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.; and TCA :

GLOBAL CREDIT FUND, LTD., :

:

Defendants, and :

:

TCA GLOBAL CREDIT FUND, LP;:

TCA GLOBAL CREDIT FUND, :

LTD.; TCA GLOBAL CREDIT :

MASTER FUND, LP, :

:

Defendants. :

WHISTLEBLOWER’S MOTION AND INCORPORATED

MEMORANDUM OF LAW SEEKING CLARIFICATION ON SCOPE OF 

BLANKET STAY AND RELIEF FROM THE SAME

COMES NOW Whistleblower Thomas Day (hereinafter “Day”), by and

through undersigned counsel, and, in compliance with Rule 7.1 of the Local Rules 

of the United States District Court in and for the Southern District of Florida, files

this, his Motion for Relief from Blanket Stay with Incorporated Memorandum of 

Law, seeking leave to file the attached lawsuit against TCA Fund Management 

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Group Corp, TCA Global Credit Fund, Ltd., Robert Press, Alyce Schreiber and 

William Fickling (Exhibit 1).

I. Factual Background

A. Day’s Employment with Defendant.

Thomas Day (“Day”) was hired as TCA’s Chief Credit Officer (“CCO”) in 

January 2018, was member of TCA’s executive leadership, and, in the scope of his 

professional duties, had access to information concerning TCA’s risk related 

policies and procedures, loan underwriting, portfolio administration, loan closings, 

cash disbursements, debt consolidation, working capital, loan portfolios, and 

ongoing transaction management. 

B. TCA’s Structure and Governance.

TCA was the acting investment manager of the TCA Global Credit Master 

Fund (“GCMF” or “the Fund”). TCA also managed and operated other funds 

which include, but may not be limited to: TCA Global Credit Fund GP, Ltd. (the 

general partner fund); TCA Global Credit Fund, LP (an onshore feeder fund); TCA 

Global Credit Fund, Ltd. (an offshore feeder fund, “GCF”); TCA Global Lending, 

Corp. (a US tax blocking entity); the Special Situations Credit Strategies ICAV (a 

fund registered in Ireland, or the “ICAV”); the TCA Opportunities Fund I, LP 

(“OPPS”); and the TCA Tamwheel UK LP (“TMWL”) (collectively, “the Funds”).

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Robert Press (“Press”) was the General Partner, Founder, and President of 

TCA and handled the flow of cash between the Funds and TCA and personnel 

decisions. 

Alyce Schreiber (“Schreiber”) was the acting CEO of TCA and, along with 

Press, handled the flow of cash between the Funds and TCA and personnel 

decisions. Schreiber appears to retain her position as TCA’s CEO. 

William Fickling (“Fickling”) was TCA’s former head of corporate 

restructuring, was TCA’s acting Chief Operating Officer (COO), and along with 

Press and Schreiber, handled the flow of cash between the Funds and TCA and 

personnel decisions. 

C. After Discovering TCA’s Fraud, Day Attempted to Escalate Issues Internally

and Report TCA to the Plaintiff.

Upon information and belief, the Securities and Exchange Commission 

(“SEC”) conducted an examination of TCA covering the period 2014 through 2015 

resulting in a findings memo signed by SEC Assistant Regional Director Jeannie 

Cabot. This memo was issued to TCA on March 3, 2016 and uncovered, among 

other things, accounting irregularities composed primarily of recording deals prior 

to loan closing to inflate TCA’s assets under management. 

Despite prior SEC scrutiny, beginning with his tenure at TCA, Day began to 

uncover what he reasonably believed was a new fraudulent scheme by TCA, 

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orchestrated by and through its directors and officers (including, but not limited to,

Press, Schreiber, and Fickling) to circumvent SEC detection while continuing to 

inflate TCA’s assets under management and offset losses.

1

 Day repeatedly raised 

questions with TCA’s officers, including Press, Schreiber, and Fickling about these 

practices, but was ignored, falsely assured these practices would cease, warned to 

not bring these issues up, or verbally abused. 

On December 24, 2019, Day submitted information on the SEC’s Tips, 

Complaints, and Referrals (“the TCR”) system regarding TCA. On January 7, 

2020, Day sent an email notifying TCA, its directors, officers, and other upper 

management personnel that he had filed the TCR after prior attempts to escalate his

concerns within TCA failed. 

D. After Learning Day Engaged in Protected Speech, TCA Immediately 

Retaliated Against Him.

