Indictment — No. 1:21-cr-20242 (Dkt. 185, S.D. Fla.)

Summary

An indictment, Document 185, entered July 20, 2023 on the Southern District of Florida docket in United States v. Mark Scott Grenon, Jonathan David Grenon, Jordan Paul Grenon and Joseph Timothy Grenon, Case No. 21-20242-CR-ALTONAGA (1:21-cr-20242-CMA). The 14-page indictment lists 18 U.S.C. § 371, 21 U.S.C. § 331(a), 21 U.S.C. § 331(d), 21 U.S.C. § 333(a)(2) and 18 U.S.C. § 401(3), and its general allegations set out the Federal Food, Drug and Cosmetic Act framework and describe Miracle Mineral Solution (MMS). Count 1 is captioned Conspiracy to Defraud and to Commit Offenses Against the United States. Counts 2 and 3 are captioned Criminal Contempt and concern a Temporary Restraining Order issued on or about April 17, 2020 and a Preliminary Injunction issued on or about May 1, 2020.

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Case 1:21-cr-20242-CMA Document 185 Entered on FLSD Docket 07/20/2023 Page 1 of 14

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-20242-CR-ALTONAGA
18 U.S.C. § 371
21 U.S.C. § 331(a)
21 U.S.C. § 331(d)
21 U.S.C. § 333(a)(2)
18 U.S.C. § 401(3)

UNITED STATES OF AMERICA

vs.

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

Defendants.
______________________________/

INDICTMENT

The Grand Jury charges that:

GENERAL ALLEGATIONS

At all times relevant to this Indictment:

Regulatory Framework

1. The United States Food and Drug Administration (“FDA”) was the federal

agency charged with the responsibility of protecting the health and safety of the American

public by assuring, among other things, that drugs marketed and distributed to the American

public were safe and effective. The FDA’s responsibilities included enforcing the Federal

Food, Drug and Cosmetic Act, 21 U.S.C. § 301 et seq. (“FDCA”), and regulating the
Case 1:21-cr-20242-CMA Document 185 Entered on FLSD Docket 07/20/2023 Page 2 of 14

manufacture, labels, labeling, and distribution of all drugs shipped or received in interstate

commerce.

2. Under the FDCA, a “drug” was defined to include, among other things: articles

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

disease in humans, 21 U.S.C. § 321(g)(1)(B); articles (other than food) intended to affect the

structure or any function of the body of humans, 21 U.S.C. § 321(g)(1)(C); or articles intended

for use as components of other drugs, 21 U.S.C. § 321(g)(1)(D).

3. The “intended use” of a drug meant the objective intent of the persons legally

responsible for the labeling of that product. The intent was determined by such persons’

expressions, the circumstances surrounding the distribution of the article, labeling claims,

advertising matter, or oral or written statements by such persons or their representatives. 21

C.F.R. § 201.128.

4. Under the FDCA, “labeling” was defined as “all labels and other written,

printed, or graphic matter (1) upon any article or any of its containers or wrappers, or

(2) accompanying such article,” 21 U.S.C. § 321(m); and “label” was defined as “a display of

written, printed, or graphic matter upon the immediate container of any article,” 21 U.S.C.

§ 321(k).

5. Under the FDCA, a “new drug” was defined as any drug “the composition of

which is such that such drug is not generally recognized, among experts qualified by scientific

training and experience to evaluate the safety and effectiveness of drugs, as safe and effective

for use under the conditions prescribed, recommended, or suggested in the labeling thereof.”

21 U.S.C. § 321(p)(1).

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6. Under the FDCA, a drug that was a “new drug” could not be lawfully

introduced or delivered for introduction into interstate commerce, unless the FDA had

approved a new drug application or an abbreviated new drug application with respect to such

drug, or such drug was exempt from approval pursuant to an effective investigational new

drug application. 21 U.S.C. §§ 331(d) & 355(a), (b), (i), & (j).

7. “Adequate directions for use” meant directions under which a layperson could

use a drug safely for the purposes for which it was intended. 21 C.F.R. § 201.5.

