DECLARATION OF GIANNA WOLFE 

I, the undersigned, Gianna Wolfe pursuant to 28 U.S.C. § 1746, declare that: 

1. My name is Gianna Wolfe, I am over twenty-one years of age, and I have personal 

knowledge of the matters set forth herein. 

2. I own a company called Radiant Images Inc. (the "Company"), which is located in 

Los Angeles, California. 

3. In November 2015, March 2016, June 2016, December 2016, January 2017, February 

2017, March 2017, April 2017, June 2017, August 2017, September 2017, October 2017, 

November 2017, December 2017, January 2018, Complete Business Solutions Group ("CBSG") 

made loans to my Company totaling $6,126,054.13 (the "Loans") through what CBSG calls its 

"merchant capital advance" ("MCA") business. 

4. I applied to CBSG for the Loans and was the sole source of contact with CBSG on 

behalf of my Company during the Loan application process and CBSG's underwriting process. 

5. My Loans were underwritten by CBSG in less than 48 hours. 

6. At no time did CBSG offer me or my Company insurance of any kind. 

7. CBSG did not conduct a personal interview before giving my Company the Loans. 

8. CBSG did not request information about my Company's expenses during the 

underwriting process or at any other time prior to approving the Loans. 

9. CBSG did not request information about my Company's profit margins during the 

underwriting process or at any other time prior to approving the Loans. 

10. CBSG did not request a debt schedule for my Company during the underwriting 

process or at any other time prior to approving the Loans. 

11. After obtaining the Loans, my primary contact at CBSG was Joe Mack, who I have 

now come to learn is Joseph LaF orte. 

Case 9:20-cv-81205-RAR Document 30-5 Entered on FLSD Docket 07/27/2020 Page 1 of 6
12. My company entered into a Non-Disclosure Agreement with Par Funding in 

September 2017. A true and correct copy of the NDA Agreement is attached as Exhibit A and 

shows "Joe Mack" as the signatory for CBSG, which is also known as Par Funding. 

13. Joe Macki, who is also Joseph Laforte, was involved on behalf of Par Funding in 

connection with litigation concerning the Loans. A true and correct copy of a July 2018 email 

exchange is attached as Exhibit B. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on July 7th, 2020, in Los Angeles, California. 

Case 9:20-cv-81205-RAR Document 30-5 Entered on FLSD Docket 07/27/2020 Page 2 of 6
Joe Macki September 13, 2017

Case 9:20-cv-81205-RAR Document 30-5 Entered on FLSD Docket 07/27/2020 Page 3 of 6
Case 9:20-cv-81205-RAR Document 30-5 Entered on FLSD Docket 07/27/2020 Page 4 of 6
From: Joe Mack <joe@parfunding.com> 

Sent: Thursday, July 26, 2018 5:44 PM

To: NORMAN VALZ <nvalz@msn.com>; Heskin, Shane <heskins@whiteandwilliams.com>

Subject: RE: Radiant Images

CAUTION: This message originated outside of the firm. Use caution when opening attachments, clicking

links or responding to requests for information.

We can resolve this by having your client pay the weekly payments that I was generous enough to

give to them.. Please

Joe Macki

Client Services Manager

Office: 215-922-2636

Fax: 888-803-4886

Email: joe@parfunding.com

From: NORMAN VALZ <nvalz@msn.com> 

Sent: Thursday, July 26, 2018 5:40 PM

To: Joe Macki <joe@parfunding.com>

Subject: Fwd: Radiant Images

We got their attention.

From: Heskin, Shane <heskins@whiteandwilliams.com>

Sent: Thursday, July 26, 2018 5:36 PM

To: nvalz@msn.com

Subject: Radiant Images

Hi Norm and Lucy,

Can you please speak with Joe and try to figure out what happened here? It looks like there

has been some misinformation going on.

Case 9:20-cv-81205-RAR Document 30-5 Entered on FLSD Docket 07/27/2020 Page 5 of 6
First, our client received via regular mail a copy of the COJ that filed on July 19th in the total

amount of $2,356,741.10. The 50+ pages that were included in the package state that Radiant

entered into 17 agreements and it included agreements that were already paid in full.

Second, and perhaps most alarming, Exhibit R is someone else's payment history. It has

nothing to do with Radiant.

Third, Exhibit C reflects my client’s full DL number exposing them identity theft.

Fourth, Exhibit G includes a Disclosure for Confession of Judgement re: factoring agreement

dated March 28, 2017 which was paid in full and is not related at all to the factoring

agreement included in exhibit G.

Fifth, Exhibit H includes a signed COJ dated April 17, 2017 for a 190 day agreement also

included. We do not believe this loan had any balance due in mid-Feb 2018 because the

estimated pay off date on the agreement states Jan 30, 2018 which was before Radiant stopped

payments. Most likely, Radiant entered into a new loan that paid this one off.

Sixth, Exhibit I reflects a factoring agreement that was paid off when entering into a new

agreement.

Seventh, Exhibit M, O, and Q includes agreements that they did not require a signed or

notarized COJ, yet a blank one is included. Exhibit P does not include any copy of any signed

COJ because they did not require one.

Eighth, Exhibit R funding history document does not reflect actual payments sent by Radiant

Images.

Please let me know how we can resolve this ASAP.

Thanks,

-Shane

Case 9:20-cv-81205-RAR Document 30-5 Entered on FLSD Docket 07/27/2020 Page 6 of 6