Reynolds v. Citadel Securities LLC — Entry #39: MOTION to Appoint Lead Plaintiff Jordan Dario Primo by Jordan Dario Primo

Case 1:26-cv-24485-RKA Document 39-5 Entered on FLSD Docket 08/28/2026 Page 1 of 5


                 EXHIBIT D







 
 
                            
         Case 1:26-cv-24485-RKA       Document 39-5 Entered on FLSD Docket 08/28/2026 Page 2 of 5


                                DECLARATION IN SUPPORT OF LEAD PLAINTIFF MOTION

                       I, the undersigned, pursuant to 28 U.S.C. § 1746, declare as follows:

                       1.     I, Jordan Dario Primo, respectfully submit this Declaration in support of my motion

              for appointment as Lead Plaintiff and approval of my selection of Pomerantz LLP (“Pomerantz”)

              as Lead Counsel in the instant class action on behalf of investors in the securities of Genius Group

              Limited (“Genius”) pursuant to the Private Securities Litigation Reform Act of 1995 (the

              “PSLRA”). I am informed of and understand the requirements and duties imposed by the PSLRA.

              I have personal knowledge about the information in this Declaration.

                       2.     I live in Boulder City, Nevada. I have an Emergency Medical Technician (“EMT”)

              certification from Santa Barbara City College, as well as completed Firefighter I Academy training

              at Allan Hancock College and paramedic training at the University of California, Los Angeles.

              Before retiring due to a work-related injury, I served as a firefighter and EMT for the Los Angeles

              County Fire Protection Districts. I have prior experience retaining and working with attorneys. I

              am 31 years old and have been investing in the securities markets for approximately 12 years. As

              reflected in my Certification, I both purchased and sold Genius securities during the Class Period

              and suffered substantial losses as a result of the violations of the federal securities laws alleged in

              this action.

                       3.     I have discussed this case with an attorney from Pomerantz. Accordingly, I am

              aware of the current status of this litigation. I understand that, in addition to myself, other investors

              in Genius securities may file motions seeking appointment as Lead Plaintiff in this action. I

              understand that on August 28, 2026, my counsel will file a memorandum of law in support of my

              motion for appointment as Lead Plaintiff. I understand that this Declaration and other supporting

              submissions prepared by Pomerantz will be filed concurrently with the memorandum of law. I

              understand that the Lead Plaintiff role includes evaluating the strengths and weaknesses of the case


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              and prospects for resolution of this matter. I understand that it is the Lead Plaintiff’s responsibility

              to direct counsel with respect to this litigation, after receiving the benefit of counsel’s advice. I

              approved Pomerantz as my designated Lead Counsel. I participated in a call with an attorney from

              Pomerantz to discuss this litigation and approved the filing of a motion on my behalf seeking

              appointment as Lead Plaintiff.

                       4.     I attest to, among other things, my belief in the merits of this action; my desire to

              achieve the best possible result for the Class; my interest in prosecuting this case; my

              understanding of the fiduciary obligations of a Lead Plaintiff; and my preparedness to supervise

              counsel and undertake all actions necessary to ensure that the Class’s claims will be zealously and

              efficiently litigated. I hereby affirm that the foregoing statements, as well as all other statements

              set forth in this Declaration, are true and correct statements of my views and intentions with respect

              to this litigation, and that I seek appointment as Lead Plaintiff in this action.

                       5.     Given my significant financial interest in the claims against the defendants, I am

              strongly motivated to recover the significant losses that I and the Class suffered as a result of

              defendants’ violations of the federal securities laws. My principal goal in seeking to serve as Lead

              Plaintiff in this case is to achieve the best possible recovery for the Class from all culpable parties.

              I am committed to ensuring the litigation is litigated as zealously and efficiently as possible, in

              accordance with my duties under the PSLRA.

                       6.     If appointed Lead Plaintiff, I will satisfy my fiduciary obligations to the Class by,

              among other steps, conferring with my counsel regarding litigation strategy and other matters,

              attending court proceedings, depositions, any settlement mediations, and hearings as needed, and

              reviewing and authorizing the filing of important litigation documents. Through these and other

              measures, I will ensure that the Genius securities litigation will be vigorously prosecuted consistent


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              with the obligations of a Lead Plaintiff under the PSLRA and in the best interests of the Class, and

              will seek to obtain the greatest possible recovery for the Class.

                       7.     After reviewing the allegations pleaded in the complaint, and consulting with my

              counsel, I independently determined to seek appointment as Lead Plaintiff, and subsequently

              approved the filing of a motion seeking my appointment as Lead Plaintiff. I agree that my

              resources and ability to engage in decision-making will materially benefit and advance the interests

              of the Class in this case.

                       8.     I understand that the Lead Plaintiff’s share of any recovery is the same as every

              other potential Class member. As my Certification states, I will not accept any payment for serving

              as a representative party beyond my pro rata share, except any reasonable costs and expenses

              directly related to the Class representation as ordered or approved by the Court pursuant to the

              PSLRA.

                       9.     I understand that the PSLRA and courts throughout the country, including courts in

              this District, have endorsed the appointment of investors to serve as Lead Plaintiff when investors

              establish that they can oversee the litigation and their proposed Lead Counsel in an independent

              manner. I intend to prosecute this litigation in such an independent and vigorous manner.

                       10.    I also understand and appreciate the Lead Plaintiff’s obligation under the PSLRA

              to select Lead Counsel and to monitor the action to ensure it is prosecuted efficiently. I have

              fulfilled this responsibility by selecting and retaining Lead Counsel with a proven history of

              handling this type of complex litigation. In this case, I selected Pomerantz to serve as Lead

              Counsel. Based on Pomerantz’s experience in achieving substantial recoveries in securities class

              actions, I believe that the firm is well-qualified to represent the Class.


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                       11.   Pomerantz has been directed to prosecute this action in an efficient, cost-effective

              manner while obtaining the best possible result for the Class. I will continue to supervise counsel

              and actively oversee the prosecution of the action for the benefit of the Class by, among other

              things, reviewing pleadings, instructing counsel, and/or attending hearings, as necessary.


              Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury under the laws of the United States
              of America that the foregoing statements are true and correct to the best of my knowledge.

                                 
              Executed on this __________ day of August, 2026.


              _________________________

              Jordan Dario Primo


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