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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

Case No. 

AARON SILBERMAN, an individual, and )

AMJ MISIL AB LLC, a Florida limited liability )

company )

Plaintiffs, )

)

vs. )

)

PREMIER BEAUTY AND HEALTH LLC, a )

Florida limited liability company, JORGE HANE, )

an individual, and FLORENCIA HANE, an )

individual, jointly and severally, )

)

Defendants. )

__________________________________________/

COMPLAINT

Plaintiffs, Aaron Silberman (“Silberman”) and AMJ Misil AB LLC (“AMJ”), by and 

through their undersigned counsel, bring this action against Defendants, Jorge Hane (“Jorge”),

Florencia Hane (“Florencia”), and Premier Beauty and Health LLC (“Premier”) (Jorge, Florencia, 

and Premier shall hereinafter be collectively referred to as “Defendants”), and state as follows: 

NATURE OF THE ACTION

1. This action arises out of Defendants’ intentional misrepresentations of material 

fact, untrue statements of material fact, and omissions of material fact made for the purpose of 

inducing Plaintiff AMJ’s investment of Four Hundred Fifty Thousand Dollars ($450,000) (the 

“Investment Funds”) in Defendant Premier through Defendants’ offering and sale of unregistered 

securities issued by Defendant Premier (the “Securities”). 

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2. When Defendants offered to sell the Securities to Plaintiffs, they represented to 

Plaintiffs that Defendant Premier: (i) marketed and sold CBD1products containing proprietary

chemical formulas formulated and developed by Defendant Premier (“CBD Blends”); (ii) was the 

sole owner of the intellectual property rights in and to the CBD Blends; (iii) hired Dr. Jeffrey Lin 

- a medical doctor trained at Harvard University and Yale University - to personally create and 

develop the proprietary CBD Blends; (iv) secured exclusive rights to be the first and only company 

to market and sell CBD products on TV home shopping networks; (v) was directed and managed 

by Defendant Jorge, an industry expert with over thirty (30) years of experience in marketing and 

selling consumer products via infomercials and TV home shopping networks, whose status as a

co-founder of the National Infomercial Marketing Association and whose relationship with the 

owner and CEO of ShopHQ2guaranteed that Defendant Premier’s sales would exceed Twelve 

Million Dollars ($12,000,000) in the first year alone; (vi) already had a special agreement, as a 

result of Defendant Jorge’s relationship with the owner and CEO of ShopHQ, pursuant to which 

ShopHQ would deviate from its standard business practice by purchasing rather than consigning

Defendant Premier’s CBD products, thereby assuring Defendant Premier of guaranteed sales and 

revenue; (vii) would receive its first purchase order from ShopHQ no later than September of 2019,

and would be selling its CBD products live on ShopHQ by October of 2019; (viii) would be selling

other products in addition to its CBD products, including a hi-tech reliever and protein bars that

Defendant Jorge had originally planned to sell through a different entity but would instead do so 

through Defendant Premier (the “Additional Products”), thereby raising Defendant Premier’s 

1 CBD is the abbreviation for cannabidiol, one of the chemical compounds found in hemp. 

2 ShopHQ is a digital retailer with a television home shopping network that showcases products 

throughout the United States. ShopHQ’s live television programming reaches over 87 million 

homes in the country via cable affiliates and satellite, and is also streamed live on select mobile 

devices and on Facebook.

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valuation; (ix) had sufficient cash reserves to operate Defendant Premier’s business without 

financial constraints; and (x) would employ Plaintiff Silberman, a member of Plaintiff AMJ, and 

provide him with the opportunity to develop and advance his career.

3. Contrary to Defendants’ representations, Defendant Premier: (i) neither formulated 

nor developed the CDB Blends, and instead purchased the chemical formulas contained in its CBD 

products from a company by the name of Cosmetic Solutions; (ii) did not own any intellectual 

property rights in and to any CBD Blends; (iii) had not secured any exclusive rights to be the first 

and only company to market and sell CBD products on TV home shopping networks; (iv) did not 

have any agreement with ShopHQ under which ShopHQ would purchase rather than consign 

Defendant Premier’s CBD products; (v) did not receive any purchase orders from ShopHQ by

September of 2019, nor did it get any air time on ShopHQ by October of 2019; (vii) never offered 

for sale or sold the Additional Products; (viii) did not have sufficient cash reserves to properly 

operate its business; and (ix) did not have any intention of employing Plaintiff Silberman, and 

solely promised Plaintiff Silberman long-term employment to induce Plaintiff AMJ’s investment.

4. As part of and in furtherance of their fraudulent scheme, Defendants embezzled 

part of the Investment Funds and knowingly and intentionally presented financial documents to 

Plaintiff AMJ and other potential investors of Defendant Premier, which documents 

misrepresented and/or omitted critical and material information about Defendant Premier. 

5. In addition, Defendants failed to disclose information material to Plaintiff AMJ’s 

purchase of the Securities. 

6. Defendant Premier, at the direction and control of Defendants Jorge and Florencia, 

employed Plaintiff Silberman on August 19, 2019. Upon Plaintiffs’ discovery of Defendants’ 

fraudulent scheme, and twelve (12) days after Defendant Premier’s full receipt of the Investment 

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Funds, Defendants swiftly terminated Plaintiff Silberman’s employment with Defendant Premier, 

without cause, and cut off Plaintiff Silberman’s access to his business emails and Plaintiff AMJ’s

access to Defendant Premier’s books and records.

7. Defendant Premier breached its employment agreement with Plaintiff Silberman 

by failing to make wage payments due thereunder.

8. In order to both induce investments such as the one made by Plaintiff AMJ, and 

market and sell Defendant Premier’s products to prospective consumers, Defendants Jorge and 

Florencia – motivated by personal financial gain – consistently make deceitful and intentional 

misrepresentations about Defendant Premier and its CBD products.

JURISDICTION AND VENUE

9. Subject matter jurisdiction exists pursuant to 28 U.S.C. §1331 over Plaintiffs’ cause 

of action founded upon 15 U.S.C. § 77l, 15 U.S.C. § 77o, 15 U.S.C. § 78j(b), and 17 C.F.R. 

§ 240.10b-5 promulgated thereunder, and 15 U.S.C. § 77t. 

10. This Honorable Court has supplemental jurisdiction over Plaintiffs’ pendent state 

claims pursuant to 28 U.S.C §1367 because they are directly related to Plaintiffs’ federal claims 

and form part of the same case or controversy. 

