Declaration of Laurence M. Rosen in Support of the Motion to Consolidate and Discontinue the Noticed Lead Plaintiff Process as Moot — In re January 2021 Short Squeeze Trading Litigation (Dkt. 565-2, S.D. Fla.)

Summary

A Declaration of Laurence M. Rosen in Support of the Motion to Consolidate and Discontinue the Noticed Lead Plaintiff Process as Moot (Document 565-2) in In re January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA, executed May 26, 2023 and entered on the FLSD docket the same day. Laurence M. Rosen, Lead Counsel for Lead Plaintiff Blue Laine-Beveridge and the named plaintiffs, supports Plaintiffs' motion to consolidate Maurice Scarborough et al v. Robinhood Financial LLC et al., No. 23-02622, originally filed in the Central District of California on April 6, 2023, with the Federal Securities Laws Tranche and to discontinue the noticed lead plaintiff process as moot. The three-page declaration states that since the Lead Plaintiff Order of October 15, 2021 no counsel asked Lead Plaintiff to pursue claims on behalf of options traders, and is signed /s/ Laurence M. Rosen.

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“Declaration of Laurence M. Rosen in Support of the Motion to Consolidate and Discontinue the Noticed Lead Plaintiff… (Dkt. 565-2).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-04-06-maurice-scarborough-et-al-v-robinhood-financial-llc-et-al/, SHA-256 c7905b6c7d0c10d4084a07ba954a42f7f037855ec3d090ba24e0ffedf802b8e7.

Full text

Case 1:21-md-02989-CMA Document 565-2 Entered on FLSD Docket 05/26/2023 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-2989-MDL-ALTONAGA/Damian

In re: JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION

This Document Relates to: All Actions Involving the Federal Securities Laws

DECLARATION OF LAURENCE M. ROSEN IN SUPPORT OF THE MOTION TO
CONSOLIDATE AND DISCONTINUE THE NOTICED
LEAD PLAINTIFF PROCESS AS MOOT

Laurence M. Rosen hereby declares under penalty of perjury:
1. I am the Managing Partner of The Rosen Law Firm, P.A., Lead Counsel for Lead
Plaintiff Blue Laine-Beveridge, named plaintiffs Abraham Huacuja, Ava Bernard, Brendan
Clarke, Brian Harbison, Cecilia Rivas, Doi Nguyen, Joseph Gurney, Marcel Poirier, Sandy Ng,
Santiago Gil Bohórquez, and Thomas Cash (collectively “Plaintiffs” or “Proposed Class
Representatives”). I make this Declaration in support of the Plaintiffs’ motion to: (1) consolidate
a putative federal securities class action transferred to this Court by the JMDL Panel, styled
Maurice Scarborough et al v. Robinhood Financial LLC et al., No. 23-02622, originally filed in
the Central District of California on April 6, 2023 (the “Scarborough Action”), with the other cases
in the Federal Securities Laws Tranche; and (2) discontinue as moot the noticed lead plaintiff
process with respect to the Scarborough Action.
2. I am an attorney duly licensed to practice in the State of Florida and before this
Court. I have personal knowledge of the matters set forth herein and, if called upon, I could and
would completely testify thereto.
3. Since the Lead Plaintiff Order was issued on October 15, 2021, neither counsel in
the Scarborough Action, nor counsel for any other injured investors, requested that Lead Plaintiff
pursue claims in the Federal Securities Laws Tranche on behalf of options traders.
Case 1:21-md-02989-CMA Document 565-2 Entered on FLSD Docket 05/26/2023 Page 2 of 3

4. A good faith conference seeking to obtain the relief requested by this motion took
place telephonically on May 18, 2023. Counsel for the Scarborough Action was asked numerous
times why they suddenly decided, in April 2023, to file a new class action on behalf of options
traders long after the PSLRA lead plaintiff process had concluded. They repeatedly stated that it
was irrelevant why they waited so long to file claims on behalf of injured options traders and
claimed that they had received a number of inquiries from options investors.
5. We understand that there are more than 4,500 unique types of call options for the
companies at issue in the Scarborough Action complaint, with GME alone having more than 2,000
call contract types outstanding during the class period.
6. Attached hereto as Exhibit A is a true and correct copy of an email from Jeffrey
Klafter to Laurence Rosen, dated March 31, 2023.
7. Attached hereto as Exhibit B is a true and correct copy of an email from Jeffrey
Klafter to Laurence Rosen, dated May 5, 2023.
8. Attached hereto as Exhibit C is a true and correct copy of an email from Stuart
Chelin to Laurence Rosen and Kevin Orsini, dated May 10, 2023.
9. Attached hereto as Exhibit D is a true and correct copy of the Class Action
Complaint styled Maurice Scarborough et al v. Robinhood Financial LLC et al., No. 23-02622
(C.D. Cal. Apr. 6, 2023).
10. Attached hereto as Exhibit E is a true and correct copy of the purported PSLRA
notice that Klafter Lesser LLP, counsel in the Scarborough Action, issued on April 10, 2023,
entitled “Notice of Filing Securities Class Action Against Robinhood Markets, Inc. – HOOD.”

I declare under the penalty of perjury, under the laws of the United States of America, that
the foregoing is true and correct.

Executed: May 26, 2023

THE ROSEN LAW FIRM, P.A.

/s/Laurence M. Rosen
Laurence M. Rosen, Esq., Fla. Bar No. 0182877

2
Case 1:21-md-02989-CMA Document 565-2 Entered on FLSD Docket 05/26/2023 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on May 26, 2023, a true and correct copy of the foregoing document
was served by CM/ECF to the parties registered to the Court’s CM/ECF system.

/s/Laurence M. Rosen

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File: gov.uscourts.flsd.590042.565.2.pdf
Size: 135,139 bytes
SHA-256: c7905b6c7d0c10d4084a07ba954a42f7f037855ec3d090ba24e0ffedf802b8e7
Our copy: gov.uscourts.flsd.590042.565.2.pdf
Original: archive.org