Steven B. Silverstein v. Jeffrey A. Wolf, Jean Wolf, Kiva LLC, Wheatley Irrevocable Trust, Meshakai Wolf, Rapid Park Holding Corp, Patush, LLC, 183 West Alameda, LLC, Madison Family Enterprises, LLC, Joshua Rey, Evergreen Family Irrevocable Trust, and Foundation for Arts Culture & Education Ltd.

CourtDistrict Court, D. Colorado
DecidedMarch 2, 2026
Docket1:22-cv-01817
StatusUnknown

This text of Steven B. Silverstein v. Jeffrey A. Wolf, Jean Wolf, Kiva LLC, Wheatley Irrevocable Trust, Meshakai Wolf, Rapid Park Holding Corp, Patush, LLC, 183 West Alameda, LLC, Madison Family Enterprises, LLC, Joshua Rey, Evergreen Family Irrevocable Trust, and Foundation for Arts Culture & Education Ltd. (Steven B. Silverstein v. Jeffrey A. Wolf, Jean Wolf, Kiva LLC, Wheatley Irrevocable Trust, Meshakai Wolf, Rapid Park Holding Corp, Patush, LLC, 183 West Alameda, LLC, Madison Family Enterprises, LLC, Joshua Rey, Evergreen Family Irrevocable Trust, and Foundation for Arts Culture & Education Ltd.) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Steven B. Silverstein v. Jeffrey A. Wolf, Jean Wolf, Kiva LLC, Wheatley Irrevocable Trust, Meshakai Wolf, Rapid Park Holding Corp, Patush, LLC, 183 West Alameda, LLC, Madison Family Enterprises, LLC, Joshua Rey, Evergreen Family Irrevocable Trust, and Foundation for Arts Culture & Education Ltd., (D. Colo. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Philip A. Brimmer

Civil Action No. 22-cv-01817-PAB-NRN

STEVEN B. SILVERSTEIN,

Plaintiff,

v.

JEFFREY A. WOLF, JEAN WOLF, KIVA LLC, WHEATLEY IRREVOCABLE TRUST, MESHAKAI WOLF, RAPID PARK HOLDING CORP, PATUSH, LLC, 183 WEST ALAMEDA, LLC, MADISON FAMILY ENTERPRISES, LLC, JOSHUA REY, EVERGREEN FAMILY IRREVOCABLE TRUST, AND FOUNDATION FOR ARTS CULTURE & EDUCATION LTD.,

Defendants.

ORDER

This matter comes before the Court on plaintiff’s Motion for Summary Judgment against Jeffrey Wolf and Madison Family Enterprises, LLC [Docket No. 220]. The Court has jurisdiction pursuant to 28 U.S.C. § 1332. I. BACKGROUND Plaintiff Steven Silverstein registered a judgment against Jeffrey Wolf, Jean Wolf, JTG Ventures, LLC, and ORD Ltd. in the District of Colorado on January 21, 2022. Silverstein v. Wolf, No. 22-rj-00001-PAB-NRN, Docket No. 1. Mr. Silverstein filed the present action on July 22, 2022. Docket No. 1. Mr. Silverstein has named a number of defendants in this action, see Docket No. 125 at 1, but moves for summary judgment only as to Jeffrey Wolf and Madison Family Enterprises, LLC (“Madison”). Although the order refers to arguments made by Mr. Wolf, those arguments were also made on behalf of Madison. On June 21, 2023, Mr. Silverstein filed a motion seeking a preliminary injunction, levy of execution, or receivership prohibiting the transfer of Mr. Wolf’s stock in Rapid Park Holding Corp. (“Rapid Park”). Docket No. 72. On July 28, 2023, the Court denied

that motion, finding that the then-operative complaint failed to state any causes of action upon which the Court could grant injunctive relief. Docket No. 113 at 6-8. Mr. Silverstein filed an amended complaint on August 18, 2023, alleging claims under the Colorado Uniform Fraudulent Transfer Act (“CUFTA”). Docket No. 125 at 12, 17, 20, 23, 25-27. On September 18, 2024, Mr. Silverstein filed the present motion, again seeking an injunction, a levy of execution, or a receivership over Rapid Park stock controlled by Mr. Wolf. Docket No. 181. On August 19, 2025, the Court held an evidentiary hearing on the motion. Docket No. 247. On August 21, 2025, the Court granted the motion for preliminary injunction, enjoining Mr. Wolf and Madison from transferring, selling, encumbering, or otherwise disposing of the shares of Rapid Park

stock that were owned by Mr. Wolf and then transferred to Madison. Docket No. 248 at 23-24. The Court also found that it was necessary to appoint a receiver to take possession of the Rapid Park stock. On March 2, 2026, the Court appointed Randel Lewis as receiver. Docket No. 260 at 2. II. UNDISPUTED FACTS1 Two judgments were entered against Mr. Wolf and in favor of plaintiff on October 11, 2021 and March 3, 2022, respectively (collectively, the “judgment”). Docket No. 220 at 2, ¶ 1.2 The cumulative base amount of the judgment as of March 3, 2022 was $1,703,725.91. Id., ¶ 2. This amount was ordered to earn interest at the rate established by Okla. Stat. tit. 12, § 727.1 from March 4, 2022. Id. Mr. Wolf has not paid any portion of the Judgment. Id., ¶ 3.3 A receivership action resulted in a payment on behalf of JTG Ventures, LLC (Wolf’s co-defendant) in the amount of $600,920.50 on

