Exhibit “3”

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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 APPROVING RECEIVER’S SALE OF REAL 

PROPERTY LOCATED AT 107 QUAYSIDE DRIVE, JUPITER, FLORIDA 33477 

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

Receiver’s Sale of, Real Property Located at 107 Quayside Drive, Jupiter, Florida 33477 [ECF No. 

_______] (“Motion”), filed on July 10, 2023. 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 107 Quayside Drive, Jupiter, 

Florida 33477 (“Quayside Property”). 

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 

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Receiver (the “Receiver”), regarding his proposed sale of the Quayside Property, and orders as 

follows:

A. The terms of the contingent As Is Residential Contract for Sale and Purchase for 

the sale of the Quayside Property (the “Contract”), a copy of which is attached to the Declaration 

as Exhibit B, by and between the Receiver and the R.W. Revocable Trust Agreement1 (the 

“Buyer”) in connection with the Receiver’s proposed sale of the Quayside Property to Buyer 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 Quayside Property to Buyer or Buyer’s 

designee, as contemplated in the Contract, in exchange for the aggregate sum of $12,100,000.00, 

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 Quayside Property;

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

Buyer or Buyer’s designee shall purchase the Quayside 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 

Quayside Property, except as expressly set forth in the Contract. Buyer or its 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 Buyer’s 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 Quayside Property to the Buyer 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 Quayside Property as provided for herein;

G. Provided Buyer or Buyer’s 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 Quayside 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 Quayside 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 Quayside 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 Quayside Property to 

Buyer or Buyer’s designee. The Receiver shall execute all documents necessary to consummate 

and otherwise effectuate the sale of the Quayside Property as “Ryan K. Stumphauzer, CourtAppointed Receiver” or any reasonable variation thereof which clearly identifies the Receiver as 

a Court-appointed 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 Quayside Property to Buyer or Buyer’s 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 Buyer or Buyer’s designee;

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

transfer title to the Quayside 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 Quayside Property; and

L. The Receiver shall provide Buyer or Buyer’s 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 Buyer or Buyer’s 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 July, 2023.

________________________________

RODOLFO A. RUIZ II

UNITED STATES DISTRICT JUDGE

Copies to: Counsel of record

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