Exhibit 10 (Document 568-10): Videotaped Deposition, William Meade, May 12, 2023 — Case No. 1:21-MD-2989-CMA
Summary
Pages from the videotaped deposition of William Meade, taken by the defendants via Zoom on May 12, 2023 in In re January 2021 Short Squeeze Trading Litigation, Case No. 1:21-MD-2989-CMA, in the U.S. District Court for the Southern District of Florida, entered on the docket June 8, 2023 as Document 568-10 and marked Exhibit 10. Questioned by Ms. Young, Meade explains a January 2021 tweet about Express that he says was a joke, and says that in that period everyone was looking for the next GameStop. He describes traders using "game theory" to predict the next short squeeze stock instead of looking at fundamentals. He calls GME, AMC, Express and Koss volatile and says more people were trading from home during COVID. The 6-page exhibit ends with the deponent's acknowledgement page.
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- Date
- 2023-06-08
Cite this document
“Exhibit 10 (Document 568-10): Videotaped Deposition, William Meade, May 12, 2023 — Case No. 1:21-MD-2989-CMA.”
Original at archive.org, dated 2023-06-08. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-08-covid-era-misc-2b53ea36-1/
, SHA-256 2b53ea361babeb971c4f746688c869a569f1b55380b09b56a61c3f93a91818a2.Full text
Case 1:21-md-02989-CMA Document 568-10 Entered on FLSD Docket 06/08/2023 Page 1 of 6
Exhibit 10
Case 1:21-md-02989-CMA Document 568-10 Entered on FLSD Docket 06/08/2023 Page 2 of 6
Page 1
1
2 IN THE UNITED STATES DISTRICT COURT
3 FOR THE SOUTHERN DISTRICT OF FLORIDA
4 Case No. 1:21-MD-2989-CMA
5 -----------------------------------x
6 IN RE JANUARY 2021 SHORT SQUEEZE
7 TRADING LITIGATION
8 -----------------------------------x
9 May 12, 2023
10 9:37 a.m.
11
12
13 Videotaped Deposition of WILLIAM
14 MEADE, taken by Defendants, pursuant
15 to Notice, held via ZOOM REMOTE,
16 before Erica Ruggieri, a Registered
17 Professional Reporter and Notary
18 Public of the State of New York.
19
20
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Case 1:21-md-02989-CMA Document 568-10 Entered on FLSD Docket 06/08/2023 Page 3 of 6
Page 94 Page 96
1 MEADE 1 MEADE
2 Q. Because that's nearly like 2 Q. And you retweet the same
3 what, seven times or something the 3 January 22nd tweet again but then on
4 $1.30 a share price on January 22nd? 4 the top you write, "$12 now, why not
5 A. Yeah, it says six six. 5 go for the 10 bagger in one week to
6 Q. Something like that? 6 $13 LOL Express"?
7 A. Yeah. 7 A. Yes.
8 Q. Okay. Do you recall any 8 Q. Can you explain what you
9 news about Express around this time 9 meant by that?
10 that you thought might explain that, 10 A. Yeah. More like -- I said
11 you know -- 11 lots of laughs. I was just shocked
12 A. Again, the only news was 12 at how extreme a move it was.
13 that everyone in the trading 13 Q. And so basically even in
14 community and Wall Street was 14 this half hour the price of Express
15 looking for the next GameStop. And 15 had risen from $9 to 12, right?
16 again, there were articles all over 16 A. Correct.
17 the financial press about how to 17 Q. I gather you considered
18 find the next GameStop or here are 18 that a significant increase in that
19 three stocks or five stocks that 19 period of time?
20 could be the next GameStop. Like 20 A. Absolutely.
21 again, it was the trade that 21 Q. Did you believe that any of
22 everyone was looking at for that 22 that increase in the price of
23 period of time. 23 Express around that time could be
24 Q. Looks like you were right 24 attributed to a short squeeze or
25 in your -- from your January 22nd 25 potential short squeeze?
Page 95 Page 97
1 MEADE 1 MEADE
2 one. You predicted correctly that 2 A. I'm not sure, but again, I
3 it did, you know, did rise. 3 think at that -- at that period
4 This is at 10:49 a.m., right? 4 everyone was looking for the next
5 A. Yes. 5 GameStop or stock similar to
6 Q. Okay. Thank you. 6 GameStop and they were buying stocks
7 MS. YOUNG: Megan, can you 7 that were looking for big moves like
8 pull up tab 25. And this will be 8 GameStop.
9 Exhibit 309. 9 Q. What's a 10 bagger?
10 (Exhibit 309, Tweet of William 10 A. A thousand percent.
11 Meade 1/27/2021, marked for 11 Q. Oh, okay. So you are
12 identification, as of this date.) 12 saying it might, you know, why not
13 Q. Do you recognize this 13 go for the thousand percent increase
14 document, Mr. Meade? 14 in one week?
15 A. I do. 15 A. I was joking and you see
16 Q. And this is a tweet of 16 lots of laughs. I was just --
17 yours from January 27, 2021. But it 17 again, I was just shocked at how
18 looks like if you look at the 18 extreme a move it was.
