At Long Last, We Know (Kind Of) What Was In Those Products Sold By The Indicted Pharmacist

For years, testing experts and regulators had looked at websites like RacehorseMeds and HorsePreRace and wondered about some of their most dramatically named products. Blood Building Explosion; White Lightning; Ice Explosion; Purple Pain – items with marketing as bright and attention-catching as the vibrant colors of the liquid inside the bottles had been a source of fascination for some time. Products that promised to “light one up” and that they “will not test” had no ingredients list, let alone a breakdown showing strengths of their active ingredients.

In her time at the Racing Medication and Testing Consortium, Dr. Mary Scollay said she had acquired bottles of these and other products from the two sites that later became part of the focus of FBI investigators. Rigorous testing had yielded mostly inactive ingredients, sugars, or harmless amino acids. Still, she had always wondered whether the makers of the substances were including some new, sinister form of performance enhancer that simply evaded even top-shelf testing.

Now, we know more about the instructions given to staff mixing up products at the direction of former pharmacist Scott Mangini, who had business involvement with both websites at various times. (Mangini was one of more than two dozen people indicted in March 2020 on drug adulteration and misbranding charges stemming from an alleged series of illegal doping rings in Thoroughbred and Standardbred racing.)

One of the final items filed by prosecutors just before Mangini's sentencing on Sept. 10 included a cache of documents seized in FBI searches related to the investigation of RacehorseMeds and HorsePreRace. Included in the public filing was a series of formulas for some of the products sold by RacehorseMeds, as well as a series of invoices for orders of product ingredients sent from a supplier based in Wuhan, China. (There was also a set of billing records for RacehorseMeds, but that was filed under seal so is inaccessible to media or the public.)

We asked Scollay and former HFL Sport Science laboratory director Dr. Rick Sams to take a look at those records and help us understand what they mean about the products sold on these sites.

Harmless, or not?

Many of the substances listed on these (and other, similar websites) were clearly intended to appear as cheaper, knock-off versions of prescription drugs already in FDA-approved mass manufacture. Usually, those shared the same names as the prescription products (clenbuterol, omeprazole, flunixin, etc.) but were offered to lay people with no requirement they be licensed veterinarians. Those substances had their own problems, but it was at least clear what was supposed to be in them.

The mysterious substances with proprietary names had been more intriguing for regulators. Formulas revealed that many of them contained nothing different from more innocuously-named oral supplements – vitamins like pyridoxine (B6) and thiamine (B1), minerals like iron and copper salts, and amino acids like L-tryptophan. Many of these things can be found naturally in feed or hay, and Scollay says there's no evidence that feeding extra of many of those ingredients produces any appreciable effect in a horse's health, let alone performance. A product named  Horse Power turns out to contain ATP, vitamins, amino acids, and di-isopropylamine dihydrochloride. It's true that they would not test, but it wouldn't be because they were magically hidden by masking agents; rather, they aren't usually tested for post-race because those substances are probably present in most horses being fed balanced diets.

Under the cloak of “proprietary formulas,” the websites managed to charge much more for those pedestrian ingredients than what they would have cost horsemen who knew what they were buying. Red Explosion Blood Builder, for example, is still listed for sale online for $35 for a 10-milliliter bottle, but according to its formulation it only contained .002 grams of B12, water, and a couple of stabilizers. The B12, according to shipping records, was purchased for $8 per gram. A mark-up is just good business of course, but injectable B12 is available from legitimate, FDA-approved mass manufacturers for less than $6 for a 100-milliliter bottle.

Besides being expensive, some of the products may not have actually been capable of being absorbed by horses' bodies, according to the formulas in the court filing. A product called TQ Explosion contained calcium levulinate, thiamine, tryptophan, and GABA.

“Calcium levulinate is a source of calcium,” said Sams. “Thiamine is a vitamin. Tryptophan is an essential amino acid. GABA is gamma aminobutyric acid and is prohibited. This product is made up in sterile water for injection instead of 0.9% sodium chloride so it may not be isotonic.”

