Exhibit 9: Deposition of Blue Laine-Beveridge (Dkt. 567-9, S.D. Fla.)
Summary
Exhibit 9 (Document 567-9) in Case 1:21-md-02989-CMA, entered on the FLSD docket June 7, 2023, is a 171-page transcript, marked confidential, of the videotape deposition of Blue Laine-Beveridge taken on April 26, 2023 at the New York offices of Cravath Swaine & Moore LLP before Silvia P. Wage of Veritext Legal Solutions. Jonathan Stern of The Rosen Law Firm appears for Plaintiffs and Antony Ryan and Robert DeNunzio of Cravath for Defendants, and Mr. Ryan conducts the examination. The exhibits include a Robinhood account statement, certifications dated 7/27/21 and 4/14/23, a Newsweek article titled How the SaveAMC Campaign Caused the Movie Theater Company's Stock to Soar, and AMC and Nokia trading data.
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
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“Exhibit 9: Deposition of Blue Laine-Beveridge (Dkt. 567-9).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-07-covid-era-misc-8b953e9a-1/
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Case 1:21-md-02989-CMA Document 567-9 Entered on FLSD Docket 06/07/2023 Page 1 of
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Exhibit 9
Case 1:21-md-02989-CMA Document 567-9 Entered on FLSD Docket 06/07/2023 Page 2 of
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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 IN RE: :
:
5 JANUARY 2021 SHORT :
SQUEEZE TRADING :
6 LITIGATION :
:
7 ------------------------ :
8
9 ** CONFIDENTIAL **
10 VIDEOTAPE DEPOSITION OF:
11 BLUE LAINE-BEVERIDGE
12 NEW YORK, NEW YORK
13 WEDNESDAY, APRIL 26, 2023
14
15
16
17
18
19
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22
23
24 REPORTED BY:
25 SILVIA P. WAGE, CCR, CRR, RPR
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1
2 April 26, 2023
3 10:02 a.m.
4
5 Videotape deposition of BLUE
6 LAINE-BEVERIDGE, held at the offices CRAVATH
7 SWAINE & MOORE LLP, 825 Eighth Avenue, Conference
8 Room 4930, New York, New York pursuant to
9 agreement before SILVIA P. WAGE, a Certified
10 Shorthand Reporter, Certified Realtime Reporter,
11 Registered Professional Reporter, and Notary
12 Public for the States of New Jersey, New York and
13 Pennsylvania.
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1
2 A P P E A R A N C E S:
3
THE ROSEN LAW FIRM
4 Attorneys for Plaintiffs
275 Madison Avenue, 40th Floor
5 New York, New York 10016
(212) 686-1060
6 Jstern@rosenlegal.com
BY: JONATHAN STERN, ESQ.
7
8 CRAVATH SWAINE & MOORE LLP
Attorneys for Defendants
9 825 Eighth Avenue
New York, New York 10019
10 (212) 474-1000
ARyan@cravath.com
11 RDenunzio@cravath.com
BY: ANTONY RYAN, ESQ.
12 BY: ROBERT DeNUNZIO, ESQ.
13
14 A L S O P R E S E N T:
15
DEVERELL WRITE
16 VIDEOGRAPHER
17
18
19
20
21
22
23
24
25
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1
2 I N D E X
3 WITNESS: BLUE LAINE-BEVERIDGE PAGE
4 EXAMINATION BY MR. RYAN 7
5
E X H I B I T S
6
NO. DESCRIPTION PAGE
7
Exhibit 269 a copy of Mr. 39
8 Laine-Beveridge's Twitter
Exhibit 270 a copy of Mr. 61
9 Laine-Beveridge's Robinhood
account statement December
10 2020 PR0001786 to PR0001800
marked Confidential
11 Exhibit 271 Exhibit 2 Mr. 79
Laine-Beveridge's
12 Certification dated 7/27/21
Exhibit 272 a copy of Mr. 88
13 Laine-Beveridge's résumé
P00001064 marked
14 Confidential
Exhibit 273 Newsweek article titled, 96
15 "How the SaveAMC Campaign
Caused the Movie Theater
16 Company's Stock to Soar,"
Exhibit 274 collection of AMC and Nokia 115
17 trading data from Mr.
Laine-Beveridge's Robinhood
18 account RHMDL00097433.001
through RHMDL00097433.097
19 marked Confidential
Exhibit 275 Mr. Laine-Beveridge's 131
20 Certification dated 4/14/23
P00002834 to P00002859
21
22 PREVIOUSLY MARKED EXHIBITS
23 NO. DESCRIPTION PAGE
Exhibit 2 2/27/23 letter from The 34
24 Rosen Law Firm to the
Cravath Law Firm and
25 attachment
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2 - - -
3 DEPOSITION SUPPORT INDEX
4 - - -
5
6 Direction to Witness Not to Answer
Page Line
7
29 14
8 30 11
9
Request for Production of Documents
10 Page Line
11 36 17
37 10
12 38 10
13
Stipulations
14 Page Line
15 61 20
16
Question Marked
17 Page Line
18
19
Reservation
20 Page Line
21
22
Motion to Strike
23 Page Line
24
25
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1 CONFIDENTIAL - BLUE LAINE-BEVERIDGE
2 THE VIDEOGRAPHER: We are going on
3 the record at 10:05 a.m., on April 26, 2023.
4 Please note that the microphones are
5 sensitive and may pick up whispering and private
6 conversations. Audio and video recording will
7 continue to take place, unless all parties agree
8 to go off the record.
9 This is Media Unit 1 of the video
10 recorded deposition of Blue Laine-Beveridge taken
11 by Counsel for the Defendant in the matter of In
12 Re: January 2021 Short Squeeze Trading
13 Litigation. This case is filed in the United
14 States District Court for the Southern District
15 of Florida.
16 My name is Deverell Write
17 representing Veritext Legal Solutions. The Court
18 Reporter is Silvia Wage from Veritext Legal
19 Solutions.
20 At this time will Counsel please
21 enter appearances.
22 MR. RYAN: Antony Ryan and Robert
23 DeNunzio, Cravath Swaine & Moore LLP,
24 representing the Robinhood Defendants.
25 MR. ROSEN: Larry Rosen, from The
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1 CONFIDENTIAL - BLUE LAINE-BEVERIDGE
2 Rosen Law Firm representing Mr. Blue
3 Laine-Beveridge and other class members.
4 THE VIDEOGRAPHER: Will the Court
5 Reporter please swear in the witness.
6 THE STENOGRAPHER: Sir, if you can
7 please raise your right hand.
8 BLUE LAINE-BEVERIDGE,
9
10 , after having been duly sworn,
11 was examined and testified as follows:
12 THE STENOGRAPHER: Thank you.
13 You may proceed.
14 EXAMINATION BY MR. RYAN:
15 Q. Good morning, Mr. Laine-Beveridge.
16 A. Good morning.
17 Q. Could you please state your full name
18 for the record?
19 A. Blue Laine-Beveridge.
20 Q. So I'm sorry. I think I've been
21 mispronouncing your last name.
22 So is it LINE-A (phonetic)?
23 A. It's LINE-A (phonetic). You can say
24 Lane (phonetic). Most people say Lane
25 (phonetic), but that's --
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2 Q. No, no, that's fine. I would,
3 obviously, line to say it right.
4 So it's Laine-Beveridge?
5 A. Yes.
6 Q. Great.
7 What is your current address?
8 A.
9
10 Q. And are you currently employed, sir?
11 A. I do private work.
12 Q. What kind of work is that?
13 A. Private nursing.
14 Q. And were you employed previously as a
15 nurse in a hospital?
16 A. Yes.
17 Q. And for what period of time was that?
18 A. I started in 2005 and I retired in
19 2020.
20 Q. Okay. I'm sure that was a difficult
21 time to be in nursing.
22 A. Yeah, it was, yeah.
23 Q. Do you understand that the Court has
24 appointed you as Lead Plaintiff in this lawsuit?
25 A. Yes.
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2 Q. What do you understand your role as
3 Lead Plaintiff to be?
4 A. To represent myself and the other
5 class members in the suit against Robinhood's
6 manipulation of the market.
7 Q. And what responsibilities do you have
8 then as the Lead Plaintiff?
9 A. To oversee my lawyers and to make
10 sure they're doing a good job for me and the
11 other class members.
12 Q. And who are your lawyers?
13 A. Larry Rosenthal [sic].
14 Q. Have you met any other lawyers --
15 well, strike that.
16 So, when you say, "Larry Rosenthal,"
17 are you referring to Larry Rosen?
18 A. Larry Rosen, I'm sorry, yes, of
19 course, yes.
20 Q. Have you met any other lawyers from
21 Mr. Rosen's firm?
22 A. Yes, Mr. Cohen. I didn't meet him;
23 on a Zoom call.
24 Q. Do you know his first name?
25 A. Michael.
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2 Q. What did you do to prepare for
3 today's deposition?
4 A. We had two Zoom calls, Larry and
5 Michael and I.
6 Q. Did you review any documents that
7 refreshed your recollection about any of the
8 events at issue in this lawsuit?
9 A. No.
10 Q. Okay. So you didn't look at any
11 documents in these Zoom calls that helped you
12 remember what took place in January and February
13 of 2021 better than you did before you looked at
14 the documents?
15 A. No, we didn't look at documents
16 during the Zoom calls.
17 Q. What do you understand this lawsuit
18 to be about?
19 A. About Robinhood turning off the buy
20 button for certain stocks and keeping the sell
21 button on for five full days, which can only
22 result in a stock price going down, and causing
23 myself and others to lose money.
24 Q. And how did you first hear about this
25 lawsuit?
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2 A. I don't remember, exactly.
3 Q. How did you first get in touch with
4 The Rosen Law Firm?
5 A. I called them.
6 Q. And how did you know about them?
7 A. I don't remember, exactly, how I
8 learned about the lawsuit, actually. But I know
9 -- I remember calling them and saying, I could be
10 a part of this.
11 Q. Have you had any relationship with
12 The Rosen Law Firm outside this lawsuit against
13 Robinhood?
14 A. No.
15 Q. Okay. So you didn't know them from
16 any other securities case?
17 A. No, no.
18 Q. Did you see something that The Rosen
19 Law Firm put out on the Internet?
20 A. I don't remember.
21 Q. Okay. So somehow you learned about
22 them and gave them a call?
23 A. Yes.
24 Q. And, on that call, you said that you
25 were interested in being a part of this lawsuit?
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2 A. Yes.
3 Q. Why was that?
4 A. Because I lost a significant amount
5 of money and I was frustrated about what
6 happened.
7 Q. How much money did you lose?
8 A. I don't remember, exactly.
9 Q. But you say that it was a
10 "significant amount"?
11 A. Yes. I remember at the time a
12 feeling that I lost a significant amount of money
13 because of what they did.
14 Q. Do you know, approximately, how much
15 that was?
16 A. No. I mean, it was based on what I
17 thought maybe the stock could have gone to. So
18 it would be speculation. So I don't know. But
19 it -- I felt at the time that it would be a
20 significant sum.
21 Q. Okay. So, when you're talking about
22 money that you lost, are you talking about the
23 difference between the price that you paid to buy
24 the stock and the price that you got when you
25 sold the stock, or are you talking about how high
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2 the stocks might have gone if events had played
3 out differently on January 28th of 2021?
4 A. Well, the latter ideally, because I
5 do think that they would have continued to go up
6 even more. But, at a minimum, yeah, from what I
7 bought and sold. Instead of them going --
8 continuing to go up, which I believe they would
9 have, they went down.
10 Q. Alright. And so, when you say you
11 lost a significant amount on the stocks at issue
12 in this lawsuit, is that based on where you
13 believe the stocks would have gone up higher on
14 January 28, 2021?
15 A. That's -- that's based on where I --
16 the difference when I bought it and when I sold
17 it, but if I -- it would have been even more than
18 that, I believe, if they hadn't turned off the
19 buy button and left the sell button on.
20 Q. Okay. What stocks are at issue in
21 this lawsuit?
22 A. Well, the ones that I purchased were
23 AMC and Nokia. But I know there's others like
24 GameStop and BlackBerry, Bed Bath & Beyond.
25 Q. You've now listed, I think, five
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1 CONFIDENTIAL - BLUE LAINE-BEVERIDGE
2 stocks in total; two that you bought and three
3 that you didn't buy, right?
4 A. Yes.
5 Q. Are there other stocks that you're
6 aware of that are also part of this lawsuit?
7 A. I know that there's some others that
8 were included. I'm not sure what they are.
9 Q. Alright. So the two stocks that you
10 bought that are at issue in this lawsuit are AMC
11 and Nokia?
12 A. Yeah. Those are the ones that
13 personally affected me.
14 Q. Right.
15 And did you lose a "significant
16 amount" on AMC?
17 A. I don't remember it, specifically. I
18 believe I lost more on AMC, but I'm not sure.
19 Q. And did you lose a "significant
20 amount" on Nokia?
21 A. I'm not sure. I don't know.
22 Q. Okay. So you have a general
23 recollection that you lost a "significant amount"
24 on the two stocks combined, but you can't tell me
25 how much that was, right?
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2 A. Yes.
3 Q. And you can't tell me whether the
4 loss was in AMC or Nokia or both; is that right?
5 A. Yes. I believe the majority was AMC,
6 but I don't recall, exactly.
7 Q. Have you heard the term "class
8 action"?
9 A. Yes.
10 Q. What do you understand a "class
11 action" to be?
12 A. It's a group of people -- a large
13 group of people that all incurred damages because
14 of another group. So they -- they're altogether
15 as, I guess, a class of Plaintiffs against the
16 person that -- the entity that damaged them.
17 Q. Have you ever been involved in a
18 class action prior to this one?
19 A. No.
20 Q. Are you involved in any other class
21 actions at this time, other than this lawsuit?
22 A. No.
23 Q. Do you know what a "class
24 representative" is?
25 A. I believe it's somebody who
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2 represents other members of the class.
3 Q. And are you aware that you are a
4 class representative in this case?
5 A. Yes.
6 Q. How frequently do you communicate
7 with The Rosen Law Firm?
8 A. Frequently. I would say every couple
9 of weeks.
10 Q. Have you read the complaint in this
11 case?
12 A. Yes.
13 Q. Did you receive a draft of the
14 complaint before it was filed with the Court?
15 A. I don't remember.
16 Q. Did you have any discussions with The
17 Rosen Law Firm about the complaint in this case
18 before they filed it with the Court?
19 A. To the best of my recollection, yes.
20 But I don't know for sure.
21 Q. Okay. So you don't have a specific
22 conversation in mind where you discussed the
23 complaint in this case with The Rosen Law Firm
24 before they filed it with the Court, right?
25 A. I don't have a specific recollection
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1 CONFIDENTIAL - BLUE LAINE-BEVERIDGE
2 of it, no.
3 Q. Do you recall making any edits to the
4 complaint before it was filed with the Court?
5 A. No.
6 Q. Do you recall making any comments to
7 The Rosen Law Firm about things that you thought
8 they should add or subtract or change in the
9 complaint before they filed it with the Court?
10 A. I don't recall anything specific that
11 I can remember.
12 Q. Okay. What claims are you bringing
13 in the complaint?
14 A. From my perspective, that Robinhood
15 manipulated the prices of these stocks causing
16 them to go down in value. And they had no
17 opportunity to go up. They could only go down.
18 And they did that to save money for themselves.
19 Q. And when you say you believed that
20 Robinhood "manipulated" the prices of these
21 stocks, what conduct by Robinhood are you
22 referring to?
23 A. They turned the buy button off for
24 these stocks and left the sell button on. And
25 when stocks can only be sold and not purchased,
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2 they can only go down in value.
3 Q. What's your understanding of when
4 Robinhood "turned the buy button off" for these
5 stocks?
6 A. When they realized that this was
7 going to cost them a lot of money, these stocks
8 going up.
9 Q. Why do you believe that the "stocks
10 going up" would have cost Robinhood money?
11 A. This is what I've read since then.
12 I've read, you know, some things online and it
13 sounds like they didn't have enough liquidity or
14 cash -- I don't know any of the technical stuff
15 -- to cover things and they realized that they
16 could maybe even go bankrupt, if they didn't turn
17 the buy button off and keep the sell button on.
18 Q. Okay. Is it your understanding that
19 it was on the morning of January 28th, 2021 that
20 Robinhood "turned the buy button off" for certain
21 stocks?
22 A. Yes, I believe it was January 28th.
23 Q. Is there any other conduct by
24 Robinhood that in your understanding is at issue
25 in this lawsuit, other than Robinhood turning the
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2 buy button off for certain stocks on
3 January 28th, 2021 while keeping the sell button
4 on?
5 A. I believe they also lied initially
6 about why they turned the buy button off.
7 Q. Were you aware on January 28th, 2021
8 that Robinhood had turned the buy button off?
9 A. I don't recall exactly when I
10 learned. But I'm sure it was the day or the next
11 day, because it was all over the news.
12 Q. Alright. And you read news articles
13 at the time about how Robinhood had turned the
14 buy button off, right?
15 A. Yes.
16 Q. Alright. So, when you say that it's
17 your understanding that Robinhood may have lied
18 about why they turned the buy button off, what is
19 it that Robinhood said about why they turned the
20 buy button off?
21 A. From what I recall, they said it was
22 because of market volatility. But from what I've
23 read since then, it sounds like they had some
24 sort of cash problem that they couldn't cover.
25 So they said it was because of volatility, but it
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2 was really to prevent them from losing lots of
3 money.
4 Q. Alright. So the statement by
5 Robinhood that you believe may have been a lie
6 was the statement that market volatility was why
7 Robinhood had turned the buy button off?
8 A. Yes.
9 Q. Do you have an understanding as to
10 whether the market for the stocks at issue in
11 this case was volatile at that time?
12 A. Can you repeat the question?
13 Q. Yeah.
14 Do you have an understanding as to
15 whether there was a lot of market volatility for
16 the stocks at issue in this case in the days
17 leading up to January 28th, 2021?
18 A. I wasn't aware at the time if there
19 was volatility, until after it happened and then
20 I read about it.
21 Q. Okay. So you were buying AMC and
22 Nokia stock in the week leading up to
23 January 28th, 2021, right?
24 A. Yes, I purchased them both before the
25 button was turned off.
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2 Q. Okay. And you were aware at the time
3 you purchased those stocks, that there was a lot
4 of market volatility, weren't you?
5 A. No.
6 Q. Okay. We'll come back to that later.
7 Alright. So do you have an
8 understanding as to whether it was truthful for
9 Robinhood to say that there was a lot of market
10 volatility for these stocks at the time?
