Exhibit D — Case 1:21-md-02989-CMA (Document 571-5)

Summary

Exhibit D (Document 571-5) in Case 1:21-md-02989-CMA, entered on the FLSD docket 06/09/2023, is an email dated Wednesday, May 10, 2023 from Stuart Chelin, addressed to Laurence and Kevin and copied to Jeff Klafter and Maurice Pessah, with the subject MDL 2989---Mediation Scheduled for May 17, 2023. It states that the Options Action, Scarborough et al. v. Robinhood Markets LLC et al., originally filed in the Central District of California, is now part of MDL No. 2989 as Case No. 23-21572-CIV-ALTONAGA. The email asks for agreement to postpone the Mediation until Lead Counsel and Lead Plaintiff for the Options Class have been determined, noting that Lead Plaintiff motions in the Options Action must be filed no later than June 5, 2023. It is signed Stuart N. Chelin, Attorney at Law, Encino, CA.

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Case 1:21-md-02989-CMA Document 571-5 Entered on FLSD Docket 06/09/2023 Page 1 of 3

EXHIBIT D
Case 1:21-md-02989-CMA Document 571-5 Entered on FLSD Docket 06/09/2023 pags eran 3

Friday, June 9, 2023 at 11:44:22 Eastern D

Subject: MDL 2989---Mediation Scheduled for May 17, 2023

Date: Wednesday, May 10, 2023 at 5:16:31 PM Eastern Daylight Time
From: Stuart Chelin

To: Laurence Rosen, korsini@cravath.com

cc: Jeff Klafter, Maurice Pessah

Attachments: image001.jpg

| External (stuart@cheliniaw.com)
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Dear Laurence and Kevin,

As you know, Messrs. Pessah, Klafter and | have filed, and served, a Complaint in Scarborough et al. v.
Robinhood Markets LLC et al. (the “Options Action”).

The Options Action, which was originally filed in the Central District of California, has been transferred, and is
now a part of MDL No. 2989 (the “MDL"), Case No. 23-21572-CIV-ALTONAGA. The Options Action asserts the
same securities fraud claims which are now pending before the Court in the MDL. However, the Options
Action seeks redress on behalf of a class which is distinct from the existing securities action currently pending
under the Securities Tranche of the MDL (“Stock Action”). The Stock Action asserts claims on behalf of those
persons who held the affected common stocks at issue as of the close of trading on January 27, 2021, and
sold such shares at a loss between January 28, 2021, and February 4, 2001 (“Stock Class”). The Options
Action asserts claims on behalf of those persons who held call options to purchase the restricted securities at
issue as of the close on January 27, 2021, and who either sold those options, or had them expire, resulting in
a loss between January 28, 2021, and February 19, 2021 (“Options Class”). Further, the basket of affected
options in the Options Action largely overlaps the basket of affected stocks in the Stock Action except that the
affected options basket (i) includes options to purchase American Airlines Group Inc. (NASDAQ: AAL), and (ii)
does not include options to purchase Koss Corp. (“KOSS”), Tootsie Roll Industries Inc. (“TR”), or Trivago N.V.

We are aware that the Court has entered an order requiring each of you to participate in a mediation on May
17, 2023 in an effort to settle the securities fraud claims sustained by the Court (“Mediation”). It is our
opinion that, given the imbrication of the securities fraud allegations in the Options Action and those in the
Stock Action, it would be most efficient and appropriate for the Mediation to include the participation of
counsel for both the Options Class and the Stock Class. However, the Options Action is governed by the
procedures of the Private Securities Litigation Reform Act of 1995 (“PSLRA”), and, given the publication date
of the notice of filing of the Options Action pursuant to the PSLRA, Lead Plaintiff motions in the Options
Action must be filed no later than June 5, 2023. Messrs. Pessah, Klafter and | intend on bringing a motion for
appointment of our clients as Lead Plaintiffs and us as Lead Counsel for the Options Action.

We are writing to seek your agreement to postpone the Mediation until after Lead Counsel and Lead Plaintiff
for the Options Class have been determined so that the Mediation can proceed with the inclusion of Lead
Plaintiffs for the Options Class as well as for the Stock Class. If you are in agreement with this, we would all
need to coordinate an approach to have the Court modify its Mediation order to specify a reasonable new
Mediation schedule.

We look forward to hearing your position on this issue.

Page 1 of 2
Case 1:21-md-02989-CMA Document 571-5 Entered on FLSD Docket 06/09/2023 Page 3 of 3

Sincerely,

Stuart N. Chelin
Attorney at Law

LAW FIRM

16133 Ventura Boulevard, Suite 700 Encino, CA 91436
O: 310.556.9664 | C: 310.776.6500 | E: stuart@chelinlaw.com

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached
to it may contain confidential information that is legally privileged. If you are not the intended recipient, or a person
responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution
or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have
received this transmission in error, please immediately notify the sender. Please destroy the original transmission and
its attachments without reading or saving in any manner. Thank you, CHELIN LAW FIRM.

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