The inclusion of salts is usually made in injectable formulas to ensure the solution is appropriately passed through the bloodstream. Blood cells are isotonic, meaning they naturally contain some salts. Pure water is naturally drawn in by salty solution, so exposure to pure water could make red blood cells swell and burst – that's why most IVs are run with saline and not sterile water. Leaving out any kind of salt probably didn't make the product risky to the horse, according to Sams, but it does mean it probably didn't get delivered throughout the body in any sort of useful way.

Sometimes, the proprietary formulas left our expert sources scratching their heads as to what the makers thought they were accomplishing. The frighteningly-named Allergy Explosion turns out to contain only formic acid.

“Formic acid is the substance that causes the stinging sensation in ant bites,” said Sams. “I don't think that injecting it in a horse is inhumane, but may lead the trainer to believe that it is doing something to excite the horse.”

Another product called Ozone contained nothing but food grade hydrogen peroxide in water. The “food grade” designation is unsettling to laboratory experts because it means the ingredient has not been created with sufficient purity to be safe for use in medication, let alone an injectable formula.

“Although hydrogen peroxide injections of people have been reported, it is not an approved therapy,” said Sams. “I wondered about the source of the hydrogen peroxide and its strength and purity as well as its stability in the injection vial and whether the peroxide interacted with the vial septum. All of these need to be addressed and answered before the product can be assumed to be safe for administration to horses. Mangini's company did not report conducting any of these studies.”

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A few of the proprietary products may have kicked up a few interesting results on Google had their ingredient lists been made available at the time of purchase, but were probably still bunk.

“As I recall, the Purple Pain was to be administered intravenously, so while there is evidence that ammonium sulfate will interrupt nerve conduction—when injected adjacent to a nerve—there's nothing to suggest that systemic administration would have any effect on pain,” said Scollay. “There is some speculative stuff about L-isoleucine and d-phenylalanine [both found in a formula called Adrenal Cortex] exerting analgesic effects, most of the credible sites said there was no legitimate evidence for that claim.”

Just because it seems like a lot of this stuff didn't work didn't mean it was a harmless waste of money for the trainers who may have been buying it. While it's not uncommon for legitimate pharmacies and pharmaceutical companies to import ingredients from China and elsewhere, there are varying standards to which those products can be held. Shipping receipts seized from Mangini showed that many of the ingredients he purchased were lacking a USP designation after their names. USP stands for United States Pharmacopeia, which is an organization that sets quality, purity, strength, and identity standards for raw ingredients. Imported ingredients with this designation have been verified to meet USP standards.

Several products were listed on shipping receipts as being less than 100% in purity – a no-no for reputable compounders to put in injectable products.

“The 98% pure claims make my skin crawl.  That other 2% can be a killer—literally,” said Scollay.

Not only were many ingredients lacking this seal of approval, Scollay and Sams point out there were a few which contained dyes or colorings to make them appear an appealing color that would match the marketing name given to them. Blast Off Yellow contained yellow food coloring which, of course, isn't intended to be injected into the veins of an animal. It remains unknown what, if any, side effects this could have.

There also isn't a lot of detail provided in the instruction sheets on filtration, which would be a key step in making an injectable formula, though it's possible there were additional instructions on filtration provided in documentation not attached to prosecutors' exhibits. We do know that sanitary conditions in Mangini's facility were lacking – state health inspectors discovered his pharmacy had no working sink for people to wash their hands before compounding drugs and the areas where drugs were made were filthy. They also found that there were no quality assurance tests taking place to check for sterility or endotoxin contamination of products like this one.

Read more about Mangini's pharmacy in this 2016 report.

Then there were the instructions to make ITTP, which is supposed to be expensive to produce, even for much more technically advanced laboratories than Scott Mangini's. Scollay couldn't decide whether the instructions for making that product were more “hilarious or horrifying.”

