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IN THE UNITED STATES DISTRICT COURT

FOR THE 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. 

______________________________________/ 

RECEIVER RYAN K. STUMPHAUZER’S NOTICE OF FILING 

TIME RECORDS IN CONNECTION WITH ORDER GRANTING RECEIVER’S 

EXPEDITED MOTION TO QUASH SUBPOENA AND FOR PROTECTIVE ORDER

The Receiver, Ryan K. Stumphauzer, pursuant to the Court’s Order Granting Receiver’s 

Expedited Motion to Quash July 23, 20231 Subpoena and for Protective Order [ECF No. 1623] 

(the “Order”), provides notice of filing the attached time records of the attorneys’ fees the Receiver

has incurred in connection with the Receiver’s Expedited Motion to Quash July 23, 2023 Subpoena 

and for Protective Order [ECF No. 1620] (the “Motion to Quash”). In the Order, the Court 

instructed the Receiver “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.” See Order at 2. 

Enclosed as Exhibit 1 and Exhibit 2 are records of the time the Receiver and his counsel 

incurred in connection with the Motion to Quash. These time records reflect that the Receiver has 

1 In filing this Notice, the Receiver notes that this reference to July 23, 2023, should have been 

“June 23, 2023.” 

Case 9:20-cv-81205-RAR Document 1630 Entered on FLSD Docket 07/03/2023 Page 1 of 3
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incurred the following attorneys’ fees in connection with the Motion to Quash: 

Law Firm Hours Fees 

Pietragallo Gordon Alfano Bosick & Raspanti, LLP (Exhibit 1) 8.7 $2,786.50 

Stumphauzer Kolaya Nadler & Sloman, PLLC (Exhibit 2) 1.5 $592.50 

 Total: 10.2 $3,279.00 

A proposed Order awarding the Receiver attorneys’ fees in this amount is attached as Exhibit 3.

Dated: July 3, 2023 Respectfully Submitted, 

STUMPHAUZER KOLAYA 

NADLER & SLOMAN, PLLC

Two South Biscayne Blvd., Suite 1600 

Miami, FL 33131 

Telephone: (305) 614-1400 

By: /s/ Timothy A. Kolaya 

TIMOTHY A. KOLAYA

Florida Bar No. 056140 

tkolaya@sknlaw.com 

Co-Counsel for Receiver 

PIETRAGALLO GORDON ALFANO 

BOSICK & RASPANTI, LLP

1818 Market Street, Suite 3402 

Philadelphia, PA 19103 

Telephone: (215) 320-6200 

By: /s/ Gaetan J. Alfano 

GAETAN J. ALFANO 

Pennsylvania Bar No. 32971 

(Admitted Pro Hac Vice)

GJA@Pietragallo.com

DOUGLAS K. ROSENBLUM

Pennsylvania Bar No. 90989 

(Admitted Pro Hac Vice)

DKR@Pietragallo.com

Co-Counsel for Receiver 

Case 9:20-cv-81205-RAR Document 1630 Entered on FLSD Docket 07/03/2023 Page 2 of 3
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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 3, 2023, I electronically filed the foregoing document 

with the clerk of the Court using CM/ECF. I also certify that the foregoing document is being 

served this day on counsel of record via transmission of Notices of Electronic Filing generated by 

CM/ECF.

 /s/ Timothy A. Kolaya 

TIMOTHY A. KOLAYA

Case 9:20-cv-81205-RAR Document 1630 Entered on FLSD Docket 07/03/2023 Page 3 of 3