-1 (28 pages), relating to the Non-Federal Securities Actions. Plaintiffs and Defendants in the cases not governed by the Private Securities Litigation Reform Act of 1995, 15 U.S.C. § 78u-4, stipulate to and petition the Court to enter it. The order defines CONFIDENTIAL and HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY information under Federal Rule of Civil Procedure 26(c), the Gramm-Leach-Bliley Act, HIPAA and the General Data Protection Regulation, routes filings under seal through Local Rule 5.4, and ends with an acknowledgment form appointing a Florida agent for service of process.
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- Date
- 2021-06-29
Cite this document
“Stipulated Protective Order — In re January 2021 Short Squeeze Trading Litigation (Document 328-1).”
Original at archive.org, dated 2021-06-29. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-06-29-covid-era-misc/
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Case 1:21-md-02989-CMA Document 328-1 Entered on FLSD Docket 06/29/2021 Page 1 of 28
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 the Non-Federal Securities Actions
STIPULATED PROTECTIVE ORDER
1. PURPOSES AND LIMITATIONS
Disclosure and discovery activity in the above-captioned action (the “Action”) are likely
to involve production of confidential, proprietary, or private information for which special
protection from public disclosure and from use for any purpose other than prosecuting or
defending this Action may be warranted. Accordingly, Plaintiffs and Defendants in the cases that
are not governed by the Private Securities Litigation Reform Act of 1995, 15 U.S.C. § 78u-4, et
seq. (collectively, the “Parties”), by and through their undersigned counsel, having met and
conferred, hereby stipulate to and petition the Court to enter the following Stipulated Protective
Order (the “Order”).
The Parties acknowledge, as set forth in Section 12.3, below, that the procedures for
filing any Protected Material, as defined herein, shall be governed by Local Rule 5.4, which sets
forth the procedures that must be followed and the standards that will be applied when a party
seeks permission from the court to file material under seal.
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2. DEFINITIONS
2.1 Challenging Party: A Party or Non-Party that challenges the designation of
information or items under this Order.
2.2 “CONFIDENTIAL” Information or Items: Information (regardless of how it is
generated, stored or maintained) or tangible things that are prohibited from disclosure by statute
or qualify for protection under Federal Rule of Civil Procedure 26(c), including but not limited
to, information or tangible things that constitute trade secrets, proprietary business information,
competitively sensitive information, personal or business financial information, or other
information prohibited from disclosure under applicable federal, state, or foreign data protection
laws, including, without limitation, the Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq.
(financial information), the Health Insurance Portability and Accountability Act (HIPAA) and
the regulations thereunder, 45 CFR Part 160 and Subparts A and E of Part 164 (medical
information), and the General Data Protection Regulation (GDPR), 2016/679 of the European
Parliament and of the Council of 27 April 2016, and repealing Directive 95/46/EC (EU personal
data).
2.3 Counsel (without qualifier): Outside Counsel of Record and In-House Counsel (as
well as their support staff).
2.4 Designating Party: A Party or Non-Party that designates information or items that
it produces in disclosures or in responses to discovery requests as “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
2.5 Disclosure or Discovery Material: All items or information, regardless of the
medium or manner in which it is generated, stored, or maintained (including, among other things,
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testimony, transcripts, and tangible things), that are produced or generated in disclosures or
responses to discovery requests in this Action.
2.6 Expert: A person with specialized knowledge or experience in a matter pertinent
to the Action who has been retained by a Party or its Counsel to serve as an expert witness or as
a consultant in this Action (as well as his or her employees and staff).
2.7 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information or
Items: Extremely sensitive “Confidential Information or Items” that a Party determines in good
faith to consist of highly proprietary business information, which should not be disclosed to
another Party’s or Non-Party’s operational and business personnel, including, without limitation,
trade secrets, the disclosure of which to another Party or Non-Party would create a substantial
risk of serious harm that could not be reasonably avoided by less restrictive means absent undue
burden.
2.8 Federal Securities Actions: The cases within the Action governed by the Private
Securities Litigation Reform Act of 1995, 15 U.S.C. § 78u-4 et seq.
2.9 In-House Counsel: Attorneys who are employees of a Party (or any affiliated
entity or subsidiary of the Party) to this Action, or their support staff. In-House Counsel does not
include Outside Counsel of Record or any other outside counsel of a Party.
2.10 Non-Party: Any natural person, partnership, corporation, association, or other
legal entity not named as a Party to this Action.
2.11 Outside Counsel of Record: Attorneys who are not employees of a Party to this
action but are retained to represent or advise a Party to this action and have appeared in this
Action on behalf of that Party or are affiliated with a law firm which has appeared on behalf of
that Party.
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2.12 Party: Any named party to this action.
2.13 Producing Party: A Party or Non-Party that produces Disclosure or Discovery
Material in this action.
2.14 Professional Vendors: Persons or entities engaged by a Party(ies) or engaged by
Outside Counsel of Record that provide litigation support services (e.g., photocopying,
videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or
retrieving data in any form or medium) and their employees and subcontractors.
2.15 Protected Material: Any Disclosure or Discovery Material that is designated as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
2.16 Receiving Party: A Party that receives Disclosure or Discovery Material from a
Producing Party.