11. Pursuant to Section 27 of the Securities and Exchange Act of 1934 (“Exchange 

Act”), 15 U.S.C. § 78aa, venue for this action properly lies in this Honorable Court because the 

transactions, acts, practices, and course of business giving rise to Plaintiffs’ claims took place in 

Miami-Dade County, Florida, and because at all material times hereto, Defendants conducted 

business, maintained their principal place of business, and resided in Miami-Dade County, Florida.

12. Defendants, directly or indirectly, used the means or instruments of interstate 

commerce or the mails in connection with the acts described in this Complaint.

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13. All conditions precedent to the initiation of the claims set forth in this Complaint 

have been performed, satisfied, excused, or waived. 

14. Plaintiffs have retained the undersigned attorneys to represent them in this action 

and have agreed to pay reasonable attorneys’ fees and costs for such legal services. 

PARTIES

15. Plaintiff Silberman is an individual residing in Miami-Dade County, Florida and is 

sui juris.

16. Plaintiff AMJ is a Florida limited liability company with its principal place of 

business in Miami-Dade County, Florida. 

17. Defendant Jorge is an individual residing in Miami-Dade County, Florida, and is 

sui juris. 

18. Defendant Florencia is an individual residing in Miami-Dade County, Florida, and 

is sui juris.

19. Defendant Premier is a Florida limited liability company with its principal place of 

business in Miami-Dade County, Florida. 

20. Defendant Premier has two (2) members – Defendant Florencia and Plaintiff AMJ. 

21. At all times material hereto, Defendant Jorge exercised operational and financial 

control over Defendant Premier’s day-to-day operations, including control over the offering and 

sale of securities to Plaintiff AMJ, by virtue of his position as manager, senior officer and/or 

authorized representative of Defendant Premier and Defendant Florencia in her capacity as a 

member and manager of Defendant Premier.

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FACTUAL BACKGROUND 

22. Defendant Premier was organized on July 23, 2018, for the alleged purpose of 

operating a business engaged in the sale of consumer products related to beauty and health on TV

via infomercials and home shopping networks. 

23. Initially, Defendant Florencia was the sole member of Defendant Premier. 

However, at all material times hereto, Defendant Jorge, Defendant Florencia’s husband, exercised 

operational and financial control over Defendant Premier’s major decisions and day-to-day 

operations. Plaintiffs eventually discovered that Defendant Florencia was listed as Defendant 

Premier’s sole member because Defendant Jorge was a defendant in at least one (1) bankruptcy 

action in which he, upon information and belief, was accused of making misrepresentations 

regarding his financial condition, and because Defendant Jorge did not want his creditors to be 

able to collect against any of Defendant Premier’s assets or cash reserves. 

24. Upon information and belief, Defendant Jorge is or has been a named defendant in 

other lawsuits in which he is and/or has been accused of fraud.

25. Defendant Jorge’s aforementioned legal issues, including his bankruptcy, were 

never disclosed to Plaintiffs prior to Plaintiff AMJ’s investment in Defendant Premier.

26. Within one (1) year of Defendant Premier’s organization, Defendants began 

soliciting investors, one of which was Plaintiff AMJ. Commencing in June of 2019, Defendants 

solicited numerous meetings with Plaintiffs in an attempt to induce Plaintiff AMJ’s investment. 

Defendant Jorge has a familial relationship with Plaintiff Silberman’s wife, and at all times 

material hereto, knew that Plaintiff Silberman’s wife came from a wealthy family that was willing 

and eager to assist Plaintiff Silberman in the development of his young career. Accordingly, 

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Defendant Jorge promised Plaintiff Silberman long-term employment and career growth with 

Defendant Premier in order to secure the Investment Funds.

27. On or about July 2, 2019, Defendants met with Plaintiffs and offered Plaintiff AMJ

the Securities for the first time (the “First Investor Meeting”). At the First Investor Meeting,

Defendants told Plaintiffs that Defendant Premier would be the first and only company to sell CBD 

products on TV via home shopping networks and that it would be directed and operated by 

Defendant Jorge, who had over thirty (30) years of experience selling consumer products via 

infomercials and on TV home shopping networks. Defendants told Plaintiffs that Defendant 

Premier was seeking to offer long-term employment to a young professional with access to capital, 

like Plaintiff Silberman, who was willing to work the business with and learn from Defendant 

Jorge. Defendant Jorge told Plaintiffs that Defendant Premier had a valuation of Three Million 

Dollars ($3,000,000) (the “Initial Valuation”), and that other investors had already offered Three 

Hundred Thousand Dollars ($300,000) in exchange for ten percent (10%) of Defendant Premier’s 

equity interest.

28. On or about July 8, 2019, Plaintiffs held a second meeting with Defendants (the 

“Second Investor Meeting”). At the Second Investor Meeting, Defendants further discussed the 

investment opportunity being presented to Plaintiff AMJ, but in this instance, also extended an 

offer of employment to Plaintiff Silberman. In response, Plaintiff Silberman asked Defendants 

whether the employment offer was conditioned on Plaintiff AMJ’s potential investment in 

Defendant Premier, which prompted Defendant Florencia to retract the offer of employment and 

to state, instead, that if Plaintiff AMJ invested in Defendant Premier, Plaintiff Silberman could 

work for Defendant Premier for a period of three (3) months without compensation to determine 

whether he was a good fit for the business. Defendant Florencia further stated that if Defendant 

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Premier determined Plaintiff Silberman to be a good fit at the conclusion of the three (3) month 

period, Defendant Premier would then offer a paid position to Plaintiff Silberman. Plaintiffs

rejected Defendant Florencia’s offer outright.

29. On July 30, 2019, Defendant Premier filed an application with the United States 

Patent and Trademark Office to register Green MD Revolution (“Green MD”), a trademark

designated to market and sell its CBD products.

30. In August of 2019, Defendants informed Plaintiffs that Defendants were launching 

the CBD product line under Green MD and requested a meeting with Plaintiffs to further discuss

Plaintiff AMJ’s potential investment in Defendant Premier. 

