Exhibit A: Revised Notice of Deposition of Robinhood Markets, Inc. — Case 1:21-md-02989-CMA (Document 586-1)

Summary

Exhibit A to Document 586 in In re: January 2021 Short Squeeze Trading Litigation, Case No. 21-2989-MDL-ALTONAGA/Damian (Case 1:21-md-02989-CMA, Document 586-1), entered on the FLSD docket August 7, 2023: a 25-page "Revised Notice of Deposition of Robinhood Markets, Inc., Robinhood Financial, Inc., and Robinhood Securities, LLC" under the Federal Rules of Civil Procedure, dated July 17, 2023. Lead Plaintiff Blue Laine-Beveridge and the named Plaintiffs, through The Rosen Law Firm, P.A., notice the deposition of the designated representatives of Robinhood Markets, Inc. for August 25, 2023 at 9:00 a.m. at the firm's New York offices. Schedule A sets out definitions, including a Relevant Period of December 1, 2020 through March 5, 2021 and a definition of Senior Management, and deposition topics 1 through 57.

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Date: 2023-08-07

Cite this document

“Exhibit A: Revised Notice of Deposition of Robinhood Markets, Inc. — Case 1:21-md-02989-CMA (Document 586-1).” Original at archive.org, dated 2023-08-07. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-08-07-covid-era-misc/, SHA-256 a091b4bf5169473f323cf36123a02f7fc54b27c5c0f81936ae459408bae17a63.

Full text

Case 1:21-md-02989-CMA Document 586-1 Entered on FLSD Docket 08/07/2023 Page 1 of 25

EXHIBIT A
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-2989-MDL-ALTONAGA/Damian

CLASS ACTION
In re: JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION REVISED NOTICE OF
DEPOSITION OF ROBINHOOD
MARKETS, INC., ROBINHOOD
FINANCIAL, INC., AND
ROBINHOOD SECURITIES,
LLC

TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD

PLEASE TAKE NOTICE that, pursuant to Rules 30(b)(6) of the Federal Rules of Civil

Procedure, Lead Plaintiff Blue Laine-Beveridge, named Plaintiffs Abraham Huacuja, Ava

Bernard, Brendan Clarke, Brian Harbison, Cecilia Rivas, Doi Nguyen, Joseph Gurney, Marcel

Poirier, Sandy Ng, Santiago Gil Bohórquez, and Thomas Cash (collectively “Plaintiffs”),

individually and on behalf of all other persons similarly situated, by Plaintiffs’ undersigned

attorneys, will take the deposition upon oral examination of the designated representative or

representatives of Robinhood Markets, Inc., (“Robinhood”). Such deposition will take place on

August 25, 2023, commencing at 9:00 a.m., at the offices of The Rosen Law Firm, P.A., 275

Madison Avenue, 40th Floor, New York, NY 10016, or at such other time and place as the parties

mutually agree. Such deposition will be recorded stenographically and videotaped by a qualified

videographer, and shall continue from day to day until completed.

Pursuant to Federal Rules of Civil Procedure 30(b)(6), Robinhood is requested to designate

one or more officers, directors, managing agents, or other persons who consent to testify on its
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behalf as to corporate matters, as to the matters set forth in Schedule A.

DATED: July 17, 2023 THE ROSEN LAW FIRM, P.A.

/s/ Laurence M. Rosen
Laurence M. Rosen, FBN# 0182877
Phillip Kim
Robin Bronzaft Howald
Michael A. Cohen
Jon Stern
Brent J. LaPointe
275 Madison Avenue, 40th Floor
New York, New York 10016
Telephone: (212) 686-1060
Facsimile: (212) 202-3827
Email: lrosen@rosenlegal.com
pkim@rosenlegal.com
rhowald@rosenlegal.com
mcohen@rosenlegal.com
jstern@rosenlegal.com
blapointe@rosenlegal.com

Lead Counsel for Plaintiffs and the Class

CERTIFICATE OF SERVICE

I hereby certify that on July 17, 2023, a true and correct copy of the foregoing
document was served to counsel for each Robinhood defendant by email.

