Exhibit 8: Deposition of Abraham Huacuja (Dkt. 567-8, S.D. Fla.)
Summary
Exhibit 8 (Document 567-8) in Case 1:21-md-02989-CMA, entered on the FLSD docket June 7, 2023, is a 122-page transcript, marked confidential, of the virtual videotaped deposition of Abraham Huacuja, taken by Defendant on March 21, 2023 before Sharon Pearce of Veritext Legal Solutions. Phillip Kim, Lawrence M. Rosen and Michael Cohen of The Rosen Law Firm appear for Plaintiff and Daniel Slifkin and Megan Vincent of Cravath Swaine & Moore LLP for Defendant. Mr. Slifkin conducts the examination, the witness gives the full name Abraham Jacier Huacuja, and the record closes at 11:01 a.m., Pacific Daylight Time.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Exhibit 8: Deposition of Abraham Huacuja (Dkt. 567-8).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-07-covid-era-misc-6ba11307-1/
, SHA-256 6ba113079ae481b2cebf9469c412b2d316043345cd49c3cebf89fa5d854bbb6a.Full text
Case 1:21-md-02989-CMA Document 567-8 Entered on FLSD Docket 06/07/2023 Page 1 of
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Exhibit 8
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Page 1
1
2 IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
3 Case No. 1:21-MD-2989-CMA
4 - - - - - - - - - - - - - - - - - - - -x
IN RE JANUARY 2021 SHORT SQUEEZE
5 TRADING LITIGATION
6 - - - - - - - - - - - - - - - - - - - -x
7 March 21, 2023
8:34 a.m. PST
8
9 ***** CONFIDENTIAL *****
10
11 Virtual Videotaped
12 Deposition of ABRAHAM HUACUJA,
13 taken by Defendant, pursuant to Notice,
14 held remotely, before Sharon Pearce, RDR,
15 CRR, CRC, NYRCR, a Registered Diplomate
16 Reporter, Certified Realtime Reporter, and
17 Notary Public of the State of New York.
18
19 * * *
20
21
22
23
24
25
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2 A P P E A R A N C E S:
3
4 THE ROSEN LAW FIRM
Attorneys for Plaintiff
5 275 Madison Avenue
40th Floor
6 New York, New York 10016
7 BY: PHILLIP KIM, ESQ.
LAWRENCE M. ROSEN, ESQ.
8 MICHAEL COHEN, ESQ.
9
10
11 CRAVATH SWAINE & MOORE LLP
Attorneys for Defendant
12 825 Eighth Avenue
Suite 4043B
13 New York, New York 10019
14 BY: DANIEL SLIFKIN, ESQ.
MEGAN VINCENT, ESQ.
15
16
17
18 ALSO PRESENT:
19 HOWARD BRODSKY, Videographer
20 NICHOLAS LIN
21 * * *
22
23
24
25
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2 THE VIDEOGRAPHER: Good morning.
3 Here begins the video recorded virtual
4 remote deposition of
5 Abraham Huacuja --
6 THE WITNESS: Yes, correct.
7 THE VIDEOGRAPHER: -- appearing
8 from his location in Santa Maria,
9 California. This deposition is taken
10 by the defendant in In Re January 2021
11 Short Squeeze Trading Litigation, Case
12 No. 1:21-MD-2989-CMA, in the
13 United States District Court, Southern
14 District of Florida.
15 Today is Tuesday,
16 March 21, 2023. The time is 8:34 a.m.
17 Pacific Daylight Time. My name is
18 Howard Brodsky, and I'm the legal
19 video specialist in association with
20 Veritext Legal Solutions with offices
21 located in New York, New York. The
22 court reporter is Sharon Pearce in
23 association with Veritext.
24 Counsel have stipulated that the
25 court reporter shall enter all
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2 appearances for this proceeding into
3 the stenographic court record and
4 further agree that the court reporter
5 may swear the deponent in remotely.
6 Will the court reporter please
7 swear in the witness.
8 A B R A H A M H U A C U J A,
9 having first been duly sworn by
10 Sharon Pearce, the Notary Public,
11 was examined and testified as
12 follows:
13 EXAMINATION
14 BY MR. SLIFKIN:
15 Q. Could you please state your full
16 name for the record.
17 A. My name is Abraham Jacier
18 Huacuja.
19 Q. So Mr. Huacuja, what is your
20 current address?
21 A. Current address is
22
23
24 Q. Okay. Have you ever been
25 deposed before?
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2 A. Who what does deposed mean? I'm
3 not sure what that is.
4 Q. Okay. So the proceeding that's
5 taking place today is called a deposition.
6 A. Oh. Yeah. Yeah. Okay. Go
7 ahead. Go ahead.
8 Q. So the court reporter will tell
9 you she can't actually get us both at
10 once.
11 A. Yes.
12 Q. So it will be question, answer,
13 question, answer. Okay?
14 A. Okay. Got it.
15 Q. So have you ever been deposed
16 before? That is to say, have you ever
17 participated in a proceeding such as the
18 one we're doing today?
19 A. No, never.
20 Q. Have you ever been involved in
21 any legal proceedings?
22 A. No, just small ones like
23 speeding tickets and stuff like that.
24 Q. Okay. So speeding tickets is on
25 the criminal side.
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2 A. Oh, okay.
3 Q. Have you ever been involved in
4 any criminal proceedings?
5 A. No.
6 Q. Okay.
7 A. Other than a speeding ticket, I
8 guess.
9 Q. Have you ever been involved in
10 any other civil proceedings where you're
11 suing someone or someone is suing you?
12 A. No.
13 Q. Do you understand that you are a
14 plaintiff in this action?
15 A. Yes, I am a plaintiff.
16 Q. And what do you understand that
17 to mean?
18 A. That I am -- I am part of the --
19 I'm sorry. I'm here I guess as -- I'm
20 sorry. Just trying to find the words.
21 I'm here as, like, a representative on the
22 behalf of I guess this case, the lawsuit
23 case.
24 Q. Have you ever heard the term
25 class action before?
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2 A. Yes.
3 Q. Okay. What do you understand a
4 class action to be?
5 A. Class action is a group of
6 participants or a group of people that
7 have -- I guess have had something happen
8 to them and they just get together and --
9 it's like a -- instead of having one
10 lawsuit, this is, like -- this involves a
11 lot of people, which kind of -- it's a
12 culmination of a lot of people, I guess.
13 Q. Okay. So you understand I take
14 it that this proceeding is a class action
15 or at least a putative class action.
16 A. Yes. Yes.
17 Q. Okay.
18 A. I understand this is a class
19 action.
20 Q. And have you ever been involved
21 in a class action prior to this one?
22 A. No.
23 Q. Currently, are you involved in
24 any other litigation other than the
25 Robin -- than the short squeeze litigation
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2 that is the one we're dealing with today?
3 A. No. This is it.
4 Q. Okay. What do you understand
5 your responsibilities to be as a
6 plaintiff?
7 A. To just make sure everything --
8 like, make sure my lawyers are doing their
9 job and to make sure everything is fair
10 for everyone else I guess that can't be
11 here, or I guess it's a class action, so
12 there's a lot of people that can't really
13 be here.
14 Q. Okay. When you say your
15 lawyers, who are you referring to?
16 A. The Rosen Law Firm.
17 Q. The Rosen Law Firm?
18 A. Yeah.
19 Q. Is that Mr. Kim?
20 A. Yeah.
21 Q. And have you dealt with anybody
22 else at the Rosen Law Firm?
23 A. Yeah. There have been several
24 people that I've spoken with in emails
25 with.
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2 Q. Without going into the substance
3 of any conversations, can you tell me,
4 like, how frequently you speak to the
5 folks at the Rosen Law Firm?
6 A. I would say a couple of times a
7 month, maybe two or three.
8 Q. Okay.
9 A. Depending on the situation.
10 Maybe even more.
11 Q. And is the -- again, don't go
12 into who said what. I'm just going to ask
13 you what the topics are.
14 Is the topic of those
15 conversations these proceedings?
16 A. No. The topics are usually
17 about information that I have regarding
18 the case.
19 Q. I see.
20 Well, let me back up a little
21 bit.
22 Do you recall that you produced
23 certain documents and records in this
24 matter?
25 A. Yes. For this -- the Robinhood
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2 case, I -- yeah. I produced -- so I guess
3 you would say that Robinhood, the company,
4 has produced the files and I have them
5 with me.
6 Q. Okay I'm asking a slightly
7 different question.
8 Were you asked to search your
9 records for materials about this
10 litigation?
11 A. Yes, I was asked to search.
12 Q. Okay. And when were you asked
13 to search?
14 A. I don't remember the exact
15 dates, but pretty early on joining the law
16 firm.
17 Q. And can you tell me what you did
18 in your search.
19 A. I looked up the files from my
20 phone, all the Robinhood -- the statements
21 that I had for Robinhood and the
22 statements that I had for my bank. I
23 looked up any kind of web information that
24 I had. I am -- I do -- I'm a YouTuber. I
25 did some videos as well, and I showed them
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2 the videos that I did about the case.
3 Those are several things.
4 Q. Okay. And again, when did you
5 do that search?
6 A. I don't know the exact dates.
7 But it was pretty early on.
8 Q. Okay. And when did you provide
9 materials to your lawyers?
10 A. As -- I don't know. I did the
11 search, and within a week, I provided the
12 info. And then I think also there was
13 stuff that they asked for afterwards, so
14 then it took some additional time. It
15 wasn't all at once. It was, like, you
16 know, kind of spread out.
17 Q. Okay. And when was the last
18 time you gave materials to your lawyers
19 relevant to this matter?
20 A. I think, like, a few -- a week
21 ago or a few weeks ago, I think. Yeah.
22 There was something that they just wanted
23 to double check that I had it. I think it
24 was just about my searches on YouTube.
25 That's what it was.
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2 Q. Okay. So you said you're a
3 YouTuber.
4 So in your words, explain to me
5 what you meant by that.
6 A. I create content on a website
7 that I -- pretty much I videotape myself,
8 or mostly, it's a gaming website, so I'll
9 be playing video games, and I will just
10 share that in a video format on YouTube.
11 Q. Okay. And did you give those
12 YouTube videos to your lawyers?
13 A. I gave them the links to the
14 videos. I did not give them the -- I
15 don't have the hard files anymore. So
16 I -- but they have the links. It's the
17 same thing.
18 Q. And that's a link to the YouTube
19 site, is it?
20 A. Yes.
21 Q. Okay. And do you also -- and
22 so -- and again, you gave them the links
23 when? Like, recently, or some time ago?
24 A. Both. Both.
25 Q. And again, how -- how recent was
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2 the last time that you gave these YouTube
3 links to your counsel?
4 A. The links -- you have to -- can
5 you clarify a little bit? Like, what
6 links? Because I -- there's two different
7 types of links. There's links that I made
8 YouTube videos, and there's also links
9 that I sent them that I just watched
10 YouTube, and these are the YouTube videos
11 that I watched for reference.
12 Q. Okay. So that's very helpful.
13 A. But I didn't create them.
14 Q. So let's start with the links to
15 the content that you created.
16 When did you send those to your
17 counsel?
18 A. Yeah. I don't remember. That
19 was, like, further in the past.
20 Q. And the links to the materials
21 that you watched on YouTube, when did you
22 send those to your counsel?
23 A. Those -- about a week ago or so.
24 Q. Okay. Can you tell me just
25 generally what you did to prepare for this
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2 litigation.
3 Let me rephrase that.
4 Can you tell me generally what
5 you did to prepare for this deposition,
6 that is to say, the proceedings today.
7 A. I looked over the material that
8 was sent to me. And I made sure that I
9 could log into the Exhibit Share, and I
10 downloaded Zoom, and I was able to do a
11 test, just several things to prepare.
12 Q. Okay. And when did you do that?
13 A. Yesterday and the day before.
14 Just yesterday, I think, was the majority
15 of it.
16 Q. You said you looked over
17 materials that were sent to you.
18 Are you with me?
19 A. Yes.
20 Q. Okay. Who sent you those
21 materials?
