5 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 6
7 LUIS GONZALEZ DIEZ, Individually Case No. 2:26-cv-00231-RFB-MDC and on behalf of all others similarly situated, 8 STIPULATION AND [PROPOSED] ORDER
APPOINTING CO-LEAD PLAINTIFFS Plaintiff, 9 AND CO-LEAD COUNSEL v. 10
RICHTECH ROBOTICS INC., WAYNE 11 HUANG, and MICHAEL HUANG,
12 Defendants. 13
14 Lead Plaintiff Movants, Charles Talisman (“Talisman”) and Hudson Mac Cayman Holding 15 Company (“Hudson”), by and through their undersigned counsel, hereby stipulate as follows in 16 support of their request for appointment as Co-Lead Plaintiffs and approval of their selection of Co- 17 Lead Counsel: 18 WHEREAS, on February 2, 2026, Luis Gonzalez Diez commenced the above-captioned 19 action (the “Action”) alleging violations of the federal securities laws on behalf of a putative class 20 consisting of investors in the securities of Richtech Robotics Inc. (“Richtech”) (see Dkt. No. 1); 21 WHEREAS, as a putative class action alleging violations of the federal securities laws, this 22 Action is governed by the Private Securities Litigation Reform Act of 1995 (the “PSLRA”), which 23 provides, inter alia, that any putative Class member may move for appointment as Lead Plaintiff in 24 the Action within 60 days of publication of notice of the pendency of the Action—here, on or before 25 April 3, 2026 (see 15 U.S.C. § 78u-4(a)(3)(B)(iii)(I)(aa)); 26 WHEREAS, on April 3, 2026, five members or member groups of the putative Class alleged 27 in the Action filed timely, separate motions seeking appointment as Lead Plaintiff in the Action and 1 Steven Crosby (Dkt. No. 23); (iii) Talisman (Dkt. No. 24); (iv) Jie Ci Li (Dkt. No. 25); and (v) Brian 2 Zhang and Steve Rodgers (Dkt. No. 26); 3 WHEREAS, Hudson and Talisman are the only remaining competing movants, as all other 4 movants have either withdrawn their motions or filed notices of non-opposition (see Dkt. Nos. 27; 29; 5 32); 6 WHEREAS, the PSLRA provides, inter alia, that the most adequate plaintiff to serve as Lead 7 Plaintiff is, in the determination of the Court, the “person or group of persons” that has the largest 8 financial interest in the relief sought by the class and otherwise satisfies the relevant requirements of 9 Rule 23 of the Federal Rules of Civil Procedure (“Rule 23”) (15 U.S.C. § 78u-4(a)(3)(B)(iii)); 10 WHEREAS, the PSLRA provides that, subject to the approval of the Court, the most adequate 11 plaintiff will select and retain counsel to represent the class (15 U.S.C. § 78u-4(a)(3)(B)(v)); 12 WHEREAS, Hudson and Talisman have each provided sworn Certifications pursuant to the 13 PSLRA in support of their respective applications for Lead Plaintiff appointment, setting forth, inter 14 alia, their transactions in Richtech securities (see Dkt. Nos. 21-4; 24-2); 15 WHEREAS, Hudson claims to have sustained losses of approximately $203,560.80 as a result 16 of Defendants’ alleged wrongful conduct (see Dkt. No. 21-5); 17 WHEREAS, Talisman claims to have sustained losses of approximately $102,158.80 as a 18 result of Defendants’ alleged wrongful conduct (see Dkt. No. 24-3); 19 WHEREAS, accordingly, Hudson and Talisman have each alleged a significant financial 20 interest in the outcome of this litigation; 21 WHEREAS, Hudson and Talisman submit that they are also each qualified to serve as Lead 22 Plaintiffs in this case given, among other things, their respective Lead Plaintiff motion submissions 23 (Dkt. Nos. 20 and 24); 24 WHEREAS, having reviewed one another’s submissions to the Court, Hudson and Talisman 25 believe that they each satisfy the typicality and adequacy