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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 QUARTERLY STATUS REPORT DATED APRIL 30, 2024

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

Entities,1 pursuant to the requirements of the Amended Order Appointing Receiver [ECF No. 141], 

hereby files this Quarterly Status Report dated April 30, 2024. By way of summary, as of the end 

1

 The “Receivership Entities” areComplete 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; ABFP Income Fund 6 Parallel; ABFP Multi-Strategy Investment 

Fund LP; ABFP Multi-Strategy Investment 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 Consultants, 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; Liberty 

Eighth Avenue LLC; The LME 2017 Family Trust; Blue Valley Holdings, LLC; LWP North LLC; 

500 Fairmount Avenue, LLC; Recruiting and Marketing Resources, Inc.; Contract Financing 

Solutions, Inc.; Stone Harbor Processing LLC; LM Property Management LLC; and ALB 

Management, Inc., and the Receivership also includes the property located at 107 Quayside Drive, 

Jupiter, Florida 33477. 

Case 9:20-cv-81205-RAR Document 1850 Entered on FLSD Docket 04/30/2024 Page 1 of 15
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of the reporting period (March 31, 2024), the Receivership Estate consisted of, among other things, 

approximately $26,500,000 of unsold real property, 2 $596,000 in other unsold tangible assets the 

Receiver has brought into the Receivership Estate, and $150,288,425 in cash. As of April 30, 2024, 

the current cash balance was $152,098,367. The report attached as Exhibit 1 includes a schedule 

reflecting the net tangible assets contained within the Receivership Estate.

I. Overall Administration of Receivership Estate

A. Quarterly Report of Receivership Estate

Pursuant to the requirements of the Amended Order Appointing Receiver [ECF No. 141], 

attached as Exhibit 1 is a full report and accounting reflecting (to the best of the Receiver’s 

knowledge as of the period covered by the report) the existence, value, and location of all 

Receivership Property, and of the extent of liabilities, both those claimed to exist by others and 

those the Receiver believes to be legal obligations of the Receivership Estates (the “Quarterly 

Report”). The Quarterly Report contains the following information: (1) summary of the operations 

of the Receiver; (2) the amount of cash on hand, the amount and nature of accrued administrative 

expenses, and the amount of unencumbered funds in the estate; (3) a schedule of all the Receiver’s 

receipts and disbursements (attached as Exhibit A to the Quarterly Status Report), with one column 

for the quarterly period covered and a second column for the entire duration of the receivership;

(4) a description of all known Receivership Property, including approximate or actual valuations, 

anticipated or proposed dispositions, and reasons for retaining assets where no disposition is 

intended; (5) a description of liquidated and unliquidated claims held by the Receivership Estate,

including the need for forensic and/or investigatory resources; approximate valuations of claims; 

and anticipated or proposed methods of enforcing such claims (including likelihood of success in: 

2

 The amounts for real property have decreased from the previous quarter as a result of the sale of real

property during the quarter, resulting in an increase in the cash balance.

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(i) reducing the claims to judgment; and, (ii) collecting such judgments); (6) a list of all known 

creditors with their addresses and the amounts of their claims; (7) the status of Creditor Claims 

Proceedings, after such proceedings have been commenced; and (8) the Receiver’s 

recommendations for a continuation or discontinuation of the receivership and the reasons for the 

recommendations, as required pursuant to Paragraphs 53 and 54 of the Amended Order Appointing 

Receiver dated August 13, 2020 [ECF No. 141].

II. Update on Other Assets Included within the Receivership Estate

A. Accounts Receivable and Collection Activities

At the time of his appointment, the Receiver obtained control over $28,779,570 in cash 

held by the various original Receivership Entities. As a result of various Orders expanding the 

Receivership, the Receiver obtained an additional $14,756,649 in cash held by the additional 

Receivership Entities. The Receiver has also acquired an additional $146,098,468 in cash through 

collections, settlements, other recoveries, and asset sales. After accounting for expenses, the total 

cash balance was $150,288,425 as of March 31, 2024. As of April 30, 2024, the current cash 

balance was $152,098,367. This increase of the cash balance is the result of, among other things,

collections activities, the receipt of proceeds from settlements the Receiver has reached with third

parties, and the sale of real estate within the Receivership Estate.