11 A. Yes, I believe that there was
12 volatility. But I don't think that that's why
13 they turned it off. I think it was because they
14 were afraid of losing money --
15 Q. Okay.
16 A. -- themselves.
17 Q. Alright. So you believe that it was
18 truthful for Robinhood to say that there was
19 market volatility, but you believe the lie was
20 that you don't believe the market volatility is
21 what caused Robinhood to turn the buy button
22 off --
23 A. Yes.
24 Q. -- is that right?
25 A. Correct.
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2 Q. Are there any other untrue statements
3 that you believe Robinhood made, other than this
4 one about market volatility being the reason for
5 turning the buy button off?
6 A. Not that I'm aware of.
7 Q. Have you ever heard the term "class
8 period"?
9 A. Yes.
10 Q. What do you understand the "class
11 period" to be in this case?
12 A. I believe it to be the five days
13 following them turning the buy button off and
14 keeping the sell button on.
15 Q. And do you have an understanding as
16 to what the proposed class in this case is?
17 A. I believe it's anyone who had those
18 stocks prior to the 28th and then sold them
19 within the five days of them turning the button
20 off.
21 Q. Okay. And you further understand
22 that to be a class member in Plaintiffs' proposed
23 class definition, you need to have lost money on
24 the stocks at issue?
25 A. I believe so, yes.
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2 Q. Alright. So your understanding of
3 the proposed class definition is it's somebody
4 who held one of the affected stocks before
5 January 28th, 2021, who sold one of the affected
6 stocks during the five-day class period that
7 begins on January 28th, 2021 and who lost money
8 in that sale; is that right?
9 A. Yes.
10 Q. And do you have believe that you are
11 a member of that class?
12 A. Yes.
13 Q. With respect to what stocks?
14 A. Personally, it would be AMC and
15 Nokia.
16 Q. Okay. So you believe you're a class
17 member as it relates to your transactions in each
18 of those stocks, right?
19 A. Yes.
20 Q. But you understand that the class
21 also includes a number of other stocks that you
22 didn't personally transact in, such as GameStop
23 and BlackBerry, right?
24 A. Yes, and Bed Bath & Beyond and some
25 others, yeah.
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2 Q. Alright. And are you willing to be
3 the Lead Plaintiff in this case as a class
4 representative as it relates to those other
5 stocks that you didn't personally transact in the
6 stock such as GameStop or BlackBerry and Bed Bath
7 & Beyond?
8 A. Yes.
9 Q. And are you willing then to represent
10 the interest of class members who did personally
11 transact in stocks such as GameStop and
12 BlackBerry and Bed Bath & Beyond?
13 A. Yes.
14 Q. What are you doing to oversee the
15 lawyers at The Rosen Law Firm who are working on
16 this case?
17 A. Maintaining frequent communication
18 with them and following the progression of the
19 case.
20 Q. Have you read any filings with the
21 Court in this case other than the complaint?
22 A. I'm not sure.
23 Q. I believe that you testified earlier
24 that you understood that one of your duties as
25 Lead Plaintiff was to make sure that the lawyers
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2 representing the class are "doing a good job."
3 A. Yes.
4 Q. Do you recall that?
5 A. Yes.
6 Q. And how are you making sure that the
7 lawyers representing the class are "doing a good
8 job"?
9 A. By talking to them and assessing what
10 they tell me and feeling that they're doing an
11 adequate job.
12 Q. Okay. Are you aware that Robinhood
13 filed what's called a "motion to dismiss" the
14 complaint in this case?
15 A. Yes.
16 Q. What's your understanding of what a
17 "motion to dismiss" is?
18 A. To throw the case out.
19 Q. Have you read Robinhood's motion to
20 dismiss?
21 A. No.
22 Q. Is it your understanding that your
23 Counsel filed what's called an "opposition" to
24 Robinhood's motion to dismiss?
25 A. I'm not sure.
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2 Q. Okay. Have you read any filings that
3 The Rosen Law Firm made with the Court in this
4 case that related to Robinhood's motion to
5 dismiss?
6 A. No.
7 Q. Are you aware that the Judge in this
8 case issued a decision on Robinhood's motion to
9 dismiss?
10 A. I believe he denied the motion to
11 dismiss.
12 Q. Do you know who the Judge in this
13 case is?
14 A. No.
15 Q. But you believe the Judge in this
16 case is a man, right?
17 A. I'm not sure. I said "he," but I'm
18 not sure.
19 Q. Okay.
20 Alright. And so you haven't read the
21 Court's decision on Robinhood's motion to
22 dismiss; isn't that right?
23 A. That's right.
24 Q. And I take it from your previous
25 answer that you're unaware that the Judge granted
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2 the motion in part and denied in part; is that
3 right?
4 A. Yes, I'm not sure.
5 Q. Okay. You had believed simply that
6 the judge had denied the motion, right?
7 A. At least, part of it, yes.
8 Q. And so are you aware of why the Court
9 dismissed certain claims in this case?
10 A. No.
11 Q. And are you aware of why the Court
12 decided not to dismiss other claims in this case?
13 A. No.
14 Q. Do you understand that your Counsel
15 has served a set of requests for production of
16 documents on Robinhood in connection with this
17 case?
18 A. Not specifically, no.
19 Q. Have you been involved at all in
20 overseeing what documents your Counsel has asked
21 Robinhood to produce in this case?
22 A. No.
23 Q. Are you familiar with the term -- as
24 lawyers use it in a lawsuit -- the term
25 "discovery"?
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2 A. Somewhat, yes.
3 Q. And have you been involved at all in
4 overseeing what "discovery" your Counsel has
5 asked from Robinhood in this case?
6 A. No.
7 Q. Are you aware that the parties have
8 retained -- strike that.
9 Do you know whether the Plaintiffs
10 are going to file a motion for what is called
11 class certification in this case?
12 A. I'm not sure.
13 Q. Okay. Is that term, that term "class
14 certification," a term that you are familiar
15 with?
16 A. I've heard the term, yes. I'm not
17 sure exactly what it means. Yeah, I'm not sure,
18 exactly.
19 Q. Okay. Do you have any understanding
20 of what the term "class certification" means?
21 A. I believe, to the best of my
22 knowledge, whether a group can be considered a
23 class.
24 Q. Okay. Without getting into the
25 substance of any communications you may have had
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2 with your lawyers, have you had any
3 communications with anybody at The Rosen Law Firm
4 about filing a motion for class certification?
5 A. No.
6 Q. Are you aware of whether there's a
7 court deadline by which the Plaintiffs have to
8 file a motion for class certification?
9 A. Not specifically, no.
10 Q. Okay. And so you haven't had any
11 conversations with your Counsel about
12 preparations on their part to file a motion for
13 class certification?
14 MR. ROSEN: [INSTRUCTION] Objection.
15 I let you ask that last question. It goes to the
16 attorney-client privilege, though, the subject
17 matter.
18 And I actually would retroactively
19 object to that prior one, when you asked about
20 whether he discussed class certification with us.
21 It's privileged so...
22 But ask your next question.
23 MR. RYAN: Okay.
24 Q. Okay. But, as you sit here today,
25 you're not aware whether there is a court
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2 deadline by which the Plaintiffs need to file a
3 motion for class certification, right?
4 A. I don't know what the deadline is.
5 Q. Okay. And am I right that you don't
6 recall any discussions with anybody at The Rosen
7 Law Firm on the topic of a motion for class
8 certification?
9 MR. ROSEN: Objection. It's
10 attorney-client privilege. The subject matter of
11 this conversation is -- [INSTRUCTION] so don't
12 answer the question.
13 MR. RYAN: Okay. Well, I believe the
14 witness answered the question before and you
15 didn't object and I don't believe that's
16 privileged.
17 A. I do remember talking about class
18 certification. I don't know the deadlines or
19 anything like that, but I know that was
20 discussed. I'm not certain of the technical
21 details of that, of what that means.
22 Q. Okay. You haven't been involved in
23 reviewing any draft filings relating to a motion
24 for class certification, have you?
25 A. Not that I recall.
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2 Q. Are you aware that the parties have
3 retained experts on the topic of class
4 certification?
5 A. Not that I recall.
6 Q. Alright. And so am I right that you
7 have not seen any of the reports that the experts
8 for the Plaintiffs have filed, right?
9 A. Yes.
10 Q. And, likewise --
11 MR. ROSEN: We still haven't filed
12 anything yet but...
13 MR. RYAN: Thank you. Let me
14 rephrase that question.
15 MR. ROSEN: It doesn't matter.
16 Q. Am I right that you have not seen any
17 of the reports that the expert for the Plaintiffs
18 has submitted to Defense Counsel?
19 A. Yeah, I haven't seen that.
20 Q. Alright. And is it also the case
21 that you haven't seen any of the reports that the
22 experts for the Robinhood Defendants have
23 submitted to Plaintiffs?
24 A. Not that I recall, no.
25 Q. Do you have any social media
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2 accounts?
3 A. I have a Twitter and that's it.
4 Q. Alright. Do you have an Instagram
5 account?
6 A. I had an Instagram account that I
7 don't have anymore.
8 Q. Okay. What was the username of your
9 Instagram account?
10 A.
11 Q. And when did you delete this account?
12 A. Some point last year.
13 Q. So that was at some point in 2022?
14 A. Yes.
15 Q. And so that was after you became the
16 Lead Plaintiff in this case; is that right?
17 A. I don't recall if it was before or
18 after.
19 Q. Okay. It was after you sought to
20 become the Lead Plaintiff in this case,
21 certainly, right?
22 A. I don't recall when I deleted it.
23 Q. Okay. Why did you delete your
24 Instagram account?
25 A. It was problematic for one of my
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2 relationships.
3 Q. A "relationship" being a romantic
4 relationship?
5 A. My -- my girlfriend was getting
6 jealous of some of the stuff on there and so I
7 got frustrated and deleted the whole thing.
8 Q. Did you ever post anything on
9 Instagram about investments?
10 A. No.
11 Q. Did you ever post anything on
12 Instagram about AMC or Nokia?
13 A. No.
14 Q. Did you ever post anything on
15 Instagram about being a plaintiff in this
16 lawsuit?
17 A. No.
18 Q. Did you ever post anything on
19 Instagram about Robinhood?
20 A. No.
21 Q. Do you have a Reddit account?
22 A. I have -- I have Reddit, yeah. I
23 don't even know what my username is on there.
24 Q. That was going to be my -- that was
25 going to be my very next question.
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2 A. Yeah.
3 Q. What is your Reddit username?
4 A. I think it's -- something to do with
5 biking. It's all biking-related stuff. But it's
6 just questions and stuff on there.
7 Q. Okay. And that's an active Reddit
8 account?
9 A. Yeah, yes.
10 Q. Okay.
11 Alright. Let me show you what's
12 previously been marked in this case as Exhibit 2.
13 (Deposition Exhibit 2, 2/27/23 letter
14 from The Rosen Law Firm to the Cravath Law Firm
15 and attachment, was previously marked for
16 identification.)
17 MR. ROSEN: Thanks.
18 Q. Okay. And do you see that this is a
19 letter sent by Larry Rosen and others at The
20 Rosen Law Firm to me and others at my law firm on
21 February 27th of this year?
22 A. Uh-huh, yes.
23 Q. And then do you see there's an
24 attachment where it lists various accounts that
25 you and the other named Plaintiffs have? Do you
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2 see that?
3 A. Yes.
4 Q. And do you see, for instance, on
5 Page 2 of the attachment that there are listings
6 for some of the named Plaintiffs for Reddit
7 accounts such as for Abraham Huacuja and Cecilia
8 Rivas that lists Reddit accounts for them? Do
9 you see that?
10 A. Yes.
11 Q. And for you on the first page, the
12 only social media username or account listed is
13 the Instagram account , right?
14 A. Yes.
15 Q. Alright. There's no listing here of
16 your Twitter account, right?
17 A. Yes.
18 Q. And there's no listing here of your
19 Reddit account, right?
20 A. Yes.
21 Q. Do you know why that is?
22 A. I told them -- I told the law firm --
23 I -- I didn't think of Reddit as social media.
24 Like, I'm happy to give you my account. It has
25 nothing to do -- it's active. It is known -- I
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2 think I have 30 tweets and I joined it last year,
3 I think; nothing about investing. I'm pretty
4 sure I joined Reddit after this buy button thing
5 happened, this whole...
6 Q. Okay. Uh-huh.
7 And so, when you say you believe the
8 account has about "30 tweets," you are talking
9 about Reddit posts, right?
10 A. No, I'm sorry. Twitter, I think, has
11 about 30, Reddit probably similar. It's all
12 biking related.
13 Q. Okay.
14 A. I mean, I'm happy to look at my phone
15 and tell you the name on it, on the Reddit, if
16 you want to see it.
17 Q. [REQUEST] That would be great if at a
18 break you could speak to your Counsel and then --
19 A. Sure.
20 Q. -- provide us please with the Reddit
21 account name.
22 A. Sure.
23 Q. Thank you.
24 Do you have a Facebook account?
25 A. I might have. I -- I don't -- there
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2 might be a Facebook account in my name that I
3 used for Broadway lotteries that I don't use at
4 all. I'm happy to give you that. I don't even
5 know if it's -- what the name is, it might be
6 Blue Beveridge or Blue Laine, I'm not sure.
7 Q. Okay. And you understand that
8 Facebook is a social media site, right?
9 A. Yes.
10 Q. Okay. [REQUEST] So I would also
11 request what your Facebook username is.
12 Let me just go back to Reddit for a
13 moment.
14 Have you heard of a forum on Reddit
15 called Wall Street Bets?
16 A. I have now, yes.
17 Q. When did you first hear about Wall
18 Street Bets?
19 A. I don't recall, but I know it was --
20 once this whole thing blew up, I read about it,
21 Wall Street Bets or...
22 Q. Alright. Before January 28th, 2021,
23 the day when that morning Robinhood put up
24 certain trading restrictions in place, before
25 that day, had you ever looked at Wall Street
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2 Bets?
3 A. No.
4 Q. Do you have a TikTok account?
5 A. When my friends send me TikToks, I
6 read those. So I guess I must have -- like, I
7 don't know. I, actually, don't have. I think
8 you can look at TikTok without having an account.
9 No, I don't believe I have a TikTok account, no.
10 Q. Okay. [REQUEST] Will you at the
11 break look into whether you have a TikTok
12 account?
13 A. Sure.
14 Q. Do you have a LinkedIn account?
15 A. Again, I think there might be a
16 LinkedIn, but I don't know if there's anything on
17 there. Like, I never posted anything on LinkedIn
18 or TikTok. But I think maybe for -- when I do
19 Broadway lotteries and you need an account for
20 that, I think, I might have. I might have done
21 something with LinkedIn to do the lotteries for
22 Broadway.
23 Q. Okay.
24 MR. RYAN: All right. Let's mark
25 this document please. So this will be
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2 Exhibit 269. And it will be a Twitter page.
3 (Deposition Exhibit 269, a copy of
4 Mr. Laine-Beveridge's Twitter, was marked for
5 identification.)
6 MR. ROSEN: What exhibit?
7 MR. RYAN: 269.
8 MR. ROSEN: Just use the yellow one.
9 Q. Yeah, yeah. Actually, let me just
10 take that one back. Thank you.
11 And is Exhibit 269 a printout from
12 your Twitter account?
13 A. Yes.
14 Q. And do you see there's a reference
15 there at the top to Blue Beveridge 66?
16 A. Yes.
17 Q. And so is that your Twitter account?
18 A. I assume looking at it. I don't even
19 remember writing that. But, yes, it must be.
20 Q. And is that a picture of you there in
21 the circle in the upper left?
22 A. Yes.
23 Q. Okay. And you I assume agree that
24 you must have posted that picture to Twitter,
25 right?
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2 A. Yes.
3 Q. And it appears that you tweeted about
4 Tom Brady, right?
5 A. Yes.
6 Q. You're a Tom Brady fan?
7 A. I didn't used to be. But I am now,
8 yeah.
9 Q. Only since he joined the Bucs?
10 A. No, before that. I think it was the
11 first time I acknowledged it.
12 Q. Okay. Did you ever use your Twitter
13 account to tweet about investments?
14 A. No.
15 Q. Or about Robinhood?
16 A. No.
17 Q. Okay. And you agree that this
18 Twitter account is not included in the list of
19 social media accounts that you gave your Counsel
20 that they provided to you in a letter marked as
21 Exhibit 2, right?
22 A. Yes.
23 Q. Have you ever used the website called
24 Stock Twits?
25 A. No.
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2 Q. Do you use any other social media
3 that we haven't talked about so far?
4 A. No, not that I can recall or think
5 about, no.
6 Q. When did you start investing in the
7 stock market?
8 A. To the best of my memory, maybe
9 12 years ago.
10 Q. Okay. Are you a Robinhood customer?
11 A. Yes.
12 Q. When did you begin using Robinhood?
13 A. When it was still pretty young. I
14 don't recall, exactly. I would -- maybe ten
15 years ago.
16 Q. Why did you decide to use Robinhood?
17 A. It was simple. I remember I don't
18 think they -- I don't think they charged money
19 for trades. I think it was one of the first
20 accessible simple trading platforms.
21 Q. So you were attracted by Robinhood's
22 user friendly app?
23 A. Yes.
24 Q. Okay. And were you also attracted by
25 the fact that Robinhood offers commission-free
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2 trades?
3 A. Yes.
4 Q. How frequently do you trade on
5 Robinhood?
6 A. Sporadically. Sometimes I have -- I
7 went through a long phase where I just had index
8 funds. So I didn't -- wasn't actively trading
9 very much. It's hard to say. I'm not a huge,
10 you know, active trader.
11 Q. Have you ever used any brokers other
12 than Robinhood to invest in the stock market?
13 A. I had a Charles Schwab account years
14 ago, again, maybe ten years ago but -- that I
15 stopped using.
16 Q. Do you have that Charles Schwab
17 account still?
18 A. No.
19 Q. Or is it closed?
20 A. No, I closed the account.
21 Q. Do you remember, approximately, when
22 you closed that Charles Schwab account?
23 A. I don't remember, exactly.
24 Approximately, I believe, it was before -- I
25 think I closed that account and then joined
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2 Robinhood.
3 Q. Okay. Since you opened the Robinhood
4 account, have you used accounts with any other
5 brokers to trade stocks?
6 A. No.
7 Q. Have you ever bought or sold index
8 funds using Robinhood?
9 A. Yes.
10 Q. And have you bought or sold stocks of
11 individual companies using Robinhood?