/s/ Laurence M. Rosen

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SCHEDULE A

I. DEFINITIONS

1. The “Action” refers to just the federal securities tranche of In re January 2021

Short Squeeze Trading Litigation, Case No. 21-2989-MDL (Altonaga/Damian).

2. The “Affected Stocks” refers to common stock in AMC Entertainment Holdings,

Inc. (“AMC”), Bed Bath & Beyond Inc. (“BBBY”), BlackBerry Ltd. (“BB”), Express Inc.

(“EXPR”), GameStop Corp. (“GME”), Koss Corp. (“KOSS”), Tootsie Roll Industries Inc. (“TR”),

or American Depositary Shares of foreign-issuers Nokia Corp. (“NOK”) and trivago N.V.

(“TRVG”), individually and collectively.

3. “Alleged Omissions and Half-Truths” means the statements that Robinhood made

omitting to disclose that it had a liquidity problem, that it would have allowed trading to continue

were it adequately capitalized, and that Robinhood knew the prices of the Affected Stocks would

decline as a result of its actions, as identified in Paragraphs 62 and 63, inclusive, of the Complaint.

4. “Complaint” means the Amended Consolidated Class Action Complaint, filed

January 17, 2023 (Docket No. 527), in the above-captioned action.

5. “Communication” means the transmittal of information (in the form of facts, ideas,

inquiries, or otherwise).

6. “Concern” or “concerning” means relating to, referring to, describing, evidencing,

or constituting.

7. “Digital Communications” means Communications (whether by text, image, audio,

video, or otherwise) through or via any collaboration application or platform, social media

platform or service, chat client, or electronic messaging medium, including but not limited Email

and Instant Messages as defined herein.

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8. “Document” or “Documents” is defined to be synonymous in meaning and equal

in scope to the usage of the term “documents or electronically stored information” in Fed. R. Civ.

P. 34(a)(1)(A). A draft or non-identical copy is a separate Document within the meaning of this

term. The terms “Document” and “Documents” specifically include, but are not limited to,

Communications, Digital Communications, and Electronically-Stored Information (“ESI”), as

each is defined herein.

9. “DTCC” means the Depository Trust & Clearing Corporation, together with its

subsidiaries, affiliates, officers, employees, agents, and anyone acting or purporting to act on its

behalf.

10. “Electronically Stored Information” (“ESI”) as used herein has the same meaning

as in the Federal Rules of Civil Procedure and other applicable law, including Rules 26 and 34(a)

of the Federal Rules of Civil Procedure. Examples of ESI include:

a. Digital Communications (e.g., e-mail, voice mail, and Instant Messages, as

defined herein);

b. E-mail server stores (e.g., Microsoft Exchange .edb);

c. Word-processed documents (e.g., Word files and drafts thereof);

d. Spreadsheets and tables (e.g., Excel worksheets);

e. Accounting application data (e.g. Quickbooks);

f. Image and facsimile files (e.g., .PDF, .TIFF, .JPG, .GIF);

g. Sound recordings (e.g., .WAV and .MP3);

h. Video and animation files(e.g., .AVI and .MOV);

i. Databases (e.g., Access, Oracle, SAP, SQL data);

j. Contact and relationship management data (e.g., Outlook contacts);

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k. Calendar and diary application data (e.g., Outlook calendar entries, blog

entries);

l. Presentations (e.g., PowerPoint);

m. Network access and server activity logs;

n. Project management application data;

o. Computer aided design/drawing files; and

p. Cloud-based or other virtualized ESI, including applications, infrastructure, and

data.

11. “Email” means electronic messages sent or received via web/HTML interface or

through messaging applications or clients, whether on personal computing devices, smartphones,

tablets, or any other similar device, including but not limited to Google (Android) Mail, Gmail,

Microsoft Outlook, Mozilla Thunderbird, and/or Apple Mail.

12. “Employee” means, without limitation, current and former officers, directors,

executives, managers, supervisors, department heads, employees, secretaries, clerical staff,

messengers, agents, attorneys, representatives, or any Person acting or authorized to act on behalf

of an entity.

