[Proposed] Order Appointing Lead Plaintiff (Cody Todd) and Approving Selection of Lead Counsel — In re January 2021 Short Squeeze Trading Litigation (Dkt. 26-6, S.D. Fla.)

Summary

A [Proposed] Order Appointing Lead Plaintiff and Approving Selection of Lead Counsel in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA (Case No. 21-2989-MDL-ALTONAGA, Document 26-6, 2 pages), in the Southern District of Florida, entered April 5, 2021. The order recites that a PSLRA notice issued on February 2, 2021 and that on April 5, 2021 Movant Cody Todd moved to be appointed Lead Plaintiff and to approve The Rosen Law Firm, P.A. as Lead Counsel, and would appoint Movant as Lead Plaintiff as having the largest financial interest in this litigation. Drafted for entry under the name of U.S. District Judge Cecilia M. Altonaga, the order would vest Lead Counsel with preparing all pleadings, directing discovery, preparing the case for trial and engaging in settlement negotiations on behalf of Lead Plaintiffs and the Class.

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Case 1:21-md-02989-CMA Document 26-6 Entered on FLSD Docket 04/05/2021 Page 1 of 2




                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA

                               CASE NO. 21-2989-MDL-ALTONAGA



   In re: JANUARY 2021 SHORT SQUEEZE
   TRADING LITIGATION




             [PROPOSED] ORDER APPOINTING LEAD PLAINTIFF AND APPROVING
                            SELECTION OF LEAD COUNSEL



           WHEREAS, pursuant to the Private Securities Litigation Reform Act of 1995

   (“PSLRA”), the lead plaintiff has the sole authority to bring claims under the federal securities

   laws;

           WHEREAS, pursuant to the PSLRA, 15 U.S.C. § 78u-4(a)(3)(A)(i), on February 2, 2021

   a notice was issued to potential class members informing them of the action and their right to

   move to serve as lead plaintiff within 60 days of the date of the issuance of said notice;

           WHEREAS, on April 5, 2021, Movant Cody Todd (“Movant”), moved the Court to: (1)

   be appointed as Lead Plaintiff; and (2) approve Movant’s selection of The Rosen Law Firm, P.A.

   (“Rosen Law”) as Lead Counsel;

           WHEREAS, the PSLRA, provides, inter alia, that the most-adequate plaintiff to serve as

   lead plaintiff is the movant that has either filed a complaint or has made a motion in response to

   a notice and has the largest financial interest in the relief sought by the Class and satisfied the

   requirement of Fed. R. Civ. P. 23; and




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Case 1:21-md-02989-CMA Document 26-6 Entered on FLSD Docket 04/05/2021 Page 2 of 2




          WHEREAS, the Court finding that Movant has the largest financial interest in this action

   and prima facie satisfies the typicality and adequacy requirements of Fed. R. Civ. P. 23. See 15

   U.S.C. § 78u-4(a)(3)(B)(iii)(I);

          IT IS HEREBY ORDERED THAT:

                 APPOINTMENT OF LEAD PLAINTIFF AND LEAD COUNSEL

          1.      Pursuant to Section 21D(a)(3)(B) of the Exchange Act, 15 U.S.C. §78u-(a)(3)(B),

   Movant is appointed as Lead Plaintiff for the class as Movant has the largest financial interest in

   this litigation and otherwise satisfy the requirements of Fed. R. Civ. P. 23.

          2.      Pursuant to the PSLRA, Movant has sole authority to bring claims in the

   multidistrict litigation under the federal securities laws.

          3.      Movant’s choice of counsel is approved, and accordingly, Rosen Law is

   appointed Lead Counsel.

          4.      Lead Counsel, after being appointed by the Court, shall manage the prosecution of

   this litigation for claims under the federal securities laws. Lead Counsel is to avoid duplicative or

   unproductive activities and is hereby vested by the Court with the responsibilities that include,

   without limitation, the following: (1) to prepare all pleadings; (2) to direct and coordinate the

   briefing and arguing of motions in accordance with the schedules set by the orders and rules of

   this Court; (3) to initiate and direct discovery; (4) to prepare the case for trial; and (5) to engage

   in settlement negotiations on behalf of Lead Plaintiffs and the Class.

                                                  SO ORDERED:


   Dated ___________, 2021                        ____________________________________
                                                  HON. CECILIA M. ALTONAGA
                                                  UNITED STATES DISTRICT JUDGE




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