12 A. Yes.
13 Q. Have you used Robinhood to trade
14 crypto?
15 A. Yes.
16 Q. And around when did you start trading
17 in crypto?
18 A. I don't remember, specifically; two
19 years ago.
20 Q. Do you know whether it was before or
21 after January 2021?
22 A. No.
23 Q. Have you ever invested money on
24 behalf of anybody else?
25 A. No.
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2 Q. Has anybody ever invested money on
3 your behalf?
4 A. No.
5 Q. Have you ever hired a financial
6 adviser?
7 A. The Charles Schwab guy, I believe,
8 was a financial adviser.
9 Q. Okay. Since you stopped using
10 Charles Schwab and opened your Robinhood account
11 a number of years ago, have you ever had a
12 financial adviser?
13 A. No.
14 Q. About how much time do you devote to
15 investing?
16 A. I don't know, exactly.
17 Do you mean looking at stocks or do
18 you mean actually making trades?
19 Q. I mean, both. So, I mean, both
20 trading in the stocks but, also, looking at
21 information that might affect your investment
22 decisions.
23 A. I probably spend a couple of hours a
24 week looking, maybe one hour a week, not to much.
25 Q. Okay. And what sources of
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2 information do you use to educate yourself about
3 stocks?
4 MR. ROSEN: Talking about now or back
5 in relevant time frame?
6 MR. RYAN: Thank you, Lar.
7 Q. So let's actually focus for a moment
8 on January 2021.
9 A. Uh-huh.
10 Q. So I'm talking about the month
11 leading up to and that sort of initial period
12 when Robinhood put certain purchase restrictions
13 in place, okay?
14 A. Okay.
15 Q. At that time in January 2021, what
16 sources of information did you use to educate
17 yourself about stocks?
18 A. I don't recall, exactly. I know that
19 I lost faith in the big stock websites, like,
20 Motley Fool and Seeking Alpha and stuff. I
21 stopped using those a long time ago, because I
22 didn't feel like they were really helpful.
23 So, I think, certain stocks I just
24 always had on my mind to possibly invest in. So
25 I don't recall exactly what I used or what I
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2 looked at.
3 Q. Okay. Did I understand you right
4 that at sometime you had a practice of looking at
5 the Motley Fool website?
6 A. Yeah, like when I first started over
7 ten years ago.
8 I think when I had Charles Schwab --
9 I believe I used to look at those websites -- you
10 know, there was another one; something house. It
11 was really old. I forget. And I was using -- it
12 was like pre-Robinhood and I was using those
13 websites. They didn't seem to work at all.
14 So my dad told me to go use this
15 Charles Schwab guy. And I remembered realizing
16 that he didn't do any better than index funds.
17 So I pulled all the money from there and closed
18 the account and then just used Robinhood.
19 Q. Okay.
20 A. So I stopped using those websites
21 even before I had a Robinhood account.
22 Q. Okay. And, to just be sure that I am
23 understanding you right, there was a point in
24 time when you used Motley Fool and Seeking Alpha,
25 but you stopped doing that before January 2021?
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2 A. At least, ten years before, yes.
3 Q. Alright. And so your dad at some
4 point advised you to use a financial adviser at
5 Charles Schwab, right?
6 A. Yes.
7 Q. And then, if I understood you right,
8 you then realized that the Charles Schwab guy
9 didn't do any better than index funds, right?
10 A. Yes.
11 Q. Alright. And so then were you then
12 engaged in self-directed trading in index funds?
13 A. Yes.
14 Q. Okay. And at some point in time, did
15 you stop doing that and start buying and selling
16 stocks of individual companies?
17 A. A little bit, yes. I bought airlines
18 and some cruise lines --
19 Q. Okay.
20 A. -- and AMC and Nokia. I think I
21 bought iBio or some bio stuff, yeah.
22 Q. Why did you start buying and selling
23 stocks of individual companies, as opposed to
24 index funds?
25 A. Because I thought I -- I hoped that
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2 they would make more money than index funds.
3 Q. Okay. So you believed that you could
4 outperform the index fund by selecting the
5 companies yourself; is that right?
6 A. I didn't believe I could. I hoped I
7 could.
8 Q. Okay. And why did you "hope" that
9 you would be able to pick stocks that would
10 outperform the market?
11 A. Why did I "hope" I could?
12 Q. Yes.
13 A. Because I did. Because I -- maybe I
14 -- just wanted to try and show my own hand at it
15 again.
16 Q. Okay. Do you have financial
17 experience?
18 A. No.
19 Q. Do you have any training or education
20 in investments?
21 A. No.
22 Q. Do you have any training or education
23 in finance?
24 A. No.
25 Q. And you understand that there are
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2 lots of people who are professional stock market
3 traders, right?
4 A. Yes.
5 Q. Okay. But you believe that you would
6 be able to pick stocks that would outperform the
7 stock market?
8 A. Yeah, sometimes you get lucky. Like,
9 I bought cruises and airlines and they doubled in
10 value once I bought them. So I know probably a
11 lot of that is luck, but sometimes you get lucky
12 and sometimes it works.
13 Q. When did you buy stocks of cruise
14 lines and airlines?
15 A. I don't remember, exactly. But
16 after, obviously, after the pandemic, they tanked
17 and I bought them and I know it doubled after I
18 bought them and that's when I sold, after they
19 doubled in value.
20 Q. Okay. And so, just to orient
21 ourselves, I believe, COVID hit in March of 2020
22 and these events at issue involving AMC and Nokia
23 began in January 2021, okay?
24 A. Uh-huh.
25 Q. So was it sometime between March of
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2 2020 and January of 2021 when you bought these
3 stocks of cruise lines and airline companies?
4 A. I don't remember, exactly. But I
5 assume it was -- because COVID was March you
6 said --
7 Q. Yes.
8 A. -- 2020?
9 Q. Yes.
10 A. So that would be ten months after.
11 Yeah, I don't remember, exactly. But
12 I assume I purchased them within ten months after
13 COVID.
14 Q. Okay.
15 A. I like to buy things that I believe
16 in and I think are low hoping that they'll go up
17 in value.
18 Q. Alright. And so did you believe at
19 this time during the COVID pandemic in 2020 that
20 the market price of big cruise line and airline
21 companies was undervalued?
22 A. I hoped. Not believed, I hoped.
23 Q. Okay. And you turned out to be
24 right, didn't you?
25 A. Yes.
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2 Q. And am I right that you made a
3 substantial amount of money on your investments
4 in cruise lines and airlines?
5 A. Yes.
6 Q. Did you read any information sources
7 at this time in 2020 about buying cruise line and
8 airline company stocks?
9 A. I -- from the best of my knowledge,
10 everything I read said not to buy them. They
11 said it would be a mistake, but I bought them
12 anyway.
13 Q. Okay. So it was a decision that you
14 made on your own?
15 A. Yeah. And I remember from back in
16 the days when I used to use those websites, that
17 they were often -- whatever they said, the
18 opposite seemed to occur. Whenever they told you
19 not to buy something, if you look back at it and
20 realize you should have bought it and some --
21 vice versa. So I went with my gut with them and
22 it worked out.
23 Q. Okay. Did you talk to anybody like
24 family or friends about buying airline and cruise
25 line company stocks in 2020?
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2 A. Again, from the best of my memory, I
3 did and they advised me against it.
4 Q. Okay. Were there any people who you
5 talked to or who you read articles by or social
6 media posts by who had the same idea you did and
7 who were advising the purchase of airline or
8 cruise line company stocks in 2020?
9 A. Not that I recall.
10 Q. Okay. So is it your view that you
11 went with your gut on the cruise line and airline
12 companies and got lucky?
13 A. Yeah, I mean, I like to give myself a
14 little credit. It wasn't pure luck but, yeah.
15 I remember Warren Buffet sold
16 everything and so everybody said, Warren Buffet
17 sold all his airlines. What are you doing?
18 And I said, I don't know. I just
19 feel like it could work and it did.
20 Q. Okay. So, at least, in this instance
21 with airline companies in 2020, you ended up
22 making a better decision than Warren Buffet?
23 A. You could say that, I guess, yeah.
24 Q. Okay. Were you following news
25 sources -- and I'm including, you know,
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2 newspapers and magazines and Internet sites that
3 informed you about how the stock prices of
4 airline companies declined when the COVID
5 pandemic hit in 2020.
6 A. I don't recall, exactly. But I must
7 have seen somewhere that they tanked in value.
8 And that's why I wanted to buy them. Because I
9 like to buy things when they're undervalue.
10 Q. Okay. Alright. So let's say we're
11 in 2020. You're interested in airline company
12 stocks like American Airlines or Delta or United.
13 Is there a website that you would go
14 to to look at stock price movements?
15 A. Usually, when I look at stocks, I
16 just go to Google and I type in the company name
17 and the stock and Google comes up with their
18 graphs, such as like their Google stock graphs
19 that I look at for their current value and their
20 historical value.
21 Q. Got it.
22 Okay. So you had a practice at this
23 time in 2020 and 2021 of going to Google and
24 looking at Google stock price charts?
25 A. Yeah. I don't know if I would call
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2 it "practice," but, yes, that's usually what I do
3 when I want to learn the current price of a
4 stock.
5 Q. Okay. And these stocks that you
6 decided to buy in 2020, the airline company
7 stocks and the cruise line company stocks, were
8 you following them for some period of time and
9 thinking about buying them or was it a quick
10 decision, you had the idea, looked on the
11 Internet and then went and executed that day?
12 A. From what I recall, I thought about
13 it for a few days, maybe a week and then pulled
14 the trigger and bought them.
15 Q. Okay. And during that time period
16 between when you had the idea and when you pulled
17 the trigger and bought the stocks, did you do
18 anything to read news about those companies?
19 A. Again, I don't recall, but I do
20 remember feeling that whatever I did read or
21 whoever I spoke to said, that's too risky, don't
22 do it.
23 And I do remember -- I don't remember
24 the sites, but I remember reading something
25 saying, like, you think these are low, it's a
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2 deal, don't make this mistake.
3 And I thought, whatever, like, after
4 I read this kind of stuff before and I'm just
5 going to -- for some reason, I just felt like I
6 should do it and I did it.
7 Q. Okay. And did you feel comfortable
8 at this time in making relatively risky
9 investments?
10 A. I was nervous, but I was comfortable
11 enough to do it.
12 Q. Okay. So you understood, didn't you,
13 that buying stocks of airline and cruise line
14 companies in 2020 that you thought were under
15 value was riskier than just buying stock market
16 index funds, right?
17 A. Yes. And the index funds, yeah,
18 almost anything is more risky than that, yeah.
19 Q. Okay.
20 Alright. So let me break that down
21 perhaps.
22 So is it your understanding that
23 buying the stock of any individual company is
24 riskier than buying an index fund because an
25 index fund has diversification of lots of
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2 different companies?
3 A. Yes.
4 Q. Alright. And then did you further
5 understand that stocks of airline and cruise line
6 companies in 2020 during the COVID pandemic were
7 riskier than the stocks of some other companies
8 that weren't as affected by the pandemic?
9 A. Yes.
10 Q. Alright. And you were comfortable
11 making those trades, right?
12 A. Comfortable enough to make the
13 trades. But I remember being very nervous in
14 making them and unsure but fingers crossed kind
15 of thing.
16 Q. And they ended up working out well
17 for you, right?
18 A. Yes.
19 Q. Do you use YouTube at all to follow
20 stocks?
21 A. No.
22 Q. Do you use Discord?
23 A. No.
24 Q. Do you use any video sources on the
25 Internet to follow stocks?
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2 A. No.
3 Q. Do you watch channels like CNBC that
4 have business news and that talk about
5 investments and the stock market?
6 A. No.
7 Q. Alright. So am I understanding right
8 that in January 2021 your source for information
9 about stocks you were thinking of investing in
10 was Google searches?
11 A. Just to get the price. It wasn't
12 even -- I wasn't looking for recommendations. It
13 was just to see the price.
14 Q. Okay. And then when you read
15 articles about companies -- right, you explained
16 that the year before in 2020 you read articles
17 about airline and cruise line companies?
18 Are those articles that you found
19 from Google searches?
20 A. I don't recall. I -- yeah, I would
21 assume, but I don't recall where I found them. I
22 don't think I read too many. I remember looking
23 at a few and everyone that warned me against it
24 made me more annoyed and made me want to buy it.
25 Q. Okay. Are there means other than
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2 Google searches that at this time in 2020 and
3 2021 you would use to find articles about
4 companies you were thinking of investing in?
5 A. No.
6 Q. Okay. So there was no newspaper or
7 magazine or website that you would regularly read
8 that had to do with investments?
9 A. No.
10 Q. Before you buy stock in an individual
11 company -- or strike that.
12 At this time in 2020 and 2021, before
13 you bought stocks in particular companies, would
14 you read any of that company's SEC filings?
15 A. No.
16 Q. Would you look at the company's
17 financial statements?
18 A. No.
19 Q. Would you look at earnings
20 announcements or other news releases from the
21 company?
22 A. No.
23 Q. Would you read any analyst reports
24 about companies that you're invested in?
25 A. No.
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2 Q. Alright. How about when you decided
3 at this time in 2020 and 2021 to sell a
4 particular stock, were there sources of
5 information that you would look at before making
6 a sell decision?
7 A. No.
8 Q. Okay. So am I right that you were
9 relying on your gut heavily to make both buy and
10 sell decisions?
11 A. Yes, mostly, uh-huh.
12 Q. Okay. Have you ever heard the term
13 "limit order"?
14 A. Yes, I've heard the term.
15 Q. What do you understand a "limit
16 order" to be?
17 A. I'm actually not sure. Yeah, I'm not
18 sure. It's something like -- I'm not that
19 advanced with investing. I don't know. I've
20 heard the term.
21 Q. Okay.
22 A. I'm trying to think of what I could
23 -- I can't even posit a guess. I don't know.
24 Q. Okay. Have you heard the term
25 "market order" before?
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2 A. Yes.
3 Q. Alright. Do you understand how a
4 market order is different from a limit order?
5 A. No.
6 Q. Okay. At this time in January of
7 2021, when you bought or sold stocks of
8 individual companies, did you have a practice of
9 just buying or selling at whatever the prevailing
10 market price is, or did you specify a price that
11 you would buy up to or a price that you would
12 sell down to?
13 A. Yeah, now that you -- with that
14 question, I'm now thinking of limit order and
15 market order is something like buy this if it
16 hits this price, sell if it goes to this price or
17 something.
18 I never did that, as far as I
19 remember, because I don't -- I just purchased it
20 at the current price.
21 Q. Okay. So you don't recall using the
22 Robinhood app to enter limits that you would, you
23 know, only have Robinhood execute the trade if
24 the stock reached a predetermined price?
25 A. No, I don't -- I don't recall doing
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2 that.
3 Q. Alright. I asked you about video
4 sources of information about investing. And just
5 to make sure that I'm asking you about all
6 possible sources. There are folks who might
7 listen to podcasts about investing.
8 Do you ever do that?
9 A. No.
10 MR. RYAN: Alright. Why don't we use
11 Tab 3.
12 Q. So we're going to mark as Exhibit 270
13 a document beginning with Bates No. P 1786.
14 (There is a discussion off the
15 record.)
16 (Deposition Exhibit 270, a copy of
17 Mr. Laine-Beveridge's Robinhood account statement
18 December 2020 PR0001786 to PR0001800 marked
19 Confidential, was marked for identification.)
20 MR. ROSEN: [STIPULATION] So, by the
21 way, I want to designate the transcript
22 "Confidential."
23 Q. Alright. Do you know what
24 Exhibit 270 is, Mr. Laine-Beveridge?
25 A. It looks like my Robinhood portfolio.
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2 Q. Alright. And would you look at your
3 monthly account statements from Robinhood?
4 A. No, I don't think I ever looked at
5 the monthly statements. I just log in and see
6 what everything was.
7 Q. Okay. So you would look at your
8 account portfolio on the Robinhood app?
9 A. Yes.
10 Q. Alright. And so do you see that this
11 indicates on the right side of the first page
12 that as of December 31st, 2020 you had
13 99.3 percent of your Robinhood portfolio
14 allocated to equities?
15 A. Yes, I see that.
16 Q. And then you had a small amount in
17 cash, right?
18 A. Yes.
19 Q. Alright. And are the equities then
20 the stocks that are listed on the second page of
21 Exhibit 270?
22 A. It looks like it, yes.
23 Q. Alright. And so you had a large
24 amount invested at this time at the end of the
25 year in American Airlines, right?
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2 A. Yes.
3 Q. And in Carnival?
4 A. Yes.
5 Q. And Delta Airlines?
6 A. Yes.
7 Q. And in Norweigian Cruise Line?
8 A. Yes.
9 Q. And in Royal Caribbean Group?
10 A. Yes.
11 Q. And in United Airlines, right?
12 A. Yes.
13 Q. Alright. And so those six companies
14 that I just went through, those are three
15 airlines and three cruise line companies, right?
16 A. Yes.
17 Q. Alright. And so am I right that
18 that's where the bulk of your money was invested
19 at that time as of December 31st, 2020?
20 A. Yes.
21 Q. Okay. So this indicates that you
22 also had a very small amount invested in a Spider
23 ETF; is that right?
24 A. Oh, where is that?
25 Q. It's the fourth line on the second
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2 page of Exhibit 270.
3 A. Yes. Uh-huh.
4 Q. And so that was an --
5 A. DIA, yeah, I had DIA.
6 Q. A Dow Jones index fund ETF, right?
7 A. Yeah, DIA index fund, yeah.
8 Q. Okay. But you only had 0.02 percent
9 of your total portfolio invested in the index
10 fund at that time, right?
11 A. Yes.
12 Q. Okay. And then you also held a small
13 amount of a company called Fuel Cell Energy?
14 A. Yes.
15 Q. What is Fuel Cell Energy?
16 A. Electric, I think, they make
17 batteries for electric cars.
18 Q. Okay. And then you had a small
19 amount of money invested in Hertz?
20 A. Yes.
21 Q. That's the car rental company, right?
22 A. Uh-huh.
23 Q. You also had a fair amount of money
24 invested in the biotech company you talked about
25 iBio, right?
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2 A. Uh-huh.
3 Q. How did you go about deciding in 2020
4 that iBio would be a good investment?
5 A. I don't recall, exactly. I think
6 somebody at work maybe suggested it. And I
7 looked at the price and it was super down. It
8 was like -- it looked like it had dropped like
9 95 percent or something itself that went on and I
10 took a shot.
11 Q. Do you remember hearing speculation
12 that iBio was working on a COVID vaccine?
