Exhibit 11: Deposition of Sandy Gar-Lun Ng (Dkt. 567-11, S.D. Fla.)
Summary
Exhibit 11 (Document 567-11) in In re January 2021 Short Squeeze Trading Litigation, Case No. 1:21-MD-2989-CMA (Case 1:21-md-02989-CMA), in the U.S. District Court for the Southern District of Florida, entered on the FLSD docket June 7, 2023: a 109-page transcript of the videotape deposition of Sandy Gar-Lun Ng, taken via Zoom videoconference on March 31, 2023 beginning at 11:00 a.m. and concluding at 1:42 p.m., Eastern Standard Time, before Maureen Ratto, RPR, CCR, and produced by Veritext Legal Solutions. Laurence Rosen and Michael Cohen of The Rosen Law Firm appear for Plaintiffs and Daniel Slifkin and Robert DeNunzio of Cravath Swaine & Moore, LLP for Defendants, with Adam Venturini as legal videographer. The transcript ends with Mr. Slifkin stating there are no further questions and Mr. Rosen stating none for Mr. Ng.
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Cite this document
“Exhibit 11: Deposition of Sandy Gar-Lun Ng (Dkt. 567-11).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-07-covid-era-misc-0163ade9-1/
, SHA-256 0163ade91f281995156b3103f08a5770eb331a7daaca168c108b1681c9109e01.Full text
Case 1:21-md-02989-CMA Document 567-11 Entered on FLSD Docket 06/07/2023 Page 1 of
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Exhibit 11
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Page 1
1 UNITED STATES DISTRICT COURT
2 SOUTHERN DISTRICT OF FLORIDA
3
4 Case No. 1:21-MD-2989-CMA
5 -----------------------------x
6 In Re: JANUARY 2021 SHORT
7 SQUEEZE TRADING LITIGATION
8 -----------------------------x
9
10 VIDEOTAPE DEPOSITION OF
11 SANDY GAR-LUN NG
12 VIA ZOOM VIDEOCONFERENCE
13 March 31, 2023
14 11:00 a.m.
15
16
17
18
19
20
21
22
23 Reported by:
24 Maureen Ratto, RPR, CCR
25
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1 * * *
2
3 Videotape deposition of Sandy
4 Gar-Lun Ng held virtually via Zoom
5 Teleconference, hosted from Veritext
6 Legal Solutions, pursuant to notice,
7 before Maureen Ratto, Certified Court
8 Reporter, License No. XI01165,
9 Registered Professional Reporter,
10 License No. 817125, and Notary Public.
11
12 * * *
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 A P P E A R A N C E S:
2
3 Counsel for Plaintiffs:
4 THE ROSEN LAW FIRM
5 275 Madison Avenue
6 New York, New York 10016
7 BY: LAURENCE ROSEN, ESQ.
8 lrosen@rosenlegal.com
9 MICHAEL COHEN, ESQ.
10 mcohen@rosenlegal.com
11
12 Counsel for Defendants:
13 CRAVATH SWAINE & MOORE, LLP
14 825 Eighth Avenue
15 New York, New York 10019
16 BY: DANIEL SLIFKIN, ESQ.
17 Dslifkin@cravath.com
18 ROBERT DeNUNZIO, ESQ.
19 rdenunzio@cravath.com
20
21 ALSO PRESENT:
22 Adam Venturini, Legal Videographer
23
24
25
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1 VIDEOGRAPHER: Good morning.
2 We are going on the record 10:59
3 a.m. Eastern Standard Time on March
4 31st, 2023.
5 Please note that this
6 deposition is being conducted
7 virtually. Quality of recording
8 depends on quality of camera and
9 internet connections of
10 participants. What is seen from the
11 witness and heard on screen is what
12 will be recorded.
13 Audio and video recording will
14 continue to take place unless all
15 parties agree to go off the record.
16 This is Media Unit 1 of the
17 video-recorded deposition of Sandy
18 Ng in the matter of In Re: January
19 2021 Short Squeeze Trading
20 Litigation, filed in the United
21 States District Court for the
22 Southern District of Florida, Case
23 No. 1:21-MD-2989-CMA.
24 This deposition is being
25 conducted remotely using virtual
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1 technology. My name is Adam
2 Venturini representing Veritext and
3 I am the videographer. The court
4 reporter today is Maureen Ratto
5 from the firm Veritext.
6 I'm not authorized to
7 administer an oath, I'm not related
8 to any party in this action, nor am
9 I financially interested in the
10 outcome.
11 If there are any objections to
12 proceeding please state them at the
13 time of your appearance.
14 Counsel and all present,
15 including those remotely, will now
16 state their appearances and
17 affiliations for the record,
18 beginning with the noticing
19 attorney.
20 MR. SLIFKIN: Good morning. My
21 name is Daniel Slifkin. I'm a
22 partner in the law firm of Cravath,
23 Swaine & Moore. I'm here
24 accompanied by my colleague Robert
25 DeNunzio, who is off camera but
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1 SANDY GAR-LUN NG
2 present in the room and we
3 represent the defendants in this
4 litigation.
5 MR. ROSEN: This is Laurence
6 Rosen. I am representing Mr. Ng,
7 as well as the other plaintiffs,
8 proposed Class Representatives in
9 this action from the Rosen Law
10 Firm.
11 * * *
12 SANDY GAR-LUN NG, having been first
13 duly sworn according to law by the
14 Officer, testifies as follows:
15 DIRECT EXAMINATION BY MR. SLIFKIN:
16 Q. Could you please give us your
17 full name?
18 A. My name is Sandy Gar-Lun Ng.
19 Q. And what is your current
20 address, Mr. Ng?
21 A. It is
22 .
23 Q. And are you a Canadian
24 citizen?
25 A. That is correct.
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2 Q. And do you both live and work
3 in Canada?
4 A. Yes, I do.
5 Q. Have you been involved in any
6 legal proceedings prior to this one?
7 A. No.
8 Q. Not involved in any civil
9 proceedings?
10 A. Correct.
11 Q. And I take it you weren't
12 involved in any criminal proceedings?
13 A. I have not been involved in
14 any of that.
15 Q. Do you understand that you are
16 a plaintiff in this action?
17 A. Yes, I do.
18 Q. What is your understanding of
19 your role as plaintiff in this matter?
20 A. I understand as a class
21 representative that there are other
22 people similar to me who feel they've
23 suffered loss.
24 Q. So you used the phrase "class
25 representative" in your prior answer.
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2 In order to get on the same
3 page, could you just give me your
4 understanding of what that is?
5 A. To provide information to my
6 lawyers that also -- and to also, like,
7 best represent the other plaintiffs who
8 are not here with us.
9 Q. Okay. When you say your
10 lawyers, are you referring to Mr. Rosen
11 and his colleagues at the Rosen Law Firm?
12 A. That is correct.
13 Q. So when did you first hear
14 about this lawsuit?
15 A. I didn't really hear about the
16 lawsuit, I was kind of upset with what
17 happened to me and I did a Google Search
18 and the Rosen Law Firm appeared in one of
19 my searches.
20 Q. Okay. So perhaps you can just
21 in your own words explain to us how you
22 came to be a plaintiff here? I don't want
23 you to get into any conversations you had
24 with your lawyers.
25 A. How? Yeah, like, I sold shares
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2 in GME at a loss, and I understood that
3 Robinhood had disabled the buy button and
4 I was a bit upset about that.
5 Q. So you -- when you say you did
6 a Google Search, what was your Google
7 Search?
8 A. Class action Robinhood.
9 Q. And when did you do that
10 Google Search, approximately?
11 A. Oh, last year sometime,
12 summer.
13 Q. Okay. And the Google results
14 led you to the Rosen Law Firm; is that
15 fair?
16 A. Yeah. I'd say that's fair.
17 Q. And again, without -- I don't
18 want to know what you said to them or
19 they said to you, but could you just tell
20 me the steps along the way what
21 ultimately you became a plaintiff?
22 A. I had emailed a couple other
23 law firms and had not received a reply. I
24 went onto the Rosen Law Firm and I
25 submitted my information and after a
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2 period of time they reached out and we
3 connected.
4 Q. Okay. And you think that was
5 sometime in 2022?
6 A. It was some time ago.
7 Q. You mentioned, what you said a
8 few moments ago, that Robinhood had
9 disabled the buy button. Can you just
10 sort of elaborate for us on what you mean
11 by that?
12 A. So there was a period of time
13 when the stocks tanked and I didn't
14 understand why and on the Reddit forums
15 people were saying that they couldn't buy
16 the shares that they wanted. So something
17 was amiss there and that shouldn't
18 happen, in my opinion.
19 Q. Okay. And when did you first
20 learn that Robinhood had disabled the buy
21 button?
22 A. I can't remember the precise
23 time but it was sometime after I sold my
24 -- yeah, so my shares tanked severely and
25 I wanted to retain some of the value I
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2 had there so I sold and that's when, you
3 know, I saw the information on Reddit.
4 Q. Okay. And so that was my next
5 question. You mentioned Reddit forums.
6 Explain to us what you mean by Reddit
7 forums?
8 A. That's the social media
9 platform.
10 Q. Okay. I'm going to come back
11 to social media platforms in a minute.
12 Let me ask you a few more questions about
13 your background before we get into the
14 substance.
15 So when did you graduate high
16 school?
17 A. Around '94. It's been a while.
18 Q. And then did you have any
19 formal education beyond high school?
20 A. I did some college, about a
21 year and a half and I dropped out of
22 that.
23 Q. Where did you go to college
24 for a year and a half?
25 A. To a community college named
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2 Centennial College, it's in the Toronto
3 area.
4 Q. In Toronto, Canada?
5 A. Correct.
6 Q. What did you study at
7 Centennial College?
8 A. Microcomputer analyst.
9 Q. Sorry. I didn't quite follow
10 that. Is that, microcomputer analyst, is
11 that a subject or a vocation?
12 A. That's just the name of the
13 course. So it involved some accounting,
14 operations management, things like that.
15 Q. Did you do any, either at high
16 school or college, did you do any classes
17 in economics?
18 A. I did a grade 10 or 11 class
19 in economics.
20 Q. Was that like a microeconomics
21 class?
22 A. It covered both. It was a very
23 general course. I even remember the
24 instructor, Mr. Tessielli.
25 Q. You have a better memory than
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2 me. I can't remember my teachers in high
3 school.
4 A. He was a good economics
5 teacher, so I remember him. My other
6 teachers were rather forgettable.