June 18, 2024. Id. The amount of $1,564,396 remains unpaid. Id. Mr. Wolf started a company called Rapid Park in New York. Id., ¶ 4. He grew the company and eventually allowed members of his family into the ownership. Id. As of the filing of this case, Mr. Wolf was the owner of 25% of the stock in Rapid Park. Id.; see also Docket No. 224 at 4, ¶ 20. On December 29, 2022, Mr. Wolf transferred (the “transfer”) all of his stock in Rapid Park to Madison. Docket No. 220 at 2, ¶ 5; Docket No. 224 at 5, ¶ 23. Mr. Wolf was the owner and manager of Madison. Docket No. 220 at 2, ¶ 5. The stock was worth approximately $35,239,331. Id. Mr. Wolf transferred his stock in Rapid Park to Madison for zero consideration. Id., ¶ 6.4 On December 31,

1 The following facts are undisputed unless otherwise noted. 2 Defendants respond that they “admit that two judgments entered against Jeffrey Wolf on October 11, 2021 and March 2, 2022,” but that they “deny these are final judgments.” Docket No. 224 at 2, ¶ 1. The Court finds this to be nonresponsive and deems this fact admitted. 3 Defendants dispute this fact, stating that, “[o]n June 14, 2024, a payment of $600,920.50 was applied to the judgments in the Oklahoma litigation. . . . Wolf has also attempted to file a bond by having liens filed by Plaintiff released in order to do so.” Docket No. 224 at 2, ¶ 3. The Court finds this to be nonresponsive and deems this fact admitted. 4 Defendants dispute this fact, stating that “Wolf received tax and estate planning benefits and benefits to charitable causes.” Docket No. 224 at 2, ¶ 6. For reasons the 2022, Madison donated 990 membership units (99 percent of the total membership units) to The Verity Charitable Fund (“Verity”), a 501(c)(3) charitable organization, as an unrestricted donation. Docket No. 224 at 5, ¶ 24. Immediately prior to the transfer, the March 4, 2022 judgment was entered establishing the amount Mr. Wolf owed, an April 7, 2022 Writ of Execution was issued seeking to attach Mr. Wolf’s stock in Rapid Park, and the immediate case was filed against Mr. Wolf on July 22, 2022. Docket No. 220 at 3, ¶ 7.5

Upon completing the transfer, Mr. Wolf had transferred substantially all of his assets out of his name. Id., ¶ 8.6 According to Mr. Wolf’s sworn interrogatory response, after transferring his stock worth $35,239,331, Mr. Wolf was left owning nothing more than “cuff links, a tie clip, gold collar stays, some cashmere sweaters, [and] a Swatch watch.” Id. According to Mr. Wolf, he was already impoverished before the transfer, as

Court will discuss in the analysis section of this order, benefits such as those identified by Mr. Wolf are not regarded as consideration for purposes of a CUFTA claim, so Mr. Wolf’s response fails to create a genuine dispute of material fact as to whether he received any consideration in exchange for transferring the stock. The Court deems this fact admitted. 5 Defendants dispute this fact, stating that “Plaintiff did not serve the writ of execution, though it was issued by the Court on April 7, 2022, in the related case of 22- rj-00001-PAB-NRN. . . . Plaintiff did not take action on the Rapid Park stock until he filed a foreign judgment in Delaware Superior Court on February 6, 2023, in Silverstein v. Wolf et al., N23J-00229, seeking to attach the stock.” Docket No. 224 at 2, ¶ 7. The Court finds this to be nonresponsive and deems this fact admitted. 6 Defendants deny this fact, stating that “Plaintiff relies upon interrogatory responses signed on December 9, 2023, which is nearly one year after the subject transfer to Madison Family Enterprises and to The Verity Charitable Fund. Exhibit 7 to the Motion requests information that Wolf has ‘owned personally.’” Docket No. 224 at 2- 3, ¶ 8. In support of his denial, Mr. Wolf points to a statement in his May 27, 2025 declaration. See id. (citing Docket No. 225 at 5, ¶ 29. For the reasons the Court will discuss in the analysis section of this order, it finds that Mr. Wolf’s effort to deny plaintiff’s asserted fact constitutes a “sham fact issue.” The Court therefore deems this fact admitted. an email from Mr. Wolf to Judge Drummond in the underlying Tulsa County District Court case in which Mr. Wolf claims he has no money to pay attorney fees. Id., ¶ 11.7 Mr. Wolf disclosed the transfer in a public court filing in Delaware on May 15, 2023. Docket No. 224 at 7, ¶ 36. III.

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Steven B. Silverstein v. Jeffrey A. Wolf, Jean Wolf, Kiva LLC, Wheatley Irrevocable Trust, Meshakai Wolf, Rapid Park Holding Corp, Patush, LLC, 183 West Alameda, LLC, Madison Family Enterprises, LLC, Joshua Rey, Evergreen Family Irrevocable Trust, and Foundation for Arts Culture & Education Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/steven-b-silverstein-v-jeffrey-a-wolf-jean-wolf-kiva-llc-wheatley-cod-2026.