Plaintiffs' Restated Opposition to Defendant Apex Clearing Corporation's Motion for Expansion of Page Limitations for Briefing on Motion to Dismiss Plaintiffs' Class Action Complaint — In re January 2021 Short Squeeze Trading Litigation (Dkt. 488, S.D. Fla.)

Summary

Plaintiffs' Restated Opposition to Defendant Apex Clearing Corporation's Motion for Expansion of Page Limitations for Briefing on Motion to Dismiss Plaintiffs' Class Action Complaint (Document 488) in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA, U.S. District Court for the Southern District of Florida, entered on the FLSD docket June 16, 2022 and relating to the Other Broker Tranche. Plaintiffs Peter Jang and Erik Chavez oppose Apex's motion [ECF Doc. 487] for the reasons set forth in their prior Opposition filed June 14, 2022 [ECF Doc. 482], repeating that the Court's Order of June 3, 2021 already set special page limits of 40, 40 and 20 pages, and ask that the motion be denied. The three-page filing is dated June 16, 2022, signed by Peter Safirstein with Gary S. Graifman and Rachel W. Furst, and closes with a certificate of service dated June 16, 2022.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Date: 2022-06-14

Cite this document

“Plaintiffs' Restated Opposition to Defendant Apex Clearing Corporation's Motion for Expansion of Page Limitations for… (Dkt. 488).” Original at archive.org, dated 2022-06-14. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2022-06-14-covid-era-misc/, SHA-256 bf5bbfdabb0f73fcf5dc8406cebecda5c43eb98e21d62ad3cacb952a74233eef.

Full text

Case 1:21-md-02989-CMA Document 488 Entered on FLSD Docket 06/16/2022 Page 1 of 3




                                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 Other Broker Tranche


   PLAINTIFFS’ RESTATED OPPOSITION TO DEFENDANT APEX CLEARING
   CORPORATION’S MOTION FOR EXPANSION OF PAGE LIMITATIONS FOR
   BRIEFING ON MOTION TO DISMISS PLAINTIFFS’ CLASS ACTION COMPLAINT
            Plaintiffs Peter Jang and Erik Chavez oppose the motion [ECF Doc. 487] of defendant

   Apex Clearing Corporation (“Apex”) for expanded briefing on the anticipated Motion to Dismiss

   for the reasons set forth in Plaintiffs’ prior Opposition filed June 14, 2022 [ECF Doc. 482]. For

   the reasons stated therein, there exists no good cause as to why Apex is unable to efficiently

   argue its positions in accordance with the Court’s Order of June 3, 2021 wherein the Court

   already ordered “special page limits” of 40 pages for the motion to dismiss, 40 pages for the

   opposition and 20 pages for reply [ECF 323].

             Accordingly, Apex’s motion should be denied.

   Dated: June 16, 2022                                  Respectfully submitted,



                                                         /s/ Peter Safirstein
                                                         Peter Safirstein*
                                                         SAFIRSTEIN LAW LLC
                                                         45 N. Broad Street
                                                         Suite 100
                                                         Ridgewood, NJ 07450
                                                         Tel: (917) 952-9458
                                                         psafirstein@safirsteinlaw.com
Case 1:21-md-02989-CMA Document 488 Entered on FLSD Docket 06/16/2022 Page 2 of 3




                                              Gary S. Graifman*
                                              KANTROWITZ, GOLDHAMER &
                                              GRAIFMAN, P.C.
                                              16 Squadron Boulevard
                                              New City, New York 10956
                                              Phone: (845) 356-2570
                                              Fax: (845) 356-4335
                                              ggraifman@kgglaw.com

                                              Plaintiffs’ Counsel in the
                                              Other Broker Tranche

                                              Rachel W. Furst
                                              GROSSMAN ROTH TAFFA
                                              COHEN, P.A.
                                              2525 Ponce de Leon Blvd., Ste 1150
                                              Coral Gables, FL 33134-6040
                                              Tel: 305-442-8666
                                              rwf@gossmanroth.com

                                              Plaintiffs’ Liaison Counsel

   *Counsels’ Certificates of Understanding
   have previously been filed
Case 1:21-md-02989-CMA Document 488 Entered on FLSD Docket 06/16/2022 Page 3 of 3




                                   CERTIFICATE OF SERVICE


          I hereby certify that on June 16, 2022, I electronically filed the forgoing with the Clerk of

   the Court using CM/ECF. I also certify that the foregoing is being served this day on all counsel

   of record in the manner specified, either via transmission of Notices of Electronic Filing

   generated by CM/ECF or in some other authorized manner for those counsel who are not

   authorized to receive Notices of Electronic Filing.


                                                         By: /s/ Gary S. Graifman
                                                             Gary S. Graifman

File and source

File: gov.uscourts.flsd.590042.488.0.pdf
Size: 588,387 bytes
SHA-256: bf5bbfdabb0f73fcf5dc8406cebecda5c43eb98e21d62ad3cacb952a74233eef
Our copy: gov.uscourts.flsd.590042.488.0.pdf
Original: archive.org