7 Q. I'm embarrassed I can't
8 remember my teacher's name.
9 Have you ever heard the phrase
10 "the efficient market hypothesis"?
11 A. No, I haven't.
12 Q. Okay.
13 A. That sounds like a very
14 advanced thing.
15 Q. Okay. So when you dropped out
16 of college, what did you go to do then?
17 A. I worked for a friend who
18 opened up an internet cafe. I did that
19 for a period of time.
20 Q. And let me try and make this
21 quicker. Are you currently employed?
22 A. Yes, I am.
23 Q. By whom are you employed?
24 A. The Government of Nunavut,
25 Department of Health. I work in health
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2 IT.
3 Q. And what are your job
4 responsibilities?
5 A. I'm responsible for supporting
6 the electronic health record system, so I
7 teach the clinicians, other users, I also
8 support the videoconferencing,
9 telehealth. That's my main job.
10 Q. Since dropping out of college,
11 have you continually been employed
12 working in, you know, technology support,
13 if I can put it that way?
14 A. Yes, I have.
15 Q. And how long have you been in
16 your current job?
17 A. This particular job, since
18 March 2011.
19 Q. Okay. I want to -- now, what
20 I would like to do is show you something
21 that's previously been marked as an
22 exhibit. I don't know if you've been
23 through how you do that, how you look at
24 that with you.
25 A. I have that Veritext thing, if
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2 that's what you're talking about.
3 Q. The Veritext thing?
4 Okay. So somebody needs to
5 help me as to what we do, Robert. What do
6 you click on, files?
7 MR. DeNUNZIO: If you tell me
8 -- I have to upload it. So if you
9 tell me --
10 MR. SLIFKIN: Okay.
11 (Exhibit 2, letter from Rosen
12 Law Firm, dated February 27, 2023
13 re: Social media, having been
14 previously marked, is shown to the
15 Deponent.)
16 Q. I'm going to show you what's
17 previously been marked as Exhibit 2. And
18 since you work in IT hopefully you're
19 going to be better at this than I am.
20 MR. DeNUNZIO: If you refresh
21 the page.
22 MR. SLIFKIN: Okay.
23 THE WITNESS: I see it.
24 Q. And you have what was
25 previously marked as Exhibit 2. Do you
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2 see that?
3 A. Yes, I do.
4 Q. And if you go down to page 3
5 of the exhibit --
6 A. I'm there.
7 Q. -- do you see there's a box
8 which says Sandy Ng in it?
9 A. Correct.
10 Q. And is that you, Mr. Ng?
11 A. Yes, it is.
12 Q. And there is another box which
13 lists Reddit, Twitter, Facebook and
14 YouTube. Do you see that?
15 A. Yes.
16 Q. And under Reddit it has the
17 word is that your user name on
18 Reddit?
19 A. That is correct.
20 Q. Similarly, on Twitter is the
21 it the case you are ?
22 A. That is correct. Those are all
23 my accounts, yes.
24 Q. I'll just ask another couple
25 of questions so it's really crystal clear
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2 on the record.
3 On Facebook are you ?
4 A. Yes, I am.
5
6 Q. Totally understood. And on
7 YouTube are you
8 A. That is correct.
9 Q. Okay. Thank you for that.
10 So your Reddit account under
11 which you are identified as , for
12 how long have you had that account?
13 A. I've had it for quite some
14 time, at least eight years.
15 Q. So I take it in 2020 and 2021
16 on Reddit was your account?
17 A. Yes.
18 Q. And in that -- let me focus
19 now on that timeframe, late 2020, early
20 2021, are you with me?
21 A. Yes.
22 Q. Okay. In that time how
23 frequently did you use Reddit?
24 A. Daily, I'd say. It's a source
25 of entertainment so...
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2 Q. And if you recall, if you can
3 generalize, how frequently would you post
4 on Reddit during that time period?
5 A. Not particularly often.
6 Q. So you were primarily reading;
7 is that fair?
8 A. Yeah.
9 Q. All right. I want to ask you
10 some questions about your investment
11 history, okay?
12 Do you currently, as we sit
13 here today, invest in stocks and shares?
14 A. Yes.
15 Q. For how long have you been a
16 stock investor?
17 A. Probably since 2000.
18 Q. And what caused you to start
19 investing money in the stock market?
20 A. In that economics class we
21 talked earlier, there was a little stock
22 piece so I found that rather interesting.
23 Q. Do you have any particular
24 recollection of what you were told in
25 your economics class that caused you to
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2 start investing in the stock market?
3 A. No, I just found it fun, so it
4 seems like a way of making money.
5 Q. So you're Canadian, you live
6 in Canada, would you invest in Canadian
7 companies?
8 A. I have invested in the past,
9 yes.
10 Q. And I take it you've invested,
11 from what you told me already, in
12 American companies?
13 A. Yes.
14 Q. United States companies?
15 A. Correct.
16 Q. Do you invest in companies
17 based outside of the U.S. or Canada?
18 A. No.
19 Q. And your stock investments,
20 are they all securities that are traded
21 in either U.S. or Canadian exchanges?
22 A. Yes.
23 Q. Okay. So if we focus -- excuse
24 me. So you understand that this
25 litigation is called the January 2021
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2 Short Squeeze Trading Litigation, I take
3 it?
4 A. Yes.
5 Q. And to be clear, what's your
6 understanding of what a short squeeze is?
7 A. When there is huge buying
8 pressure often after, like, a margin
9 call, so people will need to cover and
10 purchase shares on the open market.
11 Q. Okay. There was a lot in
12 there. So you used the phrase margin call
13 and you used the phrase cover. I want to
14 make sure we're all on the same page
15 here.
16 Can you unpack what you said?
17 Or I can ask you more questions,
18 whichever you prefer.
19 A. What would you like me to
20 elaborate on?
21 Q. Okay. So you said, you talked
22 about margin calls. So explain to me what
23 a margin call is, in your understanding?
24 A. My understanding is that if
25 you're being loaned some money or shares
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2 you have to maintain a certain amount of
3 money and if you get called, then you
4 have to pay a share or put in more
5 capital or more money.
6 Q. Okay. And how does that relate
7 to the concept of short squeeze?
8 A. That relates when there's a
9 lot of demand for a particular equity and
10 then if there's -- if the demand is high
11 enough, the price will rise with that
12 demand.
13 Q. And how does that affect
14 margin calls?
15 A. Well, as prices rise --
16 MR. ROSEN: Objection.
17 Q. You can answer.
18 A. As the price rises the margin
19 calls become -- the capital required will
20 increase as well, so it's this loop.
21 Q. Okay. And so are you referring
22 to margin calls for people who are
23 shorting the stock?
24 A. Not necessarily. You can be
25 margin called just by holding stock by
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2 leveraging what you own.
3 Q. Okay. I'm not quite following.
4 So if you hold --
5 hypothetically if you hold XYZ stock, and
6 you borrowed money against it and the
7 market price of XYZ stock goes up, in
8 your understanding how can that lead to a
9 margin call?
10 MR. ROSEN: Objection. He's
11 not testifying as an expert
12 witness. So to the extent he has
13 knowledge, he can answer the
14 question.
15 Why don't you repeat your
16 question?
17 Q. So I gave you a hypothetical,
18 like a fictitious stock called XYZ. And
19 let's say you borrowed money against the
20 XYZ stock and then the value of the stock
21 goes up because the price goes up. In
22 your understanding can that lead to a
23 margin call?
24 A. If the stock goes up, no. If
25 it goes down it would, if I'm just
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2 borrowing.
3 Q. Okay. So if there's buying
4 pressure in your, as you described to me
5 earlier, if there is buying pressure and
6 the price of a stock goes up, I take it
7 the person who could be negatively
8 affected is a person who has a short
9 position; is that right?
10 A. Yes.
11 Q. And so is that -- to go back
12 to the use of the phrase short squeeze,
13 so is it fair to say in your
14 understanding a short squeeze can occur
15 to people who hold short positions if
16 there's a lot of buying pressure that
17 drives the stock up?
18 A. Yes.
19 Q. Okay. And when you used the
20 word "cover" in your prior answer, it's
21 those folks holding short positions who
22 need to then go out and buy more stock to
23 cover their position; is that fair?
24 A. Yes.
25 Q. Have you heard the phrase
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2 gamma squeeze?
3 A. Yes.
4 Q. What do you understand a gamma
5 squeeze to be?
6 A. That's supposed to be where
7 the price is astronomical.
8 Q. Can you unpack that? The price
9 of what is astronomical?
10 MR. ROSEN: Unpack what? He
11 said three words. There is nothing
12 to unpack. So if you have a
13 question you can ask it but --
14 Q. The question was, the price of
15 what is astronomical?
16 A. The share, whatever equity is
17 being shorted that you have to cover
18 with.
19 Q. And how do you define
20 astronomical?
21 A. I can't define astronomical,
22 it's whatever one feels what the price is
23 is.
24 Q. Is it fair to say a gamma
25 squeeze is a form of short squeeze?
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2 A. Yes.
3 Q. And in the -- a gamma squeeze
4 is an extreme form of short squeeze, in
5 which, in your words, the stock price
6 becomes astronomical?
7 A. Correct.
8 Q. In your understanding, what
9 causes a gamma squeeze?
10 A. The buying pressure.
11 Q. Okay. And you mentioned
12 Robinhood earlier and disabling the buy
13 button. Do you recall that?
14 A. Yes.
15 Q. Are you with me? Okay.
16 Are you currently a Robinhood
17 customer?
18 A. No, I am not.
19 Q. Have you ever been a Robinhood
20 customer?
21 A. Never.
22 Q. What -- who do you use for
23 your stock investments?
24 A. I use TD WebBroker.
25 Q. And is TD Toronto Dominion
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2 Bank?
3 A. Yes.
4 Q. And that's a Canadian bank, I
5 take it?
6 A. Yes.
7 Q. And you say -- I think you
8 used the word TD WebBroker. So is this an
9 online platform?
10 A. That is correct.
11 Q. When did you start using --
12 well, withdrawn.
13 I'm just going to use the
14 acronym TD, is that fair, rather than the
15 full name?
16 A. That's fine. Yeah.
17 Q. When did you start using TD?
18 A. The platform, probably mid
19 2000s.
20 Q. Who did you use for stock
21 investments prior to using TD?
22 A. E-Trade.
23 Q. Why did you switch from
24 E-Trade to TD?
25 A. It was just convenient since
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2 all my banking was done through TD.