B. Accounts Receivable – Merchant Cash Advance Accounts

The Receiver, his professionals, and the staff he rehired at Par Funding have been 

continuing to collect on the accounts receivable for the merchant cash advance (“MCA”) accounts 

that were pending with the company as of the time the Receiver took over the operations of Par

Funding. Through the first quarter of 2022, the Receiver’s quarterly status reports reflected the 

full accounts receivable balances that had been recorded on Par Funding’s books for these MCA 

accounts, while explaining that these balances did not reflect appropriate reductions or reserves 

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for collectability or bad debt. Starting in the quarter that ended on June 30, 2022, the Receiver

identified MCA accounts that should be written off because the merchant had a closed 

bankruptcy, was no longer in operation, or had neither viable guarantors nor viable collateral. 

The Receiver also determined that a reserve was required for MCA accounts with ongoing

bankruptcies and in other circumstances where full payment was doubtful. See DSI’s Report, 

attached as Exhibit 1.

At the end of the second quarter of the 2022 reporting period (April 1, 2022, through June

30, 2022), the net result of these adjustments was a reduction of the total receivable balance from 

approximately $345 million to $224 million. At the end of the third quarter of the 2022 reporting 

period (July 1, 2022, through September 30, 2022), the total receivable balance was further 

reduced as a result of these adjustments to a total of $189 million. At the end of the third quarter 

of the 2023 reporting period (July 1, 2023, through September 30, 2023), the total receivable 

balance was further reduced to $68.5 million. As of the end of this reporting period, the total 

receivable balance was further reduced to $23.8 million. The Receiver anticipates further

reductions in the receivable balance.

Based on this collectability analysis, and only using information that was available to 

CBSG management, the Receiver finalized and filed an amended tax return for 2018, a previously 

unfiled return for 2019, and an amended return for 2020. Through these returns, the Receiver is 

requesting a refund of approximately $10.5 million.

C. Collection Efforts Through Outside Collection Company and Litigation

As previously reported, the Receiver engaged Altus Receivables Management, Inc. 

(“Altus”), a national collection company, to collect judgments previously entered against select 

non-performing, non-bankruptcy merchants, guarantors, and counterparties that had outstanding 

balances and/or were otherwise in default at the time of the establishment of the receivership.

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Referralsto Altus began on January 9, 2022, and 216 exemplified judgments in total were referred 

to Altus. Altus has closed 166 files, either by way of settlement or based on a determination that

further collection efforts would be futile. Although some collection efforts through Altus are

ongoing, the Receiver has not referred any additional files to Altus for several months, does not 

plan to send any additional files to Altus, and is expecting any remaining collection efforts from 

Altus to be winding down.

The Receiver also initiated 68 actions against merchants in the Philadelphia Court of 

Common Pleas, either through civil action complaints or confessions of judgment. Of these, only 

4 are being actively litigated, with the balance resolved through offers of settlement, default, or 

confessed judgments. 

D. Collection Activity and Settlements with ESC and HBC Counterparties

To date, the Receiver has resolved, either through full payoffs of the amount owed or 

settlements, the account balances of several counterparties to agreements with Eagle Six 

Consultants, Inc. (“ESC”) and Heritage Business Consulting, Inc. (“HBC”). The Receiver 

continues to explore settlement opportunities with the remaining viable counterparties to these 

agreements. Although the remaining balance owed to ESC and HBC by these counterparties is 

$29.3 million, the Receiver believes a significant portion of that amount is likely to be 

uncollectable.

E. Life Settlements

The Receiver continuesto manage the portfolios of life settlement policies owned by ABFP 

Multi-Strategy Investment Fund LP (“MSIF”) and ABFP Multi-Strategy Investment Fund II LP 

(“MSIF II”). On February 27, 2024, the Receiver was notified that one of the MSIF II life 

settlement policies had matured, and deposited the proceeds totaling $750,000 in March 2024. To

date, the Receiver has received total death benefits payable for policies owned by MSIF in the 

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amount of $5,532,479, and for policies owned by MSIF II in the amount of $7,700,000. These

amounts only include the policy face value the Receiver has received on these policies, and exclude 

any interest or dividends the Receiver has received for these policies.

