Reynolds v. Citadel Securities LLC — Entry #40: MOTION to Appoint Lead Plaintiff Duc To ( Responses due by 9/11/2026.), MOTION to Appoint Lead Counsel The Rosen Law Firm, P.A

Case: Reynolds v. Citadel Securities LLC flsd · 1:26-cv-24485

filed June 29, 2026

What this document is

Docket entry #40 · filed August 28, 2026

MOTION to Appoint Lead Plaintiff Duc To ( Responses due by 9/11/2026.), MOTION to Appoint Lead Counsel The Rosen Law Firm, P.A. by Duc To. Attorney Laurence Matthew Rosen added to party Duc To(pty:mov). (Attachments: # 1 Text of Proposed Order, # 2 Decl. of Laurence Rosen, # 3 Exhibit 1 - Early Notice, # 4 Exhibit 2 - PSLRA Cert, # 5 Exhibit 3 - Loss Chart, # 6 Exhibit 4 - RLF Firm Resume)(Rosen, Laurence) (Entered: 08/28/2026)

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.

URL: https://archive.org/download/gov.uscourts.flsd.717696/gov.uscourts.flsd.717696.40.2.pdf
Kind: court_filing
Publisher: RECAP
Published: 2026-08-28 00:00:00-04:00
Retrieved: 2026-10-07 06:41:18.060034-04:00
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SHA-256: 94acf9694b20ba1f539633e11d8d562b86aa43e7ee2c281ea537e78396e113c5

Document text

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Full text

Case 1:26-cv-24485-RKA Document 40-2 Entered on FLSD Docket 08/28/2026 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:26-CV-24485-ALTMAN/Hernandez

ARON REYNOLDS, Individually and On
Behalf of All Others Similarly Situated,

Plaintiff,
vs.

CITADEL SECURITIES LLC and VIRTU
AMERICAS LLC,

Defendants.

DECLARATION OF LAURENCE M. ROSEN IN SUPPORT OF THE MOTION OF
MOVANT DUC TO TO: (1) APPOINT LEAD PLAINTIFF; AND (2) APPROVE
SELECTION OF LEAD COUNSEL

Laurence M. Rosen, hereby declares under penalty of perjury:

1. I am the Managing Partner of The Rosen Law Firm, P.A. (“Rosen Law”), Proposed

Lead Counsel for Lead Plaintiff Movant Duc To (“Movant”). I make this Declaration in support

of the Movant’s motion to: (1) appoint Lead Plaintiff; and (2) approve the selection of Rosen Law

as Lead Counsel. I am an attorney duly licensed to practice in the State of Florida and before this

Court. I have personal knowledge of the matters set forth herein and, if called upon, I could and

would completely testify thereto.

2. Attached hereto as Exhibit 1 is a true and correct copy of the PSLRA early notice.

3. Attached hereto as Exhibit 2 is a true and correct copy of the Movant’s PSLRA

Certification.

Case 1:26-cv-24485-RKA Document 40-2 Entered on FLSD Docket 08/28/2026 Page 2 of 3

4. Attached hereto as Exhibit 3 is a true and correct copy of a loss chart evidencing

Movant’s financial interest.

5. Attached hereto as Exhibit 4 Rosen Law’s firm resume.

I declare under the penalty of perjury that the foregoing is true and correct.

Executed: August 28, 2026

THE ROSEN LAW FIRM, P.A.

/s/Laurence M. Rosen
Laurence M. Rosen, Esq., Fla. Bar No. 0182877

Case 1:26-cv-24485-RKA Document 40-2 Entered on FLSD Docket 08/28/2026 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on August 28, 2026, a true and correct copy of the foregoing document

was served by CM/ECF to the parties registered to the Court’s CM/ECF system.

/s/Laurence M. Rosen
Laurence M. Rosen