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Affidavit in Support of Supplemental Motion to Modify Post-Indictment Seizure of Assets — No. 5:25-cr-20543 (Dkt. 44-2, E.D. Mich.)

Summary

A supplemental affidavit by defendant Cemhan Biricik in support of his supplemental motion to modify post-indictment seizure of assets, dated November 18, 2025 and filed November 20, 2025 as ECF No. 44-2 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 FastLab, which conducted and made available Covid testing, from about October 2021 to 2025, and that in January 2022 FastLab became authorized to receive electronic federal transfer payments. He states that many of the seized accounts were opened before FastLab began doing business and held funds from his and his wife's earlier business activities.

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Cite this document

“Affidavit in Support of Supplemental Motion to Modify Post-Indictment Seizure of Assets — No. 5:25-cr-20543 (Dkt. 44-2, E.D. Mich.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/affidavit-in-support-of-supplemental-motion-to-modify-post-indictment-2d3ef181b3/, SHA-256 0898e4de8d927854e0963e2822e8688038e984593992b5ce6cd07d52a822d302.

Full text

Case 5:25-cr-20543-JEL-KGA ECF No. 44-2, PageID.360 Filed 11/20/25 Page 1 of 2




                            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 SUPPLEMENTAL 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 my Supplemental Motion to Release Assets.

2.         As I previously stated in my Affidavit of September 30, 2025, 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. Prior to that time, I operated a photography and marketing business,

consulted on cryptocurrency investment, and ran other businesses.

4.         In January 2022, FastLab became authorized to receive electronic federal transfer

payments. As the government has outlined in its probable cause July 29, 2025 affidavits for the

seizures, those proceeds went into various accounts.

5.         Many of my accounts, however, were opened before FastLab started doing business.

These included, among others, Mavric Marketing Chase account x2663, SunTrust x2295,

Robinhood Brokerage x825420838, and Truist x1798. These accounts have been seized by the
Case 5:25-cr-20543-JEL-KGA ECF No. 44-2, PageID.361 Filed 11/20/25 Page 2 of 2



government, but they included funds generated by my business activities, and those of my wife,

prior to and independent of FastLab operations. I am able to substantiate that many of these

6.      Contemporaneously with my July 31, 2025 arrest, government officials seized all

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

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

seized by the government.

8.      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.

9.      I am also unable to pay certain legal costs I have incurred and will be incurring further to

defend the criminal charges in this case. I borrowed funds to make initial legal retainer payments but

further such funds are not available to me.

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

me to access some portion of the seized accounts.

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: November 18, 2025




                                                Cemhan Biricik
                                                9623 Macchiato Avenue
                                                Boca Raton, Florida 33496




                                                                                                         2

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