A few hours after Day notified TCA about the TCR, TCA withdrew Day’s 

email and network access. On February 5, 2020, the undersigned counsel informed 

TCA’s counsel (Carl Schoeppl) that this constituted retaliation under the DoddFrank Act, 15 U.S.C. § 78u-6(h). On February 28, 2020, TCA terminated Day, 

claiming that TCA was winding down GCMF. 

 

1

TCA’s scheme and Day’ internal response thereto is detailed in the SEC’s original 

complaint in this action and in Day’s complaint which is attached hereto as Exhibit 1.

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Since his termination, Day has been unable to gain full employment. Until 

the SEC filed its complaint, he was unaware of the status of the SEC’s 

investigation and was concerned that if he candidly disclosed the reasons for his

departure from TCA to prospective employers it might compromise the SEC’s 

investigation. Day believes that this has frustrated his efforts to seek new 

employment because prospective employers have questions about their departure 

from TCA that they cannot completely answer. Indeed, prior to the SEC’s 

complaint, Day was mistakenly named as a defendant in a class action investor 

lawsuit against TCA and has been notified by prospective employers that they 

cannot consider him for employment because of the same when, in reality, he

prompted the SEC investigation.

E. TCA Officers Remain Employed After the Fund Winds Down and TCA 

Enters Receivership.

Despite TCA’s claims that it terminated Day because it was winding down 

the Fund, at least 10 people remained employed by TCA when the SEC filed its 

complaint over two months later. Along with five other employees, the Receiver 

retained Schreiber as TCA’s CEO. [Doc. 48 at 20]. Schreiber, along with another 

employee, was involved in processing Day’ attempts to access his TCA-sponsored 

401k retirement accounts. It appears that Schreiber maintained significant control 

over TCA’s operations even after the SEC sued TCA for investor fraud perpetrated 

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under her leadership. Although the Receiver has since dismissed Schreiber, it has 

entered consulting agreements with three employees who were responsible for 

TCA’s financial and administrative operations, including its controller and 

treasurer. [Doc. 48 at 21, 25-26]. 

II. Procedural Background

A. The SEC Files a Complaint and Consent Motion to Appoint the Receiver.

The SEC filed the underlying lawsuit on May 11, 2020. [Doc. 1]. On that 

same day, the SEC and TCA (by and through Carl Schoeppl) filed an unopposed 

expedited motion for the appointment of the Receiver. [Doc. 3]. The Court 

granted the motion the same day. Neither of Plaintiffs herein were consulted or 

notified of the motion in advance.

B. The Court Enters the Order Appointing the Receiver and Staying Litigation.

The Order Appointing the Receiver (“the Order”), among other things, stayed

All civil legal proceedings of any nature, including, but 

not limited to, bankruptcy proceedings, arbitration 

proceedings, foreclosure actions, default proceedings, or 

other actions of any nature involving: (a) the Receiver, in 

Receiver’s capacity as Receiver; (b) any Receivership 

Property, wherever located; (c) any of the Receivership 

Entities, including subsidiaries and partnerships; or, (d) 

any of the Receivership Entities’ past or present officers, 

directors, managers, agents, or general or limited partners 

sued for, or in connection with, any action taken by them 

while acting in such capacity of any nature, whether as 

plaintiff, defendant, third-party plaintiff, third-party 

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defendant, or otherwise (such proceedings are hereinafter 

referred to as “Ancillary Proceedings”). 

[Doc. 5 at ¶ 26]. It also stayed 

All Ancillary Proceedings . . . in their entirety, and all 

courts having any jurisdiction thereof are enjoined from 

taking or permitting any action until further Order of this 

Court. Further, as to a cause of action accrued or 

accruing in favor of one or more of the Receivership 

Entities against a third person or party, any applicable 

statute of limitation is tolled during the period in which 

this injunction against commencement of legal 

proceedings is in effect as to that cause of action.

[Id. at ¶ 28]. Lastly, it dismissed TCA’s “trustee, directors, officers, managers, 

employees, investment advisors, accountants, attorneys and other agents” and 

suspended their powers. [Id. at ¶ 5]. 

C. The Court Lifts Stay for a Creditor Seeking Injunctive Relief.

On June 9 2020, Lease Corporation of America (“LCA”) filed a motion to 

lift the stay so that it could recover certain equipment leased to Broward Collision, 

Inc., which it was entitled to under a lease agreement upon which Broward had 

defaulted. [Doc. 35 as ¶¶ 1, 5]. The Court granted this motion because LCA was 

not seeking “property that could legitimately be liquidated for the benefit of all 

creditors.” [Doc. 38].

