United States v. FRANCISCO ALBERTO LOPEZ REYES; JUAN EFREN PAULINO; JUAN MOISES PEREZ MENDEZ; SADIQ ABBAS HABIB SAYYED; KHIZAR MOHAMMAD IQBAL SHAIKH; WELLINGTON EUSTATE ESPINAL, et al., Southern District of New York (Sept. 30, 2024)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

v.

FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," JUAN EFREN PAULINO, a/k/a "Freddy," JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," KHIZAR MOHAMMAD IQBAL SHAIKH, WELLINGTON EUSTATE ESPINAL, a/k/a "Roni," HERIBERTO EUSTATE ESPINAL, a/k/a "Daulin," EUSEBIO PERALTA BAUTISTA, a/k/a "Luis Collazo Santos," HECTOR BIENVENIDO FELIZ FELIZ, a/k/a "Tacoma," LUIS PAULINO, MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," ALBA GONZALEZ, JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILANYI ALMANZAR POLANCO, Defendants.

SEALS

SUPERSEDING INDICTMENT

S8 23 Cr. 501 (JPC)

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and Drug Administration ("FDA") estimates that, at any given time, there are approximately 35,000 active online pharmacies. But according to the National Association of Boards of Pharmacy, only approximately five percent of those websites comply with United States pharmacy laws and practice standards.

2. The proliferation of unregulated online pharmacies has fueled the nation's fentanyl epidemic, enabling drug traffickers to peddle direct-to-consumer counterfeit pharmaceuticals, which are devoid of the medication they purport to contain and are instead comprised of deadly narcotics like fentanyl and its analogues. Fentanyl, a synthetic opioid fifty times more potent than heroin, has killed Americans at an unprecedented rate and is the leading cause of death for Americans between the ages of 18 and 45. Just two milligrams of fentanyl, equal to approximately ten to fifteen grains of table salt—an amount so tiny that it could fit on the tip of a pencil—is enough to kill a human being.

3. For at least the last two and a half years, a network of individuals located in the United States, the Dominican Republic, India, and elsewhere have exploited Americans' reliance on online pharmacies by advertising, selling, manufacturing, and shipping through the mail millions of unregulated counterfeit prescription pills to tens of thousands of victims. Instead of prescription drugs at a bargain, what customers actually received were phony pills made of fentanyl, para-fluorofentanyl—an analogue of fentanyl—and methamphetamine. Shaped, dyed, and stamped to be indistinguishable from actual prescription medication, these tablets were in fact manufactured by the defendants in industrial-scale milling facilities, or pill mills, located in the basements of several residential buildings in, among other places, Manhattan and the Bronx, New York.

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4. As part of this scheme, the defendants shipped counterfeit pharmaceuticals to victims across the United States and around the world, including in all 50 U.S. states, Washington, D.C., the U.S. Virgin Islands, Puerto Rico, Germany, and Slovenia. The victims of this criminal enterprise range in age from at least 23 to 77 years old. They include veterans, doctors, lawyers, musicians, artists, politicians, economists, restaurant managers, personal trainers, dancers, former schoolteachers, administrative executives, and first responders, among others. Some victims had legitimate prescriptions but could not obtain their medications through local brick-and-mortar pharmacies due to nationwide shortages.

5. The defendants preyed on people whom they characterized as "disabled" and "helpless." Some victims were in chronic pain from serious injuries—including those sustained in the line of duty—illness, or surgeries, and sought out prescription painkillers to manage their pain. Some victims sought medication to cope with anxiety, post-traumatic stress disorder, and other mental health difficulties. Others have battled long-term drug addiction.

6. Between in or about August 2023 and in or about June 2024, at least nine victims—all of whom purchased counterfeit prescription pills from the defendants—died of narcotics poisoning. One victim, Victim-1, a 45-year-old woman, was a veteran who had served for twelve years in the United States Army National Guard. Victim-1 believed she was purchasing 30-milligram oxycodone, also known as "M30s," from the defendants' online pharmacy, but the pills were, in fact, made of fentanyl and para-fluorofentanyl. Five days after receiving counterfeit oxycodone pills advertised, sold, manufactured, and shipped by the defendants, Victim-1 died from acute fentanyl intoxication.

7. FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, led the enterprise, orchestrating and controlling every facet of the scheme from the Dominican Republic.--- page 4 ---

With his co-conspirators, LOPEZ REYES set up dozens of online pharmacy websites, designed to appear legitimate in order to lure customers into buying, at reduced prices, tablets of fentanyl, para-fluorofentanyl, and methamphetamine disguised as real prescription medications, including oxycodone, hydrocodone, Adderall, and Xanax, among others. LOPEZ REYES also relied on others, including SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," KHIZAR MOHAMMAD IQBAL SHAIKH, and ALBA GONZALEZ, the defendants, to sell counterfeit pills to Americans over the internet and through encrypted messaging platforms.

8. To fulfill pill orders, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, enlisted JUAN EFREN PAULINO, a/k/a "Freddy," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, as his principal lieutenants to oversee the operation of multiple pill mills in New York City. At those pill mills, workers used dyes with specific colors and specialized equipment with custom molds to press powdered narcotics so as to mimic the color, shape, size, and markings of commercially manufactured prescription pills, at rates of up to 100,000 pills every 12 hours. Law enforcement raided at least three of these pill mills and two other narcotics storage locations, seizing approximately 625,000 counterfeit pills—the majority of which contained fentanyl, para-fluorofentanyl, and/or methamphetamine—six industrial pill presses, commercial mixers, industrial-grade gas masks, and more. At these facilities, law enforcement also seized staggering quantities of not yet processed narcotics. In total, law enforcement seized approximately 255 pounds of para-fluorofentanyl, 100 pounds of fentanyl, and 215 pounds of methamphetamine, in pill, powder, and crystal form. Each of these seizures were a mere snapshot in time, representing only a single day's working supply at these pill mills and storage locations. Multiple defendants—including EFREN PAULINO, PEREZ MENDEZ, WELLINGTON EUSTATE ESPINAL, a/k/a "Roni," HERIBERTO EUSTATE ESPINAL, a/k/a

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"Daulin," EUSEBIO PERALTA BAUTISTA, a/k/a "Luis Collazo Santos," HECTOR BIENVENIDO FELIZ FELIZ, a/k/a "Tacoma," and LUIS PAULINO, the defendants—worked at these pill mills day and night.

9. After the defendants manufactured the counterfeit pills containing fentanyl and methamphetamine, a network of shippers, including MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILIANYI ALMANZAR POLANCO, the defendants, packaged and mailed the pills to customers across the country at the direction of FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, who specified to whom and where to ship particular types and quantities of pills. After orders were delivered, the defendants and their co-conspirators bombarded customers with aggressive and manipulative marketing tactics to pressure their victims to order more illegal pills, including by providing unsolicited free samples via mail of counterfeit pills containing addictive and deadly fentanyl and near-daily outreach by phone call or text message. One victim had to block up to 30 phone numbers in an effort to stop the harassment.

I. THE DEFENDANTS SOLD ILLEGAL PILLS THROUGH ONLINE PHARMACY STOREFRONTS

10. As part of their scheme to traffic fentanyl and methamphetamine disguised as real pharmaceuticals, the defendants developed online pharmacy storefronts that they designed to appear legitimate. These e-commerce websites, some of which purported to be based in the United States, were operated by individuals abroad, including in India and the Dominican Republic. While the websites varied in appearance and sophistication, they all had in common a claim to sell safe prescription medications at discount prices. In reality, the websites purveyed deadly and illegal narcotics disguised as prescription pills.

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Curecog.com

11. Curecog.com ("Curecog") purported to be a "US-based online pharma store" "approved by the FDA," which "serve[s] affordable medicines ... approved by specialists and manufactured by trusted brands."1 Curecog, however, was neither legitimate nor FDA approved. Instead, Curecog was a fraudulent storefront that peddled the defendants' illicit controlled substances, including fentanyl. As described in more detail below, Victim-1 ordered purported oxycodone from Curecog. Five days after receiving her order, Victim-1 died from having ingested the fentanyl and para-fluorofentanyl pills disguised as oxycodone that she ordered from Curecog.

12. Curecog featured many aspects of a legitimate e-commerce platform. As depicted in the below screenshot of Curecog's homepage, a user could navigate by product category, click directly on a featured sale, search for particular merchandise, and place selected items into a digital cart. Curecog included an "About Us" page featuring stock photographs of doctors, a lengthy privacy policy, a copyright notice, and assurances on each of its webpages that it is an "online pharmacy site approved by the FDA" based in North Little Rock, Arkansas. In reality, however, Curecog was registered with a domain registration company based in Russia, and there is no company in Arkansas by the name "Curecog."

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13. Curecog offered 40 different types of prescription medications, including purported medications for pain (including oxycodone), attention deficit hyperactivity disorder (“ADHD”) (including Adderall), anxiety (including Xanax), “men[’s] health” (including Viagra), sleeping (including Ambien), and weight loss (including Meridia). Curecog featured a webpage for each of these pills, among others, that included photographs of the pills, explanations of what conditions they treat, warnings about potential health complications, and descriptions of potential side effects.

14. According to Curecog’s website, one of its “popular brands” was oxycodone, an addictive opioid pain reliever for which a prescription is required under United States law. A

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screenshot of the webpage for oxycodone is below and offers several types and dosages of the purported medication.

15. Curecog’s webpage for oxycodone included two different sections about safety: “Safety Measures You Need to Know” and “Safety Measures to Buy Oxycodone Online.” Curecog urged customers to “[b]e sure to thoroughly look into the pharmacy you are buying from,”

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and to "[t]ry to look for reviews and delivery proof." To that end, Curecog provided customers with so-called customer reviews, including a supposed five-star review depicted below:

Aspen Waters - October 20, 2023
Hi folks. I'm writing this review to express my gratitude towards Curecog. They have delivered my medicines safely, securely, and fast to my doorstep. Coming to the medicine Oxycodone 10 mg, I think it was a life savior for me. In terms of pain control, I would rate this medicine 10 out of 10.

16. Although the defendants and their co-conspirators designed Curecog to provide indicia of legitimacy, Curecog operated in a fashion markedly different from legal e-commerce sites. For instance, after a particular dosage of oxycodone was selected, placed in the digital cart, and ordered, the customer would receive a text message from an administrator of Curecog ("CC-1") directing the customer to call CC-1 to confirm and pay for the order. On or about September 6, 2024, for example, an undercover law enforcement officer placed an order for 30-milligram oxycodone pills from Curecog and, shortly thereafter, received a text from CC-1 requesting that the law enforcement officer call CC-1 to confirm his oxycodone order. On the call, CC-1 repeatedly assured the undercover officer of the high quality of the oxycodone pills and denied that the pills were mixed with other substances.

17. On or about September 20, 2024, CC-1 introduced the undercover law enforcement officer to CC-1's supervisor ("CC-2"). During a call on or about September 24, 2024, CC-2 told the undercover law enforcement officer, in sum and substance, that CC-2 operated over 40 websites from India through which he sold pills to American customers, many of whom CC-2 described as "helpless" and "disabled."

18. Victim-1 also ordered purported oxycodone from Curecog and spoke to CC-1. As described in more detail below, on or about February 12, 2024, Victim-1 placed an order with

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Curecog for anti-anxiety medication, and CC-1 directed Victim-1 to pay for the order by sending money electronically to ALBA GONZALEZ, the defendant. Victim-1 later emailed GONZALEZ to change that order to oxycodone. Following that change, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, fulfilled Victim-1’s order with counterfeit oxycodone pills. On or about February 16, 2024, ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," the defendant, in concert with EDWARD EUSTATE JIMENEZ, a/k/a "Chino," the defendant, shipped Victim-1’s package at LOPEZ REYES’s direction. Upon receipt of the pills, on or about February 20, 2024, Victim-1 searched the internet, attempting to determine if the pills she had received that day from Curecog were legitimate 30-milligram oxycodone tablets. Contrary to her internet findings, they were not. Days later, those pills would kill her. Victim-1’s cause of death was acute fentanyl intoxication.

Pharmacy Stores Online and Care Online Store

19. The defendants also worked with the operators of pharmacystoresonline.com ("Pharmacy Stores Online") and careonlinestore.com ("Care Online Store"), which appear to be designed using the same template. According to the nearly identical "About Us" webpages of these websites, Pharmacy Stores Online and Care Online Store each purported to be a "leading, credible and 100% authentic pharmacy store." As depicted below, the homepages of Pharmacy Stores Online and Care Online Store featured nearly identical design elements and contained, among other things, categories of pharmaceuticals for purchase, a search bar, featured products, contact information for salespeople scrolling across the top, and the ability to switch prices between U.S. Dollars and Great British Pounds. Pharmacy Stores Online claimed to be based in Los Angeles, California, while Care Online Stores purported to be based in Brooklyn, New York; both, in their respective FAQs, asserted, "We are located in USA and we have warehouse[s]

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located in USA, UK and Netherlands. “--- page 12 ---

21. On their websites, Pharmacy Stores Online and Care Online Store purported to sell medications for pain (including oxycodone), ADHD (including Adderall), and anxiety (including Xanax), among others.

22. Victim-2, a 39-year-old New Yorker, ordered from Pharmacy Stores Online after searching the internet using phrases such as “Adderall online.” Victim-2 was prescribed Adderall by his doctor, but could not fill his prescription at the pharmacy due to nationwide shortages. On approximately five occasions, between in or about October 2023 and in or about February 2024, Victim-2 placed orders for 90 Adderall pills from the defendants for approximately $400 to $600 per order. As described in more detail below, those orders were fulfilled by FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, who texted EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” MIGUEL CONCEPCION BRITO, and CYNTHIA ONEGA, the defendants, and directed them to send pills to Victim-2 at the address Victim-2 provided to Pharmacy Stores Online. Although Victim-2 ordered what he understood to be Adderall pills, LOPEZ REYES, EUSTATE JIMENEZ, CONCEPCION BRITO, and ONEGA sent Victim-2 pills made from methamphetamine that were pressed to resemble legitimate Adderall in color, shape, size, and imprint. Although Victim-2 believed the pills he received looked legitimate, upon taking the counterfeit Adderall, at some point, he became sick, anxious, and depressed for several days. Victim-2 then stopped ordering pills from the defendants. Even so, as described in more detail below, Victim-2 received repeated calls and messages asking if he wished to purchase more purported Adderall at a discount.

Your Pharmacy

23. In addition to fulfilling orders from websites like Cureog and Pharmacy Stores Online through his networks, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also directly controlled a number of online pharmacies, including yourpharmacy.online

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(“Your Pharmacy”). Your Pharmacy, which used a URL that contained a misspelling of the word “pharmacy,” purported to sell real prescription pharmaceuticals, such as oxy codone, hydrocodone, Xanax, and Adderall, but in reality, sold counterfeit pills disguised as legitimate pharmaceuticals.

24. As depicted below, Your Pharmacy’s homepage featured a phone number and email address, as well as featured sales, categories of pills, guarantees of free shipping, 24/7 support, secure payment, and a 30-day return policy.

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25. Your Pharmacy’s sales webpage for oxycodone, depicted below, featured a photograph of Your Pharmacy’s purported 30-milligram oxycodone pills, or M30s, containing an “M” on one side and a “30” over a median line on the other side.

