United States of America’s Notice Regarding Expert Testimony — United States v. Grenon (Dkt. 166, S.D. Fla.)

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The United States of America's Notice Regarding Expert Testimony in United States of America v. Mark Scott Grenon, Jonathan David Grenon, Jordan Paul Grenon, and Joseph Timothy Grenon, Case No. 21-20242-CR-ALTONAGA/TORRES, in the U.S. District Court for the Southern District of Florida, served June 23, 2023. The government explains that expert discovery under Federal Rule of Criminal Procedure 16(a)(1)(G) is triggered by a defense request, and states that the defendants have made no such demand and have disclosed no expert witnesses of their own. It notes that information about its likely expert witness, Dr. Arthur Simone, has nonetheless been available to the defendants. The notice was mailed to the four pro se defendants.

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Case 1:21-cr-20242-CMA Document 166 Entered on FLSD Docket 06/23/2023 Page 1 of 3




                             UNITED STATES DISTRICT COURT
                             SOUTHERN DISTRICT OF FLORIDA

                         CASE NO. 21-20242-CR-ALTONAGA/TORRES


  UNITED STATES OF AMERICA

  v.

  MARK SCOTT GRENON,
  JONATHAN DAVID GRENON,
  JORDAN PAUL GRENON, and
  JOSEPH TIMOTHY GRENON,

              Defendants.
  __________________________________/

       UNITED STATES OF AMERICA’S NOTICE REGARDING EXPERT TESTIMONY

          The United States of America hereby respectfully submits the following statement

  regarding discovery relating to expert testimony for the upcoming trial of this matter. Under

  Federal Rule of Criminal Procedure 16, expert discovery is governed by subsection 16(a)(1)(G),

  which provides that, “at the defendant’s request, the government must disclose to the defendant”

  information required by the Rule regarding any anticipated expert witness. Once the government

  complies with the demand, the defense must provide reciprocal discovery of any expert testimony

  intended to be used by the Defendant. See Fed. R. Crim. P. 16(b)(1)(C).

          The Defendants have not demanded expert discovery under Rule16(a)(1)(G), nor has the

  defense provided any discovery relating to any proposed expert witnesses that the Defendants may

  seek to call. We note nonetheless that information regarding the Government’s likely expert

  witness, Dr. Arthur Simone, was and is available to the Defendants in the civil action against them,

  United States v. Genesis II Church, et al., 20-21601-Civ-Williams (SDFL). To the extent any

Case 1:21-cr-20242-CMA Document 166 Entered on FLSD Docket 06/23/2023 Page 2 of 3




  Defendant does request Rule 16 expert discovery from the Government, the Government in turn

  requests reciprocal discovery from the defense.

                                              Respectfully submitted,

                                              MARKENZY LAPOINTE
                                              UNITED STATES ATTORNEY

                                       BY:    /s/ Michael B. Homer
                                              MICHAEL B. HOMER
                                              Assistant United States Attorney
                                              Court ID No. A5502497
                                              99 Northeast 4th Street
                                              Miami, Florida 33132-2111
                                              Telephone: 305-961-9289
                                              Michael.Homer@usdoj.gov

                                              JOHN C. SHIPLEY
                                              Assistant United States Attorney
                                              Senior Counsel to the Criminal Division
                                              FL Bar No. 0069670
                                              99 Northeast 4th Street
                                              Miami, Florida 33132-2111
                                              Telephone: 305-961-9111
                                              John.Shipley@usdoj.gov




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Case 1:21-cr-20242-CMA Document 166 Entered on FLSD Docket 06/23/2023 Page 3 of 3




                                 CERTIFICATE OF SERVICE

         I HEREBY CERTIFY that on June 23, 2023, I caused a true and correct copy of the

  foregoing to be delivered via Certified Mail to pro se Defendants Mark Grenon, Jonathan David

  Grenon, Jordan Paul Grenon, and Joseph Timothy Grenon at the Miami Federal Detention Center,

  Inmate Mail/Parcels, Post Office Box 019120, Miami, Florida 33101.


                                                    /s/ Michael B. Homer
                                                    MICHAEL B. HOMER
                                                    Assistant United States Attorney




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