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 — In re January 2021 Short Squeeze Trading Litigation (Dkt. 572-2, S.D. Fla.)

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A Declaration of Jeffrey A. Klafter in Support of the Motion of Movants Maurice Scarborough and Scott Schiller for Appointment as Lead Plaintiffs and Approval of Their Selection of Lead Counsel (Document 572-2) in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA, U.S. District Court for the Southern District of Florida, entered on the FLSD docket June 9, 2023 and relating to Case No. 1:23-cv-21572-CMA. Klafter, Managing Partner of Klafter Lesser LLP and proposed Lead Counsel with the Pessah Law Group, PC, declares under penalty of perjury that the exhibits are the PSLRA Options Notice published April 10, 2023 by PR Newswire, each Movant's PSLRA Certification, a loss chart of the Movants' financial interest in the claims of the Options Class and both firms' resumes. The three-page declaration is executed June 9, 2023 and signed by Jeffrey Klafter.

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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

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