Home/Source documents/Declaration Of Jeffrey A. Klafter In Support Of The Motion Of
Declaration Of Jeffrey A. Klafter In Support Of The Motion Of
Date
2023-04-10
Full text
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
Case No. 1:23-cv-21572 -CMA
DECLARATION OF JEFFREY A. KLAFTER IN SUPPORT OF THE MOTION OF
MOVANTS MAURICE SCARBOROUGH AND SCOTT SCHILLER FOR: (1)
APPOINTMENT AS LEAD PLAINTIFFS; AND (2) APPROVAL OF THEIR
SELECTION OF LEAD COUNSEL
Jeffrey A. Klafter hereby declares under penalty of perjury:
1. I am the Managing Partner of Klafter Lesser LLP (the “Klafter Lesser Firm”), proposed
Lead Counsel, together with the Pessah Law Group, PC (the “Pessah Firm”), for Lead Plaintiff
Movants Maurice Scarborough and Scott Schiller (“Movants”). I make this Declaration in
support of the Movants’ motion for (1) appointment as Lead Plaintiffs; and (2) approval of their
selection of the Klafter Lesser Firm and the Pessah Firm as Lead Counsel. I have been admitted
pro hac vice in this MDL pursuant to Pre-Trial Order No. 1 at ¶ 9 (ECF No. 46). I have personal
knowledge of the matters set forth herein and, if called upon, could and would completely testify
thereto.
2. Attached hereto as Exhibit A is a true and correct copy of the PSLRA Options Notice
published by my firm on April 10, 2023 by means of PR Newswire.
3. Attached hereto as Exhibit B are true and correct copy of each Movant’s PSLRA
Certification, which were attached to the Complaint Movants’ filed. ECF No. 1 in 1:23-cv-21572
-CMA.
4. Attached hereto as Exhibit C is a true and correct copy of a loss chart evidencing
Movants’ financial interest in the claims of the Options Class.
5. Attached hereto as Exhibit D is the Firm Resume of the Klafter Lesser Firm.
6. Attached hereto as Exhibit E is the Firm Resume of the Pessah Firm.
Case 1:21-md-02989-CMA Document 572-2 Entered on FLSD Docket 06/09/2023 Page 1 of 3
I declare under the penalty of perjury that the foregoing is true and correct.
Executed June 9, 2023
KLAFTER LESSER LLP
_/s/ Jeffrey Klafter_______________
Jeffrey A. Klafter
Case 1:21-md-02989-CMA Document 572-2 Entered on FLSD Docket 06/09/2023 Page 2 of 3
CERTIFICATE OF SERVICE
I hereby certify that on June 9, 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/ Jeffrey Klafter
Case 1:21-md-02989-CMA Document 572-2 Entered on FLSD Docket 06/09/2023 Page 3 of 3