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
4 page(s), 8,293 characters, converted from the PDF's text layer · plain text.
Full text
Case 1:26-cv-24485-RKA Document 39-3 Entered on FLSD Docket 08/28/2026 Page 1 of 4
EXHIBIT B
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Case 1:26-cv-24485-RKA Document 39-3 Entered on FLSD Docket 08/28/2026 Page 2 of 4
CERTIFICATION PURSUANT
TO FEDERAL SECURITIES LAWS
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1. I, __________________________________________, make this declaration pursuant
to Section 27(a)(2) of the Securities Act of 1933 (“Securities Act”) and/or Section 21D(a)(2) of the
Securities Exchange Act of 1934 (“Exchange Act”) as amended by the Private Securities Litigation
Reform Act of 1995.
2. I have reviewed a Complaint on behalf of investors in Genius Group Limited (“Genius”)
and authorize the filing of a motion for appointment as lead plaintiff on my behalf.
3. I did not purchase or otherwise acquire, or sell or otherwise dispose of, Genius securities
at the direction of plaintiffs’ counsel or in order to participate in any private action arising under the
Securities Act or Exchange Act.
4. I am willing to serve as a representative party on behalf of a Class of investors who
purchased or otherwise acquired, or sold or otherwise disposed of, Genius securities during the Class
Period as specified in the Complaint, including providing testimony at deposition and trial, if necessary.
I understand that the Court has the authority to select the most adequate lead plaintiff in this action.
5. The attached sheet lists all of my transactions in Genius securities during the Class
Period as specified in the Complaint.
6. During the three-year period preceding the date on which this Certification is signed, I
have not served or sought to serve as a representative party on behalf of a class under the federal
securities laws.
7. I agree not to accept any payment for serving as a representative party on behalf of the
Class as set forth in the Complaint, beyond my pro rata share of any recovery, except such reasonable
costs and expenses directly relating to the representation of the class as ordered or approved by the
Court.
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Case 1:26-cv-24485-RKA Document 39-3 Entered on FLSD Docket 08/28/2026 Page 3 of 4
8. I declare under penalty of perjury under the laws of the United States of America that
the foregoing is true and correct.
Executed _____________________________
(Date)
_______________________________________
(Signature)
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_______________________________________
(Type or Print Name)
Case 1:26-cv-24485-RKA Document 39-3 Entered on FLSD Docket 08/28/2026 Page 4 of 4
Genius Group Limited (GNS) Jordan Dario Primo
List of Purchases/Acquisitions and Sales
Transaction Number of Price Per
Type Date Shares/Unit Share/Unit
Purchase/Acquisition 8/9/2024 142,215.67100 $0.2102
Purchase/Acquisition 8/12/2024 30,673.57520 $0.1692
Purchase/Acquisition 8/13/2024 29,297.41570 $0.1365
Purchase/Acquisition 8/14/2024 37,873.49480 $0.1346
Purchase/Acquisition 8/15/2024 12,863.21090 $0.1422
Purchase/Acquisition 8/16/2024 1,583.70114 $1.2359
Purchase/Acquisition 8/20/2024 981.27917 $1.1979
Purchase/Acquisition 8/23/2024 3,142.97757 $1.1391
Purchase/Acquisition 8/27/2024 24.13793 $1.1600
Purchase/Acquisition 9/4/2024 61.88949 $0.8887
Purchase/Acquisition 9/9/2024 142.79594 $0.7003
Purchase/Acquisition 9/10/2024 729.92700 $0.6850
Purchase/Acquisition 9/11/2024 2,992.13379 $0.7779
Purchase/Acquisition 9/12/2024 5,978.44680 $0.7527
Purchase/Acquisition 9/24/2024 3,540.91093 $0.8472
Purchase/Acquisition 9/30/2024 56.94112 $0.8781
Purchase/Acquisition 10/4/2024 57.39869 $0.8711
Purchase/Acquisition 10/7/2024 731.72582 $0.8200
Purchase/Acquisition 10/8/2024 2,084.00000 $0.8387
Purchase/Acquisition 10/9/2024 678.15000 $0.7373
Purchase/Acquisition 10/16/2024 330.60037 $0.7562
Purchase/Acquisition 10/23/2024 3,239.10482 $0.6792
Purchase/Acquisition 11/1/2024 3,752.68948 $0.5942
Purchase/Acquisition 11/5/2024 1,587.30158 $0.5670
Purchase/Acquisition 11/12/2024 7,210.10077 $1.1231
Purchase/Acquisition 11/13/2024 11,307.57272 $1.1015
Purchase/Acquisition 11/14/2024 2,447.65586 $0.8171
Purchase/Acquisition 11/15/2024 347.34698 $0.8349
Purchase/Acquisition 12/9/2024 2,424.24242 $0.8250
Purchase/Acquisition 12/16/2024 129.63443 $0.7714
Purchase/Acquisition 12/20/2024 8,247.31604 $0.5565
Purchase/Acquisition 1/3/2025 429.67658 $0.6982
Purchase/Acquisition 1/13/2025 1,828.89154 $0.6025
Purchase/Acquisition 1/14/2025 554.78512 $0.6309
Purchase/Acquisition 1/28/2025 55.05092 $0.5450
Purchase/Acquisition 2/21/2025 471.69811 $0.4240
Purchase/Acquisition 3/19/2025 287.87333 $0.2780
Purchase/Acquisition 3/24/2025 3,330.88326 $0.2998
Purchase/Acquisition 3/25/2025 3,226.54521 $0.3100
Purchase/Acquisition 3/28/2025 1,910.39973 $0.2496
Purchase/Acquisition 4/2/2025 2,077.63311 $0.2504
Purchase/Acquisition 4/14/2025 196.38648 $0.2547
Purchase/Acquisition 4/24/2025 20.00000 $0.3200
Purchase/Acquisition 5/19/2025 134.12017 $2.1839
Purchase/Acquisition 5/27/2025 301.29557 $2.1327
Purchase/Acquisition 5/30/2025 95.75486 $2.0517
Sale 5/27/2025 (14,221.56710) $0.3593