requirements of Rule 23; 26 WHEREAS, after reviewing each other’s submissions to the Court, Hudson and Talisman — 27 as the only two remaining movants in contention for appointment as Lead Plaintiff—have decided 1 selections of Levi & Korsinsky, LLP (“Levi & Korsinsky”) and Hagens Berman Sobol Shapiro LLP 2 (“Hagens Berman”) to serve as Co-Lead Counsel, and for Aldrich Law Firm, LTD. (“Aldrich”) and 3 Albright, Stoddard, Warnick & Albright (“Albright”) to serve as Liaison Counsel, in that it will, inter 4 alia, allow their counsel to pool their resources to immediately and efficiently commence prosecution 5 of this Action and avoid further delay associated with a protracted lead plaintiff dispute; 6 WHEREAS, Hudson and Talisman are committed to supervising the conduct of this litigation 7 by their counsel and to ensuring that counsel coordinate appropriately, prosecute the Action 8 efficiently, and avoid any duplication of effort in the conduct of the litigation; and 9 WHEREAS, courts have endorsed stipulations among competing Lead Plaintiff movants, like 10 here, as promoting the statutory purposes of the PSLRA, and have permitted “independent lead 11 plaintiff movants [to] join together to help ensure that adequate resources and experience are available 12 to the prospective class in the prosecution of th[e] action and because [e]mploying a co-lead plaintiff 13 structure . . . will also provide the proposed class with the substantial benefits of joint decision- 14 making.” In re Rockwell Med., Inc. Sec. Litig., No. 1:16-cv-01691-RJS, Dkt. No. 18 at 2–3 (S.D.N.Y. 15 May 20, 2016) (internal quotation marks omitted) (citing Pirelli Armstrong Tire Corp. Retiree Med. 16 Benefits Tr. v. LaBranche & Co., 229 F.R.D. 395, 420 (S.D.N.Y. 2004)); see also Qawasmi v. 17 American Airlines Group Inc., No. 4:24-cv-00763-O (N.D. Tex. Nov. 22, 2024) (Dkt. No. 38) 18 (approving stipulation of competing lead plaintiff movants to serve as co-lead plaintiffs and approving 19 their selection of co-lead counsel); In re Grab Holdings Ltd. Sec. Litig., No. 1:22-cv-02189-VM 20 (S.D.N.Y.), Dkt. No. 39 (same); In re Altimmune, Inc. Sec. Litig., No. 8:24-cv-01315-ABA (D. Md.), 21 Dkt. No. 22 (same); Pizzuto v. Homology Meds., Inc., No. 2:22-cv-01968-FLA (JPRx) (C.D. Cal.), 22 Dkt. No. 38 (same); Maurer v. Argos Therapeutics Inc., No. 1:17-cv-00216-TDS-LPA (M.D.N.C.), 23 Dkt. No. 26 (same); In re Facebook, Inc. Sec. Litig., No. 5:18-cv-01725-EJD (N.D. Cal. Aug. 3, 24 2018), Dkt. No. 56 at 2 (approving stipulation of lead plaintiff movants where movants “concluded 25 that a protracted dispute concerning lead plaintiff appointment . . . [was] not in the best interests of 26 the class and that jointly prosecuting [the] litigation would be appropriate and assist with the speedy 27 commencement of [the] litigation”); In re Millennial Media, Inc. Sec. Litig., 87 F. Supp. 3d 563, 570– 1 the class the advantages of the combined knowledge, experience, and judgment of both lead 2 plaintiffs.” (collecting cases)); Martin v. BioXcel Therapeutics, Inc. et al., No. 3:23-cv-00915 (D. 3 Conn. Oct. 4, 2023) (approving joint motion of movants, finding “both the most adequate 4 representatives of the class and thus appointing them as co-Lead Plaintiffs will best serve the interests 5 of the class”); 6 IT IS HEREBY STIPULATED AND AGREED THAT, subject to the Court’s approval, as 7 follows: 8 1. Every pleading in this Action, and any related action that is consolidated with this Action, 9 shall hereafter bear the following caption: 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 IN RE RICHTECH ROBOTICS INC. Case No.