26. Your Pharmacy’s image of the 30-milligram oxycodone pill appeared to have been downloaded directly a “Drug Fact Sheet” from the official website of the United States Drug Enforcement Administration (“DEA”) concerning counterfeit pills, which warned “[c]ounterfeit pills may contain lethal amounts of fentanyl or methamphetamine and are extremely dangerous because they often appear identical to legitimate prescription pills.” Your Pharmacy’s webpages did not feature the same warning. Pictured below are the DEA photograph of authentic oxycodone, and the identical Your Pharmacy photograph of the purported oxycodone it sells. The defendants used the image, below left, that customers could compare to the image, below right, that the DEA had provided in an attempt to protect the public, to convince customers the pills the defendants

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sold were genuine. In fact, Your Pharmacy's apparent 30-miligram oxycodone pills were actually made of fentanyl and para-fluorofentanyl.

Your Pharmacy

DEA Drug Fact Sheet

II. THE DEFENDANTS SOLD ILLEGAL PILLS THROUGH ENCRYPTED MESSAGING PLATFORMS

27. In addition to marketing their deadly counterfeit pills through fake pharmaceutical websites, the defendants also relied on word-of-mouth referrals and direct-to-consumer sales tactics in order to sell large volumes of narcotic drugs disguised as pharmaceutical pills.

Sayyed's Messaging Channel

28. Another seller of counterfeit pills in the scheme was SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," the defendant, an Indian national who worked from India to sell counterfeit pills to victims in the United States. Among other controlled substances, these counterfeit pills contained fentanyl, fentanyl analogues, and methamphetamine. In addition to selling these counterfeit pills, SAYYED also sold, without requiring any prescription, what appeared to be legitimate generic versions of prescription pharmaceutical pills manufactured in India.

29. For more than five years, SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," the defendant, sold counterfeit and legitimate pills over the phone, and through calls and text messages on encrypted messaging platforms such as WhatsApp and Signal. SAYYED sold hundreds of thousands of pills in the United States, including to large-scale drug dealers. For example, one customer in Louisiana, a reseller of the pills, ordered between approximately 5,000 and 10,000 pills per week from SAYYED. Two other customers of SAYYED located in North Carolina were also resellers of the counterfeit pills. In or about September 2023, law enforcement officers arrested the two North Carolina-based customers and found them in possession of approximately 100,000 counterfeit pills.

30. SADIQ AB BAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” the defendant, required no prescription for any of his pills and told customers that he had a vast and unlimited supply that could be delivered anywhere in the United States within about four to five days of the order being placed. To encourage more sales, he often provided customers with free samples of what appeared to be legitimate pills.

31. SADIQ AB BAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” the defendant, sold two kinds of pills—pills packed in “blister packs” and pills packed “loose.” Through his network in India, Bangladesh, and other countries, SAYYED claimed to have direct access to pills packed in “blister packs,” which are plastic and foil packaging designed to prevent tampering, by allowing a user to push individual pills out of the packaging. In private discussions, SAYYED claimed that the blister packs were genuine generic pharmaceutical products manufactured in India and shipped in bulk to the United States. Below is a photograph

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of blister pack pills that SAYYED mailed to New York in or about October 2023. These pills generally tested positive for the controlled substances that the pills purported to contain.

32. However, SADIQ ABBAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” the defendant, also sold loose pills outside of blister packs, including counterfeit Adderall, oxycodone, and hydrocodone that were manufactured using fentanyl and methamphetamine at multiple locations in United States—including through the networks controlled by FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant. When selling these pills, SAYYED required a minimum order of at least 90 or 120 pills.

33. In or about early February 2024, SADIQ ABBAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” the defendant, sold an undercover law enforcement officer nearly 400 pills that SAYYED claimed were oxycodone and Adderall. However, laboratory analysis confirmed that the pills, which were manufactured to resemble legitimate pharmaceuticals, were, in fact, made from para-fluorofentanyl and methamphetamine. The counterfeit pills SAYYED sold to the undercover law enforcement officer were shipped by EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, working under the direction of

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FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant. On a recorded call with the undercover law enforcement officer in or about August 2024, SAYYED stated, in sum and substance, that he knew the individuals making the loose pills used fentanyl because without it, the pills would not be high quality. Dismissing the harm he knew fentanyl caused, SAYYED told the undercover law enforcement officer, “it’s business.”

34. “KS Pharmacy” is a purported online pharmacy operated by KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, who sold from India what appeared to be pharmaceuticals through a WhatsApp account. In reality, however, SHAIKH fulfilled the orders he received through FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, and his network, and the purported oxycodone pills they supplied to customers were actually made with fentanyl.

35. For example, Victim-3, a 23-year-old man who has struggled with drug addiction and has previously sought treatment at a drug rehabilitation facility, searched for Xanax on the internet and left his phone number and a request for Xanax on a website intended to connect sellers and buyers of manufactured goods. Thereafter, KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, contacted Victim-3 through his “KS Pharmacy” WhatsApp account. Between in or about November 2023 and in or about February 2024, Victim-3 ordered counterfeit prescription pills from SHAIKH that were shipped to Victim-3 by the defendants.

36. In or about February 2024, Victim-3 placed an order via WhatsApp with KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, for 90 pills of 30-milligram oxycodone tablets. Later that month, a package was shipped to Victim-3 from EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, containing fentanyl pills that had been recently pressed in the defendants’ pill mills and disguised to look like legitimate oxycodone.--- page 19 ---

37. On or about February 26, 2024, KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, assured Victim-3 that nobody had ever overdosed from the defendants’ counterfeit oxycodone pills and that the fentanyl they contained was a “safe amount.” The exchange between SHAIKH and Victim-3 is below:

Victim-3: any fent?

SHAIKH: Maybe of safe amount

Victim-3: i know they have been cut i can tell

Victim-3: have any customers overdosed w these?

SHAIKH: Loose pressed may contain safe amount of fentanyl

SHAIKH: No

SHAIKH: Don’t worry, people reordering them

SHAIKH: Take care [Victim-3] have a blessed day 👍

Victim-3: okay

SHAIKH: Avoid high dosage take care sir

38. The day before this exchange, Victim-1 had died from fentanyl poisoning after ingesting the very same pills manufactured and sold by the defendants.

39. In or about August 2024, KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, using the KS Pharmacy WhatsApp account, agreed to sell to an undercover law enforcement officer 90 oxycodone pills. After they arrived in September 2024, the pills tested positive for fentanyl.

III. THE DEFENDANTS MANUFACTURED MILLIONS OF COUNTERFEIT PRESCRIPTION PILLS USING DEADLY NARCOTICS

40. The defendants sold fake prescription drugs that were manufactured at at least three industrial-scale pill mills located in the basements of residential buildings throughout New York City: (i) a mill located on Wadsworth Avenue in the Washington Heights neighborhood of New York, New York (the “Wadsworth Pill Mill”); (ii) a mill located on Beaumont Avenue in the Bronx, New York (the “Beaumont Pill Mill”); and (iii) a mill located on Gerard Avenue in the

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Bronx, New York (the "Gerard Pill Mill"). The pill mills were industrial-scale factories, each capable of producing over 100,000 pills in just 12 hours. The defendants combined powdered narcotics, including fentanyl, para-fluorofentanyl, and methamphetamine, with inert substances, which they purchased in bulk from wholesale retailers. The mixtures were then colored with dyes and pressed into pills using industrial-scale pill presses. These presses were fitted with die molds purchased by the defendants from vendors based in the People's Republic of China. The die molds shaped, compressed, and stamped powdered narcotics into solid tablets, so that the pills appeared to be legitimate pharmaceuticals complete with the same lettering and numbering. What appeared to be oxycodone, hydrocodone, and Percocet contained narcotics such as fentanyl and parafluorofentanyl; what appeared to be Adderall contained methamphetamine.

41. From the Dominican Republic, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, managed the pill mills. LOPEZ REYES funded the operations of the pill mills and trained others, including, JUAN EFREN PAULINO, a/k/a "Freddy," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, on how to press pills. LOPEZ REYES directed the production of the fake pharmaceuticals, specifying the quantity and types of pills to be produced. When the pills did not meet his specifications, either because the pills were not sufficiently potent or did not look similar enough to real pharmaceuticals, LOPEZ REYES ordered their reproduction.

42. The Wadsworth, Beaumont, and Gerard Pill Mills were manned by the defendants and other co-conspirators, who worked long shifts, spanning days, pressing deadly powdered narcotics into millions of counterfeit pharmaceutical pills to be shipped to victims around the United States and the world. When law enforcement disrupted one pill mill, the defendants would simply use another.

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The Wadsworth Pill Mill

43. The Wadsworth Pill Mill, which was hidden in the basement of a residential building in Manhattan, New York, was searched and shut down by law enforcement on or about May 31, 2023. There, law enforcement officers seized over 200,000 already-made pills as well as bricks, bags, and buckets filled with powdered narcotics ready to be pressed into pills, depicted, in part, in the photograph below. In total, law enforcement officers seized, among other narcotics, (i) more than 24 kilograms of para-fluorofentanyl, over seven kilograms of fentanyl, and approximately 40 kilograms of methamphetamine in the form of pills, and (ii) in the form of powder, approximately 14 kilograms of fentanyl, one kilogram of para-fluorofentanyl, and 1.9 kilograms of methamphetamine, which could be pressed into over 550,000 additional pills.

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44. Law enforcement officers also found the equipment used to transform powdered narcotics into pill form, including three commercial-grade pill presses and a commercial grade-mixer. One of the pill presses is pictured below on the left; the mixer is pictured below on the right.

45. JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, managed the operations of the Wadsworth Pill Mill. EFREN PAULINO employed approximately six individuals at the Wadsworth Pill Mill, including JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” and HECTOR BIENVENIDO FELIZ FELIZ, a/k/a “Tacoma,” the defendants. Working at the direction of EFREN PAULINO, these employees would, among other things, grind pills made of inert substances into powdered form; mix the inert substances with colored dyes and powdered narcotics like fentanyl, para-fluorofentanyl, and methamphetamine; press the narcotics mixtures into pills; clean, count, sort, and bag the pills for eventual distribution; deliver the pills to shippers; and clean the facility.

46. The employees of the Wadsworth Pill Mill also assisted JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, in procuring pill presses and parts for those presses. For example, on or about January 14, 2023, JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,”thought
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the defendant, who at the time was working for EFREN PAULINO at the Wadsworth Pill Mill, sent a message to EFREN PAULINO that stated, in sum and substance, that a die mold had arrived and sent the below photograph of a die mold, which was used to stamp powdered fentanyl mixtures into counterfeit oxycodone pills marked with a “M” and “30.”

47. From the Dominican Republic, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, was in frequent contact with JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, ordering him to increase production of pills in response to customer demand. For example, on or about April 12, 2022, LOPEZ REYES messaged EFREN PAULINO, instructing him, in sum and substance, “to make at least 20 thousand [fake oxycodone pills] ... Because I have clients waiting.”

48. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also instructed JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, on ways to produce higher quality pills at a large volume. For example, on or about April 9, 2022, LOPEZ REYES told EFREN PAULINO, in sum and substance, to use a particular blender that “grinds [] really well.

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It makes the [narcotics-mixture] finer without clumps.” LOPEZ REYES also instructed EFREN PAULINO to obtain, in sum and substance, “a minimum of two [pill press] machines.”

49. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” and JUAN EFREN PAULINO, a/k/a “Freddy,” the defendants, took other steps to ensure that the Wadsworth Pill Mill produced pills that closely resembled real pharmaceuticals. For example, on or about May 15, 2023, LOPEZ REYES sent EFREN PAULINO a photograph of pills accompanied by a voice note stating, in sum and substance, “We are having problems, Freddy, with the pills having two different colors. This can’t keep happening. It has to be an exact color. Ones are lighter than others, some bluer than others.”

50. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also directed JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, to increase the strength of the pills, by adding more narcotics. On at least one occasion, after LOPEZ REYES expressed his dissatisfaction with the potency of the fake pharmaceuticals produced at the Wadsworth Pill Mill, EFREN PAULINO ordered his employees to re-grind the pills. On or about May 24, 2023, LOPEZ REYES messaged EFREN PAULINO and stated, in sum and substance, “a lot of clients complained about the quality Adderall [sic].” EFREN PAULINO responded, in sum and substance, that he would make the pills stronger.

The Beaumont Pill Mill

51. The Beaumont Pill Mill, which was hidden in the basement of a residential building in the Bronx, New York, was searched and shut down by law enforcement officers on or about October 5, 2023. There, law enforcement officers seized (i) approximately nine kilograms of fentanyl and over 14 kilograms of methamphetamine in the form of approximately 97,000 pills;

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and (ii) over 12 kilograms of fentanyl and over seven kilograms of a mixture of para-fluorofentanyl fentanyl, heroin, caffeine, and other substances in the form of powder.

52. Law enforcement officers also recovered equipment used to press powdered narcotics into pills, including three industrial pill presses and one disassembled pill press, one kilogram press, blenders, dyes, and jars of calcium citrate.

53. The Beaumont Pill Mill was built to be a fentanyl, para-fluorofentanyl, and methamphetamine pill pressing factory. The first-floor windows of the Beaumont Pill Mill were covered with black trash bags and dark fabric, preventing outside observers from viewing what was occurring inside. The Beaumont Pill Mill was also equipped with a surveillance system, including a television screen displaying a live feed of security camera footage from outside the pill

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mill. A pill press and industrial-grade gas masks to protect workers from the deadly narcotics being pressed, recovered from the Beaumont Pill Mill, are depicted in the photographs below.

54. HERIBERTO EUSTATE ESPINAL, a/k/a “Daulin,” and WELLINGTON EUSTATE ESPINAL, a/k/a “Roni,” the defendants, managed the operations of the Beaumont Pill Mill, supervising EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, and two other individuals. These employees of the Beaumont Pill Mill, among other things, procured inert substances to be mixed with narcotics, counted and sorted pills, and cleaned the space in which the mill operated.

55. JUAN EFREN PAULINO, a/k/a “Freddy,” HERIBERTO EUSTATE ESPINAL, a/k/a “Daulin,” and WELLINGTON EUSTATE ESPINAL, a/k/a “Roni,” the defendants, worked closely together to manage continuing operations at their respective mills. When the pill presses at the Wadsworth Pill Mill were not working, EFREN PAULINO turned to the Beaumont Pill Mill as his source of pill manufacturing. Wadsworth Pill Mill workers also went to the Beaumont Pill Mill to obtain parts for pill presses.

2656. After law enforcement officers arrested JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, on or about May 31, 2023, and shut down the Wadsworth Pill Mill, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, turned to JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, to take over his pill manufacturing process in New York, although EFREN PAULINO continued to play an active role directing the organization’s operations from prison. With the Wadsworth Pill Mill closed, PEREZ MENDEZ began overseeing the pressing of counterfeit pills at the Beaumont Pill Mill. Pill manufacturing at the Beaumont Pill Mill was done primarily for PEREZ MENDEZ and under PEREZ MENDEZ’s direction; other pills were pressed at the direction of LUIS PAULINO, the defendant. PAULINO, for his part, also provided the Beaumont Pill Mill with real oxycodone pills that HERIBERTO EUSTATE ESPINAL, a/k/a “Daulin,” and WELLINGTON EUSTATE ESPINAL, a/k/a “Roni,” the defendants, used as samples to create realistic counterfeit oxycodone pills made from fentanyl for PAULINO and PEREZ MENDEZ. PEREZ MENDEZ provided die molds to shape the narcotics into pills, directed the Beaumont Pill Mill workers to manufacture pills that were uniform in color so that they looked real, inspected the pills to ensure that they appeared to accurately resemble legitimate pharmaceuticals, and personally participated in the pill manufacturing process itself. PEREZ MENDEZ also coordinated shipping the pills manufactured at the Beaumont Pill Mill to victims across the country at the direction of LOPEZ REYES.