D. Day Cooperates with the SEC and Receiver.

Since the outset of the TCR, Day has, at all times, endeavored to aid the 

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SEC and Receiver in the exercise of their duties. In addition to filing the initial 

TCR to alert the SEC to TCA’s attempts to avoid detection, Day provided the SEC 

with interviews and documents supportive of the TCR and the SEC’s lawsuit 

against TCA. 

When, to protect himself and investors, Day informed TCA of the TCR, 

TCA attempted to interview him. To ensure that he did not disclose confidential 

aspects of the SEC’s investigation, Day declined. Day, again cognizant of 

potentially compromising the SEC’s ongoing investigation, declined to file suit 

until the SEC completed its investigation or filed a complaint.

However, when the SEC ultimately filed a complaint simultaneously with 

the motion appointing the receiver, Day found that the Court’s Order precluded 

him from asserting his claims against TCA, its directors, and officers. 

Nevertheless, after the Court appointed the Receiver, Day cooperated fully with the 

Receiver’s investigation. To date, Day provided interviews and documents to the 

Receiver and directed it to other witnesses who may be helpful in recovering 

TCA’s assets. [Doc. 48 at 25-26].

In addition, Day has, pursuant to S.D. Fla. L.R 7.1, sought both the Receiver 

and the SEC’s consent to lift the stay so that he may assert the claims outlined in 

Exhibit 1. The SEC and Receiver have declined, citing their duties to investors.

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II. Argument and Citation to Authority

A. The Court Should Toll the Statute of Limitations for Day’s Claims.

Day requests that the Court order that TCA toll the statute of limitations for 

any actions that may accrue against TCA while the stay is in place. Without 

permission from this Court to timely pursue his claims, Day will be irreparably 

prejudiced because the Order may completely bar his claims. See S.E.C. v. 

Provident Royalties, L.L.C., No. 3:09-CV-1238-L, 2011 WL 2678840, at *3 (N.D. 

Tex. July 7, 2011) (holding that, in evaluating whether to lift a stay, a court must 

balance the preservation of the status quo against substantial injury to moving 

party) (citations omitted). However, tolling the statutes of limitations for Day’s

actions against TCA and its affiliates would not prejudice TCA or other interested

parties because it serves purposes analogous to the Order imposing the stay. [Doc. 

5 at ¶ 28 (tolling statute of limitations for actions brought by TCA against other 

entities)]. 

B. Day’s Claims Do Not Involve Property that May be Liquidated for the 

Benefit of All Creditors.

To Day’s knowledge, TCA has not submitted his complaint to its insurer to 

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confirm if his claims are an insured event. If Day’s claims, like many employment 

claims, are an insured event, then the Court should lift the stay because, like LCA, 

Day’s claims would not involve “property that could legitimately be liquidated for 

the benefit of all creditors.” [Doc. 38]. If, on the other hand, Day’s claims are an 

uninsured event, an unequivocal statement from TCA’s insurer that his claims are 

not covered would allow this Court and all interested parties to more fully assess 

TCA’s potential liabilities. Therefore, at the very least, the stay should be lifted so 

that Day’s claims can be submitted to TCA for limited discovery concerning

insurance coverage and a definitive determination concerning the same.

C. Day Requests Injunctive Relief that May Preserve TCA’s Assets.

Day’s complaint is not limited to monetary relief. He also requests equitable 

relief in the form of reinstatement. Should he be reinstated, his claims for 

monetary damages—in the form of back pay, front pay, and attorneys’ fees—

would substantially decrease, to the benefit of TCA and the Receiver. Although 

TCA claims Day was terminated because it was winding down, it is clear that, 

officers and employees who, in some cases, are directly implicated in TCA’s fraud

remained employed for several months after Day’s termination. [Docs. 48 at 11-

12, 19-21; 48-2]. 

It is also clear that the Receiver has retained professionals, including former 

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TCA employees, to assist in administering the Receivership. [Docs. 9, 11, 13-14, 

21, 31-34, 41-42]. At the time of writing, the Receiver has been unable to

complete the liquidation plan by the original August 7, 2020 due date and sought a 

90-day extension, which the Court granted. [Docs. 43-44]. The Receiver 

acknowledges that it “remains in its very early stages . . . will continue to manage 

the Receivership’s operating businesses, and determine a strategy to maximize 

their value . . . the same is true of the other receivership assets including the loan 

portfolio.” [Doc. 48 at 80]. 

