UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

 

No. 20-3050-MJ-OTAZO-REYES

UNITED STATES OF AMERICA

v.

MARK SCOTT GRENON,

JONATHAN DAVID GRENON,

JORDAN PAUL GRENON, and

JOSEPH TIMOTHY GRENON,

 Defendants.

__________________________________/

GOVERNMENT’S MEMORANDUM IN SUPPORT OF DETENTION

The United States of America respectfully submits that Defendant Mark Scott Grenon and 

his sons, Defendants Jonathan, Jordan, and Joseph Grenon (collectively, the “Defendants”), should 

be detained pending trial pursuant to the Bail Reform Act, 18 U.S.C. § 3142(e)(1). 

The Defendants are currently exploiting the viral pandemic ravaging the United States by 

marketing a toxic industrial bleach as a cure for COVID-19. This bleach, which they brand as 

Miracle Mineral Solution (“MMS”), has already poisoned thousands. Due to the Defendants’ 

unlawful and immensely dangerous conduct, a U.S. District Judge for the Southern District of 

Florida issued an injunction prohibiting the Defendants from marketing MMS. Yet since then, the 

Defendants have openly and vehemently defied the Court, threatening “‘civil disobedience’ 

against this unjust order! ... The 2nd Amendment is there in case it can’t be done peaceably.” The 

whole idea of bond is that the defendants can be trusted to comply with court orders requiring their

appearance and setting conditions for their release. There is no basis to think these Defendants 

will comply with any order, let alone bond terms. They are a danger to the community, especially 

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in this public health crisis; they also present a serious risk of flight and of obstructing justice. They 

should be detained pending trial.

BACKGROUND

A. Criminal Charges

On June 29, 2020, the Honorable Alicia M. Otazo-Reyes, U.S. Magistrate Judge for the 

Southern District of Florida, authorized a Criminal Complaint charging the Defendants with

conspiracy to defraud the United States and to commit an offense against the United States by 

introducing a misbranded drug into interstate commerce, in violation of 18 U.S.C. § 371, and 

criminal contempt, in violation of 18 U.S.C. § 401(3). See Case No. 20-mj-3050 (S.D. Fla.), ECF 

No. 1 (attached hereto as Exhibit 1).

According to the United States’ preliminary calculation of the Sentencing Guidelines, if 

the Defendants are convicted of these offenses, they will likely face terms of imprisonment of 168-

210 months.

B. The Fraudulent Scheme

The Defendants manufacture, promote, sell, and distribute MMS, a chemical solution 

containing sodium chlorite and water. When ingested orally as directed by the Defendants, MMS 

becomes chlorine dioxide, a powerful bleaching agent typically used for industrial water treatment 

or bleaching textiles, pulp, and paper. 

The Defendants claim that MMS is a miracle cure-all that can treat, prevent, and cure a 

variety of serious diseases and disorders, including cancer, Alzheimer’s, autism, Parkinson’s, 

multiple sclerosis, and HIV/AIDS. Recently, the Defendants have promoted MMS as a cure for 

COVID-19. However, MMS has not been approved by the U.S. Food and Drug Administration 

(“FDA”) for the treatment of any of these diseases and disorders, or for any other use. Rather, the 

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FDA has previously issued public warnings strongly urging consumers not to purchase or use 

MMS, advising that ingesting MMS “is the same as drinking bleach” and “has caused serious and 

potentially life-threatening side effects,” including severe vomiting, diarrhea, and life-threatening 

low blood pressure. See FDA warns consumers about the dangerous and potentially life 

threatening side effects of Miracle Mineral Solution (Aug. 12, 2019), https://www.fda.gov/newsevents/press-announcements/fda-warns-consumers-about-dangerous-and-potentially-lifethreatening-side-effects-miracle-mineral. 