3 Q. Do you still have an account
4 with TD?
5 A. Yes, I do.
6 Q. Can you tell us approximately
7 how much money you had invested in the
8 stock market when you started using TD in
9 the mid 2000s?
10 A. Probably or so. I
11 started small and just started adding to
12 it.
13 Q. And as we sit here today in
14 2023, approximately how much money have
15 you invested in the stock market?
16 MR. ROSEN: Objection. Look,
17 you are not going to ask him what
18 his wealth is.
19 If you want to ask him about a
20 specific investment, that's one
21 thing but he's not going to tell
22 you what the total value of his
23 nest egg or stock portfolio is.
24 That information is not at issue
25 here.
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2 Q. You can go ahead and answer
3 the question unless you are instructed
4 not to answer.
5 A. Can you repeat your question,
6 please?
7 MR. ROSEN: I'm going to
8 instruct Mr. Ng not to disclose his
9 total wealth or the total value of
10 the stock portfolio.
11 THE WITNESS: I will take my
12 counsel's advice.
13 MR. SLIFKIN: And are you
14 instructing him based upon a
15 privilege?
16 MR. ROSEN: I believe there is
17 a right of privacy to his total
18 personal wealth. That's not
19 something at issue and it's not
20 something that you are entitled to.
21 I've been doing this many many
22 years and that is the general
23 understanding.
24 So, you know, if you want to
25 take it up with the judge later, we
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2 can take it up with the judge and
3 you can get an order allowing him
4 to -- forcing him to give you that
5 answer, but today he will not give
6 it to you.
7 MR. SLIFKIN: Okay.
8 (Direction not to answer.)
9 Q. Let's focus in January of
10 2021, the time of -- the timeframe in
11 which this litigation is concerned.
12 At that point in time, January
13 of 2021, were you an investor in the
14 stock market?
15 A. Yes.
16 Q. And were all of your
17 investments in the stock market via TD?
18 A. Yes.
19 Q. And approximately how much
20 money did you have invested in the stock
21 market via TD as of January 1, 2021?
22 A. I feel that is related to the
23 previous objection by my counsel.
24 MR. ROSEN: You are trying to
25 get his total personal wealth and I
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2 don't think you are entitled to
3 that, Mr. Slifkin, I really don't.
4 MR. SLIFKIN: Are you
5 instructing him not to answer?
6 MR. ROSEN: Yeah. I'm
7 instructing him not to -- I mean
8 and then you're going to ask him,
9 well, if you spend $100,000 on this
10 trade, what percentage of your
11 total portfolio was that or
12 something like that.
13 I mean, I've been through --
14 you are not entitled to know his
15 total wealth and, you know, it's
16 just an invasion of privacy and I
17 don't think you are entitled to it.
18 If I'm wrong, then we'll give
19 you that number when the time
20 comes, but I don't think you're
21 entitled to it today.
22 MR. SLIFKIN: So the answer to
23 my question was; you are
24 instructing him not to answer?
25 MR. ROSEN: Yes, Mr. Slifkin.
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2 MR. SLIFKIN: Okay. And are
3 you asserting attorney-client
4 privilege?
5 MR. ROSEN: I am not asserting
6 attorney-client privilege. I
7 believe it's a privacy right,
8 privacy privilege.
9 (Direction not to answer.)
10 Q. Okay. Let's do it slightly
11 differently.
12 Let's focus on the period
13 let's say January, February and March of
14 2021, okay? Are you with me?
15 How many accounts did you have
16 at TD?
17 A. I have two main accounts and
18 they are divided between a Canadian
19 account and an American account. They can
20 be further subdivided by a cash account
21 or a registered account. The registered
22 account is sort of like a -- there's tax
23 consequences, I guess, like your IRA and
24 Roths in U.S.
25 Q. One thing I'm not is an expert
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2 on Canadian taxes. So can you --
3 MR. ROSEN: Mr. Ng is not an
4 expert either. If he understands
5 your question, he can answer.
6 Q. So you say there is a thing
7 called a cash account, a thing called a
8 registered account and you say it's a bit
9 like an IRA or Roth, and can you explain
10 to me which is which?
11 A. Well, I'm not really familiar
12 with the American registered accounts. I
13 just know they are registered accounts.
14 So in Canada we have a TFSA,
15 tax-free savings account where you put
16 money in and anything that happens to
17 that there is no tax consequences. I
18 cannot claim capital losses or gains in
19 that.
20 And then another account is
21 called an RSP or registered savings plan,
22 that is usually saved for retirement. I
23 can put money in there and at some point
24 if I take money out there are tax
25 consequences.
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2 Q. Okay. So --
3 A. So the account in question, to
4 let you know before you ask, is my GME
5 was in my tax-free savings account,
6 primarily.
7 Q. And is that --
8 A. And I had some in my cash
9 account, Canadian cash account.
10 Q. Okay. So your holdings of GME,
11 when you say that, you are referring to
12 GameStop, right?
13 A. Yes.
14 Q. Okay. And your principal
15 holdings of GME were in your TSA; is that
16 correct?
17 A. Yes, the TFSA.
18 Q. TFSA?
19 A. Tax-free savings account.
20 Q. Okay. Is that also what you
21 referred to as the tax account or not?
22 A. No. That's a separate account,
23 the cash account.
24 Q. Okay. So is the TFSA --
25 withdrawn.
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2 Is the TFSA a registered
3 account?
4 A. Yes.
5 Q. Okay. And in that account, am
6 I correct in saying, you can neither be
7 taxed or -- withdrawn. Let me unpack it.
8 So your GameStop stock was
9 principally held in your TFSA, correct?
10 A. Yes.
11 Q. That is what is called a
12 registered account in Canada, correct?
13 A. Yes. Yes.
14 Q. And TFSA stands for tax-free
15 savings account?
16 A. Yes.
17 Q. And that means any capital
18 gains you receive from stocks in that
19 account are not subject to taxation in
20 Canada; is that fair?
21 A. That is correct.
22 Q. Is it also the case that any
23 losses that you suffer in your TFSA are
24 not deductible for purposes of Canadian
25 taxes?
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2 A. That is correct.
3 Q. Okay. You previously told me
4 you had two main accounts, a Canadian
5 account and an American account, I think?
6 A. Yeah. So there's the cash
7 account is the Canadian side.
8 Q. And what is the American
9 account?
10 A. Well, so the TFSA also has a
11 Canadian portion which I wasn't using. So
12 it's split in two but I was using the
13 American side of the TFSA.
14 Q. Okay. And so when you
15 distinguished between an American account
16 and a Canadian account, are you referring
17 to the location of the exchanges upon
18 which the securities are traded?
19 A. No, just the currency in which
20 the account is currently holding.
21 Q. I see. So we have been
22 provided with some of your -- with some
23 of your account statements by counsel.
24 And I'll turn to them in a minute, but
25 generally, so in your TFSA where you held
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2 the GME stock, the numbers we see, should
3 those be in U.S. dollars?
4 A. For the most part, yes. The
5 TFSA is American and that is in USD.
6 Q. All right. Thank you. That's
7 extremely helpful.
8 Your investments in
9 securities, have they always been solely
10 on your own behalf?
11 A. Yes.
12 Q. Have you ever invested money
13 for other folks?
14 A. Only recently when I had mason
15 I opened up an RESP, a Registered
16 Education Savings Plan, otherwise it's
17 all for myself.
18 Q. And the accounts we've been
19 talking about, the TFSA, that's held in
20 your name, I take it?
21 A. That is correct.
22 Q. And have you ever used an
23 investment advisor?
24 A. No, I have not.
25 Q. Does TD provide you with any
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2 financial advisory services?
3 A. I'm sure they do.
4 Q. With respect to the --
5 focusing in with respect to the purchase
6 of tradeable securities, have they
7 provided you with those services?
8 A. There are tools for
9 self-discovery of these investments.
10 Q. Okay. Can you explain what you
11 mean by that?
12 A. If I select a particular
13 stock, they'll have various, I guess,
14 heads of people who are advisors and
15 their views on the particular stock.
16 There is also, like, Morningstar ratings
17 related to the stock.
18 Q. So I take it that -- sorry. I
19 didn't mean to interrupt you. Were you
20 finished?
21 A. No. Go ahead. No. Go ahead.
22 Q. Thank you. So I take it that
23 -- so TD is an online platform, correct?
24 A. Yes. It's a direct -- what do
25 you call it? -- a discount brokerage. So
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2 the services are limited to online there.
3 Q. If you are interested in a
4 particular stock, for example, GME, can
5 you sort of search it on the platform?
6 A. Yes.
7 Q. The platform then directs you
8 to certain information about that
9 security?
10 A. Just the Morningstar rating
11 which allows you to -- I can't remember
12 if it goes to the website or not, but...
13 Q. Well, you mentioned heads of
14 people who were advisors. Can you explain
15 what you mean by that?
16 A. Yes. So there are listings of
17 advisors from various other, I guess,
18 companies, and they just -- yeah, it's
19 just a list.
20 Q. And can you click on -- click
21 on a link and get a report?
22 A. Yeah. And then, not so much a
23 report but what their opinion is or what
24 their rating is on that particular stock.
25 Q. Like buy, hold or whatever?
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2 A. That's right.
3 Q. So let's focus in on the
4 beginning of 2021, so January 2021,
5 January 1st, I don't know what day of the
6 week that was, but as of the beginning of
7 January 2021 do you recall what stocks
8 you held in your TD accounts?
9 A. I think I had some Aurora
10 Cannabis stock, I had some probably
11 Bombardier, it's a Canadian company, I
12 held ETFs. Those are index stocks.
13 Q. ETFs being electronically
14 traded funds?
15 A. Correct.
16 MR. SLIFKIN: Okay. Why don't
17 I mark -- why don't we mark tab 9,
18 Robert. So you should see if you
19 refresh Exhibit 33.
20 And let me just identify the
21 production numbers. This is
22 P00002180 through 2212.
23 (Exhibit 33, TD Investment
24 account statement, beginning Bates
25 P00002180 was received and marked
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2 on this date for identification.)
3 Q. Let me know when you have
4 Exhibit 33.
5 A. I do have it up.
6 Q. Okay. Could you just take a
7 moment to flip through it?
8 A. Yes. They're my statements.
9 Q. Okay. Do you recognize what
10 Exhibit 33 contains?
11 A. They are my accounts, yes.
12 Q. That was going to be my
13 question. So can you tell us what these
14 are?
15 A. They are my investment account
16 statements.
