Joint Status Report and [Proposed] Scheduling Order, Federal Securities Action — In re January 2021 Short Squeeze Trading Litigation (Dkt. 428, S.D. Fla.)

Summary

A Joint Status Report and [Proposed] Scheduling Order in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA (Case No. 21-2989-MDL-ALTONAGA/Torres, Document 428, 2 pages), in the U.S. District Court for the Southern District of Florida, entered October 22, 2021, relating to the Federal Securities Action. After the October 15, 2021 Order appointing Blue Laine-Beveridge as Lead Plaintiff and The Rosen Law Firm, P.A. as Lead Counsel, Lead Counsel and counsel for Robinhood propose that the amended complaint be filed by November 30, 2021 and that Robinhood respond by January 7, 2022. If Robinhood moves to dismiss, the opposition would be due February 4, 2022 and the reply February 18, 2022, over the /s/ signatures of Laurence M. Rosen of The Rosen Law Firm and Samuel A. Danon of Hunton Andrews Kurth LLP.

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Case 1:21-md-02989-CMA Document 428 Entered on FLSD Docket 10/22/2021 Page 1 of 2




                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA

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


    In re: JANUARY 2021 SHORT SQUEEZE
    TRADING LITIGATION




   This Document Relates to the Federal Securities Action


             JOINT STATUS REPORT AND [PROPOSED] SCHEDULING ORDER


          WHEREAS, on October 15, 2021, the Court entered an Order appointing Blue Laine-

   Beveridge as Lead Plaintiff and approving the selection of The Rosen Law Firm, P.A. as Lead

   Counsel in the Federal Securities Tranche (ECF No. 420) (the “Lead Plaintiff Order”);

          WHEREAS, the Court’s Lead Plaintiff Order required Lead Counsel in the Federal

   Securities Tranche to confer and file a joint status report on or before October 22, 2021, “proposing

   procedural and/or other next steps the Court should take to ensure the just and efficient disposition

   of the federal securities cases in this MDL” (ECF No. 420);

          WHEREAS, Lead Counsel has conferred with counsel for Defendants Robinhood Markets,

   Inc., Robinhood Financial LLC and Robinhood Securities, LLC (together, “Robinhood”);

          NOW, THEREFORE, Lead Counsel and Counsel for Robinhood hereby stipulate and

   agree, and respectfully request that the Court enter an Order as follows:

          1. Lead Plaintiff shall file an amended complaint on or before November 30, 2021.

          2. Robinhood shall move to dismiss, answer or otherwise respond to Lead Plaintiff’s

              amended complaint on or before January 7, 2022.

          3. If Robinhood moves to dismiss the amended complaint, Lead Plaintiff shall file his

                                                    1
Case 1:21-md-02989-CMA Document 428 Entered on FLSD Docket 10/22/2021 Page 2 of 2




              opposition to the motion to dismiss on or before February 4, 2022, and Robinhood shall

              file its reply brief in support of its motion to dismiss on or before February 18, 2022.



   Respectfully submitted,


   /s/ Laurence M. Rosen                                /s/ Samuel A. Danon
   THE ROSEN LAW FIRM, P.A.                             HUNTON ANDREWS KURTH LLP
   Laurence M. Rosen, Esq. (FBN 0182877)                Samuel A. Danon (FBN 892671)
   Phillip Kim, Esq.                                    Gustavo Javier Membiela (FBN 513555)
   Robin Howald, Esq.                                   María Castellanos Alvarado (FBN 116545)
   Erica Stone, Esq.                                    333 S.E. 2 Avenue, Suite 2400 Miami, FL
   Michael Cohen, Esq.                                  33131
   275 Madison Avenue, 40th Floor                       Telephone: (305) 810-2500
   New York, New York 10016                             Facsimile: (305) 810-2460
   Telephone: (212) 686-1060                            sdanon@huntonak.com
   Facsimile: (212) 202-3827                            gmembiela@huntonak.com
   lrosen@rosenlegal.com                                mcastellanos@hunton.com
   pkim@rosenlegal.com
   rhowald@rosenlegal.com                               CRAVATH, SWAINE & MOORE LLP
   estone@rosenlegal.com                                Antony L. Ryan
   mcohen@rosenlegal.com                                Kevin J. Orsini
                                                        Brittany L. Sukiennik
    Counsel for Lead Plaintiff                          825 Eighth Avenue
                                                        New York, NY 10019
                                                        Telephone: (212) 474-1000
                                                        Facsimile: (212) 474-3700
                                                        aryan@cravath.com
                                                        korsini@cravath.com
                                                        bsukiennik@cravath.com

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




   SO ORDERED this ___ day of ____________, 2021.



                                                _________________________________
                                                The Honorable Cecilia M. Altonaga
                                                Chief United States District Judge



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