13. “Financial Statements” means, without limitation, any interim, final, actual,

projected, complete, or partial, annual, quarterly, monthly, weekly, or otherwise, audited or

unaudited, budgets, budget plans, balance sheets, schedules of direct costs, schedules of

miscellaneous income, schedules of general services, fiscal serviceman administrative services,

statements of earnings and earnings per share, income statements, cash flow statements, statements

of revenues and statements of expenses, all notes or other commentary concerning any of the

foregoing, and all underlying work papers and all drafts used in connection with the preparation

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of any of the foregoing.

14. “FINRA” means the Financial Industry Regulatory Authority, together with its

subsidiaries, affiliates, officers, employees, agents, and anyone acting or purporting to act on its

behalf.

15. “HFSC Report” refers to “Game Stopped: How the Meme Stock Market Event

Exposed Troubling Business Practices, Inadequate Risk Management, and the Need for Regulatory

and Legislative Reform,” a report issued by the Majority Staff of the U.S. House of Representatives

Financial Services Committee in June 2022.

16. “Identify” when used to refer to a Document, shall mean: (i) the date of each

Document; (ii) the type of each such Document (i.e. correspondence, memorandum, business

record, etc.); (iii) the identity of the author(s) or preparer(s) of each such Document; and (iv) the

present location of each such Document or copies thereof.

17. “Identify” when used to refer to a natural person, shall mean to set forth that

person’s: (i) full name and title, if any; (ii) present or last known address; (iii) present or last known

business and home telephone number(s); and (iv) present or last known employer.

18. “Instant Messages” means real-time communications, including but not limited to

ephemeral communications, sent text message (e.g. SMS/MMS), or via chat application, platform,

or client, or any similar standard, including but not limited to Bloomberg Chat, Slack, Google

Talk, Google Chat, Google Hangouts, Apple iMessage, WhatsApp, WeChat, QQ, Viber, Facebook

Messenger, Microsoft Teams, Skype, Zoom, Discord, Snapchat, Signal, Line, Telegram, AOL

Instant Messenger, Huawei Cloud, Blackberry Messenger, ICQ, Pidgin, Audium, Trillian, or any

proprietary Instant Messaging system

19. “IPO” refers to the Company’s Initial Public Offering of approximately 52.4

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million shares of Company common stock priced at $38 per share, which closed on or around July

29, 2021, raising nearly $2 billion.

20. “Later-Restricted Stocks” means the fifty stocks set forth in the table in Paragraph

87 of the Complaint, indicating that the stock was subject to a restriction on January 29, 2021.

21. “Meme Stock Market Event” refers to the name used by the U.S. House of

Representatives Financial Services Committee to describe the facts and circumstances which gave

rise to, inter alia, the instant action.

22. “Meeting” means the contemporaneous presence, whether in person or through any

means of communication, of any natural persons, whether or not such presence was by chance or

prearranged and whether or not the meeting was formal, informal or occurred in connection with

some other activity.

23. “NSCC” means the National Securities Clearing Corporation, together with its

subsidiaries, affiliates, officers, employees, agents, and anyone acting or purporting to act on its

behalf.

24. “Person” means any natural person, proprietorship, corporation, partnership, trust,

joint venture, group, association, organization, governmental agency and other agency. With

respect to a business entity, the term “Person” includes any natural Person acting formally or

informally as a director, trustee, officer, agent, attorney, or other representative of the business

entity.

25. “OCC” means the Options Clearing Corporation, together with its subsidiaries,

affiliates, officers, employees, agents, and anyone acting or purporting to act on its behalf.

26. “Prospectus” refers to the Prospectus for the IPO, originally filed with the SEC on

Form S-1 on or about July 1, 2021, as amended, with the second and final amendment on SEC

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Form S-1/A filed on or about July 27, 2021.

27. “Regard,” “regarding,” “refer,” “referring,” “relate,” relating,” “pertain,” or

“pertaining” means all Documents that comprise, explicitly or implicitly refer to, were reviewed

in conjunction with or were created, generated or maintained as a result of the subject matter of

the Request, including, without limitation, all Documents that reflect, record, memorialize,

embody, discuss, evaluate, consider, review or report on the subject matter of the Request.