31. On or about August 13, 2019, Plaintiffs again met with Defendants (the “Third 

Investor Meeting”). At the Third Investor Meeting, Defendant Jorge told Plaintiffs about his 

relationship with the CEO and founder of ShopHQ. Defendant Jorge represented that he could 

guarantee Defendant Premier’s success because of his experience and lofty status in the industry 

and his history of selling successful products on TV networks such as ShopHQ, whose customary 

business practice is to work with vendors on a consignment basis. However, Defendant Jorge 

represented that he had a special agreement with ShopHQ pursuant to which ShopHQ would 

guarantee payment of purchase orders (“PO”) to Defendant Premier instead of working with 

Defendant Premier on a consignment basis. Specifically, Defendant Jorge represented that he had 

this special agreement with ShopHQ for a product he sold on ShopHQ through a company doing 

business as “Because it Works” (“BIW”), and that he had incorporated Defendant Premier’s 

products onto said agreement. Defendant Jorge emphasized to Plaintiffs that his personal 

relationship with the owner and CEO of ShopHQ ensured that Defendant Premier would have no 

problem getting its sales guaranteed by ShopHQ. In fact, he stated that he had already spoken to 

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the CEO and the owner of ShopHQ, and they agreed that the first PO for Defendant Premier’s 

products would be placed by the end of September of 2019, and Defendant Premier’s first 

appearance on the ShopHQ network would take place by October of 2019. 

32. Furthermore, Defendants represented to Plaintiffs that Defendant Premier did not 

need investors because it had enough capital and its success was all but certain. Notwithstanding, 

Defendants indicated to Plaintiffs that because of Defendant Jorge’s familial ties with Plaintiff 

Silberman’s wife, Defendant Premier would provide long term employment to Plaintiff Silberman 

if Plaintiff AMJ invested in Defendant Premier, and as a result, not only would Plaintiff AMJ be 

buying into a “once-in-a-lifetime” business opportunity, but Plaintiff Silberman would also be 

getting a great education and work experience under Defendant Jorge’s tutelage. Thereafter, while 

assuring them that their investment in Defendant Premier would be an enormous success, 

Defendants presented financial projections to Plaintiffs reflecting between Twelve Million Dollars 

($12,000,000) and Thirty Million Dollars ($30,000,000) in sales by Defendant Premier within one 

(1) year of Plaintiff AMJ’s investment. Defendant Jorge further represented that BIW was getting 

five (5) to six (6) POs totaling approximately Two Hundred Fifty Thousand Dollars ($250,000) 

per year from ShopHQ, and explained that BIW was a company that only sold one product, insoles, 

which product was far more difficult to sell than Defendant Premier’s CBD products. Defendant 

Jorge represented to Plaintiffs that if BIW was receiving large POs while only offering one (1) 

product that was difficult to sell, Defendant Premier would sell many times that amount, 

considering that Defendant Premier would be offering at least ten (10) products for sale in

ShopHQ’s highest grossing category, beauty and health. As a comparable, Defendant Jorge told 

Plaintiffs that the best skin care brands on ShopHQ, like Consult Health and Serious Skincare, 

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were each selling between Thirty Million Dollars ($30,000,000) and One Hundred Million Dollars 

($100,000,000) per year.

33. Defendants proceeded to present Plaintiffs with a list of the products allegedly 

containing the CBD Blends that would be branded and sold under the Green MD trademark (the 

“Green MD Products”), and in an effort to finally secure Plaintiff AMJ’s investment in Defendant 

Premier, Defendants represented that:

a. The CBD Blends contained in the Green MD Products were proprietary, and

formulated and developed by Dr. Lin for Defendant Premier;

b. Defendant Premier had spent over Twenty-Five Thousand Dollars ($25,000) 

developing the CBD Blends;

c. Defendant Premier was the sole owner of the intellectual property rights in and to 

the CBD Blends contained in the Green MD Products;

d. Defendant Jorge, acting on behalf of Defendant Premier, had secured exclusive 

rights for Defendant Premier to be the first and only company to market and sell consumer CBD

products on TV shopping networks;

e. Defendant Jorge had over thirty (30) years of experience in the industry of 

marketing and selling consumer products on TV via infomercials and home shopping networks, 

that he co-founded the National Infomercial Marketing Association, and in addition to his 

knowledge and expertise, he knew all the relevant people in the industry to successfully market 

and sell the Green MD Products; 

f. Defendant Premier could easily be sold to ShopHQ by the end of Defendant 

Premier’s third (3rd) year in business. Defendant Jorge told Plaintiffs that he could easily sell 

Defendant Premier to ShopHQ because of his great relationship with its owner and CEO and said 

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the home shopping networks tend to purchase successful brands like Green MD. In addition, 

Defendant Jorge told Plaintiffs that companies like Defendant Premier generate great interest from 

the public, and that he would consider taking Defendant Premier public after the third (3rd) year. 

34. At the conclusion of the Third Investor Meeting, Defendants offered Plaintiff AMJ 

Securities representing ten percent (10%) of Defendant Premier’s equity interest in exchange for 

Four Hundred Thousand Dollars ($400,000) (the “First Offer for Investment”), and an employment 

position for Plaintiff Silberman with a monthly salary of Ten Thousand Dollars ($10,000) (the 

“Employment Offer”).

35. To justify the discrepancy between the Initial Valuation and Defendant Premier’s

valuation under Defendants’ First Offer for Investment, Defendant Jorge and Defendant Florencia

represented that they had the Additional Products which they had previously planned to sell 

through other companies in which Defendant Premier’s investors did not own any equity, but 

would instead do so through Defendant Premier, thereby increasing Defendant Premier’s 

valuation. Defendants Jorge and Florencia told Plaintiffs that these Additional Products were 

already developed and would be introduced quickly and very successfully. 

36. Defendants Jorge and Florencia failed to disclose the fact that they had already tried 

to market and to sell the Additional Products, had failed, and were simply looking to try again, 

using a different brand and Plaintiff AMJ’s Investment Funds to do so. 

37. On or about August 14, 2019, relying on Defendants’ representations, Plaintiff 

AMJ accepted Defendants’ First Offer for Investment, and Plaintiff Silberman accepted the 

Employment Offer (the “Employment Agreement”). Pursuant to the First Offer for Investment, 

Plaintiff AMJ agreed to invest Four Hundred Thousand Dollars ($400,000) in Defendant Premier 

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in exchange for ten percent (10%) of Defendant Premier’s equity interest (the “First Investment 

Agreement”).

38. On or about August 19, 2019, Plaintiff Silberman began his employment with 

Defendant Premier. By September 15, 2019, Plaintiff AMJ had deposited the full amount owed 

under the First Investment Agreement in Defendant Premier’s bank account. Upon receipt thereof, 

Defendants Jorge and Florencia withdrew an amount exceeding One Hundred Twenty-Five

Thousand Dollars ($125,000), a portion of which they falsely alleged was used to reimburse them 

for the costs of formulating the allegedly proprietary CBD Blends. The remaining balance, by their 

own admission, was taken and used by Defendants Jorge and Florencia for their own personal use.

