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.

_________________________________/

SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY IN 

SUPPORT OF FIRST INTERIM DISTRIBUTION PLAN

Jonathan E. Perlman, Esq., court-appointed Receiver (the “Receiver”) of the Receivership 

Entities,

1 and the Securities and Exchange Commission (“SEC”), by and through undersigned 

counsel, hereby file this Second Unopposed Motion for Extension of Time to File Reply in Support 

of First Interim Distribution Plan (the “Motion”) and states as follows:

1. On February 28, 2022, the Receiver filed his Motion for Approval of Distribution 

Plan and First Interim Distribution (“the Distribution Plan”). [ECF No. 208]. 

2. Thereafter, on March 2, 2022, the Receiver filed his Unopposed Motion to Approve 

Deadline for Responses and Objections to Receiver’s Motion for Approval of Distribution Plan 

and First Interim Distribution, which this Court subsequently granted. [ECF No. 214, 215].

3. The order granting the Receiver’s Unopposed Motion to Approve Deadline for 

Responses and Objections to Receiver’s Motion for Approval of Distribution Plan and First 

 

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], and 

the Court’s First Expansion Order [ECF No. 16]. 

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CASE NO. 20-CIV-21964-CMA

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Interim Distribution set forth certain deadlines, including an April 29, 2022 deadline by which 

interested parties must submit comments and responses to the Court and Receiver in connection 

with the proposed Distribution Plan. See [ECF No. 215].

4. The Receiver and SEC’s reply to the comments and responses to the Distribution 

Plan is currently due on or before June 6, 2022. 

5. The Receiver has been working diligently to prepare his Reply in Support of the 

Distribution Plan. Despite good faith and reasonable efforts, the Receiver requires additional time 

to prepare Reply in Support of the Distribution Plan and a Motion for Approval of Amended 

Distribution Plan and First Amended Interim Distribution.

6. By way of this Motion, the Receiver seeks three (3) additional days, through and 

including June 9, 2022 to file his Reply in Support of the Distribution Plan and a Motion for 

Approval of Amended Distribution Plan and First Amended Interim Distribution.

7. Counsel for the Receiver conferred with the SEC and counsel for Ms. Eleanor 

Fisher and Ms. Tammy Fu, both of EY Cayman Ltd., as joint official liquidators (“JOLs”) over 

Receivership Entity Feeder Fund Ltd. regarding the extension of time sought by way of this 

Motion. Counsel for the JOLs advised that both the SEC and the JOLs consent to the requested 

extension.

8. This extension of time is made in good faith, will not unduly prejudice any of the 

parties, and is not sought for the purposes of delay. 

9. Accordingly, for the good cause set forth above, the Receiver respectfully requests

that this Court grant this Motion and grant the Receiver an extension of time through and including 

June 9, 2022 to file his Reply in Support of the Distribution Plan.

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CASE NO. 20-CIV-21964-CMA

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WHEREFORE, Receiver, Jonathan E. Perlman, and the Securities and Exchange 

Commission, by and through his undersigned counsel, respectfully requests this Court grant the 

Second Unopposed Motion for Extension of Time to File Reply in Support of First Interim 

Distribution Plan and extend the Receiver’s deadline to file his Reply in Support of First Interim 

Distribution Plan through and including June 9, 2022, and grant such other relief this Court deems 

just and proper. 

S.D. Fla. L.R. 7.1(A)(3) CERTIFICATE OF CONFERENCE

Undersigned counsel hereby certifies that counsel for the Receiver, Patrick Kalbac, 

conferred with counsel for the JOLs, Mark Bloom, on June 6, 2022, via email, regarding the 

requested relief and is authorized to represent that the JOLs have no objection to the relief 

requested herein.

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/ Patrick Kalbac

Greg M. Garno, Esq.

Florida Bar No. 87505

Patrick Kalbac, Esq.

Florida Bar No. 1011649

pkalbac@gjb-law.com

CERTIFICATE OF SERVICE

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

to all parties and notification of such filing to all CM/ECF participants in this case on the 6th day 

of June, 2022.

/s/ Patrick Kalbac

 Patrick Kalbac, Esq.

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CASE NO. 20-CIV-21964-CMA

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SERVICE LIST

Securities and Exchange Commission v. TCA Fund Management Group Corp., et al.

Case No. 20-Civ-21964-CMA

Jean-Pierre Bado, Esq

jbado@gjb-law.com

Paul Joseph Battista, Esq.

pbattista@gjb-law.com

Michael A Friedman, Esq.

mfriedman@gjb-law.com

Gregory M. Garno, Esq.

ggarno@gjb-law.com

John H. Genovese, Esq.

jgenovese@gjb-law.com

Brett M. Halsey, Esq.

bhalsey@gjb-law.com

Heather L. Harmon, Esq.

hharmon@gjb-law.com

Eric Jacobs, Esq.

ejacobs@gjb-law.com

Elizabeth G. McIntosh, Esq.

emcintosh@gjb-law.com

Jonathan Perlman, Esq.

jperlman@gjb-law.com

Thaddeus Kleckley, Esq.

tkleckley@gjb-law.com

Genovese Joblove & Battista, P.A.

100 Southeast 2nd Street, Suite 4400

Miami, Florida 33131

Attorneys for Jonathan E. Perlman, 

Receiver

Andrew O. Schiff, Esq.

schiffa@sec.gov

Stephanie N. Moot, Esq.

moots@sec.gov

801 Brickell Avenue, Suite 1950

Miami, Florida 33131

Attorneys for Plaintiff Securities and 

Exchange Commission

James J. Webb, Esq.

jwebb@mitrani.com

Mitrani, Rynor, Adamsky & Toland, P.A.

1200 Weston Road, PH

Weston, FL 33326

Attorneys for Interested Parties Krystal 

Lazares-Scaretta, Robert A. Scaretta and 

American Gold Rush, LLC

Andrew Fulton, IV, Esq.

andrew@kelleylawoffice.com

Brian S. Dervishi, Esq.

bdervishi@wdpalaw.com

Craig Vincent Rasile

crasile@mwe.com

Gerald Edward Greenberg, Esq.

ggreenberg@gsgpa.com

Gregg Alan Steinman

gsteinman@sflp.law

Mark David Bloom, Esq.

mark.bloom@bakermckenzie.com

Martha Rosa Mora, Esq.

mmora@arhmf.com

Michael David Heidt, Esq.

mheidt@aol.com

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