Free access — add to your briefcase to read the full text and ask questions with AI
5 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 6
7 LUIS GONZALEZ DIEZ, Individually Case No. 2:26-cv-00231-RFB-MDC and on behalf of all others similarly situated, 8 STIPULATION AND [PROPOSED] ORDER
APPOINTING CO-LEAD PLAINTIFFS Plaintiff, 9 AND CO-LEAD COUNSEL v. 10
RICHTECH ROBOTICS INC., WAYNE 11 HUANG, and MICHAEL HUANG,
12 Defendants. 13
14 Lead Plaintiff Movants, Charles Talisman (“Talisman”) and Hudson Mac Cayman Holding 15 Company (“Hudson”), by and through their undersigned counsel, hereby stipulate as follows in 16 support of their request for appointment as Co-Lead Plaintiffs and approval of their selection of Co- 17 Lead Counsel: 18 WHEREAS, on February 2, 2026, Luis Gonzalez Diez commenced the above-captioned 19 action (the “Action”) alleging violations of the federal securities laws on behalf of a putative class 20 consisting of investors in the securities of Richtech Robotics Inc. (“Richtech”) (see Dkt. No. 1); 21 WHEREAS, as a putative class action alleging violations of the federal securities laws, this 22 Action is governed by the Private Securities Litigation Reform Act of 1995 (the “PSLRA”), which 23 provides, inter alia, that any putative Class member may move for appointment as Lead Plaintiff in 24 the Action within 60 days of publication of notice of the pendency of the Action—here, on or before 25 April 3, 2026 (see 15 U.S.C. § 78u-4(a)(3)(B)(iii)(I)(aa)); 26 WHEREAS, on April 3, 2026, five members or member groups of the putative Class alleged 27 in the Action filed timely, separate motions seeking appointment as Lead Plaintiff in the Action and 1 Steven Crosby (Dkt. No. 23); (iii) Talisman (Dkt. No. 24); (iv) Jie Ci Li (Dkt. No. 25); and (v) Brian 2 Zhang and Steve Rodgers (Dkt. No. 26); 3 WHEREAS, Hudson and Talisman are the only remaining competing movants, as all other 4 movants have either withdrawn their motions or filed notices of non-opposition (see Dkt. Nos. 27; 29; 5 32); 6 WHEREAS, the PSLRA provides, inter alia, that the most adequate plaintiff to serve as Lead 7 Plaintiff is, in the determination of the Court, the “person or group of persons” that has the largest 8 financial interest in the relief sought by the class and otherwise satisfies the relevant requirements of 9 Rule 23 of the Federal Rules of Civil Procedure (“Rule 23”) (15 U.S.C. § 78u-4(a)(3)(B)(iii)); 10 WHEREAS, the PSLRA provides that, subject to the approval of the Court, the most adequate 11 plaintiff will select and retain counsel to represent the class (15 U.S.C. § 78u-4(a)(3)(B)(v)); 12 WHEREAS, Hudson and Talisman have each provided sworn Certifications pursuant to the 13 PSLRA in support of their respective applications for Lead Plaintiff appointment, setting forth, inter 14 alia, their transactions in Richtech securities (see Dkt. Nos. 21-4; 24-2); 15 WHEREAS, Hudson claims to have sustained losses of approximately $203,560.80 as a result 16 of Defendants’ alleged wrongful conduct (see Dkt. No. 21-5); 17 WHEREAS, Talisman claims to have sustained losses of approximately $102,158.80 as a 18 result of Defendants’ alleged wrongful conduct (see Dkt. No. 24-3); 19 WHEREAS, accordingly, Hudson and Talisman have each alleged a significant financial 20 interest in the outcome of this litigation; 21 WHEREAS, Hudson and Talisman submit that they are also each qualified to serve as Lead 22 Plaintiffs in this case given, among other things, their respective Lead Plaintiff motion submissions 23 (Dkt. Nos. 20 and 24); 24 WHEREAS, having reviewed one another’s submissions to the Court, Hudson and Talisman 25 believe that they each satisfy the typicality and adequacy requirements of Rule 23; 26 WHEREAS, after reviewing each other’s submissions to the Court, Hudson and Talisman — 27 as the only two remaining movants in contention for appointment as Lead Plaintiff—have decided 1 selections of Levi & Korsinsky, LLP (“Levi & Korsinsky”) and Hagens Berman Sobol Shapiro LLP 2 (“Hagens Berman”) to serve as Co-Lead Counsel, and for Aldrich Law Firm, LTD. (“Aldrich”) and 3 Albright, Stoddard, Warnick & Albright (“Albright”) to serve as Liaison Counsel, in that it will, inter 4 alia, allow their counsel to pool their