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Exhibit 1 (Dkt. 532-1, S.D. Fla.)

Summary

Exhibit 1 (Document 532-1) in Case 1:21-md-02989-CMA, entered on the FLSD docket February 27, 2023, is a three-page excerpt of Plaintiffs' responses to requests for production. To Request No. 4, for all Documents, Communications or Social Media Posts concerning Robinhood or this Action, Plaintiffs object as overbroad and not proportional and state that they will produce responsive, non-privileged documents from the Relevant Time Period that concern the allegations in this case, making a good faith effort to produce public social media posts. To Request No. 11, for holdings and transactions in securities other than the Relevant Securities, Plaintiffs object as not relevant and will withhold the documents, and to a further request they object as unduly burdensome and state that they will not produce any tax returns.

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Date
2023-02-27

Cite this document

“Exhibit 1 (Dkt. 532-1).” Original at archive.org, dated 2023-02-27. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-02-27-covid-era-misc/, SHA-256 68c22a5fe09400d6c274ad452dad3afdf98357aa26bf06d0b4224f15cbc6b607.

Full text

Case 1:21-md-02989-CMA Document 532-1 Entered on FLSD Docket 02/27/2023 Page 1 of 3




                         Exhibit 1
Case 1:21-md-02989-CMA Document 532-1 Entered on FLSD Docket 02/27/2023 Page 2 of 3



                                   REQUEST FOR PRODUCTION NO. 4:

           REQUEST:        All Documents, Communications or Social Media Posts concerning

   Robinhood or this Action.

           PLAINTIFFS’ RESPONSE: Plaintiffs object to this Request to the extent it is not relevant

   to the parties’ claims and defenses and is overbroad and not proportional to the needs of the case

   because it is not limited in time and to the extent the Request seeks all Documents, Communications,

   or Social Media Posts that do not concern the allegations in this case. Plaintiffs will withhold

   Documents, Communications, or Social Media Posts: (a) outside of the Relevant Time Period; or

   (b) that do not concern the allegations in this case. Plaintiffs further object that the Request is

   overbroad to the extent it seeks information protected by any privilege and/or the attorney work-

   product doctrine. Plaintiffs will produce responsive, non-privileged documents, if any exist, during

   the Relevant Time Period and that concern the allegations in this case. To the extent this Request

   seeks Social Media Posts that are in the public domain, they are equally available to Defendants;

   however, Plaintiffs will make a good faith effort to produce them after a reasonable search.

                                   REQUEST FOR PRODUCTION NO. 11:

           REQUEST: Documents sufficient to identify each of Your holdings, investments, and

   transactions in any securities other than the Relevant Securities during the Relevant Time Period.

           PLAINTIFFS’ RESPONSE: Plaintiffs object that this Request asks solely about securities

   other than the Relevant Securities, and accordingly is neither relevant to the parties’ claims and

   defenses nor proportional to the needs of the case. Plaintiffs will withhold the requested Documents,

   if any exist.
Case 1:21-md-02989-CMA Document 532-1 Entered on FLSD Docket 02/27/2023 Page 3 of 3



                                   REQUEST FOR PRODUCTION NO. 12:

          REQUEST: Your federal and state income tax returns for the most recent three years,

   including tax returns for any businesses You own, limited to Internal Revenue Service Form 1040,

   U.S. Individual Income Tax Return and Schedules A, B, D and E and the IRS worksheets related to

   these schedules, or the equivalent for any other type of return.

          PLAINTIFFS’ RESPONSE: Plaintiffs object to this Request because Plaintiffs’ federal

   and state income tax returns are neither relevant to the parties’ claims and defenses in the case, nor

   proportional to the needs of the case because the Request is unduly burdensome and appears to be

   designed to harass. Moreover, Plaintiffs object to this Request to the extent that it is cumulative. As

   set forth above, Plaintiffs have agreed to produce documents sufficient to identify transactions in

   the Relevant Securities during the Relevant Time Period. Plaintiffs will not produce any tax returns

   in response to this Request.

File and source

File
gov.uscourts.flsd.590042.532.1.pdf
Size
78,601 bytes
SHA-256
68c22a5fe09400d6c274ad452dad3afdf98357aa26bf06d0b4224f15cbc6b607
Our copy
gov.uscourts.flsd.590042.532.1.pdf
Original
archive.org
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