Author: MIL-OSI Publisher

• No. 3:24-02272 (Southern District of California)
• AUSA Emily Allen
• AUSA Evangeline Dech

On September 12, 2025, following a three-day trial, a jury convicted Jorge Acuna of importing regulated refrigerant chemicals in violation of the Clean Air Act (42 U.S.C.§ 7413(c)(1)).

Acuna, who held a Universal Environmental Protection Agency (EPA) certification allowing him to handle refrigerants known as hydrochlorofluorocarbons (HCFCs) attempted to illegally import the HCFC known as R‑22 from Mexico through the vehicle lane at the San Ysidro Port of Entry. Customs and Border Protection officers specially trained to identify these chemicals stopped Acuna as he tried to enter the country.

HCFCs (such as R-22) are ozone depleting substances, meaning that emissions of these chemicals into the atmosphere are harmful to the ozone layer. R-22 may still be lawfully procured in the United States by purchasing recycled or reclaimed gas. But its importation and production are banned due to its harmful effects on the ozone layer, the environment, and human health.

The U.S. EPA Criminal Investigation Division and Homeland Security Investigations conducted the investigation.

Trial exhibit photo of R-22 cannister defendant attempted to smuggle into the United States from Mexico.

• No. 1:25-CR-00085 (District of Hawaii)
• AUSA Craig S. Nolan

On August 28, 2025, prosecutors charged John Floyd and Nelson Wu with conspiring to commit an offense against the United States and causing another person to make a materially false statement in a matter within the jurisdiction of the executive branch (18 U.S.C. §§ 371, 1001).

Floyd and Wu were civilians employed by the U.S Navy. Between May 6, 2021, and October 1, 2021, Floyd worked as the Fuels Department Deputy Director and Wu was a Fuels Department Supervisory Engineer. Both worked at the Navy Supply Systems Command Fleet Logistics Center Pearl Harbor, which included the Red Hill Bulk Fuel Storage Facility (Red Hill). On May 6, 2021, while attempting to transfer jet fuel, two couplings on the pipeline at Red Hill failed. During the transfer, 20,000 gallons of jet fuel from a storage tank flowed into the pipeline and then spilled into a tunnel.

The Hawaii Department of Health issued a request for information to the U. S. Navy regarding the May 6, 2021, spill. In its response, the Navy reported that only 1,618 gallons of jet fuel had been spilled, instead of 20,000 gallons. Floyd and Wu were responsible for providing the erroneous figures.

The U.S. Defense Criminal Investigative Service, the U.S. Naval Criminal Investigative Service, the U.S. Environmental Protection Agency Criminal Investigation Division and its Office of Inspector General conducted the investigation.

• No. 3:25-CR-00196 (Middle District of Tennessee)
• ECS Senior Trial Attorney Matthew Morris
• AUSA Ahmed A. Safeeullah
• ECS Paralegal Chloe Harris

On September 12, 2025, a court unsealed an indictment charging two individuals with conspiracy and Clean Water Act violations (18 U.S.C. § 371; 33 U.S.C. §§ 1319(c)(2)(A), (c)(4)).

The indictment states that David Ray Stark and Caleb Warren Randall conspired to defraud the Environmental Protection Agency (EPA), bypassed treatment processes, and tampered with a monitoring device at a Nashville waste treatment facility.

Stark was the Facility Operations Manager and Randall was the Plant Supervisor at the facility operated by Allwaste Onsite, doing business as Onsite Environmental (Onsite). As part of the conspiracy, Stark and Randall directed Onsite employees to discharge untreated and partially treated wastewater into the Nashville sewer system in December 2022 and January 2023. Stark and Randall also tampered with and caused Onsite employees to tamper with a sampling device that the Metropolitan Government of Nashville and Davidson County had installed to monitor Onsite’s compliance with its pretreatment permit.

Onsite pleaded guilty in August 2025 for its involvement in the illegal discharges and is scheduled for sentencing on December 15, 2025.

The U.S. EPA Criminal Investigation Division and its Office of Inspector General conducted the investigation.

• No. 25-CR-2786 (Southern District of California)
• AUSA Evangeline Dech

On August 27, 2025, Juandaniel Medina pleaded guilty to violating the Lacey Act for importing endangered exotic birds (16 U.S.C. §§ 3372(a)(2)(A), 3373(d)(1)(A)). Sentencing is scheduled for December 1, 2025.

