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 

QUARTERLY STATUS REPORT DATED AUGUST 1, 2022

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

Entities,1 pursuant to the requirements of the Amended Order Appointing Receiver [ECF No. 141], 

1 The “Receivership Entities” are Complete Business Solutions Group, Inc. d/b/a Par Funding 

(“Par Funding”); Full Spectrum Processing, Inc.; ABetterFinancialPlan.com LLC d/b/a A Better 

Financial Plan; ABFP Management Company, LLC f/k/a Pillar Life Settlement Management 

Company, LLC; ABFP Income Fund, LLC; ABFP Income Fund 2, L.P.; United Fidelis Group 

Corp.; Fidelis Financial Planning LLC; Retirement Evolution Group, LLC; RE Income Fund LLC; 

RE Income Fund 2 LLC; ABFP Income Fund 3, LLC; ABFP Income Fund 4, LLC; ABFP Income 

Fund 6, LLC; ABFP Income Fund Parallel LLC; ABFP Income Fund 2 Parallel; ABFP Income 

Fund 3 Parallel; ABFP Income Fund 4 Parallel; ABFP Income Fund 6 Parallel; ABFP MultiStrategy Investment Fund LP; ABFP Multi-Strategy Investment Fund 2 LP; MK Corporate Debt 

Investment Company LLC; Capital Source 2000, Inc.; Fast Advance Funding LLC; Beta Abigail, 

LLC; New Field Ventures, LLC; Heritage Business Consulting, Inc.; Eagle Six Consultants, Inc.; 

20 N. 3rd St. Ltd.; 118 Olive PA LLC; 135-137 N. 3rd St. LLC; 205 B Arch St Management 

LLC; 242 S. 21st St. LLC; 300 Market St. LLC; 627-629 E. Girard LLC; 715 Sansom St. LLC; 

803 S. 4th St. LLC; 861 N. 3rd St. LLC; 915-917 S. 11th LLC; 1250 N. 25th St. LLC; 1427 

Melon St. LLC; 1530 Christian St. LLC; 1635 East Passyunk LLC; 1932 Spruce St. LLC; 4633 

Walnut St. LLC; 1223 N. 25th St. LLC; Liberty Eighth Avenue LLC; The LME 2017 Family 

Trust; Blue Valley Holdings, LLC; LWP North LLC; 500 Fairmount Avenue, LLC; Recruiting 

and Marketing Resources, Inc.; Contract Financing Solutions, Inc.; Stone Harbor Processing LLC; 

LM Property Management LLC; and ALB Management, Inc., and the Receivership also includes 

the properties located at 568 Ferndale Lane, Haverford PA 19041; 105 Rebecca Court, Paupack, 

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hereby files this Quarterly Status Report dated August 1, 2022. By way of summary, the 

Receivership Estate consists of, among other things, approximately $60 million of real property, 

$3 million in other tangible assets the Receiver has brought into the Receivership Estate (including 

boats, cars, artwork, and luxury watches), and $105,873,218 in cash (as of June 30, 2022). As of 

July 31, 2022, the current cash balance was $110,188,975.

I. Overall Administration of Receivership Estate

A. Quarterly Report of Receivership Estate

Pursuant to the requirements of the Amended Order Appointing Receiver [ECF No. 141], 

attached as Exhibit 1 is a full report and accounting reflecting (to the best of the Receiver’s 

knowledge as of the period covered by the report) the existence, value, and location of all 

Receivership Property, and of the extent of liabilities, both those claimed to exist by others and 

those the Receiver believes to be legal obligations of the Receivership Estates (the “Quarterly 

Report”). The Quarterly Report contains the following information: (1) summary of the operations 

of the Receiver; (2) the amount of cash on hand, the amount and nature of accrued administrative 

expenses, and the amount of unencumbered funds in the estate; (3) a schedule of all the Receiver’s 

receipts and disbursements (attached as Exhibit A to the Quarterly Status Report), with one column 

for the quarterly period covered and a second column for the entire duration of the receivership; 

(4) a description of all known Receivership Property, including approximate or actual valuations, 

anticipated or proposed dispositions, and reasons for retaining assets where no disposition is 

intended; (5) a description of liquidated and unliquidated claims held by the Receivership Estate, 

including the need for forensic and/or investigatory resources; approximate valuations of claims; 

PA 18451; 107 Quayside Dr., Jupiter FL 33477; 2413 Roma Drive, Philadelphia, PA 19145; 159 

26th Street, Avalon, NJ 08202; and 164 84th Street, Stone Harbor, NJ 08247.

