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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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Issuer
Source documents
Document type
Gov.Uscourts.Flsd.590042.571.4
Case
Gov.Uscourts.Flsd.590042.571.4

Cite this document

“Exhibit C — Case 1:21-md-02989-CMA (Document 571-4).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flsd-590042-571-4/, SHA-256 50d4a9637ca75960b1a2e2feaa07c6485987cc3a794e5c905c4f42425436ef16.

Full text

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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


File and source

File
gov.uscourts.flsd.590042.571.4.pdf
Size
676,197 bytes
SHA-256
50d4a9637ca75960b1a2e2feaa07c6485987cc3a794e5c905c4f42425436ef16
Our copy
gov.uscourts.flsd.590042.571.4.pdf
Original
archive.org
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