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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 THE RECEIVER’S SEVENTH MOTION TO LIFT 

LITIGATION INJUNCTION AS TO CERTAIN GARNISHMENT PROCEEDINGS

THIS CAUSE comes before the Court upon the Receiver’s Seventh Motion to Lift 

Litigation Injunction as to Certain Garnishment Proceedings [ECF No. 371] (“Motion”), filed on 

November 5, 2020. In the Motion, the Receiver seeks to modify the Court’s Amended Order 

Appointing Receiver dated August 13, 2020 [ECF No. 141], so as to lift the litigation injunction 

provided for in that Order for certain garnishment matters currently pending in the Court of 

Common Pleas of Philadelphia County, Pennsylvania to be opened for the limited purpose of 

allowing the Receiver: (1) in his discretion, to dissolve current writs of garnishment, to mark 

judgments satisfied, and/or to reopen confessed judgments, where the counterparty merchant either 

has resolved or has agreed to resolve prior defaults in certain cases in the Court of Common Pleas 

of Philadelphia County, Pennsylvania; (2) to cancel certain Security Agreements; and (3) to waive 

the requirement for financial institutions served with writs of garnishment to file Answers to 

Interrogatories in Attachment, and to dissolve writs of garnishment, if a financial institution 

represents to the Receiver in writing that it has no accounts with the merchants (and/or guarantors). 

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The Receiver has made a sufficient and proper showing in support of the relief requested. 

Accordingly, it is hereby

ORDERED AND ADJUDGED that the Receiver’s Motion [ECF No. 371] is GRANTED

as follows:

1. The litigation injunction set forth in the Court’s Amended Order Appointing 

Receiver dated August 13, 2020 [ECF No. 141] is hereby lifted in the following matters in the 

Court of Common Pleas of Philadelphia County, Pennsylvania, and solely for the purpose

described in the Motion:

a. Complete Business Solutions Group, Inc. v. Site Development Group LLC 

and Hunter Thomas, Docket No. 200302403. 

b. Complete Business Solutions Group, Inc. v. Il Pastaio and La Pasta Boutique 

LLC and Victor Munoz, Docket No. 191201357.

c. Complete Business Solutions Group, Inc. v. NOS Inc. and Shivangi Mehta,

Docket No. 191101297.

d. Complete Business Solutions Group, Inc v. Limo Star NY Inc., Mayering 

Castaneda, Acevedo Posada and Albert Andres, Docket No. 200400138.

e. Complete Business Solutions Group, Inc v. Sky Capital Finance LLC and 

Jack Roddy, Docket No. 200400401. 

f. Complete Business Solutions Group, Inc. v. Connected Transportation 

Partners Inc. and Marvin Wilcher, Docket No. 200400788. 

g. Complete Business Solutions Group, Inc. v. Prosperity Technology LLC and 

Jesse Aranda, Docket No. 190500096. 

2. The Receiver is authorized to lift the litigation injunction to release the November 

26, 2018 Security Agreement between Complete Business Solutions Group, Inc and Brian Daniel 

Sommers, Jr. a/k/a Brian Daniel Sommers and Nicole Sommers, and to release the January 22, 

2019 Security Agreement between Complete Business Solutions Group, Inc. and Dane Wilson and 

Reika Wilson. 

3. The litigation injunction set forth in the Court’s Amended Order Appointing

Receiver dated August 13, 2020 [ECF No. 141] is hereby lifted solely for the purpose described 

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in the Motion to allow the Receiver to waive the requirement for financial institutions served with 

writs of garnishment to file Answers to Interrogatories in Attachment, and to dissolve current writs 

of garnishment, if a financial institution represents to the Receiver in writing that it has no accounts 

with the merchants (and/or guarantors).

DONE AND ORDERED in Fort Lauderdale, Florida, this 5th day of November, 2020.

_________________________________

RODOLFO A. RUIZ II

UNITED STATES DISTRICT JUDGE

Copies to: Counsel of record

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