8. Under the FDCA, a “prescription drug” was any drug intended for use in

humans that, because of its toxicity or other potentiality for harmful effect, or the method of

its use, or the collateral measures necessary for its use, was not safe for use except under the

supervision of a practitioner licensed by law to administer such drug, or was limited by an

approved application under section 21 U.S.C. § 355 for use under the professional supervision

of a practitioner licensed by law to administer such drug. 21 U.S.C. § 353(b)(1).

9. Because a prescription drug, by definition, was safe for use only under the

supervision of a licensed practitioner, there were no directions that could enable a layperson

to use a prescription drug safely. Therefore, adequate directions for use could not be written

for a prescription drug.

10. Under the FDCA, upon first engaging in the manufacture, preparation,

propagation, compounding, or processing of a drug, every person was required to immediately

or operated by such person, the unique facility identifier of each such establishment, and a

point of contact email address. 21 U.S.C. §§ 360(b)(1) & (c).

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11. Under the FDCA, the terms “manufacture, preparation, propagation,

compounding, or processing” included repackaging or otherwise changing the container,

wrapper, or labeling of any drug package in furtherance of the distribution of the drug from

the original place of manufacture to the person who makes final delivery or sale to the ultimate

consumer. 21 U.S.C. § 360(a)(1).

12. The FDCA prohibited the introduction or delivery for introduction into

interstate commerce, or the causing thereof, of any “new drug” that was neither approved by

the FDA nor exempt from approval. 21 U.S.C. §§ 331(d) & 355(a).

13. The FDCA also prohibited the introduction or delivery for introduction into

interstate commerce, or the causing thereof, of any drug that was misbranded. 21 U.S.C.

§ 331(a).

14. A drug was misbranded if, among other things:

a. its labeling failed to bear “adequate directions for use,” 21 U.S.C.

§ 352(f)(1); or

b. it was manufactured, prepared, propagated, compounded, or processed in

an establishment in any State not duly registered with the FDA, 21 U.S.C.

§ 352(o).

The Drug

15. Miracle Mineral Solution (“MMS”) was a liquid solution containing sodium

chlorite and water.

16. When MMS was mixed with an acidic activator, as directed by the defendants,

the resulting chemical reaction produced chlorine dioxide.

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17. Chlorine dioxide was a powerful bleaching agent typically used for bleaching

and stripping textiles, pulp, and paper. Chlorine dioxide was also used in industrial water

treatment, because it was a disinfectant, capable of killing pathogenic microorganisms such

as fungi, bacteria, and viruses.

18. MMS was a “drug” within the meaning of 21 U.S.C. § 321(g)(1).

19. MMS was a “new drug” within the meaning of 21 U.S.C. § 321(p)(1).

20. MMS was a “prescription drug” within the meaning of 21 U.S.C. § 353(b)(1).

21. MMS was not approved by the FDA for any use, nor was it exempt from FDA

approval.

The Defendants and Co-Conspirator 1

22. MARK SCOTT GRENON manufactured, promoted, sold, and distributed

MMS to the American public. GRENON was also the leader of Genesis II Church of Health

and Healing (“Genesis”), an explicitly non-religious entity that GRENON co-founded in or

around April 2010.

23. JONATHAN DAVID GRENON was a member of Genesis, and he assisted

MARK SCOTT GRENON, who was his father, in the manufacture, promotion, sale, and

distribution of MMS.

24. JORDAN PAUL GRENON was a member of Genesis, and he assisted

MARK SCOTT GRENON, who was his father, in the manufacture, promotion, sale, and

distribution of MMS.

25. JOSEPH TIMOTHY GRENON was a member of Genesis, and he assisted

MARK SCOTT GRENON, who was his father, in the manufacture, promotion, sale, and

distribution of MMS.

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26. Co-Conspirator 1 co-founded Genesis with MARK SCOTT GRENON and

promoted MMS to the American public for the cure, mitigation, treatment, and prevention of

a variety of diseases.

Prior Civil Enforcement Action

27. On or about April 16, 2020, the United States filed a civil complaint in the

United States District Court for the Southern District of Florida, against MARK SCOTT

GRENON, JONATHAN DAVID GRENON, JORDAN PAUL GRENON, JOSEPH

TIMOTHY GRENON, and Genesis, seeking a preliminary injunction and a permanent

injunction to enjoin the defendants from violating the FDCA. See United States v. Genesis II

Church of Health and Healing, et al., Case No. 20-21601-CV-WILLIAMS, ECF Nos. 1, 3.