“Take a bottle of water under the hood, open it,” read the single page of instructions. “Pour 100 ml into one beaker, 100 ml into another. Put 10 g of calcium ball things in one beaker, put 37.5 ittp in the other. Ph the ittp to 7.5. Pour them back into the bottle that has remained under the hood. Shake, it's great. No filter. Yay we are done.”

“I'll say 'c'—all of the above,” said Scollay when considering how she viewed those instructions. “In case there would be any question about the credibility of the laboratory, or how seriously it undertook its tasks—this certainly doesn't read like the business model of a good guy just trying to make good medicine more affordable.  Unless the good guys were the writers at the National Lampoon.”

The heavy hitters

There were substances in the shipping receipts that gave Sams pause. There were some that were intended to be knockoffs of legitimate drugs, and others that were more sinister.

“The products containing dexamethasone, omeprazole, clenbuterol, flunixin, phenylbutazone, and toltrazuril are all generic knockoffs of prescription products,” Sams said. “The FDA requires generic products to be manufactured in FDA-approved facilities according to Good Manufacturing Practices standards. Mangini's operation could not have met these standards. Furthermore, the preparation of knockoff products in bulk as he was doing does not meet the definition of “compounding”.

“The remaining products contain clearly prohibited and performance-enhancing substances such as selective androgen receptor modulating drugs (SARMs) and others. I include injectable clenbuterol in this group because it is not an approved drug in the U.S. Although all of these substances are prohibited in horse racing, they are not DEA controlled substances so no DEA violations occurred.”

Given the manufacturing conditions in Mangini's lab, Sams said veterinarians and trainers could not have relied on the labeled concentrations to be accurate enough to comply with testing thresholds established by state commissions – because those thresholds were created based on the FDA approved versions of the drugs.

The SARMs that attracted the most attention from prosecutors went into a product called Ostarine MK-2866 Oral Solution. Its label promised “Ostarine MK-2866 is in the class of Selective Androgen Receptor Modulators or SARMs. SARMs offer the benefits of traditional anabolic adrogenic steroids such as testosterone, including increased muscle mass, fat loss, and bone density.”

The label also indicated the drug had a 24-hour half life, which would give a user information about how to evade testing.
“Ostarine is extensively metabolized so administration studies had to be performed in order to identify metabolites to facilitate its detection in blood and urine because orally administered ostarine is subject to substantial first-pass effects,” said Sams. “This is a drug of ongoing concern in racing and, in my opinion, is one of the more egregious violations in the Mangini document.”

Other invoices include “Cardanine,” which appears to be a misspelled version of cardarine and Antibolicum LGD4033, which is also a type of SARMs drug. They also reveal the shipment of ITPP, a prohibited substance believed to increase the oxygen-carrying ability of red blood cells. Di-isopropyl diacetate, or pangamic acid, is also among the orders and is also a prohibited substance.

Scollay thought it notable that several products – both knockoffs and proprietary formulas seemed to be reliant on the inclusion of a common thyroid drug.

“Interesting that the Light Explosion and Green Speed contain levothyroxine as their primary ingredient—just in case anyone didn't think it was being used to impact performance,” she said.

L-thyroxine is sold under various trade names, including Thyro-L and Levo-Powder, and was the subject of much concern several years ago, when California regulators discovered that trainer Bob Baffert was giving the substance to all his horses as a feed additive, whether or not they'd been diagnosed with thyroid problems. It remained a topic of concern due to its association with cobalt administration.

Read previous reporting about l-thyroxine here.

Mangini's response

To the extent Mangini responded to some of these issues in court, he maintained that the majority of his sales came from knockoffs of existing drugs like omeprazole (which he was warned by the FDA to stop mass manufacturing). Ostarine, he said, accounted for .5% of his overall sales. Blood Building Explosion, which contained cobalt, was .4% of sales, while Horse Power was .65% of sales.

At sentencing, prosecutors pointed out that the only reference they have to verify Mangini's account of his sales are the records he kept.

“This is not a company that has produced anything remotely like a wholesome breakdown of its finances,” remarked U.S. Attorney Andrew Adams.

