UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 20-CV-21984-DPG

AARON SILBERMAN and

AMJ MISIL AB LLC,

Plaintiffs,

v.

PREMIER BEAUTY AND HEALTH LLC,

JORGE HANE and FLORENCIA HANE,

Defendants.

_________________________________/

NOTICE OF FILING 

PARTIES JOINT STATEMENT OF THE CASE 

Defendants, Premier Beauty & Health LLC, Jorge Hane and Florencia Hane,

by and through undersigned counsel, and pursuant to this Court’s Order dated April 

5, 2024 [DE 487], hereby give notice of filing the parties’ agreed Joint Statement of 

the Case in the form attached hereto as Exhibit A. 

Respectfully submitted,

WOLFE LAW MIAMI PA

175 SW 7th Street, Suite 2410

Miami, Florida 33130

P: 305.384.7370

F: 305.384.7371

Email: 

rwolfe@wolfelawmiami.com 

Case 1:20-cv-21984-DPG Document 488 Entered on FLSD Docket 04/09/2024 Page 1 of 5
By: /s/ Richard C. Wolfe

 Richard C. Wolfe, Esq.

 Florida Bar No.: 355607

CERTIFICATE OF SERVICE 

I hereby certify that on April 9, 2024, 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 all counsel of record identified on the attached 

Service List in the manner specified, either via transmission of Notice of Electronic 

Filing generated by CM/ECF or in some other authorized manner for those counsel 

or parties who are not authorized to receive electronically Notice of Electronic 

Filing.

I. Albert Gonzalez, Esq. Anthony C. Hevia, Esq. 

IAG Law, PLLC Hevia Law Firm

320 Seven Springs Way 2525 Ponce de Leon Blvd., Suite 300

Brentwood, Tennessee 37027 Coral Gables, Florida 33134

iag@iaglawpllc.com anthony@hevialawfirm.com

courtney@hevialawfirm.com

susy@hevialawfirm.com 

/s/ Richard C. Wolfe 

Richard C. Wolfe

Case 1:20-cv-21984-DPG Document 488 Entered on FLSD Docket 04/09/2024 Page 2 of 5
EXHIBIT A

Case 1:20-cv-21984-DPG Document 488 Entered on FLSD Docket 04/09/2024 Page 3 of 5
JOINT STATEMENT OF THE CASE 

On August 2019, Plaintiffs agreed to invest $400,000 in Premier Beauty and Health, 

LLC (“Premier”) in return for a 10% ownership interest that was owned by Florencia

Hane (“Hane”), on the condition that Aaron Silberman (“Silberman”) be the chief 

operating officer of Premier. In August 2019 Silberman began to work as the chief 

operating officer. After about a month of doing so, AMJ Misil AB LLC (“AMJ”)

invested $100,000 and later it invested $300,000. 

From August 2019 until late February 2020, Silberman served as the chief operating 

officer and Florencia served as the president of Premier. The parties agreed that 

Florencia would get a salary of $12,000 a month and Aaron would get a salary of 

$10,000 per month.

Florencia’s husband Jorge served as a consultant to Premier and was not paid a 

salary. On January 2020, Premier aired its first TV show. In February 2020 AMJ

invested another $50,000 in Premier in return for an additional 10% interest.

In late February 2020, Plaintiff Silberman ceased working for Premier. There is a 

disagreement between Plaintiff Silberman and the Defendants as to whether he was 

fired or quit, and the reasons therefor. AMJ asserts five counts for securities 

violations, claiming that their investment in Premier is an unregistered security.

AMJ alleges that, in order to induce its investment in Premier, Defendants: a) made 

material misrepresentations and failed to disclose material facts to AMJ; and b) 

falsely promised Plaintiff Silberman, in his individual capacity (separate and apart 

from his role as a member of AMJ), a job at Premier where he would be mentored 

by Defendant Jorge Hane in all aspects of Premier’s business. Plaintiffs allege that 

AMJ relied on Defendants’ material misrepresentations and material omissions in 

deciding to invest in Premier. Defendants deny these claims. Defendants deny that 

any misrepresentations were made to Plaintiffs because all negotiations were with 

Salomon Mishaan, and these alleged misrepresentations were not material in AMJ’s 

decision to invest.

Premier denies that the investment in this closely held limited liability company is a 

security, because Silberman, as the COO of Premier was active in the business of 

Premier and therefore the investment is not a security

AMJ further alleges that upon AMJs’ transfer of $400,000 in investment funds 

(toward its $450,000 investment in Premier) in September 2019, Defendant 

Case 1:20-cv-21984-DPG Document 488 Entered on FLSD Docket 04/09/2024 Page 4 of 5
Florencia and Jorge Hane caused $100,000 of AMJ’s investment funds, to be 

transferred to one of Florencia Hane’s personal bank accounts, without authorization 

from AMJ, and that Defendants otherwise improperly used AMJ’s investment funds. 

Defendants deny these claims and claim that Florencia was authorized to transfer 

$100,000 of AMJ’s investment funds to her personal bank account in September 

2019, that they did not misuse AMJ’s investment funds and that all funds was spent 

as agreed.

Premier paid Florencia a salary of $12,000 per month and Aaron a salary of $10,000 

per month from August 2019 until January 2020. Both salaries were paid using 

AMJ’s investment funds. Silberman asserts a claim for failure to pay him salary for 

the month of February. In response, Premier asserts that all parties agreed that no 

salaries would be paid in February.

Premier has asserted a claim against Silberman because he quit his employment 

without notice leaving Premier in a bad situation with the TV network, its supplier 

and fulfillment company and causing the spokesperson to quit. Silberman denies

this. These are the factual claims that you will have to decide at the end of the case. 

I will explain to you the law that you will apply in reaching your verdict.

Case 1:20-cv-21984-DPG Document 488 Entered on FLSD Docket 04/09/2024 Page 5 of 5