________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

West Palm Beach Division

www.flsb.uscourts.gov

In re:

CEMHAN BIRICIK and ISABEL C BIRICIK,

Debtors.

_______________________________________/

Case No. 20-19507-BKC-MAM

Chapter 7

SQUEEZE, LLC, a foreign limited liability 

company, d/b/a SQUEEZE STRATEGIES, LLC

and ABIDING VENTURES, LLC, a Florida 

limited liability company,

Plaintiffs,

vs.

CEMHAN BIRICIK and ISABEL C BIRICIK,

Defendants.

_______________________________________/

Adv. Case No. 

COMPLAINT OBJECTING TO DISCHARGE AND TO

THE DISCHARGEABILITY OF A DEBT

Squeeze, LLC, a foreign limited liability company, d/b/a Squeeze Strategies, LLC 

(“Squeeze” or the “Plaintiff”) and Abiding Ventures, LLC, a Florida limited liability company 

(“Abiding Ventures”), by counsel, pursuant to 11 U.S.C. §§ 727 and 523, bring this Complaint 

Objecting to Discharge and to the Dischargeability of a Debt against Cemhan Biricik (“Cemhan”) 

and Isabel C Biricik (“Isabel”) (collectively, the “Defendants”), and allege as follows:

Jurisdiction and Venue

1. This case was commenced by the filing of a voluntary Chapter 7 petition on August 

31, 2020 (the “Petition Date”) by the Defendants.

2. This is an action objecting to the Debtors’ discharge, pursuant to 11 U.S.C. § 727, 

and objecting to the dischargeability of a debt, pursuant to 11 U.S.C. § 523.

3. This is a core proceeding and this Court has jurisdiction over this action pursuant 

to 28 U.S.C. §§ 157 and 1334 and Fed. R. Bankr. P. 7001.

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 1 of 46
Complaint

Page 2 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

4. Venue is proper herein pursuant to 28 U.S.C. §§ 1408 and 1409.

Parties

5. Squeeze, LLC is a Delaware limited liability company, d/b/a Squeeze Strategies, 

LLC. Elias Janetis (“Janetis”) is the Manager of Squeeze, LLC.

6. Abiding Ventures, LLC is a Florida limited liability company also owned by 

Janetis.

7. Cemhan Biricik is the Debtor.

8. Isabel C Biricik is the spouse of the Debtor and is the Joint Debtor.

General Allegations

9. Biricik LLC is an inactive Florida limited liability company. During all relevant 

time periods, Isabel Biricik was the sole owner and Member of Biricik LLC.

10. Squeeze operates an online website and application that allows consumers the 

ability to compare recurring services, find promotional coupons, and track their spending.

The Transactions Between Cemhan, Biricik LLC and Squeeze

11. Cemhan and Biricik LLC marketed themselves as, among other things, specialists 

in cryptocurrency consulting, investing and Initial Coin Offering (“ICO”) creation. 

12. In late January/early February 2018, Cemhan had ongoing negotiations with 

management at Squeeze to discuss whether Squeeze could benefit from creating an ICO, and if so, 

whether this was something that Cemhan and Biricik LLC could assist Squeeze with 

implementing.

13. During the course of those negotiations, Cemhan told management at Squeeze, 

repeatedly, that he was well-versed in ICO creation, that the consultancy work he was proposing 

to Squeeze was legal and did not violate any securities laws, and that if at any time Squeeze was 

dissatisfied with Cemhan’s and Biricik LLC’s work, Cemhan would promptly refund any amount 

paid to Biricik LLC for their services. 

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 2 of 46
Complaint

Page 3 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

14. Based upon these representations, on or about February 8, 2018, Squeeze entered 

into a series of agreements with Biricik LLC, including the following: 

a. An ICO Website Design Agreement (“WDA”), pursuant to which Biricik LLC

agreed to create an ICO crowd sale website; 

b. ICO Marketing Consulting Agreements (collectively “MCA”), pursuant to which 

Biricik LLC agreed to provide certain marketing services on behalf of Squeeze; and

c. A TOKEN Development Agreement (“TDA”) pursuant to which Biricik LLC

agreed, among other things, to (a) “design a custom Ethereum Token” on behalf of Squeeze, and 

(b) provide “Crowd sale custom code creation.”

Copies of the WDA, MCA and TDA (collectively referred to herein as the “Agreements”) 

are attached as Composite Exhibit “A.” 

15. In connection with these services, Cemhan and Biricik LLC issued an invoice to 

Squeeze dated February 6, 2018 in the total amount of $148,000.00, of which 50% was “due upon 

receipt.” A copy of this invoice is attached as Exhibit “B.” 

