UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

PECOS DIVISION

UNITED STATES OF AMERICA § 

Plaintiff, § 

§ 

v. § EP: 20-CV-00046-DC

§ 

MICHAEL MARC TRAVALINO § 

aka MARC WHITE EAGLE § 

Defendant. § 

[PROPOSED] PERMANENT INJUNCTION

This matter comes before the Court following a hearing on the United States’ application 

for a Permanent Injunction. Upon consideration of the application pursuant to 18 U.S.C. § 1345 

and the entire record in this case, the Court finds that:

1. This Court has jurisdiction over the subject matter of this case and all the parties 

hereto, and venue in this district is proper. 

2. There is probable cause to believe that Defendant has violated and, unless enjoined, 

will continue to violate 18 U.S.C. §§ 1341 and 1343. 

3. This Court previously entered a Preliminary Injunction, enjoining Defendant from 

the conduct alleged in the United States’ application for injunctive relief. The Preliminary 

Injunction was agreed to by the Defendant. ECF No. 16.

4. The domain name “whiteeaglenativeherbs.net” is registered to Michael Travalino. 

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

Hayden Rd, Ste. 219, Scottsdale, AZ 85260. This domain is being used as an instrumentality of 

Defendant’s crimes. 

5. Injunctive relief to protect the public interest is expressly authorized by 18 U.S.C. 

§ 1345. As such, neither a specific finding of irreparable harm, a showing of the inadequacy of 

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other remedies at law, nor a balancing of the parties’ interests is necessary prior to the issuance of

a permanent injunction. 

6. Even though a showing of irreparable harm is not necessary under Section 1345 in 

order to obtain injunctive relief, the Court has found that permitting Defendant to continue to 

perpetrate the alleged mail and wire fraud would constitute irreparable harm and that the balance 

of the equities and the public interest weigh in favor of injunctive relief. 

7. The statutory conditions for granting a permanent injunction under 18 U.S.C. § 

1345 are therefore met. 

8. Defendant’s violations of 18 U.S.C. §§ 1341 and 1343 will continue unless a 

permanent injunction is issued. 

THEREFORE, IT IS HEREBY ORDERED that, pursuant to 18 U.S.C. § 1345 and Rule 

65 of the Federal Rules of Civil Procedure, the United States’ application for a permanent

injunction is GRANTED.

IT IS FURTHER ORDERED that Defendant, his agents, officers, and employees, and all 

other persons and entities in active concert or participation with him, are enjoined from:

(A) committing mail fraud, as defined by 18 U.S.C. § 1341;

(B) committing wire fraud, as defined by 18 U.S.C. § 1343; 

(C) maintaining and doing business through the use of the domain 

“whiteeaglenativeherbs.net,” or any other website that promotes the sale of 

products claiming to cure COVID-19 or other diseases; 

(D) doing any business involved in the selling, marketing or distributing any product 

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

disease, including COVID-19;

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(E) destroying business records related to Defendant’s business, financial, or 

accounting operations; 

(F) taking any actions designed to interfere with any additional Court orders regarding 

Defendant’s operation of any business involved in the selling, marketing or 

distributing any product intended for use in the diagnosis, cure, mitigation, 

treatment or prevention of disease, including COVID-19; and 

(G) taking actions designed to interfere with any additional Court orders regarding the 

domain “whiteeaglenativeherbs.net.”

IT IS FURTHER ORDERED that this permanent injunction is effective as of the date on 

the signature below. 

IT IS FURTHER ORDERED that the United States shall serve a copy of this Permanent 

Injunction on Defendant by personally serving Defendant at his last known residential address, 

last known place of business or where he may be physically encountered.

IT IS FURTHER ORDERED, that for every day that Defendant is in violation of this 

Permanent Injunction, he may be fined up to $1000 per day and face possible incarceration of up 

to 30 days for each violation. 

Pursuant to 18 U.S.C. § 1345(a)(3) and Rule 65(c) of the Federal Rules of Civil Procedure, 

the United States shall not be required to post security for this action.

SO ORDERED, this the _____ day of _______________, 2022.

___________________________________

DAVID COUNTS

UNITED STATES DISTRICT JUDGE

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