39. Throughout his employment with Defendant Premier, whenever Plaintiff 

Silberman attempted to contribute to Defendant Premier’s decision-making, Defendant Jorge 

routinely and dismissively called him a “rookie” who “did not know what he was doing.” Indeed, 

as part of their fraudulent scheme, Defendants targeted young and unsophisticated investors, 

hoping to embezzle their funds through false promises of employment and investment returns 

which Defendants supported with documents and/or verbal representations containing fabricated 

and/or manipulated information, and which documents and/or verbal representations otherwise 

failed to disclose material information.

40. For example, Defendants deceitfully and intentionally used Plaintiff Silberman’s

naivete against him and abused his trust by requiring Plaintiff Silberman to sign the lease for the 

office space Defendant Premier used, and all of the accounts related to said lease (such as the ADT 

alarm system account and FPL) (collectively, the “Premier Accounts”), in his personal capacity. 

Although Defendants assured Plaintiff Silberman that Defendant Premier would assume all 

responsibility for the Premier Accounts, they failed to do so following their termination of Plaintiff 

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Silberman’s employment, leaving Plaintiff Silberman to fend for himself as he was personally 

liable for the Premier Accounts. 

41. In addition, after Plaintiff AMJ paid for the Securities purchased under the First 

Investment Agreement, Plaintiff Silberman discovered the following through his employment with 

Defendant Premier: 

a. the CBD Blends contained in Green MD Products were not proprietary;

b. the Green MD Products contained chemical formulas purchased by Defendants 

from a company by the name of Cosmetic Solutions;

c. Dr. Lin did not personally formulate or develop the CBD Blends. Instead, he solely 

acts as an actor and advertising agent for Defendant Premier. Dr. Lin, at Defendants’ instruction, 

knowingly lies to an audience of millions by stating that he personally developed the CBD Blends 

using unique ingredients handpicked by him. Defendant Florencia, who also appears live on air to 

market the Green MD Products, routinely deceives the public about the Green MD Products and 

their efficacy by, among other things, lying about her age and Dr. Lin’s involvement in the 

development of the Green MD Products. Defendants and Dr. Lin use Dr. Lin’s academic 

credentials, which include degrees from Harvard and Yale, to attempt to give the Green MD 

Products credibility and to perpetrate their fraud. When Plaintiff Silberman confronted Defendants 

about their fraud, Defendant Jorge dismissively responded by saying that “there was nothing 

wrong with that because it was a marketing tactic, one that is used by all the brands selling in home 

shopping networks and infomercials.”

d. Defendants actively encourage Dr. Lin to appear on TV networks and advertise 

undeniably false facts about Green MD Products, and Defendant Jorge and Defendant Florencia 

provide close guidance and tips to Dr. Lin regarding the manner in which the misrepresentations 

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of fact about Green MD Products should be made to the public in order to maximize their 

effectiveness;

e. Defendants had not spent Twenty-Five Thousand Dollars ($25,000) formulating or 

developing the CBD Blends. Instead, Defendants used Fifteen Thousand Dollars ($15,000) to 

purchase the right to manufacture products using the formulas owned by Cosmetic Solutions, and 

Ten Thousand Dollars ($10,000) to pay for their credit card debt;

f. Defendant Jorge did not have an agreement with the CEO and owner of ShopHQ 

pursuant to which ShopHQ would guarantee its purchase of Green MD Products, thereby assuring 

Defendant Premier’s sales and revenue. 

g. Defendants had neither secured exclusive rights for Green MD Products to be the 

only CBD Products sold on TV via home shopping networks nor the right to be the first company 

to do so; 

42. Contrary to Defendants’ representations, Defendant Premier did not receive a PO 

from ShopHQ by the end of September 2019, nor did it make an appearance on their network by 

October of 2019. The foregoing resulted in Defendant Premier’s failure to generate sufficient 

revenue to adequately carry on its business. Accordingly, on or about February 1, 2020,

Defendants requested that Plaintiff AMJ make an additional investment of Fifty Thousand Dollars 

($50,000) and presented Plaintiffs with documents purporting to be Defendant Premier’s financial 

statements (“Premier’s Fraudulent Financial Statements”) in support of their request. In addition, 

Defendant Jorge represented that ShopHQ would provide him with the highlights of Defendant 

Premier’s presentations on ShopHQ, which Defendant Jorge would then utilize to create 

infomercials that would be broadcast globally using Defendant Jorge’s special connections in the 

industry. To date, Defendant Premier has not aired a single infomercial.

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43. Plaintiff AMJ, concerned that Defendants’ were using Defendant Premier as an 

alter ego, offered to make the additional capital contributions on a pro-rata basis with Defendant 

Florencia, but Defendant Jorge informed Plaintiffs that Defendants Jorge and Florencia did not 

have any more money to invest in the business. Plaintiffs reiterated their concerns regarding 

Defendants Jorge and Florencia’s management of Defendant Premier’s operations, and told 

Defendants that Plaintiff AMJ would only consider contributing additional capital in exchange for 

more equity, more voting power, and an increased say in Defendant Premier’s management and 

operation. Defendants refused, and Defendant Jorge told Plaintiff AMJ that Defendant Premier 

would seek to raise capital elsewhere through other potential investors.

44. While Defendants targeted other potential investors, Plaintiff AMJ and Defendants 

had ongoing discussions and arguments about Defendant Premier’s management and its 

operational needs. During one such discussion, Plaintiff AMJ, concerned about Defendant 

Premier’s improper management, requested Defendant Premier’s credit card statements and bank 

statements. Defendant Jorge indicated to Plaintiff AMJ that Defendants would never misuse 

investor funds and expressed dismay at Plaintiffs AMJ’s mere suggestion of same. Defendant 

Jorge denied that Defendant Premier had engaged in any wrongdoing and authorized Defendant 

Premier to provide said statements.

45. Plaintiff Silberman, relying on Defendant Jorge’s aforementioned authorization, 

obtained Defendant Premier’s credit card statements and bank statements and shared them with 

Plaintiff AMJ, including its members, managers, advisers, and agents. When Defendant Jorge 

realized that Plaintiff Silberman had provided Defendant Premier’s credit card statements and bank 

statements to Plaintiff AMJ, he berated Plaintiff Silberman and told him that Defendant Jorge 

“could have explained the statements better.” Defendant Premier’s credit card statements and bank 

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statements unequivocally showed that Defendants Jorge and Florencia had misused the Investment 

Funds for personal reasons. When confronted about their misuse of the Investment Funds, 

Defendant Florencia told Plaintiffs that she “sometimes gets confused over her credit cards given 

that they all are blue.”

