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.

_____________________________________________/

[PROPOSED] ORDER GRANTING DEFENDANT MICHAEL C. FURMAN’S

AGREED MOTION TO MODIFY THE SCOPE OF THE

RECEIVERSHIP ORDERS AND ASSET FREEZE

Defendant Michael C. Furman (“Furman”), by and through his undersigned counsel, 

respectfully moves this Court jointly with the Plaintiff, Securities and Exchange Commission

(“Commission”), and the Receiver, Ryan Stumphauzer, Esq. (collectively with Furman, the 

“Parties”), to modify the scope of the receivership orders and asset freeze [ECF Nos. 42 (the “Asset 

Freeze Order”), 56, 141, and 182 (collectively, the “Receivership and Asset Freeze Orders”).

1

 

Specifically, the Parties have agreed to seek to modify the Receivership and Asset Freeze Orders 

to: 1) permit Furman to conduct his insurance business and other businesses that are unrelated to 

the instant case; and 2) provide him with reasonable living expenses for two (2) months from 

monies traceable to monies that are personal and that Mr. Furman made from businesses unrelated 

to the instant case.

1 Furman reserves his right to seek to further modify such orders in the future.

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THIS CAUSE comes before the Court upon Defendant Michael Furman’s Agreed Motion to 

Modify the Scope of the Receivership Orders and Asset Freeze [ECF No. ___] (“Motion”), filed on 

August 20, 2020. In the Motion, Furman, the United States Securities and Exchange Commission, and 

the Receiver have agreed to seek to modify the Receivership and Asset Freeze Orders to: 1) permit 

Furman to conduct his insurance business and other businesses that are unrelated to the instant case; 

and 2) provide him with reasonable living expenses for two (2) months from monies traceable to 

monies that are personal and that Mr. Furman made from businesses unrelated to the instant case.

Based on the agreement of the Parties, there is a sufficient and proper showing in support 

of the relief requested. Accordingly, it is hereby

ORDERED AND ADJUDGED that Motion [ECF No. ___] is GRANTED. Fidelis CRE 

Fund LLC (“CRE Fund”), Fidelis Senior Living Fund LLC (“Living Fund”), and Furman Holdings 

Inc. (“Furman Holdings”) are not subject to Receivership and Asset Freeze Orders [ECF Nos. 42, 56,

141, and 182]. These entities shall operate at Furman’s direction and expense. If the Receiver’s 

analysis of the additional bank records reveals that Par Funding-related investor funds were deposited 

into these accounts in the names of CRE Fund, Living Fund, and/or Furman Holdings exceeding the 

amounts previously generated from Furman’s other businesses, the Receiver may seek to have any 

such entities that were in Receivership placed back into the Receivership Estate. Mr. Furman 

understands that by agreeing to this relief, the Securities and Exchange Commission and the Receiver 

are not giving any opinion, legal or otherwise, on any issue whatsoever regarding Mr. Furman’s entities 

that are being carved out of the Receivership and asset freeze. The only issue is whether these entities 

hold funds related to Complete Business Solutions Group and/or Fidelis Financial Planning.

IT IS FURTHER ORDERED AND ADJUDGED that Furman is permitted access to 

reasonable living expenses from funds deposited into either personal account(s) or business account(s) 

to the extent that the funds may be traced to monies that are personal and that Mr. Furman made from 

Case 9:20-cv-81205-RAR Document 184-1 Entered on FLSD Docket 08/21/2020 Page 2 of 3
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businesses unrelated to the instant matter. Furman may utilize $7,800 per month for two (2) months 

commencing on the entry of an order on this motion. Furman may apply for additional reasonable 

living expenses in the future and the Commission and Receiver may oppose such a request.

DONE AND ORDERED in Fort Lauderdale, Florida, this _____ day of August, 2020.

_________________________________

RODOLFO A. RUIZ II

UNITED STATES DISTRICT JUDGE

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