Stipulated Protective Order — In re January 2021 Short Squeeze Trading Litigation (Document 329)
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 July 1, 2021 as Document 329 (28 pages), relating to the Non-Federal Securities Actions. On the Joint Motion for Entry of Stipulated Protective Order [ECF No. 328], the court orders that the Motion is GRANTED and enters the terms stipulated by the parties. 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
- 2021-07-01
Cite this document
“Stipulated Protective Order — In re January 2021 Short Squeeze Trading Litigation (Document 329).”
Original at archive.org, dated 2021-07-01. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-07-01-covid-era-misc/
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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 the Non-Federal Securities Actions
STIPULATED PROTECTIVE ORDER
THIS CAUSE came before the Court upon the Joint Motion for Entry of Stipulated
Protective Order [ECF No. 328]. Being fully advised, it is
ORDERED AND ADJUDGED that the Motion is GRANTED as follows:
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
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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.
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.
2.12 Party: Any named party to this action.
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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 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 subject to an existing and
separate duty of confidentiality or obtained by the Receiving Party after the disclosure from a
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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.
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.
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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 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
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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 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
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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.
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.
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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 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.
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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 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
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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
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;
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(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;
(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.
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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;
(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;
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(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:
(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”
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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.
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;
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(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
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.
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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
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).
17
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CASE NO. 21-2989-MDL-ALTONAGA
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 first receiving 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 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.
18
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CASE NO. 21-2989-MDL-ALTONAGA
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, 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
19
Case 1:21-md-02989-CMA Document 329 Entered on FLSD Docket 07/01/2021 Page 20 of 28
CASE NO. 21-2989-MDL-ALTONAGA
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
/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)
20
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CASE NO. 21-2989-MDL-ALTONAGA
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
/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)
21
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CASE NO. 21-2989-MDL-ALTONAGA
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
Robinhood Crypto, LLC /s/ Christopher D. Kercher
QUINN EMANUEL URQUHART & SULLIVAN,
LLP
/s/ Justina K. Sessions Christopher D. Kercher
WILSON SONSINI GOODRICH & ROSATI 51 Madison Avenue, 22nd Floor,
Justina K. Sessions New York, New York, 10010
One Market Plaza Telephone: (212) 849-7000
Spear Tower, Suite 3300 Facsimile: (212) 849-7100
San Francisco, California 94105 christopherkercher@quinnemanuel.com
Telephone: (415) 947-2197
Facsimile: (415) 947-2099 QUINN EMANUEL URQUHART & SULLIVAN,
jsessions@wsgr.com LLP
Marina E. Lev
WILSON SONSINI GOODRICH & ROSATI 865 South Figueroa Street, 10th Floor
Kenneth R. O’Rourke Los Angeles, California 90017
Brendan J. Coffman Telephone: (213) 443-3000
1700 K Street NW, 5th Floor Facsimile: (213) 443-3100
Washington, DC 20006 marinalev@quinnemanuel.com
Telephone: (202) 973-8800
Facsimile: (202) 973-8899 BARTLIT BECK LLP
korourke@wsgr.com Adam L. Hoeflich
bcoffman@wsgr.com Dawson Robinson
54 W. Hubbard St., Ste. 300
Counsel for Defendant Open to the Public Chicago, IL 60654
Investing, Inc. Telephone: (312) 494-4400
Facsimile: (312) 494-4440
adam.hoeflich@bartlitbeck.com
/s/ Daniel J. Kramer dawson.robinson@bartlitbeck.com
PAUL, WEISS, RIFKIND, WHARTON &
GARRISON LLP Counsel for Defendants Citadel Enterprise
Daniel J. Kramer Americas, LLC and Citadel Securities LLC
Richard Tarlowe
1285 Avenue of the Americas
New York, NY 10019 /s/ Harry A. Olivar, Jr.
Telephone: (212) 373-3000 QUINN EMANUEL URQUHART & SULLIVAN,
dkramer@paulweiss.com LLP
rtarlowe@paulweiss.com Harry A. Olivar, Jr.