28. On or about April 17, 2020, United States District Judge Kathleen M. Williams

issued a Temporary Restraining Order against MARK SCOTT GRENON, JONATHAN

DAVID GRENON, JORDAN PAUL GRENON, JOSEPH TIMOTHY GRENON, and

Genesis. That Temporary Restraining Order, inter alia, prohibited the defendants from

“directly or indirectly, label[ing], hold[ing], and/or distribut[ing] any [unapproved or

misbranded] drug, including but not limited to MMS . . . .” See United States v. Genesis II

Church of Health and Healing, et al., Case No. 20-21601-CV-WILLIAMS, ECF No. 4 at 3.

29. On or about May 1, 2020, United States District Judge Kathleen M. Williams

issued an Order of Preliminary Injunction against MARK SCOTT GRENON, JONATHAN

DAVID GRENON, JORDAN PAUL GRENON, JOSEPH TIMOTHY GRENON, and

Genesis. As with the Temporary Restraining Order that preceded it, that Order of Preliminary

Injunction, inter alia, prohibited the defendants from “directly or indirectly, label[ing],

hold[ing], and/or distribut[ing] any [unapproved or misbranded] drug, including but not

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limited to MMS . . . .” See United States v. Genesis II Church of Health and Healing, et al.,

Case No. 20-21601-CV-WILLIAMS, ECF No. 26 at 8.

COUNT 1
Conspiracy to Defraud and to Commit Offenses Against the United States
(18 U.S.C. § 371)

1. Paragraphs 1 through 29 of the General Allegations section of this Indictment

are re-alleged and fully incorporated herein by reference.

2. From in or around April 2010, and continuing through on or about July 20,

2020, in Miami-Dade and Broward Counties, in the Southern District of Florida, and

elsewhere, the defendants,

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

did knowingly and willfully combine, conspire, confederate, and agree with each other and

with others known and unknown to the Grand Jury, to:

(a) defraud the United States and its agencies by impeding, impairing, obstructing,

and defeating the lawful governmental functions of the FDA to protect the health and safety

of the American public by ensuring that drugs marketed and distributed to the American public

were safe and effective for their intended uses;

(b) commit an offense against the United States, that is, with the intent to defraud

and mislead, introducing and delivering for introduction into interstate commerce, and causing

to be introduced and delivered for introduction into interstate commerce, a new drug, to wit,

MMS, that did not have in effect an approval of an application filed pursuant to Title 21,

United States Code, Sections 355(b) and (j), and was not exempted from such approval

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pursuant to Title 21, United States Code, Section 355(i), in violation of Title 21, United States

Code, Sections 331(d), 355(a), and 333(a)(2); and

and mislead, introducing and delivering for introduction into interstate commerce, and causing

to be introduced and delivered for introduction into interstate commerce, a drug, to wit, MMS,

that was misbranded as defined by Title 21, United States Code, Sections 352(f)(1) and (o),

in violation of Title 21, United States Code, Sections 331(a) and 333(a)(2).

PURPOSE OF THE CONSPIRACY

3. It was the purpose of the conspiracy for the defendants and their co-

conspirators to evade government regulation of MMS, and to unlawfully manufacture,

promote, sell, and distribute MMS to consumers.

MANNER AND MEANS OF THE CONSPIRACY

The manner and means by which the defendants and their co-conspirators sought to

accomplish the objects and purpose of the conspiracy included, among others, the following:

4. MARK SCOTT GRENON and his sons, JONATHAN DAVID GRENON,

JORDAN PAUL GRENON, and JOSEPH TIMOTHY GRENON, manufactured,

promoted, sold, and distributed MMS.

5. MARK SCOTT GRENON, JONATHAN DAVID GRENON, JORDAN

PAUL GRENON, and JOSEPH TIMOTHY GRENON claimed that MMS could be used

to treat, prevent, and cure a variety of serious diseases and disorders, including cancer,

Alzheimer’s, diabetes, autism, malaria, hepatitis, Parkinson’s, herpes, HIV/AIDS, and, more

recently, novel coronavirus disease 2019, also known as COVID-19 (hereinafter,

“Coronavirus”).

