Pandemic Darlings The pandemic economy, in original documents
Home Source documents Exhibit A: Certification (Dkt. 527-1)

Exhibit A: Certification (Dkt. 527-1, S.D. Fla.)

Summary

Exhibit A (Document 527-1) in Case 1:21-md-02989-CMA, entered on the FLSD docket January 17, 2023, a 23-page set of DocuSign certifications under the federal securities laws. In each, a Plaintiff, beginning with Abraham Huacuja and ending with Thomas Cash, authorizes The Rosen Law Firm to file or amend an action against Robinhood Financial, LLC, Robinhood Securities LLC and Robinhood Markets, Inc. in connection with the Affected Securities, which include AMC Entertainment Holdings Inc., GameStop Corp., Koss Corporation and Bed Bath & Beyond Inc. Each Plaintiff declares having reviewed a complaint, not having traded at counsel's direction and being willing to serve as a lead plaintiff, and attaches a Schedule A of purchases and sales. The final schedule lists Thomas Cash's purchase of 500 GME shares on 1/28/2021 at $132.00.

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
2023-01-17

Cite this document

“Exhibit A: Certification (Dkt. 527-1).” Original at archive.org, dated 2023-01-17. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-01-17-covid-era-misc-e98dfa20-1/, SHA-256 e98dfa20d47b768bed49a3d601fac174ddbdb79f899db426c9fd39e1b171e92b.

Full text

Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 1 of 23




             EXHIBIT A
DocuSign Envelope ID: 73438056-245A-4C70-8C98-ACA7969284CF
      Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 2 of 23




                                                        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 527-1 Entered on FLSD Docket 01/17/2023 Page 3 of 23




                                                             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 527-1 Entered on FLSD Docket 01/17/2023 Page 4 of 23




                                                        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 527-1 Entered on FLSD Docket 01/17/2023 Page 5 of 23




                                                             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: 89417886-EFDD-4DDD-A47B-1C6B438CBCE8
     Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 6 of 23




                                                      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 527-1 Entered on FLSD Docket 01/17/2023 Page 7 of 23




                                                         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 527-1 Entered on FLSD Docket 01/17/2023 Page 8 of 23




                                                         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 527-1 Entered on FLSD Docket 01/17/2023 Page 9 of 23




                                                             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 527-1 Entered on FLSD Docket 01/17/2023 Page 10 of
                                             23



                                                        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 527-1 Entered on FLSD Docket 01/17/2023 Page 11 of
                                             23




                                                             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
DocuSignqudore Py FRU SSBS-EMA DbEdNENPS527-1 Entered on FLSD Docket 01/17/2023 Page 12 of
23

CERTIFICATION

Doi Nguyen (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 common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
(NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).

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 transactions Plaintiff has made in the Affected
Stocks during the class period 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.

DocuSigned by:
1/13/2023 wy,
Executed on [(

A8678EE17E8A416...

Doi Nguyen

DocuSign Envelope ID: 7F0419A5-5E73-4DF9-9715-581235ACE994
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 13 of
                                             23



                                                             SCHEDULE A

                                                             DOI NGUYEN

                                 PURCHASES                                           SALES

                             DATE          SHARES            PRICE              DATE      SHARES PRICE
                              AMC                                       AMC    2/1/2021      79    $15.02
                           Minimum                                      AMC    2/1/2021       3    $15.02
                             opening                                     BB   1/29/2021   929.8394 $16.04
                           position 30
                              shares
                               BB
                            minimum
                             opening
                             position
                            929.8394
                AMC        1/29/2021           52            ($14.51)


             *Share totals rounded to the fourth decimal.
DocuSign Envelope ID: E9084DC4-10F3-4ECD-B5BD-205E95599FDD
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 14 of
                                             23



                                                       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 527-1 Entered on FLSD Docket 01/17/2023 Page 15 of
                                             23



                                                         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: 6FB5FBD9-EE4A-4F5D-B876-2182F172DF3E
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 16 of
                                             23



                                                       CERTIFICATION

                   Marcel Poirier (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 common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
            Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
            GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
            (NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
            and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).

