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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.

____________________________________________/ 

RECEIVER AND CAPITAL SOURCE 2000 INC.’S STATUS REPORT 

PURSUANT TO ECF NO. 1779 REGARDING OBJECTION DEADLINE

Ryan K. Stumphauzer, Esq., Court-Appointed Receiver (“Receiver”) of the Receivership 

Entities,

1 and Capital Source 2000, Inc. (“CS2000”), by and through respective undersigned 

counsel, and pursuant to the Court’s Paperless Order dated December 19, 2023 [ECF No. 1779], 

1 The “Receivership Entities” are Complete Business Solutions Group, Inc. d/b/a Par Funding; Full 

Spectrum Processing, Inc.; ABetterFinancialPlan.com LLC d/b/a A Better Financial Plan; ABFP 

Management Company, LLC f/k/a Pillar Life Settlement Management Company, LLC; ABFP 

Income Fund, LLC; ABFP Income Fund 2, L.P.; United Fidelis Group Corp.; Fidelis Financial 

Planning LLC; Retirement Evolution Group, LLC;, RE Income Fund LLC; RE Income Fund 2 

LLC; ABFP Income Fund 3, LLC; ABFP Income Fund 4, LLC; ABFP Income Fund 6, LLC; 

ABFP Income Fund Parallel LLC; ABFP Income Fund 2 Parallel; ABFP Income Fund 3 Parallel; 

ABFP Income Fund 4 Parallel; and ABFP Income Fund 6 Parallel; ABFP Multi-Strategy 

Investment Fund LP; ABFP Multi-Strategy Fund 2 LP; MK Corporate Debt Investment Company 

LLC; Fast Advance Funding LLC; Beta Abigail, LLC; New Field Ventures, LLC; Heritage 

Business Consulting, Inc.; Eagle Six Consulting, Inc.; 20 N. 3rd St. Ltd.; 118 Olive PA LLC; 135-

137 N. 3rd St. LLC; 205 B Arch St Management LLC; 242 S. 21st St. LLC; 300 Market St. LLC; 

627-629 E. Girard LLC; 715 Sansom St. LLC; 803 S. 4th St. LLC; 861 N. 3rd St. LLC; 915-917 

S. 11th LLC; 1250 N. 25th St. LLC; 1427 Melon St. LLC; 1530 Christian St. LLC; 1635 East 

Passyunk LLC; 1932 Spruce St. LLC; 4633 Walnut St. LLC; 1223 N. 25th St. LLC; 500 Fairmount 

Avenue, LLC; Liberty Eighth Avenue LLC; Blue Valley Holdings, LLC; LWP North LLC; The 

LME 2017 Family Trust; Recruiting and Marketing Resources, Inc.; Contract Financing Solutions, 

Inc.; Stone Harbor Processing LLC; LM Property Management LLC; and ALB Management, 

LLC; and the receivership also includes the property located at 107 Quayside Dr., Jupiter FL. 

Case 9:20-cv-81205-RAR Document 1780 Entered on FLSD Docket 12/20/2023 Page 1 of 3
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hereby submit this status report regarding the results of their meet and confer regarding the timing 

for any objection CS2000 may wish to submit in response to the Receiver’s Notices of 

Determination regarding CS2000’s Proof of Claim in this case.

On December 19 and 20, 2023, counsel for the Receiver and counsel for CS2000 

exchanged emails and had a telephone call regarding these issues and have agreed as follows:

The Notice of Determination (“NOD”) the Receiver issued for CS2000 indicates that 

CS2000’s Proof of Claim is still “pending review.” In the NOD, a claim that is “pending review” 

is described as follows:

CLAIMS PENDING REVIEW BY RECEIVER – Claims identified in Exhibit 

D are pending review by the Receiver and may be subject to future determination 

or objection. The Receiver reserves all rights to object to any Proof of Claim on 

any basis.

(Emphasis added). The NOD further explains that a claimant may submit an objection to the 

Receiver’s NOD if the claimant “want[s] to contest the Receiver’s determination(s) of your 

Proof(s) of Claim.” Because the Receiver has not yet made a substantive determination with 

respect to CS2000’s claim, the Receiver has acknowledged that there is no need for CS2000 to file 

an objection at this time.

Once the Receiver finalizes his review of CS2000’s claim, the Receiver will issue a 

supplemental or revised NOD to CS2000. There will be a separate objection period for any 

supplemental or revised NOD the Receiver issues, with the objection deadline calculated from the 

date of the supplemental/revised NOD. As a result, the Receiver and CS2000 agree that the Court’s 

intervention is not necessary with respect to CS2000’s request for an extension of its deadline to 

object to the Receiver’s initial NOD, which indicated a status of “pending review.”

Case 9:20-cv-81205-RAR Document 1780 Entered on FLSD Docket 12/20/2023 Page 2 of 3
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Dated: December 20, 2023 Respectfully Submitted, 

Law Offices of Andre G. Raikhelson, LLC

7000 W Palmetto Park Road 

Suite 240 

Boca Raton, FL 33433 

Telephone: (954) 895-5566 

Primary Email: arlaw@raikhelsonlaw.com

/s/ Andre G. Raikhelson 

Andre G. Raikhelson, Esq. 

Bar Number: 123657 

Counsel for Defendant, Joseph Cole Barleta 

STUMPHAUZER KOLAYA

NADLER & SLOMAN, PLLC

Two South Biscayne Blvd., Suite 1600 

Miami, FL 33131 

Telephone: (305) 614-1400 

By: /s/ Timothy A. Kolaya 

TIMOTHY A. KOLAYA

Florida Bar No. 056140 

tkolaya@sknlaw.com 

PIETRAGALLO GORDON ALFANO 

BOSICK & RASPANTI, LLP

1818 Market Street, Suite 3402

Philadelphia, PA 19103 

Telephone: (215) 320-6200 

By: /s/ Gaetan J. Alfano 

GAETAN J. ALFANO 

Pennsylvania Bar No. 32971 

(Admitted Pro Hac Vice) 

GJA@Pietragallo.com

DOUGLAS K. ROSENBLUM

Pennsylvania Bar No. 90989 

(Admitted Pro Hac Vice) 

DKR@Pietragallo.com

Co-Counsel for Receiver 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on December 20, 2023, I electronically filed the foregoing 

document with the clerk of the Court using CM/ECF. I also certify that the foregoing document is 

being served this day on counsel of record via transmission of Notices of Electronic Filing 

generated by CM/ECF. 

 /s/ Timothy A. Kolaya 

 TIMOTHY A. KOLAYA

Case 9:20-cv-81205-RAR Document 1780 Entered on FLSD Docket 12/20/2023 Page 3 of 3