On May 26, 2025, authorities detained Medina at the San Ysidro Port of Entry after discovering seven live Amazon parrots in a cardboard box on the passenger floorboard. Medina was the driver and registered owner of the vehicle. He admitted paying $700 cash for the parrots with the intention of breeding and/or reselling them in the United States. All Amazon parrot species are listed under the Convention on International Trade in Endangered Species.

Smuggled birds that are not subject to quarantine may carry and spread Avian influenza (bird flu) and other diseases. Bird flu is highly contagious and can cause flu-like symptoms, respiratory illness, pneumonia, and death in humans and other birds, including those housed on poultry farms.

The U.S. Fish and Wildlife Service Office of Law Enforcement and Homeland Security Investigations conducted the investigation.

Amazon lored parrots defendant attempted to smuggle into the United States.

• No. 3:25-CR-01846 (Southern District of California)
• AUSA Emily Allen
• AUSA Elizabet Brown

On September 2, 2025, Naim Lajud Libien pleaded guilty to smuggling 12 protected orange-fronted parakeets into the United States from Mexico (18 U.S.C. § 545.) Sentencing is scheduled for November 10, 2025.

On April 29, 2025, Lajud Libien, a citizen of Mexico, attempted to cross the border in his vehicle after presenting a Border Crossing Card at the Otay Mesa Port of Entry. He was diverted to secondary inspection. Once he stepped outside of his Jeep Grand Cherokee, the Customs and Border Protection (CBP) officer noticed bulges around his ankles. The officer conducted a pat down and discovered birds wrapped in nylon stockings concealed inside the driver’s boots.

A CBP Agricultural Specialist responded and removed six birds wrapped in pantyhose from the defendant’s boots. A U.S. Fish and Wildlife Service (FWS) inspector identified the birds as orange-fronted parakeets and placed them in a cage with food and water until they could be cared for by Veterinary Services. Some of the birds appeared to have injuries on their feet where they had been tied.

The following day, CBP personnel heard birds calling from the defendant’s impounded vehicle. Officials dismantled the car, ultimately locating six more parakeets inside the seat cushion of the vehicle’s passenger seat. The birds were bound in pantyhose, and two had died.

Orange-fronted parakeets are native to Western Mexico and Costa Rica and are listed on Appendix II of the Convention on International Trade in Endangered Species.

The U.S. Fish and Wildlife Service Office of Law Enforcement and Homeland Security Investigations conducted the investigation.

Photo from complaint showing deceased parakeets that defendant had stuffed into a seat cushion in his vehicle.

• No. 24-CR-00445 (Northern District of California)
• AUSA David Ward

On September 12, 2025, Futseng “Dale” Chen pleaded guilty to charges of smuggling and Lacey Act false labeling (18 U.S.C. § 554(a); 16 U.S.C. §§ 3372(d)(2), 3373(d)(3)(A)). Chen, through his company Sealogic International, knowingly filed false and fraudulent export records and documents and intentionally failed to file required export documents for shipments of live tropical fish being sent from the United States to buyers in Asia. Sentencing is scheduled for December 19, 2025.

Between January 2018 and December 2024, Chen smuggled at least 199 shipments and falsely labeled an additional 79 shipments of live tropical fish he exported to customers in Asia. In so doing, Chen avoided paying the required export fees and filing the proper export declarations. The combined value of the smuggled and falsely labeled wildlife was $1,415,373.

Nonetheless, between August 2024 and December 2024, Chen conspired with another individual to use her license to continue illegally importing and exporting wildlife. He paid $500 and $1,200 per shipment to fraudulently use her license.

During this period, Chen made 10 illegal shipments and falsely declared a shipment value below the true value of the export to continue to avoid paying export fees. In addition, he falsely and fraudulently imported 52 shipments of live tropical fish for his domestic and international tropical fish business using his co-conspirator’s license. 

The U.S. FWS Office of Law Enforcement, Homeland Security Investigations, and the U.S. Department of Commerce, Bureau of Industry and Security, Office of Export Enforcement conducted the investigation, with the assistance of U.S. Customs and Border Protection.

• No. 2:25-CR-20223 (Western District of Tennessee)
• AUSA Carroll L. Andre, III

On September 15, 2025, PT Services, Inc., a company specializing in diesel engine repair, pleaded guilty to violating the Clean Air Act by tampering with a monitoring device (42 U.S.C. § 7413(c)(2)(C)).