resources to immediately and efficiently commence prosecution 5 of this Action and avoid further delay associated with a protracted lead plaintiff dispute; 6 WHEREAS, Hudson and Talisman are committed to supervising the conduct of this litigation 7 by their counsel and to ensuring that counsel coordinate appropriately, prosecute the Action 8 efficiently, and avoid any duplication of effort in the conduct of the litigation; and 9 WHEREAS, courts have endorsed stipulations among competing Lead Plaintiff movants, like 10 here, as promoting the statutory purposes of the PSLRA, and have permitted “independent lead 11 plaintiff movants [to] join together to help ensure that adequate resources and experience are available 12 to the prospective class in the prosecution of th[e] action and because [e]mploying a co-lead plaintiff 13 structure . . . will also provide the proposed class with the substantial benefits of joint decision- 14 making.” In re Rockwell Med., Inc. Sec. Litig., No. 1:16-cv-01691-RJS, Dkt. No. 18 at 2–3 (S.D.N.Y. 15 May 20, 2016) (internal quotation marks omitted) (citing Pirelli Armstrong Tire Corp. Retiree Med. 16 Benefits Tr. v. LaBranche & Co., 229 F.R.D. 395, 420 (S.D.N.Y. 2004)); see also Qawasmi v. 17 American Airlines Group Inc., No. 4:24-cv-00763-O (N.D. Tex. Nov. 22, 2024) (Dkt. No. 38) 18 (approving stipulation of competing lead plaintiff movants to serve as co-lead plaintiffs and approving 19 their selection of co-lead counsel); In re Grab Holdings Ltd. Sec. Litig., No. 1:22-cv-02189-VM 20 (S.D.N.Y.), Dkt. No. 39 (same); In re Altimmune, Inc. Sec. Litig., No. 8:24-cv-01315-ABA (D. Md.), 21 Dkt. No. 22 (same); Pizzuto v. Homology Meds., Inc., No. 2:22-cv-01968-FLA (JPRx) (C.D. Cal.), 22 Dkt. No. 38 (same); Maurer v. Argos Therapeutics Inc., No. 1:17-cv-00216-TDS-LPA (M.D.N.C.), 23 Dkt. No. 26 (same); In re Facebook, Inc. Sec. Litig., No. 5:18-cv-01725-EJD (N.D. Cal. Aug. 3, 24 2018), Dkt. No. 56 at 2 (approving stipulation of lead plaintiff movants where movants “concluded 25 that a protracted dispute concerning lead plaintiff appointment . . . [was] not in the best interests of 26 the class and that jointly prosecuting [the] litigation would be appropriate and assist with the speedy 27 commencement of [the] litigation”); In re Millennial Media, Inc. Sec. Litig., 87 F. Supp. 3d 563, 570– 1 the class the advantages of the combined knowledge, experience, and judgment of both lead 2 plaintiffs.” (collecting cases)); Martin v. BioXcel Therapeutics, Inc. et al., No. 3:23-cv-00915 (D. 3 Conn. Oct. 4, 2023) (approving joint motion of movants, finding “both the most adequate 4 representatives of the class and thus appointing them as co-Lead Plaintiffs will best serve the interests 5 of the class”); 6 IT IS HEREBY STIPULATED AND AGREED THAT, subject to the Court’s approval, as 7 follows: 8 1. Every pleading in this Action, and any related action that is consolidated with this Action, 9 shall hereafter bear the following caption: 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 IN RE RICHTECH ROBOTICS INC. Case No. 2:26-cv-00231-RFB-MDC 13 SECURITIES LITIGATION 14 CLASS ACTION 15 THIS DOCUMENT RELATES TO: [TITLE OF DOCUMENT] 16
17 2. When the document being filed pertains to all actions, the phrase “All Actions” shall appear 18 immediately after the phrase “This Document Relates To:”. When the document applies to some, but 19 not all, of the actions, the document shall list, immediately after the phrase “This Document Relates 20 To:”, the docket number for each individual action to which the document applies, along with the 21 name of the first-listed plaintiff in said action; 22 3. Hudson and Talisman’s motions for appointment as Lead Plaintiff and approval of selection 23 of counsel (Dkt. Nos. 20 and 24) are granted, and Hudson and Talisman are hereby appointed Co- 24 Lead Plaintiffs in this Action and any subsequently filed or transferred actions that are consolidated 25 with this Action, pursuant to 15 U.S.C. § 78u-4(a)(3)(B); and 26 4. Co-Lead Plaintiffs’ selections of Hagens Berman and Levi & Korsinsky as Co-Lead 27 Counsel and Aldrich and Albright as Liaison Counsel for the Class are hereby approved. 1 IT IS SO STIPULATED. 2 Dated: April 17, 2026 Respectfully submitted, 3