16. Based upon Cemhan’s and Biricik LLC’s repeated assurances that the ICO did not 

violate state or federal securities laws, Squeeze executed the Agreements.

17. In addition, Abiding Ventures, LLC, a limited liability company also owned by 

Janetis, on behalf of Squeeze, paid Biricik LLC an initial deposit of $74,000.00 (the “Squeeze 

Funds”). A copy of the payment is attached as Exhibit “C”.

18. Shortly thereafter, Squeeze discussed the proposed ICO in greater detail with legal 

counsel, and Squeeze discovered that the Cemhan’s and Biricik LLC’s proposed ICO was a 

violation of both state and federal securities laws.

19. Therefore, on or about March 5, 2018, Janetis, on behalf of Squeeze, sent an email 

to Cemhan explaining the foregoing and advising that Squeeze was therefore not going to move 

forward with the proposed ICO. A copy of the email is attached as Exhibit “D.” 

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 3 of 46
Complaint

Page 4 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

20. Janetis also requested that Cemhan and Biricik LLC return the Squeeze Funds that 

Squeeze, through Abiding Ventures, LLC, had previously paid.

21. Despite Squeeze’s repeated demands for the return of its initial deposit, Cemhan 

and Biricik LLC have failed to respond and failed to return the Squeeze Funds to Squeeze. 

The State Court Proceeding

22. As a result, on April 9, 2018, Squeeze commenced a lawsuit (the “Complaint”) 

against Cemhan and Biricik LLC, in the Palm Beach County Circuit Court (the “State Court”), 

Case No. 50-2018-CA-004290-XXXX-MB, for rescission of the Agreements (Count 1), 

Fraudulent Inducement (Count 2), Conversion (Count 3) and Unjust Enrichment (Count 4) (the 

“State Court Proceeding”). A true and correct copy of the Complaint filed in the State Court 

Proceeding is attached as Exhibit “E”.

23. On January 29, 2019, Cemhan filed a voluntary Chapter 13 bankruptcy proceeding, 

Case No. 19-11213-EPK, in the United States Bankruptcy Court for the Southern District of 

Florida (the “First Bankruptcy Case”).

24. Thereafter, on February 1, 2019, the State Court entered a Final Judgment in favor 

of Squeeze and against Biricik LLC, in the amount of $75,590.73, plus post-judgment interest (the 

“Biricik LLC Final Judgment”). A true and correct copy of the Biricik LLC Final Judgment is 

attached as Exhibit “F”.

25. On July 10, 2019, the First Bankruptcy Case was dismissed, by virtue of an Agreed 

Order Denying Confirmation and Dismissing Chapter 13 Case with Prejudice for 180 Days [ECF 

No. 67 in the First Bankruptcy Case].

26. On January 10, 2020, Squeeze filed an Impleader Complaint against Cemhan and 

Isabel, alleging, among other things, the existence of alter ego liability against Cemhan and Isabel, 

for the acts of Biricik LLC.

27. On July 9, 2020, the State Court entered a Final Judgment Against Cemhan Biricik, 

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 4 of 46
Complaint

Page 5 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

in the amount of $76.025.81, plus post-judgment interest (the “Cemhan Biricik Final Judgment”), 

on Squeeze’s claim(s) for Fraudulent Inducement (Count 2), Conversion (Count 3) and Unjust 

Enrichment (Count 4). A true and correct copy of the Cemhan Biricik Final Judgment is attached 

as Exhibit “G”.

28. Thereafter, on July 20, 2020, Squeeze filed the Judgment Creditor’s Motion for 

Default Final Judgment in Proceedings Supplementary to Execution (the “Motion for Default”), 

in the State Court Proceeding, against Cemhan and Isabel. The Motion for Default was scheduled 

for hearing on September 3, 2020 at 10:00 a.m. in the State Court.

29. However, on August 31, 2020, the Defendants filed the above-captioned 

bankruptcy proceeding, which automatically stayed the State Court Proceeding.

The Biricik LLC TD Bank Account

30. The Squeeze Funds were deposited into Biricik LLC’s bank account at TD Bank, 

N.A. (Acct # 6177) (the “TD Bank Account”) on February 8, 2018.

31. A cursory review of the TD Bank Account demonstrates that at all relevant times, 

Biricik LLC was nothing more than the alter ego/mere instrumentality of both Cemhan and Isabel.

32. In that regard, Cemhan and Isabel used the Squeeze Funds deposited into the Biricik 

LLC TD Bank Account as their own personal funds and cause Biricik LLC to:

a. Pay their personal credit card expenses;

b. Pay their personal motor vehicle expenses;

c. Pay their children’s school tuition and/or child support obligations;

d. Pay their personal meal expenses;

e. Pay their personal entertainment expenses; and

f. Pay off their personal debts.

