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


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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


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