Sandoz v. Waterdrop Inc. et al
Plaintiff: Sidney Sandoz
Defendant: Waterdrop Inc., Peng Shen, Kangping Shi, Nina Zhou, Kai Huang, Haiyang Yu, Yao Hu, Guang Yang, Colleen A. De Vries, Cogency Global Inc., Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC, BofA Securities, Inc., China Merchants Securities (HK) Co., Limited, CLSA Limited and Haitong International Securities Company Limited
Petitioner: On Tsang, Drew Bahl and William Gallo
Lead Plaintiff: Qi Mi
Alternative Dispute Resolution (Adr) Provider: Harold Weber
Case Number: 1:2021cv07683
Filed: September 14, 2021
Court: US District Court for the Southern District of New York
Presiding Judge: Vernon S Broderick
Nature of Suit: Securities/Commodities
Cause of Action: 15 U.S.C. ยง 77 Securities Fraud
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on April 22, 2022. A more recent docket listing may be available from PACER.

Date Filed Document Text
April 22, 2022 Filing 55 DECLARATION of Michael B. Carlinsky in Support re: #53 MOTION to Dismiss the Amended Class Action Complaint.. Document filed by BofA Securities, Inc., Cogency Global Inc., Colleen A. De Vries, Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC, Waterdrop Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D).(Carlinsky, Michael)
April 22, 2022 Filing 54 MEMORANDUM OF LAW in Support re: #53 MOTION to Dismiss the Amended Class Action Complaint. . Document filed by BofA Securities, Inc., Cogency Global Inc., Colleen A. De Vries, Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC, Waterdrop Inc.. (Attachments: #1 Appendix).(Carlinsky, Michael)
April 22, 2022 Filing 53 MOTION to Dismiss the Amended Class Action Complaint. Document filed by BofA Securities, Inc., Cogency Global Inc., Colleen A. De Vries, Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC, Waterdrop Inc...(Carlinsky, Michael)
February 21, 2022 Filing 52 AMENDED COMPLAINT amending #1 Complaint, against BofA Securities, Inc., CLSA Limited, China Merchants Securities (HK) Co., Limited, Cogency Global Inc., Colleen A. De Vries, Goldman Sachs (Asia) L.L.C., Haitong International Securities Company Limited, Yao Hu, Kai Huang, Morgan Stanley & Co. LLC, Peng Shen, Kangping Shi, Waterdrop Inc., Guang Yang, Haiyang Yu, Nina Zhou with JURY DEMAND.Document filed by Qi Mi. Related document: #1 Complaint,. (Attachments: #1 Exhibit A, Mi Certificate).(Miller, Kim)
December 22, 2021 Opinion or Order Filing 51 STIPULATION AND ORDER REGARDING TIME TO FILE AMENDED COMPLAINT AND MOTION TO DISMISS: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, subject to theCourts approval:1. Lead Plaintiff shall file an amended complaint (the "Amended Complaint") on or before February 21, 2022; 2. The Served Defendants shall answer or otherwise respond to Lead Plaintiff's Amended Complaint by April 22, 2022; 3. Lead Plaintiff shall file any opposition to such motion on or before June 21, 2022; and, 4. The Served Defendants shall file any reply in support of such motion on or before July 21, 2022. SO ORDERED. ( Amended Pleadings due by 2/21/2022., Responses due by 6/21/2022, Replies due by 7/21/2022.) (Signed by Judge Vernon S. Broderick on 12/22/2021) (tg)
December 21, 2021 Filing 50 PROPOSED STIPULATION AND ORDER. Document filed by Waterdrop Inc...(Carlinsky, Michael)
December 14, 2021 Opinion or Order Filing 49 ORDER GRANTING MOTION FOR LEAVE TO WITHDRAW AS COUNSEL granting #47 Motion to Withdraw as Attorney. Upon consideration of the Motion for Leave to Withdraw as Counsel, and for good cause shown, it is HEREBY ORDERED THAT Samuel H. Rudman and David A. Rosenfeld of Robbins Geller Rudman & Dowd LLP are hereby withdrawn as counsel of record. The Clerk of the Court is directed to remove the above-named attorneys and law firm from the docket as well as the ECF Service List. IT IS SO ORDERED. Attorney David Avi Rosenfeld and Samuel Howard Rudman terminated. (Signed by Judge Vernon S. Broderick on 12/14/2021) (vfr)
December 14, 2021 ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #48 Proposed Order was reviewed and approved as to form. (km)
December 14, 2021 ***NOTICE TO COURT REGARDING NOTICE OF VOLUNTARY DISMISSAL Document No. #46 Notice of Voluntary Dismissal was reviewed and referred to Judge Vernon S. Broderick for approval for the following reason(s): the plaintiff(s) filed their voluntary dismissal and it did not dismiss all of the parties or the action in its entirety. (km)
December 13, 2021 Filing 48 PROPOSED ORDER. Document filed by On Tsang. Related Document Number: #47 ..(Rosenfeld, David) Proposed Order to be reviewed by Clerk's Office staff.