33. In fact, Isabel was the only authorized user on the TD Bank Account from May 1, 

2017 until February 13, 2018, when she suddenly added Cemhan as an authorized user. This 

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 5 of 46
Complaint

Page 6 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

occurred just five (5) days after the Squeeze Funds were deposited into the TD Bank Account.

34. Prior to receiving the Squeeze Funds, the TD Bank Account had a negative balance.

35. Biricik LLC was administratively dissolved on September 22, 2017.

36. The continued operation of Biricik LLC after dissolution resulted in a partnership 

business operated jointly by Cemhan and Isabel under the then-fictitious name “Biricik LLC”.

37. From January 2018 until the TD Bank Account was closed in October 2018, there 

were only three (3) other deposits made into the account, to wit: (a) $20.00 on January 19, 2018; 

(b) $20.00 on February 8, 2018; and (c) $2,247.21 made on July 2, 2018. In other words, over 

97% of the funds in this account came directly from Squeeze.

38. Cemhan and Isabel used the Squeeze Funds to pay $9,133.51 to American Heritage 

School from February 2018 through July 2018 from the TD Bank Account.

39. Cemhan and Isabel used the Squeeze Funds to pay $4,394.45 to St. Paul Lutheran’s 

School from the TD Bank Account.

40. Cemhan and Isabel used the Squeeze Funds to pay $4,945.00 to Cemhan’s father 

from the TD Bank Account.

41. Cemhan and Isabel used the Squeeze Funds to pay $4,763.99 to furniture and 

electronics stores from the TD Bank Account.

42. Cemhan and Isabel used the Squeeze Funds to pay $6,492.61 towards automobiles 

and automotive insurance from the TD Bank Account.

43. Cemhan and Isabel used the Squeeze Funds to pay $3,100.00 directly to Cemhan 

from the TD Bank Account.

44. Cemhan and Isabel used the Squeeze Funds to pay $1,860.87 towards Cemhan’s 

child support payments related to his prior marriage from the TD Bank Account.

45. Cemhan and Isabel used the Squeeze Funds to incur 145 separate charges for 

purchased made on Amazon between February 2018 and July 2018 from the TD Bank Account.

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 6 of 46
Complaint

Page 7 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

46. Cemhan and Isabel used Biricik LLC to induce Squeeze into believing that through 

Biricik LLC, they routinely provided assistance in ICO creation, when in fact, they had no other 

clients and were essentially out-of-business, as evidenced by the negative account balance in the 

TD Bank Account prior to receiving the Squeeze Funds, the fact that no other significant deposits 

were made into the TD Bank Account, and the fact that Biricik LLC was administratively dissolved 

during this time period.

The Instant Bankruptcy Proceeding

47. On October 6, 2020, Squeeze, though counsel, filed a Notice of Rule 2004 

Examination Duces Tecum [ECF No. 22] (the “2004 Notice”). 

48. Squeeze requested in the 2004 Notice that the Defendants provide numerous 

documents and records no later than October 16, 2020, as listed in Exhibit “A” of the 2004 Notice

(the “Document List”).

49. Squeeze also requested in the 2004 Notice that the Defendants appear for their Rule 

2004 Examination on October 22, 2020 at 10:30 a.m. (the “2004 Examination”).

50. The Defendants did, in fact, appear at their 2004 Examination on October 22, 2020 

at 10:30 a.m.

51. Isabel testified at the 2004 Examination that she did not have any documents 

responsive to the Document List.

52. Cemhan testified at the 2004 Examination that he had a joint bank account with his 

mother at Bank of America, N.A. However, Cemhan was unable to provide an explanation as to 

several transactions from this bank account, including transactions made for his own personal use 

and benefit.

53. Cemhan also testified at the 2004 Examination that he does not “. . . really keep 

records and stuff.”

54. At the 2004 Examination, both Cemhan and Isabel were unable to explain several 

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 7 of 46
Complaint

Page 8 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

transactions made from the Biricik LLC TD Bank Account, which was comprised mostly from the 

Squeeze Funds.

55. All conditions precedent to bringing this action, if any, have occurred or have been 

performed, waived or excused.

Count 1 – Objection to Discharge (11 U.S.C. § 727(a)(3)) (Against Both Defendants)

56. The Plaintiffs reallege all of the allegations set forth in each of the paragraphs 

above.