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and anticipated or proposed methods of enforcing such claims (including likelihood of success in: 

(i) reducing the claims to judgment; and, (ii) collecting such judgments); (6) a list of all known 

creditors with their addresses and the amounts of their claims; (7) the status of Creditor Claims 

Proceedings, after such proceedings have been commenced; and (8) the Receiver’s 

recommendations for a continuation or discontinuation of the receivership and the reasons for the 

recommendations, as required pursuant to Paragraphs 53 and 54 of the Amended Order Appointing 

Receiver dated August 13, 2020 [ECF No. 141].

II. Update on Other Assets Included within the Receivership Estate

A. Accounts Receivable and Collection Activities

At the time of his appointment, the Receiver obtained control over $28,779,570 in cash 

held by the various original Receivership Entities. As a result of various Orders expanding the 

Receivership, the Receiver obtained an additional $14,756,649 in cash held by the additional 

Receivership Entities. The Receiver has also acquired an additional $86,672,538 in cash through 

collections, settlements, and other recoveries. After accounting for expenses, the total cash balance 

was $105,873,218 as of June 30, 2022. As of July 31, 2022, the current cash balance was 

$110,188,975.

B. Accounts Receivable – Merchant Cash Advance Accounts

The Receiver, his professionals, and the staff he rehired at Par Funding have been 

continuing to collect on the accounts receivable for the merchant cash advance (“MCA”) accounts 

that were pending with the company as of the time the Receiver took over the operations of Par 

Funding. Historically, the Receiver has reported the entire accounts receivable balances that were 

on Par Funding’s books for these MCA accounts, while explaining that these balances did not 

reflect appropriate reductions for collectability or bad debt. After the current reporting period

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(May 1, 2022 through June 30, 2022), the Receiver, through his outside consultants, counsel, and 

internal collection staff and accountants, analyzed the collectability of the balances for all MCA 

companies. The Receiver determined that $18.7 million should be written off due to closed 

bankruptcies; circumstances where the merchant is out of business; and circumstances where 

there is neither viable guarantors nor viable collateral. In analyzing the MCA balances, the 

Receiver also determined that a reserve in the amount of $100.6 million was required for accounts 

with ongoing bankruptcies and other circumstances where full payment is doubtful. See DSI’s 

Report, attached as Exhibit 1. The Receiver will continue to analyze this portfolio to determine 

realistic write-offs and allowances for additional amounts that are not likely to be collected. 

C. Collection Efforts Through Outside Collection Company and Litigation

Altus Receivables Management, Inc. (“Altus”) is a national collection company that the 

Receiver has engaged on a contingency fee recovery basis. Altus is seeking to collect judgments 

previously entered against select non-performing, non-bankruptcy merchants, guarantors, and 

counterparties that had outstanding balances and/or were otherwise in default at the time of the 

establishment of the receivership (collectively “merchants”). Thus, these recovery efforts are 

being pursued in the ordinary course of the administration and operation of the receivership.

The judgments against these merchants are being exemplified under Pennsylvania law 

and will be domesticated for legal action in the merchant’s home state and where assets may be 

found. The judgments referred to Altus range from low five (5)-figure balance accounts to 

accounts in excess of one million dollars ($1,000,000), based upon the Receivership Entities’ 

records. Referrals began on January 9, 2022, and 169 exemplified judgments have since been 

referred to Altus with active collection efforts are underway. The Receiver has also initiated 38 

actions against merchants in the Philadelphia Court of Common Pleas either through civil action 

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complaints or confessions of judgment. The cases filed in Philadelphia typically have resulted in 

either legal challenges to the underlying agreements; offers of settlement; or default or confessed 

judgments. Thus far, merchant challenges to the underlying agreements have been unsuccessful. 

The Receivership Estate is receiving offers of settlement through the Receiver’s litigation in the 

Philadelphia Court of Common Pleas and Altus collection activities. The Receiver is considering 

and, where appropriate, approving offers when he deems the proposal to be in the best interests 

of the Receivership Estate. Finally, as additional judgments become available from the 

Philadelphia litigation, they will be assigned to Altus for further collection efforts if not resolved 

by the Receiver directly with the merchant.

