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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-80049-CR-MARRA

UNITED STATES OF AMERICA

vs. 

LEONARD SHEMTOB and 

STRONG SUPPLEMENTS, LLC, 

Defendants. 

___________________________________/

NOTICE OF RELATED ACTION, LOCAL RULE 3.8

The United States of America, through undersigned counsel, respectfully files this Notice 

of Related Action, pursuant to Local Rule 3.8, which provides that attorneys shall bring promptly 

to the attention of the Court and opposing counsel the existence of other actions or proceeding as

described in Section 2.15.00 of the Court’s Internal Operating Procedures (“IOP”). Counsel for 

defendants Shemtob and Strong Supplements, LLC has reviewed this pleading and does not 

oppose transfer pursuant to the Local Rules. 

IOP section 2.15.00 provides that whenever an action is filed in the Court that involves 

subject matter which is a material part of the subject matter of another action pending before the 

Court “or for other reasons the disposition thereof would appear to entail the unnecessary 

duplication of judicial labor if heard by a different Judge,” the Judges involved in the actions “shall 

determine whether the higher-numbered action or proceeding shall be transferred to the Judge 

assigned to the lower-numbered action.”

On March 7, 2019, a Grand Jury, sitting in Miami, returned an indictment against Phillip 

Braun, Blackstone Labs, LLC (“Blackstone Labs”), five other individuals, and a second limited 

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liability corporation (“the Braun case”). The case was assigned to Judge Dimitrouleas under case 

number 19-80030-CR. Count 4 of the indictment charged Braun, Aaron Singerman, Blackstone 

Labs, and co-defendants with conspiring to distribute controlled substances, e.g., anabolic steroids, 

in violation of 21 U.S.C. § 846. The case is set for trial on October 26, 2020. 

On June 19, 2020, the United States filed an information against Leonard Shemtob and 

Strong Supplements, LLC (“Strong Supplements”). The case was assigned to Judge Marra under 

case number 20-80049-CR. The information charged that defendants Shemtob and Strong 

Supplements conspired with defendants in the Braun case — Braun, Aaron Singerman, and 

Blackstone Labs — to distribute controlled substances, in violation of 21 U.S.C. § 846. The 

conspiracy charged in case number 20-80049-CR involved three of the same anabolic steroids 

alleged in Count 4 of the Braun case.

The subject matter of Case No. 20-80049-CR is a material part of Count 4 of the Braun 

case. In other words, the later-filed case charges essentially the same drug conspiracy as was 

charged in Count 4 of the indictment returned last year. 

Further, in the Braun case, the conspiracy to distribute controlled substances included the 

allegation that serious bodily injury resulted to C.H. from the use of a specific anabolic steroid. 

See Case No. 19-80030-CR-WPD, Indictment, ECF No. 1, at 19. The product alleged to have 

resulted in serious bodily injury to C.H. was sold by Blackstone Labs to defendant Strong 

Supplements, and C.H. then purchased the product from Strong Supplements. Accordingly, there 

is significant factual overlap between this case and the Braun case, and the Shemtob/Strong 

Supplements subject matter is undoubtedly material to the Braun case. 

It would be judicially expedient for Judge Dimitrouleas to hear the newly filed case against 

Shemtob and Strong Supplements insofar as Judge Dimitrouleas has already expended 

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considerable judicial resources in connection with the earlier-filed Braun case, No. 19-80030-CR,

and is familiar with many of the underlying facts and legal issues that both cases share. 

In conclusion, consistent with Local Rule 3.8 and IOP 2.15.00 and to avoid unnecessary 

duplication of judicial labor, the government respectfully requests that the Court confer with Judge 

Dimitrouleas to decide whether a transfer of the present case to Judge Dimitrouleas would be 

appropriate. Government counsel has conferred with Daniel Behesnilian, counsel for defendants 

Shemtob and Strong Supplements, and he does not oppose such a transfer. 

DATED: June 24, 2020

Respectfully submitted,

ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

GUSTAV W. EYLER

DIRECTOR

CONSUMER PROTECTION BRANCH

U.S. DEPARTMENT OF JUSTICE

/s/ Alistair Reader

By: ALISTAIR F. A. READER

Court ID A5502377

STEPHEN J. GRIPKEY

Court ID A5502620

JOHN W. BURKE

Court ID A5501294

Trial Attorneys 

U.S. Department of Justice

Consumer Protection Branch

450 Fifth Street, NW Suite 6400-South

Washington, DC 20001

Alistair.F.Reader@usdoj.gov

(202) 353-9930 

Stephen.Gripkey@usdoj.gov

(202) 307-0048

Josh.Burke@usdoj.gvo

Case 9:20-cr-80049-WPD Document 2 Entered on FLSD Docket 06/24/2020 Page 3 of 4
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(202) 353-2001

(202) 514-8742 (facsimile)

CERTIFICATE OF SERVICE

I hereby certify that on June 24, 2020, a copy of the foregoing document was filed 

electronically with the Clerk of the Court by way of the CM/ECF system. Notice of this filing will 

be sent to all counsel of record by operation of the CM/ECF system. Parties may access this filing 

through the CM/ECF system. An electronic copy of the filing will also be provided to defense 

counsel Daniel Behesnilian, Esq. via email. 

/s/ Alistair Reader

Alistair F. A. Reader

Trial Attorney

U.S. Department of Justice

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