57. The Defendants have concealed, destroyed, mutilated, falsified and/or failed to 

keep or preserve recorded information, including books, documents, records and/or papers, from 

which the Defendants’ financial condition or business transactions might be ascertained.

58. Such acts or failure(s) to act were not justified under all of the circumstances of this 

case.

59. As such, the Defendants’ discharge should be denied, pursuant to 11 U.S.C. § 

727(a)(3).

WHEREFORE, Squeeze (and to the extent that the Court determines that Abiding Ventures 

is the appropriate party-plaintiff, Abiding Ventures) request(s) that this Court enter judgment 

against the Defendants: (a) denying the Defendants’ discharge pursuant to 11 U.S.C. § 727(a)(3); 

and (b) granting such other and further relief as the Court deems just and proper.

Count 2 – Objection to Discharge (11 U.S.C. § 727(a)(5)) (Against Both Defendants)

60. The Plaintiffs reallege all of the allegations set forth in each of the paragraphs 

above.

61. The Defendants have failed to explain satisfactorily, before determination of denial 

of discharge, any loss of assets or deficiency of assets to meet the Defendants’ liabilities.

62. As such, the Defendants’ discharge should be denied, pursuant to 11 U.S.C. § 

727(a)(5).

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 8 of 46
Complaint

Page 9 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

WHEREFORE, Squeeze (and to the extent that the Court determines that Abiding Ventures 

is the appropriate party-plaintiff, Abiding Ventures) request(s) that this Court enter judgment 

against the Defendants: (a) denying the Defendants’ discharge pursuant to 11 U.S.C. § 727(a)(5); 

and (b) granting such other and further relief as the Court deems just and proper.

Count 3 – Objection to the Dischargeability of a Debt (11 U.S.C. § 523(a)(2)(A))

(Against Cemhan Biricik)

63. The Plaintiffs reallege all of the allegations set forth in each of the paragraphs 

above.

64. Cemhan made false representations to Squeeze’s representative(s), with the intent 

to deceive Squeeze.

65. Cemhan knew or should have known that the representations were false at the time 

they were made.

66. Squeeze relied on the misrepresentation in signing the Agreements and remitting 

the Squeeze Funds to Biricik LLC.

67. Such reliance was justified given the circumstances.

68. Squeeze and/or Abiding Ventures sustained a loss as a result of the 

misrepresentation(s).

WHEREFORE, Squeeze (and to the extent that the Court determines that Abiding Ventures 

is the appropriate party-plaintiff, Abiding Ventures) request(s) that this Court enter judgment 

against Cemhan: (a) determining that the debt owed by Cemhan to Squeeze (and/or Abiding 

Ventures) is non-dischargeable pursuant to 11 U.S.C. § 523(a)(2)(A); and (b) granting such other 

and further relief as the Court deems just and proper.

Count 4 – Objection to the Dischargeability of a Debt (11 U.S.C. § 523(a)(4))

(Against Both Defendants)

69. The Plaintiffs reallege all of the allegations set forth in each of the paragraphs 

above.

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 9 of 46
Complaint

Page 10 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

70. As set forth above, Cemhan and Isabel appropriated the Squeeze funds for their 

own use and benefit and did so with fraudulent intent or deceit.

71. As such, debt owed by the Defendants were incurred for larceny, pursuant to 11 

U.S.C. § 523(a)(4).

WHEREFORE, Squeeze (and to the extent that the Court determines that Abiding Ventures 

is the appropriate party-plaintiff, Abiding Ventures) request(s) that this Court enter judgment 

against the Defendants: (a) determining that the debt owed by the Defendants to Squeeze (and/or 

Abiding Ventures) is non-dischargeable pursuant to 11 U.S.C. § 523(a)(4); and (b) granting such 

other and further relief as the Court deems just and proper.

Count 5 – Objection to the Dischargeability of a Debt (11 U.S.C. § 523(a)(6))

(Against Both Defendants)

72. The Plaintiffs reallege all of the allegations set forth in each of the paragraphs 

above.

73. As set forth above, Cemhan and Isabel intentionally appropriated the Squeeze funds 

for their own use and benefit.

74. Such action(s) were done with the intent to harm Squeeze.

75. Such action(s) caused damage to Squeeze.

76. Such injury is the approximate result of the action(s) of the Defendant.

77. As such, debt owed by the Defendants were incurred for a willful and malicious 

injury by the Defendants to Squeeze or to the property of Squeeze, pursuant to 11 U.S.C. § 

523(a)(6).

