IN RE January 2021 Short Squeeze Trading Litigation — Court Filing, Doc. 502

Summary

Plaintiffs' Reply Memorandum in Support of Motion for Entry of a Scheduling Order (Document 502) 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 on the FLSD docket August 2, 2022. Lead Plaintiff Blue Laine-Beveridge and the named Plaintiffs reply in support of their Motion Requesting Entry of a Scheduling Order re: Amendment of Complaint (Dkt. # 495), which the Robinhood Defendants oppose (Dkt. # 499) because no proposed amended complaint has been provided. The four-page reply states that the relief sought is only a schedule for providing the proposed amended complaint, for the Robinhood Defendants to decide whether to stipulate to its filing and for briefing a motion to amend or to dismiss, and is signed /s/ Laurence M. Rosen.

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Case 1:21-md-02989-CMA Document 502 Entered on FLSD Docket 08/02/2022 Page 1 of 4




                          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: All Actions Involving the Federal Securities Laws



           PLAINTIFFS’ REPLY MEMORANDUM IN SUPPORT OF MOTION
                    FOR ENTRY OF A SCHEDULING ORDER
Case 1:21-md-02989-CMA Document 502 Entered on FLSD Docket 08/02/2022 Page 2 of 4




          Lead Plaintiff Blue Laine-Beveridge, named Plaintiffs Abraham Huacuja, Ava Bernard,

   Brandon Martin, Brendan Clarke, Brian Harbison, Cecilia Rivas, Garland Ragland Jr., Joseph

   Gurney, Santiago Gil Bohórquez, and Trevor Tarvis (collectively “Plaintiffs”) hereby reply in

   support of their “Motion Requesting Entry of a Scheduling Order re: Amendment of Complaint”

   (Dkt. # 495) as follows:

          The Robinhood Defendants ask the Court to deny Plaintiffs’ request for relief because

   Plaintiffs have not provided a copy of their proposed amended complaint and articulated what their

   new allegations will be. Dkt. # 499 at 1. But the relief that Plaintiffs sought, first via a stipulated

   order and now by way of a motion, is entry of a scheduling order setting dates on which: Plaintiffs

   would provide a copy of the proposed amended complaint to the Robinhood Defendants to review,

   the Robinhood Defendants would decide whether to stipulate that the amended complaint could

   be filed, and the parties would brief either a motion to amend or a motion to dismiss. Dkt. # 495

   at 5. Although they initially deemed it unnecessary, the Robinhood Defendants have no basis to

   oppose this procedural motion.

          In their opposition brief, the Robinhood Defendants now take the position that they will

   not stipulate to amendment of the complaint and that a motion to amend will be required. Dkt. #

   499 at 1. Therefore, the first three sets of dates in the proposed schedule appear to be unnecessary.

   Plaintiffs hereby modify the relief initially sought and request that any schedule adopted by the

   Court commence with the filing of a motion to amend on August 19, 2022.




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Case 1:21-md-02989-CMA Document 502 Entered on FLSD Docket 08/02/2022 Page 3 of 4




   Dated: August 2, 2022              Respectfully submitted,

                                      THE ROSEN LAW FIRM, P.A.
                                      Laurence M. Rosen, FBN# 0182877
                                      Robin Bronzaft Howald
                                      Michael A. Cohen
                                      By: /s/Laurence M. Rosen
                                      Laurence M. Rosen, Esq.
                                      275 Madison Avenue 40th Floor
                                      New York, New York 10016
                                      Tel: (212) 686-1060
                                      Fax: (212) 202-3827
                                      Email: lrosen@rosenlegal.com

                                      Counsel for Lead Plaintiff Blue Laine-Beveridge
                                      and Named Plaintiffs Abraham Huacuja, Ava
                                      Bernard, Brandon Martin, Brendan Clarke, Brian
                                      Harbison, Cecilia Rivas, Garland Ragland Jr.,
                                      Joseph Gurney, Santiago Gil Bohórquez, and
                                      Trevor Tarvis




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Case 1:21-md-02989-CMA Document 502 Entered on FLSD Docket 08/02/2022 Page 4 of 4




                               CERTIFICATE OF SERVICE

         I hereby certify that on August 2, 2022, a true and correct copy of the foregoing
   document was served by CM/ECF to the parties registered to the Court’s CM/ECF system.

                                                               /s/Laurence M. Rosen




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