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6. MARK SCOTT GRENON, JONATHAN DAVID GRENON, JORDAN

PAUL GRENON, and JOSEPH TIMOTHY GRENON knew that MMS had not been

approved by the FDA for any use, and that their actions in manufacturing, promoting, selling,

and distributing MMS to consumers as a miracle cure-all were unlawful.

7. MARK SCOTT GRENON, JONATHAN DAVID GRENON, JORDAN

PAUL GRENON, and JOSEPH TIMOTHY GRENON manufactured, promoted, sold, and

distributed MMS under the guise of Genesis II Church of Health and Healing, an explicitly

non-religious entity that MARK SCOTT GRENON and Co-Conspirator 1 founded in an

attempt to evade government regulation of MMS and shield themselves from prosecution.

8. MARK SCOTT GRENON, JONATHAN DAVID GRENON, JORDAN

PAUL GRENON, and JOSEPH TIMOTHY GRENON rejected the authority of the

government to regulate MMS, defying government regulations and threatening individuals

enforcing those regulations.

9. MARK SCOTT GRENON, JONATHAN DAVID GRENON, JORDAN

PAUL GRENON, JOSEPH TIMOTHY GRENON, and Co-Conspirator 1 created and

maintained various Genesis-affiliated websites to promote and distribute MMS. These

websites included www.genesis2church.ch, www.genesis2church.is, www.g2voice.is,

www.g2sacraments.org, www.newg2sacraments.org, www.mmswiki.is, www.jimhumble.co,

and mmstestimonials.co, among others.

10. At www.g2sacraments.org and www.newg2sacraments.org, websites which

were created and maintained by MARK SCOTT GRENON, JONATHAN DAVID

GRENON, JORDAN PAUL GRENON, and JOSEPH TIMOTHY GRENON, consumers

could place online orders for MMS. Although these websites stated that MMS could be

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acquired only through a “donation” to Genesis, the donation amounts for orders of MMS were

set at specific dollar amounts, and were mandatory, such that the “donation” amounts were

effectively just sales prices.

11. MARK SCOTT GRENON, JONATHAN DAVID GRENON, JORDAN

PAUL GRENON, and JOSEPH TIMOTHY GRENON manufactured MMS in the

backyard of JONATHAN DAVID GRENON’s home in Bradenton, Florida, an

establishment that had not been duly registered with the FDA for the manufacture,

preparation, propagation, compounding, or processing of a drug.

12. MARK SCOTT GRENON, JONATHAN DAVID GRENON, JORDAN

PAUL GRENON, and JOSEPH TIMOTHY GRENON distributed over 28,000 bottles of

MMS to the American public, shipping MMS from Bradenton, Florida, to consumers all

across the country, including consumers in other states and consumers in the Southern District

of Florida.

13. As a result of their sales of MMS, MARK SCOTT GRENON, JONATHAN

DAVID GRENON, JORDAN PAUL GRENON, and JOSEPH TIMOTHY GRENON

received more than one million dollars ($1,000,000).

OVERT ACTS

In furtherance of the conspiracy, and to achieve the purpose and objects thereof, at

least one co-conspirator committed and caused to be committed, in Miami-Dade and Broward

Counties, in the Southern District of Florida, and elsewhere, at least one of the following overt

acts, among others:

1. In or around April 2010, MARK SCOTT GRENON and Co-Conspirator 1

announced that they were forming a non-religious “church,” called Genesis II Church of

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Health and Healing, in order to cloak their unlawful distribution of MMS as protected religious

exercise, and thereby attempt to evade government regulation of MMS and shield themselves

from future prosecution.

2. On or about November 13, 2014, MARK SCOTT GRENON registered the

domain name, www.genesis2church.is.

3. On or about March 23, 2015, JORDAN PAUL GRENON registered the

domain name, www.g2sacraments.org.

4. On or about December 16, 2015, MARK SCOTT GRENON registered the

domain name, www.quantumleap.is.

5. In or around December 2015, MARK SCOTT GRENON disseminated a

documentary titled, “Quantum Leap: The Global Healing Revolution,” in which MARK

SCOTT GRENON claimed that, using MMS, he had healed hundreds of thousands of people

from cancer, HIV/AIDS, malaria, diabetes, Parkinson’s, arthritis, and other serious diseases

and disorders.

