IN RE: January 2021 Short Squeeze Trading Litigation, 1:21-md-02989

The case is part of the multidistrict litigation arising from the January 2021 "short squeeze" trading events and pertains to the federal securities claims against Robinhood entities.
Plaintiffs moved to extend the fact discovery deadline by 30 days, arguing they need more time due to ongoing and late document production by Robinhood.
Robinhood completed its certified production on January 19, but continued producing documents until February 29, including a large, recent batch of over 23,000 pages.
Plaintiffs served additional discovery requests on February 15, one day late, allegedly due to a calendaring error, and seek relief for this technical lateness.
Robinhood objected, asserting Plaintiffs were neither diligent nor justified in their delays or in the additional requests, and accused them of misusing the process for strategic reasons.
The court evaluated the motion under Fed. R. Civ. P. 16(b)(4) (good cause standard), and considered whether excusable neglect existed for Plaintiffs’ late request under Rule 6(b)(1)(B).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard for Extension	Scheduling order allows extensions by stipulation.	Good cause required due to non-stipulated opposition.	Good cause standard applies; extension needs consent.
Untimely Discovery Requests	Late request excusable neglect: calendaring error, minimal prejudice, no bad faith.	No excusable neglect; calendaring errors not excusable, burdensome/unwarranted requests.	Excusable neglect present; minimal prejudice; delay excused.
Diligence in Discovery	Plaintiffs diligent; late requests due to new Robinhood production.	Plaintiffs untimely and overbroad in requests; lacked diligence.	Plaintiffs generally diligent; Robinhood’s errors contributed.
Prejudice to Robinhood	No serious prejudice; requests responsive to new documents.	Significant burden, late requests for tactical reasons.	No meaningful prejudice; objections to be resolved through process.

Oravec v. Sunny Isles Luxury Ventures, L.C., 527 F.3d 1218 (11th Cir. 2008) (explains good cause standard under Rule 16(b) for modifying scheduling orders)
Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380 (1993) (outlines factors for evaluating "excusable neglect" under federal rules)
Walter v. Blue Cross & Blue Shield United of Wis., 181 F.3d 1198 (11th Cir. 1999) (clarifies that excusable neglect is an equitable determination)
Yang v. Bullock Fin. Grp., Inc., 435 F. App’x 842 (11th Cir. 2011) (untimely filing due to mistake or carelessness may be excused as neglect)