FDA has received numerous reports of adverse reactions to MMS, including 

hospitalizations, life-threatening conditions, and death. According to the American Association 

of Poison Control Centers, since 2014, poison control centers have managed more than 16,000 

cases involving chlorine dioxide poisoning, including approximately 2,500 cases involving 

children under 12 years old, many of whom suffered serious side effects, such as a six-year-old 

autistic girl who was hospitalized with liver failure in 2017.

Over the past several years, the Defendants sold tens of thousands of bottles of MMS 

nationwide, including to consumers throughout the Middle District of Florida and Southern 

District of Florida. The Defendants promoted and distributed MMS through a complex network 

of websites that they created and maintained. These websites featured countless newsletters, posts,

and articles authored by the Defendants, and dozens of podcasts and video interviews featuring the 

Defendants, in which they tout the miracle healing powers of MMS. 

Although the Defendants have sold MMS for several years, their sales skyrocketed once 

they began promoting MMS as a cure for COVID-19 in the middle of a global public health 

emergency. According to their financial records, from April 2019 through December 2019, the 

Defendants received an average of approximately $32,000 per month in MMS-related sales 

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revenue. But in March 2020—the month when they began promoting MMS as a cure for COVID19—they received approximately $123,000 in monthly MMS-related sales revenue, a nearly 400% 

increase in sales.

The Defendants’ marketing claims with respect to MMS are neither accurate nor subtle. 

For example, on March 4, 2020, Defendant Mark Grenon published a newsletter extolling the 

healing powers of MMS as a treatment for COVID-19, which he titled, “The Coronavirus is 

curable! Do you believe it? You better!” That newsletter provided detailed dosing instructions 

for using MMS to treat COVID-19, including one set of MMS dosing instructions “for adults,” 

and another set of dosing instructions “for small children.” The newsletter claimed that these 

dosages of MMS “should wipe [ ] out” COVID-19. Several days later, Mark and his son, 

Defendant Joseph Grenon, released a podcast similarly titled “The Coronavirus is curable! Do 

you believe it? You better!” in which they claimed that oral ingestion of “MMS will kill [COVID19].”

The Defendants were well aware that their marketing activities with respect to MMS were 

unlawful. So, they decided to sell MMS under the guise of the Genesis II Church of Health and 

Healing (“Genesis”), an avowedly non-religious entity that Mark Grenon created in an attempt to 

avoid government regulation of MMS. The Defendants have repeatedly admitted that they 

operated the Genesis “church” for the express purpose of cloaking their unlawful conduct with 

respect to MMS as constitutionally protected religious exercise, in an attempt to avoid government 

scrutiny of their actions and shield themselves from liability. However, Genesis’ own websites, 

which were created and are maintained by the Defendants, describe Genesis as a “non-religious 

church.” And Mark Grenon has admitted, in recorded statements, that Genesis “has nothing to do 

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with religion,” and that he founded Genesis to “legalize the use of MMS” and avoid “going [ ] to 

jail.”

Although the roles of each defendant in the conspiracy to defraud the United States often 

overlapped, with all of the Grenons variously promoting MMS as a miracle cure-all and facilitating

the sale of MMS to consumers, their responsibilities can be broadly categorized as follows. Mark 

Grenon, the father of the other defendants, is primarily responsible for promoting the supposed 

curative powers of MMS; he promotes MMS through his extensive online writings, podcasts, 

interviews, and training seminars. Defendant Joseph Grenon is primarily responsible for assisting 

his father in the promotion of MMS; the two of them co-host a weekly podcast dedicated to 

extolling the healing powers of MMS. Defendant Jonathan Grenon is primarily responsible for

the manufacturing of MMS; he produces and bottles MMS in a shed in the backyard of his home 

in Bradenton, Florida. Defendant Jordan Grenon is primarily responsible for the distribution of 

MMS; he is the point of contact for customers who purchase MMS from the Defendants, and he 

processes and fulfills customer orders. 

