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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-80049-CR-WPD

UNITED STATES OF AMERICA

v. 

LEONARD SHEMTOB and 

STRONG SUPPLEMENTS, LLC, 

Defendants. 

___________________________________/

JOINT MOTION TO CONDUCT INITIAL APPEARANCE, WAIVER OF 

INDICTMENT AND ARRAIGNMENT BY VIDEOCONFERENCE

The United States of America and defendants Leonard Shemtob and Strong Supplements, 

LLC, by and through undersigned counsel, hereby jointly move the Court for an order allowing

defendant Leonard Shemtob, who is also the representative for defendant Strong Supplements, 

LLC, and defendants’ counsel1 to appear by videoconference for defendants’ initial appearance, 

waiver of indictment, and arraignment in this case. On June 19, 2020, the defendants were

charged by criminal information with conspiracy to distribute controlled substances, in violation 

of 21 U.S.C. § 846. ECF No. 1. 

The defendants intend to waive indictment and do not dispute the jurisdiction of this 

Court. The defendants are both represented by Daniel Behesnilian, Esq., who is located in 

Beverly Hills, California. The defendant, Leonard Shemtob, resides in California and is not in 

custody. The defendant, Strong Supplements, is incorporated in Delaware and maintained 

business addresses in Nevada and California. The government intends to recommend that, under 

 1 Defense counsel Daniel Behesnilian, Esq. is in the process of retaining local counsel in the Southern District of 

Florida.

Case 9:20-cr-80049-WPD Document 4 Entered on FLSD Docket 07/30/2020 Page 1 of 4
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the circumstances, defendant Leonard Shemtob remain on pretrial release with appropriate 

conditions of release. The parties agree that requiring the defendants and counsel to physically 

travel to the Southern District of Florida for these pretrial hearings would create unnecessary 

health risks for the Court, defendant, and counsel. 

The parties therefore respectfully request permission to appear by videoconference for 

the initial appearance, waiver and the arraignment. Pursuant to Rules 5(f) and 10(c) of the 

Federal Rules of Criminal Procedure, the defendants consent to participating in the initial 

appearance and the arraignment by video teleconferencing, and waives any potential claims 

based on the appearance via teleconference. The parties’ request is consistent with the Southern 

District of Florida Administrative Order 2020-40 concerning authorization under the CARES 

Act to conduct certain criminal proceedings by video or audio conference. The Administrative 

Order authorizes, with the consent of the defendant after consultation with counsel, to use video 

conferencing or telephone conferencing of video conferencing is not reasonably available for 

initial appearances, waivers of indictment, and arraignment pursuant to the Federal Rules of 

Criminal Procedure. 

Case 9:20-cr-80049-WPD Document 4 Entered on FLSD Docket 07/30/2020 Page 2 of 4
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CONCLUSION

WHEREFORE, for the foregoing reasons, the parties jointly and respectfully request 

that this Court enter an order allowing the defendants and counsel for defendant to appear by 

videoconference or telephone for defendants’ initial appearance and arraignment. 

DATED: July 30, 2020

Respectfully submitted,

 /s/ Daniel V. Behesnilian 

Daniel V. Behesnilian, Esq. 

Law Offices of Daniel V. Behesnilian

8484 Wilshire Blvd. Suite 700

Beverly Hills, CA 90211

Tel: (310) 854-6972

Fax: (310) 854-0128

Email: daniel@dvblaw.net

ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

GUSTAV W. EYLER 

DIRECTOR 

CONSUMER PROTECTION BRANCH 

U.S. DEPARTMENT OF JUSTICE 

 /s/ Alistair Reader

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.gov

(202) 353-2001

(202) 514-8742 (facsimile)

Case 9:20-cr-80049-WPD Document 4 Entered on FLSD Docket 07/30/2020 Page 3 of 4
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CERTIFICATE OF CONFERENCE (LOCAL RULE 88.9A)

Under local Rule 88.9A, I HEREBY CERTIFY that I conferred with counsel for 

defendants Leonard Shemtob and Strong Supplements, who join in the motion. 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I electronically filed the foregoing document with the Clerk 

of the Court using CM/ECF this July 30, 2020, and served a copy on all counsel of record via 

email.

 /s/ Alistair Reader

Alistair Reader

Trial Attorney

Case 9:20-cr-80049-WPD Document 4 Entered on FLSD Docket 07/30/2020 Page 4 of 4