III. Settlement with Eckert Seamans 

As previously reported, the Receiver and class counsel representing investor plaintiffs in 

various class action cases reached an agreement in principle to settle their claims against Eckert 

Seamans and its former partner John W. Pauciulo for $45 million, which represented the 

approximate amount of the remaining limits on the law firm’s eroding insurance policy. To 

facilitate this settlement, the Receiver attempted to resolve potential objections from the following 

groups: (1) Defendant Dean Vagnozzi and non-parties Alec Vagnozzi, Albert Vagnozzi, and Terry

Kohler (collectively, the “Vagnozzi Group”); and (2) the Plaintiffs in the case of Parker, et al. v.

Pauciulo, et al., No. 20-00892 (Phila. Ct. Com. Pl. 2020) (the “Parker Plaintiffs”). The Receiver 

attended settlement conferences before United States Magistrate Judge Bruce E. Reinhart with the 

Vagnozzi Group on October 31, 2023 (ECF No. 1727) and the Parker Plaintiffs on November 13, 

2023 (ECF No. 1728), but was unable to reach agreements with either group. 

The Receiver, together with counsel for the investor class, drafted a “Motion for (i) Approval 

of Settlement Among the Receiver, Putative Class Plaintiffs and Eckert Seamans, (ii) Approval of 

Form, Content and Manner of Notice of Settlement and Bar Order, (iii) Entry of Bar Order, and (iv) 

Scheduling a Hearing. The Receiver submitted a draft of that motion to the SEC for its review in 

December 2024, and on April 19, 2024, the SEC advised the Receiver that it would not oppose this 

motion. Now that the Receiver is aware of the SEC’s position, he intends to file the aforementioned 

motion by Friday, May 3, 2024. 

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IV. Receiver-Controlled Real Estate and Personal Property

A. Marketing of Personal Residences

The Receiver has been in control of 25 properties (the “Receiver-Controlled Properties”).

Three of the Receiver-Controlled Properties are single-family residential properties (the “SingleFamily Properties”). By Order dated January 10, 2023, the Court authorized the Receiver to market 

for sale all of the Receiver-Controlled Properties (the “Court Order”). Following the Court Order, 

the Receiver (i) commissioned market value appraisals of the Single- Family Properties and (ii)

engaged separate real estate brokers to list and market each property for sale. Currently, the 

Receiver has sold two of the three Single-Family Properties. Each sales price was above the 

property’s appraised value. 

As previously reported, the third Single-Family Property located at 107 Quayside Drive, 

Jupiter, Florida, was under an Agreement of Sale, but certain title issues, including an IRS lien 

based on Defendant Lisa McElhone’s pre-receivership federal tax obligations, has prevented the 

Receiver from closing on that sale. This property is no longer under an Agreement of Sale ̧ as the 

buyer under that agreement cancelled the contract when it became clear that these title issues could 

not be resolved promptly. The Receiver is continuing to explore methods to resolve these title 

issues, and anticipates filing a motion with the Court once he has determined the relief that will be 

necessary to satisfy a title insurance company for the purpose of providing title insurance on the 

sale of that property. 

The status of the Single-Family Properties is summarized below: 

Properties Location Listing Service Status Sale Price

105 Rebecca Court, Paupack, PA Jack Muehlhan Realty Sold $3,300,000

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568 Ferndale Lane Haverford, PA MLS Sold $3,338,000

107 Quayside Drive Jupiter, FL Waterfront Properties 

and Club 

Communities - MLS

Previously 

Under 

Contract, But 

Sale 

Cancelled

B. Marketing of Philadelphia Commercial/Mixed Use Properties

The remaining 22 properties are commercial, residential, or mixed-use rental properties in 

Philadelphia (the “Philadelphia Properties”), and 14 of them have been sold. A fifteenth property 

is scheduled to close once certain regulatory issues with the City of Philadelphia resolve. A

sixteenth property is scheduled to close on May 2, 2024. The Receiver is also finalizing 

Agreements of Sale for two (2) additional properties. The status of the Philadelphia Properties is 

summarized below:

Properties Neighborhood Listing 

Service/Broker

Status Sale Price

1. 300 Market Street, 

Philadelphia PA 

Old City LoopNetTM

Berkshire

Finalizing 

Agreement of 

Sale

2. 1427 Melon Street, 

Philadelphia PA 

Fairmount LoopNetTM

Colliers

Sold $5,550,000

3. 1530 Christian Street, 

Philadelphia PA 

Graduate 

Hospital 

Bright MLS®

Berkshire

Sold $890,000

4. 627-629 E. Girard 

Avenue, 

Philadelphia, PA 

Fishtown LoopNetTM

Berkshire

Finalizing 

Agreement of 

Sale

5. 861 N. 3rd Street, 

Philadelphia PA 

Northern 

Liberties

LoopNetTM

Berkshire

Agreement 

of Sale

($1,468,500) 

Closing on 

May 2, 2024 

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Properties Neighborhood Listing 

Service/Broker

Status Sale Price

6. 1223 N. 25th Street, 

Units A, B, C, 

Philadelphia PA 

Sharswood Bright MLS® 

COMPASS

Sold $650,000

7. 4633 Walnut Street, 

Philadelphia PA 

Walnut Hill Bright MLS®

COMPASS

Sold $700,000

8. 803 S. 4th Street, 

Philadelphia PA 

Queens 

Village

Bright MLS®

Berkshire

Sold $430,000

9. 142 N. 2nd Street 

(owned by 803 S. 4th

St., LLC),

Philadelphia PA 

Old City LoopNet

Berkshire

Agreement 

of Sale

($175,000) 

Closing to be 

determined

10. 915-917 S. 11th

Street, Philadelphia 

PA

Hawthorne Bright MLS® 

Berkshire

Sold $1,750,000

11. 135-137 N. 3rd Street, 

Philadelphia PA 

Old City LoopNetTM

Berkshire

Listed and 

actively 

showing

12. 500 Fairmount 

Avenue, Philadelphia 

PA

Northern 

Liberties

LoopNetTM

Berkshire

Sold $1,450,000

13. 2413 Roma Drive, 

Philadelphia PA 

Sienna Place Bright MLS®

Berkshire

Sold $676,000

14. 118 Olive Street, 

Philadelphia PA 

Northern 

Liberties

Bright MLS®

COMPASS

Sold $661,000

15. 1250 N. 25th Street, 

Units A, B C, 

Philadelphia PA 

Sharswood Bright MLS® 

COMPASS

Sold $650,000

16. 1248 N. 25th Street, 

Unit A (owned by 

1250 North 25th St., 

LLC), Philadelphia 

PA

Sharswood Bright MLS® 

COMPASS

Sold $250,000

17. 1932 Spruce Street, 

Philadelphia PA 

Rittenhouse 

Square 

Bright MLS® 

Berkshire

Sold $1,650,000

Case 9:20-cv-81205-RAR Document 1850 Entered on FLSD Docket 04/30/2024 Page 9 of 15
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Properties Neighborhood Listing 

Service/Broker

Status Sale Price

18. 242 S. 21st Street, 

Philadelphia PA 

Rittenhouse 

Square 

Bright MLS®

Berkshire

Sold $1,025,000

19. 1635 Passyunk Ave, 

Philadelphia PA 

East Passyunk LoopNetTM

Berkshire

Listed and 

actively 

showing

20. 715 Sansom Street, 

Philadelphia PA 

Jewelers’ Row LoopNetTM

Colliers

Sold $2,100,000

21. 20-22 N. 3rd Street 

(4 units), 

Philadelphia PA 

Old City LoopNetTM

Berkshire

Listed and 

actively 

showing 

22. 205 B Arch Street 

(104 N. 2nd Street), 

Philadelphia PA 

Old City LoopNetTM

Berkshire

Listed and 

actively 

showing 

The Receiver continues to work diligently with Berkshire to market these properties aggressively

so as to maximize their value in any sale.

Finally, the vast majority of the Philadelphia Properties are individually held by a 

corresponding single purpose limited liability company registered in Pennsylvania (the “LLC”). 

As the property held by a particular LLC is sold, the Receiver intends to dissolve the corresponding 

LLC under Pennsylvania law as part of his efforts to reduce the number of Receivership Entities 

and, ultimately, to wind down the Receivership Estate.