WHEREFORE, Squeeze (and to the extent that the Court determines that Abiding Ventures 

is the appropriate party-plaintiff, Abiding Ventures) request(s) that this Court enter judgment 

against the Defendants: (a) determining that the debt owed by the Defendants to Squeeze (and/or 

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 10 of 46
Complaint

Page 11 of 11

________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

Abiding Ventures) is non-dischargeable pursuant to 11 U.S.C. § 523(a)(6); and (b) granting such 

other and further relief as the Court deems just and proper.

Reservation of Rights

Upon completion of his investigation and discovery, the Plaintiffs reserve the right to 

amend this Complaint to assert any additional claims for relief against the Defendants as may be 

warranted under the circumstances and as permitted by law.

Dated: November 30, 2020

LEIDERMAN SHELOMITH 

ALEXANDER + SOMODEVILLA, PLLC

Counsel for the Plaintiffs

2699 Stirling Road, Suite C401

Ft. Lauderdale, Florida 33312

Telephone: (954) 920-5355

Facsimile: (954) 920-5371

By:_________/s/______________

ZACH B. SHELOMITH

Florida Bar No. 0122548

zbs@lsaslaw.com

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 11 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 12 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 13 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 14 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 15 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 16 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 17 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 18 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 19 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 20 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 21 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 22 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 23 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 24 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 25 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 26 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 27 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 28 of 46
Composite Exhibit "A"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 29 of 46
Exhibit "B"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 30 of 46
Exhibit "B"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 31 of 46
Exhibit "C"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 32 of 46
Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 33 of 46
IN THE CIRCUIT COURT FOR THE 

FIFTEENTH JUDICIAL CIRCUIT, IN 

AND FOR PALM BEACH COUNTY, 

FLORIDA

CASE NO: 

SQUEEZE, LLC, 

a Florida limited liability company,

Plaintiff, 

vs. 

BIRICIK, LLC, a Florida limited 

liability company, and CEMHAN

BIRICIK, an individual,

Defendants.

 /

COMPLAINT

Plaintiff, SQUEEZE, LLC, a Florida limited liability company (hereinafter referred to as 

“Squeeze” or “Plaintiff”), by and through its undersigned counsel, files its Complaint 

(“Complaint”) and sues Defendants, BIRICIK, LLC, a Florida limited liability company

(“Biricik”) and CEMHAN BIRICIK, an individual (“Mr. Biricik”) (collectively Biricik and Mr. 

Biricik are referred to herein as “Defendants”), and alleges as follows:

PARTIES, VENUE AND JURISDICTION 

1. This is a complaint for damages in excess of $15,000.00, exclusive of interest, fees 

and costs. 

2. Plaintiff is a Florida limited liability company with its principal place of business 

located in Palm Beach County, FL.

3. Defendant, Biricik, is a Florida limited liability company with its principal place of 

business located in Broward County, FL.

Filing # 70455187 E-Filed 04/09/2018 05:17:14 PM

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 34 of 46
CASE NO: 

2

4. Defendant, Mr. Biricik, is an individual residing in Broward County, Florida.

5. Venue is proper in Palm Beach County, Florida, pursuant to Fla. Stat. §§ 47.011

and 47.041 because the causes of action accrued in Palm Beach County, FL. 

GENERAL ALLEGATIONS

6. Squeeze operates an online website and app that allows consumers the ability to 

compare recurring services, find promotional coupons, and track their spending.

7. Defendants market themselves as, among other things, specialists in cryptocurrency 

consulting, investing and Initial Coin Offering (“ICO”) creation.

8. In late January/early February 2018, Mr. Biricik had ongoing negotiations with 

management at Squeeze to discuss whether Squeeze could benefit from creating an ICO, and if so, 

whether this was something the Defendants could assist Squeeze with implementing.

9. During the course of those negotiations, Mr. Biricik told management at Squeeze, 

repeatedly, that he was well-versed in ICO creation, that the consultancy work he was proposing 

to Squeeze was legal and did not violate any securities laws, and that if at any time Squeeze was 

dissatisfied with Defendants’ work, he would promptly refund any amount paid to Defendants for 

their services.

10. Based upon these representations, on or about February 8, 2018, Squeeze entered 

into a series of agreements with Biricik, all of which related to Biricik’s assistance with developing 

an ICO on behalf of Squeeze. The agreements specifically included the following:

• An ICO Website Design Agreement (“WDA”), pursuant to which Biricik agreed to 

create an ICO crowd sale website;

• ICO Marketing Consulting Agreements (collectively “MCA”), pursuant to which 

Biricik agreed to provide certain marketing services on behalf of Squeeze; and

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 35 of 46
CASE NO: 

3

• A TOKEN Development Agreement (“TDA”) pursuant to which Biricik agreed, 

among other things, to (a) “design a custom Ethereum Token” on behalf of Squeeze, 

and (b) provide “Crowd sale custom code creation.” 