D. Collection Activity and Settlements with ESC and HBC Counterparties

To date, the Receiver has resolved, either through full payoffs of the amount owed or 

settlements, the account balances of several counterparties to agreements with Eagle Six 

Consultants, Inc. (“ESC”) and Heritage Business Consulting, Inc. (“HBC”). In addition, the Court 

has entered motions to lift the litigation injunction to allow the Receiver to pursue claims against 

several counterparties (and their guarantors) to agreements with ESC and HBC. [ECF No. 642; 

ECF No. 747; ECF No. 879]. The Receiver is in active litigation and/or settlement discussions 

with several of these counterparties for which the litigation injunction has been lifted.

E. Life Settlements

Two of the Receivership Entities—ABFP Multi-Strategy Investment Fund LP (“MSIF”) 

and ABFP Multi-Strategy Investment Fund II LP (“MSIF II”)—own portfolios of life settlement 

policies. Since the time of his appointment, the Receiver and his consultants at DSI have been 

managing these portfolios. These duties have included, among other things, the payment of 

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premiums, corresponding with the insurers and servicers of these policies, and communicating 

with a potential third party regarding a valuation and potential purchase of these policies.

On April 26, 2022, the Receiver learned that two policies owned by MSIF matured with 

total death benefits payable in the amount of $1,000,000.00. The Receiver received and deposited 

those proceeds on July 27, 2022. The Receiver has not received notification that any other policies 

owned by MSIF have matured since he took over control of this company.

With respect to MSIF II, the Receiver was previously notified of the maturity of, and 

received the proceeds for, eight (8) of these polices, which amounted to gross death benefits 

totaling $5,482,143. Over this reporting period, the Receiver did not learn of the maturity of any 

additional policies, and the Receiver did not receive any additional death benefits. 

III. Receiver-Controlled Real Estate

A. The McElhone Properties

The Receiver controls 25 properties, either directly or indirectly owned by Lisa McElhone 

(collectively, the “Receiver-Controlled Properties”). Three (3) are single-family residential 

properties previously occupied by Joseph LaForte and McElhone (the “Single-Family Homes”): 

107 Quayside Drive, Jupiter Florida (the “Florida Home”); 105 Rebecca Court, Paupack,

Pennsylvania (the “Poconos Home”); and 568 Ferndale Lane, Haverford Pennsylvania (the 

“Haverford Home”). Pursuant to an agreement with the Receiver, McElhone and LaForte may 

live in the Haverford Home, but may not occupy or otherwise use the Florida Home or Poconos 

Home. McElhone and LaForte pay the Receiver rent for the Haverford Home and are responsible 

for paying all carrying costs (taxes, insurance, and maintenance) for all 3 Single-Family Homes.

Two other properties historically have been used for business operations, 20-22 North 3rd

Street (4 units) and 205 B Arch Street. The Receiver has consolidated all CBSG business 

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operations within the 20-22 North 3rd Street office suite and directed OCF to market 205 B Arch 

Street for rent. The remaining 20 Receiver-Controlled Properties are either commercial, 

residential, or mixed-use rental properties in Philadelphia. Prior to the Receivership, these 

properties were managed by OCF Realty LLC (“OCF”) at McElhone’s direction. The Receiver 

has retained OCF to continue its management services for these properties (the “OCF-Managed 

Properties”). The 20 OCF-Managed Properties comprise 121 rental units (110 residential units 

and 11 commercial units). The Receiver, through OCF, continues to collect rent, pay the necessary 

expenses, and market units for rent as they become available. 

B. Title Clearance Efforts 

Certain title defects encumber several Receiver-Controlled Properties dating back to 

McElhone’s original acquisition. As reported in the Receiver’s prior Status Reports, these title 

defects, which primarily relate to a failure to terminate prior owner-created liens, were effectively 

“insured over” through the title insurance policies provided to McElhone at closing. The Receiver 

is continuing to attempt to resolve these liens. 