C. Sale of Personal Property

The Receiver has now sold a substantial amount of personal property within the 

Receivership Estate, including automobiles, jet skis, fine art, and luxury watches. The Receiver is 

still in the process of selling two watercraft and one piece of artwork. The Receiver is also in the 

process of cataloguing and auctioning various items of sports memorabilia from the offices at 20-

22 N. 3rd Street, Philadelphia. The Receiver continues to explore other opportunities to sell or 

dispose of the remaining property within the Receivership Estate. 

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V. Claims and Distribution Process

On December 21, 2022, the Receiver filed a Motion to Establish and Approve: (1) Proof 

of Claim Form; (2) Claims Bar Date and Notice Procedures; and (3) Procedure to Administer and 

Determine Claims (the “Claims Motion”). The Court entered an Order granting the Claims Motion 

on December 23, 2022 (the “Claims Order”). By granting the Receiver’s Claims Motion, the Court 

has approved a procedure for each person or entity who believes he, she, or it may have a claim 

against any Receivership Entity to submit a claim to the Receivership assets.

In January 2023, the Receiver began the process of providing notice (direct and by 

publication) to potential claimants. Pursuant to the requirements of this claim process, all Proof of 

Claim Forms were required to be submitted to the Receiver’s Claims Agent, Epiq Corporate 

Restructuring, LLC (“Epiq”), on or before March 22, 2023, at 11:59 p.m. (prevailing Eastern 

Time).

Beginning on November 21, 2023, the Receiver began to send out Notices of the Receiver’s 

Determination (“NODs”) as to these proofs of claim. In these NODs, the Receiver indicated 

whether the Receiver agreed with the validity of each claim and, based on the records of the 

Receivership Entities, whether the Receiver agreed with the amount each claimant sought to 

recover from the Receivership Estate. The NODs provided each claimant with a 30-day window 

to submit a response to the NODs, indicating whether they had any objections to the Receiver’s 

determinations. Approximately 300 claimants filed objections to the Receiver’s NODs. These 

objections included various grounds, including objections to the Receiver’s basis for rejecting 

particular claims and calculating approved claim amounts, objections to distributions being paid 

to various “Agent Funds, rather than direct distributions to the end investors, and objections from 

several investors who invested through a self-directed IRA at CamaPlan, whose individual claims 

were deemed to be duplicative of the bulk claim CamaPlan submitted on behalf of each of its 

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account holders. 

On April 22, 2024, the Receiver filed a Motion to (i) Approve Proposed Treatment of 

Claims and (ii) for Determination of a Ponzi Scheme (ECF No. 1843). On Aril 23, 2024, the Court 

ordered all claimants with outstanding objections who wished to file a response to the Receiver’s 

determination to do so by May 7, 2024, and ordered the Receiver to file a reply to each response, 

or each category of response if applicable, on or before May 21, 2024 (ECF No. 1845). After the 

Court resolves these objections and rules upon the proposed distribution method, the Receiver will 

seek the Court’s permission to distribute funds to the investors with the assistance of Epiq. 

VI. Criminal Proceedings Report

On May 18, 2023, the United States filed a superseding indictment in the United States District 

Court for the Eastern District of Pennsylvania, charging 63 counts of criminal violations and two 

notices of forfeiture against Complete Business Solutions Group, Inc. d/b/a Par Funding, and 

Defendants Joseph LaForte, Joseph Cole Barletta, James LaForte, and Lisa McElhone. The Court 

unsealed the superseding indictment on May 23, 2023. Of note, 21 of the 63 counts in that indictment 

alleged criminal conduct by Par Funding. Specifically, Par Funding faced charges of conspiracy, wire 

fraud, and securities fraud. As the Receiver represents Par Funding for all legal purposes, counsel for 

the Receiver, Douglas K. Rosenblum, appeared before Magistrate Judge Richard Lloret on June 2, 

2023, and entered a plea of not guilty to all counts against the company. 

In recent months, prosecutors in the United States Attorney’s Office have filed a variety of 

superseding indictments. Various individual defendants related to Par Funding have pled guilty and 

are awaiting sentencing. For ease of reference for this Court, below is a summary of all criminal 

dockets within the United States District Court for the Eastern District of Pennsylvania related to Par 

Funding. The Honorable Mark A. Kearney is presiding over each of the following cases. 

