UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

PECOS DIVISION

UNITED STATES OF AMERICA § 

§ 

Plaintiff, § 

§ 

v. § P: 20-CV- 

§ 

MICHAEL MARC TRAVALINO § 

aka “MARK WHITE EAGLE” § 

 § 

Defendant § 

COMPLAINT FOR TEMPORARY RESTRAINING ORDER, 

PRELIMINARY INJUCTION AND PERMANENT INJUNCTION

For its Complaint against Michael Marc Travalino, aka “Mark White Eagle”

(“Defendant”), the United States of America (“United States”) alleges as follows:

INTRODUCTION

1. Defendant is engaging in and facilitating a predatory mail and wire fraud scheme 

exploiting the current COVID-19 pandemic.1

2. Defendant is the owner and operator of the website “whiteeaglenativeherbs.net,” 

wherein Defendant is selling products online that are purported to treat and cure COVID-19, 

other illnesses and diseases such as cancer, blood clots, and skin disorders. 

3. The claims made personally by Defendant and through the website 

“whiteeaglenativeherbs.net” are false. 

 

1 There is currently a global outbreak of respiratory disease caused by a novel coronavirus that 

has been named “severe acute respiratory syndrome coronavirus 2” (SARS-CoV-2). The disease 

caused by the virus has been named “Coronavirus Disease 2019” (COVID-19). FILED 

6/1/2020 

Clerk, U.S. District Court 

Western District of Texas 

by: Y. Lujan 

Deputy Clerk Case no: P:20-cv-046

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4. As determined by the World Health Organization (“WHO”), the United States

Centers for Disease Control and Prevention (“CDC”) and the United States Food and Drug 

Administration (“FDA”), there are, as of yet, no known or authorized cures for COVID-19. 

5. The purpose of the website is to induce victims to pay Defendant, and those 

working in concert with him, significant sums for products that are falsely represented to be 

effective treatments for various diseases and human pathogens, including coronaviruses.

Additionally, the Defendant accepts orders over the phone and in person at his store, where he 

also accepts credit card payments.

6. The web site whiteeaglenativeherbs.net is controlled and operated by Defendant. 

The reseller web host for this domain is GoDaddy.com, LLC, headquartered at 14455 North 

Hayden Rd, Ste. 219, Scottsdale, AZ 85260.

7. The United States seeks to prevent continuing and substantial injury to victims of 

this fraudulent scheme by bringing this civil action under 18 U.S.C. § 1345 to enjoin Defendant’s

ongoing mail and wire fraud in violation of 18 U.S.C. §§ 1341 and 1343, respectively.

JURISDICTION AND VENUE

8. The Court has subject matter jurisdiction over this action under 18 U.S.C. § 1345 

and 28 U.S.C. §§ 1331 and 1345.

9. Venue is proper in this district under 28 U.S.C. § 1391(b)(1) because Defendant 

resides in this district. Venue is also proper in this district under 28 U.S.C. § 1391(b)(2) because 

a substantial part of the events or omissions giving rise to the claims asserted herein occurred in 

this district.

THE PARTIES

10. Plaintiff is the United States of America.

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11. Defendant, Michael Marc Travalino, acting alone or in concert with others,

operated the website “whiteeaglenativeherbs.net” who has formulated, directed, controlled, had 

the authority to control, or participated in the acts and practices set forth in this Complaint. 

FRAUDULENT SCHEME

12. On or about April 28, 2020, the FBI, El Paso Division, received a complaint from 

a member of the public that Michael Travalino, who purported to be a “Medicine Man” and 

“Shaman,” was advertising on posted flyers that he had “formulas that are proven to work and 

distroy [sic]” “corona virus.” Next to the flyers were business cards, in both English and Spanish 

which provided contact information for “White Eagle.” The contact information included the 

phone number (575) 910-0849, address P.O. Box 1341, Alpine, TX 79831, web address 

www.whiteeaglenativeherbs.net and email address WhiteEagle@whiteeaglenativeherbs.net. 

13. The phone number (575) 910-0849 is registered to Michael M. Travalino, PO Box 

1341, Alpine, TX 79831.

