Jack Stein is an articling student at KND Complex Litigation, returning to the firm after being a summer student in 2024.

He earned his J.D. from the University of Windsor Faculty of Law and an Honours in Business Administration from the Ivey Business School at Western University. Prior to law school, Jack worked as a consultant for a company providing nationwide electric vehicle charging infrastructure, where he helped manage and secure financing for large-scale projects.

With this legal and business background, Jack has developed a solid foundation for assisting the firm in complex litigation matters involving commercial, corporate and securities law.

Jack is an avid sports enthusiast and a competitive tennis player, which has included competing in OTA tournaments, reaching the OFSAA tennis finals in high school and playing for the University of Windsor tennis team.

Sajjad (Sage) Nematollahi is a litigation lawyer admitted to the practice of law in British Columbia, Ontario and New York State. His practice includes complex commercial litigation and class actions, with a focus on capital markets, cybersecurity and privacy litigation. Sage also provides consulting and advisory services to select clients in relation to Canadian securities and privacy laws and regulation, class action litigation and risk management.

Sage has significant experience with Canadian and cross-border securities litigation, acting for both retail and institutional investors. His experience includes several high-profile securities class actions in Canada over the past decade, including joint proceedings under Canada’s federal insolvency legislation, the Companies’ Creditors Arrangement Act, and proceedings in relation to plans of arrangement under provincial business corporations legislation. Sage has successfully represented plaintiffs in Valeant Pharmaceuticals International Inc. Securities Litigation (resulted in settlements in the aggregate amount of $127 million), Sino-Forest Corporation Securities Litigation (resulted in settlements in the aggregate amount of more than $160 million), Poseidon Concepts Corporation Securities Litigation (resulted in a settlement in excess of $34.5 million) and Canadian Solar Securities Litigation (resulted in a settlement in the amount of US$13 million).

Sage also has significant experience with data breach and consumer privacy litigation, where he represents Canadians impacted in significant cybersecurity and privacy breaches. A strong advocate for an individual’s fundamental right to protect their identity, Sage has prosecuted a number of high-profile privacy class proceedings in Canada. His representative work includes the privacy breach class action against Facebook arising out of the Cambridge Analytica scandal, the class action against Marriott International arising out of the massive data breach reported in 2018, and class actions involving Bank of Montreal and Canadian Imperial Bank of Commerce’s Simplii Financial arising out of a data breach reported in 2018 (settled for a meaningful compensation to affected clients of the banks).

Sage holds a Master of Laws degree from Harvard Law School, where he represented his class at the Harvard Law School Student Government, and a Master of Laws degree from McGill University, Faculty of Law, where he served as a Councilor at McGill University Post-Graduate Students’ Society. He earned his Bachelor of Laws degree from the National University of Iran with high honours.

Sage enjoys studying the intersection of law and economics and business strategy, arts and outdoors, and speaks English and Farsi.

Eli obtained his law degree from Osgoode Hall law school in 2006. Since that time, for almost 15 years, Eli has combined his significant securities, consumer and commercial law knowledge with substantial courtroom experience to drive results for investors and consumers in class action litigation against banks, telecoms, and other large public companies.

Eli has had significant successes in holding large corporations accountable for their actions. A representative sample of these include acting on the counsel team for:

certifying and successfully resolving a class action against a large well known investment bank on an action alleging unpaid overtime;
certifying and successfully resolving a class action against a big 4 accounting firm alleging unpaid overtime;
certifying action against a well known travel website;
certifying and successfully resolving a class action against an accounting firm arising from allegations of misrepresentations in financial statements of a reporting issuer;
certifying an action on appeal against an investment bank relative to allegations of misrepresentation in a prospectus, and
certifying two class actions against two large telecoms.
Recently Eli acted as part of the counsel team obtaining authorization and leave to proceed against a large pharmaceutical company resulting in payouts to class members in excess of $120MM and a securities class action against a billion dollar gaming website which resulted in the largest settlement for an action involving alleged insider trading as well as the highest percentage-recovery based on secondary market liability limits under applicable securities legislation in Canadian history.

In addition to his work in the class action space, Eli maintains a busy litigation practice acting for plaintiffs and defendants, bringing and defending actions on the commercial list in Toronto, bringing and defending claims arising from aborted real estate transactions, partnership disputes, inter-corporation shareholder disputes, and acting on bankruptcy and receivership files.

Hadi is a litigation lawyer admitted to the practice of law in Ontario and British Columbia. Hadi’s practice is predominantly focused on class actions and securities litigation, with Hadi having acted as class counsel in many notable securities class proceedings litigated in recent years. Due to his having taken an interest in capital markets and econometrics from an early age, Hadi’s professional career has always been motivated by a desire to protect the interests of investors.

A representative sample of Hadi’s work include acting on the class counsel team in:

• a securities class action against a large global pharmaceutical company which recently resulted in a settlement used to fund the creation of an Investor Protection Clinic at the Faculty of Law at McGill University in Montreal, as well as provide additional funding to the Investor Protection Clinic at Osgoode Hall Law School in Toronto;
• a securities class action against a multi-billion dollar gaming company which resulted in the largest settlement for an action involving alleged insider trading as well as the highest percentage-recovery based on secondary market liability limits under applicable securities legislation in Canadian history;
• a securities class action against an accounting firm for alleged misrepresentations contained in financial statements that it audited, which was certified and settled for an amount that was greater than the applicable statutory liability limit;
• a primary market securities action pertaining to an equity share offering in which the Divisional Court overturned the Motion Court’s partial denial of certification and certified a common law negligent misrepresentation claim against the underwriters for the offering;
• a securities class action against a mining company where the Court in granting leave to proceed with a statutory secondary market claim, held that for the purposes of the Securities Act a statement could be both a misrepresentation and a partial correction related to the same alleged undisclosed material fact; and
• a securities class action in which the Court held that Ontario was the correct forum to litigate the claims of Canadians who had purchased their shares on an American stock exchange when there was a corresponding action on behalf of those who had purchased their shares of the same company on a Canadian stock exchange.

Hadi holds a BMOS (hons., dbl. major.) from the University of Western Ontario, and a JD and MSL from the University of Western Ontario, Faculty of Law. Outside of work, he enjoys travelling and rowing.

Shin is an Associate at KND Complex Litigation with a passion for plaintiff-side litigation. Practising class action has been his life-long dream.

Prior to joining KND, Shin clerked with two litigation boutiques in Texas, predominantly acting for plaintiffs in product liability and personal injury litigation. As an attorney licensed to practice in the states of Texas and New York, he also took part in the discovery processes in actions against major pharmaceutical companies.

Upon arrival in Canada before starting with KND, he worked at another litigation boutique where he was exposed to Canadian class action and commercial litigation. His work background at firms in the United States and Canada have given him invaluable litigation experience in various fields of law.

Shin received his law degree from The University of Texas School of Law, and his bachelor’s degree from the University of Wisconsin-Madison, which he calls his second home. He is originally from Seoul, South Korea, and speaks fluent Korean.

When Shin is not working, he enjoys spending time with his family, traveling, and watching his Wisconsin Badgers play.