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.
Document text
4 page(s), 4,113 characters, converted from the PDF's text layer · plain text.
Full text
Case 1:26-cv-24485-RKA Document 40-4 Entered on FLSD Docket 08/28/2026 Page 1 of 4
Exhibit 2
Case 1:26-cv-24485-RKA Document 40-4 Entered on FLSD Docket 08/28/2026 Page 2 of 4
Certification and Authorization of Named Plaintiff Pursuant to Federal
Securities Laws
The individual or institution listed below (the "Plaintiff") authorizes and, upon execution of the accompanying
retainer agreement by The Rosen Law Firm P.A., retains The Rosen Law Firm P.A. to file an action under the
federal securities laws to recover damages and to seek other relief against Genius Group Limited.
The Rosen Law Firm P.A. will prosecute the action on a contingent fee basis not to exceed one-third of the
recovery and will advance all costs and expenses. All payments of fees and expenses shall be made only
after Court review and approval. The Genius Group Limited Retention Agreement provided to the Plaintiff is
incorporated by reference herein and is effective, upon execution and delivery by The Rosen Law Firm P.A.
First Name: Duc
Middle Initial: V
Last Name: To
Mailing Address:
Redacted
City:
State:
Zip Code:
Country:
Phone:
Email Address:
Plaintiff certifies that:
1. Plaintiff has reviewed a complaint and authorized its filing or the filing of an amended complaint.
2. Plaintiff did not acquire the security that is the subject of this action at the direction of plaintiff's counsel
or in order to participate in this private action or any other litigation under the federal securities laws.
3. Plaintiff is willing to serve as a representative party on behalf of a class, including providing testimony at
deposition and trial, if necessary.
4. Plaintiff represents and warrants that he/she/it is fully authorized to enter into and execute this
certification.
5. Plaintiff will not accept any payment for serving as a representative party on behalf of the class beyond
Plaintiff's pro rata share of any recovery, except such reasonable costs and expenses (including lost
wages) directly relating to the representation of the class as ordered or approved by the court.
6. Plaintiff has made no transaction(s) during the Class Period in the debt or equity securities that are the
subject of this action except those set forth below:
Purchases: See attached Schedule A
Sales:
I have not sought to serve as a representative party on behalf of a class under the federal securities
laws during the last three years, except if set forth below.
I declare and certify under penalty of perjury, under the laws of the United States YES
of America, that the foregoing information is true and correct.
By Signing below and submitting this certification form electronically, I intend to YES
sign and execute this certification pursuant to California Civil Code Section
1633.1, et seq. - and the Uniform Electronic Transactions Act and retain the
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Case 1:26-cv-24485-RKA Document 40-4 Entered on FLSD Docket 08/28/2026 Page 3 of 4
Rosen Law Firm, P.A. to proceed on Plaintiff's behalf, on a contingent fee basis.
Date of signing: 08/14/2026 16:56:53 at Eastern Standard Time, USA
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Case 1:26-cv-24485-RKA Document 40-4 Entered on FLSD Docket 08/28/2026 Page 4 of 4
SCHEDULE A
DUC TO TRANSACTIONS
PURCHASES
Date Shares Price
8/3/2023 1,185 ($7.61)
8/3/2023 1,317 ($7.27)
8/3/2023 27,190 ($6.54)
SALES
Date Shares Price
8/3/2023 2,502 $7.07