17 Q. From TD?
18 A. That is correct.
19 Q. And do they cover the period
20 from January 1st, 2021 through March
21 31st, 2022?
22 A. To March 2022?
23 Q. Through March 31st, 2021. I
24 apologize.
25 MR. ROSEN: Take your time and
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2 go through them before you answer
3 the question.
4 Are these both accounts here,
5 Mr. Slifkin? Are they representing
6 two different accounts?
7 MR. SLIFKIN: I don't actually
8 know. I'm going to ask about that.
9 MR. ROSEN: Because one has an
10 opening balance. It looks like two
11 different accounts.
12 THE WITNESS: Yes. That's what
13 it looks like. You have the account
14 number redacted. But -- well, it
15 says "your TFSA statement", so that
16 you can tell is for the TFSA
17 account and the other would be the
18 cash account in the heading.
19 Q. If we look at the first page
20 of Exhibit 33, you see in the sort of
21 near the top right it says "your
22 investment account statement"?
23 A. Yes.
24 Q. And then if you look on page
25 2180 at the bottom, do you see that?
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2 A. Oh, yes.
3 Q. And if you go to 2183?
4 A. Yup.
5 Q. And it says "your TFSA
6 statement", do you see that?
7 A. Yes.
8 Q. So are those two different
9 accounts?
10 A. That is correct.
11 Q. Okay. So why don't we take a
12 look at the second page of Exhibit 33. So
13 this is your cash account, I take it?
14 A. Second page? Yes.
15 MR. ROSEN: That's Bates
16 stamped 2181?
17 MR. SLIFKIN: That's correct.
18 Q. So this is your investment
19 account statement. And is that the same
20 thing as your cash account?
21 A. Yes, this is the cash account.
22 Q. Okay. And this, am I correct
23 in saying that this shows the sale of
24 Aurora Cannabis stock and the purchase of
25 GameStop stock?
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2 A. That's what's happened there,
3 yes.
4 Q. Okay. So why did you decide to
5 sell your Aurora Cannabis stock?
6 A. Because I wanted to buy
7 GameStop.
8 Q. Okay. So it was for the
9 purposes of obtaining liquidity to
10 purchase another security, yes?
11 A. Correct.
12 Q. Next question. Why did you
13 want to purchase GameStop?
14 A. Why? Because I wanted to.
15 Q. But why did you want to?
16 A. Why? Because I saw a post on
17 Reddit that interested me.
18 Q. Do you recall what the Reddit
19 post said?
20 A. It was a post by DFV showing
21 his GME update.
22 Q. So on the second page of
23 Exhibit 33, the dates for the purchase of
24 GameStop is given as January 27th, 2021.
25 Do you see that?
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2 A. Yes.
3 Q. Was that when you put in the
4 instruction to purchase it or is that a
5 different date?
6 A. I believe that would have been
7 -- yeah. I'm not sure if that's the
8 settle date or what. I don't know.
9 Q. I take it you understand there
10 is a difference between, like, an order
11 date and a settlement date?
12 A. That's correct.
13 Q. And I'm going to come back to
14 that a little bit later.
15 So prior to your order date,
16 you had seen a post on Reddit by DFV; is
17 that correct?
18 A. That is correct.
19 Q. And who is DFV?
20 A. His user name is
21 DeepFuckingValue on Reddit.
22 Q. Okay. But do you know who that
23 person is?
24 A. Not personally.
25 Q. Do you have a name other than
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2 the acronym?
3 A. I've come to know him. He is
4 known on YouTube as Roaring Kitty and his
5 real name is Keith Gill.
6 Q. Let's take these in pieces.
7 Did you at the time follow DFV
8 on Reddit?
9 A. No, I did not.
10 Q. Did you watch Roaring Kitty on
11 YouTube?
12 MR. ROSEN: As of what date?
13 MR. SLIFKIN: I'm talking now
14 -- we're talking about January of
15 2021.
16 Q. Let me start again?
17 January of 2021 did you watch
18 Roaring Kitty videos on YouTube?
19 A. No, I did not.
20 Q. Have you ever watched Roaring
21 Kitty on YouTube?
22 A. Never.
23 Q. When did you start following
24 DFV on Reddit?
25 A. After I saw the post on my
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2 front page of Reddit.
3 Q. And was that in January of
4 2021?
5 A. Yes.
6 Q. And was that the post that
7 caused you to purchase GameStop stock?
8 A. It may not have been the
9 first, but I might have seen another
10 posts of his. I don't recall
11 specifically.
12 Q. Okay. And when did you first
13 learn that DFV was a user name for
14 somebody called Keith Gill?
15 A. That was probably after the
16 Congressional hearing where he had to
17 reveal himself.
18 Q. So that was subsequent to the
19 events we've been discussing, I take it?
20 A. Yes.
21 Q. So we were looking at the
22 second page of Exhibit 33. That's your
23 cash account, right?
24 A. Yes.
25 Q. So let's go forward to page
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2 2183.
3 A. Okay. TFSA account.
4 Q. And this at the top says, you
5 see under the redacted account number it
6 says Account Type: Tax-free savings
7 account CDN? Do you see that?
8 A. Yes.
9 Q. So CDN I assume means
10 Canadian?
11 A. Yes.
12 Q. And if we go to the next page,
13 am I correct in saying that in January
14 you sold Aurora Cannabis and Sabina Gold
15 and Silver out of this account?
16 A. Yes.
17 Q. And did you in January then
18 place an order for GameStop out of your
19 TFSA Canada account?
20 A. Probably in there.
21 Q. Could you see where it says on
22 the page 2184 it says Pending Activity?
23 A. There was a buy on 2183.
24 Q. If you look at 2184 --
25 A. Yeah. There is a buy on
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2 February 1st.
3 Q. And it says pending because
4 this is a statement dated January 31st,
5 right?
6 A. Yes.
7 Q. Okay. So, again, did you sell
8 Aurora Cannabis and Sabina Gold and
9 Silver in order to get liquidity to buy
10 GameStop?
11 A. Yes.
12 Q. And tell us what Sabina Gold
13 and Silver was?
14 A. It's a Canadian mining
15 company.
16 Q. Okay. Let's go forward to page
17 2186?
18 A. I'm there.
19 Q. Okay. And 2186 at the top you
20 see it says "your TFSA statement", are
21 you with me?
22 A. Yes.
23 Q. And am I right in saying that
24 this is the U.S. portion of your tax-free
25 savings account?
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2 A. Yes.
3 Q. And if we go to page 2187, it
4 shows activity towards the bottom. Do you
5 see that?
6 A. Yup.
7 Q. Give me one second just to
8 catch up here.
9 Am I right in saying that in
10 January of 2021 out of the U.S. portion
11 of your TFSA you sold Tesla stock?
12 A. Yes, I did.
13 Q. And why did you sell Tesla
14 stock?
15 A. Because I wanted to buy GME.
16 Q. So, again, for liquidity
17 reasons?
18 A. Yes.
19 Q. When did you originally
20 purchase the Tesla stock?
21 A. I can't remember.
22 Q. Did you make a profit on your
23 sale of the Tesla stock?
24 A. Yes.
25 Q. And did you take all that
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2 money from out of Tesla and put it into
3 GameStop?
4 A. That's correct.
5 Q. And if we look at the top of
6 page 2187 do you see where it says -- do
7 you see it says "GameStop Corp. CL-A
8 GME"? Do you see that?
9 A. Yes.
10 Q. And am I reading this
11 correctly to say as of January 1st, 2021
12 in, your U.S. denominated TFSA, you had
13
14 A. Yes.
15 Q. And that cost you somewhere
16 over
17 A. Yes.
18 Q. It had a market value at the
19 end of January of
20 MR. ROSEN: Objection.
21 Objection. First you got to ask a
22 question rather than make a
23 statement. But the document says
24 that. But whether he knows what the
25 actual value was and whether the
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2 document is correct is another
3 issue. So please reframe your
4 question.
5 Q. Sure. So in your -- so this is
6 your TFSA statement for January -- for
7 the month of January 2021, correct?
8 A. Yes, it's the official
9 statement.
10 Q. Okay. And was this mailed to
11 you? Did you get it online?
12 A. Online. I don't look at these,
13 generally speaking. They're horrible to
14 look at.
15 Q. So this, how do you track then
16 your investments in your TD account?
17 A. Online.
18 Q. How frequently, back in
19 January of 2021, how frequently did you
20 look online at your statements or
21 investments?
22 A. On the website, it was fairly
23 frequently, daily.
24 Q. Okay. So this statement says,
25 am I correct in reading this statement
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2 that it says the
3 that you held in your U.S. TFSA had a
4 market value of
5
6 A. That is indeed what it says.
7 Q. So as of January 31st, 2021
8 were you aware of that?
9 A. Yes.
10 Q. And so within less than a
11 month you had made more than a 200%
12 profit on your investment in GameStop, I
13 take it?
14 A. Yes, the numbers indicate
15 that.
16 Q. Okay. And again, you were
17 aware of that as of the end of January
18 2021?
19 A. Yup.
20 Q. Okay. So did you make --
21 withdrawn.
22 Did you consider selling your
23 GameStop stock in the beginning of
24 February of 2021?
25 MR. ROSEN: Objection, calls
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2 for speculation.
3 A. I considered it.
4 Q. Did you make a decision not to
5 sell?
6 A. Yes.
7 Q. I'm trying to understand. Was
8 that a conscious decision or were you
9 just holding it without paying any
10 attention to it?
11 A. Yeah, I held onto it. I felt
12 it could go up further.
13 Q. And what made you think that
14 it could go up further?
15 A. What? The possibility of a
16 squeeze.
17 Q. You mentioned the DFV post on
18 Reddit prior to the purchase of any
19 GameStop stock. Are you with me?
20 A. Yup.
21 Q. At that point in time did you
22 think there was a possibility of a
23 squeeze on GameStop?
24 A. It was mentioned but his
25 thesis was that this was an undervalued
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2 stock.
3 Q. Okay. Based upon the business
4 fundamentals, is that what you're saying?
5 A. Based on his -- yes, based on
6 his research.
7 Q. And did you do any of your own
8 research into the business fundamentals
9 of GameStop?
10 A. No, I did not.
11 Q. Throughout this period of
12 January, February and March of 2021, did
13 you do any research into the fundamental
14 business of GameStop?
15 A. Other than what Keith posted.
16 Q. So let's go forward in this
17 Exhibit, Exhibit 33, and go to page 2190.
18 A. Okay.
19 Q. So am I correct in saying this
20 is the first page of your investment
21 account statement for February 2021 in
22 your Canadian cash account?
