Exhibit 4: Certification (Dkt. 559-6, S.D. Fla.)
Summary
Exhibit 4 (Document 559-6) in Case 1:21-md-02989-CMA, entered on the FLSD docket April 28, 2023, a 14-page set of DocuSign certifications. In each, a Plaintiff, beginning with Ava Bernard and ending with Thomas Cash, authorizes The Rosen Law Firm to file or amend an action under the federal securities laws against Robinhood Financial, LLC, Robinhood Securities LLC and Robinhood Markets, Inc. over the Affected Stocks, which include AMC Entertainment Holdings, GameStop Corp., Koss Corp., Nokia and Trivago. Each Plaintiff declares having reviewed a complaint against RH, not having traded at counsel's direction and being willing to serve as a lead plaintiff, and attaches a Schedule A of transactions. The final schedule lists Thomas Cash's purchase of 500 GME shares on 1/28/2021 at $132.00.
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- Date
- 2023-04-28
Cite this document
“Exhibit 4: Certification (Dkt. 559-6).”
Original at archive.org, dated 2023-04-28. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-04-28-covid-era-misc-5e0449d1-1/
, SHA-256 5e0449d1fccc06dba8d307214915bc026388c40677b7c4b7f58093f58e1706e6.Full text
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 1 of 14
EXHIBIT 4
DocuSign Envelope ID: 51AFA7A0-160C-42C0-B8DE-B952D8CAD3BC
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 2 of 14
CERTIFICATION
Ava Bernard (the “Plaintiff”) authorizes The Rosen Law Firm, P.A. to file an action or
amend a current action under the federal securities laws to recover damages and to seek other relief
against ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC, ROBINHOOD
MARKETS, INC. (collectively “RH”) and others in connection with the purchase and sale of one
or more of the common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
(NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed a complaint against RH and retained The Rosen Law Firm,
P.A.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of Plaintiff’s counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is a representative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is a list of all of the transactions Plaintiff has made in the Affected
Stocks during the class period set forth in the consolidated complaint:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as a representative party on behalf of a class in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as a representative party beyond
Plaintiff’s pro rata share of any recovery, except reasonable costs and expenses, such as travel
expenses and lost wages directly related to the class representation, as ordered or approved by the
court pursuant to law.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
4/4/2023
Executed on __________________ ______________________________
AVA BERNARD
DocuSign Envelope ID: 51AFA7A0-160C-42C0-B8DE-B952D8CAD3BC
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 3 of 14
SCHEDULE A
AVA BERNARD (ASSIGNED FROM COLLEEN COOKE)
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC AMC 2/2/2021 500 $8.99
minimum AMC 2/3/2021 1 $8.75
opening AMC 2/3/2021 9 $8.75
position AMC 2/3/2021 17 $8.75
1,000 AMC $8.75
2/3/2021 72
shares AMC 2/3/2021 401 $8.70
NOK
AMC 2/3/2021 499 $8.70
minimum
opening AMC 2/3/2021 100 $8.95
position AMC 2/3/2021 100 $8.95
100 AMC 2/3/2021 100 $8.95
ADSs AMC 2/3/2021 100 $8.95
AMC 2/3/2021 100 ($8.88) AMC 2/3/2021 100 $8.95
AMC 2/3/2021 29 ($8.88) AMC 2/3/2021 800 $8.91
AMC 2/3/2021 100 ($8.88) AMC 2/3/2021 500 $9.14
AMC 2/3/2021 71 ($8.88) AMC 2/3/2021 500 $9.26
AMC 2/3/2021 100 ($8.88) AMC 2/3/2021 500 $9.07
AMC 2/3/2021 100 ($8.88) AMC 2/3/2021 377 $9.15
AMC 2/3/2021 800 ($8.87) AMC 2/3/2021 10 $9.15
AMC 2/3/2021 500 ($9.10) AMC 2/3/2021 3 $9.15
AMC 2/3/2021 1000 ($9.33) AMC 2/3/2021 100 $9.15
AMC 2/3/2021 500 ($9.15) AMC 2/3/2021 10 $9.15
AMC 2/3/2021 500 ($9.24) AMC 2/3/2021 500 $9.21
AMC 2/3/2021 500 ($9.17) AMC 2/3/2021 500 $9.17
AMC 2/3/2021 500 ($9.26) AMC 2/3/2021 500 $9.25
AMC 2/3/2021 500 ($9.28) AMC 2/3/2021 500 $9.27
AMC 2/3/2021 500 ($9.32) NOK 2/3/2021 100 $4.65
AMC 2/3/2021 1 ($9.64)
DocuSign Envelope ID: 3C1C1891-2A9D-4865-9D1A-5D594DE4DA3B
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 4 of 14
ASSIGNMENT
Colleen Cooke, the undersigned Assignor (“Assignor”), hereby assigns, transfers, and sets
over to Ava Bernard (“Assignee”) all rights, title, ownership and interest of the Assignor in any
and all claims, demands, and causes of action of any kind whatsoever which the Assignor has or
may have arising from violations of the U.S. federal securities laws by ROBINHOOD
FINANCIAL, LLC, ROBINHOOD SECURITIES LLC, ROBINHOOD MARKETS, INC.