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• Case number 2:22-cr-00279 charges defendant Renato Gioe with two counts of 

extortionate collections of credit and one count of conspiracy to the same offense. Mr. 

Gioe pled guilty and is scheduled for sentencing on June 5, 2024.

• Case number 2:23-cr-00010 charges defendant Perry Abbonizio with one count of 

conspiracy to commit wire fraud. Mr. Abbonizio pled guilty and is scheduled for 

sentencing on June 4, 2024.

• Case number 2:23-cr-00198 charges defendants Joseph Lafore, James Laforte, and 

Joseph Cole Barleta with RICO violations, extortion, obstruction, perjury, retaliation, 

conspiracy, and more. Although this is the original docket number under which the 

government charged Par Funding as a corporate defendant, the government has now 

separated the company in a different indictment, detailed below. All defendants in this 

case have pled not guilty, and trial is scheduled for October 8, 2024. The Court has set 

aside 23 trial days for this case. Of note, attached to this RICO indictment are notices 

of forfeiture. The assets subject to the notices include, but are not limited to, a Cesna 

Citation Sovereign 680 jet bearing tail number N789MJ that is currently in the

possession of the United States, all funds in a Charles Schwab investment account 

ending in number 7878 in the name of Tradewinds South, LLC, and parcels of land 

owned by Defendant Joseph Cole Barletta at 1745 Walnut Green Road and 1751 Walnut 

Green Road in Wilmington, Delaware. The United States has filed notices of lis 

pendens against both of these Wilmington, Delaware properties. 

• Case number 2:24-cr-00065 charges defendants Joseph Laforte, Lisa McElhone, Joseph 

Cole Barleta, Rodney Ermel, and Kenneth Bacon with tax evasion, wire fraud, 

conspiracy, and related offenses. Mr. Ermel and Mr. Bacon provided tax and 

accounting services for Joseph Laforte and Lisa McElhone, individually, as well as for 

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Mr. Laforte and Ms. McElhone’s business entities. Defendant Lisa McElhone has 

pleaded guilty to one count of wire fraud and is scheduled for sentencing on August 12, 

2024. The remaining defendants have pled not guilty and are scheduled for trial 

beginning December 3, 2024. The Court has set aside seven days for trial. 

• Case number 2:24-cr-00066 is the new superseding indictment charging Par Funding 

with the same crimes originally charged on May 18, 2023. By virtue of the superseding 

indictment, Par Funding, as a corporate defendant, is now on its own timeline. This 

case is scheduled for trial on December 20, 2024. Both counsel for Par Funding and 

the United States Attorney’s Office have notified the Court that the parties are exploring 

a non-trial disposition. The government has made clear that it does not wish to interfere 

with the Receivership proceedings before this Court in the Southern District of Florida, 

including the expeditious distribution of funds to investors. To that end, the United 

States and the Receiver are refraining from exchanging voluminous discovery materials 

in an effort to save legal fees and costs, as the overwhelming majority of discovery in 

this criminal case is duplicative of discovery materials obtained from Par Funding in 

this case. The Court has ordered the parties to file status reports at regular intervals to 

apprise the Court of the status of the proceedings before this Court in the Southern 

District of Florida. 

The Receiver will continue to monitor and, as necessary, participate in these criminal proceedings, with 

the goal of minimizing any related expense to the Receivership Estate. 

VII. Conclusion

WHEREFORE, Ryan K. Stumphauzer, as Court-Appointed Receiver, by and through his 

undersigned counsel, respectfully files this Quarterly Status Report dated April 30, 2024. 

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Dated: April 30, 2024 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

PIETRAGALLO GORDON ALFANO 

BOSICK & RASPANTI, LLP

1818 Market Street, Suite 3402 

Philadelphia, PA 19103 

Telephone: (215) 320-6200 

By: /s/ Gaetan J. Alfano 

GAETAN J. ALFANO

Pennsylvania Bar No. 32971 

(Admitted Pro Hac Vice) 

GJA@Pietragallo.com

DOUGLAS K. ROSENBLUM

Pennsylvania Bar No. 90989 

(Admitted Pro Hac Vice) 

DKR@Pietragallo.com

Co-Counsel for Receiver

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on April 30, 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

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