Regardless of Mangini's assertion that he didn't actually sell many of the problematic products on offer, Adams pointed out that each bottle of Blood Building Explosion contained many doses, so even the sale of dozens of bottles really resulted in hundreds of doses going into horses pre-race.

For his part, Mangini and his attorney said the former pharmacist was mostly “hurt” by the suggestion that his products were intended to corrupt the industry he loved so much.

“It was wrong to have this internet site and run the pharmacy the way he ran it,” said Mangini's attorney, William Harrington. “He's pled guilty to that. But to suggest that what he's really been doing was to create dozens of products to abuse animals, I just don't support that.”

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New Indictment, Court Documents Reveal More About Drug Makers In Federal Case

Two more people have been indicted as part of an ongoing federal case focusing on adulterated and misbranded performance-enhancing drugs in horse racing. On March 11, a new superseding indictment was filed in the United States District Court for the Southern District of New York in the case of former pharmacist Scott Mangini, who has since entered a guilty plea to a charge of conspiring to unlawfully distribute adulterated and misbranded drugs with the intent to defraud and mislead. The new indictment also names Carl Garofalo Sr. and veterinarian Dr. Michael Posner.

This is the third version of an indictment for Mangini, who was originally indicted alongside associate Scott Robinson in March 2020 and then was named in a superseding indictment that dropped Robinson. Robinson pleaded guilty to one count of drug adulteration and misbranding conspiracy in September 2020 and was sentenced in March 2021 to 18 months in prison.

According to the indictment, Mangini collaborated with others, including Robinson and Garofalo, to operate a series of online marketplaces which advertised substances designed to enhance performance or serve as copies of prescription drugs. Court documents filed in Mangini's case before his guilty plea detail the tangle of businesses Mangini and his associates created in an attempt to make it harder for consumers and regulators to work out who was behind their various storefronts.

Mangini apparently kept busy with multiple businesses operating on overlapping timeframes. As reported by the Paulick Report in 2016, Mangini was the pharmacist at Ergogenic Labs in Wellington, Fla., before the facility closed following a particularly negative inspection by state health department regulators. Mangini surrendered his license after that state inspection, which highlighted unsanitary facilities and mislabeled product ingredients. According to prosecutors, some of the products Mangini made at Ergogenic were sold to Robinson, who distributed them to the public via HorsePreRace.

During the same time he was working at Erogenic, Mangini, Robinson, and others were also making illegally-compounded ulcer medication under the banner of Horse Gold. Mangini, HorseGold, and HorsePreRace were all recipients of FDA warning letters in 2014 regarding ulcer products called GastroMax3 and Gastrotec which the agency said were illegally compounded. A series of knock-off omeprazole products on the market at the time had remarkably similar logos of a running horse outline with a starburst behind or near the horse.

One document from prosecutors acknowledged the same group was behind various iterations of the ulcer medication and were trying to walk a line between maintaining branding and escaping the notice of state authorities.

In November 2015, Robinson allegedly wrote to someone: “Don't use that artwork for gastromax 3 that my guy sent u – u get us all ****ed – too close-why wouldn't u use original artwork I'm serious-I don't need board of pharmacy seeing that and linking to me.”

According to a press release from Horse Gold in 2011, its ulcer products were carried in racing tack shops around the country and were also donated to aftercare charities.

After Ergogenic shuttered in 2016, prosecutors say Mangini and Robinson stopped working together and Mangini and Garofalo incorporated Pegasis Investment Group, which served as a shell for RacehorseMeds. Garofalo is accused of helping to manufacture and ship “identical drugs to those Mangini had produced while operating Ergogenic” and of enlisting family members to do the same. Documents reveal that one of the people on the government's witness list helped Mangini and Garofalo create a shell company called Diamond Enterprise Group to obscure the identity of the “true manufacturer and shipper of the drugs sold to consumers.” The person identified only as “Witness-1” was paid $1,000 a month and opened bank accounts and multiple mailboxes outside the state of Florida in the company's name to make it appear as though Diamond Enterprise was based elsewhere.

