[Proposed] Scheduling Order Re: Amendment of Complaint — In re January 2021 Short Squeeze Trading Litigation (Dkt. 495-1, S.D. Fla.)

Summary

A [Proposed] Scheduling Order Re: Amendment of Complaint in In re: January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA (Case No. 21-2989-MDL-ALTONAGA/Torres, Document 495-1, 2 pages), in the U.S. District Court for the Southern District of Florida, entered July 12, 2022. The order recites that Robinhood's motion to dismiss the Consolidated Class Action Complaint is under submission and that the House Committee on Financial Services' Majority Staff Report, GAME STOPPED, issued June 24, 2022, references evidence Plaintiffs have never seen. Drafted for entry under the name of Chief U.S. District Judge Cecilia M. Altonaga, Plaintiffs would provide the proposed First Amended Complaint by August 5, 2022, Defendants would say by August 12, 2022 whether they consent, and filing would follow by August 17, 2022, or a motion for leave by August 19, 2022.

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Case 1:21-md-02989-CMA Document 495-1 Entered on FLSD Docket 07/12/2022 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: All Actions
                                                          Involving the Federal Securities Laws


                              [PROPOSED] SCHEDULING ORDER RE:
                                 AMENDMENT OF COMPLAINT

           WHEREAS, the motion of Robinhood Markets, Inc., Robinhood Financial LLC, and

    Robinhood Securities, LLC (“Defendants”) to dismiss the Consolidated Class Action Complaint

    (“Complaint”) filed by Lead Plaintiff Blue Laine-Beveridge on behalf of a proposed investor Class

    (“Plaintiffs”) is under submission;

           WHEREAS, prior to filing the Complaint, pursuant to the statutory discovery stay imposed

    by the Private Securities Litigation Reform Act of 1995, Plaintiffs had no access to various

    defendants’ documents provided to the plaintiffs in the other MDL tranches;

           WHEREAS on June 24, 2022, the U.S. House of Representatives Committee on Financial

    Services issued a Majority Staff Report entitled: “GAME STOPPED: How the Meme Stock

    Market Event Exposed Troubling Business Practices, Inadequate Risk Management, and the Need

    for Regulatory and Legislative Reform” (“Report”); and

           WHEREAS the 138-page Report reproduces or references a broad range of evidence,

    obtained by Congress during the House Financial Services Committee’s extensive 16-month

    investigation, that Plaintiffs have never seen and believe are relevant to their claims in this action;

           For good cause shown, it is hereby ORDERED that:

           1.    Plaintiffs, through Lead Counsel, shall provide to Defendants a copy of the proposed
Case 1:21-md-02989-CMA Document 495-1 Entered on FLSD Docket 07/12/2022 Page 2 of 2




               First Amended Complaint (“FAC”) by August 5, 2022.

          2.   Defendants shall advise Lead Counsel by August 12, 2022, whether they consent to

               the filing of the FAC.

          3.   If Defendants consent to the filing of the FAC, Plaintiffs will file the FAC no later

               than August 17, 2022; Defendants shall file a motion to dismiss the FAC by

               September 14, 2022; Lead Plaintiff shall file an opposition to the motion to dismiss

               by October 12, 2022; and Defendants shall file their reply in further support of the

               motion to dismiss by October 26, 2022.

          4.   If Defendants do not consent to the filing of the FAC, Plaintiffs shall file a motion

               for leave to file the FAC by August 19, 2022, Defendants shall file their opposition

               brief by August 26, 2022, and Plaintiffs shall file a reply brief by September 2, 2022.




    Dated: ____________________, 2022                  ____________________________________
                                                       CECILIA M. ALTONAGA
                                                       CHIEF UNITED STATES DISTRICT JUDGE




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