UNITE
`D STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`DANIEL YEE, individually and on behalf of
`all other similarly situated,
`Plaintiffs,
`-against-
`KALSHIEX LLC; KALSHI INC; KALSHI
`KLEAR LLC; KALSHI KLEAR INC.,
`KALSHI TRADING LLC, and DOES 1-20,
`Defendants.
`This action relates to:
`Case No. 25-cv-8585
`[PROPOSED] STIPULATION TO
`CONSOLIDATE ACTIONS AND SET
`SCHEDULING DEADLINES
`JURY DEMAND
`Judge: Jennifer L. Rochon
`Status Conference: February 13, 2026
`Time: 12:00 p.m.
`CRYSTAL PELAYO, JACOB TINGLE,
`ISAIAH ESQUIBEL, GINO GADALETA,
`BRICE GAMBILL, RALEIGH
`MELANCON, and MICAH PARKER,
`individually and on behalf of others similarly
`situated,
`Plaintiffs,
`-against-
`KALSHI INC.;KALSHIEX LLC; KALSHI
`KLEAR INC.; KALSHI KLEAR LLC; and
`KALSHI TRADING LLC,
`Defendants.
`Case No. 1:25-cv-9913
`JURY DEMAND
`Judge: Jennifer L. Rochon
`Status Conference: February 13, 2026
`Time: 12:00 p.m.
`ALEXANDER HALLMAN DANIEL
`GREENBERG, NATHANIEL BEE, AND
`ABHIJN GUTTA, individually and on behalf
`of others similarly situated,
`Plaintiffs,
`-against-
`KALSHIEX LLC, KALSHI, INC., KALSHI
`KLEAR INC., KALSHI KLEAR LLC, and
`KALSHI TRADING LLC,
`Defendant.
`Case No.: 1:26-cv-00317
`JURY DEMAND
`Judge: Jennifer L. Rochon
`Status Conference: February 13, 2026
`Time: 12:00 p.m.
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 1 of 6
`
`
`
`
`
`
`
`-1-
`I. Consolidation
`On October 16, 2025, Plaintiff Daniel Yee filed the first class action complaint against
`Defendants alleging that Defendants operate an unlawful sports gambling platform. See Yee v.
`KalshiEX LLC et al., 25-cv-08585-JLR (the “Yee Action”). Two additional and related actions
`were subsequently filed. See Pelayo et al. v. Kalshi Inc. et al., 25-cv-09913-JLR (the “Pelayo
`Action”); and Hallman et al. v. Kalshi EX LLC et al, 26-cv-00317-JLR (the “Hallman Action”)
`(the Yee, Pelayo, and Hallman Actions are collectively referred to herein as the “Related
`Actions”).
`Because the Related Actions assert overlapping causes of actions and are premised on
`essentially the same factual background and legal theories, name the same Defendants, and assert
`claims on behalf of nearly similar classes, these Related Actions should be consolidated pursuant
`to Federal Rule of Civil Procedure 42. For these reasons, the Parties jointly stipulate to
`consolidation. The Parties further agree and propose that the Clerk administratively close the
`Pelayo and Hallman Actions.
`[PROPOSED] STIPULATION TO CONSOLIDATE ACTIONS
`AND SET SCHEDULING DEADLINES
`Plaintiffs in the above-captioned related actions (the “Related Actions”) and their counsel
`have conferred with Defendants Kalshi Inc., Kalshiex LLC, Kalshi Klear, Inc., Kalshi Klear
`LLC, and Kalshi Trading LLC (together “Defendants”) (collectively with Plaintiffs, the
`“Parties”) and their counsel and, pursuant to the Court’s Notice of Status Conference on
`February 13, 2026 at 12:00 p.m. ordering the Parties to file a [Proposed] Stipulation to
`Consolidate Actions and Set Scheduling Deadlines, state as follows:
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 2 of 6
`
`
`
`
`
`
`
`-2-
`By agreeing to consolidate the Related Actions and entering into this stipulation,
`Defendants do not waive, and expressly reserve, any and all rights and defenses which m
`ay be
`available to them in connection with the Related Actions.