3. SCOPE
The protections conferred by this Order cover not only Protected Material (as defined
above), but also all of the following, which shall also be deemed Protected Material: (1) any
information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or
compilations of Protected Material; and (3) any testimony, conversations, or presentations by
Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at
trial shall be governed by a separate agreement or order. However, the protections conferred by
this Order do not cover the following information: (a) any information that is in the public
domain at the time of disclosure to a Receiving Party or becomes part of the public domain after
its disclosure to a Receiving Party as a result of publication not involving a violation of this
Order, including becoming part of the public record through trial or otherwise; and (b) any
information known to the Receiving Party prior to the disclosure unless the Receiving Party is
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subject to an existing and separate duty of confidentiality or obtained by the Receiving Party
after the disclosure from a source who obtained the information lawfully and under no obligation
of confidentiality to the Designating Party.
4. DURATION
Even after final disposition (as defined herein) of this Action, the confidentiality
obligations imposed by this Order shall remain in effect until a Designating Party agrees
otherwise in writing or a court order otherwise directs. Final disposition shall be deemed to be
the later of: (1) dismissal of all claims and defenses in this action, with or without prejudice; and
(2) final judgment herein after the completion and exhaustion of all appeals, rehearings, remands,
trials, or reviews of this Action, including the time limits for filing any motions or applications
for extension of time pursuant to applicable law.
5. DESIGNATING PROTECTED MATERIAL
5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party
or Non-Party that designates information or items for protection under this Order must take care
to limit any such designation to specific material that qualifies under the appropriate standards.
To the extent it is practicable to do so, the Designating Party must designate for protection only
those parts of material, documents, items, or oral or written communications that qualify.
Designations that are shown to be clearly unjustified or that have been made for an
improper purpose (e.g., to unnecessarily encumber or obstruct the case development process or
to impose unnecessary expenses and burdens on another Party or Non-Party) may expose the
Designating Party to sanctions pursuant to applicable law.
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If it comes to a Designating Party’s attention that information or items that it designated
for protection do not qualify for protection, that Designating Party must promptly notify all other
Parties that it is withdrawing the designation.
5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
designated before the material is disclosed or produced.
Designation in conformity with this Order requires:
(a) For information in documentary form (e.g., paper or electronic documents,
but excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing
Party affix the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
EYES ONLY” to each page that contains Protected Material except as otherwise set forth in
other orders adopted in this Action.
A Party or Non-Party that makes original documents or materials available for
inspection need not designate them for protection until after the Receiving Party has indicated
which material it would like copied and produced. During the inspection and before the
designation, all of the material made available for inspection shall be deemed
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” as
determined by the Producing Party. After the Receiving Party has identified the documents it
wants copied and produced, the Producing Party must determine which documents, or portions
thereof, qualify for protection under this Order. Then, before producing the specified documents,
the Producing Party must affix the appropriate legend (“CONFIDENTIAL” or “HIGHLY
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY”) to each page that contains Protected
Material.
(b) For testimony given in deposition or in other pretrial or trial proceedings: that the
Designating Party identify on the record or up to 30 days afterwards (or a period otherwise
agreed upon) all Protected Material, including specifying whether any portions of the transcript
or the entire transcript shall be treated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY.”
Parties shall give the other Parties notice if they reasonably expect a deposition,
hearing, or other proceeding to include Protected Material so that the other Parties can ensure
that only authorized individuals who have signed the “Acknowledgment and Agreement to Be
Bound” (Exhibit A), if required by this Order, are present at those proceedings. The use of a
document as an exhibit at a deposition shall not in any way affect its designation as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
Transcripts containing Protected Material shall have an obvious legend on the title page that the
transcript contains Protected Material, and the title page shall be followed by a list of all pages
(including line numbers as appropriate) that have been designated as Protected Material and the
level of protection being asserted by the Designating Party. The Designating Party shall inform
the court reporter of these requirements. Any transcript that is prepared before the expiration of a
30-day (or otherwise agreed upon) period for witness review and designation shall be treated
during that period as if it had been designated “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (as determined by the Producing Party) in its
entirety unless otherwise agreed. After the expiration of that period, the transcript shall be treated
only as actually designated. If, after the 30-day period (or otherwise agreed upon), no Party has
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designated some or all of the deposition transcript as Protected Material under this Order, the
entire deposition, or those portions of the deposition not designated as Protected Material, will no
longer be considered confidential.
(c) For information produced in some form other than documentary and for
any other tangible items: that the Producing Party affix in a prominent place on the exterior of
the container or containers in which the information or item is stored, or in some other
reasonable manner, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY.” If only a portion or portions of the information or item warrant
protection, the Producing Party, to the extent practicable, shall identify the protected portion(s)
and specify the level of protection being asserted.
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
designate qualified information or items does not, standing alone, waive the Designating Party’s
right to secure protection under this Order for such material. Upon timely correction of a
designation, the Receiving Party must make reasonable efforts to assure that the material is
treated in accordance with the provisions of this Order.
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
confidentiality at any time consistent with any scheduling orders to be entered by the Court.
Unless a prompt challenge to a Designating Party’s confidentiality designation is necessary to
avoid foreseeable, substantial unfairness, unnecessary economic burdens, or a significant
disruption or delay of the Action, a Party does not waive its right to challenge a confidentiality
designation by electing not to mount a challenge promptly after the original designation is
disclosed.
