Reynolds v. Citadel Securities LLC — Entry #46
Case: Reynolds v. Citadel Securities LLC flsd · 1:26-cv-24485
filed June 29, 2026
What this document is
Docket entry #46 · filed September 22, 2026
Who is involved
- Aron Reynolds
- Citadel Securities LLC
- Virtu Americas LLC
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Applied Digital: its former name “FLIGHT SAFETY TECHNOLOGIES INC” appears in a filing in this case.
…Counsel. $1.2 million. • Flight Safety Technologies, Inc., (D. Conn.). Rosen Lead Counsel. $1…
- Core Scientific: its name “Core Scientific, Inc.” appears in a filing in this case.
…Lead Counsel. Pang v. Levitt (Core Scientific, Inc.), No. 22-CV-1191-LY (W.D. Tex.). Rosen…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 07, 2026. Federal court filings are public records.
Document text
3 page(s), 6,381 characters, converted from the PDF's text layer · plain text.
Full text
Case 1:26-cv-24485-RKA Document 46 Entered on FLSD Docket 09/22/2026 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
ARON REYNOLDS, individually and on behalf of
all others similarly situated,
Plaintiff,
vs. Case No. 1:26-CV-24485-RKA
CITADEL SECURITIES LLC and VIRTU
AMERICAS LLC
Defendants.
DEFENDANTS’ RESPONSE TO PLAINTIFF’S
NOTICE OF SUPPLEMENTAL INFORMATION
Plaintiff’s Notice of Supplemental Information (“Notice”) does not concern this case or
have any relevance to the pending Motion to Transfer. There is nothing inconsistent in the decision
of Citadel Securities LLC (“Citadel Securities”) and Virtu Americas LLC (“Virtu”) to seek to
transfer this case to the first-filed forum and simultaneously seek to withdraw the reference in a
separate case that does not belong in bankruptcy court. Both positions reflect a single, consistent
objective: to have these federal securities claims adjudicated by the appropriate Article III district
court.
The Notice refers to an adversary proceeding improperly filed in the Bankruptcy Court for
the District of Nevada on August 7, 2026 by the Trustee of a Nevada company in Chapter 7
bankruptcy and a non-debtor individual—both represented by the same counsel as Plaintiff
Reynolds. That complaint asserts non-bankruptcy securities claims on behalf of a putative class
that traded the Nevada debtor’s shares. Defendants are Citadel Securities, Virtu, and two other
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Case 1:26-cv-24485-RKA Document 46 Entered on FLSD Docket 09/22/2026 Page 2 of 3
defendants. On September 15, 2026, the defendants moved to withdraw the reference pursuant to
28 U.S.C. § 157(d), seeking to remove the adversary proceeding from the bankruptcy court and
adjudicate it in the district court, because a putative securities class action plainly does not belong
in the bankruptcy court. See Rannd Res. v. Von Harten (In re Rannd Res.), 175 B.R. 393, 396 (D.
Nev. 1994) (granting motion to withdraw because “the Court finds that consideration of these
issues will likely require substantial and material consideration of the federal securities laws”
including “§ 12(2) of the Securities Act of 1933, § 10 of the Securities Exchange Act of 1934,
and Rule 10b-5”); Meghji v. Compound Labs, Inc. (In re Celsius Network LLC), 670 B.R. 379,
389 (S.D.N.Y. 2025) (“[T]he Court finds that the bankruptcy reference for Plaintiff’s federal
securities claim [under Rule 10b-5] should be withdrawn under Section 157(d).”). Unlike here,
where the transfer motion is premised on the first-to-file rule (as well as forum non conveniens)
given the previously filed case in the Southern District of New York, there was no first-filed action
in the Nevada proceedings. Nor is there any basis for Plaintiff’s assertion that the bankruptcy court
is “far more familiar with the underlying dispute.” Notice at 1.1 Defendants’ motion to withdraw
the reference was the first substantive motion filed in the adversary proceeding (at the same time
defendants appeared) and there have been no substantive rulings. The Nevada withdrawal motion
therefore has no bearing on whether this action should be transferred to the Southern District of
New York.
Dated: September 22, 2026
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The Notice is also based on the faulty premise that “Defendants rest their motion largely on Judge
Caproni’s supposed familiarity with the Genius litigation.” Notice at 1. In fact, Defendants’
transfer motion is based on a straight-forward application of the first-to-file rule based on “(1) the
chronology of the two actions; (2) the similarity of the parties; and (3) the similarity of the issues,”
as well as Plaintiff’s counsel’s blatant forum shopping. See Transfer Mot., Dkt. 9.
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Case 1:26-cv-24485-RKA Document 46 Entered on FLSD Docket 09/22/2026 Page 3 of 3
MARCUS RASHBAUM PINIERO & MEYERS LLP
/s/ Daniel Rashbaum
Daniel Rashbaum
One Biscayne Tower
2 South Biscayne Boulevard, Suite 2530
Miami, FL 33131
Tel: (305) 400-4260
[email protected]
Attorneys for Citadel Securities LLC and
Virtu Americas LLC
SIMPSON THACHER & BARTLETT LLP
Jonathan K. Youngwood*
Meredith Karp*
Jacob Lundqvist*
425 Lexington Avenue
New York, NY 10017
Tel: (212) 455-2000
[email protected]
[email protected]
[email protected]
Attorneys for Citadel Securities LLC
PAUL, WEISS, RIFKIND, WHARTON &
GARRISON LLP
Audra J. Soloway*
Alison R. Benedon*
Daniel S. Sinnreich*
Daniel Negless*
1285 Avenue of the Americas
New York, NY 10019
Tel: (212) 373-3000
[email protected]
[email protected]
[email protected]
[email protected]
Attorneys for Virtu Americas LLC
* Appearing Pro Hac Vice
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