`II. Docketing
`The Parties propose that every pleading filed in the eventual consolidated action bear the
`following caption:
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`In re KALSHI SPORTS PREDICTION MARKET
`LITIGATION
`Lead Case No. 25-cv-08585 (JLR)
`Consolidated with cases 25-cv-09913 and
`26-cv-00317
`CLASS ACTION
`III. Appointment of Plaintiffs’ Leadership Structure
`Federal Rule of Civil Procedure 23(g)(3) authorizes the Court to “designate interim class
`counsel to act on behalf of a putative class before determining whether to certify the action as a
`class action.” All Plaintiffs in the Related Actions respectfully request that the Court appoint
`Katherine M. Aizpuru of Tycko & Zavareei LLP, and David Stellings of Lieff Cabraser Heimann
`& Bernstein LLP as Interim Co-Lead Class Counsel. Plaintiffs also ask the Court to appoint a
`small Plaintiffs’ Steering Committee comprised of Aaron L. Schwartz of Kaplan Fox &
`Kilsheimer LLP; Wilson Dunlavey of Lieff Cabraser Heimann & Bernstein LLP; Margot Cutter
`of Cutter Law P.C., and Wesley Griffith of Alameda Law Group LLC, to assist and report to
`Interim Co-Lead Counsel in connection with the management and coordination of the litigation.
`See Manual for Complex Litigation (Fourth) at § 10.221 (supporting appointment of lead counsel
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 3 of 6
`
`
`
`
`
`
`
`-3-
`and a Plain
`tiffs’ Steering Committee).1 Defendants take no position on Plaintiffs’ request for
`appointment of Interim Co-Lead Class Counsel and a Steering Committee.
`IV. Proposed Schedule
`If the Court grants consolidation and Plaintiffs’ request for appointment of a leadership
`structure, the Parties propose the following schedule:
`1. On or before March 24, 2026, Plaintiffs shall file their Consolidated Complaint;
`2. On or before April 21, 2026, Defendants shall file a motion to compel arbitration;
`3. Plaintiffs shall respond to Defendants’ motion by May 21, 2026, and Defendants
`shall submit their reply in support of their motion(s) by June 11, 2026.
`If the Court grants consolidation but prefers that Plaintiffs file a separate motion for
`appointment of Plaintiffs’ leadership structure, the Parties propose the following schedule:
`4. Plaintiffs shall file their motion for appointment of Plaintiffs’ leadership structure
`on or before February 19, 2026;
`5. Plaintiffs’ Consolidated Complaint shall be filed within forty-five (45) days of a
`decision and Order on Plaintiffs’ motion for appointment of a Plaintiffs’ leadership structure;
`6. Defendants shall move to compel arbitration, within thirty (30) days of the filing
`of Plaintiffs’ Consolidated Complaint;
`7. Plaintiffs shall have thirty (30) days to respond thereto, and Defendants shall have
`twenty-one (21) days to file their reply in support of their motion.
`If the Court denies Defendants’ motion to compel arbitration, the Parties propose the
`following schedule for Defendants to answer, move or otherwise respond to Plaintiffs’
`Consolidated Complaint:
`1 The biographies and firm resumes of the leadership applicants are attached as Exhibits A-H.
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 4 of 6
`
`
`
`
`
`
`
`-4-
`8. Defendants shall answer, move, or otherwise respond to Plaintiffs’ Consolidated
`Complaint within forty-five (45) days of the denial of their motion to compel arbitration.
`9. If Defendants’ response to Plaintiffs’ Consolidated Complaint is a motion to
`dismiss, Plaintiffs shall have forty-five (45) days to respond thereto, and Defendants shall have
`thirty (30) days to file their reply in support of their motion.
`STIPULATED AND AGREED:
`Dated: , 2026
`Hon. Jennifer L. Rochon
`United States District Judge
`Dated: February 6, 2026 Respectfully submitted,
`By: /s/ David Stellings
`David Stellings
`Wilson M. Dunlavey
`Jacob S. Miller
`LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
`250 Hudson Street, 8th Floor
`New York, NY 10013-1413
`Telephone: 212.355.9500
`Facsimile: 212.355.9592
`dstellings@lchb.com
`wdunlavey@lchb.com
`jmiller@lchb.com
`Attorneys for Plaintiffs in the Pelayo Action
`February 9
`The Clerk of Court is respectfully directed to consolidate these cases using the
`consolidated caption listed
`above and, thereafter, to administratively close the matters
`Hallm
`an, et al. v. KalshiEX LLC, et al., No. 26-cv-00317 (JLR), and Pelayo, et al. v.