Indeed, it would seem as though the scheme was successful at making it difficult for consumers to figure out how to report a problem with products purchased from one of the companies. A government motion told the story of an unidentified owner whose trainer advised her horse needed ulcer medication and directed the owner to RaceHorseMeds. The owner purchased omeprazole paste from the website without being prompted for a prescription and began giving the paste to her horse. Eight days later, she “observed a serious deterioration in her horse's health, resulting in the horse's hospitalization at an animal hospital.

“Witness-3 attempted to contact the company operating the Racehorsemeds website to find out what was in the product she ordered, but the only person Witness-3 could link to Racehorsemeds was Witness-1.”

Federal regulations require, among other elements of labeling, that the manufacturer of a drug be clearly identified on the label so consumers can report adverse drug reactions if needed.

Prior to entering his guilty plea, Mangini's attorneys had been trading motions with prosecutors about which pieces of evidence would be admissible at his trial. One point of contention was that Mangini was apparently on the radar for U.S. Customs and Border Patrol. The agency seized two packages that were addressed to people other than Mangini – one in 2020 from Wuhan, China, was bound for “Frank Stef” and one in 2018 from Jalisco, Mexico, was addressed to “Michael O'Donnell.” A defense motion sought to have this evidence excluded, pointing out that Mangini was not the addressee on either package but did not explain exactly how he related to either package. The motion did point out that the accusations against Mangini related to his sale of products in the United States, not to his receipt of drugs from foreign countries.

Garofalo, Mangini and Robinson were all longtime owners on the Standardbred racing scene, but Mangini and Garofalo did make a foray into the Thoroughbred world. In late 2015, trainer Maria Borell claimed two horses for their Pegasis Investment Group. One was claimed away and the other was later transferred to trainer Sal Santoro after Borell left Florida. A third Thoroughbred racing for Pegasis Investment Group the following year was trained by Barry Kirkham.

The indictment accuses Posner of allowing Mangini to use his name and veterinary licensing credentials to create prescriptions for horses which neither Posner nor Mangini (who is not a veterinarian) had examined. The March 2021 indictment points to a check to Posner issued by Ergogenic Labs for $243.50, with “March 2016 commissions” written in the memo line.

Mangini and Posner were charged with one count of drug adulteration and misbranding conspiracy, while Mangini and Garofalo were charged in a separate count of drug adulteration and misbranding conspiracy. Garofalo and Posner have entered not guilty pleas.

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Robinson, Defendant In Federal Doping Indictment, Sentenced To 18 Months In Prison

Scott Robinson, one of the defendants in the federal case that rocked horse racing in March 2020, has been sentenced to 18 months in prison. The Thoroughbred Daily News reported that U.S. District Judge J. Paul Oetken handed down the sentence on Tuesday after Robinson pleaded guilty to one count of drug adulteration and misbranding conspiracy in September 2020.

Robinson, together with pharmacist Scott Mangini, was accused of operating consumer-facing websites such as HorsePreRace, peddling products which purported to be blood builders and pain blockers which were allegedly untestable, as well as discounted versions of prescription drugs despite not being an FDA-approved manufacturer. Robinson is neither a veterinarian nor a pharmacist.

Click here to read the Paulick Report's investigation of HorsePreRace from 2016.

A pre-sentencing report filed by federal prosecutors ahead of Oetken's ruling revealed even more disturbing details about the conditions in which those products were made. A state pharmacy board inspection report dated February 2016 which was published by the Paulick Report had picked up on unsanitary conditions at co-conspirator Scott Mangini's facility in Florida: the Florida Department of Health Records noted that there was no working sink in the pharmacy for hand washing, and employees were instead using a ten-gallon bucket. The department noted so much dust on the counters where prescriptions were made that an investigator was able to trace letters in the dirt with an alcohol swab — a particular problem since some products were injectables. Ingredients were mislabeled.

Click here to read more about Mangini's facility from this 2016 investigative feature by the Paulick Report.