23 A. Correct.
24 Q. And if we go to the next page
25 2191, it shows a February 4th transfer
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2 out of GameStop stock?
3 A. Yes.
4 Q. Were you just moving that to
5 your U.S. cash account?
6 A. The U.S. TFSA account.
7 Q. Well, so can you go forward
8 then to 2193 and 2194 --
9 A. Okay.
10 Q. -- and look at 2194. That
11 shows a transfer in of 75 shares of
12 GameStop. Do you see that?
13 A. Yes.
14 Q. Are those the ones that came
15 out of the Canadian cash account?
16 A. Yes. So it looks like it was
17 from the Canadian cash to the U.S. cash,
18 I guess. Let's see. Yeah.
19 Q. And then you sold it; is that
20 fair?
21 A. Eventually, yes.
22 Q. Okay. And then if we go to
23 2196, this is your Canadian TFSA,
24 correct?
25 A. Yes.
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2 Q. And you buy, in February you
3 buy 55 shares of GameStop, correct?
4 A. Yes.
5 Q. And that's what's previously
6 seen as a pending order. Am I reading
7 that right?
8 A. I believe so.
9 Q. And then you transfer that out
10 of your Canadian TFSA also in February,
11 right?
12 A. Yes.
13 MR. ROSEN: Mr. Slifkin, it's
14 not clear whether these are trade
15 dates or settlement dates. So
16 unless the witness knows for sure,
17 I wouldn't put words in his mouth.
18 I think we're better off seeing the
19 confirmations.
20 Do you remember, Mr. Ng,
21 whether these are settlement dates
22 or trade dates?
23 THE WITNESS: I don't know. I
24 don't look at these statements.
25 Q. Well, I think we can clear
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2 that up in a minute or two.
3 But for now, this a statement
4 for February, right? That we can agree
5 upon?
6 A. Yes.
7 Q. Okay. And if we go forward to
8 page 2200?
9 A. Okay.
10 Q. Okay. This is now your U.S.
11 denominated TFSA, correct?
12 A. Correct.
13 Q. And so is it fair to say in
14 early February of 2021 you sold 1,633
15 shares of GameStop?
16 A. Yes.
17 Q. And then later in February you
18 bought 1,895 shares of GameStop correct?
19 A. Yup.
20 Q. And then you sold that
21 GameStop stock, the 1,895 shares a few
22 days later; is that fair?
23 A. Yup.
24 Q. Okay. So I want to ask some
25 why questions now.
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2 Why did you sell 1,633 shares
3 of GameStop in early February?
4 A. It could be because -- I'm
5 trying to think of my mindset then.
6 MR. ROSEN: If you don't know
7 the answer, you don't have to give
8 -- you don't have to guess at an
9 answer. You have to be sure of an
10 answer.
11 A. I clearly sold it and then I
12 bought it back again. So that allowed me
13 I guess to profit the difference and then
14 pick it up again later. That's what
15 happened, that's what it looks like.
16 Q. Okay. During this period in
17 time do you recall monitoring the
18 movement of GameStop stock?
19 A. Yes. It was tumultuous.
20 Q. Did you have any understanding
21 as to why it was tumultuous?
22 A. I wasn't quite sure.
23 Q. In buying and selling and
24 buying GameStop stock, what was your
25 ultimate goal here?
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2 A. On these dates here on page
3 2200?
4 Q. What were your investment
5 goals with respect to GameStop during
6 February of 2021?
7 A. I believe at this point it was
8 just damage control.
9 Q. Let me show you -- let me just
10 mark one more document. And we've been
11 going a little over an hour, so we should
12 take a break. Let me get through another
13 document first.
14 Tab 29, Robert. Thank you.
15 (Exhibit 34, TD transaction
16 confirmation, beginning Bates
17 P00002691 was received and marked
18 on this date for identification.)
19 Q. So you should have Exhibit 34
20 now, whatever this is, on your screen.
21 And this is a document with the Bates
22 numbers P00002691 through 2700. Let me
23 know when you have that?
24 A. Okay. It's on my screen.
25 Q. First question, do you know
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2 what this collection of pages are?
3 A. This is a transaction
4 confirmation.
5 Q. Are these your transaction
6 confirmations for your trading in
7 GameStop stock during January and
8 February of 2021?
9 A. That's what it looks like.
10 Q. From this can we see what the
11 order dates were and what the settlement
12 dates were?
13 A. Yes.
14 MR. SLIFKIN: Okay. You can
15 put that to one side. Why don't we
16 take, I don't know, a short break.
17 MR. ROSEN: Five minutes or
18 so?
19 MR. SLIFKIN: Whatever you
20 guys want.
21 VIDEOGRAPHER: Let me just
22 take us off the record first. Off
23 the record 12:08 p.m.
24 (Recess is taken.)
25 VIDEOGRAPHER: We're back on
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2 the record 12:24 p.m. Eastern
3 Standard Time.
4 Q. Mr. Ng, we were talking about
5 Exhibit 34. Do you still have that with
6 you?
7 A. I do.
8 Q. Okay. Could you turn to the
9 page of Exhibit 34, which has the number
10 at the bottom 2694?
11 A. 2694, yes. I have it up.
12 Q. And am I correct in saying
13 that this is the transaction confirmation
14 for your purchase of 1,550 shares of
15 GameStop that we were discussing earlier?
16 A. Yes.
17 Q. And am I -- is it correct the
18 date of January 27th is the settlement
19 date for that transaction?
20 A. That's what the statements
21 indicates.
22 Q. Do you have any reason to
23 doubt your TD transaction confirmations?
24 A. No.
25 Q. Based upon your experience
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2 over the last I guess more than 20 years
3 with TD -- let me withdraw.
4 You've been with TD a long
5 time. Have they ever sent you incorrect
6 transaction confirmations?
7 A. Not that I'm aware of.
8 Q. So is it fair to say that
9 based upon at least this page it looks
10 like you placed your order for those
11 1,550 shares on or before January 25th,
12 2021?
13 A. Yes.
14 Q. Okay. I'm going to -- okay. I
15 want to go through some Reddit posts with
16 you. So I'm going to start -- my
17 colleague is going to start putting those
18 into the Marked Exhibits folder. Let's
19 start with tab 3.
20 A. Tab 35 or tab 3?
21 Q. It should be Exhibit -- it
22 should say Exhibit 35. Do you see that?
23 A. Yes, I do.
24 Q. Okay.
25 (Exhibit 35, Reddit
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2 wallstreetbets post dated January
3 27, 2021, was received and marked
4 on this date for identification.)
5 Q. Have you seen this document
6 before?
7 A. Let me scroll through it. It
8 doesn't scroll.
9 Q. It's just one page.
10 A. Yeah. I see this post, yeah.
11 Q. So let's just try and figure
12 out the structure of this.
13 Is this what's called a
14 sub-Reddit?
15 A. Yes.
16 Q. So if you look at the sort of
17 top right-hand corner it says About
18 Community. Do you see that?
19 A. Yes. It's the wallstreetbets
20 community.
21 Q. Is that a sub-Reddit that you
22 followed in January of 2021?
23 A. Not normally.
24 Q. So if we look down at the
25 bottom of that page it says Wednesday
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2 January 27th, 2021. Do you see that?
3 A. Yes.
4 Q. And underneath that it says
5 Mudgruff. Is that you?
6 A. That is me.
7 Q. So were you commenting on the
8 posts above?
9 A. Yes.
10 Q. And were you commenting on the
11 post -- withdrawn.
12 Did you post a comment for the
13 post --
14 A. Yes.
15 Q. -- starting, "Theory: The
16 hold is working and the squeeze is
17 starting." Is that the structure?
18 A. That is the structure.
19 Q. Okay. So with respect to the
20 post on which you commented, do you know
21 who JonDum is?
22 A. Who?
23 Q. That post was posted by
24 someone called JonDum?
25 A. I see that. I do not know any
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2 of these users.
3 Q. Okay. Since you commented on
4 that post I assume you read it. Is that
5 fair?
6 A. Yes.
7 Q. Did you know what this was
8 referring to?
9 A. I'm just reading the comments
10 here. I was probably commenting on
11 mtoms48's comments, "Holding it like
12 explosive diarrhea on a bus stuck in
13 traffic."
14 Q. Okay. When you wrote, "He is
15 the rocket", what were you referring to?
16 A. Probably the guy holding the
17 diarrhea.
18 Q. Do you recall why you were
19 commenting on these posts?
20 A. Because I thought it was
21 funny.
22 Q. Okay. At the top where it says
23 the post under which you commented where
24 it says "Theory: The hold is working and
25 the squeeze is starting", do you see
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2 that?
3 A. Yes.
4 Q. Is that referring to a short
5 squeeze?
6 A. Yes.
7 Q. And in what stock was it
8 referring to a short squeeze?
9 A. Most likely GME at the time.
10 Q. Okay. Did you agree that the
11 hold was working and the squeeze was
12 starting as of January 27th, 2021?
13 A. I don't know.
14 Q. Did this Reddit post influence
15 your investment decisions in any way?
16 A. Not likely.
17 Q. Let's look at tab 4.
18 A. Okay.
19 (Exhibit 36, Reddit
20 wallstreetbets post dated January
21 28, 2021 was received and marked on
22 this date for identification.)
23 Q. Okay. I think you should have
24 Exhibit 36 there?
25 A. All right.
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2 Q. So do you recognize Exhibit
3 36?
4 A. No, not really.
5 Q. Okay. If we look at the top,
6 is this a post by you?
7 A. I don't see a post.
8 Q. Do you see the date?
9 A. Yes, but I don't see the
10 content of the post.
11 Q. Okay. Do you see a date
12 January 28, 2021? Do you see that?
13 A. Yes.
14 Q. And then it says,
15 Do you see that?
16 A. Yes.
17 Q. And are you
18 A. I am
19 Q. And then it says, "Keep
20 holding you lovely bastids." Do you see
21 that?
22 A. Yes.
23 MR. SLIFKIN: B-a-s-t-i-d-s,
24 for the court reporter's benefit.
25 A. Yes.
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2 Q. Did you write that?
3 A. Apparently I did.
4 Q. And below it it says "meme".
5 Do you see that?
6 A. Yes.
7 Q. Right below it says "meme". Do
8 you see that?
9 A. Yes.
10 Q. I know it's a little small. Do
11 you have an understanding of what the
12 word meme means?