Given, the Receiver’s reliance on TCA’s officers and retained professionals 

and need for deadline extensions, it is clear that a successful liquidation of TCA 

will require professionals who are intimately familiar with its internal processes,

the fraud underlying the SEC’s complaint and who have potential knowledge and 

forensic skills to assist in locating assets which may be hidden to evade SEC 

enforcement. Day—as TCA’s former chief credit—is, perhaps more than most, 

uniquely positioned to do this. More importantly, employing him will mitigate the 

damages Day may have if and when the stay is lifted. It will also ensure that TCA 

has full access to Day and his institutional knowledge, which we believe is 

necessary to protect and preserve TCA’s assets in the most efficient and 

expeditious manner. Therefore, the equitable relief Day seeks, in the form of 

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remunerative employment, may assist the Receiver in its mission by identifying

and preserving the Receivership assets for investors.

D. The Factors Favor Lifting the Stay as to Day.

While this Court has discretion to stay litigation in federal courts, 

[w]hen determining whether a stay against litigation 

should be lifted, the Court considers: (1) whether 

refusing to lift the stay genuinely preserves the status quo 

or whether the moving party will suffer substantial injury 

if not permitted to proceed; (2) the time in the course of 

the receivership at which the motion for relief from the 

stay is made; and (3) the merit of the moving party’s 

underlying claim. 

S.E.C. v. Onix Capital, LLC, No. 16-24678-CIV, 2017 WL 6728814, at *3 (S.D. 

Fla. July 24, 2017) (citing S.E.C. v. Wencke, 742 F.2d 1230, 1231 (9th Cir. 1984); 

S.E.C. v. Byers, 592 F. Supp. 2d 532, 536-37 (S.D.N.Y. 2008), aff'd, 609 F.3d 87 

(2d Cir. 2010); U.S. v. Acorn Tech. Fund, L.P., 429 F.3d 438, 445 (3d Cir. 2005); 

S.E.C. v. Stanford Int'l Bank, Ltd., 424 Fed.Appx. 338, 341-42 (5th Cir. 2011)). 

Here, the context of the case, the stay’s indeterminate duration, the potential 

substantial prejudice Day will experience if the stay continues, and the chilling 

affect that maintaining the stay will have on prospective SEC whistleblowers favor 

lifting the stay. 

The first factor weighs in favor of lifting the stay. As discussed previously, 

the stay is currently of an indeterminate duration which has already, and may 

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continue to, preclude Day from making any claims against TCA, its officers, 

directors, or other affiliates. However, it is not clear that lifting the stay would 

alter the status quo. As previously discussed, there is no indication that Day’s

claims would affect property that the Receiver can liquidate, which is the purported 

rationale for imposing the stay. Therefore, continuing the stay presents substantial 

and possibly irreparable prejudice to the movants, whereas lifting it causes no 

apparent disruption to the status quo. 

Under the second factor, little time has elapsed since the imposition of the 

stay, which does not weigh in the movants’ favor. However, the third factor—the 

relative merits of the movant’s claims—weighs in their favor. Day seeks to bring 

claims for retaliation under SOX, which requires a showing 

that “(i) the employee engaged in a protected activity or 

conduct; (ii) the [employer] knew or suspected, actually 

or constructively, that the employee engaged in the 

protected activity; (iii) the employee suffered an 

unfavorable personnel action; and (iv) the circumstances 

were sufficient to raise the inference that the protected 

activity was a contributing factor in the unfavorable 

action.” 

Thomas v. Tyco Int'l Mgmt. Co., LLC, 416 F. Supp. 3d 1340, 1357 (S.D. Fla.

2019) (quoting Johnson v. Stein Mart, Inc., 440 F.App'x 795, 800-1 (11th Cir.

2011)). The complaint also contains whistleblower retaliation claims under the 

Dodd-Frank Act, 15 U.S.C. § 78u-6, which requires that: he (1) engaged in 

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protected activity; (2) suffered a materially adverse employment action; and (3) 

the adverse action was causally connected to the protected activity.” Id. at 1367 

(quoting Hall v. Teva Pharmaceutical USA, Inc., 214 F. Supp. 3d 1281, 1289 

(S.D. Fla. 2016)). In addition, he brings claims under Florida’s Whistleblower 

Act, Fla. Stat. 448.102(3) (“FWA”), which is analyzed using Title VII retaliation 

claim framework. See Rutledge v. SunTrust Bank, 262 Fed. Appx. 956, 957-58 

(11th Cir. 2008). Under the FWA, a whistleblower must show that he (1) engaged 

in a statutorily protected activity by objecting to or refusing to participate in any 

employer activity, policy or practice that was in actual violation of an adopted 

law, rule or regulation; (2) he has suffered an adverse employment action; and (3) 

the adverse employment action was causally linked to the statutorily protected 

activity. See Bell v. Ga.-Pac. Corp., 390 F. Supp. 2d 1182, 118788 (M.D. Fla. 

