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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.

_______________________________/ 

ORDER GRANTING RECEIVER’S EMERGENCY MOTION TO ENJOIN ACCESS TO 

COMPLETE BUSINESS SOLUTIONS GROUP, INC. D/B/A PAR FUNDING AND FULL 

SPECTRUM PROCESSING, INC.’S ELECTRONICALLY STORED INFORMATION

THIS CAUSE comes before the Court upon the Receiver’s Emergency Motion to Enjoin 

Access to Complete Business Solutions Group, Inc. d/b/a Par Funding (“Par Funding”) and Full 

Spectrum Processing, Inc.’s (“Full Spectrum”) Electronically Stored Information [ECF No. 155] 

(“Motion”). The Court having reviewed the Motion and being otherwise fully advised, it is

ORDERED AND ADJUDGED that the Receiver’s Motion is GRANTED as follows:

1. Pursuant to the Order Granting Plaintiff Securities and Exchange Commission’s

Motion for Appointment of Receiver [ECF No. 36] and the Amended Order Appointing Receiver 

[ECF No. 141], the Court granted the Receiver the authority to, among other things: (a) “take 

immediate possession of all personal property of the Receivership Entities, wherever located, 

including but not limited to electronically stored information, computers, laptops, hard drives, 

external storage drives, and any other such memory, media or electronic storage devices” and (b)

“secure and safeguard the Receivership Entity’s information technology, data, documents, storage 

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systems, and documents” (“Authority Over Electronic Data”). See ECF No. 141 at 8; ECF No. 36 

at 3. 

2. The Court also ordered that the “Receivership Entities and all persons receiving 

notice of this Order shall not hinder or interfere with the Receiver’s efforts to take control or 

possession of the Receivership Entities’ property interests identified above, or hinder his efforts to 

preserve them” (“Prohibition Against Interference”). See ECF No. 36 at 4. 

3. In exercising his Authority Over Electronic Data and to prevent violations of the 

Prohibition Against Interference, the Receiver is authorized to suspend, temporarily, access to 

users of the G Suite electronic data platform that CBSG and Full Spectrum utilize, as well “super 

administrator access” rights for individuals who have access to other businesses or entities that 

utilize this integrated account. This suspension as it pertains to administrator rights involving 

businesses or entities other than CBSG and Full Spectrum shall only last as long as required for 

the Receiver to ensure that the electronic data of the Receivership Entities is being properly 

preserved in accordance with the Receiver’s Authority Over Electronic Data, or until the Receiver 

can take appropriate action to separate the data of those other entities from the data of CBSG and 

Full Spectrum.

4. Any employees of CBSG or Full Spectrum who accessed, downloaded, or modified 

any electronic files from the G Suite account shall preserve all such documents within their 

personal possession and provide copies of those documents to the Receiver’s counsel within two 

(2) business days, and thereafter destroy and not retain any copies within their possession.

5. All lawyers who have appeared in this action for any of the Defendants to this action 

who, at any time from July 29, 2020, to the present, communicated with individuals who are or 

were formerly employees of CBSG or Full Spectrum regarding access to CBSG’s or Full 

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Spectrum’s data from G Suite or any other electronic sources shall preserve all communications 

with these employees and produce such communications to the Receiver’s counsel.

DONE AND ORDERED in Ft. Lauderdale, Florida this 15th day of August, 2020.

 _________________________________

 RODOLFO A. RUIZ II

 UNITED STATES DISTRICT JUDGE

cc: counsel of record

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