14. On or about May 4, 2020, FBI Special Agent Alice D. Downie, from a computer 

located in Alpine Texas, visited the website www.whiteeaglenativeherbs.net and observed a tab 

on the website which read “WEB STORE.” Upon clicking on this tab, SA Downie observed 

approximately 73 products for sale, including:

“YAHWEH (All plagues, viruses, fungus, Corona Virus. $150.00,” 

“KOLON KLEEN, Works Against Corona Virus $38.00,” 

“MASKA MIAKODA, Works With Yaweh Formula for Corona Virus. $75.00” and

SHAR MAR FORMULA (Respiratory & Skin Disorders) $100.00”

15. On or about May 28, 2020, SA Downie selected an item from the “WEB STORE” 

which placed the item in a virtual “Cart.” SA Downie was then able to checkout to order the item 

and was directed to pay for the item using PayPal.

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16. On or about May 4, 2020, an FDA Special Agent, who was working in a covert 

capacity, called (575) 910-0849 (the phone number registered to Defendant) and a man 

answered, who identified himself as Marc White Eagle. 

17. The FDA Special Agent asked if White Eagle had any medication in stock to treat 

the coronavirus or COVID-19. White Eagle stated he did, and directed the FDA Special Agent to 

his website, whiteeaglenativeherbs.net. White Eagle said to look at three items on the website 

that would heal all viruses: Yahweh, Shar Mar Formula, and Maska Miakoda. 

18. The FDA Special Agent said his grandmother was in the hospital in another state 

outside of Texas, suffering from COVID-19, and the products were to treat her. White Eagle told 

the Special Agent to get her out of the hospital or she would die there. White Eagle said that if he 

could not get her out of the hospital, he should sneak some of the medicine into her water 

without telling the doctors. 

19. White Eagle said the medicines had to be taken every day and they were 100% 

pure. White Eagle said he did not need to conduct an exam of the patient. If the patient took the 

medicine, no doctor or hospital was needed, and results would be seen right away. 

20. White Eagle agreed to meet the FDA Special Agent on or about May 5, 2020 at 

237 Grant Drive, Fort Davis, Texas, to sell him the medicine.

21. On or about May 5, 2020, an FDA Special Agent, working in an undercover 

capacity, called (575) 910-0849 and spoke to White Eagle. White Eagle provided directions to 

his place of business, located in the vicinity of 237 Grant Drive, Fort Davis, Texas, where they 

then met. 

22. Based on photographs available to law enforcement, the FDA Special Agent 

identified White Eagle as Michael Travalino, Defendant. 

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23. While meeting with Defendant inside his place of business, the FDA Special 

Agent observed several bottles and other containers appearing to contain products he was selling 

along with shipping boxes and tape. 

24. During the meeting, Defendant stated that he manufactured his own products from 

secret recipes and sold them from both his warehouse, where they were meeting, and online, to 

treat various diseases to include coronavirus and Ebola. 

25. The FDA Special Agent purchased products totaling $460, which Defendant

stated would kill the coronavirus. Defendant understood that the FDA Special Agent would be 

transporting these products outside of Texas. These products included Kolon Kleen, Maska 

Miakoda, and Yahweh. 

26. Defendant provided written and verbal instructions on how to use and administer 

the products to patients suffering from coronavirus. Defendant said he guaranteed the FDA 

Special Agent’s grandmother would not die if she took the products. Defendant recommended 

giving the products to anyone with coronavirus, and he recommended the FDA Special Agent 

take them as well.

27. FBI SA Downie witnessed the meeting between the FDA Special Agent and 

Defendant. The place of business was a portable-type storage building with a travel trailer parked 

next to it on the west side. A blue 2002 Chevrolet Trailblazer, Arizona license plate BB0358, 

registered to Defendant, was parked at the front of the building. A purple 1984 Cadillac Deville, 

Arizona license plate BB0016, registered to Defendant, was parked at the rear of the building.

28. On, or about, May 14, 2020, Richard Quaresima, Acting Associate Director, 

Division of Advertising Practices, Federal Trade Commission (“FTC”) and Donald D. Ashley, 

Director for the Office of Compliance of FDA’s Center for Drug Evaluation and Research 

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(“CDER”) sent a Warning Letter to Defendant at his known email address of 

whiteeagle@whiteeaglenativeherbs.net. The Warning Letter referenced the unapproved and 

misbranded products related to coronavirus disease 2019 (COVID-19) being advertised for sale 

on his web site www.whiteeaglenativeherbs.net. 

29. This Warning Letter specifically instructed Defendant to take immediate action to 

cease the sale of such unapproved and unauthorized products for the mitigation, prevention, 

treatment, diagnosis, or cure of COVID-19 on his website because Defendant is falsely 

representing his products as an effective treatment for that disease. 

