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UNITED STATES DISTRICT COURT

FOR THE 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, RYAN K. STUMPHAUZER’S TWENTY-EIGHTH MOTION TO LIFT 

LITIGATION INJUNCTION AS TO CERTAIN GARNISHMENT PROCEEDINGS 

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

Entities1, by and through his undersigned counsel, hereby files this Twenty-Eighth Motion to Lift 

Litigation Injunction as to Certain Garnishment Proceedings, and states as follows: 

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

(“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 

Case 9:20-cv-81205-RAR Document 1656 Entered on FLSD Docket 08/09/2023 Page 1 of 4
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I. MOTION TO LIFT LITIGATION INJUNCTION AS TO CERTAIN 

GARNISHMENT PROCEEDINGS

1. The Receiver hereby moves this Court to lift the Litigation Injunction for the 

limited purpose of allowing the Receiver, in his discretion, to dissolve current writs of 

garnishment, to mark judgments satisfied, and/or to reopen confessed judgments, where the 

counterparty merchant either has resolved, or has agreed to resolve, prior defaults, or otherwise 

filed for bankruptcy protection, in the following cases in the Court of Common Pleas of 

Philadelphia County, Pennsylvania.

2

 

2. The cases are:

a. Complete Business Solutions Group Inc. d/b/a Par Funding v. Catherine G. 

Ysaguirre and RIMFX, Inc., Philadelphia Court of Common Pleas Docket 

No. 170500783.

b. Complete Business Solutions Group Inc. d/b/a Par Funding v. Dreamers 

Home Health Care LLC, Bashiel H. Smith, and Antionette C. Korvah, 

Philadelphia Court of Common Pleas Docket No. 170502631.

c. Complete Business Solutions Group Inc. by and through its Court 

Appointed Receiver Ryan K. Stumphauzer v. Department of Green Energy 

Inc. and Annika Kielland Philadelphia Court of Common Pleas Docket No.

220202821.

d. Complete Business Solutions Group Inc. d/b/a Par Funding v. Connect Link 

Inc. d/b/a Sam Diverse Specialty Contractors, Mary Jo D Gaumer, and 

Daniel Gaumer, Philadelphia Court of Common Pleas Docket No. 

190300635.

e. Complete Business Solutions Group Inc. d/b/a Par Funding v. JRose 

Wholesale Flowers Corporation d/b/a JRose Wholesale Flowers and Troy

Baksh, Philadelphia Court of Common Pleas Docket No. 200600012.

LLC; and ALB Management, LLC; and the receivership also includes the properties located at 107 

Quayside Dr., Jupiter FL 33477; and 2413 Roma Drive, Philadelphia, PA 19145.

2

 See the Court’s Amended Order Appointing Receiver dated August 13, 2020 [ECF No. 141] (the 

“Operative Receivership Order”). The Receiver generally incorporates the background section of 

his prior Motions to Lift Litigation Injunction as to Certain Garnishment Proceedings. [See, e.g.,

ECF No. 111.]. To conserve resources and promote efficiency, the Receiver is providing only a 

summary narrative, as approved by the Court at the October 7, 2020 status conference. 

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f. Complete Business Solutions Group Inc. d/b/a Par Funding v. Franken 

Frames Inc. d/b/a Franken Homes d/b/a Johnson City Framing, Roger 

Chase and Kimberly Chase, Philadelphia Court of Common Pleas Docket 

No. 180105445. 

g. Complete Business Solutions Group Inc. d/b/a Par Funding v. Brower 

Enterprises Inc. d/b/a Brower Sales d/b/a Brower Health and Stanley 

Brower, Philadelphia Court of Common Pleas Docket No. 180200627. 

h. Complete Business Solutions Group Inc. d/b/a Par Funding v. Jama’s 

Beauty College Inc. d/b/a Jama’s Beauty College and Jacqueline Marie 

Williams-Woody, Philadelphia Court of Common Pleas Docket No.

190904518. 

i. Complete Business Solutions Group Inc. d/b/a Par Funding v. Solene 

Boutique LLC d/b/a Solene Boutique d/b/a Solene and Lia Kalin, 

Philadelphia Court of Common Pleas Docket No. 191103515. 

3. The Receiver has determined, in his professional judgment, that it is in the best 

interests of the Receivership Estate to dissolve current writs of garnishment, to mark judgments 

satisfied, and/or to reopen confessed judgments with respect to these cases.

WHEREFORE, Ryan K. Stumphauzer, as Court-Appointed Receiver, by and through his 

undersigned counsel, respectfully requests this Honorable Court to grant the motion and lift the 

Litigation Injunction on a limited basis as set forth above. A proposed order for the Court’s 

consideration is attached as Exhibit 1. 

CERTIFICATION REGARDING PRE-FILING CONFERENCE

The undersigned counsel has conferred with all counsel of record and unrepresented parties 

in this matter regarding the relief sought through this motion and certifies that all counsel of record 

and unrepresented parties have either: (1) not responded to the Receiver’s meet and confer 

requests; or (2) confirmed that their clients either do not oppose or take no position with respect to 

the relief sought. The SEC also takes no position on the motion to lift the litigation injunction. 

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Dated: August 9, 2023 Respectfully Submitted, 

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 

Co-Counsel for Receiver 

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 August 9, 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 1656 Entered on FLSD Docket 08/09/2023 Page 4 of 4