13 A. That might be why it was suggested to
14 me. I don't recall exactly.
15 Q. Okay. So you may have decided to buy
16 the iBio stock on the speculation that it might
17 jump a lot, if they had succeeded in developing
18 and commercializing a COVID vaccine, right?
19 A. I may have, yes.
20 Q. Alright. And I believe you said
21 somebody at work mentioned iBio to you?
22 A. Yes.
23 Q. Who was that?
24 A. Probably Jesse or Alex, maybe
25 Brandon, some guys at work that, you know, do
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2 small investing.
3 Q. Okay.
4 A. They were always throwing out names
5 and I was like, whatever, whatever, whatever.
6 And I think I looked at that one and I said, oh,
7 that's really far down, so I could do it.
8 Q. Okay. And so there were colleagues
9 at your workplace who you talked about
10 investments with?
11 A. In a minor way, yeah.
12 Q. And where do Alex and Jesse and
13 Brandon work?
14 A. New York Presbyterian Hospital.
15 Q. I've been there. It's a fine
16 hospital.
17 A. Yeah.
18 Q. Alright. And were you working at New
19 York Presbyterian at that time?
20 A. Yes. When was this? I'm trying to
21 remember exactly when I left there. I don't
22 remember exactly when I left. It was either 2020
23 or 2021.
24 But, yeah, if they were giving me
25 ideas, it was when I was working with them.
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2 Q. Okay. And did you ever speak to
3 Alex, Jesse or Brandon about AMC?
4 A. No.
5 Q. How about Nokia?
6 A. No.
7 Q. Alright.
8 A. That was -- yeah, I definitely had
9 left the hospital by then. That was -- yeah, I
10 had already left. So, anyway, I didn't speak to
11 them about that stuff.
12 Q. Okay. So it was, I believe, around
13 April 2020 that you said you became a
14 self-employed nurse, right?
15 A. Yeah. I actually don't -- I don't
16 remember exactly when my last day there was, but
17 it was -- I think it was around there that I
18 became self-employed.
19 Q. Okay. And so being a self-employed
20 nurse, do you get shifts at a hospitals or how
21 does that work?
22 A. No, I work privately with private
23 patients at their home.
24 Q. Oh, I see, okay.
25 And is there then some sort of agency
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2 that you are involved with?
3 A. No, I work directly with the
4 families.
5 Q. Okay.
6 Okay. And so, in the time since you
7 became a private nurse, are there other people
8 who you have a practice of speaking to about
9 investments?
10 A. No. You know, I talk to my brother
11 sometimes, you know, but not really.
12 Q. Okay.
13 A. I don't have any strong investment
14 friends that I really -- mostly, it's all on my
15 own.
16 Q. Did you ever talk to your brother
17 about AMC?
18 A. I don't recall if I spoke to him
19 about it.
20 Q. Did you ever talk to your brother
21 about Nokia?
22 A. I don't recall. I know that we both
23 love movies and we're half Finnish and so we
24 always talked about Nokia. We knew Nokia to
25 crash since its heyday. So those have kind of
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2 been on our radar for a while. So AMC had been
3 way down too.
4 So I don't have any specific
5 recollection talking to him about that, but it's
6 possible I did.
7 Q. Got it.
8 Alright. So is Laine a Finnish name
9 then?
10 A. Yes.
11 Q. Alright. And so are you aware that
12 Nokia, although it's a global company, its
13 headquartered in Finland, right?
14 A. Yes.
15 Q. And was that one reason why you
16 decided to buy Nokia stock?
17 A. Yeah. My mom grew up in Finland and
18 she used to have rubber boots made by Nokia.
19 They used to make rubber boots. And I think she
20 was always sad that Nokia was this big, you know,
21 global giant for a while and then it kind of went
22 very much downhill and, you know, it was -- hoped
23 that it would make a come back.
24 Q. Right. There used to be cell phones
25 and so forth, right?
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2 A. Exactly.
3 Q. Alright. And was one reason that you
4 bought AMC stock that you're a movie fan?
5 A. Yeah. I have the AMC Stubs A-List
6 membership. I see movies frequently and I've
7 been -- when COVID happened, I was afraid that
8 they were going to close all the movie theaters
9 permanently. So I've always been a supporter of
10 AMC.
11 Q. What is the "AMC Stubs A-List"?
12 A. Pay $26 a month and you can see three
13 movies a week for free. It's 12 movies a month
14 for 26 bucks, which is a great deal.
15 Q. Got it.
16 So you're a fan of the in-the-theater
17 movie experience?
18 A. Yeah, very much, yeah.
19 Q. Okay. Alright. So I'm back now on
20 Page 2 of Exhibit 270.
21 Do you see you had a small amount of
22 money in a company called Phunware? That's
23 spelled beginning with a P-H.
24 A. Uh-huh. Yeah.
25 Q. What is Phunware?
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2 A. I don't even -- think it's a software
3 company and I think that was probably something
4 that somebody from work recommended. It sounds
5 like something that they would -- I don't think I
6 bought very much at all. It looks like it's one
7 of those things that maybe I bought just so if it
8 went up, I could say -- I mean, I bought so
9 little, I couldn't actually make or lose money
10 from it. But that would remind me to look at it
11 when I logged into Robinhood and I could tell
12 them, ah, man, you were right, I should have
13 listened to you or, you know, what are you guys
14 talking about, this thing tanked.
15 Q. Got it.
16 So you were using that small
17 investment more as a tracking mechanism?
18 A. Exactly, yes.
19 Q. Alright. And then do you see
20 beginning on Page 3 of Exhibit 270, there is a
21 listing of account activity?
22 A. On Page 3? Okay, yes.
23 Q. Alright. And so then this list just
24 goes on for some number of pages, but this lists
25 individual transactions for the month of
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2 December 2020 in your Robinhood account.
3 Do you see that?
4 A. Yes.
5 Q. And do you see that you had a lot of
6 activities -- I'm looking at, for example,
7 Pages 4, 5, 6 of this exhibit that are called
8 "crypto money movement"?
9 A. Yes.
10 Q. And does that mean that you were
11 moving money out of your stock account into a
12 crypto account?
13 A. Yeah. Let's see. Yes. Yes. Yeah,
14 because I sold the airlines and cruises at that
15 point, I believe. I don't remember exactly,
16 honestly.
17 Q. So you see here back on the first
18 page of Exhibit 270, your opening balance for the
19 month of December 2020 is shown as
20 and the closing balance is shown as
21 ?
22 A. Yes.
23 Q. And is it your understanding that
24 it's not that you lost money during this month,
25 it's that you sold some of your airline and
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2 cruise line company stocks and moved the proceeds
3 into a crypto account?
4 A. Yeah, I don't remember, exactly. But
5 it looks like that from this, yes.
6 Q. Alright. Are you familiar with short
7 selling?
8 A. Somewhat now when this whole thing
9 happened, there was a lot of articles about it
10 and I read a little bit about it. I'm still not
11 exactly sure what it is.
12 Q. Okay. So back at the beginning of
13 January 2021 -- if we can put ourselves back at
14 that time frame before the activities at issue in
15 this case -- were you familiar with what short
16 selling is?
17 A. No.
18 Q. And were you familiar with something
19 called a "short squeeze"?
20 A. No. So, I guess, short selling is
21 when -- as far as I know is when you think a
22 company is going to go down in value and somehow
23 you can make value with that belief.
24 Q. Uh-huh.
25 A. I don't know how it works exactly
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2 but, yeah.
3 Q. Okay. And so do you understand now
4 what a "short squeeze" is?
5 A. Not exactly. I believe it's -- if a
6 number of people believe or are hoping to make
7 money by a company decreasing in value, if that
8 company goes up in value, it's squeezing the
9 short sellers. But I'm not sure.
10 Q. Okay.
11 Alright. So you've got a general
12 understanding that a short squeeze is a bunch of
13 people getting together to buy a stock or hoping
14 to squeeze out short sellers, right?
15 MR. ROSEN: Objection. That's not
16 what I said.
17 A. No, not "a bunch of people." From
18 what I know, it's when people that bet against --
19 people that bet against -- short sellers are
20 betting against the company, if they made the
21 wrong bet and the company doesn't continue to go
22 down, those people are squeezed. It has nothing
23 to do with a group of people.
24 Q. Okay. Did you read articles in
25 January 2021 about a potential short squeeze?
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2 A. Not that I recall, no.
3 Q. Do you recall hearing in January 2021
4 about GameStop?
5 A. Before I purchased things?
6 Q. Alright. Let's just make sure we're
7 clear.
8 You didn't ever buy any GameStop
9 stock, did you?
10 A. No, no.
11 Q. Did you think about potentially
12 buying GameStop stock?
13 A. No, because I don't -- I'm not a
14 video game player and I usually just -- I don't
15 know anything about it. And, no, I never thought
16 about buying GameStop.
17 Q. Okay. Did you read articles in
18 January 2021 about how the price of GameStop's
19 stock was going up dramatically?
20 A. Yeah. I don't know when I read those
21 articles. But, of course, it was huge news.
22 GameStop was everywhere, you know.
23 Q. And did you read articles at the time
24 that contributed the price increase of GameStop
25 stock to a short squeeze?
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2 A. At some point, I remember reading
3 articles about that. I believe it was after
4 everything happened with Robinhood, because a lot
5 of that stuff came out.
6 Q. Okay. Did you see that there were a
7 lot of social media posts about GameStop?
8 A. Not much. I don't have really like
9 use social media that much. So I don't remember
10 seeing any social media about it. I think it was
11 more probably just open your phone and you see
12 the big news articles of the day.
13 Q. Okay.
14 A. I don't recall, specifically.
15 Q. Do you have an Apple iPhone?
16 A. Yes.
17 Q. And so do you use Apple News to see
18 news headlines?
19 A. Yes.
20 Q. Okay. And would following Apple News
21 on your phone be a principal source of
22 information for you at this time in January 2021
23 about potential investments?
24 A. No, I don't think so.
25 Q. Okay. Do you have a computer or a
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2 tablet that you use separately from the Apple
3 iPhone?
4 A. I have a laptop.
5 Q. Okay. And would you generally read
6 news on your phone or on your laptop or both?
7 A. My phone, generally.
8 Q. Alright. And would you use Apple
9 News as the kind of way to see headlines
10 normally?
11 A. Yeah, I think that most of the news
12 that I see is from my Apple News feed now. I
13 don't think -- I think I joined Apple News more
14 recently. I don't think I had it then, Apple
15 News. I don't believe I did.
16 Q. Okay. If you didn't have Apple News
17 in January 2021, do you know how you would go
18 about seeing news articles on your iPhone?
19 A. Not specifically, no.
20 MR. RYAN: Alright. Why don't we
21 take a five-minute break.
22 MR. ROSEN: Okay.
23 MR. RYAN: Probably good point.
24 MR. ROSEN: Five minutes is fine.
25 And we'll look for those social media handles.
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2 You said Twitter and Reddit and then he'll check
3 if he has a TikTok account.
4 THE WITNESS: The Twitter he got.
5 MR. ROSEN: Oh, I'm sorry. It's --
6 THE WITNESS: Reddit.
7 MR. RYAN: I think we were going to
8 look at Reddit, Facebook and TikTok.
9 MR. ROSEN: Oh, Facebook, right.
10 THE VIDEOGRAPHER: Should I go off?
11 MR. RYAN: Let's go off the record
12 please.
13 THE VIDEOGRAPHER: The time on the
14 video monitor is 11:31 a.m. We're off the
15 record. This ends Media 1.
16 (Recess taken 11:31 to 11:42 a.m.)
17 THE VIDEOGRAPHER: We are back on the
18 record. The time on the video monitor is
19 11:42 a.m. This is the start of Media 2.
20 Q. Did you have the opportunity during
21 the break, Mr. Laine-Beveridge, to look for some
22 more social media account names?
23 A. Yeah, it looks like I don't have
24 Facebook. I know I did. It's gone. I never had
25 anything on there. But I don't know when I
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2 deleted it, I think. I got rid of it because I
3 think I told, again, my girlfriend I didn't have
4 Facebook and she saw I had a Facebook, but I
5 didn't use, but now it's like I deleted it and I
6 don't have Facebook anymore.
7 My Reddit is , the same
8 as my old Instagram was. My only posts are about
9 the biking community in New York City.
10 And then TikTok I have nothing
11 posted. But I have it so I can receive TikToks
12 that people send me and it's
13 without spaces or without the
14 dash.
15 Q. Okay. Thank you.
16 A. You're welcome.
17 MR. RYAN: Alright. Let me mark our
18 next exhibit. So Exhibit 271 will be filing with
19 the Court in this case. It's ECF366-3.
20 (There is a discussion off the
21 record.)
22 (Deposition Exhibit 271, Exhibit 2
23 Mr. Laine-Beveridge's Certification dated
24 7/27/21, was marked for identification.)
25 Q. Alright. Do you recognize
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2 Exhibit 271?
3 A. Yes.
4 Q. What is it?
5 A. It's the complaint.
6 MR. ROSEN: Read it. Read it.
7 A. "Blue Laine-Beveridge authorizes The
8 Rosen Law Firm to file an action or amend the
9 current action under the federal securities laws
10 to recover damages and to seek other relief
11 against Robinhood Financial LLC, Robinhood
12 Securities LLC, Robinhood Markets Incorporated
13 and others in connection with the purchase and
14 sale of the affected securities which include
15 American Airlines, AMC, BlackBerry" --
16 MR. ROSEN: Just read it to yourself.
17 THE WITNESS: Okay.
18 MR. ROSEN: Because he asked you what
19 it is, but you have to read it to yourself, to
20 make sure you understand what the document is.
21 So just, you know --
22 THE WITNESS: Okay.
23 MR. ROSEN: -- yeah, take a look at
24 it.
25 A. Okay.
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2 Q. Alright. So do you see Exhibit 271
3 is a certification that's signed by you?
4 A. Yes.
5 Q. And you see in the second paragraph
6 it reads, "Plaintiff declares as to the claims
7 asserted under the federal securities laws that,"
8 and then there's a listings of six numbered
9 paragraphs that follow?
10 A. Yes.
11 Q. And then at the bottom, do you see
12 there is a sentence that reads, "I declare under
13 penalty of perjury under the laws of the United
14 States of America, that the foregoing is true and
15 correct"?
16 A. Yes.
17 Q. Alright. And is that your signature
18 on the bottom right of the second page of
19 Exhibit 271?
20 A. Yes.
21 Q. And is that a signature that you
22 affixed to this document electronically using
23 DocuSign?
24 A. Yes.
25 Q. And did you execute this
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2 certification that we've marked as Exhibit 271 on
3 or about July 27th of 2021?
4 A. Yes.
5 Q. And is one of the paragraphs that you
6 were declaring was true and correct numbered
7 Paragraph 4 regarding the list of the purchases
8 and sale that you made and the affected
9 securities?
10 A. Yes.
11 Q. And are the purchases and sales that
12 you made in the affected securities the one that
13 are shown -- the ones that are shown on Schedule
14 A, which is the third page of Exhibit 271?
15 A. I -- I can't -- don't remember these
16 specific purchases or anything, but it's what we
17 found when we looked at my -- at the activity,
18 yeah.
19 Q. Alright. And so who prepared
20 Schedule A to Exhibit 271?
21 A. The Rosen Law Firm.
22 Q. Alright. And did they prepare it
23 based on information that you gave them?
24 A. Yes.
25 Q. Did you give them your Robinhood
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2 account statements?
3 A. Yes. From what I recall, yes.
4 Q. Did you send them account statements
5 or did you give them electronic access to your
6 Robinhood account? How did you do that?
7 A. I don't recall.
8 Q. Okay. But somehow you gave them
9 access to the information that was in your
10 Robinhood account?
11 A. Yes.
12 Q. Alright. And this lists both
13 purchases and sales of AMC and Nokia stock; is
14 that right?
15 A. Yes.
16 Q. Alright. And you understood at the
17 time in July of 2021 that you were declaring
18 under penalty of perjury that this list of
19 purchases and sales you made was true and
20 correct, right?
21 A. Correct, yes.
22 Q. And did you understand that this
23 certification was going to be filed with the
24 court in this action?
25 A. I can't -- I don't recall it. I
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2 don't -- I -- ask -- what's the question again?
3 Q. Sure.
4 Did you understand at the time that
5 you signed this certification that we've marked
6 as Exhibit 271 that The Rosen Law Firm was going
7 to file the certification with the Court in this
8 lawsuit?
9 A. Yes.
10 Q. And did you understand that the Judge
11 was going to rely on this certification in
12 appointing you as Lead Plaintiff in this action?
13 A. Yes.
14 Q. Now, am I right that there is a total
15 of purchases of AMC shares that total 15,378
16 shares?
17 A. Where is that? Where do you see
18 that?
19 Q. Yeah, so I'm looking -- there are
20 four AMC share purchases listed, right?
21 A. Oh, purchases, yes, okay.
22 Yes, I see them, if you add them up.
23 Q. Right.
24 So there's --
25 A. Okay, I see it them.
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2 Q. -- a purchase on January 20th of 2021
3 of 3,275 shares, right?
4 A. Uh-huh.
5 Q. Correct?
6 A. Yes, I see it.
7 Q. And then there is a second purchase
8 on January 22nd, 2021 of 5,573 shares?
9 A. Uh-huh.
10 Q. Right?
11 A. Yes.
12 Q. The third purchase is on January 27,
13 2021 of exactly 6,000 shares, right?
14 A. Yes.
15 Q. And the final purchase is the same
16 day, January 27, 2021 of 530 shares, right?
17 A. Yes.
18 Q. And if you add up those four share
19 purchase amounts, you agree that you get 15,378
20 shares?
21 A. I mean, I don't have a calculator,
22 but I assume that math looks about right.
23 Q. Okay. And then do you see over in
24 the right-hand side of Page 3 of Exhibit 271,
25 there are three AMC sales listed, right?
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2 A. Yes.
3 Q. There is a sale of 15,000 shares on
4 February 3rd, 2021, right?
5 A. Yes.
6 Q. A sale of 18 shares on June 15, 2021
7 right?
8 A. Yes.
9 Q. And then the third and final sale is
10 of 360 shares also on June 15, 2021, right?
11 A. Yes.
12 Q. Alright. And so here it's maybe even
13 easier to see that if you total up those three
14 shares sale amounts, they total 15,378 shares,
15 right?
16 A. Yes.
17 Q. Alright. And so is it your
18 understanding then that before January 20th, 2021
19 you didn't hold any AMC shares, right?
