94046184.1 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

CASE NO. 9:20-cv-81205-RAR 

SECURITIES AND EXCHANGE COMMISSION, 

 Plaintiff, 

v. 

COMPLETE BUSINESS SOLUTIONS GROUP, 

INC. D/B/A PAR FUNDING, et al., 

 Defendants. 

__________________________________________/ 

COUNSEL FOR NON-PARTY TOORAK CAPITAL 

PARTNERS, LLC’S MOTION TO WITHDRAW 

Counsel for Non-Party, TOORAK CAPITAL PARTNERS, LLC, a Delaware limited 

liability company (“Toorak”), by and through its undersigned attorneys, hereby moves the Court 

for an order allowing it to withdraw as counsel for TOORAK CAPITAL PARTNERS, LLC, and 

to be removed from the service for all pleadings in this matter, stating as follows: 

1. Toorak is a non-party to this case who retained the undersigned counsel to represent 

in a request to intervene in this action in order to allow Toorak to proceed with two foreclosure 

actions in New York state court: Toorak Capital Partners, LLC v. 145 Stuyvesant Ave Prop LLC 

et al., Index No. 500868/2021 (the “145 Stuyvesant Foreclosure Action”), which named Complete 

Business Solutions Group, Inc. d/b/a Par Funding (“CBSG”) as a junior lienholder defendant and 

Toorak Capital Partners, LLC v. 347A Quincy St Prop LLC, et al., Index No. 501908/2021 (the 

“347A Quincy Foreclosure Action” and collectively, with the 145 Stuyvesant Foreclosure Action, 

the “Foreclosure Actions”), which named Fast Advance Funding Inc. (“Fast Advance”) as a junior 

lienholder defendant. 

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2. On or about September 30, 2022, the Court has ruled on Toorak’s motion [ECF 

1391] and entered an order lifting the litigation stay [ECF 1422] and allow Toorak to proceed with 

its foreclosures. 

3. Toorak, being a non-party, was denied the ability to intervene in this action and 

therefore, to this date, remains a non-party to this action. Accordingly, Toorak’s involvement in 

this action has essentially ended. 

4. Where Toorak’s involvement in this action has ended, the undersigned counsel 

would like to request an order allowing it to withdraw its appearance in this matter and to be 

removed from the service for all pleadings. 

WHEREFORE, the undersigned counsel hereby requests the Court enter an order allowing 

it to withdraw as counsel for Non-Party TOORAK CAPITAL PARTNERS, LLC, and to be 

removed from the service for all pleadings in this matter. 

Dated: March 14, 2024 

Respectfully submitted, 

POLSINELLI P.C. 

315 S. Biscayne Blvd., Suite 400 

Miami, Florida 33131 

Tel.: 305-921-1848 

Fax: 305-921-1801 

/s/ Nardo Dorsin

Nardo Dorsin 

Florida Bar No. 126301 

ndorsin@polsinelli.com 

 Attorneys for Non-Party, 

 Toorak Capital Partners, LLC 

Case 9:20-cv-81205-RAR Document 1830 Entered on FLSD Docket 03/14/2024 Page 2 of 3
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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via 

Notice of Electronic Filing by CM/ECF transmission to all counsel and parties who are registered 

to receive such service in this case on March 14, 2024. 

/s/ Nardo Dorsin

Nardo Dorsin 

Case 9:20-cv-81205-RAR Document 1830 Entered on FLSD Docket 03/14/2024 Page 3 of 3