Status Report — In re January 2021 Short Squeeze Trading Litigation (Document 704)

Summary

A Status Report in In re: January 2021 Short Squeeze Trading Litigation, Case No. 21-MD-02989-ALTONAGA (Case 1:21-md-02989-CMA, Document 704), dated October 9, 2024 and entered on the FLSD docket October 9, 2024, relating to the Federal Securities Tranche. The Robinhood defendants report on conferral with the outstanding securities plaintiffs after the September 18, 2024 Status Conference, stating that Robinhood plans to move to compel arbitration of the remaining securities claims except the Lagmanson Plaintiffs' claims, and noting that Plaintiff Damon Muncy has stipulated to dismissal with prejudice [ECF No. 703]. Robinhood suggests a deadline of December 9, 2024 for its motion to compel arbitration; the report is signed /s/ Samuel A. Danon of Hunton Andrews Kurth LLP with a certificate of CM/ECF service dated October 9, 2024.

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Date: 2024-09-18

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“Status Report — In re January 2021 Short Squeeze Trading Litigation (Document 704).” Original at archive.org, dated 2024-09-18. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2024-09-18-best-v-robinhood-financial-llc-no-21-cv-21534/, SHA-256 2d07ce714b1aef7852eac41837ac3e330bb5cf759b497d3a6b2ebe1b7497ee87.

Full text

Case 1:21-md-02989-CMA Document 704 Entered on FLSD Docket 10/09/2024 Page 1 of 5

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-MD-02989-ALTONAGA

In re:

JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION
_________________________________/

This Document Relates the Federal Securities Tranche

STATUS REPORT

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

Securities, LLC (collectively, “Robinhood”) respectfully provide this report on the status of

Robinhood’s efforts to confer with the outstanding individual securities plaintiffs regarding

Robinhood’s forthcoming motion to compel arbitration. Robinhood reports as follows:

1. On September 18, 2024, the Court convened the parties in this multidistrict

litigation (“MDL”) for a Status Conference to address “the status of each Tranche”; “what types

of individual claims for each Tranche remain, given dismissal of several Complaints”; “what

additional pre-trial activities . . . may be necessary” for the remaining claims in the consolidated

cases; and “whether Lead Counsel for the Federal Securities Tranche wishe[d] to remain as Lead

Counsel for that Tranche, now that a putative class no longer exists . . . .” See Order [ECF No.

697] (alterations added).

2. At the Status Conference, the Court heard from counsel for Robinhood, lead

counsel for each of the Tranches within this MDL, and counsel for Plaintiffs Marcus Lagmanson,

Anthony Reyes, and Brian Belderrain (collectively, the “Lagmanson Plaintiffs”).

3. As part of the “additional pre-trial activities” necessary for the remaining

consolidated claims, counsel for Robinhood informed the Court that Robinhood plans to move to

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Case 1:21-md-02989-CMA Document 704 Entered on FLSD Docket 10/09/2024 Page 2 of 5

compel arbitration of the remaining securities claims, except for those asserted by the Lagmanson

Plaintiffs. The remaining securities claims that Robinhood intends to seek arbitration of, with their

respective Southern District of Florida case numbers (collectively, the “Outstanding Securities

Claims”), are:

• Best v. Robinhood Financial, LLC, No. 21-cv-21534;

• Carrasco v. Robinhood Financial LLC, No. 21-cv-22702;

• Daniels v. Robinhood Financial, LLC, No. 21-cv-21261;

• Days v. Robinhood Markets, Inc., No. 21-cv-21310;

• Gatz v. Robinhood Financial, LLC, No. 21-cv-21296;

• Gossett v. Robinhood Financial, LLC, No. 21-cv-21293;

• Scarborough v. Robinhood Financial LLC, No. 23-cv-21572;

• Krumenacker v. Robinhood Financial, LLC, No. 21-cv-21343; and

• Quat v. Robinhood Financial, LLC, No. 21-cv-21404.

4. At the Status Conference, counsel for Robinhood requested three weeks to engage

in the pre-filing conferral process required by Local Rule 7.1 regarding Robinhood’s forthcoming

motion to compel arbitration.

5. The conferral process is well under way. Robinhood has been communicating with

all counsel of record for the Outstanding Securities Claims, except for one who has not yet

responded to Robinhood’s several attempts to get in contact by email and telephone. The

remaining counsel have responded to state their consent or objection to Robinhood’s forthcoming

motion to compel arbitration, or have affirmed that they are still conferring with their clients. 1

1
Robinhood will specify in the motion to compel arbitration each party’s final position on
consenting or objecting to arbitration.
2
Case 1:21-md-02989-CMA Document 704 Entered on FLSD Docket 10/09/2024 Page 3 of 5

6. The conferral process has also led to substantive settlement negotiations. As a

result of these negotiations, Robinhood expects that at least some of the Outstanding Securities

Claims will be resolved and dismissed before Robinhood files its motion to compel arbitration.

For example, Robinhood and Plaintiff Damon Muncy have already stipulated to the dismissal with

prejudice of Mr. Muncy’s outstanding securities claims. See Joint Stip. of Voluntary Dismissal

with Prejudice [ECF No. 703].

7. Given the ongoing nature of the conferral process and the settlement negotiations

associated with that process, Robinhood respectfully suggests that the Court establish a deadline

of December 9, 2024, for Robinhood to file its motion to compel arbitration. This will give the

parties sufficient time to continue investigating the individual claims and finalize any successful

settlement negotiations prior to the filing of Robinhood’s motion.

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Case 1:21-md-02989-CMA Document 704 Entered on FLSD Docket 10/09/2024 Page 4 of 5

Dated: October 9, 2024 Respectfully submitted,

/s/ Samuel A. Danon
HUNTON ANDREWS KURTH LLP
Samuel A. Danon (FBN 892671)
María Castellanos Alvarado (FBN 116545)
Tom K. Schulte (FBN 1025692)
333 S.E. 2nd Avenue, Suite 2400
Miami, Florida 33131
Tel.: (305) 810-2500
Fax: (305) 810-2460
sdanon@huntonak.com
mcastellanos@huntonak.com
tschulte@huntonak.com

CRAVATH, SWAINE & MOORE LLP
Antony L. Ryan (pro hac vice)
Kevin J. Orsini (pro hac vice)
Brittany L. Sukiennik (pro hac vice)
Two Manhattan West
375 Ninth Avenue
New York, NY 10001
Tel.: (212) 474-1000
Fax: (212) 474-3700
aryan@cravath.com
korsini@cravath.com
bsukiennik@cravath.com

Counsel for Robinhood Financial LLC,
Robinhood Securities, LLC, and Robinhood
Markets, Inc.

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Case 1:21-md-02989-CMA Document 704 Entered on FLSD Docket 10/09/2024 Page 5 of 5

CERTIFICATE OF SERVICE

I certify that on October 9, 2024, I electronically filed a true and correct copy of the

foregoing via CM/ECF, which will send notice to all counsel of record.

/s/ Samuel A. Danon

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