C. The Defendants’ Contemptuous Violation of Court Orders

Because of the foregoing conduct, on April 16, 2020, the United States filed a civil 

complaint against the Defendants and Genesis in the U.S. District Court for the Southern District 

of Florida, seeking an injunction to prohibit the Defendants from further violating the Federal 

Food, Drug, and Cosmetic Act, 21 U.S.C. § 301 et seq. (“FDCA”). See Case No. 20-cv-21601

(S.D. Fla.), ECF No. 1. U.S. District Judge Kathleen M. Williams issued a Temporary Restraining

Order on April 17, 2020 (the “TRO”) (attached hereto as Exhibit 2), and an Order of Preliminary 

Injunction on May 1, 2020 (the “PI”) (attached hereto as Exhibit 3), both of which prohibited the 

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

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[misbranded] drug, including but not limited to MMS . . . .” Ex. 2 at 3; Ex. 3 at 8. Notably, in 

issuing the PI, Judge Williams found that the “United States has demonstrated a substantial 

likelihood” that the Defendants’ marketing of MMS violated the FDCA. Ex. 3 at 3-5.

Despite knowing about the TRO and the PI,

1 the Defendants willfully violated those court 

orders by continuing to label and distribute MMS. With respect to labeling, as of the date of this 

motion, the Defendants have refused to remove from their website the newsletter or podcast titled, 

“The Coronavirus is curable! Do you believe it? You better!” which promotes MMS as a cure for 

COVID-19. Furthermore, on June 8, 2020, months after the issuance of the TRO and the PI, Mark 

Grenon published a newsletter featuring purported testimonials by users of MMS. One testimonial 

stated that the user “beat stage 4 terminal cancer” by ingesting MMS. That same testimonial stated 

that the user also successfully treated the flu, asthma, arthritis, fibromyalgia, and diabetes with 

MMS. Another testimonial featured in that same newsletter boasted that several MMS users had 

just “traveled to the Philippines and had to pass through Seoul, Korea and Tokyo, Japan airports 

where just about everyone was wearing the masks for coronavirus,” but the MMS users “had no 

fear (and no masks) because [they] had MMS protection.” The testimonial concluded by noting 

that the users were “back home and everyone is still healthy.”

The Defendants also violated the TRO and the PI by continuing to distribute MMS. For 

example, on June 13, 2020, Jordan Grenon published a newsletter written by his brother, Jonathan, 

in which Jonathan admitted that, despite the TRO and the PI, the Defendants “never stopped telling 

people how they can acquire [MMS]” (emphasis added). That newsletter also directed consumers 

 1 Although the Defendants have failed to appear in the civil case, despite being properly 

served and notified about the proceeding, there is no question that they are aware of the TRO and 

the PI, as evidenced by their public statements denouncing those orders and threatening the district 

judge.

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to a video featuring Jonathan, in which he explained that, despite the TRO and the PI, the 

Defendants had decided to continue distributing MMS directly to consumers. Jonathan explained 

that, to order MMS from the Defendants, a consumer simply needed to email their order directly

to Jonathan or Jordan—provided that the consumer disclose in their email if they work for law 

enforcement, because “FDA” and “DOJ” are “trying to cause us trouble.” A few weeks later, on 

July 4, 2020, Jonathan posted a new video in which he stated that the Defendants had distributed 

“over a hundred” bottles of MMS to consumers over the prior two to three weeks.

While the Defendants’ actions with respect to labeling and distributing MMS plainly 

violated the TRO and the PI, the Defendants’ public statements remove any doubt as to whether 

those violations were willful. For example, on April 21, 2020, in a letter addressed to U.S. District 

Judge Kathleen M. Williams and attorneys for the United States, co-signed by all of the 

Defendants, the Defendants claimed that they were “NOT bound to obey” the TRO. Case No. 20-

cv-21601 (S.D. Fla.), ECF No. 11 (attached hereto as Exhibit 4). In another letter addressed to 

Judge Williams and attorneys for the United States dated that same day, Mark Grenon, on behalf 

of all the Defendants, wrote: “We are practicing ‘civil disobedience’ against this unjust order! ...

