United States v. Isis Navarro Reyes, Southern District of New York (May 1, 2024) — Complaint

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF 
NEW YORK 
UNITED STATES OF AMERICA 
V. 
ISIS NAVARRO REYES, 
a/k/a "Beraly Navarro," 
Defendant. 
SOUTHERN DISTRICT OF 
NEW YORK, ss.: 
AUSA: Brandon Christopher Thompson 
SEALED COMPLAINT 
Violations 
of21 U.S.C. §§ 353(b); 33l(a); 
33l(c); 33l(k); 18 U.S.C. §§ 371; 545 
COUNTY OF OFFENSE: 
NEW YORK 
2 4MAG1686 
JASON FERNANDES, being duly sworn, deposes and says that he is a Special Agent with 
the U.S. Food and Drug Administration ("FDA"), and charges 
as follows: 
COUNT ONE 
(Receipt 
of Misbranded Drugs in Interstate Commerce) 
1. In or about January 2024 in the Southern District of New York and elsewhere, ISIS 
NAVARRO REYES, the defendant, did receive and cause the receipt 
in interstate commerce of a 
misbranded drug (an article labeled 
as " Ozempic") and did deliver and proffer delivery of such 
drug for pay and otherwise, such drug being misbranded 
in the following ways: 
a. All words,  statements,  and other information required by and under the 
authority 
of the Federal Food,  Drug,  and Cosmetic Act ("FDCA")  to appear on the label and 
labeling were not prominently placed thereon 
in the English language and with such 
conspicuousness and 
in such terms as to render it likely to be read and understood by the ordinary 
individual under customary conditions 
of purchase and use pursuant to 21 U.S.C. § 352(c); and 
b. The labeling did not bear requisite adequate directions for use pursuant to 
21 U.S.C. § 352(f)(l); and 
c. The labeling did not bear adequate warnings against use in those 
pathological conditions and by children where its use may be dangerous to health,  and against 
unsafe dosage and methods and duration 
of administration and application, in such manner and 
fotm, as were necessary for the protection 
of users pursuant to 21 U.S.C. § 352(f)(2); and 
d. It was manufactured, prepared, propagated, compounded, and processed in 
an establishment, within any foreign country, not duly  registered with FDA. 21 U.S.C. §§ 352(0) 
and 360(i). 
(Title 
21, United States Code, Sections 33l(c) and 333(a)(l)) 

COUNT TWO 
(Dispensing 
of a Misbranded Drug While Held for Sale) 
2. In or about January 2024 in the Southern District ofNew York and elsewhere, ISIS 
NAVARRO REYES, the defendant, did dispense and cause the dispensing 
of an article labeled as 
"Ozempic," a prescription drug as defined at 21 U.S.C. § 353(b)(l),  without a  prescription of a 
practitioner licensed by law to administer such drug, an act which resulted 
in the drug becoming 
misbranded while held for  sale after its shipment 
in interstate commerce. 
(Title 
21, United States Code, Sections 33l(k) and 333(a)(l)) 
COUNT THREE 
(Conspiracy to Introduce and Deliver for Introduction a Misbranded Drug 
in Interstate 
Commerce) 
3. From in or about December 2023 through at least in or about January 2024, in the 
Southern District 
of New York and elsewhere,  ISIS NA VARRO REYES,  the defendant,  did 
knowingly and willfully combine,  conspire,  confederate,  and agree with others,  known and 
unknown,  to introduce and deliver for introduction into interstate commerce a  drug (an article 
labeled as " Ozempic"), such drug being misbranded 
in the following ways: 
a. All words,  statements,  and other information required by and under the 
authority 
of the FDCA to appear on the label and labeling were not prominently placed thereon in 
the English language and with such conspicuousness and in such terms as to render it  likely to be 
read and understood by the ordinary  individual under customary conditions 
of purchase and use 
pursuant to 
21 U.S.C. § 352(c); and 
b. The labeling did not bear requisite adequate directions for use pursuant to 
21 U.S.C. § 352(f)(l); and 
c. The labeling did not bear adequate warnings against use in those 
pathological conditions and by children where its use may be dangerous to health,  and against 
unsafe dosage and methods and duration 
of administration and application, in such manner and 
form, as were necessary for the protection 
of users pursuant to 21 U.S.C. § 352(f)(2); and 
d. Prior to dispensing,  the drug,  being a  prescription drug,  had a  label that 
failed to bear the symbol "Rx only" pursuant to 
21 U.S.C. § 353(b)(4)(A). 
(Title 21, United States Code, Sections 331(a) and 333(a)(l), Title 
18, United States 
Code, Section 3 71) 
COUNT FOUR 
(Dispensing 
of a Misbranded Drug While Held for Sale) 
4. In or about February 2023, in the Southern District of New York and elsewhere, 
ISIS NAVARRO REYES,  the defendant,  did dispense and cause the dispensing 
of an article 
labeled as "Mesofrance," a  prescription drug as defined at 21 U.S.C. §  353(b)(l),  without a 
2 

