[Proposed] Order (Joint Stipulation of Voluntary Dismissal; Federal Securities Tranche) — In re January 2021 Short Squeeze Trading Litigation (Dkt. 691-1, S.D. Fla.)

Summary

A [Proposed] Order in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA (Case No. 21-MD-2989-ALTONAGA/REID, Document 691-1, 2 pages), in the U.S. District Court for the Southern District of Florida, entered August 13, 2024. The order addresses the Joint Stipulation of Voluntary Dismissal filed August 13, 2024 by Lead Plaintiff Blue Laine-Beveridge, the named Plaintiffs and Robinhood, under which Plaintiffs dismiss their individual claims, each party bears its own costs and all parties acknowledge compliance with Rule 11. Drafted for entry under the name of Chief U.S. District Judge Cecilia M. Altonaga, the order would dismiss all claims with prejudice as to Robinhood except those of Marcel Poirier, dismissed without prejudice, and retain jurisdiction solely to enforce the agreements entered into by each of the Plaintiffs with Defendants.

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Case 1:21-md-02989-CMA Document 691-1 Entered on FLSD Docket 08/13/2024 Page 1 of 2




                                 UNITED STATES DISTRICT COURT
                                 SOUTHERN DISTRICT OF FLORIDA

                              CASE NO. 21-MD-2989-ALTONAGA/REID

    In re:

    JANUARY 2021 SHORT SQUEEZE
    TRADING LITIGATION

    _____________________________________/

    This Document Relates to the Federal Securities Tranche

                                          [PROPOSED] ORDER

             THIS CAUSE came before the Court upon the Joint Stipulation of Voluntary Dismissal

    Pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii) [ECF No. ___], filed on August 13, 2024, by Federal

    Securities Tranche Lead Plaintiff Blue Laine-Beveridge and 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”),

    and Defendants Robinhood Markets, Inc., Robinhood Financial LLC and Robinhood Securities,

    LLC (collectively, “Robinhood”).

             The parties have agreed to voluntarily dismiss all claims with prejudice as to all Plaintiffs

    except as to Marcel Poirier, for whom dismissal of all claims is without prejudice. For the

    avoidance of doubt, Plaintiffs are dismissing their individual claims. Each party shall bear their

    own costs. All parties have acknowledged that the other has complied with Rule 11 and waive

    any arguments related thereto. The parties have agreed that the Court shall retain jurisdiction for

    the sole purpose of enforcing the agreements entered into by each of the Plaintiffs with

    Defendants to dismiss their individual claims.
Case 1:21-md-02989-CMA Document 691-1 Entered on FLSD Docket 08/13/2024 Page 2 of 2




              Being fully advised, it is:

              ORDERED AND ADJUDGED that: (1) all claims as to all Plaintiffs except as to

    Marcel Poirier are dismissed with prejudice as to Robinhood and with respect to the terms as

    described herein; (2) all claims as to Marcel Poirier are dismissed without prejudice as to

    Robinhood and with respect to the terms as described herein; and (3) the Court shall retain

    jurisdiction for the sole purpose of enforcing the agreements entered into by each of the Plaintiffs

    with Defendants to dismiss their individual claims.

              DONE AND ORDERED in Miami, Florida, this ____ day of August 2024.




                                                  CECILIA M. ALTONAGA
                                                  CHIEF UNITED STATES DISTRICT JUDGE

    CC:                  Counsel of Record




    [[DMS:6444479v5:08/13/2024--03:18 PM]]


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