P.T. Services modified and deleted emissions control monitoring devices from diesel engines.  Between June 2023 and August 2024, PT Services modified the onboard diagnostic systems for six diesel trucks.

The terms of the defendant’s plea agreement require the company to implement an environmental compliance plan as a term of probation and pay a fine of $150,000.

The U.S. Environmental Protection Agency Criminal Investigation Division and the Federal Bureau of Investigation conducted the investigation.

• No.1:25-CR-00113 (District of New Mexico)
• AUSA Matthew McGinley
• AUSA Eva Fontanez
• AUSA Michael Pahl

On September 23, Dineh Benally pleaded guilty to operating a vast illegal marijuana cultivation and distribution ring spanning several years that exploited workers and polluted the San Juan River on tribal lands. Benally pleaded guilty to several charges, including two charges of violating the Clean Water Act (CWA) for illegally discharging pollutants into the San Juan River (33 U.S.C. § 1319(c)(2)(A)) and smuggling undeclared pesticides into the United States (18 U.S.C. § 545).Dineh Benally is scheduled for sentencing on December 22, 2025. Co-defendants Donald Benally and Irving Lin are scheduled for trial on March 9, 2026.

Between January 2018 to November 2020, Benally and his co-conspirators established more than 30 marijuana farms, covering 400 acres, on land obtained from Navajo Nation members. To fund this illegal enterprise, Benally and a co-conspirator traveled to California and created front companies to solicit Chinese investors. These investors were charged cash fees ranging from $20,000 to $50,000 for counterfeit cannabis cultivation licenses. They were also deceived into believing they were growing legal hemp, not marijuana, and were required to pay the co-conspirators a percentage of the profit made from the harvest.

The operation involved the construction of more than 1,100 greenhouses. The defendants employed both local Navajo workers and Chinese foreign laborers, some of whom were undocumented immigrants, to grow, cultivate, and transport marijuana out of New Mexico.

Dineh Benally was also responsible for constructing an illegal sandbag dam on the San Juan River. Workers dumped sand, rocks, and agricultural waste into the river to divert water to use for irrigation. This unpermitted discharge of pollutants into a federally protected waterway is a violation of the CWA.

Law enforcement shut down the operation in November 2020, after confiscating approximately 260,000 marijuana plants and 60,000 pounds of processed marijuana.

Dineh Benally went back into business starting in January 2022, initiating a new illegal marijuana grow operation near Estancia, New Mexico. Benally initially received a state license to grow marijuana. However, state inspectors identified uncontrolled pest infestations, a lack of quality controls, and other violations that led authorities to revoke his license in December 2023 and impose a $1 million fine. Benally continued the operation in defiance of the cease-and-desist order, going so far as to tamper with a utility meter to steal electricity.

On January 23, 2025, a joint federal and state law enforcement operation raided two additional marijuana farms linked to Dineh Benally near Estancia. The raid, which also involved a search of his residence, uncovered approximately 8,500 pounds of marijuana, $35,000 in cash, illegal pesticides, methamphetamine, and firearms.

The Federal Bureau of Investigation and the U.S. Environmental Protection Agency Criminal Investigation Division conducted the investigation, with assistance from the following agencies: the Bureau of Indian Affairs, the U.S. Drug Enforcement Administration, Internal Revenue Service, and the Navajo Nation Police Department, the Torrance County Sheriff’s Office, the San Juan County Sheriff’s Office, the Valencia County Sheriff’s Office, the U.S. Border Patrol, Homeland Security Investigations, and the New Mexico State Police.

River illegally dammed for marijuana irrigation.

• No. 1:25-CR-00131 (Western District of Michigan)
• ECS Trial Attorney Lauren Steele
• AUSA Jonathan Roth

On September 25, 2025, Scott Hitchcock pleaded guilty to violating the Lacey Act for trafficking in snakes protected under the Endangered Species Act (16 U.S.C. §§ 3372(a)(1), 3373(d)(2)).

Hitchcock purchased two Louisiana pine snakes and one black pine snake for a total of $1,000 from undercover officers and transported them from Indiana to Michigan.

The U.S. Fish and Wildlife Office of Law Enforcement conducted the investigation.

