Exhibit 3

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

568 Ferndale Lane, Haverford, PA 19041]

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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 568 FERNDALE LANE, HAVERFORD, PA 19041

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

Receiver’s Sale of Real Property Located at 568 Ferndale Lane, Haverford, PA 19041 [ECF No. 

1602] (the “Motion”), filed on June 19, 2023. The Court having reviewed the Motion and the 

record in this matter, and being otherwise fully advised, 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. 1602-1] of Ryan K. Stumphauzer, Esq., the Court-Appointed Receiver 

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

as 568 Ferndale Lane, Haverford, PA 19041 (Block 108, Lot Number 11) (the “Property”), and 

orders as follows:

A. The terms of the Standard Agreement for the Sale of Real Estate, a copy of which 

is attached to the Declaration as Exhibit A (collectively, the “Contract”), by and between the 

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Receiver and S.Y.1 (the “Buyer”) in connection with the Receiver’s proposed sale of the 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 Property to Buyer or Buyer’s designee, as 

contemplated in the Contract, in exchange for the aggregate sum of $3.38 million, 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, 

Buyer or Buyer’s 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. 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;

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 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 Property as provided for herein;

1 For security purposes, the Buyer’s identities have been redacted.

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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 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 Buyer or 

Buyer’s 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;

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

or similar instrument, conveying title to the 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;

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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. 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 June, 2023.

________________________________

RODOLFO A. RUIZ II

UNITED STATES DISTRICT JUDGE

Copies to: Counsel of record

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