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6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
process by providing written notice of each designation it is challenging and describing the basis
for each challenge. To avoid ambiguity as to whether a challenge has been made, the written
notice must recite that the challenge to confidentiality is being made in accordance with this
specific paragraph of the Order. The Designating Party shall thereafter, within fourteen (14)
calendar days (or as otherwise agreed upon), respond to such challenge in writing by either:
(1) agreeing to remove the designation; or (2) stating the reasons to maintain such designation.
Should the dispute remain unresolved, the Parties shall attempt to resolve each challenge in good
faith and must begin the process by conferring directly within fourteen (14) calendar days of the
date of service of the Designating Party’s response. In conferring, the Challenging Party must
explain the basis for its belief that the confidentiality designation was not proper and must give
the Designating Party an opportunity to review the designated material, to reconsider the
circumstances, and, if no change in designation is offered, to explain the basis for the chosen
designation. A Challenging Party may proceed to the next stage of the challenge process only if
it has engaged in this meet and confer process first or establishes that the Designating Party is
unwilling to participate in the meet and confer process in a timely manner. Nothing in this
paragraph precludes the Parties from agreeing to reasonable extensions at any step of the process
described herein.
6.3 Judicial Intervention. If the Parties cannot resolve a challenge without Court
intervention through exhaustion of the procedures in paragraph 6.2, the Challenging Party may
file a motion challenging a confidentiality designation at any time following completion of the
procedure in paragraph 6.2 if there is good cause for doing so, including a challenge to the
designation of a deposition transcript or any portions thereof. Any motion brought pursuant to
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this provision must be accompanied by certification pursuant to Local Rule 7.1 certifying that the
movant has complied with the meet and confer requirements of this District.
Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
unnecessary expenses and burdens on another Party or Non-Party) may expose the Challenging
Party to sanctions pursuant to applicable law. All Parties shall continue to afford the material in
question the level of protection to which it is entitled under the Producing Party’s designation
until the court rules on the challenge.
7. ACCESS TO AND USE OF PROTECTED MATERIAL
7.1 Basic Principles. A Receiving Party may use Disclosure or Discovery Material
that is disclosed or produced by another Party or by a Non-Party in connection with this Action
only for prosecuting, defending, or attempting to settle this Action, and shall not use Disclosure
or Discovery Material for any other purpose whatsoever, including without limitation any other
litigation or any business or competitive purpose or function. Protected Material may be
disclosed only to the categories of persons and under the conditions described in this Order.
When the Action has been terminated, a Receiving Party must comply with the provisions of
section 13 below (FINAL DISPOSITION).
Disclosure or Discovery Material shall not be shared with any Plaintiffs or counsel for the
same in the Federal Securities Actions absent further order of the Court or agreement between
the Parties and Plaintiffs or counsel for the same in the Federal Securities Actions.
Disclosure or Discovery Material must be stored and maintained by a Receiving Party,
including any Counsel, Professional Vendor, Expert or other party engaged by the Receiving
Party in this Action, at a location and in a secure manner that ensures that access is limited to the
persons authorized under this Order. The Producing Party and Receiving Party shall agree on the
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level of protection expected in the storage and transfer of its information provided that such level
of protection is not greater than that reasonably used by the Producing Party for such information
in the ordinary course of the Producing Party’s business. In the event the Receiving Party,
including any Counsel, Professional Vendor, Expert or other party engaged by the Receiving
Party in this Action, experiences a data breach that affected or potentially affected Protected
Material, it shall (to the extent permitted by law) as soon as practicable notify the Producing
Party of the same, and shall cooperate with the Producing Party to address and remedy the
breach, subject to the Producing Party’s reasonable instructions. Nothing herein shall constitute
a waiver of legal rights and defenses regarding the protection of information from unauthorized
disclosure.
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
ordered by the Court or permitted in writing by the Designating Party, a Receiving Party may
disclose any information or item designated “CONFIDENTIAL” only to:
(a) The Receiving Party’s Outside Counsel of Record in this action, as well as
employees of said Outside Counsel of Record to whom it is reasonably
necessary to disclose the information for this Action;
(b) The officers, directors, and employees (including In-House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this
Action;
(c) Experts retained by the Receiving Party to whom disclosure is reasonably
necessary for this Action and who have signed the Acknowledgment and
Agreement to Be Bound (Exhibit A), unless otherwise agreed in writing
by the Designating Party or ordered by the Court, and provided that no
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disclosure shall be made to any Expert who is retained by, employed by,
or will be employed within six months by, a known competitor of the
Producing Party;
(d) Insurers of the Receiving Party to whom disclosure is reasonably
necessary for coverage-related matters and who have signed the
Acknowledgment and Agreement to Be Bound (Exhibit A);
(e) The Court, Magistrate Judge and their personnel; and any appellate court
or other court (and their personnel) before which the Parties appear in this
Action;
(f) Court reporters, videographers, and their staff;
(g) Professional jury or trial consultants, mock jurors, and Professional
Vendors to whom disclosure is reasonably necessary for this Action and
who have signed the “Acknowledgment and Agreement to Be Bound”
(Exhibit A);
(h) During their depositions, witnesses in the action to whom disclosure is
reasonably necessary and who have signed the “Acknowledgment and
Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the
Designating Party or ordered by the Court. Pages of transcribed deposition
testimony or exhibits to depositions that reveal Protected Material must be
separately bound by the court reporter and may not be disclosed to anyone
except as permitted under this Order;
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(i) The author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the
information;
(j) Special masters or discovery referees who may be appointed by the Court;
(k) Mediators or settlement officers, and their supporting personnel, subject to
the mutual agreement of the Parties engaged in settlement discussions who
have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
A);
(l) Any other person as to whom the Designating Party has consented to
disclosure in advance; and
(m) Such other persons as the Parties may agree or may be ordered by the
Court.