19 specific time underneath it, it's at 19 Q. And did you think that the
20 11:25 a.m. 20 increase in the price of Express
21 A. Okay. 21 reflected the kind of actual value
22 Q. That's like half an hour 22 of the company at that time?
23 after the prior tweet I think. Is 23 A. I have no opinion. I will
24 that right? 24 say that traders don't really look
25 A. Yes. 25 at the value of what a stock is.
25 (Pages 94 - 97)
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Case 1:21-md-02989-CMA Document 568-10 Entered on FLSD Docket 06/08/2023 Page 4 of 6
Page 106 Page 108
1 MEADE 1 MEADE
2 A. He may have been. I don't 2 think this was in the context of us
3 know the answer to that. Sorry. 3 discussing Express but you should
4 Q. That's okay. This is 4 correct me if I'm mistaken, that
5 Exhibit 312. 5 around this time there's some
6 (Exhibit 312, Article, 6 traders that weren't really looking
7 "Billionaire Investor Chamath 7 at the value of certain stocks but
8 Palihapitiya Follows Reddit. 8 more at, I think you used the phrase
9 Investors Into GameStop With 9 "game theory"?
10 Purchase of Bullish Options 10 A. Yes.
11 That Start Paying Out If the Stock 11 Q. What do you mean by game
12 Soars Another 28%", marked for 12 theory in that context?
13 identification, as of this date.) 13 A. Meaning that people were
14 Q. Do you recognize this 14 trying to predict what the next big
15 document, Mr. Meade? 15 short squeeze stock would be like
16 A. I do. 16 GameStop. You know, they are
17 Q. This is the article that 17 looking at companies with similar
18 was linked to your -- in your tweet? 18 business models at GameStop and
19 A. Yes. 19 obviously companies that had a lot
20 Q. Okay. Now, I'm going to 20 of short interest in trying to
21 actually just -- you are welcome to 21 predict or be early in stocks that
22 read the whole article if you want, 22 could turn into the next GameStop.
23 but I'll tell you right now that I'm 23 They weren't necessarily looking at
24 going to ask you specifically about 24 the fundamentals.
25 the top of the fourth page. 25 Q. Got it. And I think that
Page 107 Page 109
1 MEADE 1 MEADE
2 MS. YOUNG: Megan, if you want 2 you called that a trading style
3 to scroll down. 3 maybe that was popular at that time?
4 MS. BRAGANCA: Would you take 4 A. Yes.
5 a minute -- 5 Q. Did you notice that that
6 THE WITNESS: Yeah. 6 was a distinct shift for this
7 Q. No, yeah, take your time. 7 particular point in time?
8 So I was going to ask you 8 A. Yes.
9 specifically about the top of page 4 9 Q. And was that specifically
10 where it states, "Palihapitiya is 10 January 2021?
11 joining a group of retail investors 11 A. I would say December and
12 that have sparked a massive short 12 January, yes.
13 squeeze in the video-game retailer. 13 Q. Got it. And when you say
14 The stock soared as much as 14 that that's sort of game theory, you
15 145 percent in Monday's trading 15 know, or efforts to predict,
16 session on no apparent news." 16 anticipated efforts to predict short
17 My only question on this, 17 squeezes that being sort of
18 Mr. Meade, is whether at this time 18 different from looking at
19 you are aware of reporting in the 19 fundamentals, what do you mean by
20 media that the price of GME 20 fundamentals?
21 increased substantially on no 21 A. Fundamentals would be like
22 apparent news? 22 the price earnings ratio, the
23 A. I am. 23 balance sheet, the cash flow. That
24 Q. Thank you. And earlier I 24 generally, you know, people use that
25 think that you mentioned that -- I 25 to look for, you know, blue chip
28 (Pages 106 - 109)
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Case 1:21-md-02989-CMA Document 568-10 Entered on FLSD Docket 06/08/2023 Page 5 of 6
Page 110 Page 112
1 MEADE 1 MEADE
2 stocks to buy and hold for years. 2 potential short squeezes that we
3 In terms of game theory that traders 3 have been discussing today did you
4 or investors look at, more 4 consider the stocks that we have
5 short-term investors would look at 5 discussed today, so GME, AMC,
6 something like basically trying to 6 Express, Koss, others, to be
7 be, you know, like trying to be the 7 relatively risky investments?
8 right chess or checkers board before 8 MS. BRAGANCA: I'm going to
9 everyone else or basically escape to 9 object to that as being an
10 where the puck is going to go. 10 ambiguous question.
11 Q. What was that last, where 11 MS. YOUNG: I'm sorry, I can't
12 what is going to go? 12 hear you, Lisa. What did you say?
13 A. As a Wayne Gretzky saying 13 MS. BRAGANCA: Objection,
14 you want to skate to where the puck 14 ambiguous. You can answer.
