Chapter[ IX. The Threat Posed By Internet Sales of Steroids and Human Growth
Hormone ]
Section[ A. 2. Internet Trafficking in Performance Enhancing Substances by Rejuvenation Centers and Compounding Pharmacies ]
2. Internet Trafficking in Performance Enhancing Substances by Rejuvenation Centers and Compounding Pharmacies
In February 2007, a government raid on Signature Compounding Pharmacy in
Orlando, Florida shed light on another, more complex method of selling performance enhancing
substances illegally over the internet. It involves so-called “rejuvenation centers,” which market
steroids or human growth hormone – or, in some instances, merely a healthier lifestyle – over the
internet. When approached by a customer, the rejuvenation centers arrange for a corrupt
physician to issue a prescription for the substance the customer wants to purchase, often without
ever seeing their new “patient” and without administering any medical tests. The bad faith
prescriptions are then filled by a compounding pharmacy (which sometimes manufactures the
steroids or human growth hormone in its own laboratory) and sent to the user by mail.444
The raid on Signature Pharmacy was conducted by a task force of federal and
state agencies. It grew out of a 2004 investigation by the New York Bureau of Narcotic
Enforcement of a physician in upstate New York who had been illegally prescribing and selling
drugs, including steroids, over the internet. That initial investigation led state and federal
Sept. 28, 2007, at C1. An article that appeared after the Operation Raw Deal announcement
reported that GeneScience claimed to be China’s most profitable pharmaceutical company and to
control nearly 70% of China’s market for human growth hormone. See id.
444 The Federal Food, Drug and Cosmetics Act prohibits knowingly distributing or
possessing with intent to distribute human growth hormone for any use in humans other than the
treatment of disease or another recognized medical condition that has been recognized by the
Secretary of Health and Human Services. 21 U.S.C. § 333(e) (2006). The FDA has only
approved human growth hormone for limited uses, and it has not been approved for use for any
anti-aging, cosmetic, or athletic performance purpose. See Food and Drug Administration,
Import Alert No. 66-71, Detention Without Physical Examination of Human Growth Hormone,
also known as Somatropin (Jan. 23, 2007).
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investigators to a compounding pharmacy in Mobile, Alabama called Applied Pharmacy
Services that had been the New York physician’s source for some of his illegal products.
A December 2006 raid on Applied led, in turn, to Signature Pharmacy.445 In addition to
Signature Pharmacy, the multi-agency task force executed search warrants on several other
pharmacies, anti-aging clinics, and businesses in Florida and in Alabama, New York, and Texas.
According to investigators, Signature Pharmacy sold more than $40 million of
drugs over the internet in 2006.446 Mark Haskins, the lead investigator for the New York Bureau
of Narcotic Enforcement, described to Sports Illustrated how these operations work:
Basically you have an antiaging clinic with an Internet presence.
[Clinic operators] put the product on the Internet. The customer
finds them online, fills out a brief questionnaire and requests
steroids, hormone therapy, whatever. Someone from the clinic
contacts the customer and then develops a prescription for the
steroid treatment or hormone treatment. Then [the clinic] sends or
e-mails the prescription to a doctor, who is often not even in the
same state. He’ll sign it [because] he’s being paid by the clinic,
usually $20 to $50 for every signature. The signed prescriptions
get faxed to the compounding pharmacies, which know from the
very beginning that there is no doctor-patient relationship. The
pharmacy then sends the product to the customer.447
Other compounding pharmacies also have been raided by the task force. In
separate raids of Lowen’s Pharmacy in Brooklyn, New York that occurred in May and October
445 See Luis Fernando Llosa and L. Jon Wertheim, Rx for Trouble: Inside the Steroid
Sting, Sports Illustrated, Mar. 12, 2007, at 62.
446 See Brendan J. Lyons, A Web of Easy Steroids; Florida Raid Highlights a Lucrative
Business, Albany Times Union, Feb. 28, 2007, at A1.
447 Luis Fernando Llosa and L. Jon Wertheim, Rx for Trouble: Inside the Steroid Sting,
Sports Illustrated, Mar. 12, 2007, at 62.
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2007, authorities seized over 90 grams of raw human growth hormone, worth over $7.2 million,
as well as significant quantities of raw steroid powder that had been imported from China.448
The seizure of large amounts of raw steroids and human growth hormone from
these compounding pharmacies suggests that the pharmacies themselves formulated a significant
portion of the performance enhancing substances they sold (as opposed to reselling FDA-
approved substances purchased from mainstream pharmaceutical companies). Both Lowen’s
and Signature owned lypholyzers, vacuum freeze dryers that permit a single gram of raw human
growth hormone to be converted into thousands of doses of human growth hormone for resale to
449
consumers.
