UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

West Palm Beach Division

IN RE:

CEMHAN BIRICIK and CASE NO. 20-19507-BKC-MAM

ISABEL BIRICIK, CHAPTER 7

Debtors.

_________________________/

SQUEEZE, LLC and 

ABIDING VENTURES, LLC, 

Plaintiffs,

vs. CASE NO. 20-01404-MAM

CEMHAN BIRICIK and

ISABEL BIRICIK, 

Defendants.

________________________/

ANSWER

COMES NOW the Defendants, CEMHAN BIRICIK (“CEMHAN”) and ISABEL 

BIRICIK (“ISABEL”)(collectively, the “Defendants”), by and through undersigned counsel, and 

file this answer to the complaint, and state:

1. Admit.

2. Admit.

3. Admit.

4. Admit. 

5. Without knowledge.

6. Without knowledge. 

7. Admit.

Case 20-01404-MAM Doc 19 Filed 02/09/21 Page 1 of 5
8. Admit.

9. Admit that Biricik LLC is inactive and has been so since September, 2017. Allegations 

state “all relevant time periods”. The company was inactive prior to the entry of the 

agreements with the Plaintiff.

10. Without knowledge.

11. Deny.

12. Admit.

13. Deny.

14. Admit.

15. Admit.

16. Deny. Neither CEMHAN nor Biricik LLC are attorneys and did not render assurances 

as to laws.

17. Admit that Abiding Ventures made a deposit.

18. Without knowledge.

19. Admit.

20. Admit.

21. Admit.

22. Admit.

23. Admit.

24. Admit.

25. Admit.

26. Admit.

27. Admit.

Case 20-01404-MAM Doc 19 Filed 02/09/21 Page 2 of 5
28. Admit.

29. Admit.

30. Admit.

31. Deny. 

32. Deny.

33. Admit.

34. Admit.

35. Admit.

36. Deny that ISABEL had any involvement with Biricik LLC after dissolution of 

company.

37. Admit how funds in account were used. Deny the reference of parties using the money 

jointly.

38. Admit how funds in account were used. Deny the reference of parties using the 

money jointly.

39. Admit how funds in account were used. Deny the reference of parties using the 

money jointly.

40. Admit how funds in account were used. Deny the reference of parties using the 

money jointly.

41. Admit how funds in account were used. Deny the reference of parties using the 

money jointly.

42. Admit how funds in account were used. Deny the reference of parties using the 

money jointly.

43. Admit how funds in account were used. Deny the reference of parties using the 

Case 20-01404-MAM Doc 19 Filed 02/09/21 Page 3 of 5
money jointly.

44. Admit how funds in account were used. Deny the reference of parties using the 

money jointly.

45. Admit how funds in account were used. Deny the reference of parties using the 

money jointly.

46. Deny. ISABEL never met with anyone at Squeeze and could not have made any 

representations. 

47. Admit.

48. Admit.

49. Admit.

50. Admit.

51. Admit.

52. Deny. Allegation too broad and Defendants cannot respond.

53. Deny. Cannot formulate a response to statement without context.

54. Deny. Allegation too broad and Defendants cannot respond.

55. Deny.

56. Defendants respond in same manner as set forth above.

57. Deny. 

58. Deny.

59. Deny.

60. Defendants respond in same manner as set forth above.

61. Deny. 

62. Deny.

Case 20-01404-MAM Doc 19 Filed 02/09/21 Page 4 of 5
63. Defendants respond in same manner as set forth above.

64. Deny.

65. Deny.

66. Deny.

67. Deny.

68. Deny.

69. Defendants respond in same manner as set forth above.

70. Deny.

71. Deny.

72. Defendants respond in same manner as set forth above.

73. Deny.

74. Deny.

75. Deny.

76. Deny.

77. Deny.

I HEREBY CERTIFY that a copy of the foregoing was provided electronically to Zach 

Shelomith, Esquire, zbs@lsaslaw.com this 9th day of February, 2021. 

BRIAN K. MCMAHON, P.A.

1401 Forum Way, 6th Floor

West Palm Beach, FL 33401

Tel (561)478-2500

Fax (561)478-3111

s/ Brian K. McMahon

Brian K. McMahon

FL Bar No. 853704

Case 20-01404-MAM Doc 19 Filed 02/09/21 Page 5 of 5