Subject: Joint Status Report: Case 1:21-md-02989-CMA IN RE: January 2021 Short Squeeze Trading Litigation (dated 2023-08-17)

Summary

An email in Case 1:21-md-02989-CMA (Document 601-3), entered on the FLSD docket August 23, 2023 as a five-page attachment to Document 601: from Laurence Rosen of The Rosen Law Firm, P.A. to a list of plaintiffs' counsel, dated Thursday, August 17, 2023 5:48:00 PM, 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 email states that the message sent on August 11 has drawn no reply and requires an immediate response, repeats the request that counsel state a position on each of the Court's four questions, and adds that counsel taking no position should say so for the status report. The August 11, 2023 email is reproduced below the new message, ahead of the submission to the Court on August 23.

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Date: 2023-08-17

Cite this document

“Subject: Joint Status Report: Case 1:21-md-02989-CMA IN RE: January 2021 Short Squeeze Trading Litigation.” Original at archive.org, dated 2023-08-17. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-08-17-daniels-v-robinhood-financial-llc-et-al-no-21-cv-21261-filed-jan-28-2021/, SHA-256 b9a2fe6c8be8fc4a2ceb7016d2177752fb44e4c04d4bc1487b3916ce9a5d1a08.

Full text

Case 1:21-md-02989-CMA Document 601-3 Entered on FLSD Docket 08/23/2023 Page 1 of 5

From: Laurence Rosen
To: khannon@hannonlaw.com; mvenezia@bgrfirm.com; croth@bgrfirm.com; kmurray@bgrfirm.com;
kwesley@bgrfirm.com; jvarnell@varnellandwarwick.com; bwarwick@varnellandwarwick.com;
mpeterson@varnellandwarwick.com; ewillis@varnellandwarwick.com; jonathan@lubinlegal.com;
tamara@desilvalawoffices.com; aobergfell@bursor.com; sbeck@bursor.com; swestcot@bursor.com;
michael@estellekennedylaw.com; paul@estellekennedylaw.com; ltfisher@bursor.com
Subject: Joint Status Report: Case 1:21-md-02989-CMA IN RE: January 2021 Short Squeeze Trading Litigation
Date: Thursday, August 17, 2023 5:48:00 PM
Attachments: image001.png
Order on 8-10-23 re case status.pdf

Dear Counsel

I sent the email below to you last week on August 11.

I have not heard back from you.

This email requires an immediate response.

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.

If you take no position – just let me know and I will say that in the status report.

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.
Case 1:21-md-02989-CMA Document 601-3 Entered on FLSD Docket 08/23/2023 Page 2 of 5

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
(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 immediately. 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
Case 1:21-md-02989-CMA Document 601-3 Entered on FLSD Docket 08/23/2023 Page 3 of 5

Ranked 2nd in the nation for number of securities class action settlements in 2021 by ISS
Securities Class Action Services.

From: Laurence Rosen
Sent: Friday, August 11, 2023 10:22 AM
To: Laurence Rosen <lrosen@rosenlegal.com>
Subject: Joint Status Report: Case 1:21-md-02989-CMA IN RE: January 2021 Short Squeeze Trading
Litigation

Dear Counsel:

Judge Altonaga issued the attached order.

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
Case 1:21-md-02989-CMA Document 601-3 Entered on FLSD Docket 08/23/2023 Page 4 of 5

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
(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]).

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

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.

Ranked 2nd in the nation for number of securities class action settlements in 2021 by ISS
Securities Class Action Services.

File and source

File: gov.uscourts.flsd.590042.601.3.pdf
Size: 279,962 bytes
SHA-256: b9a2fe6c8be8fc4a2ceb7016d2177752fb44e4c04d4bc1487b3916ce9a5d1a08
Our copy: gov.uscourts.flsd.590042.601.3.pdf
Original: archive.org