IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-CIV-81205-RAR

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff, 

v.

COMPLETE BUSINESS SOLUTIONS 

GROUP, INC. d/b/a PAR FUNDING, et al., 

Defendants. 

______________________________________/

RECEIVER RYAN K. STUMPHAUZER’S INTERIM STATUS REPORT OF 

RECEIVERSHIP PER COURT ORDER DATED AUGUST 3, 2020

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

Complete Business Solutions Group, Inc. d/b/a Par Funding (“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; and RE Income Fund 

2 LLC (collectively, the “Receivership Entities”), by and through undersigned counsel, hereby

files this Interim Status Report of Receivership in accordance with this Court’s Order dated August 

3, 2020 [D.E. 74].

1. On Friday, June 24, 2020, the Securities and Exchange Commission (“SEC”) filed 

its Complaint for Injunctive and Other Relief [D.E. 1] against the Receivership Entities, Lisa 

McElhone, Joseph Cole Barleta, a/k/a Joe Cole, Joseph W. Laforte, a/k/a Joe Mack, a/k/a Joe 

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Macki, a/k/a Joe McElhone, Perry S. Abbonizio, Dean J. Vagnozzi, Michael C. Furman, John 

Gissas, and Relief Defendant L.M.E. 2017 Family Trust.

2. On Friday, July 24, 2020, the SEC also filed a Motion for Appointment of Receiver 

[D.E. 4] requesting the Court to appoint Ryan K. Stumphauzer as the Receiver for the Receivership 

Entities.

3. On Monday, July 27, 2020, the Court entered an Order Granting the SEC’s Motion 

for Appointment of Receiver (“Receivership Order”) [D.E. 36].

4. On Friday, July 31, 2020, the Court entered an Order Granting Plaintiff’s Urgent 

Motion to Amend Order Appointing Receiver to Include Litigation Injunction (the “Amended 

Receivership Order”) [D.E. 56].

5. The Amended Receivership Order, which is the operative order setting forth the 

Receiver’s duties and responsibilities, authorizes the Receiver to “engage and employ persons in 

his discretion to assist him in carrying out his duties and responsibilities hereunder, including, but 

not limited to, accountants, lawyers, and paralegals.” Amended Receivership Order at ¶ 3. 

6. Consistent with these authorized duties, the Receiver has retained the undersigned 

law firm of Stumphauzer Foslid Sloman Ross & Kolaya PLLC in Miami, Florida, along with the 

law firm of Pietragallo Gordon Alfano Bosick & Raspanti, LLP in Philadelphia, Pennsylvania, to

serve as his counsel in this matter (“Counsel”). The Receiver and his Counsel have appeared in 

this matter [D.E. 49, 50] and Counsel has filed motions for the pro hac vice admission of the 

Philadelphia-based attorneys that are not admitted in this District [D.E. 51, 52]. Those motions 

for pro hac vice admission have now been granted [D.E. 57, 58].

7. In carrying out his duties as outlined in this Court’s orders, the Receiver, with the 

assistance of his Counsel, has completed the following non-exhaustive list of tasks:

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a. Pursuant to paragraphs 1, 2, and 4 of this Court’s July 27, 2020 Receivership 

Order [D.E. 36] and July 31, 2020 Amended Receivership Order [D.E. 56] 

(collectively, the “Receivership Orders”), the Receiver has secured the offices 

of Par Funding located at 20 N. 3rd Street and 22 N. 3rd Street in Philadelphia, 

Pennsylvania. The Receiver has secured the offices with new locks and has 

reviewed the volume of documents and computer equipment that remain at 

these offices that might require analysis. The Receiver has secured all available 

deliveries by U.S. Postal Service and private carriers to these offices to the best 

of his ability.

b. Pursuant to paragraphs 1, 2, and 4 of the Receivership Orders, the Receiver has 

secured the offices of Par Funding located at 205 Arch Street in Philadelphia, 

Pennsylvania. The Receiver has secured the offices with new locks and has 

reviewed the volume of documents and computer equipment that remain at 

these offices that might require analysis. The Receiver has secured all available 

deliveries by U.S. Postal Service and private carriers to these offices to the best 

of his ability.

c. Pursuant to paragraphs 1, 2, and 4 of the Receivership Orders, the Receiver has 

secured the offices of ABetterFinancialPlan.com LLC (“ABFP”) at 234 Mall 

Boulevard, Suite 270 in King of Prussia, Pennsylvania. The Receiver has 

secured the offices with new locks and has reviewed the volume of documents 

and computer equipment at these offices that might require analysis. The 

Receiver has secured all available deliveries by U.S. Postal Service and private 

carriers to these offices to the best of his ability.

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d. Pursuant to paragraph 1 of the Receivership Orders, the Receiver has located 

and maintains custody of eight checks found at the above Mall Boulevard 

address. These checks collectively represent $522,000 of investor funds that 

have not yet been deposited by ABFP into its investment accounts.

e. Pursuant to paragraphs 1, 2, and 4 of the Receivership Orders, the Receiver has 

secured the offices of United Fidelis Group a/k/a Fidelis Financial Planning 

located at 1615 Forum Place in West Palm Beach, Florida. The Receiver has 

secured the offices with new locks and has reviewed the volume of documents 

and computer equipment that remain at these offices that might require analysis. 

The Receiver has secured all available deliveries by U.S. Postal Service and

private carriers to these offices to the best of his ability. While at this location, 

the Receiver interviewed Defendant Michael Furman, who freely and 

voluntarily provided the Receiver with the key to the office. This occurred prior 

to Mr. Furman retaining counsel, and Mr. Furman freely and voluntarily agreed 

to speak with the Receiver. The Receiver and his Counsel have been in 

communication with Mr. Furman’s counsel about providing Mr. Furman with 

access to and segregating documents and other information that are unrelated 

to the scope of the Receivership Orders.

f. Pursuant to paragraphs 1, 2, and 4 of the Receivership Orders, the Receiver has

inspected the offices of Par Funding located at 2000 PGA Boulevard in Palm 

Beach Gardens, Florida and secured all available deliveries by U.S. Postal 

Service and private carriers to this office to the best of his ability.