22 A. The Rosen Law Firm.
23 Q. Okay. Did any of those
24 materials help you remember facts?
25 A. No, not necessarily.
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2 Q. Okay. Did you speak to anyone
3 in preparation for your deposition today?
4 A. Yes. I spoke to my lawyers.
5 Q. Okay. Did you speak to anyone
6 other than your lawyers?
7 A. No.
8 Q. And when did you speak to your
9 lawyers?
10 A. In regards to this --
11 Q. Yes, to this --
12 A. Yesterday.
13 Q. Okay. And did you speak to them
14 about this deposition before yesterday?
15 A. Yes.
16 Q. Okay. And when was that?
17 A. I think throughout the whole
18 process, they just mentioned that it's
19 probably going to happen, and this is
20 probably what's going to go down. So just
21 a preparation.
22 Q. Okay. And about how long did
23 you spend preparing for this deposition?
24 A. Not long, to be honest. Not
25 long. I'm a really busy person.
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2 Q. Okay. Okay. So maybe you can
3 just tell me a little bit about your
4 personal background, starting with your
5 education.
6 A. Okay.
7 Q. So when did you graduate high
8 school?
9 A. '99.
10 Q. Okay. And so what education did
11 you have post-high school?
12 A. After high school, I went to
13 college. I have two degrees. I have two
14 bachelors of science in art, fine art --
15 Q. Okay.
16 A. Fine arts and media.
17 Q. Okay. So if you graduated in
18 '99, did you go straight to college?
19 A. Yes. I went straight to
20 college. I did four years. And then I
21 got a job in Ireland. And after two
22 years, I came back to the U.S., and I went
23 to school again for another four years.
24 Q. So that first -- that first
25 degree you took from I guess 1999 until --
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2 what -- 2000 when?
3 A. I don't know exactly, but it was
4 around 2005 or '4. It was a four-year
5 degree.
6 Q. Okay. So that first four-year
7 degree, where did you go?
8 A. I went to the Art Institute in
9 California.
10 Q. Okay. And is that in Santa
11 Monica?
12 A. Yeah. That's in Santa Monica.
13 Q. Okay. And what was your degree
14 in?
15 A. It's some bachelor's of fine --
16 bachelor's of art and -- media and art,
17 something like that. I think that was the
18 degree.
19 Q. What was your major?
20 A. Just art. Just fine arts or
21 arts. Media arts.
22 Q. Okay. And then you took a job
23 in Ireland, you said?
24 A. Yes.
25 Q. And then you came back to the
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2 United States, and you got another degree.
3 A. Yes.
4 Q. Okay. That second degree,
5 first, where was it?
6 A. That was in Seattle -- well,
7 Redmond, Washington. Redmond, Washington.
8 Q. Okay. And what was the name of
9 the institution you attended?
10 A. DigiPen Institute of Technology.
11 Q. Okay. And what degree did you
12 take?
13 A. That's the fine arts -- fine
14 arts degree. Fine arts and animation.
15 Q. Okay. Okay. So high school,
16 first degree, second degree. I'm going to
17 ask you some questions about them
18 altogether. Okay?
19 A. Okay.
20 Q. Okay. So during that period,
21 when you were studying in high school or
22 for either of your degrees, did you ever
23 study economics?
24 A. There was a course, I believe,
25 on economics here and there, but it was
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2 just, like, maybe one or two courses, one
3 for each degree.
4 Q. Did you ever study finance?
5 A. No.
6 Q. Did you ever study accounting?
7 A. No.
8 Q. So in your economics classes,
9 did you ever study the stock market?
10 A. No.
11 Q. Have you ever heard the phrase
12 "market efficiency"?
13 A. I believe I heard the phrase
14 "market efficiency."
15 Q. Okay. When did you first hear
16 the phrase "market efficiency"?
17 A. I don't recall.
18 Q. Okay. What do you understand
19 market efficiency to mean?
20 A. The market is just working as it
21 should be. That's -- I mean, I didn't
22 study it or anything, so from my
23 understanding, that's what it means.
24 Q. Okay. So are you currently
25 employed?
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2 A. Yes.
3 Q. Okay. Who is your employer?
4 A. Chumash Casino Resort.
5 Q. Okay. And how long have you
6 worked for Chumash Casino Resort?
7 A. For about eight to nine years.
8 Q. And what is your job title
9 there?
10 A. I am currently employed as a
11 poker dealer.
12 Q. Has that always been your job at
13 Chumash?
14 A. No.
15 Q. Okay. So tell me what jobs you
16 had at Chumash.
17 A. I was a -- entered as a slots
18 technician, and then I became a lead
19 technician, and now a poker dealer. And
20 actually going to soon -- within the next
21 couple of weeks, I will be a table games
22 dealer.
23 Q. Okay. And for how long have you
24 been a poker dealer?
25 A. For less than a year, but around
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2 a year. Around a year but less, a little
3 bit less than a year.
4 Q. Okay. So you started doing that
5 in 2022. Is that fair?
6 A. Yeah. That's fair.
7 Q. Okay. So if we would think
8 of -- if you think back to 2020 and 2021,
9 what was your role at Chumash?
10 A. Actually, there was an
11 in-between job there. I was a poker brush
12 before I was a dealer. But it was the
13 same amount of time. It was less than
14 half a year or around half a year. And
15 then before that was -- I was a lead
16 technician. Yeah.
17 Q. Okay. And in 2020 and 2021,
18 like, during Covid, were you actually
19 working, or were you at home?
20 A. During Covid, the casino closed
21 down. And -- yeah. They closed down
22 the -- yeah. The casino closed down, so
23 we weren't working. But they paid us for
24 I think several weeks or a month or so.
25 And then the casino opened back up shortly
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2 after with a bunch of restrictions.
3 Q. And when was that, do you
4 recall?
5 A. I don't recall the exact dates.
6 Q. Okay. So this lawsuit is called
7 In Re January 2021 Short Squeeze Trading
8 Litigation.
9 Are you aware of that?
10 A. Yes.
11 Q. Okay. So in January 2021, were
12 you working or were you at home?
13 A. I don't recall. I have to think
14 about it. But I don't recall off the top
15 of my head what I was -- if I was working
16 during that time or not.
17 Q. Okay. Did you spend any time
18 working from home?
19 MR. KIM: When?
20 MR. SLIFKIN: During Covid.
21 A. Working -- I have to clarify.
22 Working at the casino or working how?
23 Q. So I'm asking you a question.
24 During Covid, when there were
25 restrictions in place --
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2 A. Yes.
3 Q. -- did you do any work from
4 home?
5 A. No.
6 Q. Okay. Okay. So do you
7 currently invest in the stock market?
8 A. Yes, I do.
9 Q. Okay. And for how long have you
10 been investing in the stock market?
11 A. For years. I don't know exact
12 time. But it's been a couple of years
13 now.
14 Q. Okay. So did you -- again, this
15 litigation is -- in its title, it refers
16 to January 2021.
17 A. Yes.
18 Q. Were you investing in the stock
19 market at that point in time?
20 A. Yes, I was, and before then.
21 Q. Okay. And for how long had you
22 been investing in the stock market as of
23 January of 2021?
24 A. I don't recall.
25 Q. Was it years? Weeks? Days?
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2 A. Years.
3 Q. Years. Okay.
4 Do you recall why you started
5 investing in the stock market?
6 A. Not necessarily. I think
7 Robinhood was -- the app was I think
8 popular at the time, and I wanted to get
9 into it.
10 Q. Okay. So you referred to
11 Robinhood.
12 A. Yes.
13 Q. What do you understand Robinhood
14 to be?
15 A. Robinhood is an application on
16 the phone that lets you buy and sell
17 stocks.
18 Q. Okay. And I take it you were at
19 least a Robinhood customer.
20 A. I still am.
21 Q. Okay. And do you recall when
22 you opened your Robinhood account?
23 A. No, I don't know when I opened
24 it.
25 Q. Okay. So why did you decide to
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2 use Robinhood?
3 A. It was basically the only thing
4 out there at the moment -- I know there
5 was other stuff, but it was the easiest
6 thing out there to use.
7 Q. Okay. I think you said you
8 still have a Robinhood account.
9 A. Yes, I do.
10 Q. Do you actively trade in your
11 Robinhood account?
12 A. No. It's actually been a while
13 since I've traded in my Robinhood account.
14 Q. Okay. So do you have other
15 accounts?
16 A. Yes.
17 Q. Can you tell me --
18 A. For stocks?
19 Q. For stocks. Yes.
20 A. Yes. In SoFi.
21 Q. SoFi. Okay.
22 When did you open your SoFi
23 account?
24 A. Pretty much after -- or during
25 January when all the short squeeze
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2 happened.
3 Q. So you referred to January of
4 2021.
5 A. Yes, 2021.
6 Q. Okay. And you used the word
7 "short squeeze" in your last answer.
8 Can you tell us in your own
9 words what you understand a short squeeze
10 to be.
11 MR. KIM: Form. Are we talking
12 about right now? Before? Limited in
13 time?
14 Q. You just used -- okay. You just
15 used the word "short squeeze."
16 A. Yes.
17 Q. You referenced January 2021.
18 A. Yes.
19 Q. Are you with me? Okay.
20 A. Yes.
21 Q. What did you mean by short
22 squeeze?
23 A. So there -- a stock will get --
24 will get shorted, and then when
25 different -- different -- there's two
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2 parties. When one party shorts a stock,
3 then the second party will buy that stock,
4 making the people who shorted the stock
5 either have to keep paying interest in --
6 when they started shorting it, and -- or
7 they'll have to sell their stock at an
8 undesirable expense to them, and -- if
9 that stock keeps going up. So that's
10 basically the gist of a short squeeze.
11 Q. Okay. Let's start with short.
12 What do you understand a short
13 position to be?
14 A. A short position is when someone
15 buy -- borrows it -- because you're
16 selling a stock, so you're borrowing it
17 and then selling it to buy it later. And
18 you want to -- you want to buy it at a
19 lower cost, and you would take -- you
20 would take the difference. So that's how
21 you would make your money by shorting the
22 stock.
23 Q. Okay. Have you heard the phrase
24 "long position"?
25 A. Yes.
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2 Q. Okay. What do you understand a
3 long position to be?
4 A. I am actually more of a long
5 position buyer myself. So basically, you
6 buy a stock, and you hold it, and you just
7 don't let it go.
8 Q. Okay. And a short position is
9 what? The opposite? That's --
10 A. Yes. Basically, they're banking
11 on trying to make a profit quickly.
12 Q. A profit until the stock went
13 up.
14 A. Down.
15 Q. Okay.
16 A. Shorting it. Because they're
17 shorting it.
18 Q. So that's -- that's a
19 transaction where the intended outcome is
20 that the price of the stock goes down.
21 A. Yes. The short --
22 Q. Okay.
23 A. The shorting.
24 Q. Okay. And a short squeeze, as
25 you put it previously, that's an attempt
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2 to what? Drive the price of the stock up
3 in order to hurt the shorts?
4 MR. KIM: Objection to form.
5 You can answer.
6 A. The short squeeze is basically
7 when -- the shorts are betting it to go
8 down, and the short squeeze is buyers --
9 they just buy the stock so -- they're just
10 buying the stock so the price goes up.
11 And if the people that are squeeze -- or
12 the shorting is -- the people that are
13 shorting the stock will have to sell at an
14 unfavorable amount, basically.
15 Q. Okay. And in your
16 understanding, there were short squeezes
17 that were being attempted in January 2021?
18 MR. KIM: Objection to form.
19 Assumes facts. Calls for speculation.
20 Q. You can answer.
21 A. Yes. I don't -- I believe
22 that's what was going on. I mean, that's
23 what I was banking on as well.
24 Q. And when you say that's what you
25 were banking on, what do you mean by that?
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2 A. I was banking on there being a
3 short squeeze.
4 Q. Do you mean, like, in your own
5 investing, you were assuming or hoping
6 that there was going to be a short
7 squeeze?
