Subject: Joint Status Report: Case 1:21-md-02989-CMA IN RE: January 2021 Short Squeeze Trading Litigation (dated 2023-08-11)

Summary

An email in Case 1:21-md-02989-CMA (Document 601-2), entered on the FLSD docket August 23, 2023 as a three-page attachment to Document 601: from Laurence Rosen of The Rosen Law Firm, P.A. to plaintiffs' counsel, dated Friday, August 11, 2023, subject "Joint Status Report: Case 1:21-md-02989-CMA IN RE: January 2021 Short Squeeze Trading Litigation," with an attached order of 8-10-23 on case status. The order asks The Rosen Law Firm, as lead counsel in the Federal Securities Tranche, to coordinate all plaintiffs' responses to four questions: whether the parties disagree with the Court's characterization of consolidation, the complete list of Federal Securities Tranche cases, the status of Eisen v. Apex Clearing Corp, and whether further Rule 42 consolidation will be sought. It asks for responses by Wednesday August 16 ahead of a submission to the Court on August 23.

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Case 1:21-md-02989-CMA Document 601-2 Entered on FLSD Docket 08/23/2023 Page 1 of 3


     From:            Laurence Rosen
     To:              Laurence Rosen
     Bcc:             tamara@desilvalawoffices.com; jvarnell@varnellandwarwick.com; bwarwick@varnellandwarwick.com;
                      mpeterson@varnellandwarwick.com; ewillis@varnellandwarwick.com; mvenezia@bgrfirm.com;
                      croth@bgrfirm.com; kmurray@bgrfirm.com; kwesley@bgrfirm.com; khannon@hannonlaw.com;
                      maurice@pessahgroup.com; mmnussbaum@pessahgroup.com; sbenson@pessahgroup.com;
                      stuart@chelinlaw.com; ltfisher@bursor.com; aobergfell@bursor.com; sbeck@bursor.com;
                      michael@estellekennedylaw.com; paul@estellekennedylaw.com; Jeff Klafter
     Subject:         Joint Status Report: Case 1:21-md-02989-CMA IN RE: January 2021 Short Squeeze Trading Litigation
     Date:            Friday, August 11, 2023 10:21:00 AM
     Attachments:     image001.png
                      Order on 8-10-23 re case status.pdf


     Dear Counsel:

     Judge Altonaga issued the attached order.

     It requests that The Rosen Law Firm, as lead counsel in the Federal Securities Tranche for the MDL,
     coordinate all plaintiffs’ responses to the four questions that the Court posed on pages 4-5 of the
     Order. See Footnote 2 on page 4.

     Please respond to this email and provide to me your position as to each of the four questions. I will
     then prepare a single response for all plaintiffs. I will then send the response to each plaintiff
     attorney for your review prior to our submission to the court. If you have revisions you can provide
     them to me before I file the response on ECF.

     To the extent any attorneys or groups of attorneys have a single response for their group, please
     provide a single group response and a list of the attorneys/cases for which the group speaks.

     The Four Questions are as follows:

        1. Do the parties disagree with the Court’s above characterization of the status of consolidation?
           If so, please detail any disagreement and include citations to the record and legal authority.

             Please provide a response to Question 1.

        2. What is the complete list of cases that correspond to the Federal Securities Tranche?  

             In footnote 3, the court lists the following cases. If you believe any other cases should be
             added to this list or any cases deleted from the list please let me know.

             Daniels v. Robinhood Financial, LLC, et al., No. 21-cv-21261 (filed Jan. 28, 2021); Days v.
             Robinhood Markets, Inc., et al., No. 21-cv-21310 (filed Jan. 28, 2021); Diamond v. Robinhood
             Financial, LLC, et al., No. 21-cv-21263 (filed Jan. 29, 2021); Lagmanson et al. v. Robinhood
             Markets, Inc., et al., No. 21-cv-21298 (filed Jan. 29, 2021); Gossett et al. v. Robinhood
             Financial, LLC, et al., No. 21-cv-21293 (filed Jan. 29, 2021); Muncy v. Robinhood Securities,
             LLC, et al., No. 21-cv-21307 (filed Feb. 2, 2021); Krumenacker v. Robinhood Financial LLC, et
             al., No. 21-cv-21343 (filed Feb. 2, 2021); Kadin v. Robinhood Financial LLC, et al., No. 21-cv-
             21511 (filed Mar. 25, 2021); Quat et al. v. Robinhood Financial, LLC, et al., No. 21-cv-21404
Case 1:21-md-02989-CMA Document 601-2 Entered on FLSD Docket 08/23/2023 Page 2 of 3


            (filed Apr. 12, 2021); Best et al. v. Robinhood Financial, LLC, et al., No. 21-cv-21534 (filed Apr.
            21, 2021); Eisen v. Apex Clearing Corp, et al., No. 21-cv-21665 (filed Apr. 30, 2021); Carrasco
            v. Robinhood Financial LLC, et al., No. 21-cv-22702 (filed May 25, 2021); and Scarborough v.
            Robinhood Financial, LLC, No. 1:23-cv-21572 (filed Apr. 6, 2023).
            The Diamond and Kadin actions were voluntarily dismissed. (See Apr. 20, 2021 Order [ECF
            No. 214]; Apr. 28, 2021 Order [ECF No. 272]).

        3. What is the status of Eisen v. Apex Clearing Corp, et al., No. 21-cv-21665 (filed Apr. 30, 2021),
           a federal securities class action case brought against Apex Clearing Corporation and
           Interactive Brokers, LLC?  

             I have spoken with the attorney who filed that case and will provide his response to the
            court once he has finalized it.

        4. Apart from the Motion to Consolidate the Scarborough action, do the parties intend to seek
           further consolidation under Rule 42 of actions in the Federal Securities Tranche? If so, which
           actions and what degree of consolidation?

            Please provide a response to question 4.

     Please provide your responses by Wednesday August 16.   This will give me time to combine all the
     responses into a single document and provide them to each attorney for review and then make any
     necessary changes prior to our submission to the Court on August 23.

     Thank you.

     Laurence Rosen
     The Rosen Law Firm, P.A.
     275 Madison Avenue, 40th Floor
     New York, NY 10016
     Direct: (646) 437-7780
     Main: (212) 686-1060
     Fax: (212) 202-3827
     Email: lrosen@rosenlegal.com
     www.rosenlegal.com




     Ranked 2nd in the nation for number of securities class action settlements in 2021 by ISS
     Securities Class Action Services.
Case 1:21-md-02989-CMA Document 601-2 Entered on FLSD Docket 08/23/2023 Page 3 of 3


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