Copies of the WDA, MCA and TDA (collectively referred to herein as the “Agreements”) 

are attached as Composite Exhibit “A.”

11. In connection with these services, Defendants issued an invoice to Squeeze dated 

February 6, 2018 in the total amount of $148,000.00, of which 50% was “due upon receipt.” A 

copy of this invoice is attached as Exhibit “B.” 

12. Based upon Defendants’ repeated assurances that the ICO did not violate state or 

federal securities laws, Squeeze executed the Agreements and paid Defendants an initial deposit 

of $74,000.00. 

13. Shortly thereafter, Squeeze discussed the proposed ICO in greater detail with legal 

counsel, and Squeeze discovered that the Defendants’ proposed ICO was a violation of both state 

and federal securities laws.

14. Therefore, on or about March 5, 2018, Squeeze’s manager, Elias Janetis (“Mr. 

Janetis”), sent an email to Mr. Biricik explaining the foregoing and advising that Squeeze was 

therefore not going to move forward with the proposed ICO. A copy of the letter is attached as 

Exhibit “C.” Plaintiff also requested that Defendants return the initial deposit that Squeeze had 

previously paid.

15. Unfortunately, despite Plaintiff’s repeated demands for the return of its initial 

deposit, Defendants have failed to respond and failed to return Squeeze’s initial deposit.

16. All conditions precedent to bringing this action, if any, have occurred or have been 

performed, waived or excused.

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 36 of 46
CASE NO: 

4

COUNT I

RESCISSION OF THE AGREEMENTS

17. Plaintiff adopts and incorporates paragraphs 1 through 17 above, as if fully set forth 

herein.

18. In late January/early February 2018, Mr. Biricik had ongoing negotiations with 

management at Squeeze to discuss whether Squeeze could benefit from creating an ICO, and if so, 

whether this was something the Defendants could assist Squeeze with.

19. During the course of those negotiations, Mr. Biricik told management at Squeeze, 

repeatedly, that he was well-versed in ICO creation, that the consultancy work he was proposing 

to Squeeze was legal and did not violate any securities laws, and that if at any time Squeeze was 

dissatisfied with Defendants’ work, he would promptly refund any amount paid to him for his 

services.

20. Based upon these representations, on or about February 8, 2018, Squeeze entered 

into the Agreements, copies of which are attached as Composite Exhibit “A.”

21. The Agreements all pertain to Biricik’s assistance with developing an ICO on 

behalf of Squeeze. 

22. In connection with these services, Defendants issued an invoice to Squeeze dated 

February 6, 2018 in the total amount of $148,000.00, of which 50% was “due upon receipt.” A 

copy of this invoice is attached as Exhibit “B.” 

23. Based upon Defendants’ repeated assurances that the ICO did not violate state or 

federal securities laws, Squeeze executed the Agreements and paid Defendants an initial deposit 

of $74,000.00. 

24. Shortly thereafter, Squeeze discussed the proposed ICO in greater detail with legal 

counsel, and Squeeze discovered that the Defendants’ proposed ICO was a violation of both state 

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 37 of 46
CASE NO: 

5

and federal securities laws.

25. Therefore, on or about March 5, 2018, Squeeze’s manager, Mr. Janetis, sent an 

email to Mr. Biricik explaining the foregoing and advising that Squeeze was therefore not going 

to move forward with the proposed ICO. Plaintiff also requested that Defendants return the initial 

deposit that Squeeze had previously paid.

26. Unfortunately, despite Plaintiff’s repeated demands for the return of its initial 

deposit, Defendants have failed to respond and failed to return Squeeze’s initial deposit.

27. But for Defendants’ numerous misrepresentations regarding the legality of the 

proposed ICO, Plaintiff would never have entered into the Agreements.

28. Because the ICO proposed by Defendants is illegal, the Agreements should be 

rescinded and Defendants should be compelled to return Squeeze’s initial deposit of $74,000.00.

WHEREFORE, Plaintiff, SQUEEZE, LLC, respectfully requests this Court to rescind the

Agreements and order that Defendants, BIRICIK, LLC and CEMHAN BIRICIK promptly return 

Squeeze’s initial deposit, along with awarding such other and further relief that it deems just and 

proper.

COUNT II

FRAUDULENT INDUCEMENT

29. Plaintiff adopts and incorporates paragraphs 1 through 17 above, as if fully set forth 

herein. 

30. In late January/early February 2018, Mr. Biricik had ongoing negotiations with 

management at Squeeze to discuss whether Squeeze could benefit from creating an ICO, and if so, 

whether this was something the Defendants could assist Squeeze with.

