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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. 

______________________________________/ 

RECEIVER, RYAN K. STUMPHAUZER’S MOTION FOR EXTENSION 

OF TIME TO FILE MOTION TO (1) APPROVE PROPOSED PLAN OF 

DISTRIBUTION AND (2) AUTHORIZE FIRST INTERIM DISTRIBUTION

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

Entities,

1 by and through his undersigned counsel, files this Motion for Extension of Time to File 

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; and ABFP Income Fund 6 Parallel; ABFP 

Multi-Strategy Investment Fund LP; ABFP Multi-Strategy Fund 2 LP; MK Corporate Debt 

Investment Company LLC; Fast Advance Funding LLC; Beta Abigail, LLC; New Field Ventures, 

LLC; Heritage Business Consulting, Inc.; Eagle Six Consulting, 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; 500 Fairmount Avenue, LLC; Liberty Eighth Avenue LLC; Blue Valley Holdings, LLC; 

LWP North LLC; The LME 2017 Family Trust; Recruiting and Marketing Resources, Inc.; 

Contract Financing Solutions, Inc.; Stone Harbor Processing LLC; LM Property Management 

LLC; and ALB Management, LLC; and the Receivership also includes the property located at 107 

Case 9:20-cv-81205-RAR Document 2012 Entered on FLSD Docket 08/16/2024 Page 1 of 3
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Motion to (1) Approve Proposed Plan of Distribution and (2) Authorize First Interim Distribution 

(the “Distribution Motion”), and states as follows: 

1. In the Paperless Order dated July 12, 2024, the Court ordered the Receiver to file 

the Distribution Motion on or before August 16, 2024. [ECF No. 1991]. 

2. Since that time, the Receiver has been working diligently to analyze the assets 

within the Receivership Estate and the allowed claims as adjudicated in the Court’s Order Granting 

Receiver’s Motion to (1) Approve Proposed Treatment of Claims and (2) for Ponzi Determination 

[ECF No. 1976]. The Receiver has prepared a proposed distribution plan and a draft of the 

Distribution Motion. Although the Receiver has made significant progress in this regard, there are 

multiple factual and legal issues that are addressed in the Distribution Motion, and the Receiver 

requires additional time to finalize his analysis and prepare the Distribution Motion for filing. 

Accordingly, the Receiver respectfully requests that the Court grant the Receiver a one-week 

extension of time, through and including August 23, 2024, for the Receiver to file the Distribution 

Motion. 

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

undersigned counsel, respectfully requests this Honorable Court to grant this motion and extend

the deadline by which the Receiver must file the Distribution Montion by one week, through and 

including August 23, 2024. A proposed order is attached as Exhibit 1. 

CERTIFICATION REGARDING PRE-FILING CONFERENCE

The undersigned counsel conferred with counsel for the Securities and Exchange 

Commission regarding this motion, and certifies that the Securities and Exchange Commission 

does not oppose the requested relief. 

Quayside Dr., Jupiter FL 33477. 

Case 9:20-cv-81205-RAR Document 2012 Entered on FLSD Docket 08/16/2024 Page 2 of 3
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Dated: August 16, 2024 Respectfully Submitted, 

STUMPHAUZER KOLAYA 

NADLER & SLOMAN, 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@sknlaw.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 16, 2024, 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

Case 9:20-cv-81205-RAR Document 2012 Entered on FLSD Docket 08/16/2024 Page 3 of 3