December 13, 2021 Filing 47 MOTION for David A. Rosenfeld to Withdraw as Attorney . Document filed by On Tsang..(Rosenfeld, David)
December 13, 2021 Filing 46 NOTICE OF VOLUNTARY DISMISSAL pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff(s) and or their counsel(s), hereby give notice that the above-captioned action is voluntarily dismissed, without prejudice and without costs against the defendant(s) All Defendants. Document filed by Sidney Sandoz. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Rosenfeld, David)
December 8, 2021 Opinion or Order Filing 45 ORDER GRANTING MOTION OF QI MI FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF LEAD PLAINTIFFS SELECTION OF LEAD COUNSEL terminating #26 Motion to Appoint ; terminating #26 Motion to Appoint Counsel ; terminating #32 Motion to Appoint ; terminating #35 Motion to Appoint ; granting #18 Motion to Appoint ; granting #18 Motion to Appoint Counsel ; terminating #22 Motion to Appoint ; terminating #22 Motion to Appoint Counsel. Having considered the motion of Mr. Qi Mi for Appointment as Lead Plaintiff and Approval of his Selection of Lead Counsel (the "Motion"), and good cause appearing therefore, IT IS HEREBY ORDERED THAT: 1. The Motion is GRANTED; 2. The Court, having considered the provisions of the Private Securities Litigation Reform Act of 1995, 15 U.S.C. 78z-1(a)(3)(B), appoints Mr. Qi Mi as Lead Plaintiff; and 3. Pursuant to 15 U.S.C. 77zu-1(a)(3)(B)(v), the Court approves Kahn Swick & Foti, LLC as Lead Counsel for the Class. SO ORDERED.. (Signed by Judge Vernon S. Broderick on 12/8/2021) (kv)
December 6, 2021 Filing 44 REPLY MEMORANDUM OF LAW in Support re: #18 MOTION to Appoint Qi Mi to serve as lead plaintiff(s) . MOTION to Appoint Counsel . . Document filed by Qi Mi..(Miller, Kim)
November 29, 2021 Filing 43 NOTICE of NON-OPPOSITION OF HAROLD WEBER TO COMPETING MOTIONS FOR APPOINTMENT AS LEAD PLAINTIFF AND APPROVAL OF LEAD COUNSEL. Document filed by Harold Weber..(Hasson, Laurence)
November 29, 2021 Filing 42 MEMORANDUM OF LAW in Support re: #18 MOTION to Appoint Qi Mi to serve as lead plaintiff(s) . MOTION to Appoint Counsel . And in Opposition to Competing Motions. Document filed by Qi Mi..(Miller, Kim)
November 29, 2021 Filing 41 NOTICE of Non-Opposition of William Gallo to Competing Motions for Appointment as Lead Plaintiff and Approval of Lead Counsel re: #32 MOTION to Appoint William Gallo to serve as lead plaintiff(s) .. Document filed by William Gallo..(Lieberman, Jeremy)
November 24, 2021 Filing 40 NOTICE of of Withdrawal re: #22 MOTION to Appoint On Tsang to serve as lead plaintiff(s) . MOTION to Appoint Counsel .. Document filed by On Tsang..(Rosenfeld, David)
November 16, 2021 Filing 39 NOTICE of Withdrawal re: #26 MOTION to Appoint DREW BAHL to serve as lead plaintiff(s) . MOTION to Appoint Counsel .. Document filed by Drew Bahl..(Kim, Phillip)
November 16, 2021 ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #25 Proposed Order was reviewed and approved as to form. (dt)
November 16, 2021 ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #33 Proposed Order was reviewed and approved as to form. (dt)
November 16, 2021 ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #21 Proposed Order was reviewed and approved as to form. (dt)
November 16, 2021 ***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #38 Proposed Order was reviewed and approved as to form. (dt)
November 15, 2021 Filing 38 PROPOSED ORDER. Document filed by Harold Weber. Related Document Number: #35 ..(Hasson, Laurence) Proposed Order to be reviewed by Clerk's Office staff.