46. In fear of losing its initial investment, and not having yet discovered that Defendant 

Premier’s Fraudulent Financial Statements had been fabricated, Plaintiff AMJ decided to 

contribute the additional Fifty Thousand Dollars ($50,000) to Defendant Premier in exchange for 

additional equity and only under certain conditions, including requiring Defendants Jorge and 

Florencia to reimburse Defendant Premier for all the funds misused by them for personal reasons.

47. Relying on Defendant Premier’s Fraudulent Financial Statements and other 

representations about Defendant Premier’s management and operations moving forward, Plaintiff 

AMJ agreed to invest an additional Fifty Thousand Dollars ($50,000) in Defendant Premier in 

exchange for an additional ten percent (10%) of Defendant Premier’s equity interest (the “Second 

Investment Agreement”) (the First Investment Agreement, Second Investment Agreement, and the 

Employment Agreement shall hereinafter be collectively referred to as the “Investment Scheme”).

48. It was only after Defendants terminated Plaintiff Silberman’s employment that he 

discovered that critical and material information in Defendant Premier’s Fraudulent Financial 

Statements had been fabricated, misrepresented, and/or omitted by Defendants, and that this 

practice of manipulating financial documents was used by Defendants to induce Plaintiff AMJ’s 

investment and to attempt to defraud other potential investors.

49. In an effort to disguise the discrepancy between the price of the Securities 

purchased by Plaintiff AMJ pursuant to the First Investment Agreement and those purchased 

pursuant to the Second Investment Agreement, Defendants asked Plaintiff AMJ to memorialize 

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the First Investment Agreement and the Second Investment Agreement (collectively, the 

“Investment Agreement”) as one agreement through the execution of a certain Membership 

Interest Purchase Agreement (“MIPA”) dated February 14, 2020. 

50. On February 26, 2020, twelve (12) days after Plaintiff AMJ executed the MIPA 

presented by Defendants, Defendants terminated Plaintiff Silberman’s employment, blocked 

Plaintiff Silberman’s access to his business emails, cut off Plaintiff AMJ’s access to Defendant 

Premier’s books and records, and failed to pay Plaintiff Silberman the wages owed to him under 

the Employment Agreement for the month of February of 2020. 

51. The Securities sold by Defendants to Plaintiff AMJ pursuant to the Investment 

Agreement were never registered by Defendants pursuant to Section 5 of the Securities Act of 1933 

(the “Securities Act”).

52. Plaintiffs have repeatedly demanded that Defendants return the Investment Funds, 

pay Plaintiff Silberman the wages owed to him, and provide Plaintiff AMJ with access to Defendant 

Premier’s books and records, to no avail. Moreover, as of the filing of this Complaint, Defendants 

have refused to sanitize their fraud as against Plaintiffs by making Plaintiffs whole.

COUNT I

Violation of Section 12(a)(1) of the Securities Act

(Against all Defendants)

53. Plaintiff AMJ re-alleges and incorporates paragraphs one (1) through fifty-two (52)

above as if fully set forth herein.

54. This Count I is asserted against Defendant Premier, Defendant Jorge, and 

Defendant Florencia for violations of Section 12(a)(1) of the Securities Act. 15 U.S.C. § 77l(a)(1).

55. The Investment Agreement constitutes an “investment contract” and is therefore a 

security as set forth in 15 U.S.C. § 77b(a)(1), because:

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a. Plaintiff AMJ invested Four Hundred Fifty Thousand Dollars ($450,000) in 

Defendant Premier under the Investment Agreement;

b. Plaintiff AMJ’s investment under the Investment Agreement was an 

investment in a common enterprise; 

c. Plaintiff AMJ made the investment in reliance on Defendant Jorge’s

experience, knowledge, and expertise in the consumer product industry, especially in the sale of 

consumer products on TV via infomercials and home shopping networks;

d. Plaintiff AMJ entered into the Investment Agreement with an expectation 

of profits; and

e. Plaintiff AMJ expected its profits to be derived solely from the efforts of 

Defendants.

56. Defendants offered and sold unregistered securities to Plaintiff AMJ, and in so 

doing, made use of instruments of transportation or communication in interstate commerce or the 

mails in violation of Section 5 of the Securities Act. 15 U.S.C. § 77(e). 

57. Each Defendant is a “person” as defined by 15 U.S.C. § 77b(a)(2) of the Securities 

Act.

58. Each Defendant is the “seller” of the Securities purchased by Plaintiff AMJ within 

the meaning of the Securities Act because each Defendant solicited the purchase of the Securities 

by Plaintiff AMJ, motivated in large part by a desire to serve their own financial interests. 

59. Defendants’ violation entitles Plaintiff AMJ to rescind the Investment Agreement

and recover the Investment Funds, in addition to other relief in connection with its purchase of 

unregistered securities from Defendant Premier.

60. Plaintiff AMJ hereby elects to rescind the Investment Agreement.

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WHEREFORE, Plaintiff AMJ respectfully requests the entry of a final judgment in its

favor and against Defendants, jointly and severally, rescinding the Investment Agreement, with 

pre-judgment interest and post-judgment interest at the maximum rate allowable by law, and such 

further relief as this Honorable Court deems just, equitable, and proper.

COUNT II

Violation of Section 15 of the Securities Act

(Against Defendant Jorge and Defendant Florencia)

61. Plaintiff AMJ re-alleges and incorporates paragraphs one (1) through fifty-two (52)

above as if fully set forth herein.

62. This Count II is brought against Defendant Florencia and Defendant Jorge pursuant 

to Section 15 of the Securities Act. 15 U.S.C. §77o.

63. At all times material hereto, Defendant Florencia and Defendant Jorge were each

“controlling persons” of Defendant Premier within the meaning of Section 15 of the Securities Act 

by virtue of their ownership of Defendant Premier, beneficial or otherwise, and/or their positions 

as managers, senior officers, and/or authorized representatives of Defendant Premier.

64. Defendant Florencia and Defendant Jorge were culpable participants in the 

violation of Sections 12(a)(1) of the Securities Act by Defendant Premier as alleged in Count I of 

this Complaint based on their agency and/or ownership interest, beneficial or otherwise, in 

Defendant Premier, and having otherwise participated in the process which directly resulted in 

Defendant Premier’s sale of unregistered securities to Plaintiff AMJ.

WHEREFORE, Plaintiff AMJ respectfully requests the entry of a final judgment in its

favor and against Defendants Jorge and Florencia, jointly and severally with Defendant Premier, 

rescinding the Investment Agreement, with pre-judgment interest and post-judgment interest at the 

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maximum rate allowable by law, and such further relief as this Honorable Court deems just, 

equitable, and proper.

