IN THE UNITED STATES DISTRICT COURT 

FOR THE 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.

______________________________________/

RECEIVER, RYAN K. STUMPHAUZER’S MOTION FOR EXTENSION 

OF TIME TO FILE, AND FOR LEAVE TO EXCEED PAGE LIMITATION ON,

MOTION TO ESTABLISH AND APPROVE: (1) PROOF OF CLAIM FORM; (2) 

CLAIMS BAR DATE AND NOTICE PROCEDURES; AND (3) PROCEDURE TO

ADMINISTER AND DETERMINE CLAIMS

Ryan K. Stumphauzer, Esq., Court-Appointed Receiver (“Receiver”) of the Receivership 

Entities, hereby files this Motion for Extension of Time to File, and for Leave to Exceed Page 

Limitation on, Motion to Establish and Approve: (1) Proof of Claim Form; (2) Claims Bar Date 

and Notice Procedures; and (3) Procedure to Administer and Determine Claims (the “Motion”), 

and states as follows:

1. On November 23, 2022, the Court entered its Interim Scheduling Order Regarding 

the Claims Administration Process and Order Setting Interim Case Management Conference. 

(ECF No. 1454). In that Order, the Court, among other things, directed the Receiver to file on or 

before December 16, 2022, a Motion to Establish and Approve (i) Procedure to Administer and 

Determine Claims, (ii) Proof of Claim Form, (iii) Claims Bar Date, and (iv) Notice Procedures 

(the “Motion to Establish Claims Procedures”).

Case 9:20-cv-81205-RAR Document 1463 Entered on FLSD Docket 12/16/2022 Page 1 of 3
2

2. The Receiver drafted the Motion to Establish Claims Procedures, including the 

supporting documents and exhibits, and circulated these drafts to the Securities and Exchange 

Commission (the “Commission”). To ensure there is sufficient time for the Commission to review 

these documents, and for the Receiver to consider and incorporate, as appropriate, any of the 

Commission’s comments to these documents, the Receiver respectfully requests an extension of 

time, through and including December 21, 2022, to file the Motion to Establish Claims Procedures.

3. Additionally, the Receiver’s current draft of the Motion to Establish Claims 

Procedures is 25 pages, which exceeds the number of pages permitted under Local Rule 7.1(c)(2). 

Accordingly, the Receiver respectfully requests leave to exceed the standard 20-page limitation by 

five pages, for a total of 25 pages, on his anticipated Motion to Establish Claims Procedures.

1

WHEREFORE, Ryan K. Stumphauzer, as Court-Appointed Receiver, by and through his 

undersigned counsel, respectfully requests this Honorable Court to grant the Motion, extend the 

time for the Receiver to file the Motion to Approve Claims Procedures though and including 

December 21, 2022, and authorize the Receiver to file a Motion to Approve Claims Procedures 

that is 25 pages in length. A proposed order for the Court’s consideration is attached as Exhibit 1.

CERTIFICATION REGARDING PRE-FILING CONFERENCE

Pursuant to Local Rule 7.1(a)(3), undersigned counsel for the Receiver certifies that he has 

conferred with the Securities and Exchange Commission, which do not oppose the requested relief. 

1 The Receiver acknowledges that Rule 3I(1) of the Court’s CM/ECF Administrative Procedures 

requires any motion requesting leave to exceed the page limitations to attach the proposed filing 

to the motion seeking leave. Should the Court wish to review the Motion to Establish Claims 

Procedures before considering this request, the Receiver will withdraw this portion of the Motion 

and make this request separately when the final documents are ready to be filed. 

Case 9:20-cv-81205-RAR Document 1463 Entered on FLSD Docket 12/16/2022 Page 2 of 3
3

Dated: December 16, 2022 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 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on December 16, 2022, 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 1463 Entered on FLSD Docket 12/16/2022 Page 3 of 3