FOX ROTHSCHILD LLP

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

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.

 _____ /

 

MOTION FOR COMPLETE BUSINESS SOLUTIONS GROUP, INC. AND FULL

SPECTRUM PROCESSING, INC. PERMISSION TO EXCEED THE 10 PAGE LIMIT

Pursuant to Rule 7.1, Defendants, Complete Business Solutions Group, Inc. d/b/a Par 

Funding(“CBSG”) and Full Spectrum Processing, Inc. (“Full Spectrum”), respectfully request 

permission to exceed the 10 page limit set forth in the Court’s paperless order ECF 74, in 

advance of today’s 3:30 p.m. hearing, and state as follows:

Undersigned counsel initially appeared in this action on behalf of Defendants, CBSG and

Full Spectrum, as well as three individual Defendants, and a relief Defendant. Subsequently, the 

individual Defendants and Relief Defendant have retained separate counsel, while undersigned 

counsel continues to represent CBSG and Full Spectrum.

The Court has scheduled a hearing for August 4 at 3:30 p.m. to consider the appropriate 

scope of the Receivership Order. See ECF 74. The Court allowed the parties to each file 

memorandum not to exceed 10 pages, in advance of the hearing.

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FOX ROTHSCHILD LLP

Rather than filing its own separate memorandum of up to 10 pages, CBSG and Full 

Spectrum have joined in a memorandum filed by counsel for the individual Defendants, and 

Relief Defendant, in order to present a single unitary document to the Court. That filing exceeds 

the page limit by three pages. Accordingly, as the filing by CBSG and Full Spectrum, combined 

with the filing by the individual Defendants, and relief Defendant is less than the 20 total pages 

allotted by the Court, undersigned counsel respectfully submits that the parties have complied 

with the intent and the spirit of the Court’s page limitation Order. However, pursuant to Local 

Rule 7.l, Defendants move for an extension of the page limit so that CBSG and Full Spectrum, 

along with the individual Defendants, and Relief Defendant are in compliance with the Local 

Rules of this Court.

 Respectfully submitted,

FOX ROTHSCHILD LLP

Attorneys for Complete Business Solutions 

Group, Inc. d/b/a Par Funding and Full 

One Biscayne Tower, Suite 2750

2 South Biscayne Blvd.

Miami, Florida 33131

Telephone: (305) 442-6547

By: /s/Joseph DeMaria

Joseph A. DeMaria, B.C.S.

Florida Bar No. 764711

Email: JDeMaria@FoxRothschild.com

 

 Brett Berman

 2000 Market Street, 20th Floor

 Philadelphia, PA 19103, 

 Tel: (215) 299-2000

 Email: bberman@foxrothschild.com

Sec. Email: mmiller-hayle@foxrothschild.com

Case 9:20-cv-81205-RAR Document 85 Entered on FLSD Docket 08/04/2020 Page 2 of 3
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FOX ROTHSCHILD LLP

CERTIFICATE OF SERVICE

I hereby certify that on August 4, 2020, I electronically filed the foregoing with the Clerk 

of the Court using CM/ECF. 

 s/Joseph A. DeMaria 

Joseph A. DeMaria

Case 9:20-cv-81205-RAR Document 85 Entered on FLSD Docket 08/04/2020 Page 3 of 3