Affidavit of Laurence Rosen (Dkt. 601.1)

Summary

The Declaration of Laurence M. Rosen in Support of Joint Status Report in Response to the Court's August 9, 2023 Order (ECF589) (Document 601-1) in In re January 2021 Short Squeeze Trading Litigation, Case 1:21-md-02989-CMA, was executed August 23, 2023 and entered on the FLSD docket 08/23/2023. Rosen, Managing Partner of The Rosen Law Firm, P.A., Lead Counsel for Lead Plaintiff Blue Laine-Beveridge, states that emails went to plaintiffs' counsel on August 11, 2023, August 17, 2023 and August 22, 2023. The declaration lists Diamond v. Robinhood Financial, LLC, Lagmanson et al. v. Robinhood Markets, Inc. and Carrasco v. Robinhood Financial LLC as cases whose counsel have not responded, and identifies Gatz v. Robinhood Financial, LLC from the Northern District of Illinois. It adds that the parties in the Eisen case intend to voluntarily dismiss the action.

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Case 1:21-md-02989-CMA Document 601-1 Entered on FLSD Docket 08/23/2023 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-2989-MDL-ALTONAGA/Damian

In re: JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION

This Document Relates to: All Actions Involving the Federal Securities Laws

DECLARATION OF LAURENCE M. ROSEN IN SUPPORT OF
JOINT STATUS REPORT
IN RESPONSE TO THE COURT’S AUGUST 9, 2023 ORDER (ECF589)
I, Laurence M. Rosen, hereby declare under penalty of perjury:

1. Iam the Managing Partner of The Rosen Law Firm, P.A., Lead Counsel for Lead Plaintiff
Blue Laine-Beveridge, named plaintiffs Abraham Huacuja, Ava Bernard, Brendan Clarke, Brian
Harbison, Cecilia Rivas, Doi Nguyen, Joseph Gurney, Marcel Poirier, Sandy Ng, Santiago Gil
Bohorquez, and Thomas Cash (collectively “Plaintiffs’’).

2. I make this Declaration in support of the Joint Status Report In Response To The Court’s
August 9, 2023 Order (ECF589) (the “Status Order’).

3. I am an attorney duly licensed to practice in the State of Florida and before this
Court. I have personal knowledge of the matters set forth herein and, if called upon, I could and
would completely testify thereto.

4. After doing an independent search for any additional cases alleging federal
securities claims, on August 11, 2023, I emailed all of the plaintiffs’ counsel in the cases
enumerated in the Status Order as consolidated into the above-styled MDL Federal Securities Law

Tranche and asked that counsel provide responses to the four questions presented by the Court for

inclusion of their answers in a joint status report. My email attached the Court’s Status Order.
Case 1:21-md-02989-CMA Document 601-1 Entered on FLSD Docket 08/23/2023 Page 2 of 3

5. Attached hereto as Exhibit A is a true and correct copy the August 11, 2023, email.

6. On August 17, 2023, I sent a follow up email to those counsel that did not respond
to my August 11, 2023, email requesting that they please email to me responses to the Court’s four
questions for inclusion in a joint status report.

7. Attached hereto as Exhibit B is a true and correct copy of the second email I sent
on August 17, 2023.

8. On August 22, 2023, I emailed all counsel (to whom I sent the August 11, 2023
email), enclosing for their review, a draft of the joint status report that I intended to file with the
Court on behalf of plaintiffs, asking them to comment and provide any suggested changes.
Attached as Exhibit C is the August 22, 2023, email to all plaintiffs’ counsel.

9. To date, counsel for the following cases have not responded to any of my August 11,
17 or 22, 2023 emails: (Diamond v. Robinhood Financial, LLC, et al., No. 21-cv-21263; Lagmanson
et al. v. Robinhood Markets, Inc., et al., No. 21-cv-21298; and Carrasco v. Robinhood Financial
LLC, et al., No. 21-cv-22702).

10. On August 22, 2023, counsel for Robinhood brought to my attention that another
case, not previously identified by the Court’s Status Order had been brought in the Northern District
of Illinois and consolidated into this MDL. That case is Gatz v. Robinhood Financial, LLC, No. 1:21-
cv-00490 which was originally filed in Northern District of Illinois.

11. On August 22, 2023, I telephoned Mr. Gatz, an attorney who filed the case pro se,
and also emailed him a copy of the Status Order.

12. Mr. Gatz then stated to me his responses to the Court’s four questions for inclusion

in the Joint Status Report.
Case 1:21-md-02989-CMA Document 601-1 Entered on FLSD Docket 08/23/2023 Page 3 of 3

13. Attached as Exhibit D is a list of all fourteen cases consolidated in the MDL that
alleged federal securities laws claims showing the various other types of claims alleged in each
complaint (State Law, Antitrust, Other Brokers), a list of the defendants named in the actions, and
the names and email addresses of counsel for the parties in these actions.

14. On August 10, 2023, I contacted Adrian Gucovschi, attorney for the plaintiff in Eisen
v. Apex Clearing Corp., et al., No. 21-cv-21665 to determine the status of the Eisen case.

15. Mr. Gucovschi has informed me that the parties in the Eisen case intend to voluntarily

dismiss the action. Counsel for the defendants in the Kisen action have confirmed that.

I declare under penalty of perjury under the laws of the United States of America and the

State of Florida that the foregoing is true and correct.

Executed: August 23, 2023
THE ROSEN LAW FIRM, P.A.
/s/Laurence M. Rosen

Laurence M. Rosen, Esq.
Fla. Bar No. 0182877

CERTIFICATE OF SERVICE

I hereby certify that on August 23, 2023, a true and correct copy of the foregoing document
was served by CM/ECF to the parties registered to the Court’s CM/ECF system.

/s/Laurence M. Rosen


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