8 A. Yes.
9 Q. And you were going to make a
10 profit from that?
11 A. I was hoping to. Yes.
12 Q. Okay. So I'll come back to
13 that.
14 You told me that you opened the
15 SoFi account in I believe January of 2021.
16 Did I get that right?
17 A. Yeah. Around that time I
18 remember opening it. I don't know the
19 exact date.
20 Q. Okay. Have you ever had -- and
21 do you still have that SoFi account?
22 A. Yes. Yes, I do.
23 Q. And is that the account in which
24 you trade securities?
25 A. It is now, yes.
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2 Q. Okay. Okay. So you mentioned
3 Robinhood. You mentioned SoFi.
4 Have you ever had any other
5 accounts in which you trade securities?
6 A. No. No. Just those two.
7 Q. Okay. And I take it you started
8 with Robinhood. Then you opened your SoFi
9 account.
10 And is it fair to say that at
11 some point, you moved your assets from
12 Robinhood to SoFi?
13 MR. KIM: Objection to form.
14 A. I moved some of them.
15 Q. Okay. Do you still have any
16 assets held at Robinhood?
17 A. Yes, I do.
18 Q. Okay. Tell me approximately how
19 much in dollar terms.
20 A. I don't know exactly off the top
21 of my head. It's around --
22 I'm not sure.
23 Q. When you say , you mean
24 or --
25 A. Yes.
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2 Q. Or
3 A. Yes.
4 Q. Okay.
5 A.
6 Q. Okay. I'm sorry. The video
7 kind of slowed down for a second there, so
8 I had trouble hearing you.
9 Do you have any recollection as
10 to what securities you currently hold at
11 Robinhood?
12 A. What securities. Yeah. I know
13 some of them. But I don't -- I don't
14 recall all of them at the moment.
15 Q. Okay. Can you give me the ones
16 you remember?
17 A. Tesla for sure.
18 Q. Okay. And with respect to SoFi,
19 approximately what are the, you know,
20 dollar amount of your holdings at SoFi?
21 A. Same thing. I don't know the
22 exact amount at the moment. But it's
23 . Actually, it's
24
25 maybe.
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2 Q. Okay. And do you recall any of
3 the securities that you hold at SoFi?
4 A. Yes. Same thing. Tesla.
5 Q. Okay. Any other companies that
6 you recall?
7 A. There's a couple of other
8 companies. But it's only a small amount.
9 The majority is Tesla.
10 Q. Okay. So let's go back to the
11 period 2020.
12 Let's start with when you opened
13 your Robinhood account. Okay?
14 Prior to January 2021, you don't
15 remember precisely when. Is that fair?
16 A. Yes.
17 Q. But we can look that up; right?
18 A. Okay. Yeah. We can.
19 Q. Okay. I mean, do you recall
20 filling out a form when you opened your
21 Robinhood account?
22 A. An online form? I believe there
23 is some small agreement. I don't exactly
24 recall at this point in time. But just to
25 open an account in their website, I
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2 believe I signed something.
3 Q. Okay. There was, like, an
4 online application that you had to
5 complete.
6 A. I think so. I don't recall
7 exactly.
8 Q. Okay. So at that point in time,
9 did you have any, you know -- any strategy
10 with respect to trading stocks in mind?
11 A. Yeah. Yeah, I did.
12 Q. Okay. And what was that?
13 A. The very start of my investing
14 career, I wanted to learn, so I just
15 didn't -- had stocks in securities that
16 I -- that I -- that I trusted or that I --
17 how do I say it -- that I was comfortable
18 with or that I used, as stuff that I do
19 from, like, I guess day-to-day life, stuff
20 that I know about. So that's what I would
21 invest in.
22 Q. Okay. So let me see if I
23 understood that correctly.
24 So you would buy stock in
25 companies whose products or services you
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2 used in everyday life and who -- whose
3 products or services you felt comfortable
4 with. Is that fair?
5 MR. KIM: Objection.
6 A. Yeah. It's stuff that I used
7 from day-to-day life, stuff that I was
8 comfortable with, stuff that I knew.
9 Q. Do you recall any of the
10 securities you --
11 A. Yes.
12 Q. -- bought? Oh, okay.
13 So could you tell me what you
14 remember.
15 A. I invested in Starbucks, I
16 invested in Nintendo, and to Blizzard
17 Entertainment. I invested in Nvidia,
18 AMC -- not AMC. I'm sorry. My mistake.
19 It's AMD. AMD Software and just several
20 other companies that I was comfortable
21 with.
22 Q. Okay. So Starbucks is obviously
23 the coffee shop company; right?
24 A. Yes. Yes.
25 Q. Right. And Nintendo is the
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2 game --
3 A. Yes.
4 Q. -- platform.
5 Blizzard is also a game
6 manufacturer?
7 A. Yes.
8 Q. Nvidia and AMD, are they chip
9 manufacturers?
10 A. Yeah, for video cards. Video
11 cards.
12 Q. Okay. I take it you're a video
13 gamer.
14 A. Yes, I am.
15 Q. Okay. So let's wind forward a
16 little bit to January of 2021.
17 By that point in time, had your
18 investing strategy changed at all?
19 A. Yes.
20 Q. Okay. How had it changed?
21 A. I was able to do more research
22 and figure out a little bit more about the
23 stocks. Actually, when Covid hit, I
24 was -- I -- I pulled out all of the stocks
25 that I felt that didn't really -- weren't
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2 doing much for me in the stock market, and
3 I reallocated them to places where I felt
4 would make me more a profit.
5 Q. Okay. So when you say when
6 Covid hit, you're referring to March of
7 2020.
8 A. Yeah. Around that time. I
9 think -- I don't know the exact date or
10 time, but I can -- it's in the stock.
11 You'll see a dip really, really harshly at
12 a certain point.
13 Q. Okay. And at that point in
14 time, did you, like, just exit all the
15 stocks you held?
16 A. No. No. I didn't exit all the
17 stocks. I exited the ones that I felt
18 weren't going to do much for me, and then
19 I -- after, say, a few days of taking them
20 out, I put them back in, which was really
21 lucky. I put them back in right at the
22 bottom of that dip when Covid hit. And I
23 made a pretty good profit from that. But
24 yeah. I put them back in. On the
25 specific securities that I felt -- after
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2 doing more research, I felt a lot of
3 specific companies that I chose at that
4 point in time would make more of a profit
5 as a long-term investment.
6 Q. And so help me out with the
7 timeframe.
8 Is this, like, April/May of
9 2020?
10 A. I don't know the exact dates.
11 Q. Okay. But --
12 A. Around -- around when Covid hit,
13 or -- it didn't hit -- because I was
14 looking at the news, and I was aware of
15 Covid when it was in China. And it didn't
16 get to the U.S. yet. And nothing happened
17 to the stock market at the time. But I
18 do -- I was keeping track of the stock,
19 and it does dip pretty hard. When the
20 stock -- when the stock market dipped,
21 that's when I see in my head as Covid
22 hitting the U.S., when the stock market
23 first dipped.
24 Q. So you're talking about the
25 steep decline in, say, the S&P 500 that
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2 occurred in the spring of 2020, I take it.
3 A. Yes.
4 Q. Okay.
5 A. That's what it was.
6 Q. Okay. And so you sold some of
7 your portfolio at that point in time?
8 A. Yes, I sold some of my portfolio
9 at that point in time.
10 Q. Okay. And then you started
11 investing in different stocks.
12 A. Yes. Yes.
13 Q. Okay. And do you recall what
14 stocks you were investing in I think you
15 said for the long term?
16 A. Yes. That's when I started
17 investing in Tesla.
18 Q. You know, this is not relevant
19 to this, but Elon Musk is one of my
20 clients.
21 So do you have a Tesla?
22 A. No, I don't. But I would love
23 to have one. I just don't have the money
24 for it right now.
25 Q. So you invested in Tesla -- well
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2 so, you invested in Tesla sort of after
3 the spring of 2020, I take it.
4 A. Yes.
5 MR. KIM: Objection to form.
6 A. I was always looking at Tesla
7 even before the Covid, and I was doing a
8 lot of research, but I never actually -- I
9 don't think I've ever actually invested
10 until that point in time.
11 Q. Okay. And so why did you pick
12 Tesla?
13 A. Because I researched the
14 company, and I have a lot of faith in the
15 company and Elon Musk as well. So I put
16 my money in it.
17 Q. And how much time did you spend
18 researching Tesla?
19 A. I spent hours, days, weeks. I
20 spent a lot of time researching Tesla.
21 Q. Okay. And what was your
22 expectation for Tesla stock when you
23 purchased it?
24 A. My expectations for Tesla is for
25 it to keep growing as a long-term
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2 investment. I am not -- I just wanted to
3 put my money somewhere and let it sit and
4 not have to babysit my money from day to
5 day.
6 Q. And what made you think that
7 Tesla was a good long-term investment?
8 What was it specifically?
9 A. It was not, like, a specific
10 thing. It was just the whole company as a
11 whole and what they do. It's not any
12 specific thing. It's everything they do,
13 everything they strive for, everything
14 they have accomplished, not only in Tesla
15 but in SpaceX. Elon Musk is just I think
16 a phenomenal person, and he's -- he's
17 trying to make the world better. So I
18 want to put my money, help him out.
19 Q. I take it -- and I think you
20 already told me you still hold Tesla stock
21 both in Robinhood and in SoFi?
22 A. Yes.
23 Q. And if I'm recalling correctly,
24 if you purchased in sort of the spring of
25 2020, that has been a very profitable
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2 investment.
3 A. Yes.
4 Q. Okay. So -- so that -- so you
5 were explaining to me how your investment
6 strategy changed over time.
7 A. Yes.
8 Q. You know, and you explained to
9 me how you invested in Tesla, having done
10 lots of research.
11 Were there any other companies
12 that you invested in in that same way?
13 A. No.
14 Q. Okay. Now let's wind forward to
15 January of 2021.
16 Did your investment strategy
17 change at all?
18 A. Yes, for the short squeeze.
19 Yes, it did.
20 Q. Okay. And so what was your
21 strategy in January of 2021?
22 A. I -- I did research again. I
23 did a lot of research on shorting stocks
24 and what a short squeeze was. And I
25 studied specific stocks that I was -- that
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2 I was noticing and that a lot of people
3 were talking about at the time. And so I
4 just researched it, and I felt that a
5 short squeeze was going to occur. So
6 that's -- I invested my money as kind of a
7 short-term, like -- like, to have a game
8 for the short-term. It wasn't a long-term
9 plan. It was kind of like a short-term
10 thing.
11 Q. And the short-term game would be
12 from the squeeze.
13 A. Yes.
14 Q. Okay. And do you recall --
15 well, let me back up.
16 So how did you first hear of
17 there being a potential short squeeze?
18 A. I believe from the news, from
19 people at work talking about it, and a lot
20 of YouTube. I watch a lot of YouTube as
21 well. I heard a lot from YouTube. There
22 was a lot of content on YouTube about it
23 at the time.
24 Q. And do you -- do you recall what
25 particular companies' stocks that you
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2 learned about in the context of this short
3 squeeze?
4 MR. KIM: Objection to form.
5 A. There were several stocks. I
6 don't remember all of them.
7 Q. Well, what do you remember?
8 A. GME was the biggest one, just
9 GameStop. AMC was the next biggest one.
10 And there was a Bed Bath & Beyond and
11 Nokia. And there were several others.
12 Q. Okay. And of those stocks, do
13 you recall which you invested in?
14 A. Yes. In AMC and Nokia.
15 Q. And why did you pick AMC and
16 Nokia?
17 A. The biggest reason is just
18 because they were being shorted an
19 incredible amount, just like GameStop.
20 It's the same -- the same reason GameStop
21 was being -- because they were being
22 shorted, basically, and -- too much,
23 basically.
24 Q. So you said -- okay. So --
25 okay. So let's talk about AMC first.
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2 You said when you invested in
3 Tesla, that you had a lot of faith in the
4 company, and you described Elon Musk as I
5 think you said a phenomenal person; right?