13 A. I do.
14 Q. And what is your
15 understanding?
16 A. It's something that's
17 politically popular at the time.
18 Q. When you wrote, "Keep holding
19 you lovely bastids", what were you
20 referring to?
21 A. Probably the stocks.
22 Q. Is that GME stock?
23 A. I was probably holding that at
24 the time, yes.
25 Q. Is it fair to say that as of
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2 January 28, 2021 GME was the principal
3 stock you had in your portfolio?
4 A. Yes.
5 Q. And why did you want to keep
6 holding GME as of January 28, 2021?
7 A. Why? I wanted the shares to go
8 up.
9 Q. Did you believe the shares
10 would go up?
11 A. Definitely.
12 Q. Why do you say "definitely"?
13 A. It just seems like what the
14 sentiment was with everybody in
15 wallstreetbets.
16 Q. Did you think that the GME
17 stock was going to go up because of a
18 short squeeze?
19 A. I felt the potential was
20 there.
21 Q. The potential for a short
22 squeeze?
23 A. Yes.
24 Q. And then there is something
25 that has been deleted by the moderators.
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2 Do you see that?
3 A. Yes.
4 Q. Is that something that you
5 posted?
6 A. Yes. I posted it and it was
7 deleted and then moderators removed it.
8 Q. Do you recall what it is you
9 posted?
10 A. The contents, no.
11 Q. Let's go to tab 5.
12 (Exhibit 37, Reddit
13 wallstreetbets post dated January
14 28, 2021 was received and marked on
15 this date for identification.)
16 Q. So Exhibit 37 should be up
17 now.
18 A. Okay.
19 Q. Do you know what Exhibit 37
20 is?
21 A. Yes. It's a little poem I
22 made.
23 Q. A little what? I didn't hear
24 you.
25 A. It's a little poem or a chant.
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2 Q. And did you write this?
3 A. Yes.
4 Q. Right. Because it rhymes,
5 right? Squeeze and Hercules and bees all
6 rhyme?
7 A. Yeah, terribly.
8 Q. Well, we can't call be
9 Shakespeare?
10 A. No, we cannot.
11 Q. So did you post this on
12 January 28, 2021?
13 A. Yes, I did post it.
14 Q. And is it a comment on
15 something to do with GME?
16 A. Yes.
17 Q. Okay. So you wrote, "GME GME
18 must hold out for the gamma squeeze." Do
19 you see that?
20 A. Yes.
21 Q. And what did you mean by "must
22 hold out for the gamma squeeze"?
23 A. To hold one's shares.
24 Q. In anticipation of an
25 astronomical squeeze on the stock, as you
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2 described to me earlier?
3 A. Yes.
4 Q. And then, "DFV, DFV slaying
5 shorters like Hercules." Do you see that?
6 A. Yes.
7 Q. I'm sorry. Go ahead.
8 A. Yeah. Continue.
9 Q. And so DFV, that's
10 DeepFuckingValue, also known as Keith
11 Gill?
12 A. Yes.
13 Q. And when you say "slaying
14 shorters", you're talking about hedge
15 funds who assume short positions with
16 respect to GME, I take it?
17 A. Yes.
18 Q. Then it says "WSB, WSB" -- is
19 that --
20 A. That is wallstreetbets.
21 Q. -- "attacking like a swarm of
22 bees." Are you talking about the people
23 on the sub-Reddit of wallstreetbets
24 executing a short squeeze on the hedge
25 funds that you referred to in the prior
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2 stanza?
3 A. Yes. That was my observation.
4 Q. Then if you look below that it
5 says -- well, so then there's a post or a
6 comment or something by somebody called
7 due11. Do you see that?
8 A. Yes.
9 Q. And am I right, right below
10 that is this your comment on what due11
11 writes?
12 A. Allow me to read what due11
13 wrote. It's been a while.
14 Q. Sure.
15 (Deponent reviews the
16 document.)
17 A. Okay.
18 Q. Okay. So what we see at the
19 bottom where it says "It's so
20 blatantly obvious too", do you see that?
21 A. Yes.
22 Q. Was that a response to or a
23 comment on what was written above by
24 due11?
25 A. Yes.
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2 Q. And did you post that on
3 January 28th, 2021?
4 A. I do not have the precise
5 timestamp of it but if that is what it
6 is, then it is.
7 Q. That is the date at the top of
8 the page, right?
9 A. Well, comments can occur at
10 almost any time so...
11 Q. So the only particular
12 timestamp on your post at the bottom says
13 "two years ago". Do you see that?
14 A. Yes.
15 Q. So two years ago from today is
16 sometime in 2021, I take it; is that
17 right?
18 A. Yes.
19 Q. So due11 -- so in your post
20 when you say "It's so blatantly obvious
21 too", what are you referring to?
22 A. It's a comment related to how
23 Trading 212 -- okay. So he's saying that
24 new positions cannot be opened. So it
25 sounds like you can't buy additional
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2 shares in GameStop and AMC.
3 Q. I'm sorry. Have you finished
4 your answer?
5 A. That's my interpretation of
6 that.
7 Q. Okay. So what's Trading 212?
8 A. I don't know if that's a
9 brokerage or a user. I'm not sure.
10 Q. And it says, "Warning: In the
11 interest of mitigating risks for our
12 clients we have temporarily placed
13 GameStop and AMC Entertainment in
14 reduce-only mode as highly unusual
15 volumes have lead to an unprecedented
16 market environment." Do you see that?
17 A. Yes.
18 Q. Then it says, "New positions
19 cannot be opened. Existing ones can be
20 reduced or closed." Do you see that?
21 A. Yes.
22 Q. When did you learn of those
23 types of trading restrictions being
24 placed upon GameStop and AMC?
25 A. It would be around the time of
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2 this post.
3 Q. Okay. So then due11 seems to
4 -- writes "WTF?" Do you see that?
5 A. Yes.
6 Q. And this person continues,
7 "They really think people will fall for
8 the 'mitigating risk for our client.'" Do
9 you see that?
10 A. Yup.
11 Q. And then you say "It's so
12 blatantly obvious too."
13 A. Yes.
14 Q. So I'm trying to understand
15 what was blatantly obvious?
16 A. That they want to prevent
17 people from buying.
18 MR. SLIFKIN: Okay. Can we go
19 to tab 6?
20 (Exhibit 38, Reddit
21 wallstreetbets post was received
22 and marked on this date for
23 identification.)
24 Q. So Exhibit 38 should be up
25 now.
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2 MR. ROSEN: Mr. Ng, take a
3 look at the exhibit carefully
4 before you answer the questions.
5 Q. Yes, please do.
6 This is rather indistinct but
7 there is a button which allows you to
8 magnify stuff.
9 A. Yes. I am trying to zoom in on
10 it. Your screenshot is of low fidelity.
11 MR. ROSEN: It's hard to
12 magnify this.
13 Q. Let me know when you've had a
14 chance to read it.
15 A. Okay. I've read it.
16 Q. Okay. So, again, can you
17 explain to us what this document is,
18 Exhibit 38?
19 A. It's -- it looks like a post
20 by our LordofWar. He's explaining the
21 short stock. Telling people not to panic
22 and he likes the stock. Subsequently I
23 put my little chant there.
24 Q. So LordofWar posted this thing
25 about short stock and the squeeze, and
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2 then you put that same little chant that
3 we saw on Exhibit 37 as a comment to the
4 posting on Exhibit 38; is that fair?
5 A. Yes.
6 Q. So thank you for that. Why
7 don't we put up tab 7.
8 (Exhibit 39, Tweet post dated
9 January 28, 2021 was received and
10 marked on this date for
11 identification.)
12 Q. So Exhibit 39 should now be
13 available to you?
14 A. Yes, I see it.
15 Q. Okay. Do you recognize what
16 these are?
17 A. It's a Tweet. Let me read
18 this. It's been a while.
19 (Deponent reviews the
20 document.)
21 A. Okay.
22 Q. Okay. So first off, can you
23 tell us what Exhibit 39 is, please?
24 A. It's a Tweet by the WSBMod.
25 Sorry. I just clicked something. I have
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2 to reload it. Just give me a minute here.
3 Sorry.
4 Q. Yeah. Sure.
5 A. And there's -- okay. So, yeah
6 the mod is saying that TD Ameritrade
7 restricted trading. There is another user
8 who posted saying it's unreal, and I made
9 a comment on it.
10 Q. So WSBMod makes -- well,
11 Tweets out on January 28th, 2021. That's
12 at the top, right?
13 A. Yes.
14 Q. And do you know who WSBMod is?
15 A. No.
16 Q. Is that the moderator for
17 wallstreetbets?
18 A. It's possible. I don't know. I
19 can only assume.
20 Q. I'm sorry. I cut you off. I
21 apologize. Were you finished with your
22 answer?
23 A. Yeah.
24 Q. Okay. So that was posted out
25 January 28th, 2021, right?
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2 A. Yes.
3 Q. And at the bottom you reply to
4 that and to Mr. Skinner. Do you see that?
5 A. Yes.
6 Q. And below that it has a
7 timestamp of 10:36 a.m. on January 28,
8 2021?
9 A. Yes.
10 Q. Is that when you Tweeted out?
11 A. Yes.
12 Q. And you were responding to
13 WSBMod saying "There are widespread
14 reports that retail brokers such as TD
15 Ameritrade will restrict trading for
16 individual investors today." Do you see
17 that?
18 A. Yes.
19 Q. Is that the first time you
20 heard of such potential trading
21 restrictions?
22 A. Yes.
23 Q. Do you recall if you heard
24 about those trading restrictions from any
25 other sources?
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2 A. I don't recall.
3 Q. Okay. So TD Ameritrade is
4 affiliated with TD Bank, right?
5 A. I don't know their business
6 structure. It is in name, anyway.
7 Q. Am I correct in saying that
8 you were not trading on TD Ameritrade,
9 however?
10 A. That is correct. The Canadian
11 and American side are different.
12 Q. And did TD, the platform on
13 which you traded, impose any trading
14 restrictions on you?
15 A. No restrictions.
16 Q. Okay. So on the morning of
17 January 28th, 2021 you wrote "They want
18 the stimulus from the taxpayer instead of
19 those fat whales sitting on wealth doing
20 squat because it's on someone's balance
21 sheet like a high score in a video game."
22 Do you see that?
23 A. Yes.
24 Q. Can you explain what you meant
25 by that?
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2 A. Reading this, the "they" is
3 the hedge funds. So, yeah, they want the
4 people's stimulus checks.