prescription of a practitioner licensed by law to administer such drug, an act which resulted in the 
drug becoming misbranded while held for sale after its shipment 
in interstate commerce. 
(Title 
21, United States Code, Sections 33l(k) and 333(a)(l)) 
COUNT FIVE 
(Dispensing 
of a Misbranded Drug While Held for Sale) 
5. In or about July 2023 in the Southern District of New York and elsewhere,  ISIS 
NAVARRO REYES, the defendant, did dispense and cause the dispensing of an article labeled as 
"Axcion," a  prescription drug as defined at 21 U.S.C. §  353(b)(l),  without a  prescription of a 
practitioner licensed by law to administer such drug, an act which resulted in the drug becoming 
misbranded while held for sale after its shipment 
in interstate commerce. 
(Title 
21, United States Code, Sections 331(k) and 333(a)(l)) 
COUNT SIX 
(Smuggling) 
6. From 
in or about June 2023 through at least in or about July 2023 in the Southern 
District of New York,  ISIS NAY ARRO REYES,  the defendant,  fraudulently and knowingly 
received, concealed, bought,  sold and 
in any manner facilitated the transportation,  concealment, 
and sale of merchandise contrary to law,  that is, "Axcion," a  prescription drug as defined at 21 
U.S.C. § 353(b)(l ), after the importation thereof, REYES then knowing that said merchandise had 
been imported and brought into the United States contrary to law, 
in that the Axcion was a 
misbranded drug that was introduced into interstate commerce, 
in violation of Title 18,  United 
States Code, Section 545. 
(Title 
18, United States Code, Section 545) 
APPLICABLE LAW 
7. The United States Food and Drug Administration ("FDA"), is the federal agency 
charged with the responsibility 
of protecting the health and safety of the American public by 
enforcing the FDCA, 
21 U.S.C. § 301 et seq. Among the purposes of the FDCA is to ensure that 
drugs intended for human use are safe,   effective,   and bear labeling containing accurate 
information. Based on my understanding 
of the FDCA and, in particular, the proposed charges, I 
am aware, among other things, that: 
a. The FDCA defines interstate commerce as " (1) commerce between any 
State or Territory and any place outside thereof, and (2) commerce within the District 
of Columbia 
or within any other territory not organized with a legislative body." 
21 U.S.C. § 321(b). 
b. Under the FDCA, a "drug" 
is, among other things, any article intended for 
use 
in the diagnosis, cure, mitigation, treatment, or prevention of disease in humans; or any article 
(other than food) intended to affect the structure or any function 
of the body of a human. 21 U .S.C. 
§ 32 l(g). 
3 

