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Declaration Of Laurence M. Rosen In Support Of Plaintiffs’ (dated 2023-04-12)

Summary

A Declaration of Laurence M. Rosen in Support of Plaintiffs' Memorandum of Points and Authorities in Opposition to Motion to Exclude the Opinions of Dr. Adam Werner on Market Efficiency (Document 582-1) in In re January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA, in the U.S. District Court for the Southern District of Florida, executed June 21, 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, attaches as Exhibit 1 and Exhibit 2 the depositions of Daniel R. Fischel, taken April 12, 2023, and Steven Grenadier, taken April 19, 2023, as Exhibit 3 the declaration of Adam Werner dated June 21, 2023, and as Exhibit 4 the expert report of Adam Werner filed in the Shen v. Exela Technologies case. The three-page declaration is signed /s/ Laurence M. Rosen.

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Date
2023-04-12

Cite this document

“Declaration Of Laurence M. Rosen In Support Of Plaintiffs’.” Original at archive.org, dated 2023-04-12. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-04-12-werner-filed-in-shen-v-exela-technologies-inc-20-cv-00691-n-d-tex-apr-14-2023/, SHA-256 c6670428476884ff6c844b2e846e774fa024663d9ad9ca0239ee7fa4f71f98ef.

Full text

Case 1:21-md-02989-CMA Document 582-1 Entered on FLSD Docket 06/21/2023 Page 1 of 3




                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA

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


     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 PLAINTIFFS’
     MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO MOTION
    TO EXCLUDE THE OPINIONS OF DR. ADAM WERNER ON MARKET EFFICIENCY

    I, Laurence M. Rosen, hereby declare under penalty of perjury:

           1.      I am the Managing Partner of The Rosen Law Firm, P.A. (“Rosen Law”), 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”). I make

    this Declaration in support of Plaintiffs’ memorandum of points and Authorities in Opposition to

    Motion to Exclude the Opinions of Dr. Adam Werner on Market Efficiency.

           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.      Attached hereto as Exhibit 1 is a true and correct copy of the transcript of the

    deposition of Daniel R. Fischel, taken April 12, 2023.

           4.      Attached hereto as Exhibit 2 is a true and correct copy of the transcript of the

    deposition of Steven Grenadier, taken April 19, 2023.
Case 1:21-md-02989-CMA Document 582-1 Entered on FLSD Docket 06/21/2023 Page 2 of 3




           5.      Attached hereto as Exhibit 3 is a true and correct copy of the declaration of Adam

    Werner, dated June 21, 2023.

           6.      Attached hereto as Exhibit 4 is a true and correct copy of the expert report of Adam

    Werner filed in Shen v. Exela Technologies, Inc., 20-cv-00691 (N.D. Tex. Apr. 14, 2023)

           7.      Attached hereto as Exhibit 5 is a true and correct copy of the expert report of Adam

    Werner filed in In Re XL Fleet Corp Securities Litigation, 21-CV-02002 (S.D.N.Y. Mar. 10, 2023)

           8.      Attached hereto as Exhibit 6 is a true and correct copy of the report “What Should

    We Expect When Testing for Price Response to News in Securities Litigation,?” by David Tabak,

    for NERA Economic Consulting, dated August 2016.

           9.      Attached hereto as Exhibit 7 is a true and correct copy of the article “Robinhood

    Users Come Under Attack,” by Vlad Tenev, which appeared in the Wall Street Journal on September

    27, 2021.

           10.     Attached hereto as Exhibit 8 is a true and correct copy of an excerpt from R,

    Introduction to Mathematical Statistics (6th ed.) by .V. Hogg, J.W. McKean & A.T. Craig p. 133-34.

           I declare under the penalty of perjury that the foregoing is true and correct.


    Executed: June 21, 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 582-1 Entered on FLSD Docket 06/21/2023 Page 3 of 3




                                   CERTIFICATE OF SERVICE

           I hereby certify that on June 21, 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




                                                   3

File and source

File
gov.uscourts.flsd.590042.582.1.pdf
Size
202,396 bytes
SHA-256
c6670428476884ff6c844b2e846e774fa024663d9ad9ca0239ee7fa4f71f98ef
Our copy
gov.uscourts.flsd.590042.582.1.pdf
Original
archive.org
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