7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
Information or Items. Unless otherwise ordered by the court or permitted in writing by the
Designating Party, information or items designated “HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY” may only be disclosed to:
(a) The Receiving Party’s Outside Counsel of Record in this action, as well as employees
of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information
for this Action;
(b) In-House Counsel of the Receiving Party who is actively managing this Action for the
Receiving Party and who does not have material substantive input into competitive decision-
making;
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(c) Experts of the Receiving Party to whom disclosure is reasonably necessary for this
Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A)
unless otherwise agreed in writing by the Designating Party or ordered by the Court, and
provided that no disclosure shall be made to any Expert who is retained by, employed by, or will
be employed within six months by, a known competitor of the Producing Party;
(d) The Court, Magistrate Judge and their personnel; and any appellate court or other
court (and their personnel) before which the Parties appear in this action;
(e) Court reporters, videographers, and their staff,
(f) Professional jury or trial consultants, and Professional Vendors to whom disclosure is
reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement
to Be Bound” (Exhibit A); and
(g) The author or recipient of a document containing the information or a custodian or
other person who otherwise possessed or knew the information;
(h) Special masters or discovery referees who may be appointed by the Court; and
(i) Mediators or settlement officers, and their supporting personnel, subject to the mutual
agreement of the Parties engaged in settlement discussions, and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A).
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
OTHER LITIGATION
If a Party is served with a subpoena, demand or a court order issued in another litigation,
investigation or other regulatory proceeding that compels disclosure of any information or items
designated in this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY,” that Party must:
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(a) Promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order;
(b) Promptly notify in writing the party who caused the subpoena or order to
issue in the other litigation that some or all of the material covered by the
subpoena or order is subject to this Order. Such notification shall include a
copy of this Order; and
(c) Cooperate with respect to all reasonable procedures sought to be pursued
by the Designating Party whose Protected Material may be affected to
alert the interested parties to the existence of this Order and to afford the
Designating Party in this Action an opportunity to try to protect its
confidentiality interests in the court from which the subpoena or order
issued.
If the Designating Party timely seeks a protective order, the Party served with the
subpoena or court order shall not produce any information designated in this Action as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” before a
determination by the court from which the subpoena or order issued, unless the Party has
obtained the Designating Party’s permission. The Designating Party shall bear the burden and
expense of seeking protection in that court of its confidential material—and nothing in these
provisions should be construed as authorizing or encouraging a Receiving Party in this action to
disobey a lawful directive from another court, or violate any other applicable federal or state law,
rules or regulations.
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9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN
THIS ACTION
(a) The terms of this Order are applicable to information produced by a Non-
Party in this action and designated as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information
produced by Non-Parties in connection with this Action is protected by the
remedies and relief provided by this Order. Nothing in these provisions
should be construed as prohibiting a Non-Party from seeking additional
protections.
(b) In the event that a Party is required, by a valid discovery request, to
produce a Non-Party’s confidential information in its possession, and the
Party is subject to an agreement with the Non-Party not to produce the
Non-Party’s confidential information, then the Party shall:
(1) Promptly notify in writing the Requesting Party and the
Non-Party that some or all of the information requested is
subject to a confidentiality agreement with a Non-Party;
(2) Promptly provide the Non-Party with a copy of this Order,
the relevant discovery request(s), and a reasonably specific
description of the information requested; and
(3) Make the information requested available for inspection by
the Non-Party.
(c) If the Non-Party fails to object or seek a protective order from this Court
within fourteen (14) days of receiving the notice and accompanying
information, the Receiving Party may produce the Non-Party’s Protected
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Material responsive to the discovery request. If the Non-Party timely seeks
a protective order, the Receiving Party shall not produce any information
in its possession or control that is subject to the confidentiality agreement
with the Non-Party before a determination by the Court. Absent a Court
order to the contrary, the Non-Party shall bear the burden and expense of
seeking protection in this Court of its Protected Material.
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
Material to any person or in any circumstance not authorized under this Order, the Receiving
Party must immediately (a) notify in writing the Designating Party of the unauthorized
disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material,
(c) inform the person or persons to whom unauthorized disclosures were made of all the terms of
this Order, and (d) request such person or persons to execute the “Acknowledgment and
Agreement to Be Bound” that is attached hereto as Exhibit A.
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
11.1 When a Producing Party gives notice to Receiving Parties that certain
inadvertently produced material is subject to a claim of privilege or other protection, the
obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure
26(b)(5)(B).