• No. 2:25-CR-00128 (District of Maine)
• ECS Senior Trial Attorney Ryan Connors
• AUSA Nicholas Scott

On September 30, 2025, Sergey Bachkovsky pleaded guilty to a felony Lacey Act trafficking violation. Bachkovsky illegally imported and resold whale parts and bird mounts contrary to the Marine Mammal Protection Act and the Migratory Bird Treaty Act (16 U.S.C. §§ 1372(a)(4)(B), 703(a), 3372(a)(1), 3373(d)(1)(B)).

Between June 2023 and March 2024, Bachkovsky sold sperm whale teeth, blue and Antarctic minke whale ear bones, bear paws, and a broad-winged hawk carcass on eBay. He agreed to forfeit whale teeth and bones; bear teeth; walrus or hippopotamus tusks; and eagle, hawk, owl, vulture, and crow wings, tails, and feathers.

The U.S. Fish and Wildlife Service conducted the investigation as part of Operation Raw Deal.

• No. 1:25-CR-00305 (Southern District of Texas)
• AUSA William Hagen

On September 3, 2025, a court sentenced Miguel Angel Ramirez-Vidal to eight months’ incarceration and Jose Daniel Santiago-Mendoza to time served. They are the final two defendants to be sentenced for unlawfully harvesting red snapper from the Gulf of America. Jesus David Luna-Marquez and Jesus Roberto Morales-Amador were sentenced to time served in August 2025. All pleaded guilty to violating the Lacey Act (16 U.S.C. § 3372(a)(1)).

On April 17, 2025, the defendants attempted to transport and export roughly 315 kilograms of red snapper illegally taken from U.S. waters to sell in Mexico. Authorities observed the crew’s panga-style fishing vessel in the Gulf, seven miles north of the U.S.-Mexico maritime boundary line and 20 miles east of South Padre Island. The defendants’ fishing vessel was unmarked and unregistered. It was operating without running lights and not flying the flag of any nation. The defendants were using more than four thousand yards of heavy nylon fishing line and 1,200 fishing hooks. None of the crew members possessed a permit to fish in U.S. waters nor did any hold a quota for red snapper.

Homeland Security Investigations, the U.S. Coast Guard, Customs and Border Protection Air and Marine Operations, National Oceanic and Atmospheric Administration, Texas Parks and Wildlife, and the South Padre Island Police Department conducted the investigation.

• No. 3:22-CR-01754 (Western District of Texas)
• ECS Senior Litigation Counsel Todd Gleason
• ECS Senior Trial Attorney Gary Donner
• ECS Paralegal Chloe Harris

On September 4, 2025, a court sentenced Jason Lee Wagner to pay a $15,000 fine and complete a three-year term of probation, including six months’ home detention. In February 2025, a jury convicted Wagner of conspiracy and 12 smuggling violations (18 U.S.C. §§ 371, 545, 2).

Wagner and other co-conspirator suppliers and middlemen bought and sold endangered reptiles from individuals in Mexico. They used social media to offer reptiles for sale and negotiate their sale and delivery with customers in the United States and Mexico. His co-conspirators also used international money transfers to provide for “crossing fees,” sales and purchases, and other expenses. They then packaged and re-packaged the reptiles for illegal crossings using the U.S. Postal Service and other courier services to transport them between Mexico and the United States.

The U.S. Fish and Wildlife Service Office of Law Enforcement conducted the investigation.

• Nos. 4:23-CR-03122, 4:24-CR-03082 (District of Nebraska)
• AUSA Tessie Smith

On September 4, 2025, and September 11, 2025, a court sentenced the last two individuals charged in this multi-year investigation into illegal hunting and big game outfitting in Nebraska. Dustin Noble, the owner and operator of a big game guiding and outfitting business, pleaded guilty to conspiring to violate the Lacey Act (18 U.S.C. § 371). He was sentenced to 22 months’ incarceration, followed by three years of supervised release. Noble was ordered to pay $179,680 in restitution to the Nebraska Game and Parks Commission Game Law Investigative Cash Fund. He will forfeit numerous unlawfully taken wildlife taxidermy mounts, two crossbows, and several firearms. The court further ordered that Noble shall not hunt, fish, trap, guide, outfit, or associate with anyone engaged in those activities for 25 years. For the next 10 years, Noble is prohibited from conducting, assisting, or associating with any fish or wildlife taxidermy services or activities.