28. “Registration Statement” refers to the SEC Form DRS originally filed by

Robinhood on or about March 1, 2020, as amended, with the third and final amendment on SEC

Form DRS/A dated June 15, 2021, which was declared effective by the SEC on or about July 29,

2021. The Prospectus (as defined herein) also forms part of the Registration Statement.

29. “Relevant Period” is defined as December 1, 2020, through March 5, 2021, unless

otherwise stated.

30. “Restrictions” include all measures Robinhood implemented during the

“Restriction Period” changing the margin requirements for the Affected Stocks and/or the Later

Restricted Stocks, restricting the purchase of the Affected Stocks and/or Later Restricted Stocks,

or forcing the sale of the Affected Stocks and/or Later Restricted Stocks and/or put or call options

in the Affected Stocks and/or Later Restricted Stocks.

31. “Restriction Period” means the period between the first imposition of any form of

restriction, to wit, closing call option positions prior to their expiry, position closing only, purchase

limits (including of fractional shares), and total holdings limits, and the lifting of all such limits

during the Relevant Period. “Senior Management” means those persons with day-to-day

responsibility for managing Robinhood’s operations.

32.

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33. “Underwriters” refers to Goldman Sachs & Co. LLC, J.P. Morgan Securities

LLC, Barclays Capital Inc., Citigroup Global Markets, Inc., Wells Fargo Securities, LLC, Mizuho

Securities USA LLC, JMP Securities LLC, KeyBanc Capital Markets, Inc., Piper Sandler & Co.,

Rosenblatt Securities, Inc., BMO Capital Markets Corp., BTIG, LLC, Santander Investment

Securities, Inc., Academy Securities, Inc., Loop Capital Markets, LLC., Samuel A Ramirez &

Company, Inc., and Siebert Williams Shank & Co., LLC, individually and collectively.

34. “Robinhood” and the “Company” means Robinhood Markets, Inc., individually

and collectively, together with all of their respective present and former officers, directors,

committees, employees, partners, corporate parents, predecessors, successors, agents,

representatives, and all other Persons acting, or purporting to act, on behalf of any of the foregoing.

35. “You” or “Your” means Robinhood.

TOPICS FOR ROBINHOOD 30(b)(6) DEPOSITION

1. The communications media, devices, platforms, and applications used by the Relevant

Custodians, Robinhood’s, Senior Management, and its board of directors for work-

related communications.

2. The hardware devices used by the Relevant Custodians to perform their work-related

functions.

3. Robinhood’s policies and procedures for the Relevant Custodians, for its Senior

Management and its board of directors related to the use of personal communications

devices, personal email, personal computing devices or any non-Robinhood maintained

device work related communications or any work-related functions, including but not

limited to the location and identification of all Documents related to this topic.

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4. Document production: Robinhood’s production of Documents in this litigation, including

but not limited to the manner in which Documents responsive to Plaintiffs’ Requests For

Production of Documents, were searched for, identified, and retrieved, and the databases,

hardware, and devices searched.

5. The identity of all employees and agents of Robinhood whose files were searched in

connection with this Action or any related action, regulatory investigation, or

enforcement proceeding.

6. A full explanation of all of Robinhood’s public statements concerning the Meme Stock

Market Event, including but not limited to, the substance of the statements, how and

when and to whom the statements were made, and the location and identification of all

Documents and persons with knowledge related to this topic, the reasons for and

objectives of such statements, and the names, titles, and job functions of all persons who

participated in creating, editing, reviewing, discussing, implementing, authorizing or

approving such statements.

7. A full explanation of all of Robinhood’s public statements about the Restrictions it

imposed on trading in the Affected Stocks, including but not limited to, the substance of

the statements, how and when and to whom the statements were made, and the location

and identification of all Documents and persons with knowledge related to this topic, and

the reasons for and objectives of such statements, and the names, titles, and job functions

of all persons who participated in creating, editing, reviewing, discussing, implementing,

authorizing or approving such statements. This includes all statements regarding the

restrictions imposed and lifted as shown in RHMDL00047970.

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8. A full explanation of all of Robinhood’s statements to its customers about the

Restrictions it imposed on trading or lifted on the Affected Stocks, including but not

limited to, the substance of the statements, how and when and to whom the statements

were made, and the location and identification of all Documents and persons with

knowledge related to this topic and the names, titles, and job functions of all persons who

participated in creating, editing, reviewing, discussing, implementing, authorizing or

approving such statements.