The Gerard Pill Mill

57. The Gerard Pill Mill, which was hidden in the basement of a residential building in the Bronx, New York, was searched and shut down by law enforcement officers on or about April 6, 2024. There, law enforcement officers seized over 101,000 already-made pills, as well as powdered narcotics in powder form ready to be pressed into pills, depicted, in part, in the photograph below. In total, law enforcement officers seized (i) in the form of pills approximately 29 kilograms of para-fluorofentanyl and approximately 800 grams of methamphetamine; (ii) in the form of powder approximately 1.9 kilograms of fentanyl and 13 kilograms of methamphetamine; and (iii) in the form of crystal approximately 2.9 kilograms of methamphetamine.

58. Law enforcement officers also recovered the two industrial-scale pill presses, depicted below, as well as materials used to mix powdered narcotics with inert substance, and materials used to package narcotics for further distribution. Those items included mixing bowls,

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a blender, strainers, dyes, empty bottles of pills ground for filler, and thousands of glassine envelopes used to package the drugs.

59. JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” and EUSEBIO PERALTA BAUTISTA, a/k/a “Luis Collazo Santos,” the defendants, worked at the Gerard Pill Mill, pressing powdered narcotics into pills. PEREZ MENDEZ managed operations at the Gerard Pill Mill and reported directly to FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant. For example, on or about March 15, 2024, PEREZ MENDEZ texted LOPEZ REYES inventories of pills on hand, noting, among other things, that the mill had “32,000 – M30[s],” a reference to the “M” and “30” stamped into legitimately manufactured 30-milligram oxycodone pills. LOPEZ REYES ordered PEREZ MENDEZ to turn to producing counterfeit Adderall and hydrocodone. Similarly, on or about April 2, 2024, LOPEZ REYES ordered PEREZ MENDEZ, in sum and substance, to produce “more hydro m367,” a reference to the “M367” stamped into legitimately manufactured Vicodin, a prescription drug made principally from hydrocodone. On or about April 6, 2024, while discussing the manufacture of certain fake drugs, PEREZ MENDEZ messaged LOPEZ REYES, asking LOPEZ REYES, in sum and substance, “what’s printed on the front and

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what’s printed on the back of the orange ones?” LOPEZ REYES responded, in sum and substance, “AD and on the other side 30,” and included a photograph of what appear to be counterfeit Adderall pills.

60. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also funded the operations of the Gerard Pill Mill. For example, on or about April 3, 2024, LOPEZ REYES messaged JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, and tried to confirm whether PEREZ MENDEZ had received money so that PEREZ MENDEZ could produce “large quantities” of pills.

IV. SHIPPERS MAILED COUNTERFEIT PRESCRIPTION PILLS TO VICTIMS ACROSS THE UNITED STATES

61. To distribute the drugs he manufactured in basements in New York City and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, employed a network of shippers who mailed counterfeit pills created at the pill mills to victims across the country. LOPEZ REYES trained those shipping on his behalf on how to package the pills, provided the names and addresses of victims, the quantity and types of pills to send them, and shipping instructions, including whether to, for example, overnight the pills—information that he received from victims that ordered from websites or encrypted messaging applications operated by him and others. LOPEZ REYES designated a small percentage of victims to receive “la Buena,” “good,” or “la verdad” pills, indicating that the victims should receive genuine pills that were shipped in real pharmaceutical packaging. The vast majority of victims, however, received counterfeit pills that contained deadly narcotics like fentanyl or methamphetamine.

62. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also directed those shipping for him to launder money. Victims were told to pay for counterfeit pills by making payments through money transfer programs like Chime, PayPal, Apple Pay, Zelle,thought
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CashApp, and cryptocurrency. These shippers were, in turn, directed by LOPEZ REYES to transfer this money to others, including to people in the Dominican Republic, who ultimately transferred those funds to LOPEZ REYES.

CC-3

63. In or about 2022, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, recruited a new shipper ("CC-3"). CC-3 began shipping large quantities of pills—up to approximately 30 packages a day, six days per week—to victims across the country from post offices located throughout New Jersey and New York. LOPEZ REYES paid CC-3 between approximately $1,500 and $3,000 per week to ship counterfeit pills. CC-3, who was one of many shippers LOPEZ REYES employed, personally shipped packages to victims in more than 30 states. Each package contained, on average, between approximately 30 and 120 pills.

64. FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, chastised CC-3 when CC-3 sent customers incorrect pills and demanded that CC-3 carefully handle the pills, including by storing them at precise temperatures. LOPEZ REYES also directed CC-3 to change phones frequently and communicate with LOPEZ REYES exclusively through encrypted messaging applications.

65. JUAN EFREN PAULINO, a/k/a "Freddy," the defendant, supplied the pills that CC-3, in turn, shipped. EFREN PAULINO met CC-3 at locations throughout the Bronx and Manhattan and handed CC-3 backpacks containing thousands of pills. At the direction of FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, CC-3 provided EFREN PAULINO tens thousands of dollars from the money that CC-3 had received from victims.

Eustate Jimenez

66. In or about March 2023, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," and JUAN EFREN PAULINO, a/k/a "Freddy," the defendants, recruited EDWARD EUSTATE

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JIMENEZ, a/k/a “Chino,” the defendant, to ship packages of fake pills manufactured at the Wadsworth Pill Mill.

67. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” and JUAN EFREN PAULINO, a/k/a “Freddy,” the defendants, supervised the work of EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant. EFREN PAULINO provided EUSTATE JIMENEZ with pills and instructed EUSTATE JIMENEZ on how to package and mail the pills to victims. In turn, LOPEZ REYES sent EUSTATE JIMENEZ the pill orders, which included the types of pills to send, the quantity of pills, the names and addresses of the recipients, and the shipping instructions. EUSTATE JIMENEZ then packaged and mailed the pills from post offices located throughout Washington Heights and the Bronx in New York City.

68. After the arrest of JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, in or about May 2023, JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, began working with EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, to continue to ship narcotics to victims without pausing operations. For example, EUSTATE JIMENEZ periodically sent PEREZ MENDEZ audits of his pill supply, noting, for example, on or about December 11, 2023, that he had 25,000 counterfeit 30-milligram oxycodone pills on hand. In one voice note sent on or about December 12, 2023, by PEREZ MENDEZ to EUSTATE JIMENEZ, while they coordinated a pickup of pills, the sound of a pill press machine could be heard in the background. In another communication, on or about January 30, 2024, EUSTATE JIMENEZ informed PEREZ MENDEZ that he had 120,000 30-milligram oxycodone pills on hand. Photographs sent by

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EUSTATE JIMENEZ to PEREZ MENDEZ of thousands of counterfeit oxycodone, hydrocodone, and Adderall pills, respectively, are reproduced below:

69. EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, also recruited others to assist him in shipping pills, including WILIANYI ALMANZAR POLANCO and ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” the defendants. On or about February 26, 2024, EUSTATE JIMENEZ and ALMANZAR POLANCO were arrested at a post office in Manhattan while attempting to mail more than 35 packages containing over 4,000 fake prescription pills. The contents of two of the priority mail packages, containing counterfeit oxycodone and counterfeit Adderall, are pictured below.

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70. After arresting EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” and WILIANYI ALMANZAR POLANCO, the defendants, law enforcement officers searched EUSTATE JIMENEZ’s apartment in the Washington Heights neighborhood of New York, New York, where EUSTATE JIMENEZ distributed narcotics. During the search, law enforcement officers found, as depicted in part in the photograph below, approximately 83,000 counterfeit prescription pills, including fake Oxycontin, oxycodone, Adderall, and Xanax; 2,000 unused United States Postal Service (“USPS”) priority mail envelopes; and shipping receipts. In total, from the post office and EUSTATE JIMENEZ’s apartment, law enforcement officers seized approximately over 23 kilograms of para-fluorofentanyl, 1.8 kilograms of fentanyl, and 4.7 kilograms of methamphetamine, in the form of pills.

71. Over the course of just three months—from in or about December 2023 through the date of the arrest of EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, on or

34about February 26, 2024—EUSTATE JIMENEZ, with the assistance of WILIANYI ALMANZAR POLANCO and ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” the defendants, shipped at least approximately 1,800 packages containing approximately 328,000 counterfeit pills to victims living in all 50 U.S. states, Washington, D.C., Puerto Rico, and the U.S. Virgin Islands, including Victim-1, who died thereafter.

Onega and the Britos

72. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” and JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, recruited MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, JOSE CONCEPCION BRITO, and ANGEL VALDEZ BRITO, the defendants, to ship millions of fake pills to victims across the country.

73. MIGUEL CONCEPCION BRITO and CYNTHIA ONEGA, the defendants, received pills manufactured by JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, and his employees. MIGUEL CONCEPCION BRITO and ONEGA sorted and packaged the pills, and directed JOSE CONCEPCION BRITO and ANGEL VALDEZ BRITO, the defendants, to ship the packages to victims across the country according to the shipping instructions given to them by FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant. JOSE CONCEPCION BRITO and VALDEZ BRITO shipped victims approximately 70 packages per day for at least four months.

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74. MIGUEL CONCEPCION BRITO and CYNTHIA ONEGA, the defendants, packaged the pills in their apartment, where they lived with a young child, and stored narcotic pills in ONEGA’s vehicle. On or about December 4, 2023, law enforcement officers searched that vehicle and seized approximately 135,000 counterfeit pills containing approximately 30 kilograms of para-fluorofentanyl and approximately 17 kilograms of methamphetamine, including as depicted in part below.

75. Over the course of just four months—from in or about July 2023 through on or about December 4, 2023—MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, JOSE CONCEPCION BRITO, and ANGEL VALEZ BRITO, defendants, shipped at least approximately 4,500 packages containing at least approximately 580,000 counterfeit pills to approximately 2,200 unique victims. The victims lived in all 50 U.S. states, the U.S. Virgin Islands, and other countries including Germany and Slovenia.

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V. THE DEFENDANTS USED MANIPULATIVE MARKETING TO KEEP VICTIMS COMING BACK

76. Once pills had been delivered to a particular victim, the defendants developed strategies for ensuring that these victims continued to place orders through their network of online counterfeit pharmacies and messaging channels. These strategies included the provision of free “sample” pills as well as unrelenting manipulative marketing communications. The defendants found success in both approaches, targeting individuals who, in some cases, were already chemically dependent on the products that the defendants were aggressively pushing.

Free Samples

77. One way in which the defendants sought to ensure customers placed orders for purported prescription pills from their distribution channels, and not from some other source, was through the use of free samples of counterfeit drugs containing fentanyl.

78. At the direction of FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, CC-3 placed flyers advertising the defendants’ websites and other communication channels into many of the pill orders he fulfilled. When instructed to do so by LOPEZ REYES, CC-3 also often placed in those shipments an additional one to five pills along with the flyer. LOPEZ REYES directed CC-3 as to which customers were to receive the free samples, the number and type of pills that should be placed in the free samples, as well as what information to include in the flyers. The flyers, an example of which is depicted below, typically included a phone number and website where pills could be ordered, which LOPEZ REYES would periodically direct CC-3 to update as he opened new websites.

37

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Dear customer,

Do you need a good pharmacy service, with a good economic price? At [illegible] we have the best service and prices on the market....

To show our favorite customers that this is a guaranteed service. Here we are sending you a small sample of our service. [illegible] is a unique service, which guarantees you, to send your package the same day guaranteed!

For more information on, [illegible]

Contact us at: Phone +1 [illegible] https:// [illegible] com/

Thanks for everything,

Sincerely,

79. Victim-4, who was a 69-year-old grandmother from Tennessee, had begun ordering purported pharmaceuticals from the defendants in or about November 2023. On or about June 26, 2024, Victim-4 died of intoxication by fentanyl and other drugs. At the time of her death, Victim4 had counterfeit 30-milligram oxycodone pills in her home. The pills, which resembled legitimately manufactured oxycodone pills with the distinctive “M30” imprint, tested positive for fentanyl. After Victim-4 stopped ordering pills from the defendants because she had died of narcotics poisoning, the defendants sent to Victim-4’s home address one of these advertisements with free “sample” pills to try and encourage more orders. Specifically, on or about July 20, 2024—less than one month after Victim-4’s death—a package addressed to Victim-4 was delivered to her home. The package contained five counterfeit hydrocodone pills containing fentanyl that resembled the shape, color, and imprint of legitimate hydrocodone medication. Accompanying these pills was a flyer in which FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, claimed to have “the best price and the best quality on the market. Either

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wholesale or retail." The flyer noted that "if you do business with us, we will ship your order immediately," including through "one day delivery express mail with a tracking number so you can follow up on the package." After providing prices for 90, 180, 360, and 600 "tabs," the advertisement encouraged, "you can either contact us by number or email or [by] visiting our website," and listed a particular phone number as "customer care," a particular email address for "medscustomerservice," and the website for Your Pharmacy, discussed at length above.

80. FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, owned and operated both the Your Pharmacy website and the medscustomerservice email inbox ("Meds Customer Service"). From in or about April to in or about August 2024, the Meds Customer Service inbox received approximately 100 messages from individuals inquiring about pills, many of which referenced free samples of medication received alongside flyers advertising the email address. Several victims appeared to believe Meds Customer Service to be a legitimate pharmacy, with one victim writing he "may be interested in filling one of my prescriptions with you if prices are better than my current provider." Others ordering from Meds Customer Service inquired about quantities consistent with redistribution in street level drug dealing, with one individual seeking "600 percocet 600xanax and 600 hydro the Watson ones and 600 roxys." And others exhibited desperate drug-seeking behavior, including by sending six emails in four hours with pleas such as "PLEASE HELP ME??? U sent me a letter yesterday with a sample of ur product. I would like to purchase some but no one will contact me."

Manipulative Marketing

81. In addition to sending free samples, the defendants also employed manipulative or harassing marketing techniques to pressure victims of their scheme to continue making purchases of counterfeit pills. In particular, once an order was placed, the defendants and their coconspirators remained in near constant contact with their victims to offer additional narcotics and

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highlight supposed customer discounts. Victims reported receiving near daily outreach from the defendants or their co-conspirators via phone calls, text messages, emails, and encrypted messages about purchasing additional pills, to a degree that many victims found to be harassing. But even when these victims blocked the contact numbers, the defendants and their co-conspirators continued their outreach using new numbers. One victim (Victim-5), described in more detail below, reported blocking around 20 to 30 different phone numbers in an effort to stop receiving communications after having placed an order from the defendants.

82. Victim-2 experienced precisely this type of harassment. After making two purchases of Adderall from Pharmacy Stores Online, described in detail above, Victim-2 began receiving WhatsApp chats and text messages offering purported discounted Adderall and Ritalin, another ADHD drug. Between in or about April and June 2024, Victim-2 received approximately 19 different messages and several phone calls asking if he wished to purchase prescription drugs. For example, on or about May 22, 2024, Victim-2 received the message, “Hi [Victim-2] any order for me? Huge discount for Adderall and for Ritalin?” and then five days later, on or about May 27, 2024, received two messages, “Hi [Victim-2], how are you dear? Aderall [sic] and Ritalin is on discount would you like to order for any?” and “Hi [Victim-2], how are you dear? It’s Jennifer. would you like to order Ritalin or Adderall today with discount?”

