UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 20-CV-81205-RAR

SECURITIES & EXCHANGE COMMISSION,

Plaintiff,

v.

COMPLETE BUSINESS SOLUTIONS 

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

Defendants.

_______________________________________/

ORDER SETTING SETTLEMENT CONFERENCE

Ryan K. Stumphauzer, Esq., Court-Appointed Receiver (“Receiver”) notified 

the District Court about a dispute between: (a) the Receiver and class counsel for 

various investors (“Class Counsel”) and (b) Plaintiffs in the case of Parker, et al. v. 

Pauciulo, et al., No. 20-00892 (Phila. Ct. Com. Pl. 2020) (the “Parker Plaintiffs”)

regarding the Parker Plaintiffs’ potential objections (the “Potential Objections”) to 

the Receiver’s anticipated motion to seek the Court’s approval of a settlement in 

principle that the Receiver and Class Counsel have reached with Eckert Seamans 

Cherin & Mellot, LLC (“Eckert Seamans”), John W. Pauciulo, and Eckert Seamans’ 

insurance carriers to resolve certain claims against Eckert Seamans and 

Mr. Pauciulo. ECF No. 1724. Thereafter, the District Court referred the dispute 

between the Receiver, Class Counsel, and the Parker Plaintiffs over the Potential 

Objections to the undersigned for a settlement conference. ECF No. 1726. 

Accordingly, it is hereby ORDERED AND ADJUDGED as follows:

The Receiver, a representative from Class Counsel, and the Parker Plaintiffs 

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shall appear before this Court on Monday, November 13, 2023, at 12:30 p.m., at

the United States Courthouse, 701 Clematis Street, West Palm Beach, 

Florida 33401, for a settlement conference. 

On Thursday, November 9, 2023, the Court will conduct an ex parte fifteen (15) 

minute telephone conference with counsel for each side (without clients). Counsel 

shall email chambers (reinhart@flsd.uscourts.gov) at their earliest convenience to 

advise the Court of their availability on that date and schedule a time for their ex 

parte telephone conference. The following rules shall apply to the settlement 

proceedings:

a.) NO CONTINUANCES. This settlement conference shall not be 

continued unless good cause is shown for another date. Any motions for continuance 

of the settlement conference must be in writing, properly filed with the Court prior to 

the date of the conference, and shall contain a proposed date for rescheduling the 

conference. Counsel moving to continue the conference shall consult with opposing 

counsel in proposing a new date for the conference. 

b.) WRITTEN SUBMISSIONS TO THE COURT. No later than

Wednesday, November 8, 2023, counsel shall submit directly to chambers a written 

submission of no more than five (5) pages (single spaced), which shall contain a brief 

explanation of the Potential Objections and a proposal for resolving the Potential 

Objections. The submission shall also indicate the names of the individuals 

attending the settlement conference, including counsel. The Court will inform the 

U.S. Marshal Service that those individuals are permitted to bring mobile phones, 

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tablets, and laptops into the courthouse for the settlement conference. The 

submission shall further indicate whether there are any liens or any third parties 

whose involvement would help facilitate settlement. The parties are instructed not 

to submit such documents to the Clerk of Court. Rather, to facilitate timely 

submission of the documents, each party shall email their submissions to 

reinhart@flsd.uscourts.gov. Such submissions will be kept confidential and will 

not be disclosed to the opposing party without prior approval of the submitting party. 

c.) ATTENDANCE OF PARTIES REQUIRED. The Receiver, a 

representative from Class Counsel, and the Parker Plaintiffs shall participate in the 

settlement conference. Except as provided under Local Rule 16.2E, counsel and each 

party, or representatives of each party, with ultimate settlement authority must be

present at the settlement conference.

d.) STATEMENTS NOT ADMISSIBLE. Statements made by any party 

during the settlement conference shall be confidential and privileged. Accordingly, 

parties are encouraged to be frank in their discussions. The Court expects the 

parties to address each other with courtesy and respect.

DONE and ORDERED in Chambers this 19th day of October, 2023, at West 

Palm Beach in the Southern District of Florida.

____________________________________

BRUCE E. REINHART

UNITED STATES MAGISTRATE JUDGE

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