A number of physicians have been indicted as a result of the investigation. Ana
Maria Santi may be the most egregious example of the abuses uncovered by the investigation.
Santi is a former physician whose license was suspended by New York State in 1999. The
suspension did not stop her from writing prescriptions for pay; she merely did so by forging the
signature and using the DEA registration number of another physician, Dr. Abdul Almarashi,
who was retired and living in a nursing home in California at the time.450 Between January 2005
and September 2006, Santi issued prescriptions using Dr. Almarashi’s name for more than
448 See Shawn Assael, Raid in Brooklyn Nets More Than $7 Million in Human Growth
Hormone, espn.com, Oct. 16, 2007; Steroids Are Seized in Brooklyn, nytimes.com, Oct. 17,
2007; Jennifer 8. Lee, Illegal Steroids Seized, N.Y. Times, May 10, 2007, at B6.
449 News reports suggest that baseball players and other professional athletes typically
purchase generally more expensive brand-name human growth hormone that is produced and
packaged by mainstream pharmaceutical companies. Some brands are sold in pre-loaded, single
use syringes instead of as lypholized powder that must be mixed with sterile water by the user.
450 Indictment, United States v. McGlone and Santi, No. 07 CR 022 (D.R.I.); Indictment
of Anna Marie Santi, Albany County Court, New York, File No. 0616252, Jan. 25, 2007; see
also Brendan J. Lyons, Guilty Plea In Steroids Case, Albany Times Union, Mar. 21, 2007, at A1.
240
$150,000 in substances sold by Oasis Longevity and Rejuvenation Institute alone.451 According
to media reports, prescriptions in Dr. Almarashi’s name were issued to current major league
players Jay Gibbons and Jerry Hairston, Jr., among many other clients.452
In a prosecution by the Albany County District Attorney, Santi pleaded guilty to
criminal diversion of prescription medications and prescriptions.453 Thereafter, Santi pleaded
guilty to numerous federal counts relating to her illegal distribution of steroids and human
growth hormone.454
Other physicians engaged in similar practices. Dr. Victor Mariani, a former
medical school classmate of Santi, also wrote prescriptions for anabolic steroids and human
growth hormone for patients he had never seen in exchange for $25 per prescription.455
Dr. Robert Carlson, a 50-year old physician from Sarasota, Florida who is the brother-in-law of
one of the owners of the Palm Beach Rejuvenation Center, allegedly signed 3,100 prescriptions
451 Dan Goodin, Guilty Plea in Alleged Internet Steroid Ring, The Register, Mar. 21,
2007; Brendan J. Lyons, Guilty Plea in Steroids Case; Ex-Physician Admits Writing Fraudulent
Prescriptions for Internet Wellness Center, Albany Times Union, Mar. 21, 2007, at A1.
452 Luis Fernando Llosa and L. Jon Wertheim, Rx for Trouble: Inside the Steroid Sting,
Sports Illustrated, Mar. 12, 2007, at 62; Documents: Hairston received HGH; Bogus
prescriptions at heart of probe; player ‘baffled,’ SI.com, Mar. 2, 2007; Luis Fernando Llosa and
L. Jon Wertheim, Gibbons received banned drugs; O’s outfielder latest athlete tied to pipeline
pharmacy, SI.com, Sept. 9, 2007.
453 Brendan Lyons, Guilty Plea in Steroids Case, Albany Times Union, Mar. 21, 2007,
at A1.
454 See Plea Agreement, United States v. Santi, No. 07 CR 0225 (D.R.I. Apr. 27, 2007).
In November 2007, Santi was sentenced to two years in prison, a subsequent year of home
confinement and two years of supervised probation, in addition to monetary penalties. Dan
Connolly, Shamed Doctor Gets Two Years in Steroid Case; ‘Grandmotherly’ Santi Wrote
Thousands of Prescriptions, Balt. Sun, Nov. 3, 2007, at C1.
455 Indictment, United States v. Daniel McGlone and Ana Maria Santi, No. 07 CR 022
(D.R.I.), at 5-7; Plea Agreement, United States v. Mariani, No. 07 CR 0215 (D.R.I.).
241
within a 60-day period; he pleaded guilty in Albany County to fourth-degree insurance fraud.456
Dr. Claire Godfrey, an Orlando obstetrician, also pleaded guilty; she said that she was directed
by Signature Pharmacy executives to several Florida rejuvenation clinics that faxed prescriptions
for her signature knowing that she would never examine the customers.457 Within a six-month
time period, she wrote approximately $1.3 million worth of prescriptions and earned
$200,000.458
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