9. The trading Restrictions Robinhood imposed during the Meme Stock Market Event. In

particular:

(a) The nature and extent of each of the Restrictions.

(b) The precise time each Restriction was announced, imposed and lifted.

of the Restrictions was discussed, evaluated, approved, implemented, and publicized,

including the identities, by job title and specific roles and responsibilities, of any

persons involved in such decisions.

(d) The reasons Robinhood imposed and lifted each of the trading Restrictions at the

various times during the Restrictions Period.

(e) The basis for how Robinhood selected the stocks on which to impose and lift

Restrictions during the two weeks prior to, and during, the Restrictions Period,

including but not limited to each factor Robinhood considered in determining whether

or not to impose or lift Restrictions and the sources of information from which those

factors were evaluated and determined.

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(f) Robinhood’s consideration of its customers’ reactions to the imposition and lifting of

the Restrictions.

(g) Robinhood’s consideration of the possibility that purchasing demand for the Affected

Stocks or Later Affected Stocks might decline when Robinhood imposed the

Restrictions

(h) Robinhood’s consideration of the possibility that selling pressure for the Affected

Stocks or Later Affected Stocks might increase when Robinhood imposed the

Restrictions;

(i) Robinhood’s consideration of the possibility that the prices of the Affected Stocks or

Later Affected Stocks might decline when Robinhood imposed the Restrictions

(j) Robinhood’s consideration and discussion of the impact a decline in the prices of the

Affected Stocks or Later Affected Stocks would have on its customers, the market as

a whole, market participants with positions in the Later Affected Stocks, Robinhood

itself and its business relationships, including the Identity of any participants in any

such discussions.

(k) The names, titles, functions, and roles of all persons, approving, authorizing,

providing input for, responsible for and/or participating in, the decisions to implement

or lift any such Restrictions, including those persons employer and their direct

supervisor(s).

(l) The location and identification of all Documents related to this topic.

(m) The sources and bases of information from which any testimony related to this topic

derives.

10. Why Robinhood maintained position limits on several of the Affected Stocks as late as

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the market close on February 4, 2021, given that “Robinhood’s collateral deposit

requirements were within manageable levels by January 29, 2021, and the company had

raised the capital that its models suggested was sufficient to handle shock scenarios by

the end of the day on February 2, 2021,” as referenced in the HFSC Report at 75,

including but not limited to, the location and identification of all Documents related to

this topic, and the identity, job title and job function of all witnesses with material

information on this topic.

11. All bases for the comment (see RHMDL00077158) that Robinhood’s customers

represented more than 10% of the market for the Affected Stocks just prior to and/or

during the Restrictions Period including but not limited to, the location and identification

of all Documents and persons with knowledge related to this topic.

12. The existence, date, place and nature of any testimony or interviews with Robinhood

employees regarding the Meme Stock Market Event, including but not limited to, the

location and identification of all Documents related to this topic.

13. How the daily amount of PFOF earned by Robinhood from each of its six market makers

on each of the Later Restricted Stocks during the Relevant Period affected Robinhood’s

cash flow, liquidity position, and ability to meet its regulatory collateral requirements,

including any communications about this subject that occurred during the Relevant

Period, including but not limited to the location and identification of all Documents and

persons with knowledge related to this topic.

14. How Robinhood’s PFOF from Citadel and other market makers was calculated during the

Relevant Period, any changes, adjustments to the fees paid by Citadel or other brokers for

PFOF, how and why the formulas for PFOF changed over that time period, and any

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contracts pursuant to which they were paid, including but not limited to, the location and

identification of all Documents and persons with knowledge related to this topic.

15. The project or proposal that Robinhood discussed with Citadel beginning on or around

January 20, 2021, as referenced in ¶¶ 226-32 of the Antitrust Complaint (Dkt. No 451),

including but not limited to, the location and identification of all Documents and persons

with knowledge related to this topic.

16. The identification and description of the substance, nature and purpose of all

Robinhood’s communications with Citadel on January 27, 2021, including but not limited

to those referenced in the HFSC Report at 47-51, e.g., the 8 p.m. call between Robinhood

and Citadel referenced in the HFSC Report at 50-51, and including but not limited to, the

location and identification of all Documents and persons with knowledge related to this

topic.