6 A. Yeah. Yeah.
7 Q. Okay. So what was your
8 understanding of AMC's business?
9 A. AMC is a movie theater. I loved
10 going to AMCs. They're also a great
11 company. But at the time, I knew that
12 they weren't doing so well because of
13 Covid.
14 Q. Okay. Did you have any
15 intention of holding your AMC securities
16 for the long term?
17 A. I think I mentioned before it
18 was just for the short squeeze.
19 Q. Okay. Do you know who the CEO
20 of AMC was at the time?
21 A. No, I do not.
22 Q. Okay. Do you have any opinion
23 as to whether that CEO of AMC was a
24 phenomenal person?
25 A. No, I don't.
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2 MR. KIM: Objection to form.
3 Q. Okay. Did you have any
4 understanding as to what AMC's strategy --
5 business strategy was when you invested in
6 it?
7 A. At the time, no, I did not.
8 Q. Okay. Let's talk about Nokia,
9 then, for a second.
10 Did you have an understanding of
11 Nokia's business in January of 2021?
12 A. The same thing applies to Nokia
13 as AMC in my understanding of the company.
14 Q. Well, could you -- okay. Could
15 you unpack that for me a little bit?
16 So Nokia is not a movie theater
17 company.
18 A. No, no.
19 Q. No.
20 A. They're -- I know them more for
21 phone -- phone company. They made phones
22 in the past. And --
23 Q. What was your understanding of
24 the -- and what was your understanding of
25 the state of Nokia's business in January
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2 of 2021?
3 A. I figured that it was doing the
4 same as AMC. They were just on a
5 downtrend because of Covid.
6 Q. Any intention of holding Nokia
7 for the long run?
8 A. No.
9 Q. Okay. Just wanted to make
10 profit from the a short squeeze in the
11 short run?
12 MR. KIM: Objection to form.
13 A. Yes.
14 Q. Okay. Did you know who the CEO
15 of Nokia was?
16 A. No.
17 Q. Any view as to that person's
18 business acumen?
19 MR. KIM: Objection. Calls for
20 speculation. If he doesn't know who
21 it is, then -- I mean -- anyway, you
22 can answer the question.
23 A. Yeah. I don't know. I don't
24 know.
25 Q. Okay. So you mentioned GME.
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2 Is that GameStop, I take it?
3 A. Yes.
4 Q. So GME is the ticker for
5 GameStop?
6 A. Yes.
7 Q. The stock symbol. Okay.
8 So did you consider investing in
9 GME?
10 A. I did consider it. But I
11 ultimately did not.
12 Q. Okay. Why not?
13 A. At the moment, I believed
14 that -- well, there were several -- I
15 think there were two factors. So one of
16 them was the stock was pretty high at the
17 moment, and I felt that if there was a
18 short squeeze, that it wouldn't go up much
19 higher, so that's why I banked with AMC
20 and Nokia.
21 Q. Okay. And you also mentioned I
22 think Bed Bath & Beyond.
23 Did you consider investing in
24 Bed Bath & Beyond?
25 A. Yes. I think I've considered
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2 all or most of them. I didn't know all of
3 the stocks that were going to be short
4 squeezed. I had no idea which ones. But
5 I did know the more popular ones were the
6 ones that were shorted the most. And
7 those were the ones that I -- you know,
8 that I looked for, the ones that were
9 shorted the most.
10 Q. Okay. So there was a greater
11 potential for short squeeze in the short
12 term. Is that --
13 MR. KIM: Objection to form.
14 A. If that's how it would -- yeah.
15 Q. Okay. Have you ever retained an
16 investment or financial advisor?
17 A. Are you asking me if I had an
18 advisor for my financials? No.
19 Q. Yes.
20 A. Just me.
21 Q. Okay. And your decisions are
22 made, therefore, on your own research?
23 A. Yes.
24 Q. And is that, like, internet
25 research?
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2 A. Yes.
3 Q. Okay. And you mentioned I think
4 listening to or watching videos on Yahoo.
5 Is that where you get most of
6 your information before you make an
7 investment decision?
8 MR. KIM: Objection to form.
9 A. No. I -- YouTube. YouTube is
10 the place I would go for the most
11 information.
12 Q. Oh, yes. I misspoke. I
13 apologize.
14 A. That's okay.
15 MR. KIM: Hey, Dan, I don't want
16 to break your flow. But I think we're
17 close to an hour. So, you know, if
18 you want to wrap up this subtopic, we
19 could take a break -- you know, a
20 brief break after that or if you want
21 to take a break now.
22 MR. SLIFKIN: Yeah. Totally
23 fine. Let me just take a few more
24 minutes.
25 MR. KIM: Okay.
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2 BY MR. SLIFKIN:
3 Q. Okay. So you told me about
4 watching YouTube videos.
5 Do you read any newsletters or
6 publications about investing? And I'm
7 focusing now on January of 2021.
8 A. No. I am not actually -- I'll
9 tell you something. I'm not a big reader.
10 I am actually . So it's --
11
12
13
14
15
16
17
18
19
20 Q. All right. I'm sorry to hear
21 that. I was unaware. I'm sorry. I
22 apologize.
23 Do you -- well, okay. So you
24 told me about watching YouTube videos.
25 Do you listen to podcasts?
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2 A. Yeah. Every now and then.
3 Q. And to be clear, I'm
4 specifically asking about materials that
5 you considered before you made investment
6 decisions in January of 2021.
7 Are you with me?
8 A. Yes.
9 Q. And so in that context, did you
10 listen to podcasts?
11 A. Yes. I believe there were some
12 YouTube podcasts at that time that I was
13 listening to.
14 Q. Okay. So it would still be on
15 YouTube.
16 And did you watch any TV shows
17 about investing?
18 A. No. I don't watch TV at all.
19 Q. Okay. And you have told me
20 about your -- you told me about your
21
22 So do you follow any other
23 social media other than, like, YouTube
24 videos in the context of investment
25 decisions?
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2 MR. KIM: In 2020?
3 Q. In 2021.
4 MR. KIM: 2021.
5 A. It would just mainly be YouTube.
6 That would be -- mainly YouTube is where I
7 went.
8 Q. Okay. Do you have a TikTok
9 account?
10 A. I do now. But I don't think I
11 had one in the past.
12 Q. Okay. Just one more question.
13 You told me about, like, what
14 you did before you invested in Tesla.
15 So before you made your AMC and
16 Nokia investment decisions, how much time
17 did you spend researching those companies?
18 A. I never really researched those
19 companies.
20 Q. Okay. So the research you did
21 just had to do with the short squeeze?
22 A. Yes.
23 Q. Is that fair? Is that -- I just
24 didn't hear you.
25 A. Yes.
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2 Q. Is that a yes?
3 A. Yes. Yes.
4 Q. Okay. So is it fair to say you
5 never looked at the, you know,
6 fundamentals of AMC or Nokia?
7 MR. KIM: Objection to form.
8 A. I don't know what you mean by
9 fundamentals.
10 Q. The business metrics for those
11 companies.
12 A. No, I did not look at any kind
13 of business metrics for those companies.
14 Q. And you didn't form an opinion
15 as to what the value of those companies
16 was, the real value of those companies
17 was.
18 MR. KIM: Objection to form.
19 Calls for speculation.
20 A. I don't know. I don't know what
21 that was.
22 Q. Okay. Well, why don't we take a
23 break. What do you want? Ten minutes?
24 MR. KIM: Yeah. Ten minutes is
25 fine.
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2 THE VIDEOGRAPHER: All right,
3 Counsel. The time is 9:28. We are
4 off the record.
5 (Recess)
6 THE VIDEOGRAPHER: The time is
7 9:39. We're on the record.
8 BY MR. SLIFKIN:
9 Q. Okay. Mr. Huacuja, did you
10 speak to anyone on the break.
11 A. Yeah.
12 Q. Who did you speak to?
13 A. Phillip.
14 Q. Okay. And did you discuss this
15 deposition?
16 A. Yeah. I just wanted -- I
17 actually -- I contacted -- I think we were
18 just -- I just wanted to know if I was
19 doing okay. That's what I wanted.
20 MR. KIM: Well, I mean, let's
21 not -- you know, we're getting into
22 some substance of some attorney-client
23 communications. So I'm going to
24 direct him not to answer any questions
25 related to the content of our
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2 communications.
3 Q. Okay. Let me show you a
4 document which we're going to mark as
5 exhibit -- what's the number? 1. Okay.
6 And I think Megan is going to upload that,
7 and we'll let you know what to do.
8 MS. VINCENT: You should refresh
9 on Exhibit Share and you should be
10 able to see it.
11 MR. SLIFKIN: Let me see if I
12 hit refresh, I see Exhibit 1.
13 MS. VINCENT: Yeah.
14 (Huacuja Exhibit 1, YouTube
15 links, Bates P00002619, was hereby
16 marked for identification, as of this
17 date.)
18 Q. Do you have Exhibit 1 in front
19 of you?
20 A. Yeah, I see it.
21 Q. Okay.
22 MR. KIM: Make sure you scroll
23 through the -- you know, the entire
24 exhibit --
25 THE WITNESS: Okay. Thank you.
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2 MR. KIM: -- you know, once
3 something is populated.
4 THE WITNESS: Okay.
5 BY MR. SLIFKIN:
6 Q. Okay. And so Exhibit 1 bears
7 the Bates Nos. P00002619 through 2639.
8 Let me know when you've had a
9 chance to, like, look through this
10 document. You don't have to read the
11 whole thing, but just -- because first I'm
12 going to ask you to identify it for me.
13 Okay?
14 A. Okay. Yeah. I looked through
15 it.
16 Q. Okay. Do you recognize this
17 document?
18 A. Yes.
19 Q. Okay. Can you tell us what it
20 is, please.
21 A. This is basically all of the
22 research that I did on YouTube on the
23 dates that I did -- that I looked at the
24 videos, specific videos. That's what the
25 dates are there.
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2 Q. Okay. So -- okay. Is this
3 something that you provided to your
4 counsel to be part of the production of
5 materials in this matter?
6 A. Yes.
7 Q. Okay. And when did you give it
8 to your counsel?
9 A. This was within -- I think it
10 was within this week, I think, because
11 they asked for -- they asked for it.
12 So --
13 Q. Okay. Well, I mean, we got it
14 yesterday. So I haven't had the
15 opportunity to look at all these links.
16 And for that reason, I'm actually going to
17 hold this deposition open. We can see if
18 we need to call you back.
19 But let's at least --
20 MR. KIM: Well, we'll take
21 that -- we'll take that as a request,
22 and we'll take that under advisement.
23 MR. SLIFKIN: Yeah. I figured
24 you would do that, but we can sort
25 that out later.
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2 BY MR. SLIFKIN:
3 Q. But -- so explain to me how you
4 put this document together, Exhibit 1.
5 A. I went to YouTube, and I looked
6 at my search history.
7 Q. Okay. And beyond that, what --
8 if that was the first step, then what did
9 you do?
10 A. I copied and pasted. That was
11 it.
12 Q. Okay. And are these all the
13 videos that you watched prior to making
14 your investment decisions for AMC and
15 Nokia?
16 A. I am not 100 percent sure
17 because of the search options in YouTube
18 are not user friendly. But this would be
19 the majority of them, yes.
20 Q. Okay. Okay. And how much time
21 did you spend watching these videos?
22 A. I wouldn't watch the full video.
23 Q. Okay. But I mean in -- let's
24 focus now on the videos that are
25 identified on pages 2619 through 2624.
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2 Do you see that?
3 A. Yeah.
4 Q. Okay. So that's -- that's from
5 January 24th through January 28th.
6 Do you see that?
7 A. Yes.
8 Q. Okay. Do you know approximately
9 how much time it took you to watch those
10 videos?
11 A. I don't know the exact time.
12 Q. Okay. One second. If you go to
13 the second page of the document, there's
14 the date January 25, 2021.
