Declaration of Laurence M. Rosen in Support of Plaintiffs' Reply Memorandum of Law in Further Support of Plaintiffs' Motion for Class Certification — In re January 2021 Short Squeeze Trading Litigation (Dkt. 585-1, S.D. Fla.)

Summary

A Declaration of Laurence M. Rosen in Support of Plaintiffs' Reply Memorandum of Law in Further Support of Plaintiffs' Motion for Class Certification (Document 585-1) 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 30, 2023. Rosen, Managing Partner of The Rosen Law Firm and Lead Counsel for Lead Plaintiff Blue Laine-Beveridge, declares under penalty of perjury that the attached exhibits include the exhibit indexes to the depositions of Alvan Chow and Joseph Fonicello and the transcripts of the depositions of Daniel Fischel, taken April 12, 2023, and Steven Grenadier, taken April 19, 2023. The four-page declaration is executed June 30, 2023 and signed by Laurence M. Rosen.

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Date: 2023-04-25

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“Declaration of Laurence M. Rosen in Support of Plaintiffs' Reply Memorandum of Law in Further Support of Plaintiffs'… (Dkt. 585-1).” Original at archive.org, dated 2023-04-25. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-04-25-covid-era-misc-d09add2f-1/, SHA-256 d09add2f2d4473d7d69eb14dcc4dc5ac56f92a367a635352ca1e2fed5e99b06a.

Full text

Case 1:21-md-02989-CMA Document 585-1 Entered on FLSD Docket 06/30/2023 Page 1 of 4

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 PLAINTIFFS’ REPLY
MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFFS’ MOTION FOR
CLASS CERTIFICATION

I, Laurence M. Rosen, hereby declare 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”). I make this Declaration in

support of Plaintiffs’ reply memorandum of law in further support of Plaintiffs’ motion for class

certification.

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 35 is a true and correct copy of the exhibit index to the

deposition of Alvan Chow, taken on April 25, 2023.

4. Attached hereto as Exhibit 36 is a true and correct copy of the exhibit index to the

deposition of Joseph Fonicello, taken on April 4, 2023.
Case 1:21-md-02989-CMA Document 585-1 Entered on FLSD Docket 06/30/2023 Page 2 of 4

5. Attached hereto as Exhibit 37 is a true and correct copy of the transcript of the

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

6. Attached hereto as Exhibit 38 is a true and correct copy of the transcript of the

deposition of Steven Grenadier, Ph. D., taken on April 19, 2023.

7. Attached hereto as Exhibit 39 is a true and correct copy of a Seeking Alpha post

entitled, When Will the Ride End? Analyzing GameStop Short Squeeze By Looking at History, from

February 1, 2021. It was marked as exhibit 115 in the deposition of Daniel Fischel.

8. Attached hereto as Exhibit 40 is a true and correct copy of a post on Medium.com

entitled, Danger to All Robinhooders, from June 19, 2020.

9. Attached hereto as Exhibit 41 is a true and correct copy of a post on Medium.com

entitled, Retail Investor Euphoria Will Come To Tears and Cause a Long-Term Cultural, Political

and Regulatory Reckoning for Financial Engineering, from June 23, 2020.

10. Attached hereto as Exhibit 42 is a true and correct copy of an article by Brad M.

Barber, et al., entitled, Attention-Induced Trading and Returns: Evidence From Robinhood Users,

published in The Journal of Finance in December, 2022.

11. Attached hereto as Exhibit 43 is a true and correct copy of an article written by

Vlad Tenev, entitled Robinhood Users Come Under Attack, published in the Wall Street Journal

on September 27, 2021.

12. Attached hereto as Exhibit 44 is a true and correct copy of an article by Annie

Massa, et al., entitled Robinhood’s Collateral-Crunch Explanation Puzzles Wall Street, published

on Bloomberg on February 6, 2021.

13. Attached hereto as Exhibit 45 is a true and correct copy of an article by Richard

Roll, entitled R2, published in The Journal of Finance in July, 1988.

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Case 1:21-md-02989-CMA Document 585-1 Entered on FLSD Docket 06/30/2023 Page 3 of 4

14. Attached hereto as Exhibit 46 is a true and correct copy of a treatise by Andrei

Shleifer, entitled Inefficient Markets, published by Oxford University Press in 2000.

15. Attached hereto as Exhibit 47 is a true and correct copy of charts showing the losses

incurred during the Class Period by Lead Plaintiff Blue Laine-Beveridge and Named Plaintiffs

Joseph Gurney, Marcel Poirier, and Thomas Cash.

16. Attached hereto as Exhibit 48 is a true and correct copy of a chart showing the

adequacy of Plaintiffs by identifying citations to Plaintiffs’ deposition transcripts and declarations.

17. Attached hereto as Exhibit 49 is a true and correct copy of an article by Eugene

Fama, entitled Two Pillars of Asset Pricing, published in the American Economic Review in June,

2014.

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

Executed: June 30, 2023

THE ROSEN LAW FIRM, P.A.

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

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Case 1:21-md-02989-CMA Document 585-1 Entered on FLSD Docket 06/30/2023 Page 4 of 4

CERTIFICATE OF SERVICE

I hereby certify that on June 30, 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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Our copy: gov.uscourts.flsd.590042.585.1.pdf
Original: archive.org