5 Q. And was that your view as of
6 January 28th, 2021?
7 A. That was apparently my view at
8 the time.
9 MR. SLIFKIN: Okay. Let's move
10 to a few more of these. I'm trying
11 to do this chronologically.
12 Robert, let's move to tab 10.
13 I apologize. I am getting a call
14 so let me just get rid of that.
15 Okay. So Exhibit 40 should be
16 in your folder now. I think that
17 one is --
18 (Exhibit 40, Reddit
19 wallstreetbets post dated February
20 1, 2021 was received and marked on
21 this date for identification.)
22 A. Yes, I see that.
23 Q. And am I right in saying that
24 Exhibit 40 is another set of posts on the
25 sub-Reddit wallstreetbets?
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2 A. Yes.
3 Q. And is it correct that at the
4 top that's a post by DFV, who you
5 described earlier?
6 A. Yes.
7 Q. And he wrote, "GME YOLO update
8 February 1, 2021", and below that it says
9 "YOLO"?
10 A. Yes.
11 Q. And what do you understand --
12 well, withdrawn.
13 So if we go down to the
14 bottom, then you respond to that or
15 comment on that, correct, saying "If he's
16 still in, I'm still in"?
17 A. Yes.
18 Q. And what did you mean by that?
19 A. If DFV is holding, I am -- I
20 was holding.
21 Q. And you understood from YOLO
22 that he was still holding, right?
23 A. Yes.
24 Q. YOLO being an acronym for "you
25 only live once", I take it?
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2 A. Correct.
3 Q. And that's from February 1st,
4 2021, right?
5 A. Yes. A-hum.
6 Q. And then if we go to the next
7 exhibit which is being posted, tab 11.
8 (Exhibit 41, Reddit
9 wallstreetbets post dated February
10 2, 2021 was received and marked on
11 this date for identification.)
12 Q. I'm sorry. I had an error.
13 MR. ROSEN: You don't want to
14 show that Exhibit 41.
15 MR. SLIFKIN: I do. My whole
16 screen just died. Sorry. I got my
17 stuff back.
18 Q. Okay. So, yes, quickly Exhibit
19 41 --
20 A. It's another update by DFV and
21 I did reply.
22 MR. ROSEN: You got to let him
23 ask the question.
24 MR. SLIFKIN: Mr. Rosen and I
25 finally agree on something. Yeah.
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2 It really helps if you let me ask
3 the question.
4 THE WITNESS: I'm happy to
5 unite you two.
6 MR. ROSEN: That's okay. We're
7 happy to be adversaries.
8 Let him ask the question, take
9 a second, think about the answer
10 and then you can respond.
11 THE WITNESS: Yes.
12 Q. Okay. So do you have --
13 A. I can anticipate them. Yes, I
14 do.
15 Q. Do you have Exhibit 41 in
16 front of you?
17 A. I do.
18 Q. And can you tell us what
19 Exhibit 41 shows?
20 A. Similar to the previous posts,
21 it's by DeepFuckingValue, his YOLO update
22 and I replied with, "The post we needed"
23 and "If he's still in, I'm still in."
24 Q. And, again, you understood
25 Mr. Gill to be saying that he was holding
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2 GME stock as of February 2nd, 2021 and if
3 he was doing that you were going to do
4 that too; is that fair?
5 A. That's fair.
6 Q. And let's go -- so that's
7 February 2nd. Let me mark as Exhibit 41 a
8 post from February 3rd?
9 MR. ROSEN: As Exhibit 42 you
10 mean.
11 MR. SLIFKIN: Yes. I
12 apologize.
13 (Exhibit 42, Reddit
14 wallstreetbets post dated February
15 3, 2021 was received and marked on
16 this date for identification.)
17 Q. So Exhibit 42 should be up
18 now.
19 A. Okay. It's loading. Okay.
20 Q. Do you have it now, do you?
21 A. Yes.
22 Q. And is this another -- well --
23 withdrawn.
24 Can you tell me what this is?
25 A. It's a post.
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2 Q. Is that on Reddit?
3 A. Yes.
4 Q. So the post at the top is by
5 IANA?
6 A. It's by, yes, some random user
7 I don't know.
8 Q. And you commented on this
9 post, I take it?
10 A. Yes.
11 Q. And you wrote "In these hours
12 of darkness you made me laugh. Thanks!"
13 Do you see that?
14 A. Yes.
15 Q. And that's in response to the
16 post "Keep diamond dicking those suits
17 you beautiful retards. We're taking GME
18 out of the galaxy." Do you see that?
19 A. Yes.
20 Q. What made you laugh in that?
21 A. I don't know what the -- looks
22 like there is a picture of something that
23 you guys haven't included in your exhibit
24 here. I don't know what it is. It's
25 probably a picture or a video.
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2 Q. Do you know what IANA was
3 referring to when he said, "Keep diamond
4 dicking those suits you beautiful
5 retards?"
6 A. It's probably in relation to
7 the short squeeze.
8 Q. And given the next line "we're
9 taking GME out of the galaxy", is that a
10 reference to the short squeeze for GME
11 stock?
12 A. That is correct.
13 MR. SLIFKIN: Let's go
14 forward and do tab 13.
15 (Exhibit 43, Reddit
16 wallstreetbets post dated February
17 18, 2021 was received and marked on
18 this date for identification.)
19 Q. In a moment you can have
20 Exhibit 42 -- 43. I apologize.
21 A. 43. All right. I'm waiting for
22 that.
23 Q. I'm getting a little thing
24 going round and round.
25 MR. ROSEN: What number is
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2 this exhibit now?
3 MR. SLIFKIN: It should be 43.
4 MR. ROSEN: It's not showing
5 up. I'm just getting 42. I don't
6 see a 43. You may want to re-upload
7 it or something, delete and
8 re-upload it.
9 MR. SLIFKIN: Let's do that,
10 Robert. That's a good idea. This is
11 tab 13.
12 THE WITNESS: I see it.
13 MR. ROSEN: I was able to
14 access 43.
15 THE WITNESS: I have it up.
16 Q. Okay. Great. Can you identify
17 Exhibit 43 for us, please?
18 A. It is another Reddit post by a
19 random user I do not know.
20 Q. Is it one that you commented
21 on?
22 A. Yes, I did.
23 Q. So the post says "Citadel CEO:
24 We had no role in Robinhood's decision to
25 limit trading in GameStop." Do you see
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2 that?
3 A. Yes.
4 Q. And you wrote, "Hey Ken, I
5 believe you when millions don't"; is that
6 right?
7 A. That is right.
8 Q. And is "Ken" a reference to
9 Ken Griffin?
10 A. That is the person in the
11 image.
12 Q. And he is and was the CEO of
13 Citadel, I take it?
14 A. I don't know his -- I'm
15 assuming he is still.
16 Q. But that picture on Exhibit 43
17 is of Mr. Griffin, I take it?
18 A. Yes.
19 Q. And I take it that your post
20 was facetious?
21 A. That is the reasoning for the
22 "/S" at the end of the comment.
23 Q. Okay.
24 A. It indicates sarcasm.
25 Q. Sarcasm. Okay. I learned
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2 something.
3 So you made your post on
4 February 18th, 2021. Is that the first
5 time you heard of Robinhood's decision to
6 limit trading in GameStop?
7 A. Not likely.
8 Q. Okay. Why do you say "not
9 likely"?
10 A. Well, it was limited earlier.
11 I most likely would have seen other posts
12 by other users indicating the limit or
13 the restriction.
14 Q. That's prior to February 18 of
15 2021, I take it?
16 A. Yes.
17 Q. Let's go forward to tab 16.
18 (Exhibit 44, Reddit
19 wallstreetbets post dated March 10,
20 2021 was received and marked on
21 this date for identification.)
22 Q. Okay. You should have Exhibit
23 44 now.
24 A. I see it up.
25 Q. Can you tell us what Exhibit
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2 44 is?
3 A. It's a post by another random
4 user I don't know.
5 Q. A post on the wallstreetbets
6 sub-Reddit?
7 A. That is correct.
8 Q. And you placed a comment at
9 the bottom of this page on March 10th,
10 2021?
11 A. Yes.
12 Q. And so that's immediately
13 below the comment that's from Nero_Wolff.
14 Do you see that?
15 A. Yes.
16 Q. And are these comments all
17 about Robinhood?
18 A. I do not know.
19 Q. So if you look at the box, the
20 red outlined box it says, "I don't want
21 to have to say this every post but once
22 the rocket lands on Uranus I will close
23 my RH account." Do you see that?
24 A. Yes.
25 Q. Do you understand what RH
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2 refers to?
3 A. Yes, Robinhood.
4 Q. And then if we go down it
5 says, "They and other brokers cratered
6 the stock on January 27th affecting all
7 GME holders worldwide." Do you see that?
8 A. Yes.
9 Q. It says, "I'm a Canadian and
10 they fucked me. Fuck RH and fuck bitch
11 boy Vlad Tenev." Do you see that?
12 A. Yes.
13 Q. And do you have an
14 understanding who Mr. Tenev is?
15 A. I do.
16 Q. Who is he?
17 A. He is one of the founders of
18 Robinhood.
19 Q. Okay. Do you believe that
20 GameStop stock cratered on January 27th?
21 A. I don't know what the price
22 was on January 27th.
23 Q. Isn't it true, sir, that as of
24 January 31st, you had made more than a
25 200% profit on your GameStop investment?
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2 A. I did.
3 Q. Then you write, "Don't forget
4 that cunt Thomas Peterffy", if I am
5 pronouncing that correctly?
6 A. Yes.
7 Q. Who is Mr. Peterffy?
8 A. He's the chairman of
9 Interactive Brokers.
10 Q. Okay. And why were you
11 referring to Mr. Peterffy in pejorative
12 terms?
13 A. Because he felt that GameStop
14 was only worth $17.
15 Q. Okay. And you disagreed with
16 him?
17 A. I do.
18 Q. And what was your basis for
19 disagreeing with him?
20 A. That was probably in a
21 previous video of his, if not -- I don't
22 recall this specific video, but one of
23 his videos he did say that the shares --
24 if the restrictions weren't there, the
25 prices would have been into the
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2 thousands.
3 Q. And that's -- in your
4 understanding that's something that
5 Mr. Peterffy said?
6 A. That is correct.
7 Q. Then you referred to him with
8 a pejorative term?
9 A. Yes.
10 Q. Okay. Do you have any --
11 withdrawn.
