Complaint — No. 3:20-mj-01407 (Dkt. 1, S.D. Cal.)

Summary

A criminal complaint filed April 16, 2020 as Document 1 in United States v. Jennings Ryan Staley, Case No. 20mj1407, in the U.S. District Court for the Southern District of California, charging mail fraud under Title 18 U.S.C. § 1341 for causing a package containing a COVID-19 Treatment Pack to be delivered by mail on or about April 10, 2020. The statement of probable cause by FBI Special Agent Terrence Mycka, sworn before Magistrate Judge Jill L. Burkhardt, states that Skinny Beach Med Spa in San Diego offered a COVID-19 Concierge Medicine Pack (Family) for $3,995.00 that included hydroxychloroquine and azithromycin. It quotes recorded calls in which Staley told an undercover agent the drug was a 100% cure and preventive and described smuggling hydroxychloroquine powder from China. It cites CBP records of a DHL package described as yam extract.

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