11.2 Any inadvertent production of privileged or otherwise protected material that
satisfies Federal Rule of Evidence 502(b) shall not be deemed to have waived the privilege or
protection. Pursuant to Federal Rules of Evidence 502(d) and (e), the Parties have entered or will
have entered into a separate Stipulated Rule 502(d) and Privileged Materials Order, which sets
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forth the procedure concerning the inadvertent production of privileged or otherwise protected
material.
12. MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any Party to
seek its modification by the Court in the future.
12.2 Right to Assert Objections. By stipulating to the entry of this Order, no Party is
waiving any objections to the production of documents or information on any basis, including,
without limitation, the right to object to production of information and/or documents that a Party
contends are subject to any confidentiality interest of themselves, or third parties, such that
disclosure should be precluded notwithstanding the protections of this Order (e.g., in the event of
a contractual confidentiality provision between the Producing Party and a third party). In the
event such a confidentiality interest affects the production of requested material, the Producing
Party shall endeavor to resolve any issue precluding production (e.g., seek to obtain the consent
of the third party to produce the Protected Material notwithstanding a confidentiality provision).
Similarly, no Party waives any right to object on any ground to use in evidence of any of the
material covered by this Order.
12.3 Filing Protected Material. Without written permission from the Designating Party
or a court order secured after appropriate notice to all interested persons, a Party may not file in
the public record in this Action any Protected Material. A Party that seeks to file under seal any
Protected Material must comply with Local Rule 5.4. The extent of Protected Material included
within any such proposed filings under seal shall be limited to the particular items of information
and/or portions of documents that are reasonably necessary to the filing. Pursuant to Local Rule
5.4, the proposed sealed material shall not be filed unless the Court grants the motion to file
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under seal. The motion to file under seal shall specify the proposed duration of the requested
sealing. If, prior to the issuance of a ruling on the motion to file under seal, the moving party
elects or is required to publicly file a pleading, motion, memorandum, or other document that
attaches or reveals the content of the proposed sealed material, then the moving party must redact
from the public filing all content that is the subject of the motion to file under seal.
12.4 No Effect on Designating Party. This Order shall not apply to and shall not limit
in any way any Designating Party’s use, disclosure or handling of its own Protected Material.
12.5 Non-Public, Personally Identifiable Information. Producing Party may partially or
wholly redact the nonpublic, personally identifiable information from any Disclosure or
Discovery Material that may contain it, including for example customer names, Social Security
numbers, account numbers, telephone numbers, mailing addresses, and email addresses.
13. FINAL DISPOSITION
Within 60 days after the final disposition of this action, as defined in Section 4
(Duration), each Receiving Party must return all Protected Material to the Producing Party or
destroy such material. As used in this subdivision, “all Protected Material” includes all copies,
abstracts, compilations, summaries, and any other format reproducing or capturing any of the
Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party
must submit a written certification to the Producing Party (and, if not the same person or entity,
to the Designating Party) by the 60 day deadline that (1) identifies (by category, where
appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the
Receiving Party has not retained any copies, abstracts, compilations, summaries or any other
format reproducing or capturing any of the Protected Material. Notwithstanding this provision,
Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
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and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
reports, attorney work product, and consultant and expert work product, even if such materials
contain Protected Material. Any such archival copies that contain or constitute Protected
Material remain subject to this Protective Order as set forth in Section 4 (Duration). Nothing in
this provision, however, should be construed as requiring the Receiving Party to destroy any
material that it is obligated to maintain under applicable laws and regulations.
IT IS SO STIPULATED, THROUGH UNDERSIGNED COUNSEL OF RECORD.
Dated: June 29, 2021 Respectfully submitted,
/s/ Peter Safirstein /s/ Natalia M. Salas
SAFIRSTEIN METCALF LLP THE FERRARO LAW FIRM, P.A.
Peter Safirstein (NY SBN 2044550) Natalia M. Salas (FBN 44895)
Elizabeth S. Metcalf (NY SBN 4644431) James L. Ferraro (FBN 381659)
1345 Avenue of the Americas, 2nd Floor James Ferraro, Jr. (FBN 107494)
New York, NY 10105 Bruce S. Rogow (FBN 067999)
Tel: (212) 201-5845 Sean A. Burstyn (FBN 1028778)
psafirstein@safirsteinmetcalf.com 600 Brickell Avenue, Suite 3800
emetcalf@safirsteinmetcalf.com Miami, FL 33131
Tel: (305) 375-0111
nms@ferrarolaw.com
jlf@ferrarolaw.com
jjr@ferrarolaw.com
bsr@ferrarolaw.com
sab@ferrarolaw.com
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/s/ Joseph R. Saveri /s/ Frank Schirripa
JOSEPH SAVERI LAW FIRM, LLP HACH ROSE SCHIRRIPA &
Joseph R. Saveri (CA SBN 130064) CHEVERIE LLP
Steven N. Williams (CA SBN 175489) Frank Schirripa (NY SBN 4103750)
Anupama K. Reddy (CA SBN 324873) Kathryn Hettler (NY SBN 5126065)
Christopher K.L Young (CA SBN 318371) Seth Pavsner (NY SBN 4969689)
601 California Street, Suite 1000 112 Madison Ave, 10th Floor
San Francisco, CA 94108 New York, New York 10016
Tel: (415) 500-6800 Tel: (212) 213-8311
jsaveri@saverilawfirm.com fschirripa@hrsclaw.com
swilliams@saverilawfirm.com khettler@hrsclaw.com
areddy@saverilawfirm.com SPavsner@hrsclaw.com
cyoung@saverilawfirm.com
Plaintiffs’ Lead Counsel
/s/ Rachel W. Furst
GROSSMAN ROTH YAFFA COHEN, P.A.
