In re January 2021 Short Squeeze Trading — Sandy Ng Plaintiff Certification (Exhibit 61, dated 2023-06-08)
Summary
Exhibit 61 (Document 568-61) in Case 1:21-md-02989-CMA, entered on the FLSD docket June 8, 2023, is a three-page Certification in which Sandy Ng authorizes The Rosen Law Firm to file an action under the federal securities laws against Robinhood Financial, LLC, Robinhood Securities LLC and Robinhood Markets, Inc. over AMC, BBBY, BB, EXPR, GME, KOSS, TR, NOK and TRVG, the Affected Stocks. The Plaintiff states having reviewed a complaint, not having traded at the direction of counsel, and being willing to serve as a lead plaintiff. The attached schedule lists GME transfers, purchases and sales in two accounts dated 1/28/2021 and 2/4/2021, noting that it does not account for the July 22, 2022 4:1 stock split.
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- Date
- 2023-06-08
Cite this document
“In re January 2021 Short Squeeze Trading — Sandy Ng Plaintiff Certification (Exhibit 61).”
Original at archive.org, dated 2023-06-08. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-08-covid-era-misc-1e70b187-1/
, SHA-256 1e70b1871fa74956550c050a13b2c864376979af6236963349822f550cb0a535.Full text
Case 1:21-md-02989-CMA Document 568-61 Entered on FLSD Docket 06/08/2023 Page 1 of 3
Exhibit 61
DocuSign Faye !4P DIP: ACE ZOSTER TIOCUMERtB68-61 Entered on FLSD Docket 06/08/2023 Page 2 of 3
CERTIFICATION
Sandy Ng (the “Plaintiff’) authorizes The Rosen Law Firm, P.A. to file an action or amend
a current action under the federal securities laws to recover damages and to seek other relief against
ROBINHOOD FINANCIAL, LLC, ROBINHOOD SECURITIES LLC, ROBINHOOD
MARKETS, INC. (collectively “RH’’) and others in connection with the purchase and sale of one
or more of the common stock of AMC Entertainment Holdings, Inc. (NYSE: AMC), Bed Bath &
Beyond Inc. (NASDAQ: BBBY), BlackBerry Ltd. (NYSE BB), Express Inc. (NYSE: EXPR),
GameStop Corp. (NYSE: GME), Koss Corp. (NASDAQ: KOSS), Tootsie Roll Industries Inc.
(NYSE: TR), or the American Depositary Shares of foreign-issuers Nokia Corp. (NYSE: NOK)
and Trivago N.V. (NASDAQ: TRVG) (collectively “the Affected Stocks”).
Plaintiff declares, as to the claims asserted under the federal securities laws, that:
1. Plaintiff has reviewed a complaint against RH and retained The Rosen Law Firm,
P.A.
2. Plaintiff did not engage in transactions in the securities that are the subject of this
action at the direction of Plaintiff's counsel or in order to participate in this or any other litigation
under the securities laws of the United States.
3. Plaintiff is willing to serve as a lead plaintiff either individually or as part of a
group. A lead plaintiff is a representative party who acts on behalf of other class members in
directing the action, and whose duties may include testifying at deposition and trial.
4. The following is a list of all of the transactions Plaintiff has made in the Affected
Stocks during the class period set forth in the consolidated complaint:
See Schedule A
5. Plaintiff has not, within the three years preceding the date of this certification,
sought to serve or served as a representative party on behalf ofa class in an action involving alleged
violations of the federal securities laws, except: for the following company(ies):
6. Plaintiff will not accept any payment for serving as a representative party beyond
Plaintiff's pro rata share of any recovery, except reasonable costs and expenses, such as travel
expenses and lost wages directly related to the class representation, as ordered or approved by the
court pursuant to law.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. DocuSigned by:
1/11/2023 San, M
Se 15AE5248C691475...
Sandy Ng
Executed on
DocuSign FayelgPa'P: FE S2OSSE CRIA DaCuMENtB68-61 Entered on FLSD Docket 06/08/2023 Page 3 of 3
SCHEDULE A
SANDY NG
ACCOUNT 1
PURCHASES SALES
DATE SHARES PRICE DATE SHARES _ PRICE
Minimum Transfer
opening GME 2/4/2021 55 Out
position Transfer
75 shares GME 2/4/2021 75 Out
GME 1/28/2021 55 ($264.00)
ACCOUNT 2
PURCHASES SALES
DATE SHARES PRICE DATE SHARES _ PRICE
Minimum GME 2/4/2021 1,633 $56.89
opening
position
1,560
shares
GME 2/4/2021 18 ($78.50)
GME 2/4/2021 55 Transfer In
GME 2/4/2021 75 Transfer In
*Rounded to the nearest cent.
**Does not account for the July 22, 2022 4:1 stock split.
File and source
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- gov.uscourts.flsd.590042.568.61.pdf
- Size
- 178,389 bytes
- SHA-256
- 1e70b1871fa74956550c050a13b2c864376979af6236963349822f550cb0a535
- Original
- archive.org