(collectively “RH”) and others in connection with the Assignor’s transactions in the securities of
the common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath & Beyond Inc.
(NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR), GameStop Corp.
(NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc. (NYSE: TR), or the
American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK) and Trivago N.V.
(NASDAQ: TRVG) (collectively “the Affected Stocks”).
Further, the Assignor hereby appoints Ava Bernard as her true and lawful attorney-in-fact
for the purpose of exercising all owners relating to such causes of action.
Ava Bernard has agreed to remit any proceeds received as a result of this Assignment to
the Assignor.
This Assignment may not be revoked without the written consent of Ava Bernard.
This Assignment shall be binding upon and inure to the benefit of the parties, their
successors and assigns.
4/4/2023
Executed on __________________ ______________________________
COLLEEN COOKE
DocuSign Envelope ID: E7C355EF-91A5-4712-AD01-3DCD5BD7B4FA
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 5 of 14
CERTIFICATION
Blue Laine-Beveridge (the “Plaintiff”) authorizes The Rosen Law Firm, P.A. to file an
action or amend a current action under the federal securities laws to recover damages and to seek
other relief against ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC,
ROBINHOOD MARKETS, INC. (collectively “RH”) and others in connection with the purchase
and sale of one or more of the common stock of AMC Entertainment Holdings, Inc. (NYSE:
AMC), Bed Bath & Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc.
(NYSE: EXPR), GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll
Industries Inc. (NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp.
(NYSE: NOK) and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed a complaint against RH and retained The Rosen Law Firm,
P.A.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of Plaintiff’s counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is a representative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is a list of all of the transactions Plaintiff has made in the Affected
Stocks during the class period set forth in the consolidated complaint:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as a representative party on behalf of a class in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as a representative party beyond
Plaintiff’s pro rata share of any recovery, except reasonable costs and expenses, such as travel
expenses and lost wages directly related to the class representation, as ordered or approved by the
court pursuant to law.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
4/27/2023
Executed on __________________ ______________________________
BLUE LAINE-BEVERIDGE
DocuSign Envelope ID: E7C355EF-91A5-4712-AD01-3DCD5BD7B4FA
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 6 of 14
SCHEDULE A
BLUE LAINE-BEVERIDGE
PURCHASES SALES
DATE SHARES PRICE*
AMC AMC 2/3/2021 15,000 $8.34
minimum
opening
position
as of
January
27, 2021
15,000
shares
* This was a single sale order for 15,000 shares that Robinhood broke into over 1,000 separate
lots for trade execution. The above lists the average price received for the single 15,000 share sale
order.
DocuSign Envelope ID: D0DC6659-8812-4252-9B17-31C39119CFE5
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 7 of 14
CERTIFICATION
Brian Harbison (the “Plaintiff”) authorizes The Rosen Law Firm, P.A. to file an action or
amend a current action under the federal securities laws to recover damages and to seek other relief
against ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC, ROBINHOOD
MARKETS, INC. (collectively “RH”) and others in connection with the purchase and sale of one
or more of the common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
(NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed a complaint against RH and retained The Rosen Law Firm,
P.A.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of Plaintiff’s counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is a representative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is a list of all of the transactions Plaintiff has made in the Affected
Stocks during the class period set forth in the consolidated complaint:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as a representative party on behalf of a class in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as a representative party beyond
Plaintiff’s pro rata share of any recovery, except reasonable costs and expenses, such as travel
expenses and lost wages directly related to the class representation, as ordered or approved by the
court pursuant to law.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
4/11/2023
Executed on __________________ ______________________________
BRIAN HARBISON
DocuSign Envelope ID: D0DC6659-8812-4252-9B17-31C39119CFE5
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 8 of 14
SCHEDULE A
BRIAN HARBISON
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC AMC 1/28/2021 1 $15.08
minimum AMC 1/28/2021 100 $13.02
opening AMC 1/28/2021 100 $13.02
position
201
shares
DocuSign Envelope ID: 91560725-E523-40FD-B1CD-18096F560196
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 9 of 14
CERTIFICATION
Joseph Gurney (the “Plaintiff”) authorizes The Rosen Law Firm, P.A. to file an action or
amend a current action under the federal securities laws to recover damages and to seek other relief
against ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC, ROBINHOOD
MARKETS, INC. (collectively “RH”) and others in connection with the purchase and sale of one
or more of the common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
(NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed a complaint against RH and retained The Rosen Law Firm,
P.A.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of Plaintiff’s counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is a representative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is a list of all of the transactions Plaintiff has made in the Affected
Stocks during the class period set forth in the consolidated complaint:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as a representative party on behalf of a class in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as a representative party beyond
Plaintiff’s pro rata share of any recovery, except reasonable costs and expenses, such as travel
expenses and lost wages directly related to the class representation, as ordered or approved by the
court pursuant to law.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
4/7/2023
Executed on __________________ ______________________________
JOSEPH GURNEY
DocuSign Envelope ID: 91560725-E523-40FD-B1CD-18096F560196
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 10 of
14
SCHEDULE A
JOSEPH GURNEY
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC AMC 1/28/2021 21.271952 $8.01
minimum BB 1/28/2021 41 $17.00
opening BB 1/28/2021 0.093681 $17.00
position
21.271952
shares
BB
minimum
opening
position
41.093681
shares
DocuSign Envelope ID: 61AC3732-C17D-4558-A525-E42F90F3D1E8
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 11 of
14
CERTIFICATION
Santiago Gil Bohórquez (the “Plaintiff”) authorizes The Rosen Law Firm, P.A. to file an
action or amend a current action under the federal securities laws to recover damages and to seek
other relief against ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC,
ROBINHOOD MARKETS, INC. (collectively “RH”) and others in connection with the purchase
and sale of one or more of the common stock of AMC Entertainment Holdings, Inc. (NYSE:
AMC), Bed Bath & Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc.
