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
- Original
- archive.org