20 A. Yes.
21 Q. And after June 15th, 2021, you didn't
22 hold any AMC shares either, right?
23 A. Yes.
24 Q. Alright. And so you bought the
25 15,378 shares in the second half of January 2021
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2 and by June 15th of 2021 you had sold them all,
3 right?
4 A. Yes.
5 Q. Now, we spoke earlier about how the
6 COVID pandemic hit in March of 2020, right?
7 A. Yes.
8 Q. And you stopped working at New York
9 Presbyterian around April of 2020, right?
10 A. No, I think -- no, it must have been
11 2021, because I worked through COVID. So, no, I
12 didn't -- I didn't leave -- if COVID was in
13 March, I didn't leave in April.
14 Q. Okay.
15 A. I worked through COVID. So I don't
16 remember when I left, but it was after COVID had,
17 you know, died down. I think it may have been
18 April 2021 that I worked in the hospital until.
19 MR. RYAN: Okay. Why don't we mark
20 another document as Exhibit 272.
21 (There is a discussion off the
22 record.)
23 A. If you want, I can check my phone and
24 I can tell you the month that I did. Because I
25 know I had little bit of a retirement party. So
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2 I can find the pictures from that and tell you
3 when it was.
4 Q. Okay. I may take you up on that.
5 Let me show you this first.
6 This will be Exhibit 272.
7 (Deposition Exhibit 272, a copy of
8 Mr. Laine-Beveridge's résumé P00001064 marked
9 Confidential, was marked for identification.)
10 MR. RYAN: And, for the record,
11 Exhibit 272 is a document with the Bates No.
12 P 1064.
13 Do you recognize this exhibit?
14 A. Yes.
15 Q. What is it?
16 A. My résumé.
17 Q. Alright. And do you see that this
18 indicates that you began work at New York
19 Presbyterian in October of 2011 and left in
20 April 2020?
21 A. Well, I worked -- I started in 20 --
22 2005, October 20th, 2005 on the bottom at the
23 psychiatric clinic.
24 Q. Got it.
25 A. And then I worked until when I left.
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2 I don't -- COVID was it March when it started? I
3 thought it was earlier.
4 Q. So sorry. So -- and I may have
5 inadvertently confused you.
6 By "started," I mean, sort of the
7 COVID shutdown when COVID became really bad and
8 people --
9 A. It was March.
10 Q. -- stopped going into work. That was
11 March of 2020. The first news reports out of
12 China were December 2020.
13 A. Okay. I'll have to look at it.
14 Q. Excuse me, December 2019.
15 A. So I know I worked through the brunt
16 of all COVID. April sounds too early, but I have
17 to check.
18 Q. Okay. Let me focus in on
19 January 2021.
20 A. Sure.
21 Q. At the time you bought AMC and Nokia
22 shares, do you believe you were still working at
23 New York Presbyterian?
24 A. I don't think I was -- I don't know.
25 I don't know.
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2 MR. ROSEN: Do you want him to check
3 his phone?
4 MR. RYAN: Yeah.
5 MR. ROSEN: This way he can answer.
6 MR. RYAN: Yes.
7 Q. I appreciate that.
8 A. Yeah.
9 So I have on there April. Let me
10 see.
11 (The Witness searches through his
12 phone.)
13 So it wasn't April, because I'm
14 seeing pictures from July at the hospital at
15 work.
16 Sorry. I have a lot of photos.
17 I'm not -- October -- what -- my mom
18 might know. It's sounds embarrassing, but she
19 might remember better than me.
20 Do you want me to call her?
21 MR. ROSEN: At a break maybe.
22 Q. Yeah, (INAUDIBLE).
23 MR. ROSEN: But you said, at least,
24 till July.
25 A. Well, now I'm at November and I still
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2 think --
3 Q. November 2020?
4 A. Yeah.
5 Q. Okay.
6 A. I think I'm still there, because I
7 don't see any pictures of the party.
8 Q. Alright. Well, if you're already up
9 to that, let's just move forward a little bit
10 than that, right, because what I'm really
11 interested in is the January to February 2021
12 time frame.
13 A. Okay, got it. Let's see.
14 Okay. December...
15 I worked Christmas day of 2020.
16 MR. ROSEN: Is it possible that it
17 was April 2021 and you just got a typo on the --
18 THE WITNESS: It might be.
19 A. So I've got 83,000 photos in my
20 phone. It's crazy.
21 (There is a discussion off the
22 record.)
23 A. Alright. Here is February 23rd and
24 there's a little cake and, I think, that's the
25 cake they gave me when I was leaving.
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2 Okay. So I took a lot of pictures.
3 I think it was -- my last day was February 23rd.
4 Q. Got it.
5 MR. ROSEN: 2021?
6 A. Yeah, that was my last day at work
7 because all these pictures of co-workers;
8 February 23rd, 2021.
9 Q. Okay, thank you.
10 A. Yup.
11 Q. Alright. So, at the time you bought
12 the AMC and Nokia stock at the end of
13 January 2021, you were still working at New York
14 Presbyterian?
15 A. Yes.
16 Q. Alright. Thank you. I appreciate
17 that clarification.
18 A. Okay.
19 Q. Alright. So now let me ask you again
20 about AMC, right.
21 So around March of 2020 is when the
22 COVID shutdown happens.
23 A. Uh-huh.
24 Q. And I assume you understood in 2020
25 that that affected AMC's business negatively,
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2 right?
3 A. Yes.
4 Q. And were you already at that time a
5 member of the AMC stubs A list?
6 A. I don't recall when I joined. I'm
7 not sure if it was -- if they even had it then,
8 yeah.
9 Q. Okay. Is there a particular AMC
10 theater that you would regularly go to?
11 A. I have three favorites. My favorite
12 is Lincoln Square at 68th and Broadway. They've
13 got the big Imax theater.
14 Q. I've been there.
15 A. Yeah.
16 And my second favorite is 34th
17 between Eighth and Ninth.
18 And my third favorite is the 42nd
19 Street.
20 Q. Okay. And so, you knew, I assume
21 from your firsthand experience that after things
22 shut down for COVID in 2020, there weren't a lot
23 of people going in person to AMC Movie Theaters,
24 right?
25 A. They were shut down for a while. You
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2 couldn't go at all, yeah.
3 Q. Alright. And so your first purchase
4 of AMC shares is January 20th, 2021, right?
5 A. Uh-huh. Yes.
6 Q. Okay. So that's a little over ten
7 months after the COVID shutdown.
8 So what happens on January 20th, 2021
9 that leads you to decide to buy AMC stock?
10 A. I don't recall, exactly. I don't
11 know if any memory of anything specific that made
12 me buy it on that day. I just know that I had
13 been thinking about it for a long time and just
14 seemed very -- I think -- I remember thinking
15 that it seemed low and then I believe people are
16 going to start, you know, going to the movies
17 again.
18 Q. Do you remember reading any news
19 about any developments at AMC in January 2021?
20 A. No.
21 Q. I think I asked this question
22 generally before, but let me just make sure I ask
23 it, specifically.
24 In January 2021, did you read any SEC
25 filings by AMC?
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2 A. No.
3 Q. Any AMC news releases?
4 A. No.
5 Q. Any AMC financial statements?
6 A. I think I vaguely remember something
7 about them staying -- like, they said we're not
8 going to -- we're not going to go bankrupt or
9 something, like, we're going to stay -- stay
10 alive. And I remember being happy about that.
11 Q. Okay. So you heard that AMC made an
12 announcement that they believed that they were
13 not going to go bankrupt?
14 A. Yup.
15 Q. And that made you happy just as an
16 AMC customer?
17 A. Yeah. And because I had been
18 thinking about buying the stock. I thought
19 that's a good sign that maybe it's not so risky.
20 I think when I bought it, I felt like enough time
21 had passed that if they were going to go
22 bankrupt, they would have.
23 Q. Alright. Is it possible that it was
24 January 25th, 2021 when the AMC CEO said that any
25 talk of an imminent bankruptcy is off the table?
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2 A. That's possible. I don't remember
3 dates.
4 Q. Sure.
5 And really what I'm trying to ask you
6 is whether you know whether your first purchases
7 of AMC stock on January 20th and January 22nd,
8 2021 preceded the statement that you're recalling
9 by the AMC CEO that he didn't believe AMC was
10 going to go bankrupt?
11 A. I can't be sure.
12 Q. Okay. So, as you sit here, you're
13 not sure which came first, that statement by AMC
14 about not going bankrupt or your first purchase
15 of AMC stock?
16 A. I can't be sure. You know, I would
17 assume it was after, but I can't be sure.
18 Q. Alright. Why don't we look at a
19 Newsweek article from January 27th, 2021. So
20 this will be Exhibit 273.
21 (Deposition Exhibit 273, Newsweek
22 article titled, "How the SaveAMC Campaign Caused
23 the Movie Theater Company's Stock to Soar," was
24 marked for identification.)
25 Q. Alright. And so do you see that
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2 Exhibit 273 is an article entitled, "How the
3 SaveAMC Campaign Caused the Movie Theater
4 Company's Stock to Soar"?
5 A. Yes.
6 Q. And then you see there is a
7 photograph of a deserted AMC Theater with some
8 geese in an empty parking lot?
9 A. Yes.
10 Q. And underneath that there is a
11 sentence that reads, "It all started with a
12 message posted to Reddit's R/Wall Street Bets
13 community on Tuesday in which a user shared a
14 detailed list of reasons to encourage people to
15 invest in AMC Entertainment Holdings Inc."?
16 A. Yes.
17 Q. Do you recall reading about this post
18 to Reddit's Wall Street Bets community about
19 reasons for people to invest in AMC?
20 A. I don't recall doing that, no.
21 Q. Okay. And then if you turn to the
22 top of the third page of Exhibit 273, do you see
23 the text at the top of the page reads, "Anyone
24 who has been on social media the last couple of
25 days has likely, at least, seen mentions of the
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2 Wall Street Bets community. Members were
3 responsible for making 'AMC to the moon' a
4 rallying cry across various platforms, which led
5 to the creation of humorous memes such as an
6 astronaut happening upon an AMC Theater on the
7 moon"?
8 A. Uh-huh, yes.
9 Q. Do you recall hearing at this time in
10 January 2021 about the "AMC to the moon" meme?
11 A. Not specifically. I don't remember,
12 no.
13 Q. Okay. Do you recall reading news
14 articles like this Newsweek article we've marked
15 as Exhibit 273 about how there was this social
16 media activity and there were a lot of people on
17 Reddit and other forums talking about "AMC to the
18 moon"?
19 MR. ROSEN: Back in 2021?
20 MR. RYAN: Yes.
21 A. I remember after everything happened,
22 I thought, wow, like, this is affecting me. I
23 just bought this stuff.
24 And, of course, I can't say with
25 certainty that -- because I had been thinking
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2 about purchasing Nokia and AMC for a while that I
3 saw it somewhere, the name -- there were -- you
4 know, and maybe that made me think about it
5 again.
6 But when I bought them, I wasn't
7 looking at any of these Reddit campaigns and, you
8 know, any kind of short squeeze intention. I
9 just thought these are the stocks that I've been
10 thinking about getting for a while.
11 And, yeah, of course, it's possible
12 that -- I don't know if they were like, if they
13 -- if there was articles. I don't think -- I
14 don't believe that I -- cause I'm not active on
15 social media. Reddit is just for biking stuff
16 for me.
17 So I can't say with certainty.
18 Because I don't remember. But I certainly wasn't
19 thinking, oh, let me get on the short squeeze.
20 It was just -- I've been thinking about these
21 stocks for a while. I looked at the prices
22 again, bought them. And then when everything
23 blew up, I remember reading the article and
24 thought, whoa, this is what I just got.
25 Q. Right.
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2 So what, I guess, I'm trying to
3 understand is -- we're on January 20th, 2021.
4 It's little over ten months after the COVID
5 shutdown. And you've been, I guess, thinking
6 about buying AMC thinking that it's undervalued,
7 right?
8 A. Uh-huh.
9 Q. Something must have happened that
10 leads you to make that first buy of AMC shares.
11 And I guess that's what I'm trying to figure out,
12 right, because all the time has gone by since the
13 COVID shutdown when you haven't bought AMC and so
14 something must happen that leads you to make that
15 purchase.
16 A. I don't recall anything that
17 happened. Honestly, the way I am, I feel like if
18 I had seen these things, I wouldn't have done it.
19 Because I don't -- I think when things are big
20 like that, they don't work. I opposed felt it
21 like the way I did the airlines and cruises when
22 everyone told me not to do it.
23 Like, I remember -- I remember
24 hearing about GameStop and thinking, no way,
25 these things don't -- there's not -- there is no
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2 easy money. You can't read an article and listen
3 to something and make money. It doesn't work --
4 it's always too late at that point.
5 So knowing me, if I had seen these
6 things, I wouldn't have done it. I wouldn't have
7 bought those stocks.
8 Q. Alright. And so what I think you
9 just explained is that in 2020 when you bought
10 the airline cruise line company stocks, you were
11 going against conventional wisdom, right?
12 A. Yes.
13 Q. And then, I think, you explained that
14 when you heard about GameStop in January 2021,
15 you didn't think it was a good idea to jump on
16 that bandwagon, right?
17 A. I never even considered it. But I
18 remember thinking that everyone just thinks they
19 can buy GameStop and have inconsistent articles
20 about it. I doubt that would work. And I don't
21 make investments like that.
22 Q. Okay. And so it's your view then
23 that people who bought AMC and Nokia stock in
24 January 2021 just because there were a lot of
25 social media posts and articles talking about
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2 those stocks, that that's not likely a good
3 investment strategy either?
4 MR. ROSEN: Objection, calls for
5 speculation.
6 But you can answer.
7 A. Yeah, I personally I would -- if a
8 friend came to me and said, hey, look, I read
9 this thing about Reddit about this stuff, I would
10 probably say, it's probably not going to work. I
11 could be wrong. But I would say, I wouldn't take
12 that risk.
13 Because I remember when this
14 happened, I was thinking, whoa, this is crazy,
15 because I just bought these things and now
16 they're some of the stocks that were buy button
17 was turned off and sell button was left on and
18 feeling frustrated by it.
19 Q. Alright. So, in your view, buying
20 stocks because there is a social media fad isn't
21 generally a good idea, right?
22 A. Yes.
23 Q. And your testimony then is that you
24 bought the AMC and Nokia stock in January 2021
25 not knowing that there was this social media
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2 discussion?
3 A. Yes.
4 Q. And so it's your testimony that it's
5 not that you bought AMC and Nokia because of the
6 social media discussion, it's you bought those
7 stocks for different reasons, not knowing that
8 there was this social media discussion out there?
9 A. Yes.
10 Q. Do you know whether are a lot of
11 members of the proposed class who bought AMC and
12 Nokia stock because of the social media
13 discussion?
14 MR. ROSEN: Objection, calls for
15 speculation.
16 A. I'm not sure. I would assume that
17 some of them did buy it for this reason, yeah.
18 Q. So, based on the articles that you've
19 read now, you would agree that there were a lot
20 of folks in January 2021 who were buying AMC and
21 Nokia stock because of this social media
22 speculation, right?
23 MR. ROSEN: Same objection.
24 A. I would assume there was some
25 purchases for that reason looking at this. I
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2 mean, it's -- of course. I mean, it's the way
3 it's spelled out for you, right. Like, people
4 did that so...
5 Q. Right.
6 And, therefore, it stands for reason
7 that there would be a lot of members of the
8 proposed class who bought AMC and Nokia because
9 of this social media discussion, right?
10 A. I don't know. It's possible.
11 Q. Okay. But, if there are proposed
12 members of the class who bought AMC and Nokia
13 stock in January 2021 because of social media
14 discussion, they were following a different
15 investment strategy from you, right?
16 A. Yes.
17 Q. Alright. So now if we look again at
18 this certification, Exhibit 271. I don't know if
19 you still have that in front of you, Mr.
20 Laine-Beveridge.
21 MR. ROSEN: The one that says
22 Exhibit 2 on it.
23 A. Yes.
24 Q. Okay. So, if we look at Schedule A,
25 which was the third page of the exhibit.
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2 A. Uh-huh.
3 Q. So we see here that when you first
4 bought AMC shares on January 20th, the price was
5 $3.05, right?
6 A. Yes.
7 Q. And then when you bought some more
8 shares of AMC on January 22nd, 2021, the price
9 was $3.58, right?
10 A. Yes.
11 Q. Alright. And then we see that when
12 you bought 6,000 more shares of AMC on
13 January 27th, the price was now $15.89, right?
14 A. Yes.
15 Q. So the price had gone up,
16 approximately, fivefold in just five days from
17 January 27 [sic] to January 27, 2021, right?
18 A. Yes.
19 Q. Okay. So why then did you think it
20 was a good idea on January 27th to purchase 6,000
21 more shares of AMC, even though the shares had
22 just gone up fivefold over the five previous
23 days?
24 A. It's a good question. I'm not sure.
25 I don't remember, specifically, why I did that.
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2 But it doesn't seem like my usual investment
3 strategy.
4 Q. Isn't the reason that you made the
5 purchase of additional AMC shares on January 27,
6 2021 because you knew about the social media
7 fueled momentum for AMC stock?
8 A. I don't know for certain.
9 Q. Okay.
10 A. I -- I don't -- most likely I heard
11 about it at that point, but I can't -- I don't
12 remember, specifically, thinking that's why I'm
13 doing it or anything like that.
14 Q. Okay. So you're not ruling out the
15 possibility that when you bought these additional
16 AMC shares on January 27th, 2021 you knew about
17 the social media fueled momentum for AMC, right?
18 A. No, I'm not ruling that out. But I
19 don't remember, you know.
20 Q. Okay. When you bought AMC stock on
21 January 20th and January 22ne, 2021, did you
22 expect it to go up in price fivefold within less
23 than a week?
24 A. No. I remember being very surprised
25 by the timing and, you know, the increase in
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2 price.
3 Q. Okay. So I guess what I'm trying to
4 figure out is, right, you buy this AMC stock. It
5 goes up more than fivefold in a week and your
6 reaction isn't to sell the stock and make a lot
7 of profit, your reaction is to buy a whole lot
8 more stock.
9 So I'm trying to understand why
10 that's the way you reacted on January 27, 2021 to
11 this dramatic price increase in AMC stock price.
12 A. Yeah, I don't remember, exactly. But
13 at that point it stands to reason that I thought
14 it was going to go up further. It seemed to just
15 be in takeoff mode. And, yeah, it's definitely
16 not my usual strategy, but I did it at that time.