`Kalshi Inc., et
` al., No. 25-cv-09913 (ALC).
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 5 of 6
`
`
`
`
`
`
`
`
` -5-
`
`Dated: February 6, 2026
`
`By: /s/ Katherine Aizpuru
`Katherine M. Aizpuru, NY Bar No. 5305990
`Robert M. Devling, pro hac vice to be filed
`TYCKO & ZAVAREEI LLP
`2000 Pennsylvania Avenue, NW, Suite 1010
`Washington, District of Columbia 20006
`Telephone: 202.973.0900
`kaizpuru@tzlegal.com
`rdevling@tzlegal.com
`
`Attorneys for Plaintiff in the Yee Action
`Dated: February 6, 2026
`
`By: /s/ Laurence D. King
`Laurence D. King
`Aaron Schwartz
`Clara P. Abramson
`KAPLAN FOX & KILSHEIMER LLP
`800 Third Avenue, 38th Floor
`New York, NY 10022
`Telephone: (212) 687-1980
`lking@kaplanfox.com
`aschwartz@kaplanfox.com
`cabramson@kaplanfox.com
`
`Attorneys for Plaintiffs in the Hallman Action
`Dated: February 6, 2026
`
`By: /s/ Matthew J. Laroche
`Matthew J. Laroche
`MILBANK LLP
`55 Hudson Yards
`New York, NY 10001
`(212) 530-5000
`mlaroche@milbank.com
`
`Attorneys for Defendants
`
`Case 1:25-cv-08585-JLR Document 35 Filed 02/06/26 Page 6 of 6Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 6 of 6
`
`
`
`
`
`
`
`
`D STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`DANIEL YEE, individually and on behalf of
`all other similarly situated,
`Plaintiffs,
`-against-
`KALSHIEX LLC; KALSHI INC; KALSHI
`KLEAR LLC; KALSHI KLEAR INC.,
`KALSHI TRADING LLC, and DOES 1-20,
`Defendants.
`This action relates to:
`Case No. 25-cv-8585
`[PROPOSED] STIPULATION TO
`CONSOLIDATE ACTIONS AND SET
`SCHEDULING DEADLINES
`JURY DEMAND
`Judge: Jennifer L. Rochon
`Status Conference: February 13, 2026
`Time: 12:00 p.m.
`CRYSTAL PELAYO, JACOB TINGLE,
`ISAIAH ESQUIBEL, GINO GADALETA,
`BRICE GAMBILL, RALEIGH
`MELANCON, and MICAH PARKER,
`individually and on behalf of others similarly
`situated,
`Plaintiffs,
`-against-
`KALSHI INC.;KALSHIEX LLC; KALSHI
`KLEAR INC.; KALSHI KLEAR LLC; and
`KALSHI TRADING LLC,
`Defendants.
`Case No. 1:25-cv-9913
`JURY DEMAND
`Judge: Jennifer L. Rochon
`Status Conference: February 13, 2026
`Time: 12:00 p.m.
`ALEXANDER HALLMAN DANIEL
`GREENBERG, NATHANIEL BEE, AND
`ABHIJN GUTTA, individually and on behalf
`of others similarly situated,
`Plaintiffs,
`-against-
`KALSHIEX LLC, KALSHI, INC., KALSHI
`KLEAR INC., KALSHI KLEAR LLC, and
`KALSHI TRADING LLC,
`Defendant.
`Case No.: 1:26-cv-00317
`JURY DEMAND
`Judge: Jennifer L. Rochon
`Status Conference: February 13, 2026
`Time: 12:00 p.m.
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 1 of 6
`
`
`
`
`
`
`
`-1-
`I. Consolidation
`On October 16, 2025, Plaintiff Daniel Yee filed the first class action complaint against
`Defendants alleging that Defendants operate an unlawful sports gambling platform. See Yee v.