83. Throughout in or about June 2024, Victim-2 again received similar, apparently automated messages, including: (i) On or about June 5, “Hi [Victim-2], how are you dear? It’s Jennifer[.] would you like to order Ritalin or Adderall today with discount?” (ii) On or about June 7, “Hi [Victim-2], It’s Jennifer. would you like to order Ritalin or Adderall today with discount?” (iii) On or about June 14, “Hi [Victim-2], how are you? It’s Jennifer. Any order for me?” (iv) On or about June 20, “Hi [Victim-2]we do have now Teva brand Adderall with $ sigh in USA stock.--- page 41 ---

Do let me know if you are interested to make order for that?” (v) On or about June 27, “Hi [Victim2], how are you? It’s Jennifer. Are you ready to make an order?” The penultimate message, from on or about June 20, 2024, included a photograph of purported Adderall. When these attempts to pressure Victim-2 into additional purchases of methamphetamine disguised as Adderall were unsuccessful, Victim-2 began receiving messages from another number, which stated, on or about June 20, 2024, “Hi [Victim-2], Just to let you know we got T va brand with $ marking for Adrl 30. Would you like to ordr [sic] for that?” and, on or about June 25, 2024, “Hi [Victim-2], Would you like to 0rdr for round Adrl 30. with best quality and with huge discounts?”

84. Similarly, Victim-5, a psychiatrist, was prescribed painkillers after receiving a knee replacement approximately one year ago, but, when her prescription ran out, she turned to online pharmacies to obtain oxycode without a prescription. In or about November 2023, after placing two orders for Percocet on a website operated by the defendants and their co-conspirators, Victim5 received the pills, which appeared to her to be fake. Thereafter, she started receiving numerous calls from individuals trying to sell her prescription pills. Even after she blocked some numbers, she would receive calls from other numbers trying to sell her prescription pills. She had to block dozens of phone numbers in order to stop receiving the defendants’ outreach.

85. Besides Victim-5, several customers who received pills from the defendants’ scheme reported to law enforcement officers that, after receiving their orders, they were bombarded with a huge volume of near daily phone calls or text messages from the individuals who sold the pills to pressure them to place more orders for counterfeit pills.

VI. VICTIM-1 WAS KILLED BY THE DEFENDANTS’ FENTANYL PILLS

86. As described above, thousands of individuals purchased counterfeit pharmaceuticals from the defendants and their co-conspirators; at least nine of those victims later died from narcotics poisonings.

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87. As described above, on or about February 12, 2024, Victim-1 placed an order from Curecog, operated by CC-1 and CC-2, for anti-anxiety medication but, on or about February 13, 2024, emailed ALBA GONZALEZ, the defendant, to request that her order be changed to “oxyxodone [sic].” Victim-1 did not have a prescription for oxycodone and neither GONZALEZ nor the operators of Curecog requested one.

88. On or about February 16, 2024, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, sent EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, a list of customer names, addresses, and pill orders for EUSTATE JIMENEZ to fulfil. Included in the list was Victim-1’s order: “oxy M30 90,” shorthand for 90 tablets of 30-milligram oxycodone. Seconds later, LOPEZ REYES replied to his own message to EUSTATE JIMENEZ containing the customer order list and, in sum and substance, clarified, “These are almost all oxy.”

89. Also on or about February 16, 2024, less than a half hour after receiving Victim-1’s order, EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, sent a photograph of Victim-1’s order to ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” the defendant. A few hours later, RAMOS HENRIQUEZ sent to EUSTATE JIMENEZ the below photograph of fake 30-milligram oxycodone pills, with an “M” on one side and the number “30”

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on the other, ready to be shipped, along with a USPS envelope addressed to Victim-1. The package was in fact shipped to Victim-1 shortly thereafter on or about February 16, 2024.

90. On or about February 20, 2024, the defendants’ package containing the purported oxycodone was delivered to Victim-1. That same day, Victim-1 searched the internet for indicia that the pills she had received were genuine pharmaceuticals. For example, she entered into a search engine “pill” and “pill identifier.” She also visited a pill identification website and searched, “M 30 Blue and Round.” The results of Victim-1’s internet search indicated that round, blue pills with an “M” on one side and “30” on the other are 30-milligram oxycodone pills; in other words, she was led to believe that the pills she had received were real prescription medication.

91. Shortly after Victim-1 received the defendants’ pills in the mail, she became severely ill, vomited for several consecutive days, and was unable to urinate—common symptoms of fentanyl poisoning. On or about February 24, 2024, Victim-1 sent a text message to her friend stating, in sum and substance, that she was using pain medications. The following day, on or about

43

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February 25, 2024—five days after Victim-1 received the defendants’ pills—her mother found Victim-1 unresponsive in bed. Soon after, emergency services responded to Victim-1’s home, and she was pronounced dead.

92. At Victim-1’s bedside were 46 of the blue pills, depicted below, that the defendants designed to appear to be 30-milligram oxycodone tablets. Despite what Victim-1 thought she had found on the internet about the safety of those pills, testing revealed what only the defendants knew: the pills were actually made of fentanyl and para-fluorofentanyl. Because Victim-1 ingested the fentanyl and para-fluorofentanyl distributed by the defendants through their false websites, deadly pill mills, and lethal shipments, Victim-1 died. Her cause of death was acute fentanyl intoxication.

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VII. STATUTORY ALLEGATIONS

COUNT ONE

(Continuing Criminal Enterprise)

The Grand Jury further charges:

93. The allegations contained in paragraphs 1 through 92 of this Superseding Indictment are incorporated as though fully set forth herein.

94. From at least in or about April 2022, up to and including on or about the date of the filing of this Superseding Indictment, in the Southern District of New York, the Dominican Republic, India, and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” JUAN EFREN PAULINO, a/k/a “Freddy,” and JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, and others known and unknown, engaged in a continuing criminal enterprise (the “Continuing Criminal Enterprise”), in that LOPEZ REYES, PAULINO, and PEREZ MENDEZ knowingly and intentionally participated in a continuing series of violations of Title 21, United States Code, Chapter 13, Subchapters I and II, including, among others, Violations One through Seven set forth below, undertaken by LOPEZ REYES, PAULINO, and PEREZ MENDEZ, in concert with five and more persons with respect to whom LOPEZ REYES, PAULINO, and PEREZ MENDEZ occupied a position of organizer, supervisor, and any position of management, and from which such continuing violations LOPEZ REYES, PAULINO, and PEREZ MENDEZ obtained substantial income and resources.

95. Furthermore, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, was the principal administrator, organizer, and leader of the Continuing Criminal Enterprise, which involved at least 300 times the quantity of mixtures and substances containing a detectable amount of (i) para-fluorofentanyl, an analogue of fentanyl, (ii) fentanyl, and (iii) methamphetamine, its salts, isomers, and salts of its isomers, as described in Title 21, United States Code, Section 841(b)(1)(B), and the Continuing Criminal Enterprise received $10 million and more in gross receipts during a 12-month period of its existence for the manufacture, importation, and distribution of para-fluorofentanyl, fentanyl, and methamphetamine, its salts, isomers, and salts of its isomers.

Violation One

96. From at least in or about April 2022, up to and including on or about the date of the filing of this Superseding Indictment, in the Southern District of New York, the Dominican Republic, India, and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," JUAN EFREN PAULINO, a/k/a "Freddy," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, and others known and unknown, knowingly and intentionally combined, conspired, confederated, and agreed together and with each other to distribute and possess with intent to distribute (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A), and 846; (ii) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A), and 846; (iii) 500 grams and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, and salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A), and 846; (iv) one kilogram and more of mixtures and substances containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A), and 846; and (v) 500 grams and more of mixtures and substances containing a detectable amount of cocaine, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(B), and 846.

46

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97. The use of such controlled substances resulted in the death of Victim-1 on or about February 25, 2024, in Dover, Delaware.

Violation Two

98. On or about May 31, 2023, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” and JUAN EFREN PAULINO, a/k/a “Freddy,” JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, knowingly and intentionally distributed and possessed with the intent to distribute (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A); (ii) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A); (iii) 500 grams and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, and salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A); (iv) 100 grams and more of mixtures and substances containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(B); and (v) 500 grams and more of mixtures and substances containing a detectable amount of cocaine, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(B), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

Violation Three

99. On or about October 5, 2023, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” JUAN EFREN PAULINO, a/k/a “Freddy,” and JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, knowingly--- page 48 ---

and intentionally distributed and possessed with the intent to distribute: (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl; (ii) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl; (iii) 500 grams and more of mixtures and substances containing a detectable amount of methamphetamine; and (iv) one kilogram and more of mixtures and substances containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

Violation Four

100. On or about December 4, 2023, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, knowingly and intentionally distributed and possessed with the intent to distribute: (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl; and (ii) 500 grams and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, and salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

Violation Five

101. On or about February 16, 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, knowingly and intentionally distributed and possessed with intent to distribute: (i) mixtures and substances containing a detectable amount of fentanyl; and (ii) mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

102. The use of such controlled substances resulted in the death of Victim-1 on or about February 25, 2024, in Dover, Delaware.

Violation Six

103. On or about February 26, 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, knowingly and intentionally distributed and possessed with intent to distribute: (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl; (ii) 400 grams and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

Violation Seven

104. On or about April 6, 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, knowingly and intentionally distributed and possessed with the intent to distribute: (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl; (ii) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl; and (iii) 500 grams

--- page 50 ---

and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

(Title 21, United States Code, Sections 848(a), 848(b), and 848(c); and Title 18, United States Code, Section 2.)

COUNT TWO
(Conspiracy to Distribute Narcotics Resulting in Death)

The Grand Jury further charges:

105. From at least in or about April 2022, up to and including on or about the date of the filing of this Superseding Indictment, in the Southern District of New York, the Dominican Republic, India, and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," JUAN EFREN PAULINO, a/k/a "Freddy," JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," KHIZAR MOHAMMAD IQBAL SHAIKH, WELLINGTON EUSTATE ESPINAL, a/k/a "Roni," HERIBERTO EUSTATE ESPINAL, a/k/a "Daulin," EUSEBIO PERALTA BAUTISTA, a/k/a "Luis Collazo Santos," HECTOR BIENVENIDO FELIZ FELIZ, a/k/a "Tacoma," LUIS PAULINO, MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," ALBA GONZALEZ, JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILIANYI ALMANZAR POLANCO, the defendants, and others known and unknown, knowingly and intentionally combined, conspired, confederated, and agreed together and with each other to violate the controlled substance laws of the United States.

50--- page 51 ---

106. It was a part and an object of the conspiracy that FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," JUAN EFREN PAULINO, a/k/a "Freddy," JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," KHIZAR MOHAMMAD IQBAL SHAIKH, WELLINGTON EUSTATE ESPINAL, a/k/a "Roni," HERIBERTO EUSTATE ESPINAL, a/k/a "Daulin," EUSEBIO PERALTA BAUTISTA, a/k/a "Luis Collazo Santos," HECTOR BIENVENIDO FELIZ FELIZ, a/k/a "Tacoma," LUIS PAULINO, MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," ALBA GONZALEZ, JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILIANYI ALMANZAR POLANCO, the defendants, and others known and unknown, would and did distribute and possess with intent to distribute controlled substances, in violation of Title 21, United States Code, Section 841(a)(1).

--- page 52 ---

108. The use of such controlled substances resulted in the death of Victim-1 on or about February 25, 2024, in Dover, Delaware.

(Title 21, United States Code, Section 846.)

COUNT THREE
(Distribution of Narcotics Resulting in Death)

The Grand Jury further charges:

109. On or about February 16, 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," ALBA GONZALEZ, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," and ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," the defendants, knowingly and intentionally distributed and possessed with intent to distribute controlled substances, in violation of Title 21, United States Code, Section 841(a)(1), and aided and abetted the same.

110. The controlled substances involved in the offense were: (i) mixtures and substances containing a detectable amount of fentanyl; and (ii) mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl, in violation of Title 21, United States Code, Section 841(b)(1)(C).

111. The use of such controlled substances resulted in the death of Victim-1 on or about February 25, 2024, in Dover, Delaware.

(Title 21, United States Code, Sections 812, 841(a)(1), 841(b)(1)(C); Title 18, United States Code, Section 2)

COUNT FOUR
(Conspiracy to Commit Money Laundering)

The Grand Jury further charges:

112. From at least in or about May 2022 through at least in or about February 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES,
a/k/a "Frank," the defendant, and others known and unknown, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to commit money laundering, in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and (a)(2)(B)(i).

113. It was a part and an object of the conspiracy that FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, and others known and unknown, knowing that the property involved in a financial transaction represented the proceeds of some form of unlawful activity, would and did conduct and attempt to conduct such a financial transaction, which transaction affected interstate and foreign commerce and involved the use of a financial institution which was engaged in, and the activities of which affected, interstate and foreign commerce, and which in fact involved the proceeds of specified unlawful activity, to wit, felonious narcotics offenses, in violation of Title 21, United States Code, Section 841, knowing that the transaction was designed in whole and in part to conceal and disguise the nature, the location, the source, the ownership, and the control of the proceeds of specified unlawful activity, in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).

114. It was further a part and an object of the conspiracy that FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, and others known and unknown, would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer, a monetary instrument and funds from a place in the United States to and through a place outside the United States, and to a place in the United States from and through a place outside the United States, knowing that the monetary instrument and funds represented the proceeds of some form of unlawful activity, and knowing that the transaction was designed in whole or in part to conceal and disguise the nature, the location, the source, the ownership, and the control of the proceeds of--- page 54 ---

specified unlawful activity, to wit, felonious narcotics offenses, in violation of Title 21, United States Code, Section 841, in violation of Title 18, United States Code, Section 1956(a)(2)(B)(i).

(Title 18, United States Code, Section 1956(h).)

FORFEITURE ALLEGATION

115. As a result of committing the controlled substance offense charged in Count One of this Indictment, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” JUAN EFREN PAULINO, a/k/a “Freddy,” and JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853, any and all property constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said offense, any and all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, said offense, and any and all interest in, claims against, and property and contractual rights affording a source of control over the continuing criminal enterprise described in Count One of this Indictment, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of the offense.

116. As a result of committing the offenses alleged in Count Two of this Indictment, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” JUAN EFREN PAULINO, a/k/a “Freddy,” JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” SADIQ ABBAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” KHIZAR MOHAMMAD IQBAL SHAIKH, WELLINGTON EUSTATE ESPINAL, a/k/a “Roni,” HERIBERTO EUSTATE ESPINAL, a/k/a “Daulin,” EUSEBIO PERALTA BAUTISTA, a/k/a “Luis Collazo Santos,” HECTOR BIENVENIDO FELIZ FELIZ, a/k/a “Tacoma,” LUIS PAULINO, MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a “Chino,”

--- page 55 ---

ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” ALBA GONZALEZ, JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILIANYI ALMANZAR POLANCO, and the defendants, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853, any and all property constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said offense, and any and all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, said offense, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of said offense.

117. As a result of committing the offenses alleged in Count Three of this Indictment, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” ALBA GONZALEZ, EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” and ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” the defendants, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853, any and all property constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said offense, and any and all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, said offense, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of said offense.

118. As a result of committing the offense alleged in Count Four of this Indictment, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(1), any and all property, real and personal, involved in said offense, or any property traceable to such property, including but not limited to a sum of money in United States currency representing the amount of property involved in said offense.

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Substitute Assets Provision

119. If any of the above-described forfeitable property, as a result of any act or omission of the defendants:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third person;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.

(Title 21, United States Code, Section 853.)

56

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

v.

FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," JUAN EFREN PAULINO, a/k/a "Freddy," JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," KHIZAR MOHAMMAD IQBAL SHAIKH, WELLINGTON EUSTATE ESPINAL, a/k/a "Roni," HERIBERTO EUSTATE ESPINAL, a/k/a "Daulin," EUSEBIO PERALTA BAUTISTA, a/k/a "Luis Collazo Santos," HECTOR BIENVENIDO FELIZ FELIZ, a/k/a "Tacoma," LUIS PAULINO, MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," ALBA GONZALEZ, JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILANYI ALMANZAR POLANCO, Defendants.

