Exhibit “3”

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 20-CV-81205-RAR

SECURITIES AND EXCHANGE

COMMISSION,

Plaintiff,

 v.

COMPLETE BUSINESS SOLUTIONS

GROUP, INC. d/b/a PAR FUNDING, et al.,

Defendants.

______________________________________/

[PROPOSED] ORDER AWARDING ATTORNEYS’ FEES TO RECEIVER IN 

CONNECTION WITH ORDER GRANTING RECEIVER’S EXPEDITED MOTION 

TO QUASH JULY 23, 2023 SUBPOENA AND FOR PROTECTIVE ORDER

THIS CAUSE comes before the Court upon Ryan K. Stumphauzer, Court-Appointed 

Receiver’s Expedited Motion to Quash July 23, 2023 Subpoena and for Protective Order [ECF No. 

1620] (the “Motion to Quash”), the Court’s Order Granting Receiver’s Expedited Motion to Quash 

July 23, 2023 Subpoena and for Protective Order [ECF No. 1623] (the “Order Granting Motion to 

Quash”), and the Receiver’s Notice of Filing Time Records in Connection with Order Granting 

Receiver’s Expedited Motion to Quash July 23, 2023 Subpoena and for Protective Order [ECF No. 

____] (the “Notice of Filing Time Records”). The Court has reviewed the Motion to Quash, the Order 

Granting Motion to Quash, the Notice of Filing Time Records, and the record in this matter. For the 

reasons set forth in the Order Granting Motion to Quash, it is hereby

ORDERED AND ADJUDGED that

1. In the Order Granting Motion to Quash, the Court stated:

Pursuant to Fed. R. Civ. P. 26(c) and 37(a)(5), Plaintiffs in the case of Parker, et al. v. 

Pauciulo, et al., Case No. 210502334 (Phila Ct. Com. Pl. 2021) and their counsel shall 

pay the Receiver his reasonable expenses incurred in making the Motion, including 

attorneys’ fees, in an amount to be determined by the Court. The Receiver is 

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INSTRUCTED to file a notice with the billing records detailing the time his counsel 

incurred in filing this Motion, by no later than July 5, 2023. Thereafter, the Court will 

enter a subsequent order determining the amount of attorneys’ fees and costs to be paid 

to the Receiver pursuant to this Order.

Order Granting Motion to Quash at 2.

2. Fed. R. Civ. P. 26(c)(3) and 37(a)(5)(A) command courts to award reasonable 

attorneys’ fees and costs to a party prevailing on a motion to quash a subpoena and for a protective 

order. The Court, having scrutinized the 10.2 hours of billing records submitted by the Receiver in 

connection with filing the Motion to Quash and pursuing the Order Granting Motion to Quash, finds 

the time spent and hourly rates requested reasonable. See Receiver’s Notice of Filing Time Records. 

Accordingly, Plaintiffs in the case of Parker, et al. v. Pauciulo, et al., Case No. 210502334 (Phila Ct. 

Com. Pl. 2021) and their counsel are INSTRUCTED to pay the Receiver $3,279.00 in attorneys’ fees 

on or before July _____, 2023.

DONE AND ORDERED in Miami, Florida, this _____ day of July, 2023.

________________________________

RODOLFO A. RUIZ II

UNITED STATES DISTRICT JUDGE

Copies to: Counsel of record

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