COUNT III

Violation of the Securities and Exchange Act Section 10(b)

(Against all Defendants)

65. Plaintiff AMJ re-alleges and incorporates paragraphs one (1) through fifty-two (52)

above as if fully set forth herein.

66. This Count III is brought against Defendant Premier, Defendant Jorge, and 

Defendant Florencia pursuant to 17 C.F.R. §240.10b-5, a regulation promulgated under 15 U.S.C. 

78j(b), which provides, in pertinent part:

It shall be unlawful for any person, directly or indirectly, by the use 

of any means or instrumentality of interstate commerce, or of the 

mails or of any facility of any national securities exchange,

(a) To employ any device, scheme, or artifice to defraud,

(b) To make any untrue statement of a material fact or to omit to 

state a material fact necessary in order to make the statements 

made, in the light of the circumstances under which they were 

made, not misleading, or

(c) To engage in any act, practice, or course of business which 

operates or would operate as a fraud or deceit upon any person, in 

connection with the purchase or sale of any security.

67. At all times material hereto, Defendants employed a pattern of deceit aimed at 

defrauding investors and consumers alike. The Investment Scheme operated as a fraud upon 

Plaintiff AMJ in connection with the purchase and sale of the Securities. 

68. To obtain Plaintiff AMJ’s Investment Funds, Defendants made material 

misrepresentations, untrue statements of material fact, and omitted statements of material fact 

necessary in order to make the statements made, in light of the circumstances under which they 

were made, not misleading, as set forth in this Complaint.

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69. The material misrepresentations, omissions, and untrue statements of material fact 

were made in connection with the Securities sold by Defendants to Plaintiff AMJ. 

70. As is evidenced by their manipulation and fabrication of Defendant Premier’s 

Fraudulent Financial Statements, Defendants’ conduct was intentional and willful, the purpose of 

which was to deceive, manipulate, and defraud Plaintiff AMJ.

71. Plaintiff AMJ reasonably and justifiably relied upon Defendants’ material 

misrepresentations, untrue statements of material fact, and omissions of material fact when 

entering into the Investment Agreement and making the investment in Defendant Premier. But for 

Defendants’ material misrepresentations, untrue statements of material fact, and omissions of 

material fact, Plaintiff AMJ would not have entered into the Investment Agreement or participated 

in Defendants’ Investment Scheme. 

72. Plaintiff AMJ has suffered damages as a direct and proximate result of Defendants’ 

material misrepresentations, untrue statements of material fact, and omissions of material fact. 

The Investment Scheme itself shows that disclosure of part of the information Defendants’ 

misrepresented and omitted caused a significant decrease in the value of the Securities purchased 

by Plaintiff AMJ once said misrepresentations and omissions were discovered. 

73. Defendants used the means or instrumentalities of interstate commerce to make the 

material misrepresentations, untrue statements of material fact, and omissions of material fact upon 

which Plaintiff AMJ relied when determining whether to purchase the Securities sold by 

Defendants.

74. Despite Plaintiffs AMJ’s demands for a return of its Investment Funds, Defendants

have unlawfully retained same.

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75. Defendants’ violation entitles Plaintiff AMJ to rescind the Investment Agreement 

and recover the Investment Funds, in addition to other relief in connection with its purchase of 

unregistered securities from Defendants. 

76. Plaintiff AMJ hereby elects to rescind the Investment Agreement. 

WHEREFORE, Plaintiff AMJ respectfully requests the entry of a final judgment in its 

favor and against Defendants, jointly and severally, rescinding the Investment Agreement, with 

pre-judgment interest and post-judgment interest at the maximum rate allowable by law, and such 

further relief as this Honorable Court deems just, equitable, and proper.

COUNT IV

Violation of Securities and Exchange Act Section 20(a), 15 U.S.C § 78t

(Against Defendant Jorge and Defendant Florencia)

77. Plaintiff AMJ re-alleges and incorporates paragraphs one (1) through fifty-two (52)

above as if fully set forth herein.

78. This Count IV is brought against Defendant Jorge and Defendant Florencia

pursuant to Section 20(a) of the Exchange Act, 15 U.S.C. § 78t.

79. Section 20(a) of the Exchange Act reads, in pertinent part: 

Joint and several liability; good faith defense 

Every person who, directly or indirectly, controls any person liable 

under any provision of this chapter or of any rule or regulation 

thereunder shall also be liable jointly and severally with and to the 

same extent as such controlled person to any person to whom such 

controlled person is liable (including to the Commission in any 

action brought under paragraph (1) or (3) of section 78u(d) of this 

title), unless the controlling person acted in good faith and did not 

directly or indirectly induce the act or acts constituting the violation 

or cause of action. 15 U.S.C.A. § 78t.

80. Defendant Florencia participated in the operation and management of Defendant 

Premier, and conducted and participated, directly and indirectly, in the conduct of Defendant 

Premier’s business affairs. At all times material hereto, Defendant Florencia was aware of the 

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material misrepresentations, untrue statements of material fact, and omissions of material fact

made by Defendants in furtherance of their fraudulent sale of securities to Plaintiff AMJ.

81. At all times material hereto, Defendant Florencia was a “controlling person” of 

Defendant Premier within the meaning of Section 20(a) of the Exchange Act by virtue of her

ownership interest in Defendant Premier, beneficial or otherwise, and/or her positions as a 

manager, senior officer and/or authorized representative of Defendant Premier.

82. Defendant Florencia is a culpable participant in Defendant Premier’s violation of 

15 U.S.C. § 78j(b) of the Exchange Act as alleged in Count III of this Complaint based on her

ownership interest, beneficial or otherwise, in Defendant Premier and having otherwise 

participated in the process which directly resulted in Defendant Premier’s fraudulent sale of 

securities to Plaintiff AMJ.

83. Defendant Jorge participated in the operation and management of Defendant 

Premier, and conducted and participated, directly and indirectly, in the conduct of Defendant 

Premier’s business affairs. At all times material hereto, Defendant Jorge was aware of the material 

misrepresentations, untrue statements of material fact, and omissions of material fact made to 

Plaintiff AMJ in furtherance of Defendant Premier’s fraudulent sale of securities to Plaintiff AMJ.

84. At all times material hereto, Defendant Jorge was a “controlling person” of 

Defendant Premier within the meaning of Section 20(a) of the Exchange Act by virtue of his 

exercise of operational and financial control over Defendant Premier’s day-to-day operations, 

and/or his positions as manager, senior officer, and/or authorized representative of Defendant 

Premier.

