Reynolds v. Citadel Securities LLC — Entry #45: NOTICE of Supplemental Information by Aron Reynolds re 9 Defendant's MOTION to Remand /Transfer to the Southern District of New York

Case 1:26-cv-24485-RKA Document 45 Entered on FLSD Docket 09/15/2026 Page 1 of 3


                             UNITED STATES DISTRICT COURT
                             SOUTHERN DISTRICT OF FLORIDA


   ARON REYNOLDS, individually and on                 Case No. 1:26-cv-24485-RKA
   behalf of all others similarly situated,

                                  Plaintiff,          CLASS ACTION

                      v.

   CITADEL SECURITIES LLC and VIRTU
   AMERICAS LLC,

                                  Defendants.


                       NOTICE OF SUPPLEMENTAL INFORMATION

         Plaintiff Aron Reynolds submits this notice concerning the Motion to Transfer (ECF No.

  9) filed by Citadel Securities LLC and Virtu Americas LLC (“Defendants”). Defendants rest their

  motion largely on Judge Caproni’s supposed familiarity with the Genius litigation. A single,

  procedural, non-merits decision, on a lead-plaintiff application brought by a different movant, not

  Reynolds.

         Defendants have since taken the opposite position in Lovato v. Citadel Securities LLC (In

  re Meta Materials Inc.), Adv. Proc. No. 26-05036-gs (Bankr. D. Nev.). There, represented by the

  same counsel as here, Citadel and Virtu have moved to withdraw an adversary proceeding from a

  bankruptcy court far more familiar with the underlying dispute. Since March 2025, the Meta

  Materials Trustee has pursued Rule 2004 subpoenas against Citadel and Virtu over alleged

  manipulation of Meta Materials securities. Defendants fought that discovery through several

  rounds of briefing and two hearings. On February 20, 2026, the bankruptcy court ordered them to

  produce the materials; it found the Trustee was entitled to investigate potentially viable claims

  against Defendants. Defs.’ Mot. to Withdraw Reference at 5–6, 17, Lovato, ECF No. 23 (Ex. A).


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Case 1:26-cv-24485-RKA Document 45 Entered on FLSD Docket 09/15/2026 Page 2 of 3


          Yet Defendants just asked the Nevada district court to take that action away from the

  bankruptcy court. In their briefing, their motion gives no weight to the bankruptcy court’s year of

  supervising the investigation—the discovery disputes, the hearings, and the substantive Rule 2004

  ruling—as a reason to keep the resulting litigation there. Instead, they dismiss forum-shopping

  concerns on the ground that they moved to withdraw before the substantive ruling against them.

  Id. at 17.

          Defendants’ double standard demonstrates the only forum shopping here is being done by

  Defendants, not Plaintiff. Where a court has ruled in their favor, minimal judicial engagement

  becomes a reason to keep all litigation there. But where a court has ruled against them, the court’s

  year-plus familiarity matters not.

          While Defendants claim this action should be transferred to New York to prevent forum

  shopping – it’s apparent that denial of the motion is what’s necessary to prevent forum shopping.


   DATED: September 15, 2026                     Respectfully submitted,

                                                 Devin Velvel Freedman
                                                 FREEDMAN NORMAND FRIEDLAND LLP
                                                 Devin (Velvel) Freedman
                                                 1815 Purdy Avenue
                                                 Miami, FL 33139
                                                 Telephone: (786) 924-2900
                                                 [email protected]

                                                 GRANT & EISENHOFER P.A.
                                                 Abe Alexander (pro hac vice)
                                                 Vincent J. Pontrello (pro hac vice)
                                                 485 Lexington Avenue
                                                 New York, NY 10017
                                                 Telephone: (646) 722-8500
                                                 Facsimile: (610) 722-8501
                                                 [email protected]
                                                 [email protected]


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Case 1:26-cv-24485-RKA Document 45 Entered on FLSD Docket 09/15/2026 Page 3 of 3


                                      Counsel for Plaintiff Aron Reynolds and
                                      Proposed Lead Counsel for the Class


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