15 is going to be not where it is. 15 A. Sorry, could you repeat the
16 That's sort of exactly what people 16 question?
17 were trying to do, trying to figure 17 Q. Sure. So around this time
18 out what is the next stock that 18 did you consider that the stocks
19 could be the next GameStop or short 19 that we have been discussing today,
20 squeeze stock. 20 would you consider those relatively
21 Q. I see. Could you 21 risky investments?
22 characterize those types of run-ups 22 A. I would consider them
23 from some of these game theory 23 volatile.
24 investors creating a bubble? 24 Q. And volatile because of the
25 A. I would -- I would say that 25 price movements you observed?
Page 111 Page 113
1 MEADE 1 MEADE
2 generally short squeezes are short 2 A. Yeah. The extreme price
3 and extreme. I would not 3 movements.
4 necessarily characterize it as a 4 Q. We have looked at a lot of
5 bubble. 5 your tweets from around this time.
6 Q. Fair enough. 6 You obviously have a lot of
7 Do you recall that -- well, 7 followers. Do you pay attention to
8 withdrawn. That's not a good 8 kind of the amount of engagement
9 question. 9 that, you know, you tweets receive,
10 I think one of the things that 10 like the number of comments or
11 you mentioned earlier is that a 11 retweets or --
12 difficulty in trading is timing your 12 A. I don't. Actually, I
13 trades? 13 closed my comments I think like two
14 A. Yes. At the top, I 14 years ago. I don't have comments
15 mentioned that selling and trading 15 anymore. I think they are mostly
16 is the hardest thing to do. 16 useless. And most times there --
17 Q. Because you are trying to 17 there are a lot of Twitter accounts
18 figure out exactly when the stock 18 that simply you have no idea if they
19 price is going to peak? 19 are telling the truth or not.
20 A. Yes. And stocks usually go 20 Q. Fair enough. I was going
21 higher than people expect and lower 21 to ask if around this time you
22 than people expect so it's really -- 22 noticed maybe more engagement with
23 it's a very, very hard thing to do. 23 your tweets related to investing or
24 Q. And around this time 24 the stock market relative to other
25 because of the short squeezes or 25 points in time?
29 (Pages 110 - 113)
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Case 1:21-md-02989-CMA Document 568-10 Entered on FLSD Docket 06/08/2023 Page 6 of 6
Page 114 Page 116
1 MEADE 1 MEADE
2 A. Yes, absolutely. 2 THE VIDEOGRAPHER: Counsel, if
3 Q. Do you think that's because 3 there's no other stipulations and
4 of a lot of the sort of social media 4 any objections, I'll conclude the
5 enthusiasm about these meme stocks 5 video recording for today's
6 around this time? 6 proceeding. So here ends media
7 A. I think it was a couple 7 unit two.
8 things. I think we were in COVID, a 8 This concludes the video
9 period of COVID and everyone was 9 recorded virtual remote deposition
10 home and trading was one of the 10 of William Meade taken by the
11 things you could do from home and 11 defendant on Friday, May 12, 2023.
12 there were a lot of new traders that 12 The time is 12 noon Central
13 came into the market and you had 13 Daylight Time and we are going off
14 people that were watching the market 14 the record.
15 all day instead of working. Those 15 (Time noted: 12:00 p.m.)
16 are the two big things. More 16
17 participation, more people were 17
18 looking at minutes daily time. And 18
19 then yeah, just in the news, I mean 19
20 you couldn't -- you couldn't miss 20
21 the news. I many every article 21
22 every day from the sources I 22
23 followed was about GameStop, short 23
24 squeezes, et cetera, et cetera. 24
25 Q. So it's just so widely 25
Page 115 Page 117
1 MEADE 1 IN RE JANUARY 2021 SHORT SQUEEZE
2 reported that you think that that TRADING LITIGATION
3 naturally led to people paying more 2 5/12/2023 - WILLIAM MEADE
4 attention to your investment-related 3 ACKNOWLEDGEMENT OF DEPONENT
5 tweets? 4 I, WILLIAM MEADE, do hereby declare
6 A. Absolutely. I think there 5 that I have read the foregoing transcript,
7 was just more engagement on Twitter. 6 I have made any corrections, additions, or
8 I think Twitter -- again, people 7 changes I deemed necessary as noted on the
9 were home and they were engaging on 8 Errata to be appended hereto, and that the
9 same is a true, correct and complete
10 Twitter now instead of being at
10 transcript of the testimony given by me.
11 work.
11
12 Q. Right. Right. Fair
12 _________________________ _______________
13 enough.
13 WILLIAM MEADE Date
14 MS. YOUNG: I think that's
14 *If notary is required
15 probably it for us, Mr. Meade. 15
16 This was very helpful. We really 16 SUBSCRIBED AND SWORN TO BEFORE ME THIS
17 appreciate your time today and I 17 ______ DAY OF ________________, 20___.
18 hope you have a great rest of your 18
19 day. Obviously, Mr. Cohen might 19
20 have some questions for you as 20 __________________________
21 well. 21 NOTARY PUBLIC
22 MR. COHEN: Thank you, 22
23 Mr. Meade. I don't have anything 23
24 for you. 24
25 THE WITNESS: Thank you. 25
30 (Pages 114 - 117)
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