31. During the course of those negotiations, Mr. Biricik told management at Squeeze,

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 38 of 46
CASE NO: 

6

including Mr. Janetis, on several occasions, that he was well-versed in ICO creation, that the 

consultancy work he was proposing to Squeeze was legal and did not violate any securities laws, 

and that if at any time Squeeze was dissatisfied with Defendants’ work, he would promptly refund 

any amount paid to him for his services.

32. Based upon Defendants’ repeated assurances that the ICO did not violate state or 

federal securities laws, Squeeze executed the Agreement and paid Defendants an initial deposit of 

$74,000.00. 

33. Shortly thereafter, Squeeze discussed the proposed ICO in greater detail with legal 

counsel, and Squeeze discovered that the Defendants’ proposed ICO was a violation of both state 

and federal securities laws.

34. Therefore, on or about March 5, 2018, Squeeze’s manager, Mr. Janetis, sent an 

email to Mr. Biricik explaining the foregoing and advising that Squeeze was therefore not going 

to move forward with the proposed ICO. Mr. Janetis also requested that Defendants return the 

initial deposit that Squeeze had previously paid.

35. Unfortunately, despite Plaintiff’s repeated demands for the return of its initial 

deposit, Defendants have failed to respond and failed to return Squeeze’s initial deposit.

36. But for the Defendants’ numerous misrepresentations regarding the legality of the 

proposed ICO, Plaintiff would never have entered into the Agreements.

37. Defendants knew of the falsity of their representations to Squeeze, and they made 

the representations with the specific intent of inducing Squeeze to pay them an initial deposit of 

$74,000.00.

38. Squeeze reasonably relied upon Mr. Biricik’s representations and fully complied 

with its obligations.

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 39 of 46
CASE NO: 

7

39. As a result of Defendants’ actions, Squeeze has suffered damages.

WHEREFORE, Plaintiff, SQUEEZE, LLC, demands judgment against Defendants, 

BIRICIK, LLC and CEMHAN BIRICIK, for damages, interest and costs, together with such other 

and further relief deemed just, equitable and proper.

COUNT III

CONVERSION

40. Plaintiff adopts and incorporates paragraphs 1 through 17 above, as if fully set forth 

herein. 

41. Because the ICO proposed by Defendants is illegal, the Agreements are, by 

operation of law, void ab initio, and Plaintiff is entitled to the return of its $74,000.00 initial 

deposit.

42. Notwithstanding the foregoing, Defendants have failed to return Plaintiff’s initial 

deposit, and instead, have converted these funds to their own use.

43. Plaintiff has retained the undersigned attorneys to represent it in this action and is 

required to pay them a reasonable fee for their services.

WHEREFORE, Plaintiff, SQUEEZE, LLC, demands judgment against Defendants, 

BIRICIK, LLC and CEMHAN BIRICIK, for damages, interest and costs, together with such other 

and further relief deemed just, equitable and proper.

COUNT IV

UNJUST ENRICHMENT

44. Plaintiff adopts and incorporates paragraphs 1 through 17 above, as if fully set forth 

herein.

45. Because the ICO proposed by Defendants is illegal, the Agreements are, by 

operation of law, void ab initio, and Plaintiff is entitled to the return of its $74,000.00 initial 

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 40 of 46
CASE NO: 

8

deposit.

46. By failing to return Plaintiff’s initial deposit, Defendants have been unjustly 

enriched and Plaintiff has been impoverished.

47. Plaintiff has retained the undersigned attorneys to represent it in this action and is 

required to pay them a reasonable fee for their services.

WHEREFORE, Plaintiff, SQUEEZE, LLC, demands judgment against Defendants, 

BIRICIK, LLC and CEMHAN BIRICIK, for damages, interest and costs, together with such other 

and further relief deemed just, equitable and proper.

Dated: April 9, 2018.

Respectfully submitted

STORRINGS LAW

Counsel for Plaintiff

10100 West Sample Road, Suite 300

Coral Springs, FL 33065

Telephone: (954) 302-7148

Fax: (954) 358-4064

Email: harley@storringslaw.com

Agnes@storringslaw.com

By: /s/ Harley J. Storrings

Harley J. Storrings

Florida Bar No. 870641

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 41 of 46
Please Note: Exhibits to the State Court Complaint are already 

contained in Exhibits “A”, “B” and “D” to this Adversary 

Complaint 

Exhibit "E"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 42 of 46
Exhibit "F"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 43 of 46
Exhibit "F"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 44 of 46
1.

2.