c. A "prescription drug" is any drug intended for use by a human which: 
i. because of its toxicity or other potentiality for harmful effect, or the 
method 
of its use, or the collateral measures necessary to its use, is not safe for use except under 
the supervision 
of a practitioner licensed by law to administer such drug; or 
ii. is limited by an approved new drug application to use under the 
professional supervision 
of a  practitioner licensed by law to administer such drug. 21 U.S.C. 
§ 353(6 )(1 ) . 
d. Under the FDCA,  "label" is defined as " a  display of written,  printed,  or 
graphic matter upon the immediate container 
of any article." 21 U.S.C. §  321(k). The term 
" labeling," 
is broader and is defined as " all labels and other written,  printed,  or graphic matter 
(1) upon any article or any of its containers or wrappers, or (2) accompanying such article." 21 
U.S.C. § 321(m). 
e. Generally, all words, statements, and other information required by or under 
authority 
of the FDCA to appear on drug labels or labeling are required to appear thereon in the 
English language. 
1 
21 C.F .R. § 201.15( c )(1 ). 
f. Among other things, a prescription drug label is required to bear a statement 
of the recommended or usual dosage, or alternatively in some circumstances, a statement such as 
" see package insert for dosage information," where the detailed dosage information was contained 
in such insert. 21 C.F.R. §§ 201.100(6)(2) and 201.55. 
g. "Adequate directions for use" means directions under which a layman could 
use a drug safely for the purposes for which it w
as intended. 21 C.F .R. § 201.5. 
h. Because a  prescription drug,  by definition, is safe for use only under the 
supervision 
of a  licensed practitioner, there are no directions that could enable a  layman to use a 
prescription drug safely absent that supervision.  Therefore, adequate directions for use could not 
be written for a prescription drug. 
1. A drug is misbranded if, among other things: 
i. any word, statement, or other information required by or under the 
authority 
of the FDCA to appear on the label or labeling was not prominently placed thereon in 
the English language and with such conspicuousness and in such terms as to render it  likely to be 
read and understood by the ordinary individual under customary conditions of purchase and use. 
21 U.S.C. § 352(c),
2 
21 C.F.R. § 201.15(c)(l); or 
1 
In an exemption not applicable here,  drugs distributed solely in the Commonwealth of Puerto 
Rico or 
in a Territory where the predominant language is one other than English, the predominant 
language may be substituted for English. 
2 
Drugs dispensed by prescription from a  practitioner licensed by law  were exempt from the 
requirements 
of 21 U.S.C. § 352(c) if the drug contained a label containing the name and address 
of the dispenser,  the serial number and date of the prescription and its filling,  the name of the 
4 