15 Do you see that?
16 A. Yes.
17 Q. And it says "AMC Stock (Major
18 Short Squeeze Update)."
19 Do you see that?
20 A. Yes.
21 Q. Okay. Do you know who posted
22 that?
23 A. Not at the moment.
24 Q. Okay. Did you in fact watch
25 that video?
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2 A. Yeah. If it's there, I'm pretty
3 sure I watched it, because it was in my
4 history.
5 Q. Okay. Do you recall if any of
6 these videos that we identified on pages
7 2619 through 2624 -- do you recall if any
8 of them were particularly influential in
9 helping you make your investment choices?
10 A. I wouldn't say that.
11 Q. Okay. Did any one of the videos
12 stand out above the others?
13 A. No, I wouldn't say that either.
14 Q. Okay.
15 A. Not how I do my research.
16 Q. Okay. So -- what was the last
17 thing you said? I'm sorry?
18 A. That's not how I do my research.
19 Q. Okay. So how do you do your
20 research? Now I'm talking specifically
21 about during the time period in January of
22 2021.
23 MR. KIM: Objection to form.
24 Asked and answered.
25 A. So the way I do my research is I
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2 look at multiple different people's
3 perspectives, and I come up with my own
4 perspective upon that.
5 Q. Okay. But I'm asking a sort of
6 a simpler question. How did you select
7 these videos over other videos?
8 A. When you -- when you look up on
9 YouTube, usually they're the first couple
10 of pages, the first couple of ones that
11 are at the top when do you a specific
12 search. Or actually, they're also -- I
13 think there's an algorithm that YouTube
14 does. So if you watch one video, YouTube
15 kind of -- its algorithm will suggest
16 another video for you to watch, and that's
17 sort of a kind of chain reaction, sort of.
18 You'll watch one, they'll suggest other
19 ones, and now you will watch those, and it
20 will suggest other ones, so on and so
21 forth. It's just the YouTube algorithm.
22 Q. Okay. Back in that time period
23 in January of 2021, were you watching
24 whatever it is that YouTube suggested, or
25 were you making a selection?
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2 A. Both.
3 Q. Okay. So how did you make your
4 selection?
5 MR. KIM: Objection to form.
6 A. I would make my selection by
7 just -- I think the biggest thing was
8 if -- there were I think two factors. One
9 of the biggest things is how many views
10 did that video have. And the more views I
11 would watch it as well because the more
12 views something has, the more -- I would
13 say the more informative the video might
14 be because the amount of views. Also, the
15 thumbnail. The thumbnail is the little --
16 the diagram, the picture that you see when
17 you click on the video. That also
18 influenced me as well, how good the
19 thumbnail was.
20 Q. Okay. Okay. Let me mark as
21 Exhibit 2 --
22 MR. SLIFKIN: Megan, Tab 34.
23 MS. VINCENT: Yes.
24 Q. Let me mark as Exhibit 2 -- and
25 it should populate shortly --
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2 A. I see it.
3 Q. -- a letter from the Rosen Law
4 Firm to my law firm dated
5 February 27, 2023.
6 (Huacuja Exhibit 2, A letter
7 dated February 27, 2023, was hereby
8 marked for identification, as of this
9 date.)
10 MR. SLIFKIN: I do not have it.
11 Let me see here.
12 Q. Okay. I'm not going to -- I'm
13 just going to focus you on page 1 to 2 of
14 the letter in the portion that concerns
15 you, that has your name there,
16 Mr. Huacuja.
17 Do you see that?
18 A. Yes.
19 Q. Okay. So this -- well, okay.
20 Let me -- let me ask you first,
21 for that box where your name appears --
22 A. Yes.
23 Q. -- do you have any understanding
24 of what this shows?
25 A. Yes, I do.
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2 Q. What does it show?
3 A. My handles for the different
4 media outlets that I use.
5 Q. Okay. And so when you say
6 handles, what do you mean by that?
7 A. It's my -- the names that I use
8 online as a username.
9 Q. Okay. And are you, in fact, a
10 participant in all the different that are
11 identified here in the box for your name
12 account?
13 MR. KIM: Objection to form.
14 A. What do you mean participant?
15 Q. Okay. I mean, first, it says
16
17
18 What does that show?
19 A. That means on I have an
20 account under
21
22 Q. Okay. And similarly you have a
23 YouTube account, I take it.
24 A. Yes.
25 Q. A Discord account.
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2 A. Yes.
3 Q. A Steam account.
4 A. Hmm?
5 Q. Is that a yes? The court
6 reporter --
7 A. Yes.
8 Q. Yeah. Okay. And all the way
9 down, that's also LinkedIn, Messenger,
10 Instagram, TikTok, Twitter, Twitch,
11 Patreon, DeviantArt, Pinterest, WhatsApp,
12 and Reddit; right?
13 A. That's correct.
14 Q. Okay. Do you actively use each
15 of these social media accounts?
16 A. No, I don't.
17 Q. Okay. Back in January of 2021,
18 which of these accounts did you have?
19 A. I don't recall which accounts I
20 had and which I didn't at that time,
21 because I did add in -- after the
22 incident, I did enter some of these
23 accounts.
24 Q. Okay. Back in 2021, which of
25 these accounts were you actively using, if
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2 you recall?
3 A. It would probably be Facebook,
4 YouTube, Discord, Steam, and the -- yeah.
5 That's pretty much it. Messenger for
6 sure. And Twitch for sure. Patreon for
7 sure. And that's pretty much -- I did add
8 a little bit of Reddit at the time too.
9 Q. Okay. On Reddit, did you recall
10 any sub-Reddits that you used at that
11 time?
12 A. At what time?
13 Q. January of 2021.
14 A. After the incident, I did use
15 Reddit more often. I think during the
16 time, I was just -- I made the account for
17 research, basically, because during my --
18 during my research on YouTube, Reddit was,
19 you know, a popular topic and also one of
20 the major I think factors that contributed
21 to all of this stuff. So I made -- I
22 think that's when I made a Reddit account
23 at that time, or I had my -- I don't
24 recall if I made it then or if I got my
25 old account. I don't recall. But I do
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2 remember going to Reddit at that time just
3 to -- just to look and see what's going on
4 in Reddit.
5 Q. So you referred to the incident
6 in your prior answer.
7 What were you -- what did you
8 mean by "the incident"?
9 A. When Robinhood turned off the
10 buy button.
11 Q. Could you say that again? I
12 didn't catch it.
13 A. When Robinhood disabled the
14 ability to purchase stocks on specific
15 stocks.
16 Q. Okay. Let me show you another
17 document. Tab 28.
18 (Huacuja Exhibit 3, A Reddit
19 thread dated January 26, 2021, was
20 hereby marked for identification, as
21 of this date.)
22 Q. Okay. Do you have Exhibit 3,
23 sir?
24 A. Yes. I'm looking through it
25 right now. Okay.
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2 Q. Okay. So do you know what
3 Exhibit 3 is?
4 A. It looks like a thread or a post
5 on Reddit, Wallstreetbets post.
6 Q. Okay. Have you heard of
7 Wallstreetbets on Reddit before?
8 A. Before -- before when?
9 Q. Before today.
10 A. Yes.
11 Q. Okay. When did you first learn
12 about Wallstreetbets on Reddit?
13 A. Around the time of the incident,
14 like, I'd say about a few weeks before.
15 Q. Okay. And did you review
16 Wallstreetbets on Reddit at all?
17 A. Yes.
18 MR. KIM: Objection to form.
19 A. Yes, I did view it.
20 Q. Okay. And was that before the
21 incident, as you put it?
22 A. Yes. I viewed it before the
23 incident.
24 Q. Okay. So this you see is dated
25 January 26, 2021.
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2 Do you see that?
3 A. Yes, I see that.
4 Q. Okay. And if you go to the
5 second page of the document, if you look
6 towards the bottom, it says
7 "KyleKicksRocks."
8 Do you see that?
9 A. Yes.
10 Q. It says, "Is AMC still the
11 plan?"
12 A. Yeah, I see that.
13 Q. Okay. Do you know if you
14 reviewed this prior to your investment in
15 AMC?
16 A. I can say that I did not view
17 this specifically at all until now.
18 Q. Okay. But you were looking at
19 Wall Street bets prior to your investment
20 decisions in Nokia and AMC, I take it.
21 MR. KIM: Objection to form.
22 A. I was -- I was just
23 researching -- I just wanted to see what
24 it was so all about, I guess. I just
25 researched -- research. That's what it
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2 was.
3 Q. Okay. But you don't think you
4 saw this particular Reddit --
5 A. Well, I know for a fact that I
6 did not read this specific thread.
7 Q. Okay. And why do you know that
8 for a fact?
9 A. Because a lot of this -- like,
10 there's a lot of different factors. But
11 one is that I would remember it, and
12 number two, I would just browse. I
13 wouldn't read deep into any of this stuff,
14 because I really dislike Reddit. I think
15 Reddit is a horrible website that is --
16 it's not where you want to go for
17 information.
18 But I went here for research
19 just to see what it's all about. Like,
20 I'm trying to research something before I
21 put my money in it, so I came here to see
22 what it's all about so I can make a better
23 investment decision. That's why I came
24 here. And I just -- for research. That's
25 all it was.
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2 So if I even saw this thread, I
3 would only maybe read the first line at
4 the very top and then move on to the next
5 one. I would not go through the whole
6 thing. I would not even read most of this
7 stuff, because I find Reddit to be a waste
8 of time and a waste of brain cells, to be
9 honest.
10 Q. Okay. So I'm a little confused.
11 So if that's your view, I mean,
12 what -- I mean, what are you researching
13 when you looked at Wallstreetbets on
14 Reddit back in January of 2021?
15 MR. KIM: Objection to form.
16 Asked and answered. I mean, he has
17 already answered your question.
18 A. I mentioned before that I was
19 just researching what they were talking
20 about, what all the commotion was, what --
21 everything that was going on so I could
22 make an informative opinion on what I was
23 about to do.
24 Q. Okay. So you weren't -- so you
25 weren't, you know, researching particular
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2 companies. You were just researching what
3 was going on on Reddit. Is that fair?
4 A. Yes. That is fair to say.
5 Q. Okay. I get it. Right.
6 And what was your conclusion
7 about what was going on?
8 A. That -- that a whole -- that a
9 lot of people found a way to -- to do a
10 short squeeze. Yeah. Basically that a
11 lot of people sort of tripped onto the
12 discovery of making a short squeeze
13 happen.
14 Q. I see.
15 So did it -- was it your
16 understanding, based upon your research,
17 that a lot of people were coordinating
18 their trading?
19 MR. KIM: Objection to form.
20 Calls for speculation.
21 A. No. I don't believe that at
22 all.
23 Q. Okay. So what did you think was
24 going on amongst these Reddit users?
25 MR. KIM: Objection to form.
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2 Calls for speculation.
3 A. I have no idea what was going
4 on.
5 Q. No. I asked you what you
6 thought at the time.
7 MR. KIM: Objection.
8 Q. Did you have any thoughts?
9 MR. KIM: Calls for speculation.
10 Argumentative.
11 A. Yeah. I don't know what was
12 going on at the time.
13 Q. I didn't ask you that, sir.
14 I asked you what you were
15 thinking.
16 MR. KIM: Objection to form.
17 Asked and answered. Argumentative.
18 A. I was thinking that these guys
19 found -- found a way to form a short
20 squeeze.
21 Q. Okay. And when you say "these
22 guys," you mean the people who were
23 posting things on Reddit.
24 A. That's correct.
25 MR. KIM: Objection to form.
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2 Q. Okay. Have you heard the term
3 "Meme stock"?
4 A. Yes.
5 Q. When did you first hear the term
6 "Meme stock"?
7 A. Around the same time that I
8 found out about GameStop.
9 Q. So that began around about
10 January of 2021?
11 A. Yes.
12 Q. Okay. And for the court
13 reporter, I said Meme, M-E-M-E.
14 So what was your understanding
15 of what a Meme stock was?
