Friday, May 26, 2023 at 15:34:44 Eastern Daylight Time

Page 1 of 3

Subject: Re: Joseph Cole Barleta

Date: Friday, May 26, 2023 at 12:51:03 PM Eastern Daylight Time

From: Gaetan J. Alfano <GJA@Pietragallo.com>

To: Andre Raikhelson <arlaw@raikhelsonlaw.com>

CC: mmatozzo@unitedsavingsbank.com <mmatozzo@unitedsavingsbank.com>, Timothy Kolaya

<tkolaya@sknlaw.com>, Joe Cole <joecole@knewlogic.com>

AGachments: image054316.png, image503982.png

Andre,

Are you willing to provide the Receiver with complete statements for this account?

I cannot evaluate the accuracy of these representaXons without reviewing them. 

Thank you. 

Gaetan

Sent from my iPhone

Gaetan J. Alfano, Esquire

Pietragallo Gordon Alfano Bosick & Raspanti, LLP

1818 Market Street, Suite 3402

Philadelphia, PA 19103

Office: (215) 988-1441 | Fax: (215) 754-5181

GJA@Pietragallo.com| BIO|vCard

This electronic mail message, and any attachments transmitted with it, contain confidential

information, intended only for the named addressee(s). If you are not the intended recipient or the

person responsible for delivering this e-mail to the intended recipient, you are hereby notified that

any use, distribution, copying or disclosure of this communication is strictly prohibited. If you have

received this e-mail in error, please immediately notify Pietragallo Gordon Alfano Bosick & Raspanti,

LLP by reply e-mail, and delete all copies of this communication from your computer and network.

Thank you. 

On May 26, 2023, at 12:43 PM, Andre Raikhelson <arlaw@raikhelsonlaw.com> wrote:

Dear Mr. Matozzo:

I represent Mr. Barleta. As you can see, Mr. Barleta is precluded from employing any device,

scheme or arXfice to defraud, make any untrue statement of material fact or omit a material

fact, or engage in any pracXce which operaXves or would operate as a fraud. Mr. Barleta has not

been accused of doing any illegal act independent of the liXgaXon pertaining to Par Funding.

Likewise, Capital Source 2000, Inc. has not been accused of conducXng anything illegal or

violaXve of any federal or state law. As such, Judge Ruiz specifically held, based on the

agreement of the parXes, that Capital Source 2000, Inc is not a receivership enXty.

Likewise, Mr. Barleta has not sold an unregistered security.

Case 9:20-cv-81205-RAR Document 1572-5 Entered on FLSD Docket 05/26/2023 Page 1 of 3
Page 2 of 3

Likewise, Mr. Barleta has not sold an unregistered security.

Finally, as to the asset freeze. There is absolutely no evidence that Mr. Barleta is a]empXng to

dissipate his assets.

Specifically to Mr. Alfano,

I do not know what your intent is in sending Mr. Matozzo your email without any proof that Mr.

Barleta is violaXng this or any other court order. Mr. Barleta has, and conXnues, to comply with

all valid court orders from any jurisdicXon. However, please let this e-mail be construed as a

cease and desist for you not to interfere with the affairs of Mr. Barleta or his respecXve business

enXXes unless you have actual proof that such enXXes are violaXng a court order. Should you

conXnue to interfere, Mr. Barleta will explore any and all legal acXon, including filing a lawsuit

for TorXous Interference.

Respecbully,

Andre G. Raikhelson, Esq.

From: Gaetan J. Alfano <GJA@Pietragallo.com>

Date: Wednesday, May 24, 2023 at 12:28 PM

To: mmatozzo@unitedsavingsbank.com <mmatozzo@unitedsavingsbank.com>

Cc: Andre G. Raikhelson Esquire (arlaw@raikhelsonlaw.com) <arlaw@raikhelsonlaw.com>,

Timothy Kolaya <tkolaya@sknlaw.com>

Subject: FW: Joseph Cole Barleta

Mr. Matozzo,

My email below bounced due an apparently incorrect address.

Please confirm receipt.

Thank you.

Gaetan Alfano

Gaetan J. Alfano, Esquire

Pietragallo Gordon Alfano Bosick & Raspanti, LLP

1818 Market Street, Suite 3402

Philadelphia, PA 19103

Office: (215) 988-1441 | Fax: (215) 754-5181

GJA@Pietragallo.com| BIO|vCard

<image054316.png>

This electronic mail message, and any attachments transmitted with it, contain

confidential information, intended only for the named addressee(s). If you are not the

intended recipient or the person responsible for delivering this e-mail to the intended

recipient, you are hereby notified that any use, distribution, copying or disclosure of this

communication is strictly prohibited. If you have received this e-mail in error, please

immediately notify Pietragallo Gordon Alfano Bosick & Raspanti, LLP by reply e-mail, and

delete all copies of this communication from your computer and network. Thank you. 

From: Gaetan J. Alfano <GJA@Pietragallo.com> 

Case 9:20-cv-81205-RAR Document 1572-5 Entered on FLSD Docket 05/26/2023 Page 2 of 3
Page 3 of 3

Sent: Wednesday, May 24, 2023 12:26 PM

To: mma]ozzo@unitedsavingsbank.com

Cc: Andre G. Raikhelson Esquire (arlaw@raikhelsonlaw.com) <arlaw@raikhelsonlaw.com>;

Timothy Kolaya <tkolaya@sknlaw.com>

Subject: Joseph Cole Barleta

Good ahernoon Mr. Ma]ozzo,

I represent Ryan K. Stumphauzer, Esq., Court Appointed Receiver for Complete Business

SoluXons Group, Inc. ( “CBSG”) and related enXXes in the ma]er capXoned SEC v. CBSG, et al,

Case No. 20-CV-81205-RAR, pending in the United States District Court for the Southern District

of Florida. I write as I understand generally that Mr. Barleta may be conducXng business with

your bank and that this Order may be relevant to Mr. Barleta’s business with your Bank. 

Please note that on August 27, 2020, the Court entered the a]ached Order, which includes an

Asset Freeze of Mr. Barleta’s assets up to 5.5 million. See p.4 of the a]ached Order.

I have copied Mr. Barleta’s counsel, Mr. Raikhelson, on this email, as well as my co-counsel, Mr.

Kolaya. Please fee free to contact me if you would like to discuss this email.

Thank you.

Gaetan Alfano

Gaetan J. Alfano, Esquire

Pietragallo Gordon Alfano Bosick & Raspanti, LLP

1818 Market Street, Suite 3402

Philadelphia, PA 19103

Office: (215) 988-1441 | Fax: (215) 754-5181

GJA@Pietragallo.com| BIO|vCard

<image054316.png>

This electronic mail message, and any attachments transmitted with it, contain

confidential information, intended only for the named addressee(s). If you are not the

intended recipient or the person responsible for delivering this e-mail to the intended

recipient, you are hereby notified that any use, distribution, copying or disclosure of this

communication is strictly prohibited. If you have received this e-mail in error, please

immediately notify Pietragallo Gordon Alfano Bosick & Raspanti, LLP by reply e-mail, and

delete all copies of this communication from your computer and network. Thank you. 

Case 9:20-cv-81205-RAR Document 1572-5 Entered on FLSD Docket 05/26/2023 Page 3 of 3