SEALS

SUPERSEDING INDICTMENT

S8 23 Cr. 501 (JPC)

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and Drug Administration ("FDA") estimates that, at any given time, there are approximately 35,000 active online pharmacies. But according to the National Association of Boards of Pharmacy, only approximately five percent of those websites comply with United States pharmacy laws and practice standards.

2. The proliferation of unregulated online pharmacies has fueled the nation's fentanyl epidemic, enabling drug traffickers to peddle direct-to-consumer counterfeit pharmaceuticals, which are devoid of the medication they purport to contain and are instead comprised of deadly narcotics like fentanyl and its analogues. Fentanyl, a synthetic opioid fifty times more potent than heroin, has killed Americans at an unprecedented rate and is the leading cause of death for Americans between the ages of 18 and 45. Just two milligrams of fentanyl, equal to approximately ten to fifteen grains of table salt—an amount so tiny that it could fit on the tip of a pencil—is enough to kill a human being.

3. For at least the last two and a half years, a network of individuals located in the United States, the Dominican Republic, India, and elsewhere have exploited Americans' reliance on online pharmacies by advertising, selling, manufacturing, and shipping through the mail millions of unregulated counterfeit prescription pills to tens of thousands of victims. Instead of prescription drugs at a bargain, what customers actually received were phony pills made of fentanyl, para-fluorofentanyl—an analogue of fentanyl—and methamphetamine. Shaped, dyed, and stamped to be indistinguishable from actual prescription medication, these tablets were in fact manufactured by the defendants in industrial-scale milling facilities, or pill mills, located in the basements of several residential buildings in, among other places, Manhattan and the Bronx, New York.

--- page 3 ---

4. As part of this scheme, the defendants shipped counterfeit pharmaceuticals to victims across the United States and around the world, including in all 50 U.S. states, Washington, D.C., the U.S. Virgin Islands, Puerto Rico, Germany, and Slovenia. The victims of this criminal enterprise range in age from at least 23 to 77 years old. They include veterans, doctors, lawyers, musicians, artists, politicians, economists, restaurant managers, personal trainers, dancers, former schoolteachers, administrative executives, and first responders, among others. Some victims had legitimate prescriptions but could not obtain their medications through local brick-and-mortar pharmacies due to nationwide shortages.

5. The defendants preyed on people whom they characterized as "disabled" and "helpless." Some victims were in chronic pain from serious injuries—including those sustained in the line of duty—illness, or surgeries, and sought out prescription painkillers to manage their pain. Some victims sought medication to cope with anxiety, post-traumatic stress disorder, and other mental health difficulties. Others have battled long-term drug addiction.

6. Between in or about August 2023 and in or about June 2024, at least nine victims—all of whom purchased counterfeit prescription pills from the defendants—died of narcotics poisoning. One victim, Victim-1, a 45-year-old woman, was a veteran who had served for twelve years in the United States Army National Guard. Victim-1 believed she was purchasing 30-milligram oxycodone, also known as "M30s," from the defendants' online pharmacy, but the pills were, in fact, made of fentanyl and para-fluorofentanyl. Five days after receiving counterfeit oxycodone pills advertised, sold, manufactured, and shipped by the defendants, Victim-1 died from acute fentanyl intoxication.

7. FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, led the enterprise, orchestrating and controlling every facet of the scheme from the Dominican Republic.--- page 4 ---

With his co-conspirators, LOPEZ REYES set up dozens of online pharmacy websites, designed to appear legitimate in order to lure customers into buying, at reduced prices, tablets of fentanyl, para-fluorofentanyl, and methamphetamine disguised as real prescription medications, including oxycodone, hydrocodone, Adderall, and Xanax, among others. LOPEZ REYES also relied on others, including SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," KHIZAR MOHAMMAD IQBAL SHAIKH, and ALBA GONZALEZ, the defendants, to sell counterfeit pills to Americans over the internet and through encrypted messaging platforms.

8. To fulfill pill orders, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, enlisted JUAN EFREN PAULINO, a/k/a "Freddy," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, as his principal lieutenants to oversee the operation of multiple pill mills in New York City. At those pill mills, workers used dyes with specific colors and specialized equipment with custom molds to press powdered narcotics so as to mimic the color, shape, size, and markings of commercially manufactured prescription pills, at rates of up to 100,000 pills every 12 hours. Law enforcement raided at least three of these pill mills and two other narcotics storage locations, seizing approximately 625,000 counterfeit pills—the majority of which contained fentanyl, para-fluorofentanyl, and/or methamphetamine—six industrial pill presses, commercial mixers, industrial-grade gas masks, and more. At these facilities, law enforcement also seized staggering quantities of not yet processed narcotics. In total, law enforcement seized approximately 255 pounds of para-fluorofentanyl, 100 pounds of fentanyl, and 215 pounds of methamphetamine, in pill, powder, and crystal form. Each of these seizures were a mere snapshot in time, representing only a single day's working supply at these pill mills and storage locations. Multiple defendants—including EFREN PAULINO, PEREZ MENDEZ, WELLINGTON EUSTATE ESPINAL, a/k/a "Roni," HERIBERTO EUSTATE ESPINAL, a/k/a

--- page 5 ---

"Daulin," EUSEBIO PERALTA BAUTISTA, a/k/a "Luis Collazo Santos," HECTOR BIENVENIDO FELIZ FELIZ, a/k/a "Tacoma," and LUIS PAULINO, the defendants—worked at these pill mills day and night.

9. After the defendants manufactured the counterfeit pills containing fentanyl and methamphetamine, a network of shippers, including MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILIANYI ALMANZAR POLANCO, the defendants, packaged and mailed the pills to customers across the country at the direction of FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, who specified to whom and where to ship particular types and quantities of pills. After orders were delivered, the defendants and their co-conspirators bombarded customers with aggressive and manipulative marketing tactics to pressure their victims to order more illegal pills, including by providing unsolicited free samples via mail of counterfeit pills containing addictive and deadly fentanyl and near-daily outreach by phone call or text message. One victim had to block up to 30 phone numbers in an effort to stop the harassment.

I. THE DEFENDANTS SOLD ILLEGAL PILLS THROUGH ONLINE PHARMACY STOREFRONTS

10. As part of their scheme to traffic fentanyl and methamphetamine disguised as real pharmaceuticals, the defendants developed online pharmacy storefronts that they designed to appear legitimate. These e-commerce websites, some of which purported to be based in the United States, were operated by individuals abroad, including in India and the Dominican Republic. While the websites varied in appearance and sophistication, they all had in common a claim to sell safe prescription medications at discount prices. In reality, the websites purveyed deadly and illegal narcotics disguised as prescription pills.

5

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Curecog.com

11. Curecog.com ("Curecog") purported to be a "US-based online pharma store" "approved by the FDA," which "serve[s] affordable medicines ... approved by specialists and manufactured by trusted brands."1 Curecog, however, was neither legitimate nor FDA approved. Instead, Curecog was a fraudulent storefront that peddled the defendants' illicit controlled substances, including fentanyl. As described in more detail below, Victim-1 ordered purported oxycodone from Curecog. Five days after receiving her order, Victim-1 died from having ingested the fentanyl and para-fluorofentanyl pills disguised as oxycodone that she ordered from Curecog.

12. Curecog featured many aspects of a legitimate e-commerce platform. As depicted in the below screenshot of Curecog's homepage, a user could navigate by product category, click directly on a featured sale, search for particular merchandise, and place selected items into a digital cart. Curecog included an "About Us" page featuring stock photographs of doctors, a lengthy privacy policy, a copyright notice, and assurances on each of its webpages that it is an "online pharmacy site approved by the FDA" based in North Little Rock, Arkansas. In reality, however, Curecog was registered with a domain registration company based in Russia, and there is no company in Arkansas by the name "Curecog."

6--- page 7 ---

13. Curecog offered 40 different types of prescription medications, including purported medications for pain (including oxycodone), attention deficit hyperactivity disorder (“ADHD”) (including Adderall), anxiety (including Xanax), “men[’s] health” (including Viagra), sleeping (including Ambien), and weight loss (including Meridia). Curecog featured a webpage for each of these pills, among others, that included photographs of the pills, explanations of what conditions they treat, warnings about potential health complications, and descriptions of potential side effects.

14. According to Curecog’s website, one of its “popular brands” was oxycodone, an addictive opioid pain reliever for which a prescription is required under United States law. A

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screenshot of the webpage for oxycodone is below and offers several types and dosages of the purported medication.

15. Curecog’s webpage for oxycodone included two different sections about safety: “Safety Measures You Need to Know” and “Safety Measures to Buy Oxycodone Online.” Curecog urged customers to “[b]e sure to thoroughly look into the pharmacy you are buying from,”

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and to "[t]ry to look for reviews and delivery proof." To that end, Curecog provided customers with so-called customer reviews, including a supposed five-star review depicted below:

Aspen Waters - October 20, 2023
Hi folks. I'm writing this review to express my gratitude towards Curecog. They have delivered my medicines safely, securely, and fast to my doorstep. Coming to the medicine Oxycodone 10 mg, I think it was a life savior for me. In terms of pain control, I would rate this medicine 10 out of 10.

16. Although the defendants and their co-conspirators designed Curecog to provide indicia of legitimacy, Curecog operated in a fashion markedly different from legal e-commerce sites. For instance, after a particular dosage of oxycodone was selected, placed in the digital cart, and ordered, the customer would receive a text message from an administrator of Curecog ("CC-1") directing the customer to call CC-1 to confirm and pay for the order. On or about September 6, 2024, for example, an undercover law enforcement officer placed an order for 30-milligram oxycodone pills from Curecog and, shortly thereafter, received a text from CC-1 requesting that the law enforcement officer call CC-1 to confirm his oxycodone order. On the call, CC-1 repeatedly assured the undercover officer of the high quality of the oxycodone pills and denied that the pills were mixed with other substances.

17. On or about September 20, 2024, CC-1 introduced the undercover law enforcement officer to CC-1's supervisor ("CC-2"). During a call on or about September 24, 2024, CC-2 told the undercover law enforcement officer, in sum and substance, that CC-2 operated over 40 websites from India through which he sold pills to American customers, many of whom CC-2 described as "helpless" and "disabled."

18. Victim-1 also ordered purported oxycodone from Curecog and spoke to CC-1. As described in more detail below, on or about February 12, 2024, Victim-1 placed an order with

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Curecog for anti-anxiety medication, and CC-1 directed Victim-1 to pay for the order by sending money electronically to ALBA GONZALEZ, the defendant. Victim-1 later emailed GONZALEZ to change that order to oxycodone. Following that change, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, fulfilled Victim-1’s order with counterfeit oxycodone pills. On or about February 16, 2024, ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," the defendant, in concert with EDWARD EUSTATE JIMENEZ, a/k/a "Chino," the defendant, shipped Victim-1’s package at LOPEZ REYES’s direction. Upon receipt of the pills, on or about February 20, 2024, Victim-1 searched the internet, attempting to determine if the pills she had received that day from Curecog were legitimate 30-milligram oxycodone tablets. Contrary to her internet findings, they were not. Days later, those pills would kill her. Victim-1’s cause of death was acute fentanyl intoxication.

Pharmacy Stores Online and Care Online Store

19. The defendants also worked with the operators of pharmacystoresonline.com ("Pharmacy Stores Online") and careonlinestore.com ("Care Online Store"), which appear to be designed using the same template. According to the nearly identical "About Us" webpages of these websites, Pharmacy Stores Online and Care Online Store each purported to be a "leading, credible and 100% authentic pharmacy store." As depicted below, the homepages of Pharmacy Stores Online and Care Online Store featured nearly identical design elements and contained, among other things, categories of pharmaceuticals for purchase, a search bar, featured products, contact information for salespeople scrolling across the top, and the ability to switch prices between U.S. Dollars and Great British Pounds. Pharmacy Stores Online claimed to be based in Los Angeles, California, while Care Online Stores purported to be based in Brooklyn, New York; both, in their respective FAQs, asserted, "We are located in USA and we have warehouse[s]

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located in USA, UK and Netherlands. “--- page 12 ---

21. On their websites, Pharmacy Stores Online and Care Online Store purported to sell medications for pain (including oxycodone), ADHD (including Adderall), and anxiety (including Xanax), among others.

22. Victim-2, a 39-year-old New Yorker, ordered from Pharmacy Stores Online after searching the internet using phrases such as “Adderall online.” Victim-2 was prescribed Adderall by his doctor, but could not fill his prescription at the pharmacy due to nationwide shortages. On approximately five occasions, between in or about October 2023 and in or about February 2024, Victim-2 placed orders for 90 Adderall pills from the defendants for approximately $400 to $600 per order. As described in more detail below, those orders were fulfilled by FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, who texted EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” MIGUEL CONCEPCION BRITO, and CYNTHIA ONEGA, the defendants, and directed them to send pills to Victim-2 at the address Victim-2 provided to Pharmacy Stores Online. Although Victim-2 ordered what he understood to be Adderall pills, LOPEZ REYES, EUSTATE JIMENEZ, CONCEPCION BRITO, and ONEGA sent Victim-2 pills made from methamphetamine that were pressed to resemble legitimate Adderall in color, shape, size, and imprint. Although Victim-2 believed the pills he received looked legitimate, upon taking the counterfeit Adderall, at some point, he became sick, anxious, and depressed for several days. Victim-2 then stopped ordering pills from the defendants. Even so, as described in more detail below, Victim-2 received repeated calls and messages asking if he wished to purchase more purported Adderall at a discount.

Your Pharmacy

23. In addition to fulfilling orders from websites like Cureog and Pharmacy Stores Online through his networks, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also directly controlled a number of online pharmacies, including yourpharmacy.online

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(“Your Pharmacy”). Your Pharmacy, which used a URL that contained a misspelling of the word “pharmacy,” purported to sell real prescription pharmaceuticals, such as oxy codone, hydrocodone, Xanax, and Adderall, but in reality, sold counterfeit pills disguised as legitimate pharmaceuticals.

24. As depicted below, Your Pharmacy’s homepage featured a phone number and email address, as well as featured sales, categories of pills, guarantees of free shipping, 24/7 support, secure payment, and a 30-day return policy.

13

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25. Your Pharmacy’s sales webpage for oxycodone, depicted below, featured a photograph of Your Pharmacy’s purported 30-milligram oxycodone pills, or M30s, containing an “M” on one side and a “30” over a median line on the other side.

26. Your Pharmacy’s image of the 30-milligram oxycodone pill appeared to have been downloaded directly a “Drug Fact Sheet” from the official website of the United States Drug Enforcement Administration (“DEA”) concerning counterfeit pills, which warned “[c]ounterfeit pills may contain lethal amounts of fentanyl or methamphetamine and are extremely dangerous because they often appear identical to legitimate prescription pills.” Your Pharmacy’s webpages did not feature the same warning. Pictured below are the DEA photograph of authentic oxycodone, and the identical Your Pharmacy photograph of the purported oxycodone it sells. The defendants used the image, below left, that customers could compare to the image, below right, that the DEA had provided in an attempt to protect the public, to convince customers the pills the defendants

14

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sold were genuine. In fact, Your Pharmacy's apparent 30-miligram oxycodone pills were actually made of fentanyl and para-fluorofentanyl.

Your Pharmacy

DEA Drug Fact Sheet

II. THE DEFENDANTS SOLD ILLEGAL PILLS THROUGH ENCRYPTED MESSAGING PLATFORMS

27. In addition to marketing their deadly counterfeit pills through fake pharmaceutical websites, the defendants also relied on word-of-mouth referrals and direct-to-consumer sales tactics in order to sell large volumes of narcotic drugs disguised as pharmaceutical pills.