`KalshiEX LLC et al., 25-cv-08585-JLR (the “Yee Action”). Two additional and related actions
`were subsequently filed. See Pelayo et al. v. Kalshi Inc. et al., 25-cv-09913-JLR (the “Pelayo
`Action”); and Hallman et al. v. Kalshi EX LLC et al, 26-cv-00317-JLR (the “Hallman Action”)
`(the Yee, Pelayo, and Hallman Actions are collectively referred to herein as the “Related
`Actions”).
`Because the Related Actions assert overlapping causes of actions and are premised on
`essentially the same factual background and legal theories, name the same Defendants, and assert
`claims on behalf of nearly similar classes, these Related Actions should be consolidated pursuant
`to Federal Rule of Civil Procedure 42. For these reasons, the Parties jointly stipulate to
`consolidation. The Parties further agree and propose that the Clerk administratively close the
`Pelayo and Hallman Actions.
`[PROPOSED] STIPULATION TO CONSOLIDATE ACTIONS
`AND SET SCHEDULING DEADLINES
`Plaintiffs in the above-captioned related actions (the “Related Actions”) and their counsel
`have conferred with Defendants Kalshi Inc., Kalshiex LLC, Kalshi Klear, Inc., Kalshi Klear
`LLC, and Kalshi Trading LLC (together “Defendants”) (collectively with Plaintiffs, the
`“Parties”) and their counsel and, pursuant to the Court’s Notice of Status Conference on
`February 13, 2026 at 12:00 p.m. ordering the Parties to file a [Proposed] Stipulation to
`Consolidate Actions and Set Scheduling Deadlines, state as follows:
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 2 of 6
`
`
`
`
`
`
`
`-2-
`By agreeing to consolidate the Related Actions and entering into this stipulation,
`Defendants do not waive, and expressly reserve, any and all rights and defenses which m
`ay be
`available to them in connection with the Related Actions.
`II. Docketing
`The Parties propose that every pleading filed in the eventual consolidated action bear the
`following caption:
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`In re KALSHI SPORTS PREDICTION MARKET
`LITIGATION
`Lead Case No. 25-cv-08585 (JLR)
`Consolidated with cases 25-cv-09913 and
`26-cv-00317
`CLASS ACTION
`III. Appointment of Plaintiffs’ Leadership Structure
`Federal Rule of Civil Procedure 23(g)(3) authorizes the Court to “designate interim class
`counsel to act on behalf of a putative class before determining whether to certify the action as a
`class action.” All Plaintiffs in the Related Actions respectfully request that the Court appoint
`Katherine M. Aizpuru of Tycko & Zavareei LLP, and David Stellings of Lieff Cabraser Heimann
`& Bernstein LLP as Interim Co-Lead Class Counsel. Plaintiffs also ask the Court to appoint a
`small Plaintiffs’ Steering Committee comprised of Aaron L. Schwartz of Kaplan Fox &
`Kilsheimer LLP; Wilson Dunlavey of Lieff Cabraser Heimann & Bernstein LLP; Margot Cutter
`of Cutter Law P.C., and Wesley Griffith of Alameda Law Group LLC, to assist and report to
`Interim Co-Lead Counsel in connection with the management and coordination of the litigation.
`See Manual for Complex Litigation (Fourth) at § 10.221 (supporting appointment of lead counsel
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 3 of 6
`
`
`
`
`
`
`
`-3-
`and a Plain
`tiffs’ Steering Committee).1 Defendants take no position on Plaintiffs’ request for
`appointment of Interim Co-Lead Class Counsel and a Steering Committee.
`IV. Proposed Schedule
`If the Court grants consolidation and Plaintiffs’ request for appointment of a leadership
`structure, the Parties propose the following schedule:
`1. On or before March 24, 2026, Plaintiffs shall file their Consolidated Complaint;
`2. On or before April 21, 2026, Defendants shall file a motion to compel arbitration;
`3. Plaintiffs shall respond to Defendants’ motion by May 21, 2026, and Defendants
`shall submit their reply in support of their motion(s) by June 11, 2026.