Rachel W. Furst (FBN 45155)
2525 Ponce de Leon Blvd Ste 1150
Coral Gables, FL 33134-6040
Tel: 305-442-8666
rwf@grossmanroth.com
Plaintiffs’ Liaison Counsel
/s/ Gabriel Amin Assaad /s/ Jeffrey A. Klafter
MCDONALD WORLEY, P.C. KLAFTER LESSER, LLP
Gabriel Amin Assaad (TX SBN 24076189) Jeffrey A. Klafter (NY SBN 1662428)
Matthew Yezierski (TX SBN 24076989) Amir Alimehri (NY SBN 5631262)
McDonald Worley Two International Drive Suite 350
1770 St. James Place, Suite 100 Rye Brook, NY 10573
Houston, TX 77056 Tel: (914) 934-9200
Tel: (713) 523-5500 jak@klafterlesser.com
gassaad@mcdonaldworley.com amir.alimehri@klafterlesser.com
matt@mcdonaldworley.com
don@mcdonaldworley.com
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/s/ Maurice D. Pessah /s/ Roy T. Willey, IV
Pessah Law Group, PC ANASTOPOULO LAW FIRM
Maurice D. Pessah (CA SBN 275955) Roy T. Willey, IV (SC SBN 101010)
Michael Morris-Nussbaum (CA SBN Eric M. Poulin (SC SBN 100209)
317146) Blake Abbott (SC SBN 104423)
Summer E. Benson (CA SBN 326398) 32 Ann Street
Jason Sunshine (CA SBN 336062) Charleston, SC 29403
Stuart Neil Chelin (CA SBN 320357) Tel: (843) 614-8888
661 N Harper Avenue, Suite 208 roy@akimlawfirm.com
West Hollywood, California 90048 eric@akimlawfirm.com
Tel: (310) 772-2261 blake@akimlawfirm.com
maurice@pessahgroup.com
mmnussbaum@pessahgroup.com
sbenson@pessahgroup.com
jsunshine@pessahgroup.com
stuart@chelinlaw.com
Plaintiffs’ Steering Committee
/s/ Kevin J. Orsini /s/ Marc De Leeuw
HUNTON ANDREWS KURTH LLP SULLIVAN & CROMWELL LLP
Samuel A. Danon (FBN 892671) Marc De Leeuw
Gustavo Javier Membiela (FBN 513555) 125 Broad Street
María Castellanos Alvarado (FBN 116545) New York, New York 10004
333 S.E. 2 Avenue, Suite 2400 Telephone: (212) 558-4000
Miami, FL 33131 Facsimile: (212) 558-3588
Telephone: (305) 810-2500 deleeuwm@sullcrom.com
Facsimile: (305) 810-2460
sdanon@huntonak.com SULLIVAN & CROMWELL LLP
gmembiela@huntonak.com Adam S. Paris
mcastellanos@hunton.com 1888 Century Park East
Los Angeles, CA 90067
CRAVATH, SWAINE & MOORE LLP Telephone: (310) 712-6600
Antony L. Ryan Facsimile: (310) 712-8800
Kevin J. Orsini parisa@sullcrom.com
Brittany L. Sukiennik
New York, NY 10019 SHOOK, HARDY & BACON L.L.P.
Telephone: (212) 474-1000 Jennifer A. McLoone (Fla. Bar No. 0029234)
Facsimile: (212) 474-3700 Citigroup Center Suite 3200
aryan@cravath.com 201 South Biscayne Boulevard
korsini@cravath.com Miami, Florida 33131
bsukiennik@cravath.com Telephone: 305-358-5171
Counsel for Defendants Robinhood Counsel for Defendant Ally Financial, Inc.
Financial LLC, Robinhood Securities,
LLC, Robinhood Markets, Inc. and
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Robinhood Crypto, LLC
/s/ Christopher D. Kercher
QUINN EMANUEL URQUHART & SULLIVAN,
/s/ Justina K. Sessions LLP
WILSON SONSINI GOODRICH & ROSATI Christopher D. Kercher
Justina K. Sessions 51 Madison Avenue, 22nd Floor,
One Market Plaza New York, New York, 10010
Spear Tower, Suite 3300 Telephone: (212) 849-7000
San Francisco, California 94105 Facsimile: (212) 849-7100
Telephone: (415) 947-2197 christopherkercher@quinnemanuel.com
Facsimile: (415) 947-2099
jsessions@wsgr.com QUINN EMANUEL URQUHART & SULLIVAN,
LLP
WILSON SONSINI GOODRICH & ROSATI Marina E. Lev
Kenneth R. O’Rourke 865 South Figueroa Street, 10th Floor
Brendan J. Coffman Los Angeles, California 90017
1700 K Street NW, 5th Floor Telephone: (213) 443-3000
Washington, DC 20006 Facsimile: (213) 443-3100
Telephone: (202) 973-8800 marinalev@quinnemanuel.com
Facsimile: (202) 973-8899
korourke@wsgr.com BARTLIT BECK LLP
bcoffman@wsgr.com Adam L. Hoeflich
Dawson Robinson
Counsel for Defendant Open to the Public 54 W. Hubbard St., Ste. 300
Investing, Inc. Chicago, IL 60654
Telephone: (312) 494-4400
Facsimile: (312) 494-4440
/s/ Daniel J. Kramer adam.hoeflich@bartlitbeck.com
PAUL, WEISS, RIFKIND, WHARTON & dawson.robinson@bartlitbeck.com
GARRISON LLP
Daniel J. Kramer Counsel for Defendants Citadel Enterprise
Richard Tarlowe Americas, LLC and Citadel Securities LLC
1285 Avenue of the Americas
New York, NY 10019
Telephone: (212) 373-3000 /s/ Harry A. Olivar, Jr.