II. 
if its labeling failed to bear requisite " adequate directions for use." 
21 U.S.C. § 352(±)(1)3; or 
111. if its labeling failed to bear such adequate warnings against use in 
those pathological conditions or by children where its use may be dangerous to health, or against 
unsafe dosage or methods or duration of administration or application, in such manner and form, 
as are necessary for the protection of users. 21 U.S.C. § 352(±)(2). 
j. A drug 
is misbranded while held for  sale if,  among  other things, it is a 
prescription drug and 
is dispensed without a  prescription of a  practitioner licensed by law to 
administer such drug. 
21 U.S.C. § 353(6)(1). 
k. A drug 
is adulterated if it contains in whole or in part any filthy, putrid, or 
decomposed substance;  or 
if it  has been prepared, packed, or held under insanitary conditions 
whereby 
it may have been contaminated with filth or whereby it may have been rendered injurious 
to health. 
21 U.S.C. § 35l(a)(l). 
REYES SELLS WEIGHT LOSS DRUGS ON TIKTOK AND POSTS 
INSTRUCTIONAL VIDEOS ON HOW THE DRUGS SHOULD BE USED 
8. Based on my participation in this investigation,  my conversations with law 
enforcement special agents and officers,  my conversations with victims,  my review 
of social 
media, accounts, my review 
of communications, my review of documents and records, my review 
of shipping records,  and my review of physical evidence,  I  know,  among other things,  the 
following: 
prescriber, and, 
if stated in the prescription, the name of the patient, and the directions for use and 
cautionary statements, 
if any, contained in such prescription. 
3 
A prescription drug is misbranded if it did not comply with FDA regulations that exempted 
certain prescription drugs from the adequate directions for use requirement. In an exemption not 
applicable to the drugs marketed and sold by ISIS NAVARRO REYES,  the defendant,  FDA-
approved prescription drugs were exempted from the requirement 
of bearing labeling with 
adequate directions for use when they complied with regulations related to who possessed the drug 
and the contents 
of the drug's label and labeling. 21 C.F .R. §  201.100. For that exemption to 
apply, the drug' s  labeling requirements included that the label bore the statement "Rx only," the 
usual dosage, the route 
of administration, the quantity and proportion of each active ingredient and 
the names 
of all inactive ingredients for drugs not for oral use. 21 C.F .R. § 201.100; 21 C.F .R. 
§ 201.15(c)(l). Additionally, for that exemption to apply, the drugs must be 
in the possession of 
(1) a  person (or his agents or employees) regularly and lawfully engaged in the manufacture, 
transportation, storage, or wholesale distribution of prescription drugs; or (2) a retail, hospital, or 
clinic pharmacy,  or a public health agency, regularly and lawfully engaged in dispensing 
prescription drugs; or (3) a  practitioner licensed by law to administer or prescribe such drugs. 
Unapproved prescription drugs and prescription drugs that did not meet all 
of the conditions listed 
in 21 C.F .R. § 201.100 were misbranded for failing to bear adequate directions for use. 
5 

a. From at least in or about November 2022 through at least on or about 
November 2023,   ISIS NAVARRO REYES,   the defendant,   using the TikTok username 
" beralyreyes88" posted dozens 
of videos pertaining to weight loss drugs including, but not limited 
to, Ozempic, Axcion, and Mesotherapy. 
b. Ozempic. Ozempic is the brand name  for an FDA-approved prescription 
drug manufactured by Novo Nordisk A/S.   The active pharmaceutical ingredient 
in Ozempic is 
semaglutide.  Ozempic is administered by subcutaneous injection. Ozempic was indicated for use 
as "an adjunct to diet and exercise to improve glycemic control in adults with type 2  diabetes 
mellitus;  and to reduce the risk 
of major ad verse cardiovascular events in adults with type 2 
diabetes mellitus and established cardiovascular disease."
4 
Ozempic bears a  boxed warning, 
commonly referred to 
as a  " black box warning," which is the strongest warning FDA requires, 
indicating that the drug carries a significant risk 
of serious or even life-threatening adverse effects. 
The boxed warning addresses the risk 
of thyroid C-cell tumors.  Generally, foreign-market versions 
of Ozempic that are not approved by FDA could not lawfully be commercially distributed in the 
United States.
5 
Injectable products purporting to be Ozempic and intended to be used for weight 
loss or to treat type 2  diabetes are prescription drugs.   Over the past 
few  years,  the public has 
learned that semaglutide,  one 
of the active ingredients in Ozempic,  can assist in weight loss.
6 
Ozempic has quickly  become popular as a  weight-loss drug. Ozempic and other drugs with the 
same active ingredient-s
emaglutide-have been on the FDA' s drug shortage list since in or about 
March 
31, 2022. 
c. Axcion. Axcion is a brand of weight loss pills that are sold in Mexico. See 
"Axcion: The Mexican Brand of Phentermine," available: 
https://www.phentermine.com/brands/acxion/ (last accessed December 3,  2023). The active 
ingredient 
in Axcion, phentermine, is an appetite suppressant that is used to accelerate weight loss. 
See "Phentermine," av  ailable: https://www.drugs.com/phentermine.html (last accessed December 
3, 2023).  Axcion 
is not approved in the United States and may only be obtained in Mexico when 
prescribed by a doctor. 
d. Mesofrance. Mesoterapia, or mesotherapy in English, refers to a technique 
in which individuals inject microinjections of conventional homeopathic medication and/or 
vitamins into the mesoderm or middle layer 
of the skin to promote healing or corrective treatment 
4 
See Ozempic package insert. https://www.accessdata.fda.Q:ov/ 
drugsatfda docs/ label/2023/209637s020s021 lbl.pdf. (last accessed February 2, 2024). 
5 
In very limited circumstances not applicable here, the FDCA may permit certain pharmacists and 
wholesalers to import specific prescription drugs from Canada. 21 U.S.C. § 384. 
6 
See " Ozempic for weight loss: Does it  work and what do experts recommend?" Available: 
https ://health. ucdavis.ed u/b log/cultivating-health/ ozempic-for-weight-loss-does-it-work-and-
what-do-experts-
recommend/2023/07# :~:text= What%20is%20Ozem pic%3 F, the%20pancreas%20make%20more 
%20insulin. (last accessed December 3, 2023); 
see also "What ls Ozempic and Why Is It Getting 
So Much Attention?" N.Y. Times November 22, 2022,   updated November 13,   2023, 
https:/ /www.nytimes.com/2022/11 /22/well/ozempic-diabetes-weight-loss.html (last accessed 
December 4, 2023). 
6 