17. The importance to Robinhood’s financial performance, liquidity and financial condition

of PFOF during the Relevant Period, including the percentage of its revenues that PFOF

and in particular PFOF from Citadel had to its financial performance, liquidity and

financial condition.

18. Robinhood’s liquidity position and financial condition during the Relevant Period, as it

related to its ability to meet its collateral and deposit requirements with all of its

regulators during that time period, including but not limited to, the location and

identification of all Documents related to this topic, and the identity, job title and job

function of all witnesses with material information on this topic.

19. Robinhood’s communications with the NSCC and DTCC during the Meme Stock Market

Event, including but not limited to, the location and identification of all such

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communications and all Documents memorializing both any part of the interactions with

the NSCC and DTCC, as well as Robinhood’s strategy in its dealings with the NSCC and

DTCC, and Documents authored and gathered in response to requests by the NSCC and

DTCC. Methods by which Robinhood recorded or memorialized these communications.

20. Robinhood’s ability or inability to meet the multiple collateral and deposit requirements

of the NSCC/DTCC during the Meme Stock Market Event, including the necessity of a

capital infusion to meet such requirements, and including but not limited to, the location

and identification of all Documents and persons with knowledge related to this topic, e.g.,

cash or liquidity projections, bank records, financial statements, fundraising efforts, and

responses to requests made by the NSCC and DTCC, and the identity, job title and job

function of all witnesses with material information on this topic..

21. The bases for CEO Vlad Tenev’s statement that Robinhood would have continued to

allow unrestricted trading in the Later Affected Stocks during the Restrictions Period had

Robinhood been more adequately capitalized as stated by CEO Tenev to Dave Portnoy

and others.

22. The reasons why Robinhood did not disclose to the market during the Restrictions period

the complete detailed set of reasons for imposing, lifting and reimposing Restrictions,

including that it did not have adequate capitalization or liquidity to meet the collateral

and deposit requirements of the NSCC/DTCC on January 28, 2021, and that had it not

maintained the Restrictions during the Restrictions Period it might not have had adequate

capitalization or liquidity to meet the collateral and deposit requirements of the

NSCC/DTCC during the entirety of the Restrictions Period. The identity, job title and job

function of all witnesses with material information on this topic.

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23. The reasons why Robinhood did not announce publicly (i) the date when Robinhood

intended to fully remove the Restrictions, and (ii) the contingencies affecting when it

would fully remove the Restrictions. The identity, job title and job function of all

witnesses with material information on this topic.

24. Robinhood’s belief or position as to whether the Alleged Omissions and Half-Truths were

in fact disclosed and if so the basis for any such belief, and if so, the identity of all such

disclosures.

25. The identity of any facts or evidence, including but not limited to the beliefs, knowledge,

discussions, position or statements of Robinhood and/or its employees concerning or

related to whether the Alleged Omissions and Half-Truths during the Restrictions Period:

(1) caused or contributed to decreased demand for the purchase of the Affected Stocks, (3)

caused or contributed to a sell-off for the Affected Stocks that detrimentally affected the

prices of the Affected Stocks (4) caused or contributed to a decrease in the share prices of

the Affected Stock, or (3) caused or contributed to damages to Robinhood customers and

other investors with positions in the Affected Stocks who sold shares of the Affected Stocks

during the Class Period, and (4) the bases for any such beliefs. This topic includes but is

not limited to discussions among Senior Management, all hands meetings, and board

meetings.

26. The identity of any facts or evidence, including but not limited to the beliefs, knowledge,

position, discussions or statements of Robinhood and/or its employees concerning or

related to whether during the Restrictions Period the Alleged Omissions and Half-Truths

had an effect on: (i) Robinhood customers, (ii) investors with positions in the Affected

Stocks, or (iii) the prices of the Affected Stocks, and the bases for any of Robinhood’s

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beliefs or positions related to this topic. This topic includes but is not limited to

discussions among Senior Management, all hands meetings, and board meetings.