`If the Court grants consolidation but prefers that Plaintiffs file a separate motion for
`appointment of Plaintiffs’ leadership structure, the Parties propose the following schedule:
`4. Plaintiffs shall file their motion for appointment of Plaintiffs’ leadership structure
`on or before February 19, 2026;
`5. Plaintiffs’ Consolidated Complaint shall be filed within forty-five (45) days of a
`decision and Order on Plaintiffs’ motion for appointment of a Plaintiffs’ leadership structure;
`6. Defendants shall move to compel arbitration, within thirty (30) days of the filing
`of Plaintiffs’ Consolidated Complaint;
`7. Plaintiffs shall have thirty (30) days to respond thereto, and Defendants shall have
`twenty-one (21) days to file their reply in support of their motion.
`If the Court denies Defendants’ motion to compel arbitration, the Parties propose the
`following schedule for Defendants to answer, move or otherwise respond to Plaintiffs’
`Consolidated Complaint:
`1 The biographies and firm resumes of the leadership applicants are attached as Exhibits A-H.
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 4 of 6
`
`
`
`
`
`
`
`-4-
`8. Defendants shall answer, move, or otherwise respond to Plaintiffs’ Consolidated
`Complaint within forty-five (45) days of the denial of their motion to compel arbitration.
`9. If Defendants’ response to Plaintiffs’ Consolidated Complaint is a motion to
`dismiss, Plaintiffs shall have forty-five (45) days to respond thereto, and Defendants shall have
`thirty (30) days to file their reply in support of their motion.
`STIPULATED AND AGREED:
`Dated: , 2026
`Hon. Jennifer L. Rochon
`United States District Judge
`Dated: February 6, 2026 Respectfully submitted,
`By: /s/ David Stellings
`David Stellings
`Wilson M. Dunlavey
`Jacob S. Miller
`LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
`250 Hudson Street, 8th Floor
`New York, NY 10013-1413
`Telephone: 212.355.9500
`Facsimile: 212.355.9592
`dstellings@lchb.com
`wdunlavey@lchb.com
`jmiller@lchb.com
`Attorneys for Plaintiffs in the Pelayo Action
`February 9
`The Clerk of Court is respectfully directed to consolidate these cases using the
`consolidated caption listed
`above and, thereafter, to administratively close the matters
`Hallm
`an, et al. v. KalshiEX LLC, et al., No. 26-cv-00317 (JLR), and Pelayo, et al. v.
`Kalshi Inc., et
` al., No. 25-cv-09913 (ALC).
`Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 5 of 6
`
`
`
`
`
`
`
`
` -5-
`
`Dated: February 6, 2026
`
`By: /s/ Katherine Aizpuru
`Katherine M. Aizpuru, NY Bar No. 5305990
`Robert M. Devling, pro hac vice to be filed
`TYCKO & ZAVAREEI LLP
`2000 Pennsylvania Avenue, NW, Suite 1010
`Washington, District of Columbia 20006
`Telephone: 202.973.0900
`kaizpuru@tzlegal.com
`rdevling@tzlegal.com
`
`Attorneys for Plaintiff in the Yee Action
`Dated: February 6, 2026
`
`By: /s/ Laurence D. King
`Laurence D. King
`Aaron Schwartz
`Clara P. Abramson
`KAPLAN FOX & KILSHEIMER LLP
`800 Third Avenue, 38th Floor
`New York, NY 10022
`Telephone: (212) 687-1980
`lking@kaplanfox.com
`aschwartz@kaplanfox.com
`cabramson@kaplanfox.com
`
`Attorneys for Plaintiffs in the Hallman Action
`Dated: February 6, 2026
`
`By: /s/ Matthew J. Laroche
`Matthew J. Laroche
`MILBANK LLP
`55 Hudson Yards
`New York, NY 10001
`(212) 530-5000
`mlaroche@milbank.com
`
`Attorneys for Defendants
`
`Case 1:25-cv-08585-JLR Document 35 Filed 02/06/26 Page 6 of 6Case 1:26-cv-00317-JLR Document 20 Filed 02/09/26 Page 6 of 6
`
`
`
`
`
`
`
`
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