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Declaration of Laurence M. Rosen in Support of Plaintiffs’ Motion for Reconsideration (Document 668-1)

Summary

A Declaration of Laurence M. Rosen in Support of Plaintiffs' Motion for Reconsideration of the Court's Order Denying Plaintiffs' Motion for Class Certification in In re: January 2021 Short Squeeze Trading Litigation, Case No. 21-2989-MDL-ALTONAGA/Reid (Case 1:21-md-02989-CMA, Document 668-1), executed May 2, 2024 and entered on the FLSD docket May 2, 2024. Rosen, Lead Counsel for Lead Plaintiff Blue Laine-Beveridge and the named plaintiffs, states that Plaintiffs provided Robinhood with a merits expert report on loss causation and damages containing a per share damages model that isolates price declines caused by the trading restrictions' removal of Robinhood customer demand for the Affected Stocks, plus an alternative event-study model. The three-page declaration is signed /s/ Laurence M. Rosen (Fla. Bar No. 0182877) with a certificate of CM/ECF service dated May 2, 2024.

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Cite this document

“Declaration of Laurence M. Rosen in Support of Plaintiffs’ Motion for Reconsideration (Document 668-1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2024-05-02-covid-era-misc/, SHA-256 86d90bc387c350b8b2c3fbf382ae139eb6de857f2c35e3aef5d50e2d8ddb49a4.

Full text

Case 1:21-md-02989-CMA Document 668-1 Entered on FLSD Docket 05/02/2024 Page 1 of 3




                             UNITED STATES DISTRICT COURT
                             SOUTHERN DISTRICT OF FLORIDA

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


     In re: JANUARY 2021 SHORT SQUEEZE
     TRADING LITIGATION



    This Document Relates to: All Actions Involving the Federal Securities Laws



     DECLARATION OF LAURENCE M. ROSEN IN SUPPORT OF PLAINTIFFS’
     MOTION FOR RECONSIDERATION OF THE COURT’S ORDER DENYING
            PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION

    I, Laurence M. Rosen, hereby declare under penalty of perjury:
           1.      I am the Managing Partner of The Rosen Law Firm, P.A. (“Rosen Law”),
    Lead Counsel for 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”).
           2.      I make this Declaration in support of Plaintiffs’ Motion for Reconsideration
    of the Court’s Order Denying Plaintiffs’ Motion for Class Certification.
           3.      I am an attorney duly licensed to practice in the State of Florida and before
    this Court. I have personal knowledge of the matters set forth herein and, if called upon,
    I could and would completely testify thereto.
           4.      Pursuant to the Court’s scheduling order, Plaintiffs provided Robinhood
    with a merits expert report pertaining to loss causation and damages. The report contains
    a per share damages model that isolates price declines caused solely by the trading
    restrictions’ removal of Robinhood’s customer demand for the Affected Stocks from the
    market and a method by which each class member can easily calculate damages for sales
    of each stock on each day of the Class Period.
Case 1:21-md-02989-CMA Document 668-1 Entered on FLSD Docket 05/02/2024 Page 2 of 3




          5.     The expert report also provides an alternative damages model that
    measures per share damages using event studies that disaggregate price declines
    unrelated to Robinhood’s restrictions.
          I declare under the penalty of perjury that the foregoing is true and correct.


    Executed: May 2, 2024

                                             THE ROSEN LAW FIRM, P.A.

                                             /s/Laurence M. Rosen
                                             Laurence M. Rosen, Esq.
                                             Fla. Bar No. 0182877




                                                2
Case 1:21-md-02989-CMA Document 668-1 Entered on FLSD Docket 05/02/2024 Page 3 of 3




                               CERTIFICATE OF SERVICE

         I hereby certify that on May 2, 2024, a true and correct copy of the foregoing
    document was served by CM/ECF to the parties registered to the Court’s CM/ECF system.

                                    /s/Laurence M. Rosen




                                             3

File and source

File
gov.uscourts.flsd.590042.668.1.pdf
Size
110,774 bytes
SHA-256
86d90bc387c350b8b2c3fbf382ae139eb6de857f2c35e3aef5d50e2d8ddb49a4
Our copy
gov.uscourts.flsd.590042.668.1.pdf
Original
archive.org
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