85. Defendant Jorge was a culpable participant in Defendant Premier’s violation of 15 

U.S.C. § 78j(b) of the Exchange Act as alleged in Count III of this Complaint based on his exercise

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of operational and financial control over Defendant Premier’s day-to-day operations, and/or his 

positions as manager, senior officer, and/or authorized representative of Defendant Premier, and 

having otherwise participated in the process which directly resulted in Defendant Premier’s

fraudulent sale of securities to Plaintiff AMJ.

86. By reason of their conduct and position, Defendant Jorge and Defendant Florencia 

are liable pursuant to Section 20(a) of the Exchange Act for the violations committed by Defendant 

Premier.

WHEREFORE, Plaintiff AMJ respectfully requests the entry of a final judgment in its 

favor and against Defendants Jorge and Florencia, jointly and severally with Defendant Premier, 

rescinding the Investment Agreement, with pre-judgment interest and post-judgment interest at the 

maximum rate allowable by law, and such further relief as this Honorable Court deems just, 

equitable, and proper.

COUNT V

Violation of Florida Securities and Investor Protection Act, Section 517.301, Florida 

Statutes

(Against all Defendants)

87. Plaintiff AMJ re-alleges and incorporates paragraphs one (1) through fifty-two (52)

above as if fully set forth herein.

88. This Count V is brought against Defendant Premier, Defendant Jorge, and 

Defendant Florencia pursuant to Section 517.301, Florida Statutes (2019). 

89. Section 517.301(1)(a), Florida Statues, provides, in pertinent part:

It is unlawful and a violation of the provisions of this chapter for a 

person:

(a) In connection with the rendering of any investment advice 

or in connection with the offer, sale, or purchase of any investment 

or security, including any security exempted under the provisions of 

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s. 517.051 and including any security sold in a transaction exempted 

under the provisions of s. 517.061, directly or indirectly:

1. To employ any device, scheme, or artifice to defraud;

2. To obtain money or property by means of any untrue statement of 

a material fact or any omission to state a material fact necessary in 

order to make the statements made, in the light of the circumstances 

under which they were made, not misleading; or

3. To engage in any transaction, practice, or course of business 

which operates or would operate as a fraud or deceit upon a person.

90. At all times material hereto, Defendants employed a pattern of deceit aimed at 

defrauding investors and consumers alike. The Investment Agreement operated as a fraud upon 

Plaintiff AMJ in connection with the purchase and sale of securities. 

91. To obtain Plaintiff AMJ’s Investment Funds, Defendants made material 

misrepresentations of fact, made untrue statements of material fact, and omitted statements of 

material fact necessary in order to make the statements made, in light of the circumstances under 

which they were made, not misleading.

92. Plaintiff AMJ justifiably and reasonably relied upon Defendants’ material 

misrepresentations, untrue statements of material fact, and omissions of material fact when 

entering into the Investment Agreement and making the investment in Defendant Premier. But for 

Defendants’ material misrepresentations, untrue statements of material fact, and omissions of 

material fact, Plaintiff AMJ would not have entered into the Investment Agreement or participated 

in Defendants’ Investment Scheme. 

93. The material misrepresentations, omissions, and untrue statements of material fact 

were made in connection with the Securities sold by Defendants to Plaintiff AMJ. 

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94. At all times material hereto, Defendants knew that their untrue statements were 

false and intentionally made them for the purpose of inducing Plaintiff AMJ’s reliance thereon. 

95. As is evident by their manipulation and fabrication of Defendant Premier’s 

Fraudulent Financial Statements presented to investors, Defendants’ conduct was intentional and 

willful, the purpose of which was to deceive, manipulate, and defraud Plaintiff AMJ.

96. Plaintiff AMJ has suffered damages as a direct and proximate result of Defendants’ 

material misrepresentations, untrue statements of material fact, and omissions of material fact. 

The Investment Scheme itself shows that disclosure of part of the information Defendants 

misrepresented and omitted caused a significant decrease in the value of the Securities purchased 

by Plaintiff AMJ once said misrepresentations and omissions were discovered. 

97. Despite Plaintiff AMJ’s demands for a return of its Investment Funds, Defendants

have unlawfully retained same.

98. Plaintiff AMJ elects to rescind the Investment Agreement pursuant to Section 

517.211(3), Florida Statutes (2019).

WHEREFORE, Plaintiff AMJ respectfully requests the entry of a final judgment in its 

favor and against Defendants, jointly and severally, rescinding the Investment Agreement, 

awarding Plaintiff AMJ attorneys’ fees and costs pursuant to Fla. Stat. § 517.211(6), pre-judgment 

interest and post-judgment interest at the maximum rate allowable by law, and for any additional 

available statutory relief and other relief that this Honorable Court deems just, equitable, and 

proper.

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COUNT VI

Breach of Fiduciary Duties

(Against Defendant Florencia)

99. Plaintiff AMJ re-alleges and incorporates paragraphs one (1) through fifty-two (52)

above as if fully set forth herein.

100. This Count VI is brought against Defendant Florencia pursuant to Section 

605.04091, Florida Statutes (2019). 

101. Defendant Florencia, as the managing member of Defendant Premier and pursuant 

to the Florida Revised Limited Liability Company Act, owed fiduciary duties of loyalty and care 

to Plaintiff AMJ and to Defendant Premier and was required to comply with the standards of 

conduct required by section 605.04091, Florida Statutes (2019), and other applicable Florida law

in discharging her duties.

102. The duty of care requires that Defendant Florencia refrain from grossly negligent 

or reckless conduct, willful or intentional misconduct, or knowing violations of law. The duty of 

loyalty requires that Defendant Florencia not appropriate company property for her own benefit. 

In addition, Defendant Florencia is required to discharge her duties and obligations, and to exercise 

any of her rights, consistent with the obligation of good faith and fair dealing. 

