UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-CIV-21964-CMA

SECURITIES AND EXCHANGE 

COMMISSION,

Plaintiff,

v.

TCA FUND MANAGEMENT GROUP CORP., 

et al.,

Defendants.

______________________________________/

RECEIVER, JONATHAN E. PERLMAN’S, EXPEDITED MOTION TO APPROVE 

RETAINED PROFESSIONALS

Basis for expedited relief:

The Receiver seeks relief on an expedited basis on or before 

Thursday, May 14, 2020 because it has come to the Receiver’s 

attention that certain actions need to be taken immediately in order 

to meet with the timely reporting requirements in the Court’s 

Appointment Order which cannot be completed without the 

assistance of the below-reference professional services. 

COMES NOW, Jonathan E. Perlman, Esq., Court-Appointed Receiver (“Receiver”) of the 

Receivership Entities,

1 by and through undersigned counsel, and pursuant to L.R. 7.1(d)(2) hereby 

files this Expedited Motion to Approve Retained Professionals and accordingly states as follows:

1. On May 11, 2020, the Securities and Exchange Commission (“SEC”) filed its 

Complaint for Injunctive Relief against TCA Fund Management Group, Corp., TCA Global Credit 

Fund GP, LTD., (“Receivership Defendants”), and TCA Global Credit Fund, LP, TCA Global 

Credit Fund, LTD., and TCA Global Credit Master Fund, LP (“Relief Defendants”) (collectively,

“Defendants”). [ECF No. 1]. 

 

1 All terms not specifically defined herein have the meaning ascribed to them in the SEC’s Motion for Appointment 

of Receiver [ECF No. 3] and the Court’s Appointment Order [ECF No. 5]. 

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2. The SEC also filed an Expedited Motion for Appointment of Receiver. [ECF No. 

3]. 

3. On the same day, the Court granted the motion and appointed Jonathan E. Perlman, 

Esq., of the law firm Genovese Joblove & Battista, P.A. (“GJB”), as permanent Receiver over the 

Receivership Entities [ECF No. 5] (“Appointment Order”).

4. The Appointment Order immediately granted the Receiver authority to retain GJB 

as counsel. Id. at § I ¶ 2. Receiver’s counsel has entered appearances accordingly. 

5. Pursuant to the Appointment Order, the Receiver is empowered to, among other 

things, “engage and employ persons in Receiver’s discretion to assist Receiver in carrying out 

Receiver’s duties and responsibilities...” Id. at § II ¶ 5.F. 

6. Further, pursuant to § XIV ¶¶ 52–53, the Receiver may solicit persons and entities 

(“Retained Personnel”) to assist the Receiver in carrying out his duties under the Appointment 

Order. Retained Personnel may only be engaged after “Order of the Court authorizing such 

engagement.” Id.

7. Acting under the express authority of the Appointment Order the Receiver has 

solicited the following professions which in his best judgment are highly experienced in their 

respective fields and would best be able to assist the Receiver in carrying out his duties. 

Accordingly, the Receiver seeks this Court’s approval for their formal engagement as Retained 

Professionals:

a. Forensic Accounting and Financial Investigations: Maria M. Yip, CPA with 

Yip Associates. Yip Associates have agreed to the following hourly rates: $340 for 

Partners, $295 for Directors, $245 for Managers and Senior Associates, $195 for 

Associates, and $100 for Paraprofessionals. Additional details regarding Mrs. Yip’s CV 

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and Yip Associate’s rate card information are attached as Exhibit A.

b. Tax Accounting and Analysis: Mitchell Hall, CPA, JD, LLM with 

Rehmann. Rehmann has agreed to the following hourly rates: Executive at $300, Senior at 

$215, Staff at $150, Administrative Staff at $75, and Travel at $150. Additional details 

regarding the Rehmann team and rate card information are attached as Exhibit B.

c. Data storage and document review platform: E-Hounds. E-Hounds has 

agreed to provide the following hourly rates: Standard: $195, Expert Consultant $300, File 

Conversion $95-195 per GB, Intake and Preservation $225 per media, Triage Service 

$1000 flat rate per computer, and additional services as provided in the attached agreement. 

Additional details regarding Adam D. Sharp’s CV and rate card information, and 

information regarding E-Hounds services and capabilities are attached as Exhibit C.

8. None of the above professionals have requested retainers and have all committed 

to significant discounts of their usual hourly rates for their work in this matter. 

9. Engagement of these professionals is sought on an expedited basis to facilitate the 

transition and early marshalling of all the Receivership Assets for eventual recovery to the 

investor-victims. 

10. Each of these professionals has prior experience in similar matters and have advised 

the Receiver that no conflicts of interest exist in connection with their potential retention in this 

matter. 

WHEREFRORE, Receiver, Jonathan E. Perlman, by and through his undersigned counsel 

respectfully requests that this Honorable Court grant the expedited motion and approve each of the 

Receiver’s solicited professionals for engagement on this matter. A proposed order for the Court’s 

consideration is attached as Exhibit D. 

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GENOVESE JOBLOVE & BATTISTA, P.A.

Attorneys for Jonathan E. Perlman, Receiver

100 Southeast 2nd Street, Suite 4400

Miami, Florida 33131

Telephone: (305) 349-2300

Facsimile: (305) 349-2310

By: /s/Irina R. Sadovnic

Irina R. Sadovnic, Esq., FBN 124502

Isadovnic@gjb-law.com

CERTIFICATE OF CONFERENCE

I, Irina Sadovnic, Esq., hereby certify that I conferred with Stephanie Moot, via phone and 

e-mail correspondence on May 13, 2020, regarding the requested relief and she indicated that the 

SEC has no objection to the relief sought in the motion.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing was served via CM/ECF Notification 

and/or U.S. Mail to all parties and notification of such filing to all CM/ECF participants in this 

case on the 13th day of May, 2020.

By: /s/ Irina R. Sadovnic

 Irina R. Sadovnic, Esq.

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