C. Abbonizio Properties

Pursuant to the Receiver’s settlement with Perry Abbonizio and PCA 159 26th St. Avalon 

LLC, the Receiver acquired two single family properties located in Cape May County, New Jersey:

159 26th Street, Avalon, NJ (the “Avalon Property”) and 164 84th Street, Stone Harbor, NJ (the 

“Stone Harbor Property”). On July 12, 2022, in accordance with the “Sales Procedures” 

established in a Stipulation the Receiver entered into with the Securities and Exchange 

Commission and Defendant Perry Abbonizio [ECF No. 1301] (the “Stipulation”), which the Court 

has approved, the Receiver listed each property for sale at a price of $4,250,000. On July 27, 2022, 

the Receiver executed an agreement to sell the Stone Harbor Property for $4,150,000 in an allCase 9:20-cv-81205-RAR Document 1334 Entered on FLSD Docket 08/01/2022 Page 7 of 13
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cash transaction, a sales price that exceeds the appraised value of the property. On Saturday, July 

30, 2022, the Receiver filed a motion, pursuant to the procedures established in the Stipulation, to 

authorize the sale of the Stone Harbor Property. Assuming the motion is granted, the sale of the 

Stone Harbor Property is scheduled to close on August 31, 2022. The Receiver continues to market 

the Avalon Property for sale.

IV. Information Regarding Anticipated Claims and Distribution Process

The Receiver continues to receive numerous inquiries from investors and other creditors 

of the Receivership Entities regarding the timing of a claims and distribution process in this matter, 

as well as an estimate of the potential amounts that will be distributed to each investor/creditor. 

With respect to timing, the Receiver continues to assemble information regarding all known 

investors in and creditors of the Receivership Entities, and anticipates that the claims and 

distribution process will begin as soon as possible following the Court’s resolution of the SEC’s 

motion seeking an order of disgorgement and penalties against the Defendants. 

There still remain a number of questions and uncertainties surrounding the accounts 

receivable of the Receivership Entities and other claims the Receiver is pursuing or otherwise 

evaluating. Additionally, the amount of the orders of disgorgement and/or penalties to be entered 

against the Defendants have not yet been determined, much less an understanding of how much 

will be collected and available for distribution from those amounts. The Court will also need to 

consider the Receiver’s recommendations and establish a procedure for determining the manner 

in which various claims will be evaluated and administered. As a result, it is still too early for the 

Receiver to provide any estimates of the amounts that may be available—either on an individual 

level or in total—for distribution to investors and other creditors. 

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Additionally, given that certain claims or collection efforts from various sources of 

potential recovery are not likely to be resolved in the near future, the Receiver also anticipates the 

possibility of recommending a phased distribution process. Under this phased process, the 

Receiver would request permission to make an initial distribution from amounts already collected,

after the disgorgement and penalty amounts have been determined. Then, as the Receiver 

continues to recover additional funds on behalf of the Receivership Estate and otherwise liquidates

assets the Receiver has collected, the Receiver would anticipate making a supplemental 

distribution (or supplemental distributions, depending on the timing of these future recoveries). 

The Receiver and his professional staff will continue to evaluate these issues and provide updates 

as they are available. Information regarding the proposed claims and distribution plan will be 

posted on the Receivership website after the Receiver has filed it with the Court.

V. Expansion of Receivership Estate 

In total, the Receiver has filed and obtained Orders from the Court granting 10 motions to 

expand the Receivership Estate.

In addition, as the Receiver has previously reported, the Court’s Order Granting Motion to 

Expand Receivership Estate dated December 16, 2020 [ECF No. 436], through which several 

entities and properties were included in the Receivership Estate as additional Receivership Entities, 

is currently on appeal to the United States Court of Appeals for the Eleventh Circuit. That appeal 

is fully briefed and oral argument was conducted before the Eleventh Circuit in Miami on June 7, 

2022. No opinion has been issued yet on this appeal.

VI. Update on Pending Motions and Other Matters

As of the filing of this report, there are three pending motions that pertain specifically to 

the Receiver and the administration of the Receivership Estate:

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1. Receiver’s Expedited Motion to Expand the Receivership to include 19 Country 

Drive, Morristown, NJ 07960 [ECF No. 1180], filed on March 9, 2022. Through this Motion, the 

Receiver seeks to expand the scope of the Receivership Estate over certain property located at 19 

Country Drive, Morristown, NJ 07960 that Daniel Scaramellino purchased with comingled 

investor funds he received from one of the Receivership Entities, Eagle Six Consultants, Inc. The 

Receiver filed this Motion upon learning that Scaramellino was attempting to sell the property in 

a transaction he failed to disclose to the Receiver at a time the Receiver was in discussions with 

Scaramellino in an attempt to resolve the more than $8.7 million debt he owes to the Receivership 

Estate. Pursuant to an agreement between the affected parties, the sale of the property was 

permitted to close and the net proceeds from that sale were substituted in place of the property as 

the subject of the Motion, which the Receiver is holding in trust pending the resolution of the 

Motion. After several unopposed extensions of time to facilitate settlement discussions between 

the Receiver and Scaramellino that were ultimately unsuccessful, the Motion is now fully briefed 

and scheduled for a hearing before the Court on August 3, 2022, at 10:30 a.m. [ECF No. 1321].

