Robinhood's Unopposed Motion for Extension of Time to File an Answer to Plaintiffs' Federal Securities Tranche Complaint — In re January 2021 Short Squeeze Trading Litigation (Dkt. 504, S.D. Fla.)

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Robinhood's Unopposed Motion for Extension of Time to File an Answer to Plaintiffs' Federal Securities Tranche Complaint in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA (Case No. 21-MD-2989-ALTONAGA/TORRES, Document 504, 3 pages), in the U.S. District Court for the Southern District of Florida, entered August 19, 2022. Robinhood recounts that Plaintiffs filed the complaint on November 30, 2021, that Robinhood moved to dismiss, and that the Court's Order [ECF No. 503] dismissed Count I in part and let the action proceed. Robinhood asks to extend its deadline to answer from August 25, 2022 through and including September 12, 2022 to evaluate the allegations, which may be amended.

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE No. 21-MD-2989-ALTONAGA/TORRES

In re:

JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION
_____________________________________/

This Document Relates to the Federal Securities Tranche

ROBINHOOD’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE AN
ANSWER TO PLAINTIFFS’ FEDERAL SECURITIES TRANCHE COMPLAINT

Defendants Robinhood Markets, Inc., Robinhood Financial LLC and Robinhood
Securities, LLC (collectively, “Robinhood”), by and through undersigned counsel, and pursuant
to Fed. R. Civ. P. 6(b), respectfully submit this unopposed motion for an extension of time to file
an Answer to Plaintiffs’ Federal Securities Tranche Complaint [ECF No. 446]. In support
thereof, Robinhood states:
1. Plaintiffs filed their Federal Securities Tranche Complaint on November 30, 2021.
2. Robinhood filed its Motion to Dismiss [ECF No. 449] on January 7, 2022.
3. On August 10, 2022, this Court issued its Order on Robinhood’s Motion to Dismiss
[ECF No. 503], dismissing Plaintiffs’ Count I in part and allowing the action to
proceed.
4. In the same Order, this Court gave Plaintiffs until August 22, 2022 to file a notice
indicating whether they would like to proceed with their Motion Requesting Entry of
a Scheduling Order Re: Amendment of Complaint [ECF No. 495].
5. Pursuant to Fed. R. Civ. P. 12(a)(4)(A), Robinhood now has until August 25, 2022 to
respond to the remaining counts in Plaintiffs’ Federal Securities Tranche Complaint.
Case 1:21-md-02989-CMA   Document 504   Entered on FLSD Docket 08/19/2022   Page 1 of 3

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6. Robinhood requests an extension of its deadline to file an Answer to the Federal
Securities Tranche Complaint through and including September 12, 2022 so that it
may further evaluate Plaintiffs’ allegations, analyze relevant documents, formulate a
proper response, and not waste judicial resources responding to allegations that may
be amended by Plaintiffs.
7. This motion is not sought for the purposes of delay, but rather to facilitate the
efficient and effective use of judicial resources.
8. This is Robinhood’s first request for an extension of time to file an Answer to the
Federal Securities Tranche Complaint.
9. Plaintiffs do not oppose the relief sought herein.
WHEREFORE, Robinhood respectfully requests an extension of time through and
including September 12, 2022 to file an Answer to the Federal Securities Tranche Complaint.
CERTIFICATE OF GOOD FAITH CONFERENCE

Pursuant to Local Rule 7.1(a)(3)(A), I hereby certify that, on August 17 and 18, 2022,
counsel for Robinhood conferred via email with Plaintiffs’ counsel regarding the relief sought in
this motion. Plaintiffs do not oppose this motion.

Case 1:21-md-02989-CMA   Document 504   Entered on FLSD Docket 08/19/2022   Page 2 of 3

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Dated:  August 19, 2022
/s/ Samuel A. Danon
HUNTON ANDREWS KURTH LLP
Samuel A. Danon (FBN 892671)
María Castellanos Alvarado (FBN 116545)
333 S.E. 2 Avenue, Suite 2400
Miami, FL 33131
Telephone: (305) 810-2500
Facsimile: (305) 810-2460
sdanon@HuntonAK.com
mcastellanos@HuntonAK.com
CRAVATH, SWAINE & MOORE LLP
Antony L. Ryan
Kevin J. Orsini
Brittany L. Sukiennik
825 Eighth Avenue
New York, NY 10019
Telephone: (212) 474-1000
Facsimile: (212) 474-3700
aryan@cravath.com
korsini@cravath.com
bsukiennik@cravath.com
Counsel for Defendants Robinhood Financial
LLC, Robinhood Securities, LLC and
Robinhood Markets, Inc.

Case 1:21-md-02989-CMA   Document 504   Entered on FLSD Docket 08/19/2022   Page 3 of 3

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