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.

______________________________________/ 

ORDER GRANTING RECEIVER’S TWENTY-NINTH MOTION TO LIFT 

LITIGATION INJUNCTION AS TO CERTAIN GARNISHMENT PROCEEDINGS 

THIS CAUSE comes before the Court upon the Receiver’s Combined Twenty-Ninth

Motion to Lift Litigation Injunction as to Certain Garnishment Proceedings and to Authorize 

Foreclosure Sale on 1804 Green Hollow Dr., Iselin, NJ (“Motion”), [ECF No. 1748], filed on 

November 14, 2023. 

In Section I of the Motion, the Receiver seeks to modify the Court’s Amended Order 

Appointing Receiver dated August 13, 2020, [ECF No. 141], so as to lift the litigation injunction 

provided for in that Order for certain garnishment matters currently pending in the Court of 

Common Pleas of Philadelphia County, Pennsylvania to be opened for the limited purpose to 

authorize the Receiver, in his direction, to dissolve current writs of garnishment, to mark 

judgments satisfied, and/or to reopen confessed judgments, where the counterparty merchant either 

has resolved, has agreed to resolve prior defaults, or otherwise filed for bankruptcy protection, in 

certain cases in the Court of Common Pleas of Philadelphia County, Pennsylvania. 

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The Receiver has made a sufficient and proper showing in support of the relief requested. 

Accordingly, it is hereby

ORDERED AND ADJUDGED that the Receiver’s Motion is GRANTED with respect 

to the relief requested. Specifically, the litigation injunction set forth in the Court’s Amended 

Order Appointing Receiver dated August 13, 2020, [ECF No. 141], is hereby lifted in the following 

matters in the Court of Common Pleas of Philadelphia County, Pennsylvania, and solely for the 

purpose as described in the Motion:

a. Complete Business Solution Group Inc. d/b/a Par Funding v. Agency ACBH 

Inc. d/b/a Agency ACBH and William Harper, Jr., Philadelphia Court of 

Common Pleas Docket No. 190300886.

b. Complete Business Solution Group Inc. d/b/a Par Funding v. Markus Corp. and 

Marek Kusmierczyk, Philadelphia Court of Common Pleas Docket No.

200400147.

c. Complete Business Solution Group Inc. d/b/a Par Funding v. ARM 

Transportation INC d/b/a ARM Transportation, d/b/a The Park AT AR, Faisal 

Khan, Amber Zulfiquan Khan, and Maryam Khan, Philadelphia Court of 

Common Pleas Docket No. 190705030.

d. Complete Business Solution Group Inc. d/b/a Par Funding v. Sidney Browne 

Sole Proprietor d/b/a All Tines and Sidney S. Browne, Philadelphia Court of 

Common Pleas Docket No. 170802260.

e. Complete Business Solution Group Inc. d/b/a Par Funding v. Sidney Browne 

Sole Proprietor d/b/a All Tines and Sidney S. Browne, Philadelphia Court of 

Common Pleas Docket No. 191100531.

f. Complete Business Solution Group Inc. d/b/a Par Funding v. AFBC Logistics, 

Inc. d/b/a AFBC Logistics and Mirzohid Muminov, Philadelphia Court of 

Common Pleas Docket No. 200201606.

g. Complete Business Solution Group Inc. d/b/a Par Funding v. Greenwood 

Collision Center, Inc. d/b/a Greenwood Collision Center, and Robert Myshkoff, 

Philadelphia Court of Common Pleas Docket No. 190701652.

h. Complete Business Solution Group Inc. d/b/a Par Funding v. Bera 

International LLC d/b/a Bera International d/b/a Bera Wines Inc. and Raquel 

Gonzalez, Philadelphia Court of Common Pleas Docket No. 190802163.

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i. Complete Business Solution Group Inc. d/b/a Par Funding v. Jesse Black Sole 

Proprietor of AJ’s Tree Service and Jesse Allen Black, Philadelphia Court of 

Common Pleas Docket No. 191200171.

j. Complete Business Solution Group Inc. d/b/a Par Funding v. Oakbend 

Enterprises Inc. d/b/a MAACO d/b/a MAACO of Athens d/b/a MAACO Auto 

Painting & Body Work et al., Philadelphia Court of Common Pleas Docket No.

190901717.

In Section II of the Motion, the Receiver seeks to modify the Court’s Amended Order 

Appointing Receiver dated August 13, 2020, [ECF No. 141], for the limited purpose of lifting the 

litigation injunction provided for in that Order relating to the case captioned Citibank N.A. v. 

Surech Nayak aka Suresh Chandra Nayak, et al. in the Middlesex County Superior Court of New 

Jersey at Case SWC-F-001688-20. 

The Receiver has made a sufficient and proper showing in support of the relief requested. 

Accordingly, it is hereby

ORDERED AND ADJUDGED that the Receiver’s Motion is GRANTED with respect 

to the relief requested in Section II thereof. Specifically, the litigation injunction set forth in the 

Court’s Amended Order Appointing Receiver dated August 13, 2020, [ECF No. 141], is hereby 

lifted so as to allow the case captioned Citibank N.A. v. Surech Nayak aka Suresh Chandra Nayak,

et al., in the Middlesex County Superior Court of New Jersey at Case SWC-F-001688-20 to 

proceed. 

DONE AND ORDERED in Miami, Florida, this 14th day of November, 2023. 

_________________________________

RODOLFO A. RUIZ II

UNITED STATES DISTRICT JUDGE

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