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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, RYAN K. STUMPHAUZER’S STATUS 

REPORT REGARDING CLAIMS DETERMINATION MOTION

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

Entities,

1 hereby files this Status Report regarding the progress of his forthcoming motion to 

approve the Receiver’s claims determinations in this case, 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 

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

Case 9:20-cv-81205-RAR Document 1840 Entered on FLSD Docket 04/05/2024 Page 1 of 3
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As the Receiver and the Securities and Exchange Commission (“SEC”) reported in their 

joint status report dated March 21, 2023 [ECF No. 1833], the Receiver has decided to seek the 

Court’s approval of his determinations of the claims that investors submitted in this case utilizing 

a calculation method that considers the investors’ net investment in Par Funding (i.e., total cash 

in, minus total cash out). The SEC has taken the position that the Court must first determine that 

Par Funding was operating a Ponzi scheme before this claim calculation methodology can be 

utilized. Without taking a position on whether a Ponzi scheme determination is necessary for 

utilizing the Receiver’s proposed claim calculation methodology, the Receiver is proceeding in 

that manner and is in the process of preparing his motion and supporting material for approval of 

the Receiver’s claims calculations and for a Ponzi scheme determination.

The SEC has requested that, once the Receiver has finalized his draft motion, the Receiver 

provide the SEC with a copy of the draft motion and, prior to filing, allow the SEC two weeks to 

review the draft and confirm its position on the requested relief. Accordingly, the Receiver intends 

to file another status report with the Court in two weeks (i.e., on April 29, 2024), wherein the 

Receiver will provide the Court with a further update on the timeline for the filing of this motion.

Dated: April 5, 2024 Respectfully Submitted,

STUMPHAUZER KOLAYA 

NADLER & SLOMAN, 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@sknlaw.com

Quayside Dr., Jupiter FL 33477.

Case 9:20-cv-81205-RAR Document 1840 Entered on FLSD Docket 04/05/2024 Page 2 of 3
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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

Co-Counsel for Receiver 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on April 5, 2024, 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 1840 Entered on FLSD Docket 04/05/2024 Page 3 of 3