(NYSE: EXPR), GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll
Industries Inc. (NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp.
(NYSE: NOK) and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed a complaint against RH and retained The Rosen Law Firm,
P.A.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of Plaintiff’s counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is a representative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is a list of all of the transactions Plaintiff has made in the Affected
Stocks during the class period set forth in the consolidated complaint:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as a representative party on behalf of a class in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as a representative party beyond
Plaintiff’s pro rata share of any recovery, except reasonable costs and expenses, such as travel
expenses and lost wages directly related to the class representation, as ordered or approved by the
court pursuant to law.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
4/17/2023
Executed on __________________ ______________________________
SANTIAGO GIL BOHÓRQUEZ
DocuSign Envelope ID: 61AC3732-C17D-4558-A525-E42F90F3D1E8
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 12 of
14
SCHEDULE A
SANTIAGO GIL BOHÓRQUEZ
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC AMC 1/28/2021 183 $12.13
minimum AMC 1/28/2021 100 $12.21
opening AMC 1/28/2021 17 $12.38
position AMC 1/29/2021 100 $14.40
400 AMC 1/29/2021 81 $15.10
shares AMC 2/1/2021 100 $12.37
BB
AMC 2/2/2021 150 $9.99
minimum
opening BB 1/28/2021 100 $16.91
position BB 1/29/2021 100 $14.05
200 EXPR 1/28/2021 200 $6.11
shares EXPR 1/29/2021 173 $6.22
EXPR EXPR 1/29/2021 229 $5.60
minimum EXPR 2/1/2021 186 $5.16
opening EXPR 2/1/2021 14 $5.16
position NOK 1/28/2021 200 $4.93
788
shares
NOK
minimum
opening
position
200 ADSs
AMC 1/28/2021 81 ($16.02)
AMC 1/29/2021 100 ($12.81)
AMC 2/1/2021 150 ($15.20)
EXPR 1/28/2021 14 ($4.88)
*May reflect pre- and post-market transactions.
**Rounded to the nearest cent.
DocuSign Envelope ID: 42F16DD8-C77B-45F1-B8AC-1D26A188E3D3
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 13 of
14
CERTIFICATION
Thomas Cash (the “Plaintiff”) authorizes The Rosen Law Firm, P.A. to file an action or
amend a current action under the federal securities laws to recover damages and to seek other relief
against ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC, ROBINHOOD
MARKETS, INC. (collectively “RH”) and others in connection with the purchase and sale of one
or more of the common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
(NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed a complaint against RH and retained The Rosen Law Firm,
P.A.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of Plaintiff’s counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is a representative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is a list of all of the transactions Plaintiff has made in the Affected
Stocks during the class period set forth in the consolidated complaint:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as a representative party on behalf of a class in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as a representative party beyond
Plaintiff’s pro rata share of any recovery, except reasonable costs and expenses, such as travel
expenses and lost wages directly related to the class representation, as ordered or approved by the
court pursuant to law.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
4/11/2023
Executed on __________________ _____________________________
Thomas Cash
DocuSign Envelope ID: 42F16DD8-C77B-45F1-B8AC-1D26A188E3D3
Case 1:21-md-02989-CMA Document 559-6 Entered on FLSD Docket 04/28/2023 Page 14 of
14
SCHEDULE A
THOMAS CASH
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
Minimum GME 1/28/2021 500 $132.00
opening GME 2/3/2021 5 $90.13
position
500 shares
GME 1/28/2021 5 ($280.00)
*Rounded to the nearest cent.
**Does not account for the July 22, 2022 4:1 stock split.
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