2005).

Here, provided he is permitted to administratively exhaust his SOX claims, 

Day can establish a prima facie case of retaliation under SOX, Dodd-Frank, or the 

FWA. First, he engaged in protected activity by informing TCA’s officers about 

his concerns about fraudulent reporting of assets and returns, filing the TCR, and 

informing TCA of the same. Second, as evidenced by the SEC’s decision to file 

the underlying claims against TCA, Day’s belief that TCA was violating the law 

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was reasonable. Third, Day suffered adverse action because TCA locked him out 

of work immediately after learning of his protected activity and, a month later, 

terminated him. Fourth, the fact that other TCA employees—including those 

junior to Day and without the necessary expertise to assist TCA in winding down 

the Fund—remained employed raises an inference that his termination was 

causally related to their protected activity. 

Lastly, the balance of the equities and the public interest favor lifting the 

stay as to Day. Day has already suffered substantially at the hands of TCA and its 

officers and directors due to his efforts to protect investors and prevent the fraud 

underlying this lawsuit. Indeed, were it not for Day’s willingness to notify the 

SEC of TCA’s fraud, it is doubtful that the SEC would have uncovered it, 

prosecuted it, and the investors would have been in any position to recover 

anything. As a result of Day’s actions, he was denied his bonuses and other 

compensation due to him, locked out of work, harassed and threatened by TCA and 

its employees, and terminated. Even so, Day continued to preserve the 

confidentiality of the SEC’s investigation and refrained from filing a lawsuit that 

might compromise the investigation underlying their retaliation claims. Day has

not secured new employment and, now, the Court’s Order precludes him from 

even bringing claims against TCA for retaliating against him for filing the very 

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TCR that resulted in the underlying action. 

If this is what whistleblowers can expect when they bring fraud to the SEC’s 

attention, it will undoubtedly chill future whistleblower activity. This is especially 

so in today’s post-Covid socioeconomic climate, where job openings are few, fraud 

may be particularly rampant, and the ability of government entities to directly 

interact with the institutions it regulates may be limited. Indeed, the SEC recently 

acknowledged as much, noting that “in these dynamic circumstances, corporate 

insiders are regularly learning new material nonpublic information that may hold 

an even greater value than under normal circumstances.” Statement from SEC Dir. 

Enforcement Stephanie Avakian, Steven Peikin, https://www.sec.gov/news/publicstatement/statement-enforcement-co-directors-market-integrity (Mar. 23, 2020). 

By making it difficult for Day to preserve his claims, let alone pursue them, the 

Court sends a message that would-be whistleblowers have no legal recourse should 

their protected speech result in retaliation, in effect, abrogating Dodd-Frank.

III. Conclusion

For the foregoing reasons, Day requests that the Court lift the blanket stay as 

it applies to his whistleblower claims. In the alternative, Day requests that the 

Court order TCA and its officers, directors, and all other parties covered by the 

stay to toll the statute of limitations for Day’s claims and permit Day to file his 

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complaint and conduct discovery for the limited purpose of definitely determining 

if their claims are an insured event under TCA’s applicable policies.

Certificate of Conferral 

Lead counsel for Plaintiff previously contacted counsel for Defendants, who indicated

that Defendants oppose the relief sought in this Motion.

Respectfully submitted this 28th day of February 2022.

 

BUCKLEY BEAL, LLP

 s/ Edward D. Buckley

 Edward D. Buckley

 Pro Hac Vice Pending

Georgia Bar No. 092750

edbuckley@buckleybeal.com

600 Peachtree Street NE, Suite 3900

Atlanta, Georgia 30308

Telephone: (404) 781-1100 

Facsimile: (404) 781-1101

HESS LAW FIRM

s/ Ephraim R. Hess 

Ephraim Roy Hess

Florida Bar No. 983100

erh@thehessfirm.com

erhpalaw@gmail.com

205 Davie Boulevard

Fort Lauderdale, Florida 33315

Telephone: (954) 585-8599

Attorneys for Plaintiff

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on FEBRUARY 28th , 2022, 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.

s/ Ephraim R. Hess 

Ephraim Roy Hess, Esquire

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