4 ALDRICH LAW FIRM, LTD.
5 /s/ John P. Aldrich John P. Aldrich 6 John P. Aldrich, Esq. 7866 West Sahara Avenue 7 Las Vegas, Nevada 89117 Tel: (702) 853-5490 8 Fax: (702) 227-1975 Email: jaldrich@johnaldrichlawfirm.com 9
10 Liaison Counsel for Charles Talisman and [Proposed] Liaison Counsel for the Class 11
12 LEVI & KORSINSKY, LLP Adam M. Apton (to be admitted pro hac vice) 13 33 Whitehall Street, 27th Floor New York, NY 10004 14 Tel: (212) 363-7500 Fax: (212) 363-7171 15 Email: aapton@zlk.com
16 Lead Counsel for Charles Talisman and 17 [Proposed] Co-Lead Counsel for the Class
19 Dated: April 17, 2026 ALBRIGHT, STODDARD, WARNICK & ALBRIGHT 20
21 /s/ G. Mark Albright G. Mark Albright, Esq. 22 Nevada State Bar #001394 801 S. Rancho 23 Drive, Suite D-4 Las Vegas, NV 89106 Telephone: (702) 384-7111 24 Facsimile: (702) 384-0605 gma@albrightstoddard.com 25
26 Liaison Counsel for Hudson Mac Cayman Holding Company and [Proposed] Liaison 27 Counsel for the Class 1 HAGENS BERMAN SOBOL SHAPIRO LLP 2 Reed R. Kathrein (to be admitted pro hac vice) Lucas E. Gilmore (admitted pro hac vice) 3 715 Hearst Avenue, Suite 202 Berkeley, CA 4 94710 Telephone: (510) 725-3000 Facsimile: (510) 725-3001 reed@hbsslaw.com 6 Lead Counsel for Hudson Mac Cayman Holding Company and [Proposed] Co-Lead 7 Counsel for the Class PURSUANT TO STIPULATION, IT IS SO ORDERED. The foregoing stipulation appointing 8 Hagens Berman et al. and Levi & Korsinsky as Co-Lead Counsel and Aldrich and Albright as g ||Liaison Counsel for the Class is APPROVED. IT IS FURTHER ORDERED that future stipulations must comply with LR IA 6-2, which requires the judicial signature block to appear 10 |Jon the same page as the last substantive matter of the stipulation. Failure to comply may result in denial or rejection of stipulation. p “p, , “7 an DATED: 5-5-26. ff fF on 12 at af a 13 Hon,via tiliano } bX ouvillier Ill Ugited tates Mags Aral} Judge 14 jf Jif Ff 15 “ 16 17 18 19 20 21 22 23 24 25 26 27 28
1 CERTIFICATE OF SERVICE 2 I hereby certify that on April 17, 2026, I electronically filed the foregoing document using 3 || the CM/ECF system which will send notification of such filing to the email addresses registered 4 ||in the CM/ECF system, as denoted on the Electronic Mail Notice List. > /s/ G. Mark Albright 6 G. Mark Albright 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28