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 1 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(“[T]he Court finds that the bankruptcy reference for Plaintiff’s federal securities claim [under Rule 10b-5] should be withdrawn under Section 157(d).”).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 1 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. 2 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 drashbaum@mrpfirm.com 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 jyoungwood@stblaw.com meredith.karp@stblaw.com jacob.lundqvist@stblaw.com 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 asoloway@paulweiss.com abenedon@paulweiss.com dsinnreich@paulweiss.com dnegless@paulweiss.com Attorneys for Virtu Americas LLC * Appearing Pro Hac Vice 3