Korinna S. Anderson
Counsel for Defendant Point72 Asset 865 S. Figueroa Street, 10th Floor
22
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CASE NO. 21-2989-MDL-ALTONAGA
Management, L.P. Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
/s/ Jason J. Mendro harryolivar@quinnemanuel.com
GIBSON, DUNN & CRUTCHER LLP korinnaanderson@quinnemanuel.com
Jason J. Mendro
Russell B. Balikian QUINN EMANUEL URQUHART & SULLIVAN,
1050 Connecticut Ave., NW LLP
Washington, DC 20036 Linda J. Brewer
Telephone: (202) 887-3726 50 California Street, 22nd Floor
jmendro@gibsondunn.com San Francisco, California 94111-4788
rbalikian@gibsondunn.com Telephone: (415) 875-6600
Facsimile: (415) 875-6700
GIBSON, DUNN & CRUTCHER LLP lindabrewer@quinnemanuel.com
Theodore J. Boutrous, Jr.
333 South Grand Avenue Counsel for Defendant Sequoia Capital
Los Angeles, CA 90071 Operations LLC
Telephone: (213) 229-7804
tboutrous@gibsondunn.com
/s/ Shari Ross Lahlou
Counsel for Defendants Charles Schwab & DECHERT LLP
Co., Inc.; TD Ameritrade, Inc.; TD Shari Ross Lahlou
Ameritrade Clearing, Inc.; TD Ameritrade 1900 K Street, NW
Holding Corporation; and The Charles Washington, D.C. 20006
Schwab Corporation Telephone: (202) 261-3300
Facsimile: (202) 261-3333
shari.lahlou@dechert.com
/s/ Robin Nunn
MORGAN, LEWIS & BOCKIUS LLP Dechert LLP
Robin Nunn Andrew J. Levander
101 Park Avenue Three Bryant Park
New York, NY 10178-0060 1095 Avenue of the Americas
Telephone: (212) 309-6000 New York, NY 10036
Facsimile: (212) 309-3001 Telephone: (212) 698 3500
robin.nunn@morganlewis.com Facsimile: (212) 698 3599
andrew.levander@dechert.com
Counsel for Defendant Stash Financial,
Inc. DECHERT LLP
Steven Bizar
Cira Centre
/s/ Peter W. Homer 2929 Arch Street
HOMER BONNER JACOBS ORTIZ, P.A. Philadelphia, PA 19104
Peter W. Homer (Florida Bar No. 291250) Telephone: (215) 994 4000
1200 Four Seasons Tower Facsimile: (215) 994 2222
1441 Brickell Avenue steven.bizar@dechert.com
Miami, Florida 33131
Telephone: (305) 350-5139 Counsel for Defendant Interactive Brokers
23
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CASE NO. 21-2989-MDL-ALTONAGA
Facsimile: (305) 372-2738 LLC
phomer@homerbonner.com
DAVIS POLK & WARDWELL LLP /s/ Thomas E. Redburn, Jr.
Brian S. Weinstein LOWENSTEIN SANDLER LLP
Gina Cora Thomas E. Redburn, Jr.
Janet Jones-Duffey Maya Ginsburg
450 Lexington Avenue 1251 Avenue of the Americas
New York, New York 10017 New York, NY 10020
Telephone: (212) 450-4000 Telephone: (212) 262-6700
Facsimile: (212) 701-5972 Facsimile: (973) 597-2457
brian.weinstein@davispolk.com tredburn@lowenstein.com
gina.cora@davispolk.com mginsburg@lowenstein.com
janet.jones-duffey@davispolk.com
LOWENSTEIN SANDLER LLP
Counsel for Defendants Morgan Stanley Zarema Arutyunova Jaramillo
Smith Barney LLC, E*TRADE Financial 2200 Pennsylvania Avenue, NW
Corporation, E*TRADE Securities LLC Washington, DC 20037
and E*TRADE Financial Holdings, LLC Telephone: (202) 753-3800
Facsimile: (202) 753-3838
/s/ Thomas G. Haskins, Jr. zjaramillo@lowenstein.com
BARNES & THORNBURG LLP
Thomas G. Haskins, Jr. Counsel for Defendant Melvin Capital
Allison Gerard Management LP and Candlestick Capital
2121 N. Pearl Street, Suite 700 Management LP
Dallas, TX 75201
Telephone: (214) 258-4200
Facsimile: (214) 258-4199 /s/ Patrick Gibbs
thaskins@btlaw.com COOLEY LLP