Even before that inspection however, the report cited communications from Robinson to Mangini indicating he knew something could be wrong with the products he was selling. In spring 2015, Robinson began asking Mangini whether there had been changes to manufacturing processes.

“R u making stuff different? I have a lot of stuff that doesn't look same and has stuff floating in it. Blood building peptide has black particles,” one message to Mangini read.

“[Employee] has been complaining of bugs coming out of boxes u send. I told him he was crazy until I found one floating in bottle today when labeling,” read another, also to Mangini.

The Board of Pharmacy conducted its inspection in December 2015, but Robinson was dismissive of any danger resulting from the inspection, writing to Mangini, “And board of pharmacy worries about u? They got bigger problems! Lol.”

(Mangini, who has been charged with two counts of drug adulteration and misbranding, has entered a not guilty plea and his case is ongoing.)

Between December 2015 and January 2016, Robinson fielded complaints from trainers who had injected Pentosan into their horses, only to see the horses become severely depressed and unable to move. The horses' veterinarian attributed the reactions to a bad batch. The pre-sentencing report indicated Robinson “was dismissive of these complaints.”

When federal agents executed search warrants on premises used by Robinson in September 2019, prosecutors say he became incensed and “attempted to extort the federal agents involved in the seizure by threatening to release a letter to certain members of the racehorse industry informing them of of the existence and scope of the FBI's investigation if the FBI did not immediately return his electronic devices the same day they were seized. After being informed his threat was itself a crime, Robinson retracted his threat hours later.”

After he became aware the FBI was investigating him, prosecutors say Robinson continued distributing adulterated and misbranded drugs, generating “millions of dollars in revenue.”

Prosecutors had requested the maximum available sentence of five years in prison, while Robinson's defense team, pointing out his lack of prior criminal convictions, suggested he serve no time. Defense attorneys painted a picture of a man who had risen to business success from near-homelessness and who battled depression and chronic traumatic encephalopathy (CTE) due to injuries sustained in the United States Navy. Letters from friends and family framed Robinson as a caring person who gave liberally to charity and financially supported family members.

Although Robinson had no criminal history, prosecutors did note that he was court martialed in 1998 and dishonorably discharged from the Navy after he admitted to reselling anabolic steroids to other enlisted members of the Navy.

One character reference letter in support of Robinson's defense came from New Vocations Racehorse Adoption Program, where executive director Dot Morgan wrote that Robinson “donated a massive amount of his compounded omeprazole ulcer treatment” to the program in 2010 and 2011. In 2014, HorsePreRace and HorseGold (of which Robinson was president) were the recipients of warning letters from the Food and Drug Administration warning them to stop marketing omeprazole and other products designed to act as prescription drugs because they were not approved as mass manufacturers of drugs.

Another letter, from Robinson's psychiatrist, highlighted the defendant's feelings for horses.

“From my three years of work with Mr. Robinson, I have become aware of his great knowledge of and love for racehorses,” wrote Dr. Ronald E. DeMao. “Horses and horse racing have literally “been his life.” It is inconceivable to me that he would ever do anything to intentionally harm a horse. In fact, he has developed products to aid in the physical health and rehabilitation of horses. I have heard him speak in very pejorative terms about others who 'dope' or harshly train racehorses.”

Robinson is required to surrender himself on Sept. 7, 2021 to begin his sentence. He will have another three years of supervised release after serving his time.

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Kentucky Pharmacy, Owner Plead Guilty In Federal Charges Over Illegal Drug Distribution

Tailor Made Compounding, LLC and its founder, Jeremy Delk, pleaded guilty this week to federal charges of unlawful drug distribution, according to a press release from the U.S. Attorney's Office for the Eastern District of Kentucky. Tailor Made entered a guilty plea to one count of distributing unapproved new drugs in the United States between October 2018 and April 2020. Those drugs were selective androgen receptor modulators, more commonly known as SARMs, which are designed to mimic the effects of anabolic steroids. Tailor Made admitted to distributing a series of substances, including BPC 157, Cerebrolysin, CJC 1295, DSIP, Epitalon, GW 501516, Ipamorelin, LGD-4033, LL-37, Melanotan II, MK 677, PEG-MGF, Selank, and Semax. The pharmacy will forfeit the value of its 2019 sales of those products, which totals $1,788,906.82.