November 15, 2021 Filing 37 MEMORANDUM OF LAW in Support re: #35 MOTION to Appoint HAROLD WEBER to serve as lead plaintiff(s) AND APPROVAL OF COUNSEL. . Document filed by Harold Weber. (Attachments: #1 Declaration of Lauren Hasson, #2 Exhibit A- Early Notice, #3 Exhibit B- Certification, #4 Exhibit C- Loss Chart, #5 Exhibit D- Assignment, #6 Exhibit E- Firm Resume).(Hasson, Laurence)
November 15, 2021 Filing 36 DECLARATION of Jeremy A. Lieberman in Support re: #32 MOTION to Appoint William Gallo to serve as lead plaintiff(s) .. Document filed by William Gallo. (Attachments: #1 Exhibit A - Loss Chart, #2 Exhibit B - Press Release, #3 Exhibit C - Certification, #4 Exhibit D - Movant Declaration, #5 Exhibit E - Pomerantz Firm Resume).(Lieberman, Jeremy)
November 15, 2021 Filing 35 MOTION to Appoint HAROLD WEBER to serve as lead plaintiff(s) AND APPROVAL OF COUNSEL. Document filed by Harold Weber..(Hasson, Laurence)
November 15, 2021 Filing 34 MEMORANDUM OF LAW in Support re: #32 MOTION to Appoint William Gallo to serve as lead plaintiff(s) . . Document filed by William Gallo..(Lieberman, Jeremy)
November 15, 2021 Filing 33 PROPOSED ORDER. Document filed by William Gallo. Related Document Number: #32 ..(Lieberman, Jeremy) Proposed Order to be reviewed by Clerk's Office staff.
November 15, 2021 Filing 32 MOTION to Appoint William Gallo to serve as lead plaintiff(s) . Document filed by William Gallo..(Lieberman, Jeremy)
November 15, 2021 Filing 31 NOTICE OF APPEARANCE by Jeremy Alan Lieberman on behalf of William Gallo..(Lieberman, Jeremy)
November 15, 2021 Filing 30 NOTICE OF APPEARANCE by Joseph Alexander Hood, II on behalf of William Gallo..(Hood, Joseph)
November 15, 2021 Filing 29 NOTICE OF APPEARANCE by Lesley Frank Portnoy on behalf of William Gallo..(Portnoy, Lesley)
November 15, 2021 Filing 28 NOTICE OF APPEARANCE by James Michael LoPiano on behalf of William Gallo..(LoPiano, James)
November 15, 2021 Filing 27 MEMORANDUM OF LAW in Support re: #26 MOTION to Appoint DREW BAHL to serve as lead plaintiff(s) . MOTION to Appoint Counsel . . Document filed by Drew Bahl. (Attachments: #1 Exhibit 1 - PSLRA Early Notice, #2 Exhibit 2 - PSLRA Cert., #3 Exhibit 3 - Loss Chart, #4 Exhibit 4 - Firm Resume).(Kim, Phillip)
November 15, 2021 Filing 26 MOTION to Appoint DREW BAHL to serve as lead plaintiff(s) ., MOTION to Appoint Counsel . Document filed by Drew Bahl. (Attachments: #1 Proposed Order).(Kim, Phillip)
November 15, 2021 Filing 25 PROPOSED ORDER. Document filed by On Tsang. Related Document Number: #22 ..(Rosenfeld, David) Proposed Order to be reviewed by Clerk's Office staff.
November 15, 2021 Filing 24 DECLARATION of David A. Rosenfeld in Support re: #22 MOTION to Appoint On Tsang to serve as lead plaintiff(s) . MOTION to Appoint Counsel .. Document filed by On Tsang. (Attachments: #1 Exhibit A - PSLRA Notice, #2 Exhibit B - Certification, #3 Exhibit C - Estimate of losses, #4 Exhibit D - Mr. Tsang's Declaration).(Rosenfeld, David)
November 15, 2021 Filing 23 MEMORANDUM OF LAW in Support re: #22 MOTION to Appoint On Tsang to serve as lead plaintiff(s) . MOTION to Appoint Counsel . . Document filed by On Tsang..(Rosenfeld, David)
November 15, 2021 Filing 22 MOTION to Appoint On Tsang to serve as lead plaintiff(s) ., MOTION to Appoint Counsel . Document filed by On Tsang..(Rosenfeld, David)
November 15, 2021 Filing 21 PROPOSED ORDER. Document filed by Qi Mi. Related Document Number: #18 ..(Miller, Kim) Proposed Order to be reviewed by Clerk's Office staff.