17 Q. What do you mean by "takeoff mode"?
18 A. It would seem like a, you know, like
19 crypto stock at that point, which is doing really
20 well.
21 I don't remember buying this
22 purchase. But I can only assume that I thought
23 it would go up further. That's why I bought it
24 and bought more.
25 Q. So do you believe that when you made
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2 the additional purchases of AMC stock on
3 January 27th, 2021, you thought the stock had
4 momentum?
5 A. Yes.
6 Q. Okay. So you made a reference
7 earlier to a statement you recall at some point
8 in time from AMC that they didn't think that they
9 were going to go bankrupt, right?
10 A. (No response.)
11 Q. Do you recall learning anything else
12 about the company in January 2021 that influenced
13 your decision to buy AMC shares?
14 A. No. And now I'm thinking.
15 Did you mention before that the
16 article by AMC that they weren't going to go
17 bankrupt until the 25th?
18 Q. I believe there was a statement by
19 the AMC CEO that was reported in the press on
20 January 25th about his belief the company would
21 not go bankrupt, yes?
22 A. So that may have influenced why I
23 purchased the extra shares on the 27th.
24 Q. Okay. But you don't recall sort of
25 actually going through that thought process at
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2 the time, do you?
3 A. No. I don't remember detailed dates.
4 I remember I liked AMC. I bought it and then it
5 was all the sudden this big stock in the news.
6 And I remember hearing that it wasn't going to go
7 bankrupt and I remember feeling guilty because I
8 had never purchased it before and, you know, I
9 just felt confident when I finally decided to do
10 it that it was -- you know, I was hoping to have
11 another cruise line/airline experience with it.
12 Q. Okay. Do you recall when you bought
13 these additional shares of AMC on January 27,
14 2021 for 15 or $18 a share, do you recall kicking
15 yourself for not buying more AMC stock the week
16 before?
17 A. I must have. I don't recall it, but
18 I probably did, you know.
19 Q. Alright. And so, if you were still
20 working at New York Presbyterian Hospital at this
21 time, right, because we talked earlier about how
22 your last day was February 23rd, 2021, do you
23 recall talking about this experience of buying
24 AMC stock and then seeing it go up fivefold
25 within a few days? Do you recall talking about
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2 that experience with Alex or Jesse or Brandon or
3 any of your other colleagues at New York
4 Presbyterian?
5 A. I don't recall discussing it with
6 them, no.
7 Q. Did you e-mail or text anybody like
8 friends or family about this experience you were
9 having about AMC stock rocketing up so
10 dramatically?
11 A. I don't recall. I may have talked to
12 my brother and told him or something, but nothing
13 specific.
14 Q. Okay.
15 A. I think I do remember at work talking
16 about GameStop and I think I remember telling
17 them that I didn't think that was a good idea.
18 Q. Okay.
19 A. But I remember not -- I was -- I
20 didn't really know much about it. They just --
21 but I remember hearing something about GameStop
22 and I said, I wouldn't recommend it or something.
23 Q. Okay. And so is the reason that you
24 were leery about GameStop you just thought that
25 there was a lot of people talking about it and
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2 the stock price had gone up and so anybody who
3 would be getting in later would already be
4 getting in too late; is that the reason?
5 MR. ROSEN: Objection.
6 A. I don't have any specific
7 recollection. But, generally, it's just once
8 things -- once something is talked about -- like
9 same with the crypto craze. When crypto was --
10 once everyone -- once it's in the boom cycle, I
11 feel like it's too late.
12 Q. Yeah.
13 A. You got to buy it when nobody is
14 buying it and I know they said the same about
15 GameStop.
16 Q. Okay. And so, for an investment
17 where there is a lot of momentum like this, the
18 people who are going to make money are going to
19 be the people who get in on the ground floor,
20 right?
21 A. Yes.
22 Q. And so were you hoping that when your
23 purchases of AMC and Nokia stock in January of
24 2021 that you would be getting in early enough
25 that you would be able to make a lot of money?
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2 A. I don't know about "a lot," but it
3 just seemed low and I just had this feeling that
4 it could go up.
5 Q. Alright. And at this time between
6 January 20th and January 27th of 2021, was it
7 your feeling that it was already too late to get
8 into GameStop because it had already been talked
9 about so much?
10 A. I don't remember. I don't remember
11 anything about like the time periods or if it was
12 talked about before this happened or after. I
13 really don't remember.
14 Q. Okay. Is that generally, though, how
15 you would think about a momentum driven stock
16 like GameStop or a crypto investment, that if
17 it's been talked about a lot and it's risen up a
18 lot in price, then it's probably too late to jump
19 in?
20 A. Yeah.
21 Q. Now, let me ask about Nokia, right.
22 So you spoke earlier about how your
23 mother's Finnish, right?
24 A. (No response.)
25 Q. And so you had a certain affinity for
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2 Nokia that way, right?
3 A. Uh-huh.
4 Q. Are there any other reasons that you
5 bought Nokia stock, other than that it's a
6 Finnish company?
7 A. Not that I recall, specifically, no.
8 Q. And so my question, I guess, again,
9 is going to be about January 27th, 2021, right.
10 You, obviously, knew about Nokia and
11 about the fact that it's Finnish for years,
12 right?
13 A. Yeah, of course, yeah.
14 Q. So what happens that that day on
15 January 27, 2021 that leads you to pull the
16 trigger and buy Nokia stock?
17 A. I don't recall. But looking at the
18 dates now, it's funny I thought that I bought
19 them at the same time. But I'm seeing here that
20 Nokia I purchased on the 27th.
21 To the best of my recollection, I
22 bought Nokia because I always wanted to buy it
23 and it's a Finnish company. By looking at these
24 dates I don't know if I had heard about Nokia
25 somewhere and it might have spurned me to, you
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2 know, reconsider buying it.
3 Q. Okay. So you think that it's
4 possible that you saw something in the news on
5 January 27th, 2021 about Nokia stock price going
6 up and that's what led you to buy it?
7 A. It's possible, of course. And -- but
8 I do know that I remember thinking that it was
9 still low in value when I bought it. But, yeah,
10 I don't have any specific recollection of looking
11 at something and thinking, this is why I'm going
12 to buy it.
13 Q. Alright. At this time in
14 January 2021, when you bought stocks on
15 Robinhood, would you generally buy them on your
16 iPhone using the Robinhood app?
17 A. Yes, usually, I would use the phone,
18 uh-huh.
19 Q. Okay. Do you remember what time you
20 got off work at this time in January 2021, right?
21 So this is the month before your last work month
22 at New York Presbyterian like what shift?
23 A. So my shifts start at 7:30 a.m. until
24 8 p.m. And then I'd usually leave the hospital
25 at around 8:30 on average. If I'm lucky, I'd get
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2 out at eight. If there were tough patients, then
3 we would get out at nine.
4 Q. Long shift.
5 A. Yeah.
6 Q. Okay. Alright. Let me show you --
7 MR. RYAN: Let's mark Tab 6, Robert.
8 (Deposition Exhibit 274, collection
9 of AMC and Nokia trading data from Mr.
10 Laine-Beveridge's Robinhood account
11 RHMDL00097433.001 through RHMDL00097433.097
12 marked Confidential, was marked for
13 identification.)
14 MR. RYAN: Alright. So Exhibit 274
15 will be a collection of AMC and Nokia trading
16 data from Mr. Laine-Beveridge's Robinhood account
17 that has the Bates No. RHMDL00097433.001 through
18 .097.
19 MR. ROSEN: Thank you.
20 Q. So I can represent to you, Mr.
21 Laine-Beveridge, that what this is is information
22 that we pulled from our client's database at
23 Robinhood about the buys and sells in your
24 account with the account number that's shown in
25 the left-hand column here for AMC and Nokia and
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2 it has timestamps that show when you placed the
3 various orders, okay?
4 A. Okay.
5 Q. And so you see this very first order
6 on January 20th, 2021 for AMC stock looking at
7 the column in the middle of the page where it
8 says, "order created at UTC."
9 And do you see that says 20:22?
10 A. Yes.
11 Q. And some seconds?
12 A. Yes.
13 Q. Alright. And so my understanding is
14 that that's in universal time or Greenwich Mean
15 Time. And so what that means is 3:22 in the
16 afternoon New York Time.
17 MR. ROSEN: So you subtract?
18 MR. RYAN: Subtract five hours.
19 A. Okay.
20 Q. Okay. And so my question, I guess,
21 is, based on your practice when you would use the
22 Robinhood app, is it that you're not working that
23 day, right?
24 Obviously, you've got very long
25 shifts. So I'm not sure you're working every day
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2 then, right?
3 Is it a day that you're not working
4 or would you like go on the Robinhood app when
5 you're in the break room at work? How did that
6 work?
7 A. I work three days a week. Actually,
8 no, at that time I was part-time. So I only
9 worked two days a week. It's possible I could
10 have checked my Robinhood app at work.
11 Q. Okay.
12 A. If it was only the two days I was
13 working that week, yeah.
14 Q. Were there days of the week that you
15 regularly worked at that time?
16 A. No. It was -- it was self-scheduling
17 and I would try to work Monday through Friday --
18 or Friday through Monday. I worked Friday,
19 Saturday, Sunday, Monday, four days in a row and
20 then I'd be off for ten days. I would work
21 another four days and be off for ten days,
22 because those were my -- Friday and Saturday were
23 the two days that one week and then Sunday Monday
24 were the two days -- two days of the following
25 week. The weeks switched between Saturday and
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2 Sunday.
3 Q. Yeah, got it.
4 Okay. Alright. And then you see --
5 and I'm, again, on this very first row here in
6 Exhibit 274.
7 Do you see that this is described as
8 a limit order?
9 A. Yes.
10 Q. With an order price of $3.08?
11 A. Yes.
12 Q. And then you see over in the
13 right-hand column there is an execution price of
14 3 dollars and 4.91 cents?
15 A. Yes.
16 Q. And does that refresh your
17 recollection that the way you made this buy order
18 is that you were placing a buy order at a price
19 up to $3.08?
20 A. Yeah, I see that, yes.
21 Q. Alright. And then Robinhood ended up
22 getting you an execution price that was a bit
23 better than that, that was a little bit less than
24 3 cents a share more favorable than your limit
25 order price, right?
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2 A. Yes.
3 Q. Have you ever traded in AMC options?
4 A. No, not that I can recall, no.
5 Q. How about Nokia options?
6 A. Not that I can recall.
7 Q. Have you ever traded in options for
8 any stock?
9 A. I don't know what an "option" is.
10 So, if I did it, it's weird because I don't know
11 what it is, yeah.
12 Q. Okay.
13 Alright. Do you recall that
14 January 28th, 2021 was the day when Robinhood
15 imposed purchase restrictions on certain stocks
16 before the market opened that day?
17 A. I don't recall like a specific -- I
18 don't recall a moment where I -- I don't remember
19 a moment right now where this is the moment that
20 they turned everything off.
21 Yeah, I have a pretty bad memory in
22 general about the past.
23 Q. Do you recall that there was a lot of
24 news coverage that day that Robinhood had imposed
25 these certain purchase restrictions?
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2 A. Again, I can't say for certain that
3 day. I know that there was a lot of stuff within
4 the days afterward. I don't remember if I
5 remember anything that day or when I -- when I
6 heard about it. But I know there was a lot of
7 news coverage.
8 Q. Do you remember that Robinhood sent
9 you a notification on your phone that day that
10 informed you about the Robinhood purchase
11 restrictions?
12 A. I don't recall that.
13 Q. Okay. I take it you don't deny that
14 you got a notification from Robinhood on your
15 phone of that type, do you?
16 A. No.
17 Q. Alright. At some point whether it
18 was that day or shortly thereafter, you agree
19 that you read a lot of news coverage about the
20 Robinhood purchase restrictions, right?
21 A. I don't know if I can say I read "a
22 lot." I don't know if it was even that day or
23 the next day. I don't -- I may have just not
24 been paying attention for a couple days and
25 learned about it a few days after that. Like, I
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2 don't know what day it was. But it had to have
3 -- I had to have learned about it at some point
4 within the next few days at some point, yeah.
5 Q. Okay. And the first sale that you
6 make of any these shares that you bought in AMC
7 and Nokia, according to exhibit 271, was a sale
8 of 15,000 AMC shares on February 3rd, 2021.
9 Do you see that?
10 A. Yes.
11 Q. Alright. And so, if I represent to
12 you that it was on the morning of January 28th
13 that Robinhood put the purchase restrictions in
14 place, you would agree that you knew about those
15 already by the time you sold your AMC shares on
16 February 3rd, 2021, right?
17 A. Yes.
18 Q. Alright. And you sold those shares
19 at a price of $8.34, right?
20 A. Yes.
21 Q. And then you held onto 378 shares of
22 AMC, right?
23 A. Yes.
24 Q. Why?
25 A. I don't recall. I guess I just
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2 didn't want to give up the whole idea. I mean,
3 it seems like a small amount to keep, right. I
4 have no recollection of why I did that.
5 Q. Okay. And you held those 378 shares
6 of AMC until June 15, 2021, right?
7 A. Yes.
8 Q. When you sold them for,
9 approximately, $59 a share, right?
10 A. Yes.
11 Q. Alright. Now, isn't it the case that
12 on the AMC purchases and sales that are shown on
13 Page 3 of Exhibit 271, you made money?
14 A. Yes. Well, I didn't even realize it
15 went up that much.
16 Q. Okay. Alright. So you agree that on
17 the AMC shares that you bought between
18 January 20th and January 27th of 2021, in total,
19 looking at all three of the sales you made, 2 on
20 February 3rd and 2 of them on June 15, 2021,
21 overall you made money our AMC investment, right?
22 MR. ROSEN: Objection, calls for a
23 legal conclusion and expert testimony.
24 A. You're asking if overall I made or
25 lost money on AMC?
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2 Q. Right.
3 A. Let's see. I bought it at three,
4 bought more on 15.
5 I don't know, because I bought 6,000
6 shares at $15 and sold 15,000 shares at $8. So I
7 don't know. I haven't done the math. But, I
8 mean, I definitely lost a lot of money on those
9 that I bought for the 6,000 shares I bought for
10 15 and sold most of that for $8.
11 Q. Okay. But you've got no reason to
12 disagree with me that if we did the math here, if
13 for all of your AMC purchases and sales that are
14 shown on Page 3 of Exhibit 271, if we multiplied
15 out the number of shares by the price, you've got
16 no reason to disagree with me that overall the
17 money you got from the sales is more than the
18 money that you spent on the purchases, right?
19 A. No, there is no reason to say that's
20 not possible.
21 Q. Okay. Alright. And I'll represent
22 to you that that's what this math, in fact,
23 shows.
24 A. Okay. Okay.
25 Q. That you made money on the sales
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2 compared to your purchase price in AMC.
3 Do you have an understanding based on
4 that fact whether you are a member of the
5 proposed class with respect to your investments
6 in AMC?
7 A. Ask -- what was the question again?
8 Q. Right.
9 So assuming that my math is right --
10 A. Yeah.
11 Q. -- and that you made money on your
12 AMC sale, do you have an understanding whether
13 you are a member of the proposed class with
14 respect to your investments in AMC?
15 MR. ROSEN: Objection, calls for a
16 legal conclusion.
17 But you can answer the question.
18 A. I think because during that period I
19 lost money. I'm still a member. During the five
20 days after they turned the buy button off, I'm
21 still a member. I lost money in that period.
22 Q. So you're now saying if we look only
23 at your sale on February 3rd, 2021 and if we
24 ignore the sales on June 15th, 2021 you believe
25 you lost money on the February 3rd sale alone?
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2 A. Well, I did, right, if you look at
3 the numbers, yeah.
4 Q. Okay.
5 A. And looking at where it went, this is
6 why this is so frustrating. Because I wouldn't
7 have sold if they didn't turn the buy button off
8 and it went up to $60, which is very frustrating.
9 But that's why we're here.
10 Q. On February 3rd, Robinhood -- or by
11 February 3rd, 2021, Robinhood had turned the buy
12 button back on for AMC, right?
13 A. I'm not sure when they turned it back
14 on. I don't know which day exactly.
15 Q. Okay. So you don't know whether the
16 buy button was back on on February 3rd, 2021 on
17 the Robinhood app for AMC stock; is that right?
18 A. Well, it was off for five days. 28
19 -- how many days in January?
20 So, no, I don't remember,
21 specifically, having a recollection of that time.
22 Q. Okay. I'm just trying to make sure I
23 understand what your understanding of the facts
24 of the case is.
25 A. Let's see.
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2 Q. Your understanding of the facts of
3 the case it appears is that --
4 A. Yeah, no.
5 Q. -- the buy button was turned off for
6 the whole time --
7 A. When I sold -- when I sold the first
8 AMC, the buy button was still off and the sell
9 button was still on. So it was still going down
10 in value.
11 Q. Okay. So is it your understanding of
12 the facts of this case that for the five trading
13 day class period, which I can represent to you is
14 January 28th, 2021 through February 4th, 2021,
15 it's your understanding that the buy button was
16 off at Robinhood for that entire period, right?
17 A. Yeah. When I first made the big
18 sell, it was still off.
19 Q. Okay. And so would it surprise you
20 to learn that, in fact, Robinhood had turned the
21 buy button back on for AMC stock by February 3rd,
22 2021?
23 MR. ROSEN: Objection. It's not
24 accurate. I mean, they had multiple
25 restrictions.
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2 MR. RYAN: Don't make speaking
3 objections.
4 MR. ROSEN: But it's not accurate.
5 A. Yeah, I'm not --
6 MR. RYAN: I believe it is accurate.
7 A. I remember there was like bogus stuff
8 where they would let you buy one share or five
9 shares, which is totally -- it might as well be
10 20. It was total scam to try and get people to
11 -- to try to act like they weren't restricting I
12 mean. If you can buy five shares, that's as good
13 as no shares.
14 Q. Alright. So you do understand that
15 there was a period in time when Robinhood turned
16 the buy button back on and had a share purchase
17 restriction that said there is certain number of
18 shares that somebody could buy?
19 A. Yeah, a laughably small amount that
20 wasn't anything that anybody could really invest
21 with.
22 Q. Alright. And so do you understand
23 whether by February 3rd, 2021 Robinhood had in
24 fact turned the buy button back on and replaced
25 it with a share purchase limitation of the type
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2 that we just discussed?
3 A. Yeah, I personally wouldn't call it
4 turning the buy button back on. I would say the
5 buy button was still off, but they allowed you to
6 buy a few shares. That's how I would word it.