12 We've been referencing
13 restrictions that Robinhood placed on the
14 trading of GME stock on its platform. Are
15 you with me, sir?
16 A. Yes.
17 Q. Do you have any understanding
18 as to why Robinhood placed those
19 restrictions on trading?
20 A. At the time I wasn't sure.
21 Rather, I didn't know. But after reading
22 the Complaint, I do now.
23 Q. And when you say "the
24 Complaint" you are referring to the
25 Complaint in this litigation, I take it?
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2 A. That is correct.
3 Q. Okay. And when did you first
4 read the Complaint in this litigation?
5 A. When it was sent to me. I do
6 not have a specific date.
7 Q. I take it that was well after
8 the spring of 2021?
9 A. Most definitely.
10 Q. Okay. So in the spring of 2021
11 -- well, let me be more precise.
12 In the period January 1st
13 through March 31st, 2021 did you have any
14 understanding as to why Robinhood had
15 imposed trading restrictions on its
16 platform?
17 A. No, I didn't really know what
18 was going on there.
19 Q. Did you care?
20 A. Did I care? Yes, I did care.
21 Q. Did you make any effort to
22 determine the reasons behind Robinhood's
23 actions?
24 A. I don't know if I was looking
25 at posts on the website. I don't
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2 remember. I don't know. I might have dug.
3 It's been a while.
4 Q. But you don't recall learning
5 anything as to the reasons behind
6 Robinhood's actions?
7 A. No, I don't remember.
8 Q. So one of the -- we've been
9 talking about GME. You saw there was a
10 reference in one of the documents we
11 looked at to AMC. Do you recall that?
12 A. Yes.
13 Q. And do you have an
14 understanding as to what AMC was?
15 A. It's the movie chain. It's one
16 of the other meme stocks that were
17 restricted.
18 Q. Okay. And do you understand
19 whether or not a short squeeze was being
20 placed upon AMC stock?
21 A. I believe that the people felt
22 that was a possibility as well.
23 Q. Did you invest in AMC?
24 A. Not during that timeframe.
25 Q. And why not?
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2 A. My money was in GME.
3 Q. Okay. So you told me
4 previously that you read the Complaint in
5 this matter, correct?
6 A. Yes.
7 Q. And you understand there
8 are -- beyond AMC and GME stock, there
9 were seven other stocks at issue?
10 A. Yes.
11 Q. Are you familiar with that?
12 A. Yes.
13 Q. I don't have to list them,
14 they're listed in the Complaint, unless
15 you want me to.
16 A. No.
17 Q. But did you consider investing
18 in any of those other stocks, other than
19 GME and AMC, that are identified in the
20 Complaint of this matter?
21 A. I did not.
22 Q. And why not?
23 A. I wasn't interested in them.
24 MR. SLIFKIN: Okay. Maybe we
25 can just go off the record and I
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2 can look through my materials and
3 see what else I have.
4 MR. ROSEN: How long do you
5 want to take?
6 MR. SLIFKIN: Why don't we
7 just go to -- I like to give a
8 coming back time, so why don't we
9 just say 1:30.
10 MR. ROSEN: So 13 minutes.
11 VIDEOGRAPHER: Let me just
12 take us off the record. Off the
13 record 1:17 p.m. Eastern Standard
14 Time.
15 (Recess is taken.)
16 VIDEOGRAPHER: We're back on
17 the record 1:30 p.m., Eastern
18 Standard Time.
19 Q. Okay. Could we go back to
20 Exhibit 33, and can you go to page 2210?
21 MR. ROSEN: 2210?
22 MR. SLIFKIN: Yes. It's
23 towards the back.
24 MR. ROSEN: March 1st TFSA
25 statement?
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2 MR. SLIFKIN: Yes.
3 Q. Mr. Ng, are you with me?
4 A. Yes.
5 Q. So that looks to be your U.S.
6 TFSA statement for March of 2021; is that
7 right?
8 A. Yes.
9 Q. And if we go to the next page,
10 am I right in saying in March of 2021 you
11 acquired 512 shares of GameStop?
12 A. That is correct.
13 Q. So why were you buying
14 GameStop again in March of 2021?
15 A. At that time I noticed that
16 there is a huge uptick in GameStop's
17 price, so I bought it again.
18 Q. And what did you think was
19 going on with respect to GameStop stock?
20 A. Possible squeeze again or
21 maybe de-squeeze. Who knows. At the time
22 I wasn't sure.
23 MR. SLIFKIN: Okay. Let's mark
24 tab 17.
25 (Exhibit 45, Reddit
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2 wallstreetbets post dated March 10,
3 2021 was received and marked on
4 this date for identification.)
5 MR. ROSEN: That be Exhibit
6 45?
7 MR. SLIFKIN: Yes, it would.
8 Q. That's up now. Do you have
9 Exhibit 45?
10 A. I see it. It's loading. Okay.
11 Q. Okay. And do you recognize
12 Exhibit 45?
13 A. It's a post I made.
14 Q. Is that on the wallstreetbets
15 sub-Reddit?
16 A. Yes.
17 Q. And at the bottom -- well,
18 sort of the bottom third you say "I want
19 your autograph?"
20 A. Yes.
21 Q. And then you say "No can do.
22 I'm still holding."
23 A. Yes.
24 Q. What are you referring to?
25 A. The short squeeze.
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2 Q. Is that the short squeeze of
3 GME?
4 A. Yes.
5 Q. And then there is one more
6 document so tab 18. So shortly Exhibit 46
7 should show up?
8 A. Okay. I'm waiting for it.
9 (Exhibit 46, Reddit
10 wallstreetbets post dated March 16,
11 2021 was received and marked on
12 this date for identification.)
13 Q. You should have that now.
14 A. Okay. It's loading. I see the
15 Reddit post.
16 Q. So you have Exhibit 46 in
17 front of you?
18 A. Yes.
19 Q. Okay. And can you tell us what
20 it is, please?
21 A. It's a Reddit post and I'm
22 replying to someone's comment.
23 Q. Is it a comment with respect
24 to GME? (Coughing.)
25 A. Yes, I can hear you.
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2 Q. Sorry. Something went the
3 wrong way. Let me start again.
4 And this Reddit post, which is
5 Exhibit 46, is it -- does it concern GME?
6 A. Yes, it does.
7 Q. And on March 16th, 2021 did
8 you write "It has hit some nice highs
9 twice. Why not a third time?"
10 A. Yes.
11 Q. And are you referring again to
12 GME there?
13 A. Yes.
14 Q. And what did you mean by "nice
15 highs twice"?
16 A. It had -- if you look at the
17 graph there is two spikes in the pricing.
18 Q. When you say "the graph", are
19 you referring to the thing in the top
20 right-hand corner?
21 A. It could be that or in general
22 the GME graph that everyone posts.
23 Q. And as of March 16, 2021 did
24 you believe that GME was going to hit a
25 third high?
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2 A. Quite possible.
3 Q. And did it hit a third high?
4 A. I don't believe so.
5 Q. Do you still hold GME stock?
6 A. Yes, I do.
7 Q. Subsequent to March of 2021,
8 did you sell any of your GME stock?
9 A. No. I've held the 512 and
10 increased my holdings of GME.
11 Q. And do you recall
12 approximately when you increased your GME
13 holdings?
14 A. Well, the day I bought the 512
15 and I've added a few more. But no, I
16 don't have specific dates. It's been then
17 and now.
18 Q. Okay. "Then" being March of
19 2021 and now?
20 A. Yes. Yeah.
21 Q. And why did you increase your
22 holdings since March of 2021 of GME?
23 A. I like the company. I wanted
24 more shares of it.
25 Q. Okay. I'll just ask you a few
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2 questions about your role as a plaintiff
3 here.
4 So you explained to me
5 previously how you came in contact with
6 the Rosen Law Firm. I think you also said
7 you reviewed the Complaint. Do you recall
8 that?
9 A. Yes.
10 Q. Was that before --
11 A. Yes.
12 Q. I'm sorry. Was that before it
13 was filed?
14 A. Yes.
15 Q. And did you provide any
16 comments? You can answer that "yes" or
17 "no". I'm not asking you for what you
18 said.
19 A. No.
20 Q. Okay. And I take it you
21 consented to your name being added as a
22 plaintiff?
23 A. Yes.
24 Q. Okay. So at about that time
25 did you take any measures to preserve
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2 your documents?
3 A. Yes.
4 MR. ROSEN: At what time?
5 MR. SLIFKIN: At the time that
6 he was reading the Complaint.
7 Q. What did you do to preserve
8 documents?
9 A. I did nothing.
10 Q. Okay. Did you become aware
11 that there were document requests served
12 upon you?
13 A. Yes.
14 Q. And when did you become aware
15 of that?
16 A. When my counsel emailed me for
17 them.
18 Q. Okay. And do you recall
19 approximately when that was?
20 A. Pardon me? Your voice broke
21 up.
22 Q. Do you recall approximately
23 when that was?
24 A. No, I do not.
25 Q. Okay. So when you were
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2 emailed, what did you do to search for
3 documents?
4 A. For my statements, I looked
5 through my brokerage account. For Reddit,
6 I downloaded a -- they have a link where
7 you can request information on your
8 account, so I put in the dates requested,
9 I downloaded the CSV file. For Twitter, I
10 just -- I wasn't active on there, it was
11 easy, so I just went to my profile.
12 Facebook, I do not post on there. And
13 YouTube, I looked at my history there,
14 but there wasn't very much there. Most of
15 my social media activity is on Reddit.
16 Q. Did you look at your emails?
17 A. I do not talk to people about
18 GME over emails.
19 Q. Did you look at your texts?
20 A. I do not use texting to talk
21 to anyone about GME.
22 Q. Prior to searching for
23 documents on social media sites, had you
24 deleted any of your Tweets concerning
25 GME?
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2 A. No.
3 Q. Had you deleted any of your
4 Reddit posts concerning GME?
5 A. No.
6 Q. Had you sent any private
7 social media messages concerning GME?
8 A. No.
9 MR. SLIFKIN: I think I have
10 no further questions. Thank you.
11 MR. ROSEN: I don't have any
12 questions for you, Mr. Ng, so I
13 think we're done. The videographer
14 is going to close us out.
15 VIDEOGRAPHER: I'll take us
16 off the record right now.
17 We are concluded for the day
18 and off the record at 1:42 p.m.
19 Eastern Standard Time.
20 (The proceedings were
21 adjourned at 1:42 p.m.)
22
23
24
25
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