Hunter Mark Cooper was sentenced after pleading guilty to violating the Lacey Act (16 U.S.C. §§ 3372(a)(2)(A), 3373(d)(2)). Cooper will pay a $5,000 fine to the Lacey Act Reward Account and $15,000 in restitution to the Nebraska Game and Parks Commission Game Law Investigative Cash Fund. He will complete a two-year term of probation, and is banned from hunting, fishing, trapping, guiding, outfitting, or associating with anyone engaged in those activities for a four- year period. Cooper will also abandon a 5 X 5 mule deer taxidermy mount, three additional mule deer taxidermy mounts and antler sets, and several white-tailed deer antlers.

A total of 20 defendants were collectively sentenced to 22 months’ imprisonment, 15 years’ probation, 32 years’ hunt/fish/trap restrictions, and ordered to pay more than $275,000 in fines and restitution for state and federal convictions related to this case. The investigation included the seizure and subsequent forfeiture or abandonment of more than 50 trophy wildlife antlers and taxidermy mounts from 27 Noble Outdoors clients and associates.

Operation No Trace was a joint investigation conducted by the U.S. Fish and Wildlife Service Office of Law Enforcement, and the Nebraska Game and Parks Commission Law Enforcement Division.

Photo of mounts seized during the Operation No Trace investigation. Published by the Nebraska Game and Parks Commission.

• No. 3:25-mj-00011 (Eastern District of Virginia)
• AUSA Carla Jordan-Detamore

On September 5, 2025, a court sentenced Robert C. Schmid to complete a one-year term of probation to include six months’ home confinement. Schmid will also pay $33,262 in restitution divided among seven victim companies. Schmid pleaded guilty to violating the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 U.S.C. §§ 136j(a)(1)(A), 1361(b)(1)(B)).

Schmid owned the Atlantic Manufacturing Group, LLC (AMG), which manufactured and sold cleaning and janitorial products. AMG marketed and sold its products through its website and outside sales representatives. In September 2017, AMG entered into an agreement with an entity referred to as Company 1 to purchase a product called “Maquat 64-PD,” for which Company 1 had obtained a registration from the EPA. AMG entered into this agreement in order to distribute and sell its liquid ProAmenities Lemon Detergent Disinfectant, made with Company 1’s Maquat 64-PD. In October 2017, the EPA approved the label for AMG’s ProAmenities Lemon Detergent Disinfectant. The label clearly stated that the product was hazardous to humans and animals and was not for use on clothing or skin.

Beginning in May 2020, and acting on behalf of AMG, Schmid began manufacturing and selling AMG “Hygienic Facility Wipes” that purportedly protected users from COVID-19. Schmid sold these wipes to janitorial services that supported government entities, gyms and health clubs, universities, and janitorial product retailers. AMG manufactured these wipes by applying the ProAmenities Lemon Detergent Disinfectant to dry wipes and packaging the wipes in plastic buckets or plastic packages. These wipes, however, were not registered with the EPA pursuant to FIFRA and did not have EPA approved labels or safety guidance. Investigators also determined that Schmid, his employees, and outside sales reps made unauthorized claims about the efficacy and safety of the product to potential customers.

After Company 1 issued Schmid a cease-and-desist email in August of 2020 regarding the unauthorized use of its product, Schmid switched to using a liquid manufactured by Company 2,  in its wipes.  Company 2’s product was not registered with the EPA. Schmid, however, continued to claim that his wipes were an EPA-registered product. AMG also generated product labels that claimed the wipes eradicated corona viruses and included a falsified list of ingredients.

Between March and November 2020, AMG sold approximately 5,000 cases of the wipes, taking in close to $415,000 in sales and making approximately $33,000 in gross profit.

The U.S. Environmental Protection Agency Criminal Investigation Division conducted the investigation.

• No. 4:25-CR-00089 (District of Montana)
• AUSA Randy Tanner

On September 9, 2025, a court sentenced Bryant Mikkelson to pay a $10,000 fine for failing to report the taking of a grizzly bear, in violation of the Endangered Species Act (16 U.S.C. §§ 1538(a)(1)(G), 1540(b)(1)). The fine will be paid to the Cooperative Endangered Species Conservation Fund.

