Exhibit C — Case 1:21-md-02989-CMA (Document 571-4)
Summary
Exhibit C (Document 571-4) in Case 1:21-md-02989-CMA, entered on the FLSD docket 06/09/2023, is an email dated Monday, May 8, 2023 from Laurence Rosen to Jeff Klafter with the subject RE: RH Securities Fraud Options Claims, followed by the Friday, May 5, 2023 email from Jeff Klafter. Rosen writes that there is no intent to resolve the claims of any securities holders other than common stock holders at the May 17 mediation, and that no formal position has yet been determined on the claims raised in the complaint filed in California and transferred to the MDL in Miami. The May 5, 2023 email asks for confirmation that the options claims of the members of the alleged options class will not be settled or compromised.
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- Gov.Uscourts.Flsd.590042.571.4
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- Gov.Uscourts.Flsd.590042.571.4
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“Exhibit C — Case 1:21-md-02989-CMA (Document 571-4).”
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Case 1:21-md-02989-CMA Document 571-4 Entered on FLSD Docket 06/09/2023 Page 1 of 4 EXHIBIT C Case 1:21-md-02989-CMA Document 571-4 Entered on FLSD Docket 06/09/2023 Page 2 of 4 Friday, June 9, 2023 at 11:47:06 Eastern Daylight Time Subject: RE: RH Securities Fraud Options Claims Date: Monday, May 8, 2023 at 5:04:18 PM Eastern Daylight Time From: Laurence Rosen To: Jeff Klafter cc: maurice@pessahgroup.com, Stuart Chelin Attachments: image001.png, image002.jpg Report This Email FAQ Agio Phishing Protection Dear Mr. Klafter: Thank you for your email concerning our upcoming mediation. We do not intend to resolve the claims of any securities +holders other than common stock holders at the May 17 mediation. We have not yet determined what our formal position will be as to the claims raised in the complaint you filed in California and which was transferred to our MDL in Miami. Very truly yours, LAURENCE ROSEN THE ROSEN LAW Fir, P.A. 275 Madison Avenue, 40th Floor New York, NY 10016 Direct: (646) 437-7780 Main: (212) 686-1060 Fax: (212) 202-3827 Email: lrosen@rosenlegal.com ~ | The Rosen Law Firm Ranked 2nd in the nation for number of securities class action settlements in 2021 by ISS Securities Class Action Services. 500 LEADING PLAINTIFF FINANCIAL LAWYERS Page 1 of 3 Case 1:21-md-02989-CMA Document 571-4 Entered on FLSD Docket 06/09/2023 Page 3 of 4 From: Jeff Klafter <jak@klafterlesser.com> Sent: Friday, May 5, 2023 5:02 PM To: Laurence Rosen <Irosen@rosenlegal.com> Cc: maurice@pessahgroup.com; Stuart Chelin <stuart@chelinlaw.com> Subject: RH Securities Fraud Options Claims [EXTERNAL EMAIL} Larry, As you are no doubt aware, we filed a securities action on behalf of a class of option holders who held options in certain affected securities as of the close of trading on January 27, 2021. The putative options class sold their options, or had to let them expire, at a loss. Lead Plaintiff motions in our action are not due until June 9, 2023. You are due to participate in a Court-ordered mediation on May 17, 2023. The case you have prosecuted is limited to only stockholders as of the close of trading on January 27, 2021. This has been consistent across the PSLRA notice you published, your Amended Complaint and the motion for class certification you filed last week. As we are pursuing claims on behalf of a different class which was harmed by the same underlying conduct which damaged your class, we are writing to obtain confirmation from you that you will not seek to settle or compromise the options claims of the members of our alleged class. If you do intend to seek a settlement or compromise on behalf of option- holders, or for whatever reason are unable to provide the confirmation we are requesting, we will seek appropriate relief from the Court. We hope to be appointed lead counsel for the options class, and, if you have not settled your stockholder claims by then, we would like to explore working in tandem with you to obtain an appropriate settlement from Robinhood covering both the stockholder and option holder claims. Your prompt response to this email would be appreciated. Should you wish to hold a conference call with me and my co-counsels, please let us know. Jeffrey A. Kiafter KLAFTER LESSER LLP Two International Drive, Suite 350 Rye Brook, NY 10573 (914) 934-9200 x 301 Fax: (914) 934-9220 The information in this transmittal may be legally privileged, confidential, and/or otherwise protected by law from disclosure, and is intended only for the recipient(s) listed above. If you are neither the intended recipient(s) nor a person responsible for the delivery of this transmittal to the intended recipient(s), you are hereby notified that any distribution or copying of this transmittal is prohibited. If you have received this transmittal in error, please notify Klafter Lesser LLP immediately at (914) 934- 9200 or by return e-mail and take the steps necessary to delete it completely from your computer system. Thank you. Page 2 of 3 Case 1:21-md-02989-CMA Document 571-4 Entered on FLSD Docket 06/09/2023 Page 4 of 4 The information in this transmittal may be legally privileged, confidential, and/or otherwise protected by law from disclosure, and is intended only for the recipient(s) listed above. If you are neither the intended recipient(s) nor a person responsible for the delivery of this transmittal to the intended recipient(s), you are hereby notified that any distribution or copying of this transmittal is prohibited. If you have received this transmittal in error, please notify Klafter Lesser, LLP immediately at (914) 934-9200 or by return e-mail and take the steps necessary to delete it completely from your computer system. Thank you. Page 3 of 3
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