dkramer@paulweiss.com QUINN EMANUEL URQUHART & SULLIVAN,
rtarlowe@paulweiss.com LLP
Harry A. Olivar, Jr.
Counsel for Defendant Point72 Asset Korinna S. Anderson
Management, L.P. 865 S. Figueroa Street, 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
/s/ Jason J. Mendro Facsimile: (213) 443-3100
GIBSON, DUNN & CRUTCHER LLP harryolivar@quinnemanuel.com
Jason J. Mendro korinnaanderson@quinnemanuel.com
Russell B. Balikian
1050 Connecticut Ave., NW QUINN EMANUEL URQUHART & SULLIVAN,
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Washington, DC 20036 LLP
Telephone: (202) 887-3726 Linda J. Brewer
jmendro@gibsondunn.com 50 California Street, 22nd Floor
rbalikian@gibsondunn.com San Francisco, California 94111-4788
Telephone: (415) 875-6600
GIBSON, DUNN & CRUTCHER LLP Facsimile: (415) 875-6700
Theodore J. Boutrous, Jr. lindabrewer@quinnemanuel.com
333 South Grand Avenue
Los Angeles, CA 90071 Counsel for Defendant Sequoia Capital
Telephone: (213) 229-7804 Operations LLC
tboutrous@gibsondunn.com
Counsel for Defendants Charles Schwab & /s/ Shari Ross Lahlou
Co., Inc.; TD Ameritrade, Inc.; TD DECHERT LLP
Ameritrade Clearing, Inc.; TD Ameritrade Shari Ross Lahlou
Holding Corporation; and The Charles 1900 K Street, NW
Schwab Corporation Washington, D.C. 20006
Telephone: (202) 261-3300
Facsimile: (202) 261-3333
/s/ Robin Nunn shari.lahlou@dechert.com
MORGAN, LEWIS & BOCKIUS LLP
Robin Nunn Dechert LLP
101 Park Avenue Andrew J. Levander
New York, NY 10178-0060 Three Bryant Park
Telephone: (212) 309-6000 1095 Avenue of the Americas
Facsimile: (212) 309-3001 New York, NY 10036
robin.nunn@morganlewis.com Telephone: (212) 698 3500
Facsimile: (212) 698 3599
Counsel for Defendant Stash Financial, andrew.levander@dechert.com
Inc.
DECHERT LLP
Steven Bizar
/s/ Peter W. Homer Cira Centre
HOMER BONNER JACOBS ORTIZ, P.A. 2929 Arch Street
Peter W. Homer (Florida Bar No. 291250) Philadelphia, PA 19104
1200 Four Seasons Tower Telephone: (215) 994 4000
1441 Brickell Avenue Facsimile: (215) 994 2222
Miami, Florida 33131 steven.bizar@dechert.com
Telephone: (305) 350-5139
Facsimile: (305) 372-2738 Counsel for Defendant Interactive Brokers
phomer@homerbonner.com LLC
DAVIS POLK & WARDWELL LLP
Brian S. Weinstein /s/ Thomas E. Redburn, Jr.
Gina Cora LOWENSTEIN SANDLER LLP
Janet Jones-Duffey Thomas E. Redburn, Jr.
450 Lexington Avenue Maya Ginsburg
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New York, New York 10017 1251 Avenue of the Americas
Telephone: (212) 450-4000 New York, NY 10020
Facsimile: (212) 701-5972 Telephone: (212) 262-6700
brian.weinstein@davispolk.com Facsimile: (973) 597-2457
gina.cora@davispolk.com tredburn@lowenstein.com
janet.jones-duffey@davispolk.com mginsburg@lowenstein.com
Counsel for Defendants Morgan Stanley LOWENSTEIN SANDLER LLP
Smith Barney LLC, E*TRADE Financial Zarema Arutyunova Jaramillo
Corporation, E*TRADE Securities LLC 2200 Pennsylvania Avenue, NW
and E*TRADE Financial Holdings, LLC Washington, DC 20037
Telephone: (202) 753-3800
/s/ Thomas G. Haskins, Jr. Facsimile: (202) 753-3838
BARNES & THORNBURG LLP zjaramillo@lowenstein.com
Thomas G. Haskins, Jr.