27. Robinhood’s awareness of, and methods for, its internal calculations of its deposit and

collateral requirements owed to the NSCC and DTCC during the Relevant Period,

including but not limited to VaR and ECP charges, and including the location and

identification of all Documents related to this topic, the identity, job title and job function

of all witnesses with material information on this topic.

28. The specific amounts for Robinhood’s collateral deposit and capital charges due to NSCC

and DTCC associated with each of the restricted stocks during each day of the Relevant

Period, and how those amounts changed during the Relevant Period particularly as

compared to other stocks that were heavily bought on Robinhood at the same time and the

reasons and calculations therefore including but not limited to, the location and

identification of all Documents related to this topic.

29. The day and time Robinhood first discovered the potential for a liquidity problem during

the Relevant Period, and how it discovered it, including but not limited to, the location

and identification of all Documents and persons with knowledge related to this topic.

30. The nature, scope, causes of the liquidity problem that Robinhood experienced during the

Restriction Period, such as that referenced in the HFSC Report at 24, 30, 31, 54, 55, 61,

66, 68 and 69, including but not limited to, the location and identification of all

Documents and persons with knowledge related to this topic.

31. Robinhood’s belief that it would not be shut down or forced to liquidate its customers’

positions by the NSCC/DTCC because it was “to[o] big to fail,” as referenced in the

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HFSC Report at 65 (citing RH_HFSC_00007111), including but not limited to the

location and identification of all documents related to this topic.

32. .Robinhood’s predictions for its customers’ daily demand (i.e. likely purchase and sale

quantities) for the Affected Stocks in the two weeks prior to, and during, the Restrictions

Period, including but not limited to, how such predictions are made, the reasons for the

predictions and the location and identification of all Documents and persons with

knowledge related to this topic.

33. Robinhood’s view that Robinhood’s systems were having trouble handling the volume of

trades on its platform, e.g., “handling scale,” such as those referenced in the HFSC

Report at pp. 23-25, 31, 36 and 57, and reasons why, including but not limited to the

location and identification of all documents related to this topic.

34. Robinhood’s awareness that imposing Restrictions on the Affected Stocks could cause a

decline in the market price of the Affected Stocks, including but not limited to that

referenced in the HFSC Report at 31 (citing RH_HFSC_00029118) (“us PCO will trigger

a crash, I am certain”), including but not limited to the location and identification of all

Documents and persons with knowledge related to this topic.

35. Robinhood’s consideration of, and its decision to, limit in any way the number or pace of

new account sign-ups during the Relevant Period, and the reasons therefor such as those

referenced in the HFSC Report at 31, 56, and 58, including but not limited to the location

and identification of all documents and persons with knowledge related to this topic.

36. The number of total Robinhood accounts, daily new Robinhood account sign-ups, and the

total dollar amount held in Robinhood accounts on a daily basis during the Relevant Period,

including but not limited to the location and identification of all Documents and persons

18
Case 1:21-md-02989-CMA Document 586-1 Entered on FLSD Docket 08/07/2023 Page 20 of
25

with knowledge related to this topic.

37. The volume and type of trading (buys, sells, options, stocks) in the Affected Stocks by new

accounts in the period, including but not limited to the location and identification of all

Documents and persons with knowledge related to this topic.

38. The amount and the changes in total daily volume of trading in Robinhood accounts in

the stock and options of the Affected Stocks during the Relevant Period, including but

not limited to, the location and identification of Documents related to this topic.

39. Robinhood’s efforts to raise capital from investors or any other source of funding during

the Relevant Period, including but not limited to the reasons for Robinhood raising

capital, the search for and identification of investors, negotiations, and Robinhood’s

representations of the reasons for the capital infusion, and the terms and nature of the

transactions by which Robinhood raised additional capital during the Relevant Period,

including but not limited to the location and identification of all Documents and persons

with knowledge related to this topic and all persons participating in or approving the

raising of additional capital during the Relevant Period..

40. The impact of the Meme Stock Market Event on Robinhood’s efforts to pursue and

complete an initial public offering, including but not limited to the location and

identification of all documents related to this topic.

41. Robinhood’s insurance policies in place during the Relevant Period covering (i) securities

fraud claims, (ii) errors and omissions, and (iii) liability of any kind, including but not

limited to the location and identification of all Documents and persons with knowledge

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