UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 20-CV-81205-RAR/REINHART 

SECURITIES AND EXCHANGE 

COMMISSION, 

Plaintiff, 

v. 

COMPLETE BUSINESS SOLUTIONS 

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

Defendants. 

______________________________________/ 

NON-PARTY PACIFIC LIFE INSURANCE COMPANY’S UNOPPOSED 

MOTION FOR AN EXTENSION OF TIME TO RESPOND TO THE 

RECEIVER’S MOTION TO COMPEL COMPLIANCE WITH SUBPOENA

Pursuant to Federal Rule of Civil Procedure 6(b) and Local Rule 7.1 of the Local Rules of 

Court for the Southern District Florida, Non-Party Pacific Life Insurance Company (“Pacific 

Life”) specially appears and hereby moves, unopposed, for a seven-day enlargement of time to file 

its response to Receiver, Ryan K. Stumphauzer’s Motion to Compel Pacific Life Insurance 

Company’s Compliance with Subpoena (D.E. 1655) (the “Motion to Compel”). In support of this 

motion, Pacific Life states the following: 

1. On August 24, 2022, Receiver, Ryan K. Stumphauzer (the “Receiver”) served a 

subpoena duces tecum on Non-Party Pacific Life seeking certain documents relating to the 

Company’s administration of life insurance policies during the COVID-19 pandemic. See Motion 

to Compel, Ex. 1. 

2. On or about October 6, 2022, Pacific Life responded to the Receiver’s subpoena 

duces tecum, produced a responsive document, and provided a Custodian of Records Affidavit 

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confirming that the document produced was a true and correct copy prepared in the ordinary course 

of business. Pacific Life subsequently confirmed that it did not have any additional documents 

responsive to the subpoena. 

3. On August 9, 2023, almost a year after serving Non-Party Pacific Life with the 

subpoena, the Receiver filed his Motion to Compel against Non-Party Pacific Life seeking an order 

compelling Pacific Life to produce any additional responsive documents. 

4. Non-Party Pacific Life recently retained undersigned counsel to assist in its 

response to the Receiver’s Motion to Compel, which is currently due on August 23, 2023. 

5. Due to undersigned counsel’s recent retention, and the press of other matters 

including various briefing deadlines and hearings in other matters, Non-party Pacific Life 

respectfully requests an extension of time through and including August 30, 2023 to respond to 

the Receiver’s Motion to Compel. 

6. The requested extension will permit Pacific Life and its counsel an adequate 

opportunity to investigate the Receiver’s allegations and arguments in the Motion to Compel, and 

prepare an appropriate response. The requested extension will also provide the Receiver and 

Pacific Life an opportunity to confer further in an effort to avoid additional Court action. 

7. Counsel for the Receiver have graciously informed Pacific Life that they have no 

objection to the extension of time requested in this motion. 

8. This request for an extension of time is reasonable, made in good faith, supported 

by good cause, and not interposed for delay or any other improper purpose. The request extension 

will not prejudice any party or non-party. 

9. This is Non-Party Pacific Life’s first request for an extension of time in this matter. 

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WHEREFORE, Non-Party Pacific Life respectfully requests that this Court enter an order 

granting an extension of time until August 30, 2023 for Pacific Life to respond to the Receiver’s 

Motion to Compel. A proposed order will be emailed to the Court’s ECF mailbox in connection 

with this motion. 

Dated: August 23, 2023 Respectfully submitted, 

/s/ Todd M. Fuller 

Todd M. Fuller (Fla. Bar. No. 666211) 

CARLTON FIELDS, P.A. 

2 MiamiCentral, Suite 1200 

700 NW 1st Avenue 

Miami, Florida 33136 

Telephone: (305) 530-0050 

Facsimile: (305) 530-0055 

tfuller@carltonfields.com 

Counsel for Non-Party Pacific Life 

Insurance Company 

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