to a  specific area of the body.
7 
Mesotherapy is a  popular weight loss strategy. Mesofrance,  a 
Mexican pharmaceutical company,  offers its own prescription drug for use 
as Mesoterapia-
Triac-intended to, among other things,  assist users in losing unwanted body fat. Triac,  when 
intended 
to be injected for the purposes of weight loss or losing unwanted body fat, is a prescription 
drug and does not have a requisite drug approval from the FDA. Mesofrance has a  directory of 
approved distributors on its website. 
8 
e. In her videos,9 REYES showcases the weight loss drugs, instructs viewers 
how frequently they should be used, describes how they should be taken or injected, and claims to 
describe her personal 
experiences-for example, side effects and effectiveness in causing weight 
loss-in detail. In several of these videos, REYES tells viewers that they can contact her via an 
encrypted messaging application using a number ending 
in -4416 (the "Cellphone") if they would 
like to order the weight loss drugs that she 
is selling.  The paragraphs below offer a representative 
sample 
of the videos REYES posted and a sample of certain messages REYES sent to viewers via 
an encrypted messaging application. 
f. In or about November 2022, a  woman who had viewed content posted to 
REYES' s TikTok account ("Victim-I")  called the call number assigned to the Cellphone for the 
purpose 
of ordering weight loss drugs. The individual who answered Victim-1 ' s call identified 
herself as "Isis Navarro Reyes." 
g. On or about March 3, 2023, REYES sent a video of a tutorial pertaining to 
burning localized fat using Mesofrance to a group chat consisting 
of individuals who had expressed 
interest 
in purchasing her products via an encrypted messaging application. The text at the bottom 
of the video directs viewers to place orders via the call number assigned to the Cellphone. A 
screenshot from this TikTok post 
is below. 
7 
See "Mesotherapy," available: 
https ://pubmed.ncbi.nlm.nih.gov / 17314456/#:-:text=Mesotherapy%20is%20a%20technique%20 
which,specific%20area%20of0/o20the%20body. (last accessed December 3, 2023). 
8 
See "Dealers,"  available https://mesofrance.com/distribuidores/ (last accessed December 3, 
2023). 
9 
ISIS NAVARRO REYES,  the defendant,  posts primarily in Spanish. To the extent posts or 
messages were originally 
in the Spanish language, I have been assisted in reviewing this content 
by 
an investigator with the United States Attorney' s Office for the Southern District of New York 
who 
is fluent in the Spanish language. The Spanish language translations included in this 
Complaint are drafts and subject to change. 
7 

