Reynolds v. Citadel Securities LLC — Entry #39: MOTION to Appoint Lead Plaintiff Jordan Dario Primo by Jordan Dario Primo
Case: Reynolds v. Citadel Securities LLC flsd · 1:26-cv-24485
filed June 29, 2026
What this document is
Docket entry #39 · filed August 28, 2026
MOTION to Appoint Lead Plaintiff Jordan Dario Primo by Jordan Dario Primo. Attorney Nathan C. Zipperian added to party Jordan Dario Primo(pty:mov). Responses due by 9/11/2026. (Attachments: # 1 Affidavit Declaration of Nathan Zipperian in Support of Motion of Movant JORDAN DARIO PRIMO for Appointment as Lead Plaintiff, # 2 Exhibit A - Damages Analysis, # 3 Exhibit B - Certification and Schedule A, # 4 Exhibit C - June 29, 2026 Press Release, # 5 Exhibit D - Movant Declaration, # 6 Exhibit E - Pomerantz Firm Resume, # 7 Exhibit F - Miller Shah Firm Resume, # 8 Text of Proposed Order)(Zipperian, Nathan) (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.
Document text
3 page(s), 3,024 characters, converted from the PDF's text layer · plain text.
Full text
Case 1:26-cv-24485-RKA Document 39-1 Entered on FLSD Docket 08/28/2026 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No. 1:26-24485-Civ-ALTMAN
ARON REYNOLDS, individually and on CLASS ACTION
behalf of all others similarly situated,
Plaintiff,
v.
CITADEL SECURITIES LLC and VIRTU
AMERICAS LLC,
Defendants.
DECLARATION OF NATHAN C. ZIPPERIAN IN SUPPORT OF MOTION OF
MOVANT JORDAN DARIO PRIMO FOR APPOINTMENT AS LEAD PLAINTIFF
AND APPROVAL OF SELECTION OF COUNSEL
Case 1:26-cv-24485-RKA Document 39-1 Entered on FLSD Docket 08/28/2026 Page 2 of 3
I, Nathan C. Zipperian, hereby declare as follows:
1. I am a partner at Miller Shah LLP (“Miller Shah”), counsel on behalf of Jordan
Dario Primo (“Primo”), and have personal knowledge of the facts set forth herein. I make this
Declaration in support of Primo’s motion for appointment as Lead Plaintiff for the Class in the
above-captioned action (the “Action”) and approval of his selection of Pomerantz LLP
(“Pomerantz”) as Lead Counsel and Miller Shah as Liaison Counsel for the Class.
2. Attached hereto as the exhibits indicated are true and correct copies of the
following:
Exhibit A: Chart setting forth Primo’s financial interest in this litigation;
Exhibit B: Shareholder Certification executed by Primo;
Exhibit C: Press release published via Business Wire on June 29, 2026,
announcing the pendency of the Action;
Exhibit D: Declaration executed by Primo;
Exhibit E: Firm resume of Pomerantz; and
Exhibit F: Firm resume of Miller Shah.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing facts are true and correct.
Executed on August 28, 2026.
/s/ Nathan C. Zipperian
Nathan C. Zipperian
1
Case 1:26-cv-24485-RKA Document 39-1 Entered on FLSD Docket 08/28/2026 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on August 28, 2026, I electronically filed a true and correct copy of
the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the
foregoing document is being served this day on all counsel of record via CM/ECF.
/s/ Nathan C. Zipperian
Nathan C. Zipperian
2