Exhibit A: Certification (Abraham Huacuja) (Dkt. 446-1, S.D. Fla.)
Summary
Exhibit A, filed as Document 446-1 (22 pages) in Case 1:21-md-02989-CMA and entered November 30, 2021, collects certifications authorizing The Rosen Law Firm, P.A. to sue Robinhood Financial, LLC, Robinhood Securities LLC and Robinhood Markets, Inc. under the federal securities laws. Certifying plaintiffs include Abraham Huacuja, Ava Bernard, Brandon Martin, Brendan Clarke and Brian Harbison, each covering purchases and sales of the Affected Securities such as AAL, AMC, BB, BBBY and GME. Each certification lists the plaintiff's transactions in the Affected Securities.
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- Date
- 2021-11-30
Cite this document
“Exhibit A: Certification (Abraham Huacuja) (Dkt. 446-1).”
Original at archive.org, dated 2021-11-30. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-11-30-covid-era-misc-1d56d98b-1/
, SHA-256 1d56d98bc968e0cc07baa00db3d71d13fca8be70647e946aff9f8539a2291bde.Full text
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 1 of 22
Exhibit A
DocuSign Envelope ID: 73438056-245A-4C70-8C98-ACA7969284CF
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 2 of 22
CERTIFICATION
Abraham Huacuja (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 one or more 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..
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/29/2021
Executed on __________________ _____________________________
Abraham Huacuja
DocuSign Envelope ID: 73438056-245A-4C70-8C98-ACA7969284CF
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 3 of 22
SCHEDULE A
ABRAHAM HUACUJA
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC 1/27/2021 1,000 ($19.09) AMC 1/28/2021 71 $13.00
AMC 1/27/2021 15 ($18.24) AMC 1/28/2021 100 $13.00
AMC 1/27/2021 105 ($17.86) AMC 1/28/2021 45 $13.00
AMC 1/27/2021 100 ($17.85) AMC 1/28/2021 100 $13.00
AMC 1/27/2021 100 ($17.85) AMC 1/28/2021 30 $13.00
AMC 1/27/2021 100 ($17.85) AMC 1/28/2021 40 $13.00
AMC 1/27/2021 100 ($17.85) AMC 1/28/2021 25 $13.00
AMC 1/27/2021 300 ($17.85) AMC 1/28/2021 6 $13.00
AMC 1/27/2021 95 ($17.85) AMC 1/28/2021 6 $13.00
AMC 1/27/2021 150 ($16.35) AMC 1/28/2021 600 $13.00
AMC 1/27/2021 5 ($16.25) AMC 1/28/2021 15 $13.00
AMC 1/27/2021 50 ($16.35) AMC 1/28/2021 12 $13.00
AMC 1/27/2021 1 ($15.25) AMC 1/28/2021 250 $13.00
AMC 1/27/2021 9 ($15.39) AMC 1/28/2021 25 $13.00
AMC 1/27/2021 70 ($15.15) AMC 1/28/2021 22 $13.00
NOK 1/27/2021 100 ($7.68) AMC 1/28/2021 15 $13.00
NOK 1/27/2021 100 ($7.68) AMC 1/28/2021 27 $13.00
NOK 1/27/2021 1,000 ($7.53) AMC 1/28/2021 100 $13.00
NOK 1/27/2021 774 ($7.27) AMC 1/28/2021 3 $13.00
NOK 1/27/2021 100 ($7.27) AMC 1/28/2021 708 $13.00
NOK 1/27/2021 51 ($7.27) NOK 1/28/2021 43 $4.86
NOK 1/27/2021 75 ($7.27) NOK 1/28/2021 288 $4.86
NOK 1/27/2021 900 ($7.18) NOK 1/28/2021 200 $4.86
NOK 1/27/2021 100 ($7.18) NOK 1/28/2021 100 $4.86
NOK 1/27/2021 60 ($6.73) NOK 1/28/2021 85 $4.86
NOK 1/27/2021 50 ($6.73) NOK 1/28/2021 100 $4.86
NOK 1/27/2021 26 ($6.73) NOK 1/28/2021 115 $4.86
NOK 1/27/2021 100 ($6.73) NOK 1/28/2021 100 $4.86
NOK 1/27/2021 64 ($6.73) NOK 1/28/2021 100 $4.86
NOK 1/27/2021 25 ($6.73) NOK 1/28/2021 100 $4.86
NOK 1/27/2021 100 ($6.73) NOK 1/28/2021 100 $4.86
NOK 1/27/2021 18 ($6.73) NOK 1/28/2021 15 $4.86
NOK 1/27/2021 41 ($6.73) NOK 1/28/2021 35 $4.86
NOK 1/27/2021 16 ($6.73) NOK 1/28/2021 75 $4.86
NOK 1/28/2021 5 $4.86
NOK 1/28/2021 10 $4.86
NOK 1/28/2021 1,000 $4.86
NOK 1/28/2021 1,229 $4.86
DocuSign Envelope ID: 15E9497C-4331-4936-91CF-32C6CB0A80A2
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 4 of 22
CERTIFICATION
Ava Bernard (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 one
or more 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..
