Exhibit 65: Certification (Dkt. 567-65, S.D. Fla.)
Summary
Exhibit 65 (Document 567-65) in Case 1:21-md-02989-CMA, entered on the FLSD docket June 7, 2023, a three-page DocuSign certification in which Santiago Gil Bohórquez authorizes The Rosen Law Firm to file or amend an action under the federal securities laws against Robinhood Financial, LLC, Robinhood Securities LLC and Robinhood Markets, Inc. over the Affected Stocks, which include AMC Entertainment Holdings, GameStop Corp., Koss Corp., Nokia and Trivago. The Plaintiff declares having reviewed a complaint against RH, not having traded at counsel's direction and being willing to serve as a lead plaintiff. The attached Schedule A lists transactions in the Affected Stocks, including BB, EXPR, NOK and AMC trades dated between 1/28/2021 and 2/1/2021.
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- Date
- 2023-06-07
Cite this document
“Exhibit 65: Certification (Dkt. 567-65).”
Original at archive.org, dated 2023-06-07. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-07-covid-era-misc-f122d087-1/
, SHA-256 f122d087afd4e2b57b844ca41629a5a8ad8b613d81be80e4fff57edb6cac139c.Full text
Case 1:21-md-02989-CMA Document 567-65 Entered on FLSD Docket 06/07/2023 Page 1 of 3
Exhibit 65
DocuSign Envelope ID: 61 AC3732-C1 7D-4558-A525-E42F90F3D1 E8
Case 1:21-md-02989-CMA Document 567-65 Entered on FLSD Docket 06/07/2023 Page 2 of 3
CERTIFICATION
Santiago Gil Bohórquez (the "Plaintiff") authorizes The Rosen Law Firm, P.A. to file an
action or amend acurrent action under the federal securities laws to recover damages and to seek
other relief against ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC,
ROBINHOOD MARKETS, INC. (collectively "RH") and others in connection with the purchase
and sale of one or more of the common stock of AMC Entertainment Holdings, Inc. (NYSE:
AMC), Bed Bath & Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc.
(NYSE: EXPR), GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll
Industries Inc. (NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp.
(NYSE: NOK) and Trivago N.V. (NASDAQ: TRYG) (collectively "the Affected Stocks").
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed acomplaint against RH and retained The Rosen Law Firm,
P.A.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of Plaintiff's counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is arepresentative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is alist of all of the transactions Plaintiff has made in the Affected
Stocks during the class period set forth in the consolidated complaint:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as arepresentative party on behalf of aclass in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as arepresentative party beyond
Plaintiff's pro rata share of any recovery, except reasonable costs and expenses, such as travel
expenses and lost wages directly related to the class representation, as ordered or approved by the
court pursuant to law.
Ideclare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. —DocuSined by
LSait
1
4/17/202 3
Executed on
SANTIAGO GIL BOHORQUEZ
Exhibit
00273
P00002863
DocuSign Envelope ID: 61 AC3732-C1 7D-4558-A525-E42F90F3D1 E8
Case 1:21-md-02989-CMA Document 567-65 Entered on FLSD Docket 06/07/2023 Page 3 of 3
SCHEDULE A
SANTIAGO GIL BOHORQUEZ
PURCHASES SALES
DATE SHARES PRICE DATE SHARES PRICE
AMC AMC 1/28/2021 183 $12.13
minimum AMC 1/28/2021 100 $12.21
opening AMC 1/28/2021 17 $12.38
position AMC 1/29/2021 100 $14.40
400
AMC 1/29/2021 81 $15.10
Shares
AMC 2/1/2021 100 $12.37
BB
AMC 2/2/2021 150 $9.99
minimum
BB 1/28/2021 100 $16.91
opening
position BB 1/29/2021 100 $14.05
200 EXPR 1/28/2021 200 $6.11
shares EXPR 1/29/2021 173 $6.22
EXPR EXPR 1/29/2021 229 $5.60
minimum EXPR 2/1/2021 186 $5.16
opening EXPR 2/1/2021 14 $5.16
position NOK 1/28/2021 200 $4.93
788
shares
NOK
minimum
opening
position
200 ADSs
AMC 1/28/2021 81 ($16.02)
AMC 1/29/2021 100 ($12.81)
AMC. 2/1/2021 150 ($15.20)
EXPR 1/28/2021 14 ($4.88)
*M ayreflect pre- and post-market transactions.
**Roun dedto the nearest cent.
P00002864
File and source
- File
- gov.uscourts.flsd.590042.567.65.pdf
- Size
- 100,818 bytes
- SHA-256
- f122d087afd4e2b57b844ca41629a5a8ad8b613d81be80e4fff57edb6cac139c
- Original
- archive.org