30. In addition, this Warning Letter instructed Defendant to complete specific steps to 

correct the violations within 48 hours. 

31. This letter was also posted to the public on the FDA website 

https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warningletters/white-eagle-native-herbs-607744-05142020. 

32. On May 18, 2020, a read receipt was received by FDA Consumer Safety 

personnel at approximately 11:09 a.m. Eastern Time, indicating the email had been opened.

33. On May 20, 2020, at approximately 2:23 p.m., Mountain Time, an FDA Special 

Agent navigated to Defendant’s website www.whiteeaglenativeherbs.net to see if the site still 

advertised products for sale that were specifically listed as Unapproved and Misbranded Products 

Related to Coronavirus Disease 2019 (COVID-19) in the Warning Letter issued on May 14, 

2020. 

34. After confirming the products were still advertised for sale, an FDA Special 

Agent, in an undercover capacity, purchased the following products offered for sale through the 

website www.whiteeaglenativeherbs.net, with claims to treat and/or cure “Corona Virus”:

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YAHWEH Capsules

KOLON KLEEN powder

MASKA MIAKODA liquid

YAHWEH Liquid

35. After completing the purchase, the FDA Special Agent was issued Receipt 

Number # 9L126369JJ9399124 through the same website.

36. On May 20, 2020, at approximately 3:10 p.m., Mountain Time, an FDA Special 

Agent, acting in an undercover capacity, called Defendant on his cell phone, 575-910-0849, to 

confirm he had received the online order of products. Defendant stated he was not home and had 

not received the order, but would check on it when he returned home.

37. On May 20, 2020, at approximately 7:47 p.m., Mountain Time, an FDA Special 

Agent received a text message from Defendant’s phone, 575-910-0849. This text stated the 

following:

Ur box was sent off today to Indian Hills Co 80454 today an Expected Delivery Day is 

tuesday 05/56/2020 Ur Tracking No. Is: 9505514204560142221644. Thanks for your 

purchase by Marc Whiteeagle at 575-910-0849.

38. On May 22, 2020, at approximately 9:58 a.m., Mountain Time, an FDA Special 

Agent, acting in an undercover capacity, called Defendant on his cell phone, 575-910-0849, and 

asked Defendant if he had indeed received the order for products. During this call, Defendant

stated he had sent a text giving the tracking number and that he had indeed shipped out the 

products on May 20, 2020. 

39. On or about May 27, 2020, the package was received by an FDA Special Agent, 

who was located in a state other than Texas, who verified it contained most of the products 

ordered online on May 20, 2020. The package was mailed via United States Postal Service 

Priority Mail. The package contained the items ordered except for the Yahweh capsules, which 

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were missing. The return address on the package was one of Defendant’s business cards, which 

matched those displayed with the flyers in Fort Davis, Texas.

40. On May 28, 2020, at approximately 5:11 p.m., Eastern Time, FDA/CDER 

received an email from “James LeBlanc” (email address jamesleblanc82@yahoo.com) with the 

subject line “Compliance Letter White Eagle Native Herbs.” The email attached a letter from 

Mark White Eagle, which stated:

To: Covid-19 Task Force

From: Mark White Eagle White Eagle Native Herbs

Re: Response to letter dated May 14, 2020

Date: 5/28/2020

This is a response to a letter received on 5/28/2020. I’m a Native American Medicine 

Man and Shaman as referenced in my web site. I’m recognized by the Department of 

Interior and Bureau of Indian Affairs and I believe that I’m operating under Public Law 

95-341 95th Congress protecting Native Americans. I’m domiciled in the Navaho [sic] 

Nation and not a u.s. citizen. However I’m willing to have all Covid-19 references to all 

six products mentioned and anywhere else it may be within the web site cited in your 

letter by my web site contacts as soon as possible. Further contact can be made through 

the E-Mail address of jamesleblanc82@yahoo.com due to my limited access to internet 

however I prefer that you use my U.S.P.S. temporary address at Alpine TX, 79831 PO 

BOX 1341. 

Respectfully Submitted,

Mark White Eagle Medicine Man and Shaman

See Exhibit E.