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g. Pursuant to paragraphs 1, 2, and 4 of the Receivership Orders, the Receiver has 

secured the offices of Retirement Evolution Group, LLC located at 3990 E. 

State Route 44 in Wildwood, Florida. The Receiver has secured the offices 

with new locks and has reviewed the volume of documents and computer 

equipment that remain at these offices that might require analysis. The Receiver 

has been engaged in ongoing discussions with counsel representing Defendant 

John Gissas and Retirement Evolution Group, LLC to segregate materials and 

funds unrelated to the receivership.

h. Pursuant to paragraphs 4 and 7 of the Receivership Orders, the Receiver 

(through Counsel) communicated with defense counsel regarding the alleged 

necessity to continue certain financial transactions through ACH transfers. 

Defense counsel suggested that Defendant Joseph Cole Barleta, a/k/a/ Joe Cole 

(“Mr. Cole”) participate in an interview regarding the procedures for ACH 

transfers at Par Funding. Mr. Cole refused to participate in such an interview 

when the Receiver declined to agree that such conversation would be subject to 

Federal Rule of Evidence 408 governing settlement discussions.

i. Pursuant to paragraphs 4 and 7 of the Receivership Orders, the Receiver has 

interviewed Ms. Aida Lau, an accountant at Par Funding in Philadelphia, 

Pennsylvania. Ms. Lau explained the mechanics of the ACH processing of 

merchant cash advance (“MCA”) agreements. She told the Receiver that Par 

Funding has approximately $500 million in outstanding MCA agreements that 

are considered “performing.,” i.e., where the merchant is not in default and 

continues to pay the periodic payments required under its MCA agreement with 

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Par Funding. Of these $500 million in performing MCA agreements, 

approximately 10% are the subject of daily negotiations regarding payments, 

including “restructuring” the agreements to advance additional funds to the 

merchantso that the merchant can continue to make the required payments. Ms. 

Lau said that Par Funding has an additional $500 million in MCA agreements 

that are “non-performing,” i.e., the subject of collection efforts and/or other 

litigation throughout the country.

j. Pursuant to paragraphs 4 and 7 of the Receivership Orders, the Receiver has 

interviewed an accountant for ABFP, Mr. Stephen Breslow. Mr. Breslow 

described the various fund accounts at ABFP, the flow of funds from investors 

into the accounts, the flow of funds to and from Par Funding, the flow within 

the various fund accounts, and the operation of agent accounts at ABFP. Mr. 

Breslow committed to providing the Receiver with a list of all accounts 

associated with ABFP, but the Receiver has not yet received that list. 

k. Pursuant to paragraphs 4 and 7 of the Receivership Orders, the Receiver and his 

counsel have participated in dozens of telephone calls and e-mail

correspondence with Counsel for various Defendants.

l. Pursuant to paragraphs 4 and 7 of the Receivership Orders, the Receiver and his 

Counsel have participated in dozens of telephone calls and e-mail 

correspondence with counsel for various MCA clients of Par Funding,

including many whose bank accounts have been frozen or are subject to liens 

by Par Funding.

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m. Pursuant to paragraphs 6 and 7 of the Receivership Orders, the Receiver is in 

the process of filing notices of the receivership in 13 federal districts in which 

property of the Receivership Entities has been identified.

n. Pursuant to paragraph 7 of the Receivership Orders, the Receiver has served 

preservation notices and related orders on all Defendants, various data hosts 

(including Google, Inc., GoDaddy, Ionos, Barracuda Networks, and Hyopsys 

LLC) and the outside accountant for several of the Receivership Entities 

(Friedman LLP).

o. Pursuant to paragraph 3 of the Receivership Orders, the Receiver has researched 

and interviewed financial consultants for possible retention to, among other 

things: (i) review and analyze the financial records of the Receivership Entities; 

(ii) assist the Receiver with financial analysis and forensic accounting services; 

(iii) assess the ongoing operations of the Receivership Entities and provide 

input and guidance regarding the management and oversight of the day-to-day 

operations of the Receivership Entities, including efforts to collect on accounts 

receivable and to maximize recovery for investors.

p. Pursuant to paragraphs 4 and 7 of the Receivership Orders, the Receiver, 

through Counsel, contacted counsel for Defendants McElhone, Laforte, Cole, 

Abbonizio, and Furman on August 3, 2020 to schedule interviews and gain a 

greater understanding of operations and finances with the goal of protecting 

investor funds. To date, none of these Defendants have agreed to be 

interviewed by the Receiver in response to this request.

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8. To date, the Receiver has not taken any action to seize or obtain a freeze of any 

bank accounts or other financial accounts of the Receivership Entities.

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Dated: August 4, 2020 Respectfully Submitted, 

STUMPHAUZER FOSLID SLOMAN

ROSS & KOLAYA, PLLC

Two South Biscayne Blvd., Suite 1600

Miami, FL 33131

Telephone: (305) 614-1400

Facsimile: (305) 614-1425

By: /s/ Timothy A. Kolaya

TIMOTHY A. KOLAYA

Florida Bar No. 056140

tkolaya@sfslaw.com

Co-Counsel for Receiver 

PIETRAGALLO GORDON ALFANO 

BOSICK & RASPANTI, LLP

1818 Market Street, Suite 3402

Philadelphia, PA 19103

Telephone: (215) 320-6200

Facsimile: (215) 981-0082

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 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 4, 2020, 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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