7 Q. Okay. So what happened on
8 February 3rd, 2021 that led you to sell 15,000
9 AMC shares, right? Because I'm asking you didn't
10 sell on January 28th or in any of the subsequent
11 days when you knew that the buy button was turned
12 off.
13 Why is it that on February 3rd you
14 made the decision to sell 15,000 AMC shares?
15 A. I guess I just probably saw it. I
16 was afraid it was going to go even lower and I
17 thought that they were going to continue to
18 manipulation things and crash the price. I
19 didn't trust that they would, you know, fix it.
20 So I sold.
21 Q. Okay. And if you held those 15,000
22 AMC shares until June 2021, you would have made a
23 lot of money, right?
24 A. Yup.
25 Q. When you made the sale decision of
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2 the 15,000 AMC shares on February 3rd, 2021, did
3 you have any new information about AMC's
4 business?
5 A. Not that I recall.
6 Q. Had you read any company earnings
7 releases or SEC filings?
8 A. No, not that I recall.
9 Q. Had you read any analyst reports
10 about AMC leading up to your February 3rd, 2021
11 sale of 15,000 shares?
12 A. Not that I recall.
13 Q. Alright. And is it your
14 understanding that you're a member of the
15 proposed class as it relates to your transactions
16 in AMC because one of your sales was during the
17 proposed class period, namely, your February 3rd,
18 2021 sale?
19 A. Yes.
20 Q. Okay. So, for Nokia, do you agree
21 that you did not have any sales during the
22 proposed class period?
23 A. Yes.
24 Q. And so is it your understanding then
25 that you are not a member of the proposed class
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2 as it relates to Nokia?
3 A. I'm not sure. I'm not -- I'm not
4 totally sure about that.
5 Q. Okay. So, as you sit here today,
6 you're uncertain one way or the other as to
7 whether you are a member of the proposed class as
8 it relates to your transactions in Nokia; is that
9 right?
10 A. I thought I -- I thought my Nokia
11 transactions were relevant. But I'm not sure
12 because if the class period is only five days and
13 I didn't sell it until the 22nd. I don't know.
14 Q. Alright. Your first sale of Nokia
15 sales was on February 22nd, 2021, right?
16 A. Yes.
17 Q. Okay. Now, did you at some point
18 execute a new certification?
19 A. You mean like Exhibit 2? A new one
20 like that you mean?
21 Q. Yes. And by "Exhibit 2," you're
22 referring to what we marked in this deposition as
23 Exhibit 271 that says in big bold letters on the
24 front page "Exhibit 2," correct?
25 A. Yes.
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2 Q. So I'm asking did you at any point in
3 time execute a certification that in its form is
4 very similar to the certification that we've
5 marked at Exhibit 271 in this deposition?
6 A. I don't recall, exactly.
7 MR. RYAN: Alright. Let me mark the
8 next document as Exhibit 275.
9 And this, for the record, will be
10 documents with Bates No. P 2834 through 59.
11 (Deposition Exhibit 275, Mr.
12 Laine-Beveridge's Certification dated 4/14/23
13 P00002834 to P00002859, was marked for
14 identification.)
15 MR. ROSEN: Thank you.
16 This is 275?
17 MR. RYAN: Yes.
18 Q. Do you recognize Exhibit 275, Mr.
19 Laine-Beveridge?
20 A. Yes.
21 Q. And is this a document that is
22 headed, "Certification," on the first page?
23 A. Yes.
24 Q. And that similar to the Certification
25 we were looking at before in Exhibit 271 begins
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2 with the word, "Blue Laine-Beveridge, the
3 Plaintiff, authorizes The Rosen Law Firm, P.A.,
4 to file an action or amend a current action under
5 the federal securities laws to recover damages
6 and to seek other relief against Robinhood
7 Financial LLC, Robinhood Securities LLC,
8 Robinhood markets Inc.," and others in connection
9 with the purchase or sale of one or more of the
10 nine stocks listed?
11 A. Yes.
12 Q. And like the Certification that we
13 were looking at in Exhibit 271, the Certification
14 in Exhibit 275 reads, "Plaintiff declares as to
15 the claims asserted under the federal securities
16 laws," and then has six numbered paragraphs,
17 right?
18 A. Yes.
19 Q. And like the Certification we looked
20 at in Exhibit 271, the Certification in
21 Exhibit 275 states that you "declare under
22 penalty of perjury under the laws of the United
23 States of America that the foregoing is true and
24 correct," right?
25 A. Yes.
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2 Q. And is that your signature in the
3 bottom right at the first page of Exhibit 275?
4 A. Yes.
5 Q. And is that a signature that you
6 affixed electronically by DocuSign?
7 A. Yes.
8 Q. And did you sign this Certification
9 in Exhibit 275 on or about April 14th, 2023?
10 A. Yes.
11 Q. Why did you execute a revised
12 Certification? Well, strike that.
13 Why did you execute the new
14 Certification that we've marked as Exhibit 275?
15 A. I believe the lawyers missed some of
16 the transactions initially and they amended it,
17 from what I recall.
18 Q. Okay. And is that something that
19 somebody from The Rosen Law Firm told you?
20 A. Yes.
21 Q. In your understanding, was your
22 Certification in Exhibit 271 an error?
23 MR. ROSEN: Well, what -- you mean
24 the list of transactions; is that what you're
25 talking about?
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2 MR. RYAN: No. Let me ask -- it's
3 very simple question.
4 Q. When you executed Exhibit 275 --
5 A. Uh-huh.
6 Q. -- did you believe that there was
7 anything wrong with Exhibit 271?
8 A. I think they added transactions. I
9 don't know if I call it an "error." But they
10 missed some of them, initially.
11 Q. Alright. So it's your understanding
12 that in preparing Exhibit 271, your lawyers from
13 The Rosen Law Firm missed certain transactions
14 that they then added to the version of the
15 Certification in Exhibit 275?
16 A. I'm not sure exactly, but, yes,
17 something was changed, like, there was some
18 transactions that they -- yes, you can use the
19 word "missed."
20 Q. Alright. If you look at Exhibit 275,
21 do you see that all the transactions listed are
22 in AMC?
23 A. Without looking at every page
24 individually, yeah, it looks like it.
25 Q. Alright. So there are no longer any
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2 transactions in Nokia stock listed in the
3 Schedule A that's attached to Exhibit 275 when
4 there were in the certification attached to
5 Exhibit 271, right?
6 A. Yes. I guess that's because they
7 were outside of the class period --
8 Q. Okay.
9 A. -- like the Nokia ones.
10 Q. Alright. And so, when you executed
11 the Certification marked as Exhibit 275, were you
12 aware that your transactions in Nokia stock had
13 been removed?
14 A. At the time, yeah, I do. I'm
15 recalling now that that was one of the issues is
16 that I didn't lose money on Nokia during the
17 class period.
18 Q. Okay. And so now that you've seen
19 the Certification in Exhibit 275, does that lead
20 you to revise your previous response that you
21 don't know one way or the other whether you're
22 member of the proposed class as it relates to
23 your transactions in the Nokia stock?
24 A. Yes.
25 Q. Okay. Do you now agree that you are
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2 not a member of the proposed class as it relates
3 to your transactions in Nokia stock?
4 A. Yes.
5 Q. Alright. And we talked before about
6 how you knew that Exhibit 271 was filed with the
7 Court, right?
8 A. Yes.
9 Q. And that you knew that the Judge in
10 this action had relied upon your Certification
11 marked as Exhibit 271 in appointing you as Lead
12 Plaintiff right?
13 A. Yes.
14 Q. Okay. Are you aware that your
15 Certification marked as Exhibit 275 has not been
16 filed with the Court in this action?
17 A. No, I'm not aware.
18 Q. Okay. Are you surprised to learn
19 that your Counsel has not filed your
20 Certification marked as Exhibit 275 with the
21 Court in this action?
22 A. No.
23 Q. Why are you not surprised by that?
24 A. Because I don't know the system and
25 the timing of things and I trust my law firms to
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2 be doing well on my behalf, you know.
3 Q. So let's look back at your
4 Certification marked as Exhibit 271.
5 You sign here under a sentence that
6 reads, "I declare under penalty of perjury under
7 the laws of the United States of America that the
8 foregoing is true and correct," right?
9 A. Yes.
10 Q. Do you still believe the contents of
11 the Certification in Exhibit 271 are true and
12 correct?
13 A. Shall I read them again, all six?
14 Q. Sure.
15 A. I'm not sure. Let me see.
16 Well, let's see. No. 4 the following
17 is a list of all the purchases and sales
18 Plaintiff has made in affected securities during
19 the class period set forth in -- I guess, you can
20 say that those Nokia transactions that aren't
21 part of the affected securities, because they're
22 outside the class window.
23 Q. Okay. So do you now believe that the
24 statement in Paragraph 4 of the Certification
25 we've marked as Exhibit 271 to this deposition is
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2 not true and correct?
3 MR. ROSEN: Well, hold on a second.
4 Hold on a second.
5 You have to be fair to him. Because
6 he does not have the complaint that this first
7 Certification refers to. The class period in
8 that first complaint is different than the class
9 period in the subsequent complaint.
10 So I don't recall exactly what that
11 class period is. But, you know, to show him the
12 second complaint and compare the current class
13 period to the first class period is not fair.
14 MR. RYAN: I've not shown the witness
15 any complaints.
16 MR. ROSEN: Well --
17 A. Yeah, so I'm not certain at this
18 point what the class period was. I'm not sure
19 what I believe the class period was on July of
20 2021. It doesn't say here what the class period
21 was. So I can't say for certain I knew what the
22 class period was at that time.
23 Q. Alright. So I think what you're
24 saying is, as you sit here today, you don't know
25 one way or the other whether the Certification
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2 we've marked as Exhibit 271 to this deposition
3 was true and correct as of the day you signed it
4 right?
5 A. I believed it was on the day I signed
6 it.
7 MR. ROSEN: And objection because he
8 did testify as to corrections for some shares
9 that were not included that were added. He
10 testified to that.
11 MR. RYAN: Right. That wasn't part
12 of my question.
13 MR. ROSEN: Yeah.
14 Q. So let me ask you.
15 Is it the case, as you sit here
16 today, you don't know one way or the other
17 whether the Certification we marked as 271 --
18 A. Uh-huh.
19 Q. -- was true and correct on July 27,
20 2021?
21 A. Without knowing what the class period
22 was at the time, I can't say with certainty. I
23 know that I believe that these all fell under the
24 class period when I signed it.
25 Q. Okay. So it's your understanding
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2 today that the proposed class period currently in
3 the case is -- strike that.
4 It's your understanding today that
5 the proposed class currently in the case is
6 people who sold one or more of the nine stocks at
7 issue during the five-day proposed class period
8 and lost money, right?
9 A. Yes.
10 Q. And so do you agree that at a minimum
11 the Certification that you signed in July 2021
12 that we've marked as Exhibit 271 is not correct
13 under the current class definition?
14 A. Under the current class, no, Nokia
15 would not fall as -- it would not be labeled as
16 an affected security during this current class
17 period.
18 Q. Okay. And so you're aware as we
19 talked about before, that the Judge relied upon
20 your Certification marked as Exhibit 271 in
21 appointing you Lead Plaintiff, right?
22 A. Well --
23 MR. ROSEN: Objection, calls for
24 speculation.
25 A. Yeah, I don't know enough about this,
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2 how this works to say yes to that.
3 Q. Alright. You did say "yes" earlier,
4 right?
5 So, before I had show you
6 Exhibit 275 --
7 MR. ROSEN: Well, if he already said
8 "yes" already, why did you ask him a second time?
9 MR. RYAN: Please don't interrupt me.
10 Q. Before I showed you that you had
11 changed your Certification --
12 A. Okay.
13 Q. -- you agreed that you knew the Judge
14 had relied on your initial Certification in
15 appointing you Lead Plaintiff, right?
16 A. I don't even remember that. But,
17 okay, yeah, if I said -- if I said, yes, then I
18 said, yes.
19 Q. Okay. Don't you think the Judge
20 should know that you have changed your
21 Certification relating to your transactions in
22 these stocks?
23 A. Well, I assume the Judge would know
24 at some point.
25 Q. Okay. So you agree that this
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2 Certification that we've marked as Exhibit 275 to
3 this deposition should be brought to the Judge's
4 attention, right?
5 MR. ROSEN: And, for the record, it
6 will be -- well, let him answer.
7 MR. RYAN: You do not need to make
8 speaking objections.
9 MR. ROSEN: No, I just want to put on
10 the record.
11 A. Of course, at some point the Judge
12 should know the class period.
13 Q. Right.
14 MR. ROSEN: Okay. So, for the
15 record, it's going be filed with the class
16 certification motion. That's the plan. That's
17 why we gave it to you in plain -- with enough
18 advance time so you can question him on it and it
19 would be filed with the class certification
20 motion. That's the plan.
21 Q. Alright. So Exhibit 275, this
22 Certification from April 14, 2023, instead of
23 simply listing three AMC shares the way we saw in
24 your certification in Exhibit 2021 [sic], lists
25 many dozens; Exhibit 271.
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2 A. What do you mean "three"? You mean
3 sales?
4 Q. Yeah, so let me do this more slowly.
5 A. Oh, I see sales, okay.
6 Q. So do you see that in Exhibit 271
7 there were three sales of AMC stock listed?
8 A. Yes.
9 Q. And now you've got -- there must be
10 hundreds listed in --
11 A. Yes.
12 Q. -- Exhibit 275, right?
13 A. Yes.
14 Q. Why is that?
15 A. I don't know. I think that's the way
16 Robinhood processes their sales. I don't know.
17 I guess that's the way Robinhood showed when we
18 requested a transcript of all the transactions.
19 Q. Okay. So do you believe that the
20 sales shown in your initial Certification in
21 Exhibit 271 are wrong?
22 A. I don't know. I'm assuming Robinhood
23 provided both of these.
24 Q. Robinhood had nothing to do with
25 either 271 or 275, sir. These are documents that
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2 you signed that come from you and your Counsel.
3 Robinhood played no role in creating these
4 documents.
5 MR. ROSEN: So what's your question?
6 Q. So my question is, do you know why in
7 your initial Certification there are three sales
8 of AMC stock listed and in your revised
9 Certification, Exhibit 275, there are hundreds of
10 sales of AMC stock listed?
11 MR. ROSEN: Take a moment and look.
12 Q. Do you know why?
13 MR. ROSEN: Take a moment and look at
14 the document and see if you could figure out why
15 there's a difference.
16 A. Well, I'm assuming if you add all
17 these up, it's going to equal the same amount of
18 shares. And if you add all these prices up and
19 divide it by the same amount of shares, it's
20 going to equal this -- the average $8.34.
21 These are all 15,000 shares sold on
22 the 3rd. If you add all these shares up, I
23 assume it equals 15,000 -- or 14,977 and the
24 average price of them all was 8.34. I think I
25 just hit sell all of them and Robinhood executes
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2 it like this. So this is the same. This is just
3 the average of them.
4 Q. And so why did you change the way
5 that you were presenting this February 3rd, 2021
6 sale of AMC stock between the initial
7 Certification in Exhibit 271 and the new
8 Certification in Exhibit 275?
9 A. Just to be more exact. This is
10 exactly how Robinhood processed the transactions.
11 Q. Okay.
12 A. And it looks like we overcounted by 3
13 shares initially or 23 shares.
14 THE STENOGRAPHER: I'm sorry, 23
15 shares or 3 shares?
16 A. Well, the initial shares were 15,000
17 and now it's -- with the new one it's 14,977. So
18 this is 23 less shares.
19 Q. Okay. So let me just make sure I'm
20 following you.
21 So I believe you're looking at the
22 second page of the new Certification in
23 Exhibit 275. And you're looking in the purchase
24 column where it reads, "AMC minimum opening
25 position 14,977 shares"?
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2 A. I see. This is purchase.
3 Okay. So, you know, I'm looking at
4 this wrong. This is the purchase.
5 So this might -- you told me the
6 number before when we added these purchases up.
7 Q. 15,378, yes.
8 MR. ROSEN: Well, not all were sold
9 during the class period. 15,000 were sold during
10 the class period. These sales are just class
11 period sales, from what I understand. So --
12 MR. RYAN: Please stop making
13 speaking objections. It's also inaccurate.
14 MR. ROSEN: I just don't want you to
15 misrepresent what the document shows.
16 MR. RYAN: I'm not misrepresenting
17 anything. Let Mr. --
18 Q. We'll do this again very slowly.
19 Page 2 of your new Certification
20 Exhibit 275 --
21 A. Uh-huh.
22 Q. -- in the purchase column --
23 A. Yes.
24 Q. -- it reads, "AMC minimum opening
25 position 14,977 shares," right?
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2 A. Yes.
3 Q. Alright. And you noted that that is
4 23 fewer shares than your sale of 15,000 shares
5 on February 3rd, 2021, right?
6 A. That's 23 less. But I was looking at
7 -- I'm not -- I thought this was sales. When I
8 look -- first looked at Page 2 of 275, I read
9 that as sales. And I only saw here that the
10 sales are 15,000. Cause these are on this date
11 -- I thought that this 275 was all February 3rd.
12 So I just thought that there was a discrepancy
13 between those two numbers.
14 Q. Alright. It is a fact, isn't it,
15 that at the end of the day on January 27, 2021,
16 you held 15,378 AMC shares?
17 A. Yes, on the -- at the end of the day
18 on the 27th, yes.
19 Q. Okay. Why then in your new
20 Certification marked as 275, why then don't you
21 tell the Court that your opening position was
22 15,378 shares?
23 A. What is this when it says, "AMC
24 minimum opening position"?
25 Q. This is your Certification, sir. You
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2 signed this. All I can do is read the words.
3 A. I can't say with certainty. I know
4 that the lawyers told me they had to change some
5 of the transactions and I trusted them.
6 Q. Okay. But you would agree that, in
7 fact, your opening position when the class period
8 began was 15,378 AMC shares, right?
9 A. According to this document, yes.
10 Q. And by "this document," you're now
11 referring to your initial Certification,
12 Exhibit 271, right?
13 A. Yes, yes.
14 Q. Okay. And you don't know why your
15 new Certification, Exhibit 275, states "AMC
16 minimum opening position 14,977 shares," right?
17 A. What was the first number, 15,000
18 what?
19 Q. 15,378.
20 A. No, I don't know for certain why
21 that's different.
22 Q. Okay.
23 Alright. Go down --
24 A. Wait, 15,378 and...
25 Q. 15,378 is the number of AMC shares
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2 that you held at the end of the day on
3 January 27, 2021 --
4 A. (INAUDIBLE DUE TO CROSS-TALK.)
5 Q. -- according to your initial
6 Certification marked as Exhibit 271.
7 A. Yeah, I don't know exactly why it's
8 different.
