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 LISA MCELHONE’S AND JOSEPH LAFORTE’S 

MOTION FOR ENLARGEMENT OF TIME TO FILE THEIR RESPONSE

TO THE RECEIVER’S DISTRIBUTION MOTION [ECF NO. 2014]

Defendants, Lisa McElhone and Joseph LaForte (“Defendants”), by and through their

undersigned counsel, hereby file this Motion for a one-week enlargement of time to file their 

response to the Receiver’s Motion to (1) Approve Proposed Plan of Distribution and (2) Authorize 

First Interim Distribution (the “Distribution Motion”, ECF No. 2014), and as support therefore state 

as follows: 

1. The Receiver filed the Distribution Motion on August 23, 2024.

2. On August 26, 2024, the Court entered an Order Setting Briefing Schedule for 

Distribution Plan (the “Order,” ECF No. 2015), which requires all claimants with outstanding 

objections to the Distribution Motions (including Defendants) to file their responses to the 

Distribution Motion on or before September 9, 2024. 

3. Defendants are in the process of analyzing the Receiver’s proposed plan of 

distribution, and anticipate filing a response to preserve their rights with respect to their appeal of 

the Final Judgments entered against them and the Order expanding the scope of the Receivership 

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(which is currently pending before the Eleventh Circuit), and Defendants’ other rights and property 

interests.

4. Due to the undersigned counsel’s trial schedule and the press of other deadlines, 

Defendants respectfully request a one-week enlargement of the deadline to file their response to the

Distribution Motion. If the request is granted, the new deadline will be September 16, 2024.

5. Defendants’ counsel conferred with counsel for the Receiver and was advised that the 

Receiver does not oppose the requested enlargement of time.

6. Defendants are seeking the requested enlargement due to the foregoing circumstances, 

and not for the purposes of delay. No party will be prejudiced if the enlargement is granted.

WHEREFORE, Defendants respectfully request an enlargement of time, up to and including 

September 16, 2024, to file their response to the Receiver’s Distribution Motion.

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 in a good faith effort to resolve the issues raised in this motion and are authorized to state 

that the Receiver has indicated the following: “Notwithstanding the requested extension of time, the 

Receiver will endeavor to draft and file his reply to the Defendants’ response by the current deadline 

of September 23, 2024 [ECF No. 2015], so as not to delay the Court’s resolution of the Distribution 

Motion and, on that basis, does not oppose the requested enlargement of time.”

Respectfully submitted,

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KOPELOWITZ OSTROW 

FERGUSON WEISELBERG GILBERT

Attorneys for Defendant 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 

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 5th day of September, 2024, 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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