h. On or about April 15, 2023, the call number assigned to the Cellphone sent 
a  message via an encrypted messaging application to Victim-I 
in which the sender identifies 
herself as "Isis Navarro." 
i. On or about October 
11,  2023,  REYES posted a video pertammg to 
Ozempic. 
In this video, REYES demonstrates how to inject oneself with the medication and shares 
her experience using the drug. Toward the end 
of the video, REYES instructs viewers to contact 
her on an encrypted messaging application via the call number assigned to the Cellphone 
if they 
are interested 
in having her obtain Ozempic for them.  A screenshot from this TikTok post is below. 
8 

j . On or about October 12, 2023, REYES posted a video in which she can be 
seen placing boxes 
of Axcion into shipping envelopes. A screenshot from this TikTok post is 
below. 
9 

k. On or about November 28, 2023, REYES posted a video about Mesofrance. 
In the video, REYES instructs viewers where the injections can be injected and that the drugs are 
used for burning fat. A screenshot from this TikTok post 
is below. 
I. In or about November 2023,  the United States Department of Homeland 
Security,  Homeland Security Investigations provided a  photo from a  2019 United States Visa 
application associated with the name "Isis Navarro Reyes"  (the "Visa Application"
). The photo 
from the Visa Application closely resembles REYES. 
VICTIM-1 DEVELOPS MULTIPLE MYCOBACTERIUM ABSCESSUS AFTER 
USING MESOTHERAPY PURCHASED FROM REYES 
9. Based on my participation in this investigation,  my conversations with law 
enforcement special agents and officers, my review 
of electronic devices, my conversations with 
witnesses,  my review 
of communications,  my review of documents and records,  my review of 
shipping records, and my review of physical evidence, I know, among other things, the following: 
a. In or about February 2023, Victim-I purchased 30 injections ofMesofrance 
from ISIS NAVARRO REYES,  the defendant. REYES mailed the Mesofrance to Victim-1 ' s 
residence,  which 
is in White Plains,  New York. REYES did not ask  Victim-I to provide a 
prescription and Victim-I  did not provide one. 

b. Between in or about February  2023 and in or about June 2023,  Victim-I 
self-administered 28 injections. In an audio message that she recorded and transmitted through an 
encrypted messaging application,  REYES provided Victim-I with instructions on how to 
administer the drug; REYES told Victim-I , among other things, to inject herself every three days. 
c. All of the label and labeling of the vials that contained the Mesofrance that 
Victim-I purchased from REYES were 
in a language other than English. 
d. On or about July 13,  2023,  Victim-I began developing lesions from 
administering the Mesofrance. Victim-I sent Spanish-language messages to REYES about her 
injuries and sent photos. 
e. In or about October 2023,  Victim-1 ' s  physician diagnosed her with a 
mycobacterium abscessus infection,   which 
is frequently caused by the contamination of 
medications, medical products, and medical devices with the mycobacterium abscessus bacterium. 
f. In or about November 2023, the New York Department of Health tested one 
of the v ials of Mesofrance that Victim- I  purchased from REYES.  The substance tested positive 
for mycobacterium abscessus,  a  species 
of rapidly  grow ing,  multidrug-resistant,  nontuberculous 
mycobacteria. 
U.S. CUSTOMS AND BORDER PROTECTION SEIZES A PACKAGE 
CONTAINING FOREIGN WEIGHT LOSS DRUGS AND NOTIFIES REYES OF 
THE SEIZURE 
10. Based on my participation in this investigation,  my conversations with law 
enforcement special agents and officers,  my re view of electronic dev ices,  and my review of 
documents and records, I know, among other things, the following: 
a. On or about January 27,  2023,  agents with U.S. Customs and Border 
Protection (" CBP") seized a parcel sent from Mex ico w ith "Beraly Navarro"  listed as the recipient 
(the " Intercepted Package"
). 
10 
b. The Intercepted Package contained weight loss drugs, including dozens of 
boxes of Axcion.  A photo depicting some of the contents of the Intercepted Package is below: 
10 
Based on my  participation in this investigation,  I  know that ISIS NAVARRO REYES,  the 
defendant, also used the name "Beraly."  For example, REYES had a TikTok account w ith a handle 
that used the name "Beraly" and, 
in addition, the email address listed in the subscriber information 
for this TikTok account also used the name "Beraly." 
11 