IN THE CIRCUIT COURT FOR THE FIFTEENTH

JUDICIAL CIRCUIT, IN AND FOR PALM BEACH

COUNTY, FLORIDA

SQUEEZE, LLC,

a Florida limited liability company, 

Plaintiff,

vs.

BIRICIK, LLC, a Florida limited

liability company, and CEMHAN

BIRICIK, individually, jointly and CASE NO: 502018CA004290XXXXMB

severally,

Defendants,

 /

FINAL JUDGMENT AGAINST DEFENDANT CEMHAN BIRICIK

THIS CAUSE came before this Court for a one-day bench trial on June 4, 2020 on

Plaintiff, SQUEEZE, LLC’s (“Plaintiff”) Complaint against Defendant, CEMHAN BIRICIK

(“Mr. Biricik”) alleging (a) Fraudulent Inducement against Mr. Biricik (Count II); (b) Conversion

against Mr. Biricik (Count III); and (c) Unjust Enrichment against Mr. Biricik.1 Having observed

all witness testimony at trial, having reviewed the exhibits offered into evidence at trial, having

heard argument of counsel, and being fully apprised in the premises, this Court finds as follows:

Preliminarily, the Court notes that this non-jury trial was held remotely through Zoom

videoconference technology. Mr. Biricik did not appear at trial despite the fact that, among other

things, (a) an email was sent out at the direction of this Court from CADDivisionAG@pbcgov.org to Plaintiff’s counsel and to Mr. Biricik at the email he provided to the

Court (iceepc@gmail.com) on May 14, 2020 advising all recipients, including Mr. Biricik, that

this matter has been set per the E-Calendar Call form on the Division AG website posted trial

docket and to review the court's trial docket to see when the case was set for trial; and (b) the

Court Reporting Agency that hosted the Zoom videoconference (U.S. Legal Support) sent an

email to all parties, including Mr. Biricik (at iceepc@gmail.com) in which it provided the date of

trial, the starting time of trial, and a link to attend trial. 

Based upon the testimony that was provided at trial, this Court hereby enters Final

Page 1 of 2

Exhibit "G"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 45 of 46
3.

4.

5.

6.

Judgment in favor of Plaintiff, SQUEEZE, LLC (901 NW 35th Street, Boca Raton, FL 33431;

FEI/EIN Number 47-5581141) and against Defendant, CEMHAN BIRICIK (6398 Amberwoods

Drive, Boca Raton, FL 33433) on Plaintiff’s claims for (a) Fraudulent Inducement against Mr.

Biricik (Count II); (b) Conversion against Mr. Biricik (Count III); and (c) Unjust Enrichment

against Mr. Biricik. 

Although Plaintiff was seeking principal damages against Mr. Biricik in the amount of

Seventy-Four Thousand Dollars ($74,000.00), based upon the evidence presented, this Court

finds that Plaintiff’s principal damages are Seventy-Two Thousand Dollars ($72,000.00). 

The Court further finds that Plaintiff is entitled to recover its reasonable costs from Mr.

Biricik, and based upon the Affidavit provided by Plaintiff, this Court finds that Plaintiff is

entitled to recover costs from Mr. Biricik in the amount of $4,025.81. 

Therefore, the total amount of this Final Judgment is $76,025.81, which shall bear

interest at the statutory rate (currently 6.66% interest per annum). 

Defendant, CEMHAN BIRICIK, shall complete under oath Florida Rule of Civil

Procedure Form 1.977 (Fact Information Sheet for Individuals), including all required

attachments, and serve same on Plaintiff’s counsel within 45 days of Plaintiff’s attorney mailing

and emailing said form to Defendant, unless the Final Judgment is satisfied prior to that time. 

DONE AND ORDERED in Palm Beach County, Florida.

Copies furnished to:

Harley J. Storrings, Esq. and Greg Barthelette, Esq., Storrings Law, 9600 W. Sample Road,

Suite 206, Coral Springs, FL 33065, email: Harley@storringslaw.com;

Greg@storringslaw.com; and Assistant@storringslaw.com; and

Cemhan Biricik, 6398 Amberwoods Drive, Boca Raton, FL 33433, email: iceepc@gmail.com.

1 Count I of Plaintiff’s Complaint for Rescission of Agreements is moot as it was previously resolved by

virtue of this Court’s Final Judgment in favor of Plaintiff and against Defendant, BIRICIK, LLC dated February 1,

2019.

Case No. 50-2018-CA-004290-XXXX-MB

Page 2 of 2

Exhibit "G"

Case 20-01404-MAM Doc 1 Filed 11/30/20 Page 46 of 46