Sayyed's Messaging Channel

28. Another seller of counterfeit pills in the scheme was SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," the defendant, an Indian national who worked from India to sell counterfeit pills to victims in the United States. Among other controlled substances, these counterfeit pills contained fentanyl, fentanyl analogues, and methamphetamine. In addition to selling these counterfeit pills, SAYYED also sold, without requiring any prescription, what appeared to be legitimate generic versions of prescription pharmaceutical pills manufactured in India.

29. For more than five years, SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," the defendant, sold counterfeit and legitimate pills over the phone, and through calls and text messages on encrypted messaging platforms such as WhatsApp and Signal. SAYYED sold hundreds of thousands of pills in the United States, including to large-scale drug dealers. For example, one customer in Louisiana, a reseller of the pills, ordered between approximately 5,000 and 10,000 pills per week from SAYYED. Two other customers of SAYYED located in North Carolina were also resellers of the counterfeit pills. In or about September 2023, law enforcement officers arrested the two North Carolina-based customers and found them in possession of approximately 100,000 counterfeit pills.

30. SADIQ AB BAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” the defendant, required no prescription for any of his pills and told customers that he had a vast and unlimited supply that could be delivered anywhere in the United States within about four to five days of the order being placed. To encourage more sales, he often provided customers with free samples of what appeared to be legitimate pills.

31. SADIQ AB BAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” the defendant, sold two kinds of pills—pills packed in “blister packs” and pills packed “loose.” Through his network in India, Bangladesh, and other countries, SAYYED claimed to have direct access to pills packed in “blister packs,” which are plastic and foil packaging designed to prevent tampering, by allowing a user to push individual pills out of the packaging. In private discussions, SAYYED claimed that the blister packs were genuine generic pharmaceutical products manufactured in India and shipped in bulk to the United States. Below is a photograph

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of blister pack pills that SAYYED mailed to New York in or about October 2023. These pills generally tested positive for the controlled substances that the pills purported to contain.

32. However, SADIQ ABBAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” the defendant, also sold loose pills outside of blister packs, including counterfeit Adderall, oxycodone, and hydrocodone that were manufactured using fentanyl and methamphetamine at multiple locations in United States—including through the networks controlled by FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant. When selling these pills, SAYYED required a minimum order of at least 90 or 120 pills.

33. In or about early February 2024, SADIQ ABBAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” the defendant, sold an undercover law enforcement officer nearly 400 pills that SAYYED claimed were oxycodone and Adderall. However, laboratory analysis confirmed that the pills, which were manufactured to resemble legitimate pharmaceuticals, were, in fact, made from para-fluorofentanyl and methamphetamine. The counterfeit pills SAYYED sold to the undercover law enforcement officer were shipped by EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, working under the direction of

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FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant. On a recorded call with the undercover law enforcement officer in or about August 2024, SAYYED stated, in sum and substance, that he knew the individuals making the loose pills used fentanyl because without it, the pills would not be high quality. Dismissing the harm he knew fentanyl caused, SAYYED told the undercover law enforcement officer, “it’s business.”

34. “KS Pharmacy” is a purported online pharmacy operated by KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, who sold from India what appeared to be pharmaceuticals through a WhatsApp account. In reality, however, SHAIKH fulfilled the orders he received through FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, and his network, and the purported oxycodone pills they supplied to customers were actually made with fentanyl.

35. For example, Victim-3, a 23-year-old man who has struggled with drug addiction and has previously sought treatment at a drug rehabilitation facility, searched for Xanax on the internet and left his phone number and a request for Xanax on a website intended to connect sellers and buyers of manufactured goods. Thereafter, KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, contacted Victim-3 through his “KS Pharmacy” WhatsApp account. Between in or about November 2023 and in or about February 2024, Victim-3 ordered counterfeit prescription pills from SHAIKH that were shipped to Victim-3 by the defendants.

36. In or about February 2024, Victim-3 placed an order via WhatsApp with KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, for 90 pills of 30-milligram oxycodone tablets. Later that month, a package was shipped to Victim-3 from EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, containing fentanyl pills that had been recently pressed in the defendants’ pill mills and disguised to look like legitimate oxycodone.--- page 19 ---

37. On or about February 26, 2024, KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, assured Victim-3 that nobody had ever overdosed from the defendants’ counterfeit oxycodone pills and that the fentanyl they contained was a “safe amount.” The exchange between SHAIKH and Victim-3 is below:

Victim-3: any fent?

SHAIKH: Maybe of safe amount

Victim-3: i know they have been cut i can tell

Victim-3: have any customers overdosed w these?

SHAIKH: Loose pressed may contain safe amount of fentanyl

SHAIKH: No

SHAIKH: Don’t worry, people reordering them

SHAIKH: Take care [Victim-3] have a blessed day 👍

Victim-3: okay

SHAIKH: Avoid high dosage take care sir

38. The day before this exchange, Victim-1 had died from fentanyl poisoning after ingesting the very same pills manufactured and sold by the defendants.

39. In or about August 2024, KHIZAR MOHAMMAD IQBAL SHAIKH, the defendant, using the KS Pharmacy WhatsApp account, agreed to sell to an undercover law enforcement officer 90 oxycodone pills. After they arrived in September 2024, the pills tested positive for fentanyl.

III. THE DEFENDANTS MANUFACTURED MILLIONS OF COUNTERFEIT PRESCRIPTION PILLS USING DEADLY NARCOTICS

40. The defendants sold fake prescription drugs that were manufactured at at least three industrial-scale pill mills located in the basements of residential buildings throughout New York City: (i) a mill located on Wadsworth Avenue in the Washington Heights neighborhood of New York, New York (the “Wadsworth Pill Mill”); (ii) a mill located on Beaumont Avenue in the Bronx, New York (the “Beaumont Pill Mill”); and (iii) a mill located on Gerard Avenue in the

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Bronx, New York (the "Gerard Pill Mill"). The pill mills were industrial-scale factories, each capable of producing over 100,000 pills in just 12 hours. The defendants combined powdered narcotics, including fentanyl, para-fluorofentanyl, and methamphetamine, with inert substances, which they purchased in bulk from wholesale retailers. The mixtures were then colored with dyes and pressed into pills using industrial-scale pill presses. These presses were fitted with die molds purchased by the defendants from vendors based in the People's Republic of China. The die molds shaped, compressed, and stamped powdered narcotics into solid tablets, so that the pills appeared to be legitimate pharmaceuticals complete with the same lettering and numbering. What appeared to be oxycodone, hydrocodone, and Percocet contained narcotics such as fentanyl and parafluorofentanyl; what appeared to be Adderall contained methamphetamine.

41. From the Dominican Republic, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, managed the pill mills. LOPEZ REYES funded the operations of the pill mills and trained others, including, JUAN EFREN PAULINO, a/k/a "Freddy," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, on how to press pills. LOPEZ REYES directed the production of the fake pharmaceuticals, specifying the quantity and types of pills to be produced. When the pills did not meet his specifications, either because the pills were not sufficiently potent or did not look similar enough to real pharmaceuticals, LOPEZ REYES ordered their reproduction.

42. The Wadsworth, Beaumont, and Gerard Pill Mills were manned by the defendants and other co-conspirators, who worked long shifts, spanning days, pressing deadly powdered narcotics into millions of counterfeit pharmaceutical pills to be shipped to victims around the United States and the world. When law enforcement disrupted one pill mill, the defendants would simply use another.

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The Wadsworth Pill Mill

43. The Wadsworth Pill Mill, which was hidden in the basement of a residential building in Manhattan, New York, was searched and shut down by law enforcement on or about May 31, 2023. There, law enforcement officers seized over 200,000 already-made pills as well as bricks, bags, and buckets filled with powdered narcotics ready to be pressed into pills, depicted, in part, in the photograph below. In total, law enforcement officers seized, among other narcotics, (i) more than 24 kilograms of para-fluorofentanyl, over seven kilograms of fentanyl, and approximately 40 kilograms of methamphetamine in the form of pills, and (ii) in the form of powder, approximately 14 kilograms of fentanyl, one kilogram of para-fluorofentanyl, and 1.9 kilograms of methamphetamine, which could be pressed into over 550,000 additional pills.

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44. Law enforcement officers also found the equipment used to transform powdered narcotics into pill form, including three commercial-grade pill presses and a commercial grade-mixer. One of the pill presses is pictured below on the left; the mixer is pictured below on the right.

45. JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, managed the operations of the Wadsworth Pill Mill. EFREN PAULINO employed approximately six individuals at the Wadsworth Pill Mill, including JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” and HECTOR BIENVENIDO FELIZ FELIZ, a/k/a “Tacoma,” the defendants. Working at the direction of EFREN PAULINO, these employees would, among other things, grind pills made of inert substances into powdered form; mix the inert substances with colored dyes and powdered narcotics like fentanyl, para-fluorofentanyl, and methamphetamine; press the narcotics mixtures into pills; clean, count, sort, and bag the pills for eventual distribution; deliver the pills to shippers; and clean the facility.

46. The employees of the Wadsworth Pill Mill also assisted JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, in procuring pill presses and parts for those presses. For example, on or about January 14, 2023, JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,”thought
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the defendant, who at the time was working for EFREN PAULINO at the Wadsworth Pill Mill, sent a message to EFREN PAULINO that stated, in sum and substance, that a die mold had arrived and sent the below photograph of a die mold, which was used to stamp powdered fentanyl mixtures into counterfeit oxycodone pills marked with a “M” and “30.”

47. From the Dominican Republic, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, was in frequent contact with JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, ordering him to increase production of pills in response to customer demand. For example, on or about April 12, 2022, LOPEZ REYES messaged EFREN PAULINO, instructing him, in sum and substance, “to make at least 20 thousand [fake oxycodone pills] ... Because I have clients waiting.”

48. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also instructed JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, on ways to produce higher quality pills at a large volume. For example, on or about April 9, 2022, LOPEZ REYES told EFREN PAULINO, in sum and substance, to use a particular blender that “grinds [] really well.

23

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It makes the [narcotics-mixture] finer without clumps.” LOPEZ REYES also instructed EFREN PAULINO to obtain, in sum and substance, “a minimum of two [pill press] machines.”

49. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” and JUAN EFREN PAULINO, a/k/a “Freddy,” the defendants, took other steps to ensure that the Wadsworth Pill Mill produced pills that closely resembled real pharmaceuticals. For example, on or about May 15, 2023, LOPEZ REYES sent EFREN PAULINO a photograph of pills accompanied by a voice note stating, in sum and substance, “We are having problems, Freddy, with the pills having two different colors. This can’t keep happening. It has to be an exact color. Ones are lighter than others, some bluer than others.”

50. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also directed JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, to increase the strength of the pills, by adding more narcotics. On at least one occasion, after LOPEZ REYES expressed his dissatisfaction with the potency of the fake pharmaceuticals produced at the Wadsworth Pill Mill, EFREN PAULINO ordered his employees to re-grind the pills. On or about May 24, 2023, LOPEZ REYES messaged EFREN PAULINO and stated, in sum and substance, “a lot of clients complained about the quality Adderall [sic].” EFREN PAULINO responded, in sum and substance, that he would make the pills stronger.

The Beaumont Pill Mill

51. The Beaumont Pill Mill, which was hidden in the basement of a residential building in the Bronx, New York, was searched and shut down by law enforcement officers on or about October 5, 2023. There, law enforcement officers seized (i) approximately nine kilograms of fentanyl and over 14 kilograms of methamphetamine in the form of approximately 97,000 pills;

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and (ii) over 12 kilograms of fentanyl and over seven kilograms of a mixture of para-fluorofentanyl fentanyl, heroin, caffeine, and other substances in the form of powder.

52. Law enforcement officers also recovered equipment used to press powdered narcotics into pills, including three industrial pill presses and one disassembled pill press, one kilogram press, blenders, dyes, and jars of calcium citrate.

53. The Beaumont Pill Mill was built to be a fentanyl, para-fluorofentanyl, and methamphetamine pill pressing factory. The first-floor windows of the Beaumont Pill Mill were covered with black trash bags and dark fabric, preventing outside observers from viewing what was occurring inside. The Beaumont Pill Mill was also equipped with a surveillance system, including a television screen displaying a live feed of security camera footage from outside the pill

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mill. A pill press and industrial-grade gas masks to protect workers from the deadly narcotics being pressed, recovered from the Beaumont Pill Mill, are depicted in the photographs below.

54. HERIBERTO EUSTATE ESPINAL, a/k/a “Daulin,” and WELLINGTON EUSTATE ESPINAL, a/k/a “Roni,” the defendants, managed the operations of the Beaumont Pill Mill, supervising EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, and two other individuals. These employees of the Beaumont Pill Mill, among other things, procured inert substances to be mixed with narcotics, counted and sorted pills, and cleaned the space in which the mill operated.

55. JUAN EFREN PAULINO, a/k/a “Freddy,” HERIBERTO EUSTATE ESPINAL, a/k/a “Daulin,” and WELLINGTON EUSTATE ESPINAL, a/k/a “Roni,” the defendants, worked closely together to manage continuing operations at their respective mills. When the pill presses at the Wadsworth Pill Mill were not working, EFREN PAULINO turned to the Beaumont Pill Mill as his source of pill manufacturing. Wadsworth Pill Mill workers also went to the Beaumont Pill Mill to obtain parts for pill presses.

2656. After law enforcement officers arrested JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, on or about May 31, 2023, and shut down the Wadsworth Pill Mill, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, turned to JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, to take over his pill manufacturing process in New York, although EFREN PAULINO continued to play an active role directing the organization’s operations from prison. With the Wadsworth Pill Mill closed, PEREZ MENDEZ began overseeing the pressing of counterfeit pills at the Beaumont Pill Mill. Pill manufacturing at the Beaumont Pill Mill was done primarily for PEREZ MENDEZ and under PEREZ MENDEZ’s direction; other pills were pressed at the direction of LUIS PAULINO, the defendant. PAULINO, for his part, also provided the Beaumont Pill Mill with real oxycodone pills that HERIBERTO EUSTATE ESPINAL, a/k/a “Daulin,” and WELLINGTON EUSTATE ESPINAL, a/k/a “Roni,” the defendants, used as samples to create realistic counterfeit oxycodone pills made from fentanyl for PAULINO and PEREZ MENDEZ. PEREZ MENDEZ provided die molds to shape the narcotics into pills, directed the Beaumont Pill Mill workers to manufacture pills that were uniform in color so that they looked real, inspected the pills to ensure that they appeared to accurately resemble legitimate pharmaceuticals, and personally participated in the pill manufacturing process itself. PEREZ MENDEZ also coordinated shipping the pills manufactured at the Beaumont Pill Mill to victims across the country at the direction of LOPEZ REYES.

The Gerard Pill Mill

57. The Gerard Pill Mill, which was hidden in the basement of a residential building in the Bronx, New York, was searched and shut down by law enforcement officers on or about April 6, 2024. There, law enforcement officers seized over 101,000 already-made pills, as well as powdered narcotics in powder form ready to be pressed into pills, depicted, in part, in the photograph below. In total, law enforcement officers seized (i) in the form of pills approximately 29 kilograms of para-fluorofentanyl and approximately 800 grams of methamphetamine; (ii) in the form of powder approximately 1.9 kilograms of fentanyl and 13 kilograms of methamphetamine; and (iii) in the form of crystal approximately 2.9 kilograms of methamphetamine.

58. Law enforcement officers also recovered the two industrial-scale pill presses, depicted below, as well as materials used to mix powdered narcotics with inert substance, and materials used to package narcotics for further distribution. Those items included mixing bowls,

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a blender, strainers, dyes, empty bottles of pills ground for filler, and thousands of glassine envelopes used to package the drugs.

59. JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” and EUSEBIO PERALTA BAUTISTA, a/k/a “Luis Collazo Santos,” the defendants, worked at the Gerard Pill Mill, pressing powdered narcotics into pills. PEREZ MENDEZ managed operations at the Gerard Pill Mill and reported directly to FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant. For example, on or about March 15, 2024, PEREZ MENDEZ texted LOPEZ REYES inventories of pills on hand, noting, among other things, that the mill had “32,000 – M30[s],” a reference to the “M” and “30” stamped into legitimately manufactured 30-milligram oxycodone pills. LOPEZ REYES ordered PEREZ MENDEZ to turn to producing counterfeit Adderall and hydrocodone. Similarly, on or about April 2, 2024, LOPEZ REYES ordered PEREZ MENDEZ, in sum and substance, to produce “more hydro m367,” a reference to the “M367” stamped into legitimately manufactured Vicodin, a prescription drug made principally from hydrocodone. On or about April 6, 2024, while discussing the manufacture of certain fake drugs, PEREZ MENDEZ messaged LOPEZ REYES, asking LOPEZ REYES, in sum and substance, “what’s printed on the front and

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what’s printed on the back of the orange ones?” LOPEZ REYES responded, in sum and substance, “AD and on the other side 30,” and included a photograph of what appear to be counterfeit Adderall pills.

60. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also funded the operations of the Gerard Pill Mill. For example, on or about April 3, 2024, LOPEZ REYES messaged JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, and tried to confirm whether PEREZ MENDEZ had received money so that PEREZ MENDEZ could produce “large quantities” of pills.

IV. SHIPPERS MAILED COUNTERFEIT PRESCRIPTION PILLS TO VICTIMS ACROSS THE UNITED STATES

61. To distribute the drugs he manufactured in basements in New York City and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, employed a network of shippers who mailed counterfeit pills created at the pill mills to victims across the country. LOPEZ REYES trained those shipping on his behalf on how to package the pills, provided the names and addresses of victims, the quantity and types of pills to send them, and shipping instructions, including whether to, for example, overnight the pills—information that he received from victims that ordered from websites or encrypted messaging applications operated by him and others. LOPEZ REYES designated a small percentage of victims to receive “la Buena,” “good,” or “la verdad” pills, indicating that the victims should receive genuine pills that were shipped in real pharmaceutical packaging. The vast majority of victims, however, received counterfeit pills that contained deadly narcotics like fentanyl or methamphetamine.

62. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, also directed those shipping for him to launder money. Victims were told to pay for counterfeit pills by making payments through money transfer programs like Chime, PayPal, Apple Pay, Zelle,thought
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CashApp, and cryptocurrency. These shippers were, in turn, directed by LOPEZ REYES to transfer this money to others, including to people in the Dominican Republic, who ultimately transferred those funds to LOPEZ REYES.

CC-3

63. In or about 2022, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, recruited a new shipper ("CC-3"). CC-3 began shipping large quantities of pills—up to approximately 30 packages a day, six days per week—to victims across the country from post offices located throughout New Jersey and New York. LOPEZ REYES paid CC-3 between approximately $1,500 and $3,000 per week to ship counterfeit pills. CC-3, who was one of many shippers LOPEZ REYES employed, personally shipped packages to victims in more than 30 states. Each package contained, on average, between approximately 30 and 120 pills.

64. FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, chastised CC-3 when CC-3 sent customers incorrect pills and demanded that CC-3 carefully handle the pills, including by storing them at precise temperatures. LOPEZ REYES also directed CC-3 to change phones frequently and communicate with LOPEZ REYES exclusively through encrypted messaging applications.

65. JUAN EFREN PAULINO, a/k/a "Freddy," the defendant, supplied the pills that CC-3, in turn, shipped. EFREN PAULINO met CC-3 at locations throughout the Bronx and Manhattan and handed CC-3 backpacks containing thousands of pills. At the direction of FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, CC-3 provided EFREN PAULINO tens thousands of dollars from the money that CC-3 had received from victims.

Eustate Jimenez

66. In or about March 2023, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," and JUAN EFREN PAULINO, a/k/a "Freddy," the defendants, recruited EDWARD EUSTATE

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JIMENEZ, a/k/a “Chino,” the defendant, to ship packages of fake pills manufactured at the Wadsworth Pill Mill.

67. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” and JUAN EFREN PAULINO, a/k/a “Freddy,” the defendants, supervised the work of EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant. EFREN PAULINO provided EUSTATE JIMENEZ with pills and instructed EUSTATE JIMENEZ on how to package and mail the pills to victims. In turn, LOPEZ REYES sent EUSTATE JIMENEZ the pill orders, which included the types of pills to send, the quantity of pills, the names and addresses of the recipients, and the shipping instructions. EUSTATE JIMENEZ then packaged and mailed the pills from post offices located throughout Washington Heights and the Bronx in New York City.

68. After the arrest of JUAN EFREN PAULINO, a/k/a “Freddy,” the defendant, in or about May 2023, JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, began working with EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, to continue to ship narcotics to victims without pausing operations. For example, EUSTATE JIMENEZ periodically sent PEREZ MENDEZ audits of his pill supply, noting, for example, on or about December 11, 2023, that he had 25,000 counterfeit 30-milligram oxycodone pills on hand. In one voice note sent on or about December 12, 2023, by PEREZ MENDEZ to EUSTATE JIMENEZ, while they coordinated a pickup of pills, the sound of a pill press machine could be heard in the background. In another communication, on or about January 30, 2024, EUSTATE JIMENEZ informed PEREZ MENDEZ that he had 120,000 30-milligram oxycodone pills on hand. Photographs sent by

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EUSTATE JIMENEZ to PEREZ MENDEZ of thousands of counterfeit oxycodone, hydrocodone, and Adderall pills, respectively, are reproduced below:

69. EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, also recruited others to assist him in shipping pills, including WILIANYI ALMANZAR POLANCO and ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” the defendants. On or about February 26, 2024, EUSTATE JIMENEZ and ALMANZAR POLANCO were arrested at a post office in Manhattan while attempting to mail more than 35 packages containing over 4,000 fake prescription pills. The contents of two of the priority mail packages, containing counterfeit oxycodone and counterfeit Adderall, are pictured below.

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70. After arresting EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” and WILIANYI ALMANZAR POLANCO, the defendants, law enforcement officers searched EUSTATE JIMENEZ’s apartment in the Washington Heights neighborhood of New York, New York, where EUSTATE JIMENEZ distributed narcotics. During the search, law enforcement officers found, as depicted in part in the photograph below, approximately 83,000 counterfeit prescription pills, including fake Oxycontin, oxycodone, Adderall, and Xanax; 2,000 unused United States Postal Service (“USPS”) priority mail envelopes; and shipping receipts. In total, from the post office and EUSTATE JIMENEZ’s apartment, law enforcement officers seized approximately over 23 kilograms of para-fluorofentanyl, 1.8 kilograms of fentanyl, and 4.7 kilograms of methamphetamine, in the form of pills.

71. Over the course of just three months—from in or about December 2023 through the date of the arrest of EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, on or

34about February 26, 2024—EUSTATE JIMENEZ, with the assistance of WILIANYI ALMANZAR POLANCO and ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” the defendants, shipped at least approximately 1,800 packages containing approximately 328,000 counterfeit pills to victims living in all 50 U.S. states, Washington, D.C., Puerto Rico, and the U.S. Virgin Islands, including Victim-1, who died thereafter.

Onega and the Britos

72. FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” and JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, recruited MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, JOSE CONCEPCION BRITO, and ANGEL VALDEZ BRITO, the defendants, to ship millions of fake pills to victims across the country.

73. MIGUEL CONCEPCION BRITO and CYNTHIA ONEGA, the defendants, received pills manufactured by JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, and his employees. MIGUEL CONCEPCION BRITO and ONEGA sorted and packaged the pills, and directed JOSE CONCEPCION BRITO and ANGEL VALDEZ BRITO, the defendants, to ship the packages to victims across the country according to the shipping instructions given to them by FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant. JOSE CONCEPCION BRITO and VALDEZ BRITO shipped victims approximately 70 packages per day for at least four months.

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74. MIGUEL CONCEPCION BRITO and CYNTHIA ONEGA, the defendants, packaged the pills in their apartment, where they lived with a young child, and stored narcotic pills in ONEGA’s vehicle. On or about December 4, 2023, law enforcement officers searched that vehicle and seized approximately 135,000 counterfeit pills containing approximately 30 kilograms of para-fluorofentanyl and approximately 17 kilograms of methamphetamine, including as depicted in part below.

75. Over the course of just four months—from in or about July 2023 through on or about December 4, 2023—MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, JOSE CONCEPCION BRITO, and ANGEL VALEZ BRITO, defendants, shipped at least approximately 4,500 packages containing at least approximately 580,000 counterfeit pills to approximately 2,200 unique victims. The victims lived in all 50 U.S. states, the U.S. Virgin Islands, and other countries including Germany and Slovenia.

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V. THE DEFENDANTS USED MANIPULATIVE MARKETING TO KEEP VICTIMS COMING BACK

76. Once pills had been delivered to a particular victim, the defendants developed strategies for ensuring that these victims continued to place orders through their network of online counterfeit pharmacies and messaging channels. These strategies included the provision of free “sample” pills as well as unrelenting manipulative marketing communications. The defendants found success in both approaches, targeting individuals who, in some cases, were already chemically dependent on the products that the defendants were aggressively pushing.

Free Samples

77. One way in which the defendants sought to ensure customers placed orders for purported prescription pills from their distribution channels, and not from some other source, was through the use of free samples of counterfeit drugs containing fentanyl.

78. At the direction of FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, CC-3 placed flyers advertising the defendants’ websites and other communication channels into many of the pill orders he fulfilled. When instructed to do so by LOPEZ REYES, CC-3 also often placed in those shipments an additional one to five pills along with the flyer. LOPEZ REYES directed CC-3 as to which customers were to receive the free samples, the number and type of pills that should be placed in the free samples, as well as what information to include in the flyers. The flyers, an example of which is depicted below, typically included a phone number and website where pills could be ordered, which LOPEZ REYES would periodically direct CC-3 to update as he opened new websites.

37

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Dear customer,

Do you need a good pharmacy service, with a good economic price? At [illegible] we have the best service and prices on the market....

To show our favorite customers that this is a guaranteed service. Here we are sending you a small sample of our service. [illegible] is a unique service, which guarantees you, to send your package the same day guaranteed!

For more information on, [illegible]

Contact us at: Phone +1 [illegible] https:// [illegible] com/

Thanks for everything,

Sincerely,

79. Victim-4, who was a 69-year-old grandmother from Tennessee, had begun ordering purported pharmaceuticals from the defendants in or about November 2023. On or about June 26, 2024, Victim-4 died of intoxication by fentanyl and other drugs. At the time of her death, Victim4 had counterfeit 30-milligram oxycodone pills in her home. The pills, which resembled legitimately manufactured oxycodone pills with the distinctive “M30” imprint, tested positive for fentanyl. After Victim-4 stopped ordering pills from the defendants because she had died of narcotics poisoning, the defendants sent to Victim-4’s home address one of these advertisements with free “sample” pills to try and encourage more orders. Specifically, on or about July 20, 2024—less than one month after Victim-4’s death—a package addressed to Victim-4 was delivered to her home. The package contained five counterfeit hydrocodone pills containing fentanyl that resembled the shape, color, and imprint of legitimate hydrocodone medication. Accompanying these pills was a flyer in which FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, claimed to have “the best price and the best quality on the market. Either

38--- page 39 ---

wholesale or retail." The flyer noted that "if you do business with us, we will ship your order immediately," including through "one day delivery express mail with a tracking number so you can follow up on the package." After providing prices for 90, 180, 360, and 600 "tabs," the advertisement encouraged, "you can either contact us by number or email or [by] visiting our website," and listed a particular phone number as "customer care," a particular email address for "medscustomerservice," and the website for Your Pharmacy, discussed at length above.

80. FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, owned and operated both the Your Pharmacy website and the medscustomerservice email inbox ("Meds Customer Service"). From in or about April to in or about August 2024, the Meds Customer Service inbox received approximately 100 messages from individuals inquiring about pills, many of which referenced free samples of medication received alongside flyers advertising the email address. Several victims appeared to believe Meds Customer Service to be a legitimate pharmacy, with one victim writing he "may be interested in filling one of my prescriptions with you if prices are better than my current provider." Others ordering from Meds Customer Service inquired about quantities consistent with redistribution in street level drug dealing, with one individual seeking "600 percocet 600xanax and 600 hydro the Watson ones and 600 roxys." And others exhibited desperate drug-seeking behavior, including by sending six emails in four hours with pleas such as "PLEASE HELP ME??? U sent me a letter yesterday with a sample of ur product. I would like to purchase some but no one will contact me."

Manipulative Marketing

81. In addition to sending free samples, the defendants also employed manipulative or harassing marketing techniques to pressure victims of their scheme to continue making purchases of counterfeit pills. In particular, once an order was placed, the defendants and their coconspirators remained in near constant contact with their victims to offer additional narcotics and

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highlight supposed customer discounts. Victims reported receiving near daily outreach from the defendants or their co-conspirators via phone calls, text messages, emails, and encrypted messages about purchasing additional pills, to a degree that many victims found to be harassing. But even when these victims blocked the contact numbers, the defendants and their co-conspirators continued their outreach using new numbers. One victim (Victim-5), described in more detail below, reported blocking around 20 to 30 different phone numbers in an effort to stop receiving communications after having placed an order from the defendants.

82. Victim-2 experienced precisely this type of harassment. After making two purchases of Adderall from Pharmacy Stores Online, described in detail above, Victim-2 began receiving WhatsApp chats and text messages offering purported discounted Adderall and Ritalin, another ADHD drug. Between in or about April and June 2024, Victim-2 received approximately 19 different messages and several phone calls asking if he wished to purchase prescription drugs. For example, on or about May 22, 2024, Victim-2 received the message, “Hi [Victim-2] any order for me? Huge discount for Adderall and for Ritalin?” and then five days later, on or about May 27, 2024, received two messages, “Hi [Victim-2], how are you dear? Aderall [sic] and Ritalin is on discount would you like to order for any?” and “Hi [Victim-2], how are you dear? It’s Jennifer. would you like to order Ritalin or Adderall today with discount?”

83. Throughout in or about June 2024, Victim-2 again received similar, apparently automated messages, including: (i) On or about June 5, “Hi [Victim-2], how are you dear? It’s Jennifer[.] would you like to order Ritalin or Adderall today with discount?” (ii) On or about June 7, “Hi [Victim-2], It’s Jennifer. would you like to order Ritalin or Adderall today with discount?” (iii) On or about June 14, “Hi [Victim-2], how are you? It’s Jennifer. Any order for me?” (iv) On or about June 20, “Hi [Victim-2]we do have now Teva brand Adderall with $ sigh in USA stock.--- page 41 ---

Do let me know if you are interested to make order for that?” (v) On or about June 27, “Hi [Victim2], how are you? It’s Jennifer. Are you ready to make an order?” The penultimate message, from on or about June 20, 2024, included a photograph of purported Adderall. When these attempts to pressure Victim-2 into additional purchases of methamphetamine disguised as Adderall were unsuccessful, Victim-2 began receiving messages from another number, which stated, on or about June 20, 2024, “Hi [Victim-2], Just to let you know we got T va brand with $ marking for Adrl 30. Would you like to ordr [sic] for that?” and, on or about June 25, 2024, “Hi [Victim-2], Would you like to 0rdr for round Adrl 30. with best quality and with huge discounts?”

