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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’S MOTION TO CONTINUE STATUS CONFERENCE ON APRIL 10, 2023

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

Entities,1 by and through his undersigned counsel, files this Motion to Continue Status Conference 

on April 10, 2023 (the “Motion”). In support thereof, the Receiver states: 

1

 The “Receivership Entities” are Complete Business Solutions Group, Inc. d/b/a 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 located at 568 

Ferndale Lane, Haverford PA 19041; 105 Rebecca Court, Paupack, PA 18451; 107 Quayside Dr., 

Case 9:20-cv-81205-RAR Document 1532 Entered on FLSD Docket 03/20/2023 Page 1 of 3
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1. On March 6, 2023, the Court entered an Order setting an in-person status 

conference in this case for Monday, April 10, 2023. (ECF No. 1520). 

2. The purpose of the status conference is for the Receiver and his counsel to provide 

the Court with an update on the claims administration process, as well as an update regarding 

collection efforts on behalf of the investors. (Id.)

3. Undersigned counsel will be out of the country on April 10, 2023, and returning to 

Miami on April 13, 2023, and, therefore, would not be able to be present at a status conference on 

April 10, 2013. 

4. Although other counsel for the Receiver can be present at a status conference on 

April 10, 2013, undersigned counsel for the Receiver has been primarily responsible for providing 

updates to the Court on the claims administration process.

5. Given that counsel are required to attend this status conference in-person, 

undersigned counsel respectfully requests that the Court continue this status conference to another 

date at the Court’s discretion on a date after April 13, 2023.

WHEREFORE, undersigned counsel respectfully requests the Court to continue the status 

conference currently scheduled for April 10, 2023, to another date at the Court’s discretion on a 

date after April 13, 2023.

Jupiter FL 33477; and 2413 Roma Drive, Philadelphia, PA 19145.

Case 9:20-cv-81205-RAR Document 1532 Entered on FLSD Docket 03/20/2023 Page 2 of 3
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Dated: March 20, 2023 Respectfully Submitted,

STUMPHAUZER KOLAYA

NADLER & SLOMAN, PLLC

Two South Biscayne Blvd., Suite 1600 

Miami, FL 33131 

Telephone: (305) 614-1400 

By: /s/ Timothy A. Kolaya 

TIMOTHY A. KOLAYA

Florida Bar No. 056140 

tkolaya@sknlaw.com 

 Co-Counsel for Receiver

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on March 20, 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

Case 9:20-cv-81205-RAR Document 1532 Entered on FLSD Docket 03/20/2023 Page 3 of 3