A court has heard there may not be enough frozen assets of the religious group Agape Ministries to cover all the legal claims against it.
A former parishioner who sued fugitive leader Rocco Leo still has not been repaid.
The Adelaide District Court delivered a default judgment against Leo earlier in year, ordering he repay $420,000 to severely-disabled stroke victim Silvana Melchiorre.
She claimed she was brainwashed into donating to the group.
The court heard that money was yet to be repaid and Ms Melchiorre's lawyers were having problems tracing part of it through Leo and his associate's various bank accounts.
It also heard a significant claim against Leo and Agape Ministries by the Australian Tax Office might be increased, which would mean the claim would be larger than the value of the assets currently frozen.
Another civil claim against Leo previously was settled out of court.
Ms Melchiorre's case will return to court in November.
