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.

/

DEFENDANTS JOSEPH LAFORTE AND LISA MCELHONE’S UNOPPOSED 

MOTION FOR AN EXTENSION OF TIME TO FILE THEIR

OPPOSITION TO THE RECEIVER’S MOTION TO SHOW CAUSE

Defendants, Joseph LaForte and Lisa McElhone (collectively the “Defendants”), by and 

through their undesigned counsel, respectfully request an extension of time of one business day to 

file their Memorandum in Opposition to the Receiver’s Motion for an Order to Show Cause why the 

Defendants should not be held in contempt (D.E. 1328), and as support therefore state as follows:

1. The current deadline for the Defendants to file their Memorandum in Opposition to 

the Receiver’s Order to Show Cause why the Defendants should not be held in contempt is August 

26, 2022.

2. Defendants respectfully request an extension of this deadline for one business day 

(through Monday, August 29th) due to the press of other deadlines and unforeseen circumstances that 

have delayed the completion of the Defendants’ work. 

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3. The Defendants also believe that this brief extension is warranted because the 

Receiver only recently provided the Defendants with the bank statements and other records which 

he relied upon in preparing and filing the contempt motion.1

4. The Defendants have been working expeditiously on this matter, but require time to 

evaluate the Receiver’s newly produced materials in order to respond to the Receiver’s allegations 

and prepare their defenses. 

5. Defendants are seeking a one-day extension of the deadline due to the foregoing 

circumstances, and not for the purposes of delay. 

6. The Receiver does not oppose the requested extension, and has advised that he would 

also like a brief extension (through Thursday, September 8) to file a Reply brief. Assuming the Court 

grants Defendants a one-day extension, the Defendants have no objection to the Receiver being given 

the extension he requested.

WHEREFORE, the Defendants Joseph LaForte and Lisa McElhone respectfully request a 

one-day extension of time, up to and including August 29, 2022, to file their Response to the 

Receiver’s Motion for an Order to Show Cause, and request that the Receiver be given a one-day 

extension, up to and including September 8, 2022, to file his Reply.

S.D. Fla L. R. 7.1(a)(3) Certification of Counsel

Counsel for the Defendants hereby certify that they have conferred with counsel for the 

Receiver, Timothy A. Kolaya, and are authorized to represent that the Receiver does not oppose the 

relief sought in this Motion.

1 These materials were produced by the Receiver at 9:56 p.m. on Friday August 19, 2022 – one week 

before Defendants response brief was due – even though the Defendants had asked for them nine

days prior, and had procured the Receiver’s agreement to produce them seven days before the 

production was actually made. 

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KOPELOWITZ OSTROW 

FERGUSON WEISELBERG GILBERT

Attorneys for Joseph W. LaForte

One W. Las Olas Blvd., Suite 500 

Fort Lauderdale, Florida 33301

Tel: (954) 525-4100

By: /s/ David L. Ferguson

DAVID L. FERGUSON

Florida Bar Number: 0981737

Ferguson@kolawyers.com 

JOSHUA R. LEVINE

Florida Bar Number: 91807

Levine@kolawyers.com

KAPLAN ZEENA LLP

Attorneys for Defendant Lisa McElhone

2 South Biscayne Boulevard, Suite 3050

Miami, Florida 33131

Telephone: (305) 530-0800

Facsimile: (305) 530-0801 

By: /s/ James M. Kaplan

JAMES M. KAPLAN

Florida Bar No.: 921040

james.kaplan@kaplanzeena.com 

elizabeth.salom@kaplanzeena.com

service@kaplanzeena.com

NOAH E. SNYDER

Florida Bar No.: 107415

noah.snyder@kaplanzeena.com

maria.escobales@kaplanzeena.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 25th day of August, 2022, I electronically filed the 

forgoing 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 transmissions of Notices of Electronic 

Filing generated by CM/ECF.

By: /s/ James M. Kaplan

 JAMES M. KAPLAN

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