16 A. My understanding of a Meme
17 stock. So it's -- a Meme is basically a
18 joke, without the stocks -- without
19 stocks. So just the word "Meme" by itself
20 is basically a joke or something to be --
21 to laugh at or some kind of humorous
22 depiction of, you know, something that --
23 that's kind of satire, just something
24 comical. And it's just a stock. I
25 guess in that tense, it's just a stock
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2 that's, like, a funny stock -- I didn't --
3 I don't know the exact meaning of a Meme
4 stock. But that's what I concluded, that
5 it was just some kind of satire on the
6 specific stock, so something funny was
7 going on basically.
8 Q. Was it your understanding
9 that -- well, withdrawn.
10 Did you think, back in January
11 of 2021, that AMC was a Meme stock?
12 MR. KIM: Objection to form.
13 Calls for speculation.
14 A. I -- personally, I don't know.
15 But people were calling them Meme stocks.
16 So --
17 Q. Yeah. Sir, I didn't ask if you
18 knew. I was just asking what was going on
19 in your head.
20 What were you thinking?
21 MR. KIM: Objection to form.
22 Asked and answered. Calls for
23 speculation.
24 A. Thinking about if they were Meme
25 stocks or not?
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2 Q. Yeah. Did you think in your own
3 mind that AMC was a joke?
4 MR. KIM: Objection. Calls for
5 speculation. If you know.
6 A. No. I did not think AMC was a
7 joke.
8 Q. Okay. Did you think Nokia was a
9 joke?
10 A. No.
11 Q. Did you think either AMC or
12 Nokia were Meme stocks?
13 MR. KIM: Objection to form.
14 Asked and answered.
15 A. I don't know if they were or
16 they weren't.
17 Q. Okay. You didn't have any view
18 in that regard.
19 A. No.
20 MR. KIM: Objection to form.
21 Asked and answered.
22 Q. Okay. Did you think that any
23 stocks back in January of 2021 were Meme
24 stocks?
25 A. I don't know. I didn't care
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2 about that aspect of it.
3 Q. Okay. So you had heard the
4 phrase "Meme stock" back in January of
5 2021; right?
6 A. Yes.
7 Q. And you had an understanding of
8 what it meant; right?
9 MR. KIM: Objection to form.
10 Asked and answered.
11 A. Yes, somewhat.
12 Q. And you didn't have any view as
13 to whether any particular stock was or
14 wasn't a Meme stock.
15 MR. KIM: Objection to form. I
16 mean, you're going to keep asking the
17 same questions?
18 A. I think I've answered that
19 question before.
20 Q. Yeah. Could you do it again,
21 please?
22 MR. KIM: No. He's not going to
23 do it again.
24 MR. SLIFKIN: Are you
25 instructing him not to answer?
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2 MR. KIM: Yeah. If you keep
3 asking the same questions, he's going
4 to give the same answer. We're going
5 to waste everyone's time.
6 MR. SLIFKIN: Are you
7 instructing him not to answer?
8 MR. KIM: Yes, I am.
9 MR. SLIFKIN: Okay. Is that an
10 assertion of privilege?
11 MR. KIM: It's not. It's an
12 assertion of common sense and let's
13 not waste time. You acknowledged that
14 you're repeating the same question.
15 So are we going to sit here and you're
16 going to ask him the same question
17 multiple times until you get an answer
18 that you like? Let's go.
19 MR. SLIFKIN: Okay.
20 BY MR. SLIFKIN:
21 Q. Back in January of 2021, is it
22 true that you didn't have any view as to
23 whether any particular stock was or wasn't
24 a Meme stock?
25 MR. KIM: Objection to form.
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2 Asked and answered.
3 A. Isn't that the same question,
4 sir?
5 Q. Could you please answer the
6 question?
7 A. I have --
8 MR. KIM: Objection to form.
9 Asked and answered.
10 A. I don't know about that. I
11 didn't care about Meme stocks.
12 Q. Okay.
13 A. I didn't know what they were.
14 Same answer.
15 Q. Okay. Is it fair to say what
16 you really cared about was whether or not
17 there was a short squeeze going on?
18 MR. KIM: Objection to form.
19 A. That was the only thing that I
20 was looking at.
21 Q. Okay. Okay. Let me show you --
22 let me show you -- okay. So before I show
23 you another document, are you familiar
24 with what's called the complaint in this
25 matter?
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2 A. The complaint for this Robinhood
3 lawsuit?
4 Q. Yes.
5 A. The short squeeze -- yes.
6 Q. Okay. Actually, that's what I
7 want to actually go to first.
8 MR. SLIFKIN: Can we just -- can
9 you just post to whatever this is,
10 Exhibit Share, the amended
11 consolidated class action complaint.
12 (Huacuja Exhibit 4,
13 Certification, was hereby marked for
14 identification, as of this date.)
15 MR. KIM: Is that supposed to be
16 Exhibit 4? Exhibit 4 is something
17 else.
18 MR. SLIFKIN: Exhibit 4 --
19 Exhibit 4 is Exhibit A to the
20 complaint. But --
21 THE WITNESS: So you want me to
22 look --
23 MR. SLIFKIN: -- I want you to
24 look first at Exhibit 5.
25
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2 (Huacuja Exhibit 5, Amended
3 Consolidated Class Action Complaint,
4 was hereby marked for identification,
5 as of this date.)
6 THE WITNESS: 5. Okay. Hold on
7 one second. Yeah. Okay. I
8 scrolled -- I scrolled through it.
9 BY MR. SLIFKIN:
10 Q. Okay. Have you ever -- so do
11 you have Exhibit 5 in front of you?
12 A. Yes.
13 Q. Okay. Have you ever seen this
14 document before?
15 A. Yes, I have.
16 Q. Do you have an understanding as
17 to what it is?
18 A. Yeah. The gist of it.
19 Q. All right. Just -- I'm starting
20 with what the document is.
21 Could you identify the document
22 for us.
23 A. It is the amended consolidated
24 class action complaint.
25 Q. Okay. And did you review this
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2 document prior to its filing in court?
3 A. I don't know. I believe I did,
4 but I'm not positive it was before or
5 after the filing.
6 Q. Okay. I understand you just
7 told me how, you know, you have
8 and you
9
10 A. Yes.
11 Q. So, I mean, do you actually
12 recall reviewing this document?
13 A. I did view this document -- yes,
14 I did. I remember the length of it, and I
15 remember the title. And I also remember
16 that -- our names, because it was -- one
17 of the first things I saw it was in
18 beginning -- yeah. There it is. My name
19 is right there in the beginning as a
20 plaintiff. So I did skim it. I did
21 see -- yeah. I do recall it.
22 Q. Okay. So -- okay. Now go back
23 to Exhibit 4, please.
24 A. Okay.
25 Q. Do you have that now?
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2 A. Yes, I do.
3 Q. Okay. Let me focus you on the
4 second page. Do you see it says
5 "Certification" at the top?
6 A. On the second page. Yes.
7 Certification.
8 Q. Okay. So we're on the second
9 page of Exhibit 4.
10 And is that your signature at
11 the bottom?
12 A. Yes, that is. I remember
13 signing it.
14 Q. Okay. So let's go to the third
15 page of the exhibit, which is -- has the
16 heading "Schedule A."
17 Do you see that?
18 A. Yes, I see it.
19 Q. And there's your name there.
20 Okay. Do you know what this
21 document is?
22 A. Yes, I do.
23 Q. Schedule A?
24 A. Yes.
25 Q. Okay. Can you tell us what it
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2 is, please.
3 A. This is my purchases and my
4 sales of the AMC and Nokia. Did you get
5 that?
6 Q. Okay. So --
7 A. Did you get that?
8 Q. Could you just say it again?
9 A. Yes. These are my purchases and
10 my sales of AMC and Nokia.
11 Q. Okay. AMC and Nokia stock;
12 right?
13 A. Stock. Stock.
14 Q. And the purchases were all done
15 on January 27, 2021; is that right?
16 A. Yes, all on Robinhood.
17 Q. And the sales were all done, all
18 made on January 28, 2021.
19 A. Yes.
20 Q. Is that right?
21 A. That's correct.
22 Q. Okay. And is this an accurate
23 representation of your trading in AMC and
24 Nokia stock in January of 2021?
25 A. Yes. I believe this was pulled
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2 from Robinhood's -- my records from
3 Robinhood.
4 Q. Okay. You see in the column
5 price.
6 A. The column of where? Price?
7 Yes.
8 Q. Price. Do you see that?
9 A. Yes.
10 Q. Okay. So let's first take a
11 look at the purchases.
12 Are you with me?
13 A. Yes.
14 Q. Okay. So there are -- let's
15 look -- first look at AMC.
16 Again, are you with me?
17 A. Yes.
18 Q. There are multiple entries for
19 purchases of AMC stock on January 27th.
20 Do you see that?
21 A. Yes.
22 Q. And they're at different prices.
23 Do you see that?
24 A. Yes, I do.
25 Q. And the prices are descending on
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2 this schedule.
3 A. Yes.
4 Q. Okay. So -- okay. Why did you
5 decide to make multiple purchases of AMC
6 stock on January 27th?
7 MR. KIM: Objection to form.
8 A. So there was a lot that was
9 actually going on on my thinking behind
10 this. At first, I just wanted to put a
11 little bit in, and then I decided to put
12 more in, and then I thought more about it,
13 and I decided to put -- I think -- I
14 believe I put all of it in, all of it that
15 I had.
16 Q. Did you say all that you had?
17 You cut off.
18 A. All that I had in the stocks.
19 Yes. All that I had investing stocks.
20 Q. Okay. So did you sell
21 securities prior to making these
22 purchases?
23 A. Yes, I did.
24 Q. Okay. Which securities did you
25 sell?
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2 A. All of my securities.
3 Q. All the -- that includes Tesla?
4 A. Yes. That includes Tesla.
5 Q. Okay. So all of the securities
6 you had at Robinhood, did you sell all of
7 those in order to make these purchases?
8 A. Yes. Yes, I did.
9 Q. Did you sell securities out of
10 any other account?
11 MR. KIM: Objection.
12 A. No. All I had was Robinhood.
13 Q. So you didn't have SoFi?
14 A. I don't believe that I had any
15 investments in SoFi at the time.
16 Q. Okay. Did you put any
17 additional monies into Robinhood in order
18 to fund these purchases?
19 A. No.
20 Q. Okay. So why did you decide to
21 do this in steps?
22 MR. KIM: Objection. Form.
23 Calls for speculation.
24 A. I don't recall at the time.
25 Q. Okay. You told me earlier you
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2 decided to put in a little bit and then
3 put in more and then put in everything.
4 Do you recall that? You just
5 testified --
6 A. Yes.
7 Q. -- to that?
8 A. Yes, I do.
9 Q. Okay. So what happened during
10 the day to make you -- make you think that
11 way?
12 A. My thinking behind the whole
13 thing. And actually, it's kind of funny.
14 My -- my belief in Tesla actually made me
15 do this.
16 Q. Can you explain that?
17 A. Yeah. I am long Tesla. I'm
18 really committed, and I see it as, like,
19 you're either all in or you're all out.
20 So that's sort of kind of my thinking
21 behind this whole thing. And then you --
22 the short squeeze was -- well, I felt that
23 it was going to happen because of all the
24 research that I did.
25 Q. Okay. So I'm a little confused.
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2 So you say you were long Tesla.
3 You still hold Tesla.
4 A. Yes.
5 Q. Right?
6 So those are purchases that you
7 made subsequent to January 28th of 2021;
8 right?
9 A. Yes.
10 Q. Okay. And so given that, why
11 did you sell your Tesla securities in
12 January of 2021 in order to buy AMC and
13 Nokia?
14 MR. KIM: Objection to form.
15 Asked and answered.
16 A. You're asking why I sold Tesla?
17 Q. Yeah.
18 MR. KIM: Same objection.
19 A. So like I said, like, I really
20 felt like the short squeeze was going to
21 happen, and that's why I sold Tesla and
22 basically said, like, you're all in or
23 you're all out. So that's why I was --
24 that's why I made the small amount of
25 purchases in the very beginning. But then
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2 I thought about it. I was, like, you
3 know, this -- either I'm all in or I'm all
4 out. So I started putting more and more
5 into AMC and Nokia. And I was going back
6 and forth between them. I wasn't just
7 doing all AMC and all Nokia. I was doing
8 some AMC, some Nokia, some AMC, some
9 Nokia.
10 Q. Okay. And are these -- to your
11 recollection, are these purchases
12 identified on Schedule A in chronological
13 order at least within the security?