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/29/2021
Executed on __________________ _____________________________
Ava Bernard
DocuSign Envelope ID: 15E9497C-4331-4936-91CF-32C6CB0A80A2
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 5 of 22
SCHEDULE A
AVA BERNARD (ASSIGNED FROM COLLEEN COOKE)
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC 1/27/2021 500 ($16.29) AMC 2/02/2021 500 $8.90
AMC 1/27/2021 500 ($16.10) AMC 2/03/2021 500 $9.32
DocuSign Envelope ID: 15E9497C-4331-4936-91CF-32C6CB0A80A2
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 6 of 22
ASSIGNMENT
Colleen Cooke, the undersigned Assignor (“Assignor”), hereby assigns, transfers, and
sets over to Ava Bernard all rights, title, ownership and interest of the Assignor in any and all
claims, demands, and causes of action of any kind whatsoever which the Assignor has or may
have arising from violations of the U.S. federal securities laws in connection with
the Assignor’s transactions in the securities of AMC Entertainment Holdings, Inc. Further, the
Assignor hereby appoints Ava Bernard as her true and lawful attorney-in-fact for the
purpose of exercising all owners relating to such causes of action.
Ava Bernard has agreed to remit any proceeds received as a result of this Assignment to
the Assignor.
This Assignment may not be revoked without the written consent of Ava Bernard.
This assignment shall be binding upon and inure to the benefit of the parties, their
successors and assigns.
11/29/2021
Executed on _______________.
__________________________
Colleen Cooke
DocuSign Envelope ID: 81157E1F-267C-49F0-838E-7299A80D8ECA
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 7 of 22
CERTIFICATION
Brandon Martin (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 one
or more 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.
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/29/2021
Executed on __________________ _____________________________
Brandon Martin
DocuSign Envelope ID: 81157E1F-267C-49F0-838E-7299A80D8ECA
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 8 of 22
SCHEDULE A
BRANDON MARTIN
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC 1/27/2021 45.663354 ($16.42) AMC 1/28/2021 45.663354 $8.98
GME 1/27/2021 5 ($324.84) GME 1/28/2021 5 $170.00
GME 1/27/2021 0.819605 ($316.01) GME 2/2/2021 0.819605 $130.00
DocuSign Envelope ID: 89417886-EFDD-4DDD-A47B-1C6B438CBCE8
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 9 of 22
CERTIFICATION
Brendan Clarke (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 one
or more 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.
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/30/2021
Executed on __________________ _____________________________
Brendan Clarke
DocuSign Envelope ID: 89417886-EFDD-4DDD-A47B-1C6B438CBCE8
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 10 of
22
SCHEDULE A
BRENDAN CLARKE
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
GME 1/27/2021 3.584445 ($306.88) GME 2/2/2021 6.642439 $103.59
GME 1/27/2021 1.139977 ($368.43)
GME 1/27/2021 0.97842 ($367.94)
GME 1/27/2021 0.939597 ($329.93)
DocuSign Envelope ID: E90483F4-5511-4114-8831-022C73EF49B6
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 11 of
22
CERTIFICATION
Brian Harbison (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 one
or more 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.
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/29/2021
Executed on __________________ _____________________________
Brian Harbison
DocuSign Envelope ID: E90483F4-5511-4114-8831-022C73EF49B6
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 12 of
22
SCHEDULE A
BRIAN HARBISON
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC 1/27/2021 200 ($15.98) AMC 1/28/2021 200 $12.99
DocuSign Envelope ID: F997DB97-05F6-4BC4-B186-040942EF9B61
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 13 of
22
CERTIFICATION
Cecilia Rivas (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 one
or more 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.