103. Defendant Florencia failed to comply with section 605.04091, Florida Statutes

(2019), and otherwise breached her fiduciary duties by, among other things:

a. Intentionally misrepresenting material facts about the Green MD Products to an 

audience of millions of potential customers, which misconduct, in addition to being reckless and 

willful, dramatically increased the risks associated with Plaintiff AMJ’s investment in Defendant 

Premier; 

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b. Knowingly violating applicable laws, including laws against false and misleading 

trade practices and fraud;

c. Embezzling a portion of the Investment Funds by transferring same to a personal 

account;

d. Using Defendant Premier’s credit cards for personal expenses; 

e. Failing to assume responsibility for the Premier Accounts;

f. Failing to distribute Defendant Premier’s profits to Defendant Premier’s members 

in accordance with the terms of Defendant Premier’s First Amendment and Restatement of 

Operating Agreement of Premier Beauty and Health LLC, a Limited Liability Company, executed 

by and between Defendant Florencia and Plaintiff AMJ (“Operating Agreement”);

g. Failing to conduct Defendant Premier’s affairs in compliance with the obligation 

of good faith and fair dealing.

h. Misrepresenting Defendant Premier’s relationship and agreement with ShopHQ, 

and manipulating and fabricating Defendant Premier’s Fraudulent Financial Statements;

i. Preventing Plaintiff AMJ from accessing Defendant Premier’s books and records;

j. Failing to market or sell the Additional Products.

k. Failing to provide Plaintiff AMJ with reasonable access to Defendant Premier’s 

books, records, and other information, and otherwise failing to keep Plaintiff AMJ appraised of 

Defendant Premier’s business performance or its use of the Investment Funds, as provided by the 

Operating Agreement and applicable Florida law. 

104. Plaintiff AMJ suffered damages as a direct and proximate result of Defendant 

Florencia’s breach of fiduciary duties.

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WHEREFORE, Plaintiff AMJ respectfully requests a final judgment in its favor and 

against Defendant Florencia for actual and compensatory damages, pre-judgment interest and postjudgment interest at the maximum rate allowable by law, and for any additional available statutory 

relief and other relief that this Honorable Court deems just, equitable, and proper.

COUNT VII

Fraudulent Inducement

(Against all Defendants)

105. Plaintiffs re-allege and incorporate paragraphs one (1) through fifty-two (52) as if 

fully set forth herein.

106. Defendants made misrepresentations, untrue statements, and omissions as set forth 

in this Complaint prior to and at the time Plaintiffs entered into the Investment Scheme. 

107. Defendants’ misrepresentations, untrue statements, and omissions were material.

108. At all material times, Defendants knew that their misrepresentations and untrue 

statements of material fact were false and made them for the purpose of inducing Plaintiffs’

reliance thereon when deciding to accept employment with and acquire the Securities offered by 

Defendants.

109. Defendants intended for Plaintiffs to rely upon their fraudulent misrepresentations 

and omissions of material fact in entering into the Investment Scheme.

110. Plaintiffs reasonably and justifiably relied upon Defendants’ fraudulent 

misrepresentations and untrue statements of material facts when deciding to participate in 

Defendants’ Investment Scheme. 

111. Plaintiffs suffered damages as a direct and proximate result of Defendants’ fraud.

WHEREFORE, Plaintiffs respectfully demand a final judgment in their favor and against 

Defendants, jointly and severally, for actual and compensatory damages, pre-judgment interest and 

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post-judgment interest at the maximum rate allowable by law, and for any additional available 

statutory relief and other relief that this Honorable Court deems just, equitable, and proper.

COUNT VIII

Breach of Employment Agreement

(Against Defendant Premier)

112. Plaintiff Silberman re-alleges and incorporates paragraphs one (1) through fiftytwo (52) above as if fully set forth herein.

113. The Employment Agreement is an enforceable contract.

114. Plaintiff Silberman complied with all of his obligations under the Employment 

Agreement.

115. All conditions precedent to Defendant Premier’s obligation to perform under the 

Employment Agreement occurred. 

116. Under the Employment Agreement, Plaintiff Silberman was entitled to receive 

monthly payments of Ten Thousand Dollars ($10,000) (“Salary Payments”).

117. Defendant Premier breached the Employment Agreement by failing to make the 

Salary Payments to Plaintiff Silberman for the month of February 2020. 

118. Plaintiff Silberman has suffered damages as a direct and proximate cause of 

Defendant Premier’s material breach of the Employment Agreement.

WHEREFORE, Plaintiff Silberman respectfully requests a final judgment in his favor and

against Defendant Premier for actual and compensatory damages, pre-judgment interest and postjudgment interest at the maximum rate allowable by law, and for any additional available statutory 

relief and other relief that this Honorable Court deems just, equitable, and proper.

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COUNT IX

Breach of Membership Interest Purchase Agreement (“MIPA”)

(Against Defendant Premier)

119. Plaintiff AMJ re-alleges and incorporates paragraphs one (1) through fifty-two (52)

above as if fully set forth herein.

120. The MIPA is an enforceable contract.

121. Plaintiff AMJ complied with all of its obligations under the Investment Agreement.

122. All conditions required by the Investment Agreement for Defendant Premier’s 

performance have been satisfied. 

123. Under section 5(iii)(c) of the MIPA, Defendant Premier, as seller, represents and 

warrants to Plaintiff AMJ, as purchaser, that “[n]either the execution or delivery of this agreement 

nor the consummation of the sale of the membership interest to PURCHASER [Plaintiff AMJ] 

will ... violate any statute or law....” 

124. Defendant Premier materially breached its obligations under the MIPA by violating 

section 5(iii)(c) thereunder, because Defendant Premier was in violation of applicable law from 

the moment it began offering the Securities to Plaintiff AMJ and through the closing of the 

transaction memorialized in the MIPA, as set forth in this Complaint. 

125. Plaintiff AMJ suffered damages as a direct and proximate result of Defendants’ 

material breach of section 5(iii)(c) of the MIPA.

126. Defendant Premier’s breach of the MIPA has caused Plaintiff AMJ to incur 

damages. 

WHEREFORE, Plaintiff AMJ respectfully requests the entry of a final judgment in its 

favor and against Defendant Premier for actual and compensatory damages, pre-judgment interest 

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and post-judgment interest at the maximum rate allowable by law, and for any additional available 

statutory relief and other relief that this Honorable Court deems just, equitable, and proper.

JURY DEMAND

Plaintiffs demand a trial by jury on all issues so triable.

Dated this 12

th day of May, 2020.

Respectfully submitted,

G&F LAW GROUP, LLP

Alexander C. Flint, Esq.

Florida Bar No. 117715

I. Albert Gonzalez, Esq.

Florida Bar No. 695971

Ariel Rapaport, Esq.

Florida Bar No. 1011939

15807 Biscayne Blvd, Suite 217

North Miami Beach, FL 33160

Telephone: (305) 503-9073

Fax: (305) 397-2716

acf@gflawgroup.com

iag@gflawgroup.com

arap@gflawgroup.com

/s/ Alexander C. Flint

Alexander C. Flint, Esq.

/s/ I. Albert Gonzalez

I. Albert Gonzalez, Esq.

/s/ Ariel Rapaport

Ariel Rapaport, Esq.

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