2. Receiver’s Motion for an Order to Show Cause Why Defendants Joseph LaForte 

and Lisa McElhone Should Not Be Held in Contempt, and to Lift Litigation Injunction Against 

Specified Third Parties [ECF No. 1328], filed on July 29, 2022. In this Motion, the Receiver 

requests the Court to issue an order to show cause why Defendants Joseph LaForte and Lisa 

McElhone should not be held in civil contempt based on alleged violations of the Court’s Orders 

appointing the Receiver in this case. The Court’s Orders authorized the Receiver to exercise 

exclusive possession or control over Receivership Property and to marshal and preserve 

Receivership Assets and Recoverable Assets. The Orders also prohibited the Defendants from 

interfering with the Receiver’s efforts to take control, possession, or management of any 

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Receivership Property. The Motion asserts that despite the Orders, Defendants Joseph LaForte and 

Lisa McElhone, with the assistance of various third parties, diverted funds due and owing to the 

Receivership Estate, and interfered with the Receiver’s efforts to recover Receivership Property 

and to marshal and preserve Receivership Assets and Recoverable Assets. Specifically, the Motion 

alleges that Defendants Joseph LaForte and Lisa McElhone violated the Orders by: (1) diverting 

merchant collections from CBSG and its affiliate, Contract Financing Solutions, Inc. (“CFS”) to 

other entities LaForte and McElhone controlled; (2) laundering the diverted funds through shell 

and nominee corporations; and (3) using the laundered funds for their personal use and benefit, 

including the payment of their legal and expert witness fees in this case. The Receiver also requests 

the Court to lift the litigation injunction provided for in the Amended Order Appointing Receiver 

dated August 13, 2020 [ECF No. 141] to allow the Receiver to pursue claims against various 

individuals and entities that assisted LaForte and McElhone in executing the diversion scheme, or 

that received proceeds from the diversion scheme. On July 30, 2022, the Court entered an Order

[ECF No. 1332] on the Motion: (a) requiring LaForte and McElhone to file a written response to 

the Motion on or before August 26, 2022; (b) requiring the Receiver to file any reply on or before 

September 7, 2022; (c) scheduling an evidentiary hearing on the Motion on September 12, 2022, 

at 11:00 A.M., and (d) lifting the litigation injunction, as requested in the Motion.

3. Receiver’s Motion for Order Authorizing Receiver’s Sale of Real Property Located 

at 164 84th Street, Stone Harbor, NJ 08247 [ECF No. 1331], filed on July 30, 2022. As described 

above in Section III(C), the Receiver filed a motion, pursuant to the procedures established in a 

Stipulation approved by the Court, to authorize the sale of the residential property located at 164 

84th Street, Stone Harbor, NJ 08247. If neither the Securities and Exchange Commission nor 

Defendant Perry Abbonizio file an objection to the proposed sale within 10 days from the date the 

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Receiver filed the Motion (i.e., by August 9, 2022), then the Court may enter an Order approving 

the sale. The Receiver does not anticipate that the Commission or Mr. Abbonizio will be filing an 

objection.

VII. Website / Communications with Interested Parties

The Receiver continues to receive many e-mails, telephone calls, and other inquiries from 

investors, merchants, administrators of agent funds, and other interested parties. The Receiver and 

his professionals have returned phone calls and emails from thousands of investors, merchants, 

and others. Since the Receiver established the receivership website on August 16, 2020, which is 

available at parfundingreceivership.com, there have been more than 118,522 visitors and 539,024

pageviews to the website. The Receiver will continue to update this website with key court filings, 

news and updates, reports from the Receiver, answers to frequently asked questions, important 

dates and deadlines (including Zoom or telephone dial-in information for status conferences and 

other significant hearings before the Court), and other pertinent information. Additionally, the 

Receiver will utilize this website to provide notice to investors and other claimants regarding the 

claims and distribution process in this matter, once that information is available.

VIII. Conclusion

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

undersigned counsel, respectfully files this Quarterly Status Report dated August 1, 2022.

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Dated: August 1, 2022 Respectfully Submitted, 

STUMPHAUZER FOSLID SLOMAN

ROSS & KOLAYA, 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@sfslaw.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 August 1, 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

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