                     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 transactions Plaintiff has made in the Affected
            Stocks during the class period 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.
                            1/9/2023
            Executed on __________________                          _____________________________
                                                                             Marcel Poirier
DocuSign Envelope ID: 6FB5FBD9-EE4A-4F5D-B876-2182F172DF3E
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 17 of
                                             23



                                                             SCHEDULE A

                                                       MARCEL POIRIER

                                PURCHASES                                        SALES

                             DATE         SHARES         PRICE              DATE      SHARES PRICE
                           Minimum                                   BB   1/28/2021    5,000 $16.03
                            opening                                  BB   1/29/2021    3,000 $14.21
                            position                                 BB    2/1/2021    5,000 $14.77
                             15,000                                  BB    2/2/2021    4,000 $11.58
                             shares
                 BB        1/28/2021         8,000       ($19.49)


            *Rounded to the nearest cent.
            **May include averaged prices.
DocuSign Envelope ID: F05339A9-A99F-485C-9097-360D621624F3
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 18 of
                                             23



                                                         CERTIFICATION

                     Sandy Ng (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 common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
             Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
             GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
             (NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
             and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).

                      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 transactions Plaintiff has made in the Affected
             Stocks during the class period 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.
                             1/11/2023
             Executed on __________________                          _____________________________
                                                                                Sandy Ng
DocuSign Envelope ID: F05339A9-A99F-485C-9097-360D621624F3
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 19 of
                                             23



                                                             SCHEDULE A

                                                             SANDY NG
                                                             ACCOUNT 1

                              PURCHASES                                            SALES

                  DATE    SHARES                    PRICE                 DATE      SHARES   PRICE
                Minimum                                                                      Transfer
                 opening                                            GME 2/4/2021      55       Out
                 position                                                                    Transfer
                75 shares                                           GME 2/4/2021      75       Out
            GME 1/28/2021   55                     ($264.00)


                                                             ACCOUNT 2

                              PURCHASES                                            SALES

                 DATE    SHARES                     PRICE                DATE SHARES         PRICE
                Minimum                                             GME 2/4/2021 1,633       $56.89
                opening
                position
                  1,560
                 shares
            GME 2/4/2021   18                      ($78.50)
            GME 2/4/2021   55                     Transfer In
            GME 2/4/2021   75                     Transfer In



      *Rounded to the nearest cent.
      **Does not account for the July 22, 2022 4:1 stock split.
DocuSign Envelope ID: 5482EE6B-C8FC-47B3-8B98-C2B8615122A5
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 20 of
                                             23



                                                        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 527-1 Entered on FLSD Docket 01/17/2023 Page 21 of
                                             23



                                                             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: 7E4CA659-0AEB-420B-8659-4335BCD3C53B
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 22 of
                                             23



                                                       CERTIFICATION

                   Thomas Cash (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 common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
            Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
            GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
            (NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
            and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).

                     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 transactions Plaintiff has made in the Affected
            Stocks during the class period 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.
                           1/12/2023
            Executed on __________________                          _____________________________
                                                                              Thomas Cash
DocuSign Envelope ID: 7E4CA659-0AEB-420B-8659-4335BCD3C53B
       Case 1:21-md-02989-CMA Document 527-1 Entered on FLSD Docket 01/17/2023 Page 23 of
                                             23



                                                         SCHEDULE A

                                                        THOMAS CASH

                                PURCHASES                                      SALES

                         DATE          SHARES          PRICE              DATE      SHARES PRICE
                        Minimum                                  GME    1/28/2021     500  $132.00
                         opening
                         position
                        500 shares


            *Rounded to the nearest cent.
            **Does not account for the July 22, 2022 4:1 stock split.

File and source

File
gov.uscourts.flsd.590042.527.1.pdf
Size
1,643,336 bytes
SHA-256
e98dfa20d47b768bed49a3d601fac174ddbdb79f899db426c9fd39e1b171e92b
Our copy
gov.uscourts.flsd.590042.527.1.pdf
Original
archive.org
Back to top