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.

________________________________________________/

PLAINTIFF SECURITIES AND EXCHANGE COMMISSION’S 

NOTICE OF FILING EXHIBIT 1 TO RESPONSE TO 

LISA MCELHONE’S MOTION TO LIFT ASSET FREEZE

Attached as Exhibit 1 is a filing in the criminal case against Lisa McElhone, which provides 

her current address at 2200 Benjamin Franklin Parkway, Unit 1902, where McElhone currently resides 

while her husband, Joseph LaForte is currently incarcerated, under a lease commencing in March 2023 

for $9,720 per month plus $300 in parking costs.

OCTOBER 21, 2023 Respectfully submitted,

By: Amie Riggle Berlin

Amie Riggle Berlin, Esq.

Senior Trial Counsel

Florida Bar No. 630020

Direct Dial: (305) 982-6322

Email: berlina@sec.gov

Attorney for Plaintiff

SECURITIES AND EXCHANGE

COMMISSION

801 Brickell Avenue, Suite 1950

Miami, Florida 33131

Telephone: (305) 982-6300

Facsimile: (305) 536-4154

Case 9:20-cv-81205-RAR Document 1731 Entered on FLSD Docket 10/21/2023 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

________________________________________________________________________ 

UNITED STATES OF AMERICA : CRIMINAL ACTION

 v. 

 : 

 

JOSEPH LAFORTE : NO. 20-231 

________________________________________________________________________ 

O R D E R

 AND NOW, to wit, this day of , it is hereby ORDERED AND 

DECREED that the defendant JOSEPH LAFORTE’S Motion to Modify Conditions of 

Release is GRANTED, and he is permitted to reside at 2200 Benjamin Franklin Parkway 

Unit 1902 west, Philadelphia Pa. 

 ________________________________________ 

 THE HONORABLE JUAN R. SANCHEZ 

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 IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

________________________________________________________________________ 

UNITED STATES OF AMERICA : CRIMINAL ACTION

 FILED UNDER SEAL

vs. : 

 

JOSEPH LAFORTE : NO. 20-231 

________________________________________________________________________ 

MOTION TO MODIFY CONDITIONS OF RELEASE PERMITTING

DEFENDANT JOSEPH LAFORTE TO RESIDE AT 2200 BENJAMIN 

PARKWAY, UNIT 1902 WEST IN PHILADELPHIA, PA 

Defendant, JOSEPH LAFORTE, by his attorney, BRIAN J. MCMONAGLE, 

Esquire, hereby moves that this Honorable Court enter an ORDER modifying defendant’s 

conditions of release permitting him to reside at 2200 Benjamin Franklin Parkway, Unit 

1902 west, Philadelphia, Pa, and in support thereof avers the following: 

1. On October 8, 2020, the Honorable Petrese Tucker issued an order granting 

Joseph LaForte’s pretrial release under a condition that he reside at 568 

Ferndale Ave in Haverford, Pa. with his wife, under house arrest. Thereafter, 

as a result of his outstanding compliance with his conditions of release he was 

released from house arrest and permitted to leave the house under a condition 

of curfew. 

2. On May 5, 2023, Judge Rodolfo Ruiz, who is presiding over civil litigation 

brought against Mr. LaForte in the Southern District of Florida issued an order 

evicting Mr. LaForte and his wife from their Haverford home, requiring them 

to leave the residence by May 5, 2023, and directed a bankruptcy receiver to 

take possession of the property. 

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3. In compliance with this order, Mr. LaForte will leave the Haverford residence

and will now reside at 2200 Benjamin Franklin Parkway, Unit 1902 west, in

Philadelphia with his wife.

4. Mr. LaForte has notified his pretrial officer of the order and his change of

residence, and has been informed that pretrial does not object to the change.

5. Mr. LaForte has dutifully complied with all conditions of release, and

respectfully requests that his conditions of pretrial release be modified to

permit him to reside at 2200 Benjamin Franklin Parkway, Unit 1902 west, in

Philadelphia, with his wife.

WHEREFORE, for all of the foregoing reasons, defendant JOSEPH LAFORTE, 

requests that the Court grant the instant Motion. 

Respectfully Submitted, 

/s/ BRIAN J. MCMONAGLE

BRIAN J. MCMONAGLE, ESQUIRE

MCMONAGLE, PERRI, MCHUGH & MISCHAK

1845 Walnut Street 

19th Floor 

Philadelphia, PA 19103 

(215) 981-0999 Fax 981-0977

E-mail: bmcmonagle@mpmpc.com

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 CERTIFICATION OF SERVICE

BRIAN J. MCMONAGLE, ESQUIRE, hereby certifies that the Defendant Joseph 

LaForte’s Motion to Modify his Conditions of Release has been electronically filed.

 s/s/BRIAN J. MCMONAGLE

BRIAN J. MCMONAGLE, ESQUIRE

 

DATED: 5/3/23 

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