c. On or about March 22,  2023,  CBP sent ISIS NAVARRO REYES,  the 
defendant
11
, 
a  letter (the "CBP Letter")  informing her that, on or about January 27, 2023, agents 
seized the Intercepted Package, that 
it contained Phentermine
12 
and D-norpseudoephedrine, and 
that importation 
of these substances into the United States violated provisions of the United States 
Code prohibiting the importation 
of Schedule IV controlled substances and adulterated or 
misbranded products. 
VICTIM-2 PURCHASES FOREIGN DIET MEDICATION NOT APPROVED BY 
THE FDA FROM REYES 
11. Based on my participation in this investigation,  my conversations with law 
enforcement special agents and officers, my review 
of communications, my review of documents 
and records, my review 
of shipping records, and my review of physical evidence, I know, among 
other things, the following: 
11 
The letter is addressed to "Beraly Navarro." As explained in footnote 8, supra, based on my 
paiticipation 
in this investigation, I understand that ISIS NAVARRO REYES, the defendant, also 
went by the name "Beraly Navarro." 
12 
Based on my participation in this investigation, I  know that Axcion boxes have the word 
" fentermina,"  which based on my consultation with individuals fluent in the Spanish language, 
means "phentermine." 
12 

a. In or about June 2023, an individual ("Victim-2") contacted ISIS 
NAVARRO REYES,  the defendant,  via 
an encrypted messaging application at the number 
assigned to the Cellphone to inquire about purchasing weight-loss drugs.  Victim-2 asked REYES 
to sell her Axcion. 
b. On or about July 10,  2023,  Victim-2 sent REYES money to purchase 
Axcion. REYES did not ask Victim-2 to provide a prescription and Victim-2 did not provide one. 
c. On or about July 12, 2023, REYES mailed Victim-2 a substance labeled as 
Axcion from Center Moriches, New York to Victim-2' s residence 
in North Brunswick, New Jersey 
via United States Postal Service ground advantage. Based on my conversations with inspectors 
from United States Postal Service ("USPS"),  I  understand that the package was transported via 
motor vehicle and that,  based on the path USPS typically takes to transport packages by motor 
vehicle from this original to this destination, the motor vehicle passed through the Southern District 
of New York. A photo of the Axcion that REYES mailed Victim-2 is below: 
d. All 
of the label and labeling of the substance labeled as Axcion that Victim-
2 purchased from REYES was 
in the Spanish language. 
13 