6. On or about August 12, 2016, MARK SCOTT GRENON registered the

domain name, www.g2voice.is.

7. On or about July 25, 2017, JORDAN PAUL GRENON and JONATHAN

DAVID GRENON caused one bottle of MMS to be mailed from Bradenton, Florida, to

Davie, Florida.

8. On or about October 3, 2019, JORDAN PAUL GRENON and JONATHAN

DAVID GRENON caused one bottle of MMS to be mailed from Bradenton, Florida, to

Plantation, Florida.

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9. On or about November 20, 2019, JORDAN PAUL GRENON and

JONATHAN DAVID GRENON caused one bottle of MMS to be mailed from Bradenton,

Florida, to Miami, Florida.

10. On or about March 3, 2020, MARK SCOTT GRENON sent an email to the

subscribers of his newsletter in which MARK SCOTT GRENON claimed that MMS could

cure Coronavirus. In this newsletter, MARK SCOTT GRENON provided detailed dosing

instructions for using MMS to treat Coronavirus, with one set of dosing instructions for adults,

and another set of dosing instructions for young children.

11. On or about March 8, 2020, MARK SCOTT GRENON and JOSEPH

TIMOTHY GRENON disseminated a podcast titled, “The Coronavirus is curable! Do you

believe it? You better!,” in which MARK SCOTT GRENON and JOSEPH TIMOTHY

GRENON promoted MMS as a cure for Coronavirus.

12. On or about March 15, 2020, MARK SCOTT GRENON and JOSEPH

TIMOTHY GRENON recorded a podcast titled, “The Controversial Healing Cure,” in which

MARK SCOTT GRENON and JOSEPH TIMOTHY GRENON promoted MMS as a cure

for Coronavirus.

13. On or about March 18, 2020, JORDAN PAUL GRENON and JONATHAN

DAVID GRENON caused one bottle of MMS to be mailed from Bradenton, Florida, to

Atlanta, Georgia.

All in violation of Title 18, United States Code, Section 371.

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COUNT 2
Criminal Contempt – Temporary Restraining Order
(18 U.S.C. § 401(3))

1. Paragraphs 1 through 25 and 27 through 29 of the General Allegations section

of this Indictment are re-alleged and fully incorporated herein by reference.

2. From on or about April 17, 2020, and continuing through on or about May 1,

2020, in Miami-Dade County, in the Southern District of Florida, and elsewhere, the

defendants,

JONATHAN DAVID GRENON and
JORDAN PAUL GRENON,

did knowingly and willfully, and in disobedience and resistance to a lawful order and

command of the United States District Court for the Southern District of Florida, that is, a

Temporary Restraining Order issued in Miami, Florida, on or about April 17, 2020, in the case

of United States v. Genesis II Church of Health and Healing, et al., Case No. 20-21601-CV-

WILLIAMS, violate that Temporary Restraining Order, in that the defendants did directly and

indirectly label, hold, and distribute an unapproved and misbranded drug, namely, MMS.

In violation of Title 18, United States Code, Sections 401(3) and 2.

COUNT 3
Criminal Contempt – Preliminary Injunction
(18 U.S.C. § 401(3))

1. Paragraphs 1 through 25 and 27 through 29 of the General Allegations section

of this Indictment are re-alleged and fully incorporated herein by reference.

2. From on or about May 1, 2020, and continuing through on or about July 20,

2020, in Miami-Dade County, in the Southern District of Florida, and elsewhere, the

defendants,

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JONATHAN DAVID GRENON and
JORDAN PAUL GRENON,

did knowingly and willfully, and in disobedience and resistance to a lawful order and

command of the United States District Court for the Southern District of Florida, that is, a

Preliminary Injunction issued in Miami, Florida, on or about May 1, 2020, in the case of

United States v. Genesis II Church of Health and Healing, et al., Case No. 20-21601-CV-

WILLIAMS, violate that Preliminary Injunction, in that the defendants did directly and

indirectly label, hold, and distribute an unapproved and misbranded drug, namely, MMS.

In violation of Title 18, United States Code, Sections 401(3) and 2.

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