84. Similarly, Victim-5, a psychiatrist, was prescribed painkillers after receiving a knee replacement approximately one year ago, but, when her prescription ran out, she turned to online pharmacies to obtain oxycode without a prescription. In or about November 2023, after placing two orders for Percocet on a website operated by the defendants and their co-conspirators, Victim5 received the pills, which appeared to her to be fake. Thereafter, she started receiving numerous calls from individuals trying to sell her prescription pills. Even after she blocked some numbers, she would receive calls from other numbers trying to sell her prescription pills. She had to block dozens of phone numbers in order to stop receiving the defendants’ outreach.

85. Besides Victim-5, several customers who received pills from the defendants’ scheme reported to law enforcement officers that, after receiving their orders, they were bombarded with a huge volume of near daily phone calls or text messages from the individuals who sold the pills to pressure them to place more orders for counterfeit pills.

VI. VICTIM-1 WAS KILLED BY THE DEFENDANTS’ FENTANYL PILLS

86. As described above, thousands of individuals purchased counterfeit pharmaceuticals from the defendants and their co-conspirators; at least nine of those victims later died from narcotics poisonings.

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87. As described above, on or about February 12, 2024, Victim-1 placed an order from Curecog, operated by CC-1 and CC-2, for anti-anxiety medication but, on or about February 13, 2024, emailed ALBA GONZALEZ, the defendant, to request that her order be changed to “oxyxodone [sic].” Victim-1 did not have a prescription for oxycodone and neither GONZALEZ nor the operators of Curecog requested one.

88. On or about February 16, 2024, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, sent EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, a list of customer names, addresses, and pill orders for EUSTATE JIMENEZ to fulfil. Included in the list was Victim-1’s order: “oxy M30 90,” shorthand for 90 tablets of 30-milligram oxycodone. Seconds later, LOPEZ REYES replied to his own message to EUSTATE JIMENEZ containing the customer order list and, in sum and substance, clarified, “These are almost all oxy.”

89. Also on or about February 16, 2024, less than a half hour after receiving Victim-1’s order, EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” the defendant, sent a photograph of Victim-1’s order to ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” the defendant. A few hours later, RAMOS HENRIQUEZ sent to EUSTATE JIMENEZ the below photograph of fake 30-milligram oxycodone pills, with an “M” on one side and the number “30”

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on the other, ready to be shipped, along with a USPS envelope addressed to Victim-1. The package was in fact shipped to Victim-1 shortly thereafter on or about February 16, 2024.

90. On or about February 20, 2024, the defendants’ package containing the purported oxycodone was delivered to Victim-1. That same day, Victim-1 searched the internet for indicia that the pills she had received were genuine pharmaceuticals. For example, she entered into a search engine “pill” and “pill identifier.” She also visited a pill identification website and searched, “M 30 Blue and Round.” The results of Victim-1’s internet search indicated that round, blue pills with an “M” on one side and “30” on the other are 30-milligram oxycodone pills; in other words, she was led to believe that the pills she had received were real prescription medication.

91. Shortly after Victim-1 received the defendants’ pills in the mail, she became severely ill, vomited for several consecutive days, and was unable to urinate—common symptoms of fentanyl poisoning. On or about February 24, 2024, Victim-1 sent a text message to her friend stating, in sum and substance, that she was using pain medications. The following day, on or about

43

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February 25, 2024—five days after Victim-1 received the defendants’ pills—her mother found Victim-1 unresponsive in bed. Soon after, emergency services responded to Victim-1’s home, and she was pronounced dead.

92. At Victim-1’s bedside were 46 of the blue pills, depicted below, that the defendants designed to appear to be 30-milligram oxycodone tablets. Despite what Victim-1 thought she had found on the internet about the safety of those pills, testing revealed what only the defendants knew: the pills were actually made of fentanyl and para-fluorofentanyl. Because Victim-1 ingested the fentanyl and para-fluorofentanyl distributed by the defendants through their false websites, deadly pill mills, and lethal shipments, Victim-1 died. Her cause of death was acute fentanyl intoxication.

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VII. STATUTORY ALLEGATIONS

COUNT ONE

(Continuing Criminal Enterprise)

The Grand Jury further charges:

93. The allegations contained in paragraphs 1 through 92 of this Superseding Indictment are incorporated as though fully set forth herein.

94. From at least in or about April 2022, up to and including on or about the date of the filing of this Superseding Indictment, in the Southern District of New York, the Dominican Republic, India, and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” JUAN EFREN PAULINO, a/k/a “Freddy,” and JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, and others known and unknown, engaged in a continuing criminal enterprise (the “Continuing Criminal Enterprise”), in that LOPEZ REYES, PAULINO, and PEREZ MENDEZ knowingly and intentionally participated in a continuing series of violations of Title 21, United States Code, Chapter 13, Subchapters I and II, including, among others, Violations One through Seven set forth below, undertaken by LOPEZ REYES, PAULINO, and PEREZ MENDEZ, in concert with five and more persons with respect to whom LOPEZ REYES, PAULINO, and PEREZ MENDEZ occupied a position of organizer, supervisor, and any position of management, and from which such continuing violations LOPEZ REYES, PAULINO, and PEREZ MENDEZ obtained substantial income and resources.

95. Furthermore, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, was the principal administrator, organizer, and leader of the Continuing Criminal Enterprise, which involved at least 300 times the quantity of mixtures and substances containing a detectable amount of (i) para-fluorofentanyl, an analogue of fentanyl, (ii) fentanyl, and (iii) methamphetamine, its salts, isomers, and salts of its isomers, as described in Title 21, United States Code, Section 841(b)(1)(B), and the Continuing Criminal Enterprise received $10 million and more in gross receipts during a 12-month period of its existence for the manufacture, importation, and distribution of para-fluorofentanyl, fentanyl, and methamphetamine, its salts, isomers, and salts of its isomers.

Violation One

96. From at least in or about April 2022, up to and including on or about the date of the filing of this Superseding Indictment, in the Southern District of New York, the Dominican Republic, India, and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," JUAN EFREN PAULINO, a/k/a "Freddy," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, and others known and unknown, knowingly and intentionally combined, conspired, confederated, and agreed together and with each other to distribute and possess with intent to distribute (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A), and 846; (ii) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A), and 846; (iii) 500 grams and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, and salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A), and 846; (iv) one kilogram and more of mixtures and substances containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A), and 846; and (v) 500 grams and more of mixtures and substances containing a detectable amount of cocaine, in violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(B), and 846.

46

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97. The use of such controlled substances resulted in the death of Victim-1 on or about February 25, 2024, in Dover, Delaware.

Violation Two

98. On or about May 31, 2023, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” and JUAN EFREN PAULINO, a/k/a “Freddy,” JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, knowingly and intentionally distributed and possessed with the intent to distribute (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A); (ii) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A); (iii) 500 grams and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, and salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A); (iv) 100 grams and more of mixtures and substances containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(B); and (v) 500 grams and more of mixtures and substances containing a detectable amount of cocaine, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(B), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

Violation Three

99. On or about October 5, 2023, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” JUAN EFREN PAULINO, a/k/a “Freddy,” and JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, knowingly--- page 48 ---

and intentionally distributed and possessed with the intent to distribute: (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl; (ii) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl; (iii) 500 grams and more of mixtures and substances containing a detectable amount of methamphetamine; and (iv) one kilogram and more of mixtures and substances containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

Violation Four

100. On or about December 4, 2023, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, knowingly and intentionally distributed and possessed with the intent to distribute: (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl; and (ii) 500 grams and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, and salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

Violation Five

101. On or about February 16, 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, knowingly and intentionally distributed and possessed with intent to distribute: (i) mixtures and substances containing a detectable amount of fentanyl; and (ii) mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

102. The use of such controlled substances resulted in the death of Victim-1 on or about February 25, 2024, in Dover, Delaware.

Violation Six

103. On or about February 26, 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, knowingly and intentionally distributed and possessed with intent to distribute: (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl; (ii) 400 grams and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

Violation Seven

104. On or about April 6, 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," and JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," the defendants, knowingly and intentionally distributed and possessed with the intent to distribute: (i) 100 grams and more of mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl; (ii) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl; and (iii) 500 grams

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and more of mixtures and substances containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A), and aided and abetted the same, in violation of Title 18, United States Code, Section 2.

(Title 21, United States Code, Sections 848(a), 848(b), and 848(c); and Title 18, United States Code, Section 2.)

COUNT TWO
(Conspiracy to Distribute Narcotics Resulting in Death)

The Grand Jury further charges:

105. From at least in or about April 2022, up to and including on or about the date of the filing of this Superseding Indictment, in the Southern District of New York, the Dominican Republic, India, and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," JUAN EFREN PAULINO, a/k/a "Freddy," JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," KHIZAR MOHAMMAD IQBAL SHAIKH, WELLINGTON EUSTATE ESPINAL, a/k/a "Roni," HERIBERTO EUSTATE ESPINAL, a/k/a "Daulin," EUSEBIO PERALTA BAUTISTA, a/k/a "Luis Collazo Santos," HECTOR BIENVENIDO FELIZ FELIZ, a/k/a "Tacoma," LUIS PAULINO, MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," ALBA GONZALEZ, JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILIANYI ALMANZAR POLANCO, the defendants, and others known and unknown, knowingly and intentionally combined, conspired, confederated, and agreed together and with each other to violate the controlled substance laws of the United States.

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106. It was a part and an object of the conspiracy that FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," JUAN EFREN PAULINO, a/k/a "Freddy," JUAN MOISES PEREZ MENDEZ, a/k/a "Caballero," SADIQ ABBAS HABIB SAYYED, a/k/a "Rakesh Sharma," a/k/a "Jonathan Acosta," KHIZAR MOHAMMAD IQBAL SHAIKH, WELLINGTON EUSTATE ESPINAL, a/k/a "Roni," HERIBERTO EUSTATE ESPINAL, a/k/a "Daulin," EUSEBIO PERALTA BAUTISTA, a/k/a "Luis Collazo Santos," HECTOR BIENVENIDO FELIZ FELIZ, a/k/a "Tacoma," LUIS PAULINO, MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," ALBA GONZALEZ, JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILIANYI ALMANZAR POLANCO, the defendants, and others known and unknown, would and did distribute and possess with intent to distribute controlled substances, in violation of Title 21, United States Code, Section 841(a)(1).

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108. The use of such controlled substances resulted in the death of Victim-1 on or about February 25, 2024, in Dover, Delaware.

(Title 21, United States Code, Section 846.)

COUNT THREE
(Distribution of Narcotics Resulting in Death)

The Grand Jury further charges:

109. On or about February 16, 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," ALBA GONZALEZ, EDWARD EUSTATE JIMENEZ, a/k/a "Chino," and ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a "Junior," a/k/a "Kiko," the defendants, knowingly and intentionally distributed and possessed with intent to distribute controlled substances, in violation of Title 21, United States Code, Section 841(a)(1), and aided and abetted the same.

110. The controlled substances involved in the offense were: (i) mixtures and substances containing a detectable amount of fentanyl; and (ii) mixtures and substances containing a detectable amount of para-fluorofentanyl, an analogue of fentanyl, in violation of Title 21, United States Code, Section 841(b)(1)(C).

111. The use of such controlled substances resulted in the death of Victim-1 on or about February 25, 2024, in Dover, Delaware.

(Title 21, United States Code, Sections 812, 841(a)(1), 841(b)(1)(C); Title 18, United States Code, Section 2)

COUNT FOUR
(Conspiracy to Commit Money Laundering)

The Grand Jury further charges:

112. From at least in or about May 2022 through at least in or about February 2024, in the Southern District of New York and elsewhere, FRANCISCO ALBERTO LOPEZ REYES,
a/k/a "Frank," the defendant, and others known and unknown, willfully and knowingly combined, conspired, confederated, and agreed together and with each other to commit money laundering, in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and (a)(2)(B)(i).

113. It was a part and an object of the conspiracy that FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, and others known and unknown, knowing that the property involved in a financial transaction represented the proceeds of some form of unlawful activity, would and did conduct and attempt to conduct such a financial transaction, which transaction affected interstate and foreign commerce and involved the use of a financial institution which was engaged in, and the activities of which affected, interstate and foreign commerce, and which in fact involved the proceeds of specified unlawful activity, to wit, felonious narcotics offenses, in violation of Title 21, United States Code, Section 841, knowing that the transaction was designed in whole and in part to conceal and disguise the nature, the location, the source, the ownership, and the control of the proceeds of specified unlawful activity, in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).

114. It was further a part and an object of the conspiracy that FRANCISCO ALBERTO LOPEZ REYES, a/k/a "Frank," the defendant, and others known and unknown, would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer, a monetary instrument and funds from a place in the United States to and through a place outside the United States, and to a place in the United States from and through a place outside the United States, knowing that the monetary instrument and funds represented the proceeds of some form of unlawful activity, and knowing that the transaction was designed in whole or in part to conceal and disguise the nature, the location, the source, the ownership, and the control of the proceeds of--- page 54 ---

specified unlawful activity, to wit, felonious narcotics offenses, in violation of Title 21, United States Code, Section 841, in violation of Title 18, United States Code, Section 1956(a)(2)(B)(i).

(Title 18, United States Code, Section 1956(h).)

FORFEITURE ALLEGATION

115. As a result of committing the controlled substance offense charged in Count One of this Indictment, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” JUAN EFREN PAULINO, a/k/a “Freddy,” and JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendants, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853, any and all property constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said offense, any and all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, said offense, and any and all interest in, claims against, and property and contractual rights affording a source of control over the continuing criminal enterprise described in Count One of this Indictment, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of the offense.

116. As a result of committing the offenses alleged in Count Two of this Indictment, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” JUAN EFREN PAULINO, a/k/a “Freddy,” JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” SADIQ ABBAS HABIB SAYYED, a/k/a “Rakesh Sharma,” a/k/a “Jonathan Acosta,” KHIZAR MOHAMMAD IQBAL SHAIKH, WELLINGTON EUSTATE ESPINAL, a/k/a “Roni,” HERIBERTO EUSTATE ESPINAL, a/k/a “Daulin,” EUSEBIO PERALTA BAUTISTA, a/k/a “Luis Collazo Santos,” HECTOR BIENVENIDO FELIZ FELIZ, a/k/a “Tacoma,” LUIS PAULINO, MIGUEL CONCEPCION BRITO, CYNTHIA ONEGA, EDWARD EUSTATE JIMENEZ, a/k/a “Chino,”

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ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” ALBA GONZALEZ, JOSE CONCEPCION BRITO, ANGEL VALDEZ BRITO, and WILIANYI ALMANZAR POLANCO, and the defendants, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853, any and all property constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said offense, and any and all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, said offense, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of said offense.

117. As a result of committing the offenses alleged in Count Three of this Indictment, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” ALBA GONZALEZ, EDWARD EUSTATE JIMENEZ, a/k/a “Chino,” and ROBERT JUNIOR RAMOS HENRIQUEZ, a/k/a “Junior,” a/k/a “Kiko,” the defendants, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853, any and all property constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said offense, and any and all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, said offense, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of said offense.

118. As a result of committing the offense alleged in Count Four of this Indictment, FRANCISCO ALBERTO LOPEZ REYES, a/k/a “Frank,” the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(1), any and all property, real and personal, involved in said offense, or any property traceable to such property, including but not limited to a sum of money in United States currency representing the amount of property involved in said offense.

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Substitute Assets Provision

119. If any of the above-described forfeitable property, as a result of any act or omission of the defendants:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third person;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.

(Title 21, United States Code, Section 853.)

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