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, 

and 

THE LME 2017 FAMILY TRUST, a/k/a

LME 2017 FAMILY TRUST,

 Relief Defendant.

______________________________________________/ 

DEFENDANT, MICHAEL C. FURMAN’S, MOTION TO 

RELEASE SEALED TRIAL TRANSCRIPTS

Pursuant to the applicable rules of this Court, Defendant, Michael C. Furman (“Furman”), 

by and through the undersigned counsel, hereby requests that the Court issue an Order to release 

sealed trial transcripts dated December 8, 2021 (the “Motion”), and in support thereof, Furman 

states as follows: 

1. On December 8, 2021, this Court held day 3 of trial, which is referenced at DE’s 

1081, 1082, and 1084. 

2. Furman is currently in the process of appeal and on April 17, 2023, filed his 

Transcript Information Form requesting the December 8, 2021 trial transcript [DE 1549]. 

3. To date, no transcript has been received because it is currently filed under seal. 

4. Accordingly, Furman requests an Order from this Court releasing the Transcript of 

Trial Day 3, dated December 8, 2021, as referenced in DE’s 1081, 1082 and 1084. 

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5. This request is being made in good faith and not for the purpose of delay or any 

other improper purpose. The requested rescheduling will not prejudice any party and is imperative 

to Furman’s preparation of appeal. 

WHEREFORE, Defendant, Michael C. Furman, respectfully requests that the Court enter 

an Order: (i) Granting the Motion, (ii) directing the Clerk of Court to release the Transcript of Trial 

Day 3, dated December 8, 2021, as referenced in DE’s 1081, 1082 and 1084; and (iii) Granting 

such further relief as the Court deems just and proper. 

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1(a)(3)

I HEREBY CERTIFY that counsel for the Movant has conferred with all parties or nonparties who may be affected by the relief sought in this Motion in a good faith effort to resolve the 

issue and that as of the filing of the instant motion, counsel for the SEC has not responded to the 

inquiry. However, given the due date of Furman’s brief of June 1, 2023, Furman requests that the 

Court address this Motion on an expedited basis. 

Respectfully submitted, 

 MILLENNIAL LAW, INC.

Attorneys for Michael C. Furman

501 E. Las Olas Blvd Ste 200/314 

Fort Lauderdale Fl 33301 

Phone: 954-271-2719 

By: s/ Zachary P. Hyman 

Zachary P. Hyman

Florida Bar No. 98581

zach@millenniallaw.com

malcolm@millenniallaw.com 

jessica@millenniallaw.com

assistant@millenniallaw.com

millenniallawforms@gmail.com 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 25th day of May, 2023, the foregoing was filed using 

the Court’s CM/ECF Filing system which will transmit Notices of Electronic Filing generated by 

CM/ECF to all counsel of record. 

By: s/ Zachary P. Hyman 

Zachary P. Hyman

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