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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 568 FERNDALE LANE, HAVERFORD, PA 19041

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 568 Ferndale Lane, Haverford, PA 19041 (the 

“Haverford 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] (the “Order Authorizing Sale”).

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

contingent Contract for Sale of Real Estate for the sale of the Haverford Property (the “Contract”). 

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The Contract, which is subject to approval by this Court, is scheduled for a closing on June 29, 

2023. 

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

“Declaration”), providing additional detail regarding the proposed sale, and requesting the Court 

to enter an order authorizing and approving the proposed sale, as provided for in the Contract. 

5. Attached hereto as Exhibit 2 is a Stipulation of Waiver of Requirements Under 28 

U.S.C. §2001 and 28 U.S.C. §2004 for the Sale of 568 Ferndale Lane, Haverford, Pennsylvania 

19041. 

6. Attached hereto as Exhibit 3 is a Proposed Order Authorizing Receiver’s Sale of 

Real Property Located at 568 Ferndale Lane, Haverford, PA 19041 (the “Proposed Order”). 

7. The Receiver requests that, should no party file an objection to the Contract within 

seven (7) days of the filing of this Motion (i.e., by June 26, 2023), the Court enter the Proposed 

Order.

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

Order, provided that no party files an objection to the Contract within seven (7) days from the 

filing of this Motion (i.e., by June 26, 2023),

Dated: June 19, 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

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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

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on June 19, 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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