Exhibit 2

Proposed Order Authorizing Receiver’s Sale of Real Property Located at

627-629 E. Girard Avenue, Philadelphia, PA 19125

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UNITED STATES DISTRICT COURT

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.

_____________________________________/ 

[PROPOSED] ORDER AUTHORIZING RECEIVER’S SALE OF REAL PROPERTY 

LOCATED AT 627-629 E. GIRARD AVENUE, PHILADELPHIA, PA 19125 

 THIS CAUSE comes before the Court upon the Receiver’s Motion for Order Approving 

Receiver’s Sale of Real Property Located at 627-629 E. Girard Avenue, Philadelphia, PA 19125

[ECF No. ____] (the “Motion”), filed on June 17, 2024. The Court has reviewed the Motion and 

the record in this matter, and is otherwise fully advised. 

In the Motion, the Court-Appointed Receiver, Ryan K. Stumphauzer (“Receiver”) asks the 

Court to approve and authorize the sale of the real property located at 627-629 E. Girard Avenue, 

Philadelphia, PA 19125. 

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

in the Motion. Accordingly, for the reasons stated in the Motion, it is hereby ORDERED AND 

ADJUDGED that the Motion is GRANTED as set forth herein.

In accordance with its Order granting Receiver’s Motion for Order Authorizing Receiver’s 

Sale of All Real Property Within the Receivership Estate [ECF No. 1486], this Court has reviewed 

the Declaration [ECF No. ______-1] of Ryan K. Stumphauzer, Esq., the Court-Appointed Receiver 

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(the “Receiver”), regarding his proposed sale of the real property located at and commonly known 

as 627-629 E. Girard Avenue, Philadelphia, PA 19125 (the “Property”), and orders as follows:

A. The terms of the Purchase and Sale Agreement, a copy of which is attached to the 

Declaration as Exhibit C (collectively, the “Contract”), by and between the Receiver and E-G-A-

____, LLC, dated May 3, 20241 (the “Buyers”) in connection with the Receiver’s proposed sale of 

the Property to Buyers are approved;

B. The Court ratifies the Receiver’s execution of the Contract and authorizes the 

Receiver to perform all of his obligations under the Contract;

C. The Receiver is authorized to sell the Property to Buyer or Buyers’ designee, as 

contemplated in the Contract, in exchange for the aggregate sum of $2,750,000, subject to the 

applicable terms of this Order.

D. The Receiver is further authorized to pay any commissions provided for in the 

Contract and in connection with the consummation of his sale of the Property;

E. In accordance with the terms of the Contract, and without limiting those terms, 

Buyers or Buyers’ designee shall purchase the Property on an “as-is / where-is” basis, without any 

representations or warranties whatsoever by the Receiver and his agents and/or attorneys 

including, without limitation, any representations or warranties as to the condition of the Property, 

except as expressly set forth in the Contract. Buyers or their designee is responsible for all due 

diligence, including but not limited to, inspection of the condition of and title to the Property, and 

is not relying on any representation or warranty of the Receiver, except as expressly set forth in 

the Contract;

1 For security purposes, the Buyers’ identity has been redacted.

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F. In the performance of his obligations pursuant to this Order, the Receiver’s liability 

in connection with the Contract and the sale of the Property to the Buyers shall be limited to the 

assets of the Receivership Estate (the “Estate”). Neither the Receiver nor his professionals shall 

have any personal liability for claims arising out of or relating to the performance of any actions 

necessary to complete the sale of the Property as provided for herein;

G. Provided Buyers or Buyers’ designee consents, in writing, the Receiver is hereby 

authorized to amend or otherwise modify the Contract, in writing, as necessary to complete the 

sale of the Property in the event that the Receiver determines, in his reasonable business judgment, 

that such amendment or modification is reasonable and necessary, will benefit the Estate, avoid 

the imposition of any liability upon the Estate, or is required pursuant to the terms of the Contract 

or any other amendment or modification thereto, provided that any such amendment or 

modification does not change the material terms of the Contract, including the parties to the 

Contract and the purchase price for the Property;

H. The Receiver is hereby authorized to take all actions and execute all documents 

necessary to consummate and otherwise effectuate the sale of the Property to Buyer or Buyer’s 

designee, including, but not limited to, the Contract itself, any other documents required to be 

executed pursuant to the Contract, and any related documentation, escrow instructions, or 

conveyance documents consistent with selling and conveying title to the Property to Buyers or 

Buyers’ designee. The Receiver shall execute all documents necessary to consummate and 

otherwise effectuate the sale of the Property as “Ryan K. Stumphauzer, Court-Appointed 

Receiver” or any reasonable variation thereof which clearly identifies the Receiver as a Courtappointed Receiver;

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I. The Receiver is hereby authorized to execute and acknowledge a Receiver’s Deed, 

or similar instrument, conveying title to the Property to Buyers or Buyers’ designee (the 

“Receiver’s Deed”) to effectuate the conveyance, and cause the Receiver’s Deed to be recorded 

on the date on which close of escrow occurs pursuant to the terms of the Contract, or as determined 

by and between the Receiver and Buyers or Buyers’ designee;

J. Any licensed title insurer may rely on this Order as authorizing the Receiver to 

transfer title to the Property as provided in the Contract and as authorized herein;

K. This Court shall retain jurisdiction over any dispute involving the Receiver in 

connection with the sale of the Property; and

L. If requested by the Buyer, the Receiver shall provide Buyers or Buyers’ designee 

with a certified copy of this Order, as entered by the Court, directly or through escrow, prior to the 

Close of Escrow, or as provided for in the Contract, and Buyers or Buyers’ designee shall 

acknowledge receipt of a copy of this Order, in writing. A certified copy of this Order may be 

recorded concurrently with the Receiver’s Deed, or at any time before the close of escrow, 

provided, however, that failure to record this Order shall not affect the enforceability of this Order, 

the enforceability and viability of the Contract, or the validity of the Receiver’s Deed.

DONE AND ORDERED in Miami, Florida, this _____ day of ____________, 2024.

________________________________

RODOLFO A. RUIZ II

UNITED STATES DISTRICT JUDGE

Copies to: Counsel of record

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