41. Defendant’s response serves as further confirmation that he received the Warning 

Letter from the FDA. In his response, Defendant does not make any affirmative representation 

that he will cease and desist from selling his fraudulent products. More significantly, as recently 

as May 29, 2020, Defendant continued to offer for sale to the public, through his 

“whiteeaglenativeherbs.net” website the products that were specifically listed as Unapproved and 

Misbranded Products Related to Coronavirus Disease 2019 (COVID-19) in the FDA Warning 

Letter

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42. Defendant’s statements that his products treat and cure COVID-19 are false and 

fraudulent. The WHO, FDA and CDC have all concluded and made publicly known, that there 

are no cures or preventative drugs for COVID-19. See WHO website 

(https://www.who.int/emergencies/diseases/novel-coronavirus-2019/advice-for-public/mythbusters); CDC website (https://www.cdc.gov/coronavirus/2019-ncov/hcp/therapeuticoptions.html) and FDA website (https://www.fda.gov/consumers/health-fraud-scams/fraudulentcoronavirus-disease-2019-covid-19-products).

43. Victims suffer financial losses from the mail and wire fraud scheme engaged in 

and facilitated by Defendant. 

44. Absent injunctive relief by this Court, Defendant’s conduct will continue to cause 

injury to victims.

COUNT ONE

18 U.S.C. § 1341 

MAIL FRAUD

45. The United States re-alleges and incorporates each of the preceding paragraphs as 

though fully set forth herein.

46. By reason of the conduct described herein, Defendant has violated, is violating, 

and is about to violate 18 U.S.C. § 1341 by engaging in and facilitating a scheme and artifice to 

defraud and obtain money or property by means of false or fraudulent representations with the 

intent to defraud, and, in so doing, use mail to carry out the scheme.

COUNT TWO

18 U.S.C. § 1345

WIRE FRAUD

47. The United States re-alleges and incorporates each of the preceding paragraphs as 

though fully set forth herein.

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48. By reason of the conduct described herein, Defendant has violated, is violating, 

and is about to violate 18 U.S.C. § 1343 by engaging in and facilitating a scheme and artifice to 

defraud and obtain money or property by means of false or fraudulent representations with the 

intent to defraud, and, in so doing, use interstate or foreign wire communications to carry out the 

scheme.

49. Upon a showing that Defendant is committing or about to commit a violation of 

either 18 U.S.C. § 1341 or 18 U.S.C. § 1343, the United States is entitled, under 18 U.S.C. § 

1345, to seek a temporary restraining order, a preliminary injunction, and a permanent injunction 

restraining all future fraudulent conduct. The Court may also grant such other relief it deems just 

and proper to prevent a continuing and substantial injury to victims of the fraud scheme.

50. As a result of the foregoing, the Court should enjoin Defendant’s conduct under 

18 U.S.C. § 1345.

PRAYER FOR RELIEF

WHEREFORE, the United States requests judgment in its favor and against the 

Defendant, including the following relief:

A. That the Court issue an order, pursuant to 18 U.S.C. § 1345, pending a hearing 

and determination of the United States’ application for a preliminary injunction, that Defendant, 

his agents, officers, and employees, and all other persons or entities in active concert or 

participation with them, are temporarily restrained from committing wire fraud, as defined by 18 

U.S.C. §§ 1341 and 1343, from maintaining and doing business through the use of the domain 

“whiteeaglenativeherbs.net” and from continuing to sell, market or distribute any product 

intended for use in the diagnosis, cure, mitigation, treatment or prevention of disease, including 

COVID-19;

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B. That the Court issue a preliminary injunction, pursuant to 18 U.S.C. § 1345, on 

the same basis and to the same effect;

C. That the Court issue a permanent injunction, pursuant to 18 U.S.C. § 1345, on the 

same basis and to the same effect;

D. All such further relief as may be just and proper.

Dated: May 29, 2020

JOSEPH H. HUNT

Assistant Attorney General

GUSTAV W. EYLER

Director

Consumer Protection Branch

ROSS S. GOLDSTEIN

Senior Litigation Counsel

D.C. Bar No. 480280

U.S. Department of Justice

Consumer Protection Branch

P.O. Box 386

Washington, DC 20044

(202) 353-4218 

ross.goldstein@usdoj.gov

Respectfully submitted,

JOHN F. BASH

United States Attorney

 /s/ Eduardo R. Castillo

EDUARDO R. CASTILLO

Assistant United States Attorney

Texas State Bar No. 03984803

700 E. San Antonio, Ste. 200

El Paso, Texas 79901

Tel: (915) 534-6555 

Fax: (915) 534-3490 

eddie.castillo@usdoj.gov

Counsel for the United States

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