Exhibit 2: Certification (Blue Laine-Beveridge) (Dkt. 366-3, S.D. Fla.)
Summary
Exhibit 2, filed as Document 366-3 (3 pages) in Case 1:21-md-02989-CMA and entered July 27, 2021, is the certification of Blue Laine-Beveridge authorizing The Rosen Law Firm, P.A. to file or amend an action under the federal securities laws against Robinhood Financial, LLC, Robinhood Markets, Inc. and Robinhood Securities LLC, among others. The certification lists the Affected Securities, among them AAL, AMC, BB, BBBY, GME, EXPR, KOSS, NAKD, NOK, SNDL and TR. An attached schedule lists purchases and sales, including NOK sales of 35,000 shares at $4.00 on 2/22/2021 and AMC sales of 15,000 shares at $8.34 on 2/3/2021.
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- Date
- 2021-07-27
Cite this document
“Exhibit 2: Certification (Blue Laine-Beveridge) (Dkt. 366-3).”
Original at archive.org, dated 2021-07-27. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-07-27-covid-era-misc-955cb768-1/
, SHA-256 955cb768271f95e6294ce706c7ff36beb9dd49688ffffb4a77ac4d535aedb2e6.Full text
Case 1:21-md-02989-CMA Document 366-3 Entered on FLSD Docket 07/27/2021 Page 1 of 3
EXHIBIT 2
DocuSign Envelope ID: 2901D58F-4CFA-46E0-9197-023C2CF65A67
Case 1:21-md-02989-CMA Document 366-3 Entered on FLSD Docket 07/27/2021 Page 2 of 3
CERTIFICATION
Blue Laine-Beveridge (the “Plaintiff”) authorizes The Rosen Law Firm, P.A. to file an
action or amend a current action under the federal securities laws to recover damages and to seek
other relief against ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC,
ROBINHOOD MARKETS, INC. (collectively “RH”) and others in connection with the purchase
and sale of the Affected Securities which include American Airlines Group Inc. (NASDAQ: AAL),
AMC Entertainment Holdings Inc. (NYSE: AMC), BlackBerry Limited (NYSE: BB), Bed Bath
& Beyond Inc. (NASDAQ: BBBY), GameStop Corp. (NYSE: GME), Express (NYSE: EXPR),
Koss Corporation (NASDAQ: KOSS), Naked Brand Group (NASDAQ: NAKD), Nokia
Corporation (NYSE: NOK), Sundial Growers, Inc. (NASDAQ: SNDL), Tootsie Roll Industries
(NYSE: TR), and Trivago NV (NASDAQ: TRVG).
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed a complaint against RH and retained The Rosen Law Firm,
P.A. and authorizes it to file a Lead Plaintiff motion on his behalf.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of plaintiff’s counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is a representative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is a list of all of the purchases and sales Plaintiff has made in
Affected Securities during the class period set forth in the complaint on RH platform. Plaintiff has
made no transactions during the class period in the securities that are the subject of this lawsuit
except those attached:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as a representative party on behalf of a class in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as a representative party beyond
his pro rata share of any recovery, except reasonable costs and expenses, such as travel expenses
and lost wages directly related to the class representation, as ordered or approved by the court
pursuant to law.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
7/27/2021
Executed on __________________ _____________________________
Blue Laine-Beveridge
DocuSign Envelope ID: 2901D58F-4CFA-46E0-9197-023C2CF65A67
Case 1:21-md-02989-CMA Document 366-3 Entered on FLSD Docket 07/27/2021 Page 3 of 3
SCHEDULE A
BLUE LAINE-BEVERIDGE TRANSACTIONS
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC 1/20/2021 3,275 ($3.05) AMC 2/3/2021 15,000 $8.34
AMC 1/22/2021 5,573 ($3.58) AMC 6/15/2021 18 $58.85
AMC 1/27/2021 6,000 ($15.89) AMC 6/15/2021 360 $59.05
AMC 1/27/2021 530 ($18.29) NOK 2/22/2021 35,000 $4.00
NOK 1/27/2021 15,000 ($6.72) NOK 3/9/2021 3,000 $3.99
NOK 1/27/2021 6,900 ($6.82) NOK 3/9/2021 6,500 $3.99
NOK 1/27/2021 9,100 ($6.98) NOK 4/14/2021 250 $4.12
NOK 1/27/2021 350 ($6.92)
NOK 1/27/2021 13,400 ($7.46)
File and source
- File
- gov.uscourts.flsd.590042.366.3.pdf
- Size
- 192,798 bytes
- SHA-256
- 955cb768271f95e6294ce706c7ff36beb9dd49688ffffb4a77ac4d535aedb2e6
- Original
- archive.org