On June 2, 2025, a Montana Fish, Wildlife, and Parks Game Warden informed a U.S. Fish and Wildlife Service (FWS) agent  that Mikkelson had killed a grizzly bear in the Highwood Mountains in Choteau County, Montana, on May 27, 2025. Mikkelson worked as an outfitter for bear hunts and other big game hunts on private-land leases in the Highwood and Little Belt Mountains. The warden learned of the killing from a person who worked as a guide for Mikkelson.

Mikkelson texted the guide and others messages about the killing, as well as pictures of himself with the grizzly bear and the gun he used to shoot it. Mikkelson then told everyone he had texted to delete the texts and pictures he had sent. Other acquaintances and guides who worked for Mikkelson confirmed this story and provided the FWS agent additional text messages with photographs from Mikkelson.

Two weeks after shooting the bear, Mikkelson called the FWS agent to report that he had shot the bear and gave the agent the location.

On June 11, 2025, authorities located the kill site and found where Mikkelson took pictures of the dead grizzly bear. They also located a blood pool and internal organs, but not the bear carcass.

The U.S. FWS Office of Law Enforcement and Montana Fish, Wildlife, and Parks conducted the investigation.

• No. 3:24-CR-00076 (Northern District of Indiana)
• AUSA Lydia Lucius

On September 11, 2025, a court sentenced Dylan Nissley to complete a two-year term of probation and to perform 144 hours of community service. Nissley is banned from any hunting, fishing, or trapping activities while under supervision. Nissley paid $10,000 into the Lacey Act Reward Fund and forfeited a rifle, crossbow, and wildlife he illegally acquired. Nissley pleaded guilty to three misdemeanor violations of the Lacey Act (16 U.S.C. §§ 3372(a)(2)(A), 3373(d)(1)(B)).

During the spring of 2023, Nissley offered unlawful guided fishing trips in Lake Erie, Ohio. At the time of the trips, Nissley did not possess a valid U. S. Coast Guard Captain License or a valid fishing guide license. He also allowed individuals to “double bag” and catch and keep several more walleye than allowed by the legal bag limit. In November 2023, during the archery-only portion of the Missouri hunting season, Nissley killed a buck with a firearm, failed to report all the deer he harvested, and took more than two antlered deer during the season.

The U.S. Fish and Wildlife Service Office of Law Enforcement conducted the investigation, with assistance from the Indiana Department of Natural Resources, Ohio Department of Natural Resources, United States Coast Guard Investigative Service, and Missouri Department of Conservation. 

• No. 9:25-CR-00164 (District of South Carolina)
• ECS Senior Trial Attorney Ryan Connors
• AUSA Winston Holliday
• AUSA Elle Klein

On September 15, 2025, a court sentenced Lauren DeLoach to pay a $15,000 fine, and complete a two-year term of probation to include 30 days of home confinement. DeLoach pleaded guilty to violating the Marine Mammal Protection Act and the Lacey Act for illegally importing and selling sperm whale teeth and bones (16 U.S.C. §§ 1372(a)(4)(B), 3372(a)(1), 3373(b)(1)(B)).

DeLoach illegally imported sperm whale parts into South Carolina, with at least 30 shipments coming from Australia, Latvia, Norway, and Ukraine. DeLoach instructed suppliers to label the items as “plastic” or “resin” so they would not be seized by U.S. Customs authorities. Items sold on eBay were worth at least $15,000. Laboratory analysis confirmed the teeth and bones belonged to sperm whales, which are a protected species.

The U.S. Fish and Wildlife Service Office of Law Enforcement and the National Oceanic and Atmospheric Administration conducted the investigation.

• No. 1:24-CR-00066 (Southern District of Ohio)
• ECS Senior Trial Attorney Adam Cullman
• AUSA Tim Oakley
• ECS Paralegal Chloe Harris

On September 30, 2025, a court sentenced Giancarlo Morelli to 48 months’ incarceration, followed by 36 months’ supervised release. Morelli will also pay a $25,000 fine. He pleaded guilty to conspiracy and to creating and distributing videos depicting the torture of monkeys (known as animal “crush” videos) (18 U.S.C. §§ 371, 48(a)(3)).

Morelli paid another individual 19 times for videos depicting the torture and abuse of monkeys. Morelli also corresponded extensively with the individual supplying him with the videos, providing feedback on the content of the videos, and offering suggestions for future videos.

The U.S. Fish and Wildlife Service Office of Law Enforcement and the Federal Bureau of Investigation conducted the investigation.