allison.gerard@btlaw.com Patrick Gibbs
Brett De Jarnette
BARNES & THORNBURG LLP Rebecca Ferrari
Kevin Rising 3175 Hanover Street
2029 Century Park E, Suite 300 Palo Alto, CA 94304-1130
Los Angeles, CA 90067-2904 Telephone: (650) 843-5000
Telephone: (310) 284-3888 Facsimile: (650) 849-7400
Facsimile: (310) 284-3894 pgibbs@cooley.com
krising@btlaw.com bdejarnette@cooley.com
rferrari@cooley.com
BARNES & THORNBURG LLP
Paul Olszowka Counsel for Defendant M1 Finance, LLC
One North Wacker Drive, Suite 4400
Chicago, IL 60606-2833
Telephone: (312) 214-5612 /s/ Jack E. Pace III
Facsimile: (312) 759-5646 WHITE & CASE LLP
paul.olszowka@btlaw.com Jack E. Pace III
Bryan D. Gant
24
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CASE NO. 21-2989-MDL-ALTONAGA
Counsel for Defendants Dough, LLC and 1221 Avenue of the Americas
tastyworks, Inc. New York, NY 10020-1095
Telephone: (212) 819-8200
Facsimile: (212) 354-8113
/s/ Alfred C. Pfeiffer, Jr. jpace@whitecase.com
LATHAM & WATKINS LLP bgant@whitecase.com
Alfred C. Pfeiffer, Jr.
Belinda S Lee WHITE & CASE LLP
505 Montgomery Street, Suite 2000 J. Mark Gidley
San Francisco, CA 94111-6538 701 Thirteenth Street, NW
Telephone: (415) 391-0600 Washington, DC 20005-3807
Facsimile: (415) 395-8095 Telephone: (202) 626-3600
al.pfeiffer@lw.com Facsimile: (202) 639-9355
belinda.lee@lw.com mgidley@whitecase.com
Counsel for Defendants Square, Inc. and WHITE & CASE LLP
Cash App Investing LLC Angela Daker
Southeast Financial Center
200 South Biscayne Boulevard, Suite 4900
/s/ Gregory M. Boyle Miami, FL 33131-2352
JENNER & BLOCK, LLP Telephone: (305) 995-5297
Gregory M. Boyle Facsimile: (305) 358-5744
353 North Clark Street adaker@whitecase.com
Chicago, Illinois 60654-3456
Telephone: (312) 923-2651 Counsel for Defendant Apex Clearing Corp.
gboyle@jenner.com
Counsel for Defendants The Depository /s/ Leiv H. Blad, Jr.
Trust & Clearing Corporation; The LOWENSTEIN SANDLER LLP
Depository Trust Company Leiv H. Blad, Jr.
Allison M. Vissichelli
2200 Pennsylvania Avenue, NW
/s/ Evangeline A.Z. Burbidge Washington, DC 20037
Lewis & Llewellyn LLP Telephone: (202) 753-3800
Evangeline A.Z. Burbidge Facsimile: (202) 753-3838
Paul T. Llewellyn lblad@lowenstein.com
601 Montgomery Street, Suite 2000 avissichelli@lowenstein.com
San Francisco, CA 94111-6538
Telephone: (415) 800-0590 LOWENSTEIN SANDLER LLP
Facsimile: (415) 390-2127 H. Gregory Baker
eburbidge@lewisllewellyn.com 1251 Avenue of the Americas
pllewellyn@lewisllewellyn.com New York, NY 10020
Telephone: (212) 262-6700
Counsel for Defendant FF Trade Republic Facsimile: (973) 597-2457
Growth, LLC hbaker@lowenstein.com
Counsel for Defendants Alpaca Securities
25
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CASE NO. 21-2989-MDL-ALTONAGA
LLC, eToro USA Securities Inc., WeBull
Financial LLC and Fumi Holdings, Inc.
26
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CASE NO. 21-2989-MDL-ALTONAGA
Pursuant to Stipulation, it is hereby
DONE AND ORDERED in Miami, Florida, this 30th day of June, 2021.
_________________________________
CECILIA M. ALTONAGA
UNITED STATES DISTRICT JUDGE
cc: counsel of record; pro se Plaintiffs
27
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CASE NO. 21-2989-MDL-ALTONAGA
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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