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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’S MOTION FOR ORDER AUTHORIZING RECEIVER’S SALE OF REAL 

PROPERTY LOCATED AT 4633 WALNUT STREET, PHILADELPHIA, PA 19139

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

Entities, by and through his undersigned counsel, files this Motion for Order Authorizing 

Receiver’s Sale of Real Property Located at 4633 Walnut Street, Philadelphia, PA 19139 (the 

“Walnut Street Property”). In support thereof, the Receiver states:

1. On January 10, 2023, the Receiver filed a Motion for Order: (1) Authorizing 

Receiver’s Sale of All Real Property Within the Receivership Estate; and (2) Compelling Lisa 

McElhone and Joseph LaForte to Vacate and Surrender Haverford Home or, in The Alternative, 

Pay Obligations for Single-Family Homes [ECF No. 1484] (“Motion for Order Authorizing Sale”).

2. On January 11, 2023, the Court entered an Order Approving the Motion for Order 

Authorizing Sale [ECF 1486] (“Order Authorizing Sale”).

3. In the Order Authorizing Sale, the Court authorized the Receiver to begin the 

process of marketing for sale all real estate within the Receivership Estate, including the Walnut 

Street Property.

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4. In accordance with the Order Authorizing Sale, the Receiver has entered into a 

Purchase and Sale Agreement for the sale of the Walnut Street Property (the “Contract”). The 

Contract, which is subject to approval by this Court, is scheduled for a closing on September 15,

2023, provided the Court approves the Contract and authorizes the sale of the Walnut Street 

Property.

5. Attached hereto as Exhibit 1 is a Declaration of Ryan K. Stumphauzer. Esq. (the 

“Declaration”), requesting the Court to enter an order authorizing and approving the proposed sale, 

as provided for in the Contract.

6. The Receiver believes that the sale price for the Walnut Steet Property under the 

Contract, which he has accepted subject to this Court’s approval, is in the best interests of the 

Receivership Estate.

7. The Receiver represents that this Contract to Purchase the Walnut Street Property 

is a bona fide offer from a proposed buyer with whom the Receiver has no relationship and is the 

product of arms-length negotiation.

8. The Receiver proposes to proceed with the sale of the Walnut Street Property 

pursuant to the Contract, provided the Court approves the sale free and clear of liens, 

encumbrances, and other related obligations or claims.

9. A Proposed Order authorizing and approving the sale of the Walnut Street Property 

is attached as Exhibit 2.

10. To provide an opportunity for any potential objections to the sale of the Walnut

Street Property pursuant to the Contract, the Receiver requests that the Court enter the Proposed 

Order no earlier than seven (7) days after the filing of this Motion (i.e., on or after August 23, 

2023), so that the Court may consider and resolve any potential objections to the Contract.

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WHEREFORE, the Receiver respectfully requests that the Court enter the Proposed Order

on or after August 23, 2023, approving the Contract and authorizing the Receiver to sell the Walnut 

Street Property.

Local Rule 7.1 Certification

Pursuant to Local Rule 7.1, the undersigned counsel for the Receiver certifies that he has

conferred with counsel for the United States Securities and Exchange Commission (“SEC”), 

regarding the relief requested in this motion. Counsel for the SEC has confirmed that the SEC does 

not oppose the relief requested herein and agrees to the waiver of the requirements of 28 U.S.C. 

§2001 and 28 U.S.C. §2004 for the sale of the Walnut Street Property. 

Dated: August 16, 2023 Respectfully Submitted,

STUMPHAUZER KOLAYA

NADLER & SLOMAN, PLLC

Two South Biscayne Blvd., Suite 1600

Miami, FL 33131

(305) 614-1400 (Telephone)

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

(215) 320-6200 (Telephone)

By: /s/ Gaetan J. Alfano

GAETAN J. ALFANO

Pennsylvania Bar No. 32971 

(Admitted Pro Hac Vice) 

GJA@Pietragallo.com

Co-Counsel for Receiver

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 16, 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

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