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Affidavit in Support of Motion to Modify Post-Indictment Seizure of Assets — No. 5:25-cr-20543 (Dkt. 23-2, E.D. Mich.)

Summary

An affidavit by defendant Cemhan Biricik in support of a motion to modify post-indictment seizure of assets, dated September 30, 2025 and filed as ECF No. 23-2 in United States v. Biricik and Martin Perlin, Case 5:25-cr-20543, in the U.S. District Court for the Eastern District of Michigan. Biricik states that he operated a business, FastLab, from about October 2021 to 2025 conducting and making available Covid testing, and that its operations are the subject of the case. He states that he was arrested on July 31, 2025, that government officials seized his personal and real property and bank accounts, and that he has no assets other than what was seized.

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“Affidavit in Support of Motion to Modify Post-Indictment Seizure of Assets — No. 5:25-cr-20543 (Dkt. 23-2, E.D. Mich.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/affidavit-in-support-of-motion-to-modify-post-indictment-seizure-of-as-98768f8dd6/, SHA-256 d699b51137ade224a645c0d62c81b83f4ca94ba324adf69b90efaa9c81248f58.

Full text

Case 5:25-cr-20543-JEL-KGA ECF No. 23-2, PageID.232 Filed 09/30/25 Page 1 of 3




                   UNITED STATES DISTRICT COURT
                   EASTERN DISTRICT OF MICHIGAN
                        SOUTHERN DIVISION
_________________________________
                                  )
UNITED STATES OF AMERICA,         )
                                  )
v.                                ) Case 5:25-cr-20543
                                  )
Cemhan “Jimmy” Biricik,           )
Dr. Martin Perlin,                )
                                  )
     Defendants.                  )
_________________________________ )

            AFFIDAVIT IN SUPPORT OF MOTION TO MODIFY
               POST-INDICTMENT SEIZURE OF ASSETS

1.    My name is Cemhan Biricik. I am a defendant in the above captioned case. I

submit this Affidavit to support motion to Modify Post-Indictment Seizure of

Assets.

2.    I am currently incarcerated at Livingston County Jail, 150 S. Highlander

Way, Howell, Michigan. I permanently reside at 9623 Macchiato Avenue, Boca

Raton, Florida. I live there with my wife and children. I was born in Turkey but

emigrated to the United States in 1983. In 2001, I became a U.S. citizen.

3.    I operated a business (FastLab) from about October 2021 to 2025 conducting

and making available Covid testing. The operations of that business are the subject

of the instant criminal case.
Case 5:25-cr-20543-JEL-KGA ECF No. 23-2, PageID.233 Filed 09/30/25 Page 2 of 3




4.    I was arrested on July 31, 2025 in this case in Florida. My case was later

transferred to the Eastern District of Michigan, Southern Division.

5.    Contemporaneously with my arrest, government officials seized all my

personal and real property, and my bank accounts. A lien was imposed on my

property.

6.    I have no assets of any sort, nor any cash or bank accounts, other than that

already seized by the government.

7.    My family is unable to meet their regular domestic needs because our funds

have been seized. These include property maintenance, food, medical expenses

and education costs.

8.    I am also unable to pay certain related staff costs at FastLab which are

necessary for me to obtain extensive data about business operations from business

software programs, data that is necessary for me to defend these charges.

Specifically, I have six employees who are owed back due wages totaling $11,083.

I cannot obtain business operational data without paying these employees their

back due wages.

9.    Lastly, I am unable to pay legal costs necessary for me to fully defend

myself in this complicated case.

10.    For these reasons, I request the Court modify the outstanding seizure orders

to permit allocation of costs in these areas.
Case 5:25-cr-20543-JEL-KGA ECF No. 23-2, PageID.234 Filed 09/30/25 Page 3 of 3




11.   I swear under penalty of perjury pursuant to 28 U.S.C. § 1746 the foregoing

is true and correct to the best of my knowledge and belief. I understand this

document will be used in a court proceeding.

Dated: September 30, 2025




                                       __________________
                                       Cemhan Biricik
                                       Livingston County Jail
                                       150 S. Highlander Way
                                       Howell, MI 48843

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