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.

_______________________________/ 

ORDER GRANTING PRELIMINARY INJUNCTION 

BY CONSENT AS TO DEFENDANT LISA MCELHONE

THIS CAUSE is before the Court upon the Court’s Order to Show Cause why a 

Preliminary Injunction should not be granted against Defendants [ECF No. 42 at 3], entered on 

July 28, 2020, and Plaintiff’s Motion for Entry of Proposed Consent Order [ECF No. 221], filed 

on September 2, 2020. Based on the consent of Defendant Lisa McElhone and good cause 

appearing in the record, it is hereby

ORDERED AND ADJUDGED that Plaintiff’s request for a Preliminary Injunction is 

GRANTED with respect to Defendant McElhone as set forth herein.

I. PRELIMINARY INJUNCTION

A. Section 17(a) of the Securities Act of 1933 (“Securities Act”)

Until further Order of Court, McElhone is restrained and enjoined from violating Section 

17(a) of the Securities Act (15 U.S.C. § 77q(a)) in the offer or sale of any security by the use of 

any means or instruments of transportation or communication in interstate commerce or by use of 

the mails, directly or indirectly:

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(a) to employ any device, scheme, or artifice to defraud;

(b) to obtain money or property by means of any untrue statement of a material fact or 

any omission of a material fact necessary in order to make the statements made, in 

light of the circumstances under which they were made, not misleading; or

(c) to engage in any transaction, practice, or course of business which operates or 

would operate as a fraud or deceit upon the purchaser

by, directly or indirectly (i) creating a false appearance or otherwise deceiving any person, or (ii) 

disseminating false or misleading documents, materials, or information or making, either orally or 

in writing, any false or misleading statement in any communication with any investor or 

prospective investor, about: (A) any investment in securities; (B) the prospects for success of any 

product or company; (C) the use of investor funds; (D) the safety of any securities investment; (E) 

the use of investor funds or investment proceeds; (F) Orders issued against the Defendants by state 

or federal enforcement agencies; (G) the financial status of Par Funding; or (H) the management 

of Par Funding.

As provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also 

binds the following who receive actual notice of this Preliminary Injunction: (a) McElhone’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with McElhone or with anyone described in (a).

B. Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) 

and Rule 10b-5

Until further Order of Court, McElhone is restrained and enjoined from violating, directly 

or indirectly, Section 10(b) of the Exchange Act (15 U.S.C. § 78j(b)) and Rule 10b-5 promulgated 

thereunder (17 C.F.R. § 240.10b-5), by using any means or instrumentality of interstate commerce, 

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or of the mails, or of any facility of any national securities exchange, in connection with the 

purchase or sale of any security:

(a) to employ any device, scheme, or artifice to defraud;

(b) to make any untrue statement of a material fact or to omit to state a material fact 

necessary in order to make the statements made, in the light of the circumstances 

under which they were made, not misleading; or

(c) to engage in any act, practice, or course of business which operates or would 

operate as a fraud or deceit upon any person,

by, directly or indirectly (i) creating a false appearance or otherwise deceiving any person, or (ii) 

disseminating false or misleading documents, materials, or information or making, either orally or 

in writing, any false or misleading statement in any communication with any investor or 

prospective investor, about: (A) any investment in securities; (B) the prospects for success of any 

product or company; (C) the use of investor funds; (D) the safety of any securities investment; (E) 

the use of investor funds or investment proceeds; (F) Orders issued against the Defendants by state 

or federal enforcement agencies; (G) the financial status of Par Funding; or (H) the management 

of Par Funding.

As provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also 

binds the following who receive actual notice of this Preliminary Injunction by personal service or 

otherwise: (a) McElhone’s officers, agents, servants, employees, and attorneys; and (b) other 

persons in active concert or participation with McElhone or with anyone described in (a).

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C. Section 5 of the Securities Act

Until further Order of Court, McElhone is restrained and enjoined from violating Section 

5 of the Securities Act (15 U.S.C. § 77e) by, directly or indirectly, in the absence of any applicable 

exemption:

(a) Unless a registration statement is in effect as to a security, making use of any means

or instruments of transportation or communication in interstate commerce or of the 

mails to sell such security through the use or medium of any prospectus or 

otherwise;

(b) Unless a registration statement is in effect as to a security, carrying or causing to 

be carried through the mails or in interstate commerce, by any means or instruments 

of transportation, any such security for the purpose of sale or for delivery after sale; 

or

(c) Making use of any means or instruments of transportation or communication in 

interstate commerce or of the mails to offer to sell or offer to buy through the use 

or medium of any prospectus or otherwise any security, unless a registration 

statement has been filed with the Securities and Exchange Commission as to such 

security, or while the registration statement is the subject of a refusal order or stop 

order or (prior to the effective date of the registration statement) any public 

proceeding or examination under Section 8 of the Securities Act (15 U.S.C. § 77h).

As provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also 

binds the following who receive actual notice of this Preliminary Injunction by personal service or 

otherwise: (a) McElhone’s officers, agents, servants, employees, and attorneys; and (b) other 

persons in active concert or participation with Defendant or with anyone described in (a).

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II. ASSET FREEZE

A. McElhone and her respective directors, officers, agents, servants, employees, 

attorneys, depositories, banks, and those persons in active concert or participation with her who 

receive notice of this Order by personal service, mail, email, facsimile transmission or otherwise, 

hereby are restrained from, directly or indirectly, transferring, setting off, receiving, changing,

selling, pledging, assigning, liquidating or otherwise disposing of, or withdrawing any assets or 

property, including but not limited to cash, free credit balances, fully paid for securities, personal 

property, real property, and/or property pledged or hypothecated as collateral for loans, or charging 

upon or drawing from any lines of credit, owned by, controlled by, or in the possession of, whether 

jointly or singly, and wherever located, Lisa McElhone.

B. Any financial or brokerage institution or other person or entity holding any such 

funds or other assets, in the name, for the benefit or under the control of McElhone, directly or 

indirectly, held jointly or singly, and wherever located, and which receives actual notice of this 

Order by personal service, mail, email, facsimile, or otherwise, shall hold and retain within its 

control and prohibit the withdrawal, removal, transfer, disposition, pledge, encumbrance,

assignment, set off, sale, liquidation, dissipation, concealment, or other disposal of any such funds 

or other assets.

This asset freeze is limited to the amount of $482,000,000 Million Dollars.

III. RECORDS PRESERVATION

Until further Order of the Court, McElhone, any of her directors, officers, agents, servants, 

employees, attorneys, depositories, banks, and those persons in active concert or participation with 

any one or more of them, and each of them, be and they hereby are restrained and enjoined from, 

directly or indirectly, destroying, mutilating, concealing, altering, disposing of, or otherwise 

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rendering illegible in any manner, any of the books, records, documents, correspondence, 

brochures, manuals, papers, ledgers, accounts, statements, obligations, files and other property of 

or pertaining to any of the Defendants or Relief Defendant, wherever located and in whatever form, 

electronic or otherwise.

IV. RETENTION OF JURISDICTION

This Court shall retain jurisdiction over this matter and Defendants and Relief Defendant 

in order to implement and carry out the terms of all Orders and Decrees that may be entered and/or 

to entertain any suitable application or motion for additional relief within the jurisdiction of this 

Court, and will order other relief that this Court deems appropriate under the circumstances.

DONE and ORDERED in Fort Lauderdale, Florida, this 2nd day of September, 2020.

______________________________

RODOLFO A. RUIZ II

UNITED STATES DISTRICT JUDGE

Copies to: Counsel of Record

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