November 15, 2021 Filing 20 DECLARATION of Kim E. Miller in Support re: #18 MOTION to Appoint Qi Mi to serve as lead plaintiff(s) . MOTION to Appoint Counsel .. Document filed by Qi Mi. (Attachments: #1 Exhibit A - PSLRA Certification, #2 Exhibit B - Loss Chart, #3 Exhibit C - Statutory Notice, #4 Exhibit D - Mi Declaration, #5 Exhibit E - KSF Resume).(Miller, Kim)
November 15, 2021 Filing 19 MEMORANDUM OF LAW in Support re: #18 MOTION to Appoint Qi Mi to serve as lead plaintiff(s) . MOTION to Appoint Counsel . . Document filed by Qi Mi..(Miller, Kim)
November 15, 2021 Filing 18 MOTION to Appoint Qi Mi to serve as lead plaintiff(s) ., MOTION to Appoint Counsel . Document filed by Qi Mi..(Miller, Kim)
October 25, 2021 Filing 17 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Morgan Stanley Domestic Holdings, Inc., Other Affiliate Morgan Stanley Capital Management, LLC, Other Affiliate Morgan Stanley, Other Affiliate Mitsubishi UFJ Financial Group, Inc. for Morgan Stanley & Co. LLC. Document filed by Morgan Stanley & Co. LLC..(Rosenberg, Jonathan)
October 25, 2021 Filing 16 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent The Goldman Sachs Group, Inc. for Goldman Sachs (Asia) L.L.C.. Document filed by Goldman Sachs (Asia) L.L.C...(Rosenberg, Jonathan)
October 25, 2021 Filing 15 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent NB Holdings Corporation, Other Affiliate Bank of America Corporation, Other Affiliate Berkshire Hathaway Inc. for BofA Securities, Inc.. Document filed by BofA Securities, Inc...(Rudzin, Abby)
October 25, 2021 Filing 14 NOTICE OF APPEARANCE by Abby Faith Rudzin on behalf of BofA Securities, Inc., Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC..(Rudzin, Abby)
October 25, 2021 Filing 13 NOTICE OF APPEARANCE by Jonathan Rosenberg on behalf of BofA Securities, Inc., Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC..(Rosenberg, Jonathan)
October 20, 2021 Filing 12 SUMMONS RETURNED EXECUTED. Cogency Global Inc. served on 10/14/2021, answer due 11/4/2021. Service was accepted by Jolita Quinadara, Service of Process Intake Clerk. Document filed by Sidney Sandoz..(Rudman, Samuel)
October 20, 2021 Filing 11 SUMMONS RETURNED EXECUTED. Colleen A. De Vries served on 10/20/2021, answer due 11/10/2021. Service was accepted by Jacob J. Waldman, Attorney for Defendant. Document filed by Sidney Sandoz..(Rudman, Samuel)
October 14, 2021 Opinion or Order Filing 10 STIPULATION AND ORDER ADJOURNING DEFENDANTS' TIME TO RESPOND TO THE COMPLAINT. IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff and the Served Defendants, by and through their undersigned counsel, as follows: 1. The Served Defendants, and any Defendants that may be served with the complaint going forward, have no current obligation to respond to the complaint in this action. 2. No more than 14 days after lead counsel for plaintiff and lead plaintiff are chosen, lead counsel for plaintiff and counsel for the Served Defendants and any Defendants that may be served with the complaint going forward shall jointly submit to the Court a proposed schedule for the filing of a consolidated or amended complaint and for briefing of any motion to dismiss that consolidated or amended complaint. IT IS SO ORDERED. (Signed by Judge Vernon S. Broderick on 10/14/21) (yv)
October 13, 2021 Filing 9 PROPOSED STIPULATION AND ORDER. Document filed by Cogency Global Inc., Colleen A. De Vries, Waterdrop Inc...(Carlinsky, Michael)
September 28, 2021 Filing 8 SUMMONS RETURNED EXECUTED. Goldman Sachs (Asia) L.L.C. served on 9/23/2021, answer due 10/14/2021. Service was accepted by Daisy Montenegro, Service of Process Intake Clerk. Document filed by Sidney Sandoz..(Rudman, Samuel)
September 28, 2021 Filing 7 SUMMONS RETURNED EXECUTED. Morgan Stanley & Co. LLC served on 9/23/2021, answer due 10/14/2021. Service was accepted by Daisy Montenegro, Service of Process Intake Clerk. Document filed by Sidney Sandoz..(Rudman, Samuel)
September 28, 2021 Filing 6 SUMMONS RETURNED EXECUTED. Waterdrop Inc. served on 9/23/2021, answer due 10/14/2021. Service was accepted by Fidan Hasanbayli, Service of Process Intake Clerk. Document filed by Sidney Sandoz..(Rudman, Samuel)
September 28, 2021 Filing 5 SUMMONS RETURNED EXECUTED. BofA Securities, Inc. served on 9/23/2021, answer due 10/14/2021. Service was accepted by Robin Huttbanks, Service of Process Intake Clerk. Document filed by Sidney Sandoz..(Rudman, Samuel)