SARMs are best known as performance-enhancing drugs in human sport, but have also made their way into the horse racing world, as evidenced by a case from Quarter Horse racing earlier this year.

Delk, 40, entered a guilty plea for unlawfully distributing prescription drugs as a wholesaler despite Tailor Made not being licensed to operate as a wholesaler. According to federal prosecutors, he oversaw Tailor Made's distribution of methylcobalimin, or B-12, to physicians in California and Maryland. Prosecutors also say he tried to hide records of those and other sales when Tailor Made was visited by federal and state pharmacy inspectors in 2018.

Sentencing in the case will take place Feb. 24, 2021. Delk could face up to 10 years in prison and a fine of up to $250,000.

Tailor Made Compounding is not affiliated in any way with Taylor Made Farm or Taylor Made Sales Agency, also located in Nicholasville, Ky.

In March of this year, the FBI confirmed judicially-authorized activity at 200 Moore Drive in Nicholasville, the address of Tailor Made Compounding. That activity took place on the same day as the arrests of several trainers, veterinarians, and others on charges of drug adulteration and misbranding. In a statement provided to the Paulick Report later that week, a representative of Tailor Made stated federal authorities questioned Tailor Made employees in connection with “a highly publicized equine investigation in New York involving MediVet Equine.”

MediVet was the producer of SGF-1000, one of the substances referenced by indicted trainer Jason Servis in telephone conversations recorded by the FBI.

Read more about the marketing of SGF-1000 in this report from March 2020.

Tailor Made maintained that it “has no business affiliation whatsoever with MediVet Equine” and “is a separate business altogether which does not compound veterinary medication.”

Until the week of the arrests, MediVet Equine's website said it was located at 200 Moore Drive, and that it was “continuing research and development in partnership with Tailor Made Compounding.”

According to the Kentucky Secretary of State, MediVet Equine Associates LLC (one of several entities using the MediVet name in Kentucky) was then registered to a Michael Kegley, with Kristian S. Rhein as a member. Michael Kegley Jr. and Rhein were among the 27 indicted by the U.S. Attorney for the Southern District of New York in connection with a doping ring.

Besides their address, MediVet and Tailor Made did share something else — an important associate in Jeremy Delk. On his LinkedIn page, Delk lists himself as CEO of Tailor Made Compounding from December 2014 to the present and founder of MediVet Biologics from January 2008 to present. The registered agent for MediVet Biologics changed from Delk to Thomas Masterson in May 2019, according to a filing with the Kentucky Secretary of State.

Delk appeared on MediVet Equine's archived website as co-founder of the company alongside Michael Kegley Sr. Michael Kegley Jr. was listed as director of sales for MediVet Equine. That page vanished during the week of the arrests in connection with the Navarro/Servis indictments (which included Kegley Jr.) and the FBI's appearance at Tailor Made. As of this week, MediVet Biologics is listed under the heading “investments and portfolio companies” on the Delk Enterprises website.

Delk's biography on his LinkedIn page reads in part: “In addition to his businesses, Mr. Delk's other passion is horses and animals. Mr. Delk's family has owned race horses for more than four decades. In 1978 his grandfather's horse, Special Honor, competed in the Kentucky Derby against Affirmed and Alydar. Mr. Delk learned of MediVet Pty in 2008 when a trainer had remarkable success using some of the companies product ranges on one of Mr. Delk's racehorses. So impressed with the product and after further research formed a partnership with the principles of MediVet Pty, Ltd. to offer the company's leading edge all natural therapeutic products in North America.

Today, Delk Enterprises has crossed over into a more focused approach in human health care including OTC consumer products, small molecule drug development, peptides, and orthobiologics.”

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