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/23/2021
Executed on __________________ _____________________________
Cecilia Rivas
DocuSign Envelope ID: F997DB97-05F6-4BC4-B186-040942EF9B61
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 14 of
22
SCHEDULE A
CECILIA RIVAS
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
GME 1/27/2021 1 ($290.00) GME 1/27/2021 1 $345.00
GME 1/27/2021 1 ($305.00) GME 2/4/2021 1 $57.22
DocuSign Envelope ID: 6AC4B1DF-4F75-433A-9480-516099060EB2
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 15 of
22
CERTIFICATION
Garland Ragland Jr. (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 one or more 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.
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/30/2021
Executed on __________________ _____________________________
Garland Ragland Jr.
DocuSign Envelope ID: 6AC4B1DF-4F75-433A-9480-516099060EB2
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 16 of
22
SCHEDULE A
GARLAND RAGLAND JR.
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC 1/27/2021 3 ($18.46) AMC 1/28/2021 3 $8.01
NOK 1/27/2021 10 ($6.85) NOK 1/28/2021 10 $4.70
DocuSign Envelope ID: E9084DC4-10F3-4ECD-B5BD-205E95599FDD
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 17 of
22
CERTIFICATION
Joseph Gurney (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 one
or more 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..
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/23/2021
Executed on __________________ _____________________________
Joseph Gurney
DocuSign Envelope ID: E9084DC4-10F3-4ECD-B5BD-205E95599FDD
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 18 of
22
SCHEDULE A
JOSEPH GURNEY
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
BB 1/27/2021 24.83321 ($26.98) BB 1/28/2021 41 $17.00
BB 1/27/2021 7 ($26.83) BB 1/28/2021 0.0936681 $17.00
BB 1/27/2021 0.076022 ($26.83)
BB 1/27/2021 0.377351 ($26.82)
BB 1/27/2021 4 ($23.12)
BB 1/27/2021 0.411764 ($23.12)
BB 1/27/2021 1.999684 ($22.19)
BB 1/27/2021 0.253775 ($22.15)
BB 1/27/2021 1.995353 ($21.48)
BB 1/27/2021 0.036962 ($21.43)
BB 1/27/2021 0.096552 ($21.43)
BB 1/27/2021 0.013001 ($21.43)
DocuSign Envelope ID: 5482EE6B-C8FC-47B3-8B98-C2B8615122A5
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 19 of
22
CERTIFICATION
Santiago Gil Bohórquez (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 one or more 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..
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/29/2021
Executed on __________________ _____________________________
Santiago Gil Bohórquez
DocuSign Envelope ID: 5482EE6B-C8FC-47B3-8B98-C2B8615122A5
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 20 of
22
SCHEDULE A
SANTIAGO GIL BOHÓRQUEZ
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
EXPR 1/27/2021 300 ($9.9481) EXPR 1/28/2021 200 $6.1100
EXPR 1/27/2021 312 ($9.6862) EXPR 1/29/2021 173 $6.2219
EXPR 1/27/2021 176 ($8.3000) EXPR 1/29/2021 229 $5.6000
EXPR 1/28/2021 14 ($4.8790) EXPR 2/1/2021 200 $5.1619
NOK 1/27/2021 200 ($5.1137) NOK 1/28/2021 200 $4.9300
BB 1/27/2021 200 ($20.8998) BB 1/28/2021 100 $16.9100
BB 1/29/2021 100 $14.0501
DocuSign Envelope ID: 0CF14F52-F95E-4E66-B02B-B2B43608F208
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 21 of
22
CERTIFICATION
Trevor Tarvis (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 one
or more 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..
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 the
Affected Securities for which Plaintiff seeks redress pursuant to the claims set forth in the
consolidated complaint:
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
Plaintiff’s 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.
11/23/2021
Executed on __________________ _____________________________
Trevor Tarvis
DocuSign Envelope ID: 0CF14F52-F95E-4E66-B02B-B2B43608F208
Case 1:21-md-02989-CMA Document 446-1 Entered on FLSD Docket 11/30/2021 Page 22 of
22
SCHEDULE A
TREVOR TARVIS
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
BB 1/27/2021 4 ($22.28) BB 1/28/2021 4.48833 $15.18
BB 1/27/2021 0.48833 ($22.28) NOK 1/28/2021 69 $4.76
NOK 1/27/2021 28.97965 ($6.88) NOK 1/28/2021 0.099259 $4.76
NOK 1/27/2021 0.090909 ($6.88)
NOK 1/27/2021 0.781804 ($6.49)
NOK 1/27/2021 23.54788 ($6.35)
NOK 1/27/2021 0.074015 ($6.35)
NOK 1/27/2021 15.625 ($6.40)
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