REYES SOLD VICTIM-2 AXCION AFTER RECEIVING THE CBP LETTER 
12. Based on my participation in this investigation, my conversations with law 
enforcement special agents and officers, my review of communications, my review of documents 
and records, and my review 
of physical and electronic evidence I know, among other things, the 
following: 
a. On or about February 
15, 2024, law enforcement officers and special agents 
executed a  search warrant for two residences associated with ISIS NAVARRO REYES,  the 
defendant. 
b. Law enforcement officers and special agents seized,  among other things, 
multiple boxes 
of different weight loss drugs, syringes, antibiotics, and multiple electronic devices, 
including an iPhone that REYES identified as belonging to her ("REYES' s Phone"
). 
c. Law enforcement officers and special agents searched REYES' s  Phone 
pursuant 
to the search warrant. The search of REYES' s Phone revealed, among other things, that 
on or about March 4, 2023, REYES took a photo 
of the first page of the CBP Letter. 
REYES SELLS MISBRANDED OZEMPIC TO AN UNDERCOVER LAW 
ENFORCEMENT OFFICER 
13. Based on my participation in this investigation, my conversations with law 
enforcement special agents and officers, my review 
of communications, my review of documents 
and records, 
my review of shipping records, and my review of physical evidence, I know, among 
other things, the following: 
a. In or about December 2023,  a law enforcement officer acting in an 
undercover capacity (the "UC") began messaging ISIS NAVARRO REYES, the defendant, via an 
encrypted messaging application at the call number assigned 
to the Cellphone. 
b. From in or about December 2023 through in or about January 2024, the UC 
and REYES exchanged several messages via an encrypted messaging application concerning 
REYES' s supply 
of Ozempic and  the UC's interest in purchasing Ozempic from REYES. 
c. On or about January 7, 2024, pursuant to instructions from REYES, the UC 
sent $375 
to a Zelle account in the name of "Isis Reyes Navarro." REYES did not ask the UC to 
provide a prescription and the UC did not provide one. 
d. On or about January 9, 2024, REYES dropped off a package intended for 
the UC at a post office located 
in or around Shirley, New York. 
e. On or about January 12,  2024,  law enforcement received a  package 
addressed to the UC from REYES (the "UC Parcel") 
in Manhattan. The UC Parcel contained a 
box containing what purported to be Ozempic. 
13 
Photos of packaging containing the purported 
Ozempic that REYES mailed the UC are below: 
13 
To date, there is no evidence that the Ozempic that REYES sold the UC is not genuine. 
14 

Semaglutida 
1,34mg/ml 
Soluci6n inyectable en 
pluma precargada 
f. All of the label and labeling accompanying the Ozempic in the UC Parcel 
was in the Spanish language. 
U.S. CUSTOMS AND BORDER PROTECTION INTERCEPTS AN INTERNATIONAL 
PARCEL INTENDED FOR REYES AND CONTAINING PURPORTED OZEMPIC 
14. Based on my participation in this investigation,  my conversations with other law 
enforcement special agents and officers, and my review 
of documents and records, I know that on 
or about January 30,  2024,  U.S. Customs and Border Protection officers located 
in or around 
Miami, Florida intercepted a parcel that was shipped from an individual in El Salvador 
("CC-I") 
and addressed to ISIS NAVARRO REYES, the defendant (the "Salvadorian Parcel"). 
15. The Salvadorian Parcel contained,  among  other things,  five boxes 
of purported 
Ozempic.
14 
All of the label and labeling accompanying the purported Ozempic was in the Spanish 
language. 
14 
Law enforcement has not yet determined whether the purported Ozempic is counterfeit. 
15 

REYES ACKNOWLEDGES SELLING WEIGHT 
LOSS DRUGS ON TIKTOK 
16. Based on my participation in this investigation and my conversations with other 
law enforcement special agents and officers,  I  know that on or about February 15,  2024,  ISIS 
NAVARRO REYES, the defendant, participated 
in a consensual, non-custodial interview with law 
enforcement special agents and officers (the "Interview").  During the Interview, REYES stated, 
in sum and substance, among other things, the following: 
a. She had been selling products on TikTok for one year; 
b. She has sold Ozempic five times 
in the past; 
c. She sends money to another individual, who ships Ozempic to her from El 
Salvador; 
d. She purchased Mesofrance on Facebook; 
e. She stopped selling Mesofrance because she knew it was illegal and did 
not want any problems; and 
f. She knew that it was illegal to sell medication to others unless she was a 
doctor, nurse practitioner, or member 
of the medical field. 
WHEREFORE,  I  respectfully request that a  warrant be issued for the arrest 
of ISIS 
NAVARRO REYES, the defendant, and that she be arrested, and imprisoned or bailed, as the case 
may be. 
JASON FERNAND'ifs 
SPECIAL AGENT 
U.S. FOOD AND DRUG ADMINISTRATION 
-OFFICE 
OF CRIMINAL INVESTIGATIONS 
Sworn to before me this 
L.: ay of April 2024. 
THEH~·MSES 
United States Magistrate Judge 
Southern District 
of New York 
16