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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-THIRD MOTION TO LIFT 

LITIGATION INJUNCTION AS TO CERTAIN GARNISHMENT PROCEEDINGS

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

Entities,

1 by and through undersigned counsel, hereby files this Twenty-Third 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; Capital Source 2000, Inc.; 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 properties 

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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. Fast Advance Funding LLC v. Ecosense Interiors LLC and Guilia 

Finetto, Philadelphia Court of Common Pleas Docket No. 

1906068040.

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

MHGC Holdings LLC and Gabriel Gaviria, Philadelphia Court of 

Common Pleas Docket No. 200301939.

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

Esquina Del Pan Con Bistec #2 and Gabriel Jamie Gaviria, 

Philadelphia Court of Common Pleas Docket No. 200301965.

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

Modern Living Supplies Inc. d/b/a Modern Living Supplies and 

Mark Naylon, Philadelphia Court of Common Pleas Docket No.

190901459.

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

Dragan Segvic LLC and Dragan Segvic, Philadelphia Court of 

Common Pleas Docket No. 200600328.

located at 568 Ferndale Lane, Haverford PA 19041; 105 Rebecca Court, Paupack, PA 18451; 107 

Quayside Dr., Jupiter FL 33477; 2413 Roma Drive, Philadelphia, PA 19145; 159 26th Street, 

Avalon, NJ 08202; and 164 84th Street, Stone Harbor, NJ 08247.

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 Nos. 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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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 regarding the relief 

sought through this motion and certifies that counsel of record for the Defendants have either (a) 

confirmed that they and/or their clients either do not oppose or take no position with respect to the 

relief sought or (b) have not responded to the Receiver’s meet-and-confer requests. The SEC has 

confirmed that it does not oppose the Receiver’s requests to lift the litigation injunction.

Dated: June 10, 2022 Respectfully Submitted, 

STUMPHAUZER FOSLID SLOMAN

ROSS & KOLAYA, PLLC

Two South Biscayne Blvd., Suite 1600

Miami, FL 33131

Telephone: (305) 614-1400

Facsimile: (305) 614-1425

By: /s/ Timothy A. Kolaya

TIMOTHY A. KOLAYA

Florida Bar No. 056140

tkolaya@sfslaw.com

Co-Counsel for Receiver 

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PIETRAGALLO GORDON ALFANO 

BOSICK & RASPANTI, LLP

1818 Market Street, Suite 3402

Philadelphia, PA 19103

Telephone: (215) 320-6200

Facsimile: (215) 981-0082

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 June 10, 2022, 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

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