14 A. I can't tell you that unless I
15 see the times. So I don't know.
16 Q. Okay. You see -- let's just
17 focus on AMC for a second. You see the --
18 you know, it starts with a thousand
19 shares, and then it has 15 shares, and
20 then it has 105 shares.
21 Do you see that?
22 A. Yes.
23 MR. KIM: Dan, I can tell you
24 this is a schedule that we prepared,
25 the Rosen Law Firm prepared. And just
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2 looking at it, I mean, it seems to me
3 that it was sorted by price per share.
4 A. Yeah. It looks like it's sorted
5 by price. It's not sorted by --
6 Q. Okay.
7 MR. KIM: And you guys -- I
8 mean, look, you guys have all his
9 documents, you know, you and
10 Robinhood. So, you know, you know
11 what the order of these trades were.
12 And sometimes each of these entries
13 don't reflect an actual trade. Right?
14 Some of these could be broken up
15 themselves by Robinhood. So, you
16 know, this is something that we
17 prepared. So I just want to make the
18 record clear for that.
19 MR. SLIFKIN: Okay. That's very
20 helpful.
21 BY MR. SLIFKIN:
22 Q. Okay. Do you have any
23 recollection as to what was happening to
24 AMC stock during the day on the 20 -- on
25 January 27, 2021?
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2 A. Yeah. It was fluctuating.
3 Q. Okay. So you were monitoring
4 the price during the day as you were
5 making your purchase decisions?
6 A. Yes.
7 Q. Okay. Is that also true of
8 Nokia?
9 A. Yes.
10 Q. Okay. And just for the record,
11 to be really clear, were you monitoring
12 the price of Nokia during the day on
13 January 27, 2021, while you were making
14 your purchase decisions?
15 A. Yes.
16 Q. And do you have any recollection
17 of what was happening with respect to
18 Nokia stock during that day?
19 A. Like, in the stock market, if it
20 was going up or down? I was monitoring
21 it, yes.
22 Q. Yeah. And do you recall was it
23 going up? Was it going down? Was it
24 fluctuating? Do you have any memory?
25 A. It was fluctuating.
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2 Q. Okay. Okay. So I take it that
3 you then sold all of your AMC and Nokia
4 stock the next day, January 28th.
5 A. Yes.
6 Q. Okay. Why did you decide to
7 pull out of the -- your investments in
8 Nokia and AMC stock?
9 A. Because of -- like I mentioned
10 before, the incident, which was Robinhood
11 disabling the buy button.
12 Q. Okay. And when did you first --
13 okay. So let me just ask you this
14 differently.
15 So when did you learn of
16 Robinhood disabling the buy button, as you
17 put it?
18 A. I learned on that specific day
19 when their markets opened. I didn't know
20 for a fact that that's what they did. I
21 thought it might have been a bug or a
22 glitch in their software. And I was
23 wondering what was going on. I had no
24 idea -- I did not receive any kind of
25 warning or any kind of email that this was
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2 going to happen prior or even during the
3 whole incident. I didn't receive
4 anything. And I was on the app, and I --
5 Robinhood opens at a specific time
6 every -- every day. And I was up before
7 that time, and during that time, because I
8 was going to monitor the stocks, because I
9 was going to pull out when the short
10 squeeze happened. So that's why I was
11 there monitoring it. And when the -- when
12 Robinhood finally opened up their market,
13 I guess, their button wasn't available. I
14 thought it was maybe a bug. I tried to
15 reset it, the phone. I tried to reopen
16 their app. It wasn't working. So then I
17 went to -- I went online to try to figure
18 out what was going on. A lot of people
19 were having the same problem. And then I
20 figured out, you know, that they
21 actually -- they did this on purpose.
22 Q. Okay. And was it after figuring
23 that out that you made the decision to
24 sell the securities, AMC and Nokia?
25 A. Yes. I did not know how long
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2 they were going to do this for. I had no
3 idea that they could even do this in the
4 first place. I was unaware and unsure
5 about any -- anything that they were doing
6 or what they could do on top of it. If
7 they could do this, then what else could
8 they do? I had no idea. So I decided to
9 pull out all of my stocks as soon as
10 possible so I can mitigate or cut my
11 losses, basically.
12 Q. Okay. In your mind -- so you
13 understood that Robinhood was not allowing
14 users of its platform to make any further
15 purchases of certain stocks, I take it.
16 A. Yes, at that time.
17 Q. Did you know if those stocks
18 were available for purchase on other
19 platforms?
20 A. At that time, I did not know.
21 Q. Okay. So what was it about the
22 inability for Robinhood users to purchase
23 those stocks that caused you to make a
24 sell order?
25 A. I'm sorry. Can you rephrase
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2 that question?
3 Q. What was it about the inability
4 of Robinhood users to purchase certain
5 stocks that caused you to place a sell
6 order?
7 MR. KIM: Objection to form.
8 Asked and answered.
9 A. Well, if you disable the buy
10 button, there's only one way a stock can
11 go. I mean, when this happened, and I
12 figured out that they disabled that
13 option, like, immediately after, a light
14 bulb went in my head, like, what the fuck
15 are they doing? Because the only way a
16 stock can move is down if no one can buy a
17 security anymore. I mean, it would be the
18 same if no one can sell a security. It's
19 a simple supply-and-demand situation. I
20 mean, if no one can sell anything and only
21 people can buy, of course the price is
22 going to raise. And the same thing goes
23 for if anyone -- if you can't buy anything
24 and you can only sell, the price is going
25 to go down. It's obvious.
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2 And like I said, I didn't know
3 for how long they were going to do this.
4 I had -- no one told me. I was on their
5 app the whole time. They didn't bother to
6 send me any kind of message at all. I was
7 on their app before their market opened,
8 after their market opened, during the,
9 market -- the whole -- during the whole
10 thing was happening. I didn't get any
11 kind of notification. I didn't get any
12 email. I didn't get anything on their
13 app. I was on their app the whole time.
14 Nothing. So I decided to pull out because
15 I didn't know how long this was going to
16 last. I had no idea what else they could
17 do. And I just -- it was just horrible.
18 So I just decided to cut my losses.
19 Q. So you spoke about, you know,
20 the inability to purchase AMC and Nokia at
21 least.
22 You were referring specifically
23 to on the Robinhood app, I take it.
24 A. Yes.
25 Q. You were unaware of whether
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2 those stocks were available to purchase
3 through other brokers.
4 A. I did not bother, because I did
5 not have stocks with other brokers.
6 Q. Okay. Can we just --
7 MR. SLIFKIN: Megan, can you
8 pull up Tab 8.
9 So I'm just going to move to
10 another exhibit, Mr. Huacuja.
11 (Huacuja Exhibit 6, A Robinhood
12 article dated January 28, 2021, was
13 hereby marked for identification, as
14 of this date.)
15 Q. So Exhibit 6 should be up.
16 A. I see it.
17 MR. KIM: Some of the page the
18 seem slow to populate. I don't know
19 if that's just me or --
20 MR. SLIFKIN: Oh, yeah. No.
21 It's me too. Oh, no. It's everybody.
22 So -- but it's not terribly long.
23 A. All right. I see it.
24 Q. Okay. And you see this is dated
25 January 28, 2021?
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2 A. Let me see. At the very top?
3 Yes.
4 Q. Right. And you see it's -- it
5 says "Robinhood" at the very top. And
6 then the --
7 A. Yes.
8 Q. And there's a logo. That's the
9 Robinhood logo, I take it?
10 A. Yes.
11 Q. It says "Keeping Customers
12 Informed Through Market Volatility."
13 Do you see that?
14 A. Yes.
15 Q. Okay. Have you ever seen this
16 document before?
17 A. No.
18 Q. Did you see it on
19 January 28, 2021, in your recollection?
20 MR. KIM: Objection to form.
21 Asked and answered.
22 A. No, not that I can remember.
23 Q. Okay. Okay. We can put that
24 down.
25 MR. SLIFKIN: Okay. Let's put
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2 up Tab 5.
3 (Huacuja Exhibit 7, A Twitter
4 Post, was hereby marked for
5 identification, as of this date.)
6 MR. KIM: Dan, we've been going
7 for an hour, I think. So, you know, I
8 don't want to break your flow, but
9 maybe we could take a couple of
10 minutes to stretch our legs, you know,
11 after you're done with any of the
12 questioning. Or do you think this is
13 a good time to take, like, three or
14 four minutes? Five minutes?
15 MR. SLIFKIN: Five minutes. Why
16 not? Okay.
17 MR. KIM: Okay. All right.
18 MR. SLIFKIN: Okay. Thanks.
19 THE VIDEOGRAPHER: Off the
20 record, then, Counsel. The time is
21 10:27. We are off the record.
22 (Recess)
23 THE VIDEOGRAPHER: The time is
24 10:34. We are on the record.
25 BY MR. SLIFKIN:
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2 Q. Okay. So we were talking about
3 certain restrictions, trading restrictions
4 that Robinhood imposed in January of 2021.
5 Are you with me?
6 A. Yes.
7 Q. Do you know if any other brokers
8 put similar restrictions in place at the
9 same time?
10 MR. KIM: Objection to form.
11 A. This is at the time --
12 Q. In January of 2021. Yes.
13 A. Yeah. I did not know. I wasn't
14 aware until -- I found out later.
15 Q. Okay. And what did you find out
16 later?
17 A. That there was other companies
18 that made restrictions, but they weren't
19 as severe as Robinhood.
20 Q. Okay. But at the time you made
21 your decisions in -- on January 28, 2021,
22 you only knew about Robinhood; is that
23 correct?
24 A. Yeah. I only knew about
25 Robinhood.
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2 Q. Okay. So let me mark a couple
3 more documents.
4 MR. SLIFKIN: Tab 12, Megan.
5 Q. So exhibit -- one second --
6 Exhibit 7 is a Twitter post which has your
7 name on the top of it.
8 Do you see that?
9 A. It's still loading for me.
10 Q. Oh, I'm sorry.
11 A. I'm trying to refresh. I don't
12 know what's going on. It's just loading.
13 Okay. There it goes.
14 Q. Okay. Do you have Exhibit 7 in
15 front of you?
16 A. Yes.
17 Q. Do you know what Exhibit 7 is?
18 A. Looks like a Twitter post.
19 Q. Okay. Do you know who made this
20 Twitter post?
21 A. It looks like I did.
22 Q. And a few questions.
23 There's a picture of a raven, I
24 guess. Is that a raven?
25 A. Yes.
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2 Q. Okay. And is that an identifier
3 for you?
4 A. Yes, it is.
5 Q. Okay. And below that, it says
6 "Streamlabs.com."
7 Do you see that?
8 A. Yes.
9 Q.
10 A. Yes.
11 Q. Okay. What is
12 ?
13 A. is one of my handles.
14 It stands for , which is
15 actually my computer -- I built this
16 myself, and my computer's name is
17 So I'm This is
18 So that's where comes
19 from. Streamlabs is the software that I
20 use to stream online.
21 Q. Okay. So explain to me what
22 Streamlabs does.
23 A. Streamlabs is basically -- it --
24 it's a software -- it's a recording
25 software that records -- it records you
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2 to -- it's -- I forget the technical term.
3 But it just records you so you can stream
4 your webcam or stream what you're doing
5 with whatever media that you're doing on
6 your computer and stream it out to a
7 service like Twitch, like Twitch.
8 Q. Okay. When you say stream,
9 you're indicating that this is a live
10 feed.
11 A. Yes.
12 Q. Okay. As opposed to a YouTube
13 posting, which is a recording. Is that
14 fair?