Allison Gerard Counsel for Defendant Melvin Capital
2121 N. Pearl Street, Suite 700 Management LP and Candlestick Capital
Dallas, TX 75201 Management LP
Telephone: (214) 258-4200
Facsimile: (214) 258-4199
thaskins@btlaw.com /s/ Patrick Gibbs
allison.gerard@btlaw.com COOLEY LLP
Patrick Gibbs
BARNES & THORNBURG LLP Brett De Jarnette
Kevin Rising Rebecca Ferrari
2029 Century Park E, Suite 300 3175 Hanover Street
Los Angeles, CA 90067-2904 Palo Alto, CA 94304-1130
Telephone: (310) 284-3888 Telephone: (650) 843-5000
Facsimile: (310) 284-3894 Facsimile: (650) 849-7400
krising@btlaw.com pgibbs@cooley.com
bdejarnette@cooley.com
BARNES & THORNBURG LLP rferrari@cooley.com
Paul Olszowka
One North Wacker Drive, Suite 4400 Counsel for Defendant M1 Finance, LLC
Chicago, IL 60606-2833
Telephone: (312) 214-5612
Facsimile: (312) 759-5646 /s/ Jack E. Pace III
paul.olszowka@btlaw.com WHITE & CASE LLP
Jack E. Pace III
Counsel for Defendants Dough, LLC and Bryan D. Gant
tastyworks, Inc. 1221 Avenue of the Americas
New York, NY 10020-1095
Telephone: (212) 819-8200
/s/ Alfred C. Pfeiffer, Jr. Facsimile: (212) 354-8113
LATHAM & WATKINS LLP jpace@whitecase.com
Alfred C. Pfeiffer, Jr. bgant@whitecase.com
Belinda S Lee
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505 Montgomery Street, Suite 2000 WHITE & CASE LLP
San Francisco, CA 94111-6538 J. Mark Gidley
Telephone: (415) 391-0600 701 Thirteenth Street, NW
Facsimile: (415) 395-8095 Washington, DC 20005-3807
al.pfeiffer@lw.com Telephone: (202) 626-3600
belinda.lee@lw.com Facsimile: (202) 639-9355
mgidley@whitecase.com
Counsel for Defendants Square, Inc. and
Cash App Investing LLC WHITE & CASE LLP
Angela Daker
Southeast Financial Center
/s/ Gregory M. Boyle 200 South Biscayne Boulevard, Suite 4900
JENNER & BLOCK, LLP Miami, FL 33131-2352
Gregory M. Boyle Telephone: (305) 995-5297
353 North Clark Street Facsimile: (305) 358-5744
Chicago, Illinois 60654-3456 adaker@whitecase.com
Telephone: (312) 923-2651
gboyle@jenner.com Counsel for Defendant Apex Clearing Corp.
Counsel for Defendants The Depository
Trust & Clearing Corporation; The /s/ Leiv H. Blad, Jr.
Depository Trust Company LOWENSTEIN SANDLER LLP
Leiv H. Blad, Jr.
Allison M. Vissichelli
/s/ Evangeline A.Z. Burbidge 2200 Pennsylvania Avenue, NW
Lewis & Llewellyn LLP Washington, DC 20037
Evangeline A.Z. Burbidge Telephone: (202) 753-3800
Paul T. Llewellyn Facsimile: (202) 753-3838
601 Montgomery Street, Suite 2000 lblad@lowenstein.com
San Francisco, CA 94111-6538 avissichelli@lowenstein.com
Telephone: (415) 800-0590
Facsimile: (415) 390-2127 LOWENSTEIN SANDLER LLP
eburbidge@lewisllewellyn.com H. Gregory Baker
pllewellyn@lewisllewellyn.com 1251 Avenue of the Americas
New York, NY 10020
Counsel for Defendant FF Trade Republic Telephone: (212) 262-6700
Growth, LLC Facsimile: (973) 597-2457
hbaker@lowenstein.com
Counsel for Defendants Alpaca Securities
LLC, eToro USA Securities Inc., WeBull
Financial LLC and Fumi Holdings, Inc.
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Pursuant to Stipulation, it is hereby,
DONE AND ORDERED in Miami, Florida, this __ day of ____, 2021.
_________________________________
CECILIA M. ALTONAGA
UNITED STATES DISTRICT JUDGE
cc: counsel of record; pro se Plaintiffs
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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, _____________________________ [print or type full name], of _________________ [print or
type full address], declare under penalty of perjury that I have read in its entirety and understand
the Stipulated Protective Order that was issued by the United States District Court for the Southern
District of Florida in the case of In re Jan. 2021 Short Squeeze Trading Litigation, Case No. 21-
2989-MDL-ALTONAGA/Torres. I agree to comply with and to be bound by all the terms of this
Stipulated Protective Order and I understand and acknowledge that failure to so comply could
expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will
not disclose in any manner any information or item that is subject to this Stipulated Protective
Order to any person or entity except in strict compliance with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court for the
Southern District of Florida for the purpose of enforcing the terms of this Stipulated Protective
Order, even if such enforcement proceedings occur after termination of this action.
I hereby appoint __________________________ [print or type full name] of
_______________________________________ [print or type full address and telephone number]
as my Florida agent for service of process in connection with this action or any proceedings related
to enforcement of this Stipulated Protective Order.
Date: ______________________________________
City and State where sworn and signed: _________________________________
Printed name: _______________________________
Signature: __________________________________
28
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