UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-CIV-81205-RAR

SECURITIES AND EXCHANGE

COMMISSION,

Plaintiff,

v.

COMPLETE BUSINESS SOLUTIONS

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

Defendants.

____________________________________/

VAGNOZZI PLAINTIFFS’ OBJECTION AND RESERVATION OF RIGHT TO 

CONTEST MOTION FOR APPROVAL OF ATTORNEYS’ FUND

Defendant, Dean Vagnozzi (“Vagnozzi”), and Non-Parties Albert Vagnozzi, Terrence 

Kohler, PTK Financial LLC, and Alec Vagnozzi (collectively “Vagnozzi Plaintiffs”), by and 

through undersigned counsel, hereby submits this Objection and Reservation of Rights to Contest 

Motion for Approval of Attorneys’ Fund [ECF No. 1913]:

1. The Vagnozzi Plaintiffs object to the attorney fees and costs sought by the Motion 

for Approval of Attorney Fees. 

2. On May 6, 2024, the Receiver filed a Motion for: (I) Approval of Settlement Among 

Receiver, Putative Class Plaintiffs, and Eckert Seamans; (II) Approval of Form, Content and 

Manner of Notice of Settlement and Bar Order; (III) Setting Deadline to Object to Approval of the 

Settlement and Entry of Bar Order; and (IV) Scheduling a Hearing. [ECF No. 1861].

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3. On May 13, 2024, the Court entered an Order Preliminarily Approving Settlement 

Among Receiver, Putative Class Plaintiffs, and Eckert Seamans, and setting forth a schedule for 

the filing objections and a final approval hearing. [ECF No. 1906]. 

4. On May 30, 2024, after a status conference, the Court entered an Order resetting 

the Final Approval Hearing for August 13, 2024, and resetting the objection deadlines to no later 

than thirty (30) days before the Final Approval Hearing. [ECF No. 1945] 

5. The proposed Settlement includes a provision that counsel for the Putative Class 

Plaintiffs would receive $6.75 million in attorney fees, and in that regard, on May 16, 2024, 

Counsel for the Putative Class Plaintiffs filed a Motion for Approval of Attorneys’ Fund, seeking 

court approval of its requested $6.75 million fee. [ECF No. 1913]. 

6. The Vagnozzi Plaintiffs intend to include the factual and legal basis of their 

objections to the attorney fees sought by Counsel for the Putative Class in the Objections to be 

filed as part of the Receiver’s Motion for Approval of Settlement, which will be filed on or before 

July 15, 2024. 

Respectfully submitted,

BOCHETTO & LENTZ, P.C.

1524 Locust Street 

Philadelphia, PA 19102 

Telephone: 215-735-3900 

Fax: 215-735-2455 

Email: gbochetto@bochettoandlentz.com 

Email: mminsky@bochettoandlentz.com 

/s/ Matthew L. Minsky 

 /s/ George Bochetto 

By: _________________________ 

 George Bochetto, Esquire 

Pro Hac Vice 

 Matthew L. Minsky, Esquire 

 FBN: 1033408 

Attorneys for Dean Vagnozzi

Case 9:20-cv-81205-RAR Document 1952 Entered on FLSD Docket 06/06/2024 Page 2 of 3
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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that the foregoing document was electronically filed June 6, 2024 

with the CM/ECF filing portal, which will send a notice of electronic filing to all counsel of record.

Respectfully submitted, this 6th day of June 2024. 

BOCHETTO & LENTZ, P.C.

1524 Locust Street 

Philadelphia, PA 19102 

Telephone: 215-735-3900 

Fax: 215-735-2455 

Email: gbochetto@bochettoandlentz.com 

Email: mminsky@bochettoandlentz.com 

/s/ Matthew L. Minsky 

 /s/ George Bochetto 

By: _________________________ 

 George Bochetto, Esquire 

Pro Hac Vice 

 Matthew L. Minsky, Esquire 

 FBN: 1033408 

Attorneys for Dean Vagnozzi

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