15 A. Yes.
16 Q. And so how frequently would
17 you -- do you use Streamlabs?
18 MR. KIM: Objection to form.
19 Are we talking about a particular
20 period of time?
21 Q. Yeah. I want to talk -- we're
22 all talking about early 2021; right?
23 A. I don't recall the amount of
24 times that I streamed during that time.
25 Q. Okay. And so this is dated
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2 February 18, 2021.
3 Do you see that?
4 A. Yes, I see that at the bottom
5 there.
6 Q. Okay. And there's a heading
7 which says "Live Now GameStop SEC
8 Hearing - Going to work soon."
9 Do you recall what you were
10 streaming here?
11 A. No, I don't recall exactly.
12 Q. Okay. Let me -- let's go to
13 Tab 5. I'm going to show you a different
14 document.
15 A. Oh, I remember now. I don't
16 know if you want me to say --
17 Q. Okay. So what is it you
18 remember now?
19 A. I remember what I was streaming
20 at this time because of the title.
21 Q. And you're referring back to --
22 one second -- Exhibit 7?
23 A. The tab -- yeah. Exhibit 7.
24 Yeah.
25 Q. Okay. So what were you
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2 streaming at this time?
3 A. So I remember that I was
4 streaming the GameStop SEC hearing, which
5 was a hearing that was going to be put on
6 by -- I don't know exactly who it was.
7 There were several lawyers or several
8 counsel people. I don't know who some --
9 I don't know, but I know this was a big
10 thing at the time. Everyone was looking
11 forward to seeing it. So I basically -- I
12 turned on YouTube to watch it, or I don't
13 know if -- I don't think it was YouTube.
14 I turned on whatever platform had it
15 streaming. So somebody was streaming the
16 SEC hearing. And I was just going to
17 watch it and watch it along with other
18 people who wanted to watch it with me.
19 Q. I see.
20 So you were picking up, like, a
21 live feed from somebody else and re --
22 A. Yes.
23 Q. -- broadcasting it. Is that
24 fair?
25 A. That is fair to say.
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2 Q. Okay. Your -- like, the stuff
3 you put on Streamlabs, is it saved at all?
4 A. Some of it is, and some of it
5 isn't.
6 Q. You --
7 A. A lot of it gets deleted after a
8 certain amount of time. A lot of it gets
9 deleted after a certain amount of time.
10 Q. Have you saved any of your
11 Streamlabs posts or live streams?
12 A. Yes, I have.
13 Q. Okay. And did you provide those
14 to your lawyers as part of this
15 litigation?
16 A. None of the stuff that I
17 saved -- like, this specific stuff is --
18 the stuff that I saved was for the gaming
19 that I do. It's not -- it doesn't have
20 anything to do with this -- this hearing.
21 Q. Nothing having to do with this
22 litigation.
23 A. Yeah. The litigation.
24 Q. And the subject matter of this
25 litigation. Okay. Fair enough.
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2 Okay. So why don't we put up
3 tab -- why don't we mark as Exhibit 8
4 Tab 5.
5 (Huacuja Exhibit 8, A thumbnail
6 with a link, Bates P00001312, was
7 hereby marked for identification, as
8 of this date.)
9 Q. Okay. Exhibit 8 should have
10 popped up. And it's a document with the
11 Bates No. P00001312.
12 Do you see that?
13 A. Yes, I do.
14 Q. Okay. Do you recognize this
15 document?
16 A. Yes, I do.
17 Q. Can you tell us what it is,
18 please.
19 A. This is -- it looks like a
20 thumbnail to I think my -- one of my first
21 videos or the first video I put up about
22 stocks.
23 Q. Okay. And when you say
24 thumbnail, what do you mean by thumbnail?
25 A. The thumbnail is the picture --
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2 basically the picture of my face and the
3 text that appears on it.
4 Q. Okay. And I take it, if you
5 click on the thumbnail, it takes you to
6 the YouTube video?
7 A. Yes, that's correct.
8 Q. Okay. And the title is "How I
9 got into Stonks."
10 Do you see that?
11 A. Yes.
12 Q. What -- what do you mean by
13 "stonks"?
14 A. Like, a -- like, it's -- like, I
15 guess, like, you could say it's, like, a
16 Meme. It's the same thing as stocks but
17 with an "n." It's more of what you --
18 what we call -- and "we" is referring to
19 gamers. In the gamer language, it's --
20 it's sort of -- what do you call it --
21 it's kind of like E-speak is what you call
22 it. It's, like, E-speak. It's, like,
23 internet speak, usually, when people type
24 to each other back and forth. There's a
25 whole history about it. But it's
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2 basically E-speak.
3 Q. I'm sorry. I don't know what
4 E-speak is. So maybe you could explain
5 that to me.
6 A. Yeah. So, like, just -- I guess
7 a lot of people refer to it as, like, you
8 know, if you've ever chatted with anybody
9 on a phone, like a messenger, any kind of
10 messenger app, and you're on your phone
11 typing, and you type "LOL." What does
12 "LOL" mean? "LOL." What is that? But
13 it's "laugh out loud" if you actually
14 spell it out. So the word I'm looking for
15 is leetspeak. So that's what it's called.
16 Leetspeak is this -- it's like a phrasing
17 of certain words, rephrasing of other
18 words. It's just to make it either funny
19 or shorter or condensed in -- when you're
20 typing to somebody online or -- yeah. In
21 this situation, it would be to make the
22 word "stock" be funny by saying "stonks."
23 Q. Okay. "LOL" I understood.
24 MR. KIM: These young kids and
25 their rock and roll.
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2 MR. SLIFKIN: "LOL" I actually
3 got. I'm not that far behind the
4 time.
5 Q. Okay. Well, let's -- okay. So
6 we went and clicked on that link. And
7 let's go back to the exhibits and see if
8 this works.
9 What I'd like to do is take the
10 video file and mark it as an exhibit.
11 MR. SLIFKIN: Is that working or
12 not?
13 Q. Okay. For whatever reason, it's
14 not working. But let's just -- let's just
15 be clear on the record. You know, there
16 is a 36-minute, 50-second video that you
17 uploaded onto YouTube, which is accessible
18 through this thumbnail, which is
19 identified on Exhibit 8; correct?
20 A. That's correct.
21 Q. Okay. So why did you post this
22 video?
23 A. I posted this video for anybody
24 interested in learning about stocks, I
25 believe. I would need to watch the video
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2 in full to tell you. But this was just my
3 introduction into stocks and how I got
4 into it, which is the title there. Do you
5 see?
6 Q. Okay. Well, was the video an
7 accurate reflection of your views at the
8 time you posted it?
9 A. Yes. At the time I posted it.
10 Actually, not necessarily. I think that's
11 when I first got into stocks. I think I
12 go over how I was when I first got into
13 stocks and how I was at the time. And I
14 don't recall exactly if I got into Tesla
15 in that video. But I might or might have
16 not. I just need to watch the video again
17 to let you know. But I don't recall.
18 Q. Okay. But -- so in this video,
19 there's a description of what -- how you
20 got into stocks and how your views changed
21 over time.
22 Is that fair?
23 A. Yeah.
24 Q. Okay. And so for each
25 particular point in time that you
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2 describe, are you describing accurately
3 your views?
4 A. In the video? Yes.
5 Q. Yes.
6 A. I believe so.
7 Q. Okay. And you -- is it correct
8 that you posted this on January 27, 2021?
9 A. Yes. That's what it says there.
10 Q. Okay. And you wrote here,
11 "Links below are all to SoFi."
12 Do you see that?
13 A. Yes.
14 Q. And, at that point in time, did
15 you have a SoFi account?
16 A. Yes. I believe I was just
17 getting into SoFi at this time.
18 Q. Okay. Why were you posting
19 links to SoFi?
20 A. Because I think as a new member
21 of SoFi, they gave me referrals, and I
22 wanted just to refer people to SoFi and
23 hopefully -- like, if -- I don't know -- I
24 forget how the referrals work, but if
25 someone picks up the referral, they will
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2 get some money, and then I'll get some
3 money too. I think that's how it worked.
4 I'm not, like, 100 percent on that.
5 Q. Okay.
6 A. They were just referrals.
7 That's all they were.
8 Q. Let me -- what I want to do now
9 is mark Tab 31.
10 (Huacuja Exhibit 9, Document,
11 was hereby marked for identification,
12 as of this date.)
13 MR. SLIFKIN: Sorry. I was
14 getting a call from somebody called
15 Spam Risk.
16 THE WITNESS: It might be
17 important.
18 MR. SLIFKIN: Yes. He's calling
19 a lot of firms right now.
20 BY MR. SLIFKIN:
21 Q. Okay. So let's see if this new
22 document is up.
23 A. 11?
24 Q. Exhibit -- I don't know what
25 happened to 9 and 10.
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2 (Huacuja Exhibit 11, Schedule D,
3 Capital Gains and Losses, was hereby
4 marked for identification, as of this
5 date.)
6 Q.
7
8
9
10 A.
11 Q.
12 .
13
14 A.
15 Q.
16
17 A.
18
19 Q.
20
21 A.
22 Q.
23
24
25 A.
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2
3 Q.
4
5
6
7
8 A.
9
10
11
12 Q.
13 A. .
14 Q.
15 A.
16 Q.
17
18 A.
19 Q.
20
21
22 A.
23
24
25
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2
3
4
5 .
6 Q.
7
8
9 A.
10 Q.
11 A.
12 Q.
13 A.
14 Q.
15
16 A.
17 Q.
18
19
20 A.
21
22 Q.
23
24
25 A.
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2
3 Q.
4 .
5 MR. SLIFKIN: Why don't we go
6 off the record for maybe until -- why
7 don't we go off the record until 2:00
8 and just let me see what else I have.
9 Okay?
10 THE VIDEOGRAPHER: 2:00 Eastern;
11 right?
12 MR. SLIFKIN: Oh, yes. Yes.
13 Sorry. Not 2:00 California. No, no,
14 no. Okay. So, like, five minutes.
15 THE VIDEOGRAPHER: Okay,
16 Counsel. The time is 10:54. We're
17 off the record.
18 (Recess)
19 THE VIDEOGRAPHER: The time is
20 10:59. We are on the record.
21 MR. SLIFKIN: Okay. I have no
22 further questions at this time. It's
23 defendant's position that we want to
24 hold the deposition open to allow us
25 an opportunity to review the videos,
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2 the links to which were produced
3 yesterday, and also the material that
4 was produced to us this morning prior
5 to the deposition which we didn't have
6 time to review ahead of time. Okay?
7 MR. KIM: I understand your
8 position. We'll take that request
9 under advisement. And I think, sort
10 of provisionally, we'll mark the
11 transcript as Confidential pursuant to
12 the protective order, and we'll deal
13 with that, you know, in accordance
14 with the protective order.
15 And just for the record, so
16 there's a gap between Exhibit 8 and
17 11. So there's no Exhibit 9 or 10,
18 just so it's clear on the cover sheet.
19 MR. SLIFKIN: Well, we tried to
20 mark the video, and it didn't work.
21 MR. KIM: Okay.
22 MR. SLIFKIN: The technology
23 didn't work. And I think we clicked
24 on it twice, which is why it's 9 and
25 10.
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2 MR. KIM: I got you.
3 MR. SLIFKIN: Okay.
4 MR. KIM: I have no questions.
5 MR. SLIFKIN: We can all --
6 thank you.
7 THE VIDEOGRAPHER: Okay,
8 Counsel. I'll sign off our video
9 today.
10 So here ends Media Unit No. 2.
11 This concludes the video recorded
12 virtual remote deposition of
13 Abraham Huacuja taken by the defendant
14 on Tuesday, March 21, 2023. The time
15 is 11:01 a.m. Pacific Daylight Time,
16 and we are going off the record.
17 (TIME NOTED: 11:01 a.m. PST.)
18
19 ____________________________
ABRAHAM HUACUJA
20
21 Subscribed and sworn to before me
22 this _____ day of ____________, 2023.
23
24 _______________________________
Notary Public
25
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