Exhibit 2: [Proposed] Scheduling Order, The Federal Securities Tranche (Document 515-2)

Summary

Exhibit 2 to Document 515 in Case 1:21-md-02989-CMA (Document 515-2), entered on the FLSD docket 10/07/2022, is a second [Proposed] Scheduling Order for the Federal Securities Tranche of In re: January 2021 Short Squeeze Trading Litigation, Case No. 21-2989-MDL-ALTONAGA/Torres, which would assign the case to a modified complex case management track allowing 11 months of fact discovery. Its dated deadlines, from December 19, 2022 to April 16, 2024, cover joinder and amendment, mediation, class certification expert reports and motions, document production, fact and expert discovery, and summary judgment and Daubert motions. The parties propose oppositions to summary judgment and Daubert motions 60 days after filing (June 17, 2024) and replies 45 days after opposition (August 1, 2024), and the order closes with the name and title of Cecilia M. Altonaga, United States District Judge.

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Issuer: Source documents
Document type: Gov.Uscourts.Flsd.590042.515.2
Case: Gov.Uscourts.Flsd.590042.515.2

Cite this document

“Exhibit 2: [Proposed] Scheduling Order, The Federal Securities Tranche (Document 515-2).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flsd-590042-515-2/, SHA-256 db69f24e12925cf5436cce5071afe6b956e9f77a764b588cf274e05f75029546.

Full text

Case 1:21-md-02989-CMA Document 515-2 Entered on FLSD Docket 10/07/2022 Page 1 of 5

Exhibit 2
Case 1:21-md-02989-CMA Document 515-2 Entered on FLSD Docket 10/07/2022 Page 2 of 5

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 Tranche

[PROPOSED] SCHEDULING ORDER

Pursuant to Rule 16(b) of the Federal Rules of Civil Procedure, Local Rule 16.1(b)(3) of the

Local Rules of the United States District Court for the Southern District of Florida, upon consideration

of the Joint Planning and Scheduling Report filed by the parties in the above-styled matter, and this

Court being otherwise fully advised in the premises, it is:

ORDERED AND ADJUDGED as follows:

A. Track:

This case shall be assigned to a modified complex case management track that allows for 11 months

of fact discovery from the date of the scheduling order.

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Case 1:21-md-02989-CMA Document 515-2 Entered on FLSD Docket 10/07/2022 Page 3 of 5

B. The parties shall adhere to the following schedule:

Deadline to join additional parties or to file motion to amend
December 19, 2022
pleadings.
The parties shall select a mediator pursuant to Local Rule 16.2, shall
schedule a time, date and place for mediation, and shall jointly file a
proposed order scheduling mediation in the form specified on the
Court’s website, http://www.flsd.uscourts.gov. If the parties cannot
agree on a mediator, the Clerk shall designate a certified mediator on
a blind rotation basis. Counsel for all parties shall familiarize December 19, 2022
themselves with and adhere to all provisions of Local Rule 16.2.
Within seven (7) days of mediation, the parties are required to file a
mediation report with the Court. Pursuant to the procedures outlined
in the CM/ECF Administrative Procedures, the proposed order must
be emailed to altonaga@flsd.uscourts.gov in Word format.
January 13, 2023
Plaintiffs shall file any expert witness reports on issues of class
certification.

Defendants shall file any expert witness reports in opposition on February 27, 2023
issues of class certification.

Plaintiffs shall file any reply expert witness reports on issues of class March 29, 2023
certification.
Depositions of expert witnesses on issues of class certification shall
be completed.
April 28, 2023
Plaintiffs shall file motion for class certification. The parties shall file
any Daubert motions related to expert witnesses on issues of class
certification.
Parties shall substantially complete production of documents. Parties
agree to commence producing documents on a rolling basis as is May 1, 2023
possible in advance of this deadline.
Defendants shall file opposition to Plaintiffs’ motion for class
June 7, 2023
certification and the parties shall file any oppositions to Daubert
motions relating to class certification.
Plaintiffs shall file reply in support of motion for class certification
June 30, 2023
and the parties shall file any replies in support of Daubert motions
relating to class certification.

Parties must have completed mediation and filed a mediation report. August 14, 2023

Close of fact discovery including depositions. September 18, 2023

Plaintiffs shall provide expert witness disclosures as required by Fed.
October 18, 2023
R. Civ. P. 26(a)(2)(A)-(C).

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Case 1:21-md-02989-CMA Document 515-2 Entered on FLSD Docket 10/07/2022 Page 4 of 5

Defendants shall provide expert witness disclosures as required by
December 18, 2023
Fed. R. Civ. P. 26(a)(2)(A)-(C).

Plaintiffs shall provide any rebuttal expert reports. January 18, 2024

All discovery, including expert depositions, is completed.
Depositions of expert witnesses shall not commence until after February 16, 2024
Plaintiffs provide rebuttal expert reports, if any.
All summary judgment and Daubert motions (which include motions
to strike experts) are filed. Each motion shall be governed by Local
Rule 7.1. Leave to exceed the 20-page limit in Local Rule 7.1(c) will
be granted if the issues addressed in either the summary judgment
motion or any Daubert motions cannot be addressed within those
page limits. The parties are reminded that Daubert motions must
April 16, 2024
contain the Local Rule 7.1(a)(3) certification.

The parties further propose that all oppositions to summary judgment
motions and Daubert motions be due 60 days after such motions are
filed (June 17, 2024) and replies be due 45 days after opposition
(August 1, 2024).

45 Days After a Decision is
Parties submit joint pre-trial stipulation, proposed jury instructions
Rendered on Dispositive
and verdict form, or proposed findings of fact and conclusions of law,
Motions Including Summary
as applicable.
Judgment

Motions in limine directed to trial evidence due. The parties are
14 Days Before
reminded that motions in limine must contain the Local Rule
Commencement of Trial.
7.1(a)(3) certification.

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Case 1:21-md-02989-CMA Document 515-2 Entered on FLSD Docket 10/07/2022 Page 5 of 5

IT IS FURTHER ORDERED as follows:

Pretrial motions will be resolved, to the extent feasible, within _ days of the close of

fact discovery. The pretrial conference will be held at , on .

Trial will begin at , on .

DONE AND ORDERED in Chambers, at Miami-Dade County, Florida, this _____ day

of ___________________, 2022.

______________________________________

CECILIA M. ALTONAGA
UNITED STATES DISTRICT JUDGE

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