9 Q. Okay.
10 Alright. And despite the fact that
11 Exhibit 275 no longer shows your sales of AMC
12 shares from June of 2021, you still agree with me
13 that if we look at all of your purchases and
14 sales of AMC shares, you made money overall,
15 right?
16 MR. ROSEN: Objection.
17 A. I would have to do the math myself.
18 I -- I'm sure it's possible.
19 Q. Alright. So, I guess, we'll do that
20 in just a second here.
21 But if I'm understanding right,
22 you're sitting here as the Lead Plaintiff in this
23 case. You acknowledge now that you're no longer
24 a member of the class as it relates to your Nokia
25 transactions, right?
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2 A. Yes.
3 Q. So you agree that the only so-called
4 affected stock that could make you a member of
5 the class is AMC, right?
6 A. Yes.
7 Q. Yet you don't know whether you made
8 or lost money overall on your AMC transaction; is
9 that right?
10 MR. ROSEN: Objection, calls for a
11 legal conclusion.
12 A. Well, I thought that the class period
13 was if you lost money during the class period,
14 which I did lose money. So I don't know why the
15 overall is relevant.
16 Q. Right. So that's a question for the
17 Judge to rule on eventually.
18 I'm simply asking a factual question.
19 Am I right --
20 MR. ROSEN: He answered the question.
21 MR. RYAN: Well, I'll ask the
22 question again.
23 MR. ROSEN: You didn't like the
24 answer, but he answered it.
25 MR. RYAN: No.
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2 Q. My question is this.
3 Am I right that, as you sit here
4 today, you do not know one way or the other
5 whether you made or lost money overall on your
6 transactions in AMC shares?
7 A. Yes, I'm not certain if overall -- if
8 all my transactions on Robinhood with AMC, if I
9 made or lost money I'm not sure.
10 Q. Okay.
11 (There is a discussion off the
12 record.)
13 Q. Did you conduct a search of your
14 e-mails to see whether you had any e-mails about
15 AMC or Nokia or Robinhood?
16 A. Yes.
17 Q. And is that a search that you
18 personally conducted?
19 A. Yes.
20 Q. And did you find any e-mails about
21 AMC, Nokia or Robinhood?
22 A. I got some Robinhood general e-mails
23 in my account or something from Robinhood. But,
24 no, nothing else.
25 Q. Okay. And did you conduct a search
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2 of text on your phone to see whether you had any
3 text about AMC or Nokia or Robinhood?
4 A. Yes.
5 Q. And is that a search that you also
6 conducted personally?
7 A. Yes.
8 Q. And did you find any text about AMC
9 or Nokia or Robinhood?
10 A. No.
11 MR. RYAN: Alright. Why don't we go
12 off the record for a minute because the tape is
13 ending.
14 THE VIDEOGRAPHER: Yes, thanks.
15 The time is the video monitor is
16 1:18 p.m. We are off the record. This ends
17 Media 2.
18 (Recess taken 1:18 to 1:32 p.m.)
19 THE VIDEOGRAPHER: We are back on the
20 record. The time on the video monitor is
21 1:32 p.m. This is the start of Media 3.
22 Q. Alright. So I've got more questions
23 about the scheduled transactions on your original
24 Certification, Exhibit 271, okay?
25 A. Okay.
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2 Q. Alright. So we talked before about
3 the fact that you don't know whether there was a
4 loss or gain overall on the AMC transactions
5 shown here in Exhibit 271. So I want to try to
6 nail that down.
7 A. Okay.
8 Q. So do you have a calculator on your
9 phone?
10 A. Yup.
11 Q. Alright. So the first purchase --
12 MR. ROSEN: He's not going to do
13 calculations for you. He's not going to do
14 calculations for you.
15 MR. RYAN: Well --
16 MR. ROSEN: Ask him questions.
17 Put your phone away.
18 He's not going to do calculations.
19 He was nice enough to go searching through his
20 phone to find out the precise date he left. But
21 he's not going to go through his phone and
22 calculate stuff for you.
23 You've got an Excel spreadsheet. You
24 can do it. In fact, your client made the trades.
25 So don't ask him to calculate numbers.
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2 MR. RYAN: So what I'm entitled to
3 know is whether there was a loss or a gain
4 overall of sales --
5 MR. ROSEN: Look, you can do
6 calculations. But he's not going to break out a
7 calculator and you're not going to check his
8 arithmetic, you know, while he's being
9 videotaped. I just don't -- you know, that's --
10 you're allowed to ask questions. You can ask
11 questions and he will answer them.
12 MR. RYAN: Are you willing to
13 stipulate that there is an overall gain on the
14 AMC transactions shown here?
15 MR. ROSEN: You and I can talk
16 afterwards and we'll break out a spreadsheet and
17 we can do the arithmetic and it says -- you know,
18 I mean, it's going to be obvious whatever it is.
19 But I don't think that it's appropriate to have
20 him do calculations.
21 BY MR. RYAN:
22 Q. Well, let me ask you these questions
23 then, sir.
24 The first purchase shown here is of
25 3,275 shares at a price of $3.05 per share,
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2 right?
3 A. Yes.
4 Q. And you believe that that's correct,
5 right?
6 A. Yes. This is what they told me so,
7 yes.
8 Q. And the second purchase -- I'm sorry.
9 By they you mean The Rosen Law Firm
10 Counsel?
11 A. Robinhood -- Robinhood gave me this
12 information and the law firm compiled the data.
13 Q. Alright. So -- and you signed this
14 based on the compilation that your Counsel put
15 together for you, right?
16 A. Yes.
17 Q. Alright. So, based on the
18 compilation that your Counsel put together, you
19 believe it's correct that your first purchase of
20 AMC shares on January 20, 2021 was a purchase of
21 3,275 shares at $3.05 a share, right?
22 A. Yes.
23 Q. And you believe it's correct that
24 your second purchase on January 22nd, 2021 was a
25 5,573 shares at a price of $3.58 a share?
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2 A. Yes. Yes.
3 Q. Alright. And you believe that it's
4 correct that your third purchase on January 27th,
5 2021 was a purchase of 6,000 AMC shares at a
6 price of $15.89 per share, right?
7 A. Yes, but this is the newer
8 transaction sheet, right, on 275? I assume
9 you're going by this one.
10 Q. I'm asking you about Exhibit 271.
11 I'm asking you whether you believe today that the
12 information on Exhibit 271 is correct. And I've
13 asked you so far about the first three
14 transactions and I believe you told me that you
15 still believe today that that is true and
16 correct.
17 Am I understanding you right or am I
18 misunderstanding you?
19 A. If you really want me to give you an
20 answer, I have to log into Robinhood and look at
21 it all myself because this is what the law firm
22 compiled and I don't want to say yes to find out
23 they missed something and then I'm committing
24 perjury.
25 If you want me to log into Robinhood
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2 and do all the numbers myself -- I can't do it
3 right now -- I'll do that.
4 When I was given this, I admit that I
5 didn't go into Robinhood and add up every single
6 thing. I assumed that this was an accurate
7 compilation of data.
8 Q. So let me try to understand.
9 A. And I believe it's very -- it's very
10 close to accurate.
11 Q. I have two certifications from you,
12 sir, Exhibit 271 and 275. They are both signed
13 under penalty of perjury where you stated that
14 the information was true and correct, right?
15 A. Yes.
16 Q. And am I understanding you right now
17 that you are unwilling to tell me under oath
18 today whether the information --
19 MR. ROSEN: Objection.
20 Q. -- that you simply don't know?
21 MR. ROSEN: Objection. Don't speak
22 to him like that. You are not going -- you are
23 not going to speak to him like that. Are you
24 clear? Are you clear?
25 MR. RYAN: Stop yelling at me. I
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2 asked a very simple question.
3 MR. ROSEN: You are not going to
4 speak to him like that.
5 MR. RYAN: Your tone of voice is
6 completely uncalled for.
7 MR. ROSEN: I am upset with the way
8 you are speaking and harassing my client. You've
9 been on this for about an hour. We corrected the
10 Certification form. It's being filed with the
11 Court. Don't harass him, alright?
12 Now, ask a proper question.
13 MR. RYAN: My questions are entirely
14 "proper." And I would like you to refrain from
15 yelling at me.
16 Q. My question, sir, is, can you answer
17 today whether the information in Exhibit 271 is
18 true and correct?
19 MR. ROSEN: Asked and answered.
20 A. My answer is if you give me time to
21 log in and do this -- I did not do the math
22 myself when I looked at these. They looked to be
23 correct and I trusted my attorneys to compile the
24 data properly. And I think that's very
25 reasonable.
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2 Q. Okay. So are you telling me without
3 logging into your Robinhood account, you can't
4 tell me one way or the other today whether the
5 information in Exhibit 271 is true and correct?
6 MR. ROSEN: Objection, asked and
7 answered many times.
8 A. Yeah, I've answered it many times. I
9 can't say without absolute certainty that these
10 are all -- all these numbers are perfectly
11 correct, because I did not log into Robinhood
12 when I got this and do all the math myself. It
13 looked very accurate overall.
14 Q. Are you able to tell me today under
15 oath whether the information for your four
16 purchases of AMC shares in Exhibit 271 is
17 generally true and correct?
18 A. Yeah, generally true and correct,
19 yes.
20 Q. So you believe that this information
21 about the four purchases is generally true and
22 correct, right?
23 A. Yes.
24 Q. Alright. And so let me ask you
25 again, because the record is now confused.
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2 You believe today that your first
3 purchase on January 20th was of 3,275 shares for
4 $3.05 a share, right?
5 A. Well, again, you're being very
6 specific and I don't know if that's exactly. In
7 general, I believe, I made this -- around this
8 many purchases for these prices on these dates
9 and I'm sure it's very close to accurate. I
10 believe that there was some small error and they
11 amended it, from my understanding. And that's my
12 answer.
13 Q. The new Certification, Exhibit 275,
14 has no information about purchases, right?
15 A. Yes.
16 Q. And instead has a statement, "AMC
17 minimum opening position 14,977 shares," that you
18 can't explain, right?
19 A. What do you mean, I can't explain?
20 Q. Well, I asked you before whether you
21 knew why it said that and you told me you didn't.
22 Do you recall that?
23 A. Yes. But if you give me time with
24 Robinhood, I could probably look up the numbers
25 myself and explain it.
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2 Q. Alright. As you sit here today --
3 A. Yeah.
4 Q. -- you can't explain why your new
5 Certification, Exhibit 275, states "AMC minimum
6 opening position 14,977 shares," right?
7 A. I can explain it. I think that my
8 lawyers who are representing me looked at the
9 data and came up with this number.
10 Q. Okay. And you agree that that number
11 is wrong, right?
12 MR. ROSEN: No.
13 A. No.
14 MR. ROSEN: He didn't say that.
15 A. I didn't say it was wrong.
16 MR. ROSEN: Why are you putting words
17 in his mouth?
18 Q. Do you agree -- do you agree then
19 that you held 15,378 shares at the beginning of
20 the proposed class period?
21 A. Again, I would need to look at
22 through the Robinhood information, if you want me
23 to give you a perfectly exact answer.
24 Q. Okay. So do you believe that I can
25 rely on Schedule A, the third page of
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2 Exhibit 271, your initial Certification, if I
3 want to understand what your purchases and sales
4 of AMC shares are? Can I rely on this document
5 or not in your view?
6 A. Of 271?
7 Q. Yes.
8 MR. ROSEN: Objection, objection. He
9 gave you an amended one, okay. He gave you an
10 amended Certification, alright. We delivered
11 that to you.
12 And you know exactly what his
13 transactions are. You have every single one of
14 them listed right here in Exhibit 274.
15 MR. RYAN: Please stop. Please stop
16 making these speaking objections.
17 MR. ROSEN: So why are you harassing
18 him? You're harassing him.
19 A. I don't mind. I just think this
20 nitpicking is -- is comical, because it's mostly
21 completely accurate. If they made a small -- you
22 know, if they amended slightly, that's what we're
23 dealing with. And, obviously, you're asking me
24 to be specific about something I can't be
25 completely specific about. And it seems so
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2 silly.
3 Q. Do you believe that I can rely on
4 this information or not that's in Exhibit 271?
5 A. I will say again I would have to log
6 into Robinhood and do all the math myself to say
7 if you can rely on this perfectly.
8 Q. Okay. Do you believe that I can rely
9 on the information that's in Exhibit 275?
10 A. Same answer. I would have to do --
11 look at it myself. Obviously, something doesn't
12 add up perfectly and that's what you're focused
13 on.
14 So, if I had time to look at my
15 Robinhood and spent a long time, I can probably
16 give you the exact answers that, apparently, know
17 you can get yourself, but you're asking me to
18 tell you. And, like, you're implying that I did
19 something purposely to mislead something in this
20 and anyone listening to this knows that that's
21 bullshit.
22 Q. Fine.
23 A. There were -- there were some slight
24 errors, some slight -- you know, they looked at
25 something and they possibly missed and it's very
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2 minor. If you want to focus on that, fine. But
3 that's my answer.
4 Q. Alright. So your understanding is
5 the reason that Exhibit 275 differs from
6 Exhibit 271 is that there were slight errors in
7 271; is that your understanding?
8 A. Yeah, I believe that when they
9 re-looked at the data, they saw something that
10 they missed the first time.
11 Q. Okay. But even after this correction
12 process, you can't tell me that I can rely on
13 275?
14 MR. ROSEN: Objection.
15 A. How can I unless I do the math myself
16 and I look at -- look, this is how Robinhood does
17 it. This is how they supply their information.
18 I have to go with the calculator and go through
19 every single one of these. Do you understand
20 that?
21 Are you asking -- are you asking me
22 have I done that? Because I haven't done that.
23 Q. Okay.
24 A. Is that your question? Have I done
25 it -- have I used a calculator --
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2 Q. No, that wasn't my question.
3 A. Well, it's implied in your question.
4 The only way I can answer
5 definitively is if I use a calculator for every
6 single one of these and done the math myself; is
7 that correct?
8 Q. The reason I ask these questions,
9 sir, was to understand whether you have an
10 overall gain or loss on your transactions in AMC
11 shares. And I was trying to get at that by using
12 your Certifications including the one that was
13 filed with the Court and the one that Mr. Rosen
14 says is going to be filed with the Court.
15 A. But you have Robinhood's data, so you
16 can look at the actual data and tell me. And if
17 you've told me I've overall gained, then I have
18 no reason not to believe you. If you look at
19 Robinhood's data, the actual data, and tell me I
20 made money with AMC, I have no reason to believe
21 you're lying.
22 Q. Okay.
23 A. I also don't see why that's relevant
24 to the case period of a gain or loss during the
25 five days after the buy button was turned off and
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2 sell button was left on.
3 Q. Okay. So I can represent to you that
4 the information that Robinhood has from your
5 account indicates that you made an overall gain
6 in trading in AMC shares.
7 And are you saying you've got no
8 reason to dispute that?
9 A. Yes.
10 Q. Now, you said earlier, I believe,
11 that the reason you sold AMC shares on
12 February 3rd, 2021 was because you believed that
13 Robinhood turning off the buy button had led the
14 shares to decline in price; is that right?
15 A. Yes, that's absolutely correct, yes.
16 Q. Okay. And at that time on
17 February 3rd, 2021, why did you believe that
18 Robinhood turning off the buy button had caused
19 the AMC stock price to decline?
20 A. Because if you can't buy a stock and
21 you can only sell it, it can only go in one
22 direction, which is down. That's the only thing
23 that can happen. It cannot go up, if nobody can
24 buy a stock. So they literally prevented
25 anything from happening except a drop in these
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2 prices.
3 Q. Are you aware of whether people could
4 buy Robinhood's stock with Charles Schwab?
5 A. I don't know for certain. But I
6 believe -- I see your point.
7 Well, yeah, I wasn't -- I'm not -- I
8 think there was some restrictions from other
9 trading platforms but nothing as restrictive as
10 Robinhood.
11 Q. Were you aware on February 3rd
12 whether somebody could buy AMC stock on e-Trade?
13 A. I wasn't sure one way or the other.
14 But I do remember believing that Robinhood's
15 restrictions were the most restrictive.
16 Q. Did you have an understanding as of
17 February 3rd, 2021 that some other brokers had
18 also imposed certain restrictions?
19 A. I can't recall, exactly. But I
20 believe there were restrictions elsewhere.
21 Q. You're only suing Robinhood, right?
22 A. Right.
23 Q. If some other brokers also imposed
24 certain trading restrictions on these stocks
25 including AMC, why are you not suing other
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2 brokers?
3 A. I saw that there was a class action
4 suit against Robinhood and that's the one that I
5 personally invested with. So I -- I chose to
6 join the class action against Robinhood.
7 Q. Do you know whether the trading
8 restrictions that certain other brokers imposed
9 on AMC stock could have influenced the AMC stock
10 price?
11 MR. ROSEN: Calls for expert
12 testimony, objection.
13 A. Any brokerage firm that imposed a
14 restriction in theory could have affected the
15 price. But Robinhood's restrictions, I believe,
16 were by far the most -- the largest reason for
17 the decline in the prices of the stocks.
18 Q. And why is it that you believe that
19 Robinhood's trading restrictions were a larger
20 reason for the decline in price of the stocks
21 than other broker's trading restrictions?
22 A. Because from what I remember reading,
23 their restrictions were much -- they blocked all
24 purchasing and for a much longer period of time.
25 Q. Do you know how many other brokers
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2 imposed trading restrictions on AMC stock in
3 January 2021?
4 A. No.
5 Q. We spoke earlier about how you
6 believed there was a Robinhood statement
7 attributing the trading restrictions to market
8 volatility.
9 And I believe you were saying that
10 it's your understanding that Robinhood, in fact,
11 had liquidity reason for imposing the trading
12 restrictions; is that right?
13 A. Yes.
14 Q. Do you believe that the reason or
15 reasons that Robinhood gave for imposing the
16 trading restrictions affected the price of AMC's
17 stock?
18 A. I don't think the reasons they gave
19 affected it. I think the fact that they turned
20 the button off affected it.
21 Q. Okay. I have no further questions.
22 Thank you.
23 A. You're welcome.
24 MR. ROSEN: Alright. I think we're
25 done.
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2 Thank you.
3 THE VIDEOGRAPHER: Yes. We are going
4 off the record at 1:51 p.m. This ends our
5 deposition for today.
6 (Time noted: 1:50 p.m.)
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