September 15, 2021 Filing 4 ELECTRONIC SUMMONS ISSUED as to BofA Securities, Inc., CLSA Limited, China Merchants Securities (HK) Co., Limited, Cogency Global Inc., Colleen A. De Vries, Goldman Sachs (Asia) L.L.C., Haitong International Securities Company Limited, Yao Hu, Kai Huang, Morgan Stanley & Co. LLC, Peng Shen, Kangping Shi, Waterdrop Inc., Guang Yang, Haiyang Yu, Nina Zhou..(gp)
September 15, 2021 CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Vernon S. Broderick. Please download and review the Individual Practices of the assigned District Judge, located at #https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #https://nysd.uscourts.gov/rules/ecf-related-instructions..(gp)
September 15, 2021 Magistrate Judge Sarah L. Cave is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (gp)
September 15, 2021 Case Designated ECF. (gp)
September 14, 2021 Filing 3 REQUEST FOR ISSUANCE OF SUMMONS as to Waterdrop Inc., Peng Shen, Kangping Shi, Nina Zhou, Kai Huang, Haiyang Yu, Yao Hu, Guang Yang, Colleen A. De Vries, Cogency Global Inc., Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. LLC, BofA Securities, Inc., China Merchants Securities (HK) Co., Limited, CLSA Limited and Haitong International Securities Company Limited, re: #1 Complaint,. Document filed by Sidney Sandoz..(Rudman, Samuel)
September 14, 2021 Filing 2 CIVIL COVER SHEET filed..(Rudman, Samuel)
September 14, 2021 Filing 1 COMPLAINT against BofA Securities, Inc., CLSA Limited, China Merchants Securities (HK) Co., Limited, Cogency Global Inc., Colleen A. De Vries, Goldman Sachs (Asia) L.L.C., Haitong International Securities Company Limited, Yao Hu, Kai Huang, Morgan Stanley & Co. LLC, Peng Shen, Kangping Shi, Waterdrop Inc., Guang Yang, Haiyang Yu, Nina Zhou. (Filing Fee $ 402.00, Receipt Number ANYSDC-25061013)Document filed by Sidney Sandoz..(Rudman, Samuel)

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Search for this case: Sandoz v. Waterdrop Inc. et al
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Plaintiff: Sidney Sandoz
Represented By: Samuel Howard Rudman
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Defendant: Waterdrop Inc.
Represented By: Michael Barry Carlinsky
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Defendant: Peng Shen
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Defendant: Kangping Shi
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Defendant: Nina Zhou
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Defendant: Kai Huang
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Defendant: Haiyang Yu
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Defendant: Yao Hu
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Defendant: Guang Yang
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Defendant: Colleen A. De Vries
Represented By: Michael Barry Carlinsky
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Defendant: Cogency Global Inc.
Represented By: Michael Barry Carlinsky
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Defendant: Goldman Sachs (Asia) L.L.C.
Represented By: Jonathan Rosenberg
Represented By: Abby Faith Rudzin
Represented By: Michael Barry Carlinsky
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Defendant: Morgan Stanley & Co. LLC
Represented By: Jonathan Rosenberg
Represented By: Abby Faith Rudzin
Represented By: Michael Barry Carlinsky
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Defendant: BofA Securities, Inc.
Represented By: Jonathan Rosenberg
Represented By: Abby Faith Rudzin
Represented By: Michael Barry Carlinsky
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Defendant: China Merchants Securities (HK) Co., Limited
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Defendant: CLSA Limited
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Defendant: Haitong International Securities Company Limited
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Lead plaintiff: Qi Mi
Represented By: Kim Elaine Miller
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Petitioner: On Tsang
Represented By: David Avi Rosenfeld
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Petitioner: Drew Bahl
Represented By: Phillip C. Kim
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Petitioner: William Gallo
Represented By: James Michael LoPiano
Represented By: Jeremy Alan Lieberman
Represented By: Joseph Alexander Hood, II
Represented By: Lesley Frank Portnoy
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Alternative dispute resolution (adr) provider: Harold Weber
Represented By: Laurence Jesse Hasson
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