Civil disobedience is permitted in the US Constitution[,] peaceably of course at first[,] if possible 

. . . . NOTE: The 2nd Amendment is there in case it can’t be done peaceably . . . . The Genesis II 

Church of Health and Healing will not stop . . . providing [MMS] to the world! The DOJ and FDA 

have NO authority over our Church.” See Case No. 20-cv-21601 (S.D. Fla.), ECF No. 11 (attached 

hereto as Exhibit 5). Similarly, in several of the weekly Genesis podcasts co-hosted by Mark and 

Joseph Grenon, they acknowledged: “We’re violating a temporary restraining order. Well, we 

don’t care. Okay? Don’t care . . . . We’re going to do it whether you like it or not.” They further 

threatened to “pick up guns” and instigate “a Waco” should the government interfere with the 

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Defendants’ marketing of MMS, while remarking of Judge Williams, “You think we’re afraid of 

some Obama-appointed judge that broke their oath? ... You’re no judge . . . . This judge could go 

to jail . . . . You could be taken out, Ms. Williams . . . . [W]e’re not obeying it. Don’t care what 

you do.”

I. ARGUMENT

The Bail Reform Act empowers the Court to detain a defendant pending trial upon a finding 

that “no condition or combination of conditions will reasonably assure the appearance of the 

person as required and the safety of any other person and the community.” 18 U.S.C. § 3142(e)(1) 

A finding that a defendant represents an unacceptable risk of nonappearance must be supported by 

a preponderance of the evidence, while a finding that a defendant presents a danger to the 

community must be supported by clear and convincing evidence. See 18 U.S.C. § 3142(f); United 

States v. Quartermaine, 913 F.2d 910, 917 (11th Cir. 1990). As discussed below, a finding that a

defendant will attempt to obstruct justice also supports pretrial detention.

In determining whether detention pending trial is appropriate, the Court must consider the 

following factors: (1) the nature and circumstances of the offense charged; (2) the weight of the 

evidence against the person; (3) the history and characteristics of the person; and (4) the nature 

and seriousness of the danger to any person or the community that would be posed by the person’s 

release. 18 U.S.C. § 3142(g). Consideration of these factors indicates that each of the Defendants

should be detained pending trial.

A. The Nature and Circumstances of the Offenses Charged

The sophisticated nature of the Defendants’ conspiracy, their extensive efforts to cloak

their unlawful conduct as protected religious exercise, their exposure to lengthy terms of 

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imprisonment, and their demonstrated refusal to comply with court orders, show they pose a 

substantial risk of nonappearance and threat to public safety. 

As explained in detail in the criminal complaint, the Defendants spent years marketing

MMS through a complex network of websites they controlled. These websites featured a vast 

array of newsletters, articles, podcasts, and video interviews produced by the Defendants, in which 

the Defendants lauded the miracle healing properties of MMS. Through these wide-ranging online 

promotional efforts, which targeted vulnerable populations with incurable or otherwise serious 

diseases and disorders, the Defendants sold thousands of bottles of MMS to consumers all across 

the country, poisoning countless Americans. Knowing full well that their conduct was illegal, the 

Defendants decided to market MMS under the guise of a “health church,” an elaborate ruse 

designed to shield themselves from government regulation and liability. And when the 

government attempted to halt the Defendants’ unlawful conduct, and a federal court issued an 

injunction prohibiting them from further marketing MMS, the Defendants willfully violated that 

injunction, giving rise to criminal contempt.

The Defendants’ ongoing contempt is especially important in considering whether there 

are conditions of bond that will ensure their appearance. The Defendants have a history of proudly 

violating court orders, making it highly unlikely that any combination of conditions will 

reasonably assure their presence at future proceedings as required by the Court. Time and again 

over the past several months, the Defendants have flouted their refusal to comply with court orders 

prohibiting them from marketing MMS, while proclaiming that they need not, and will never, obey 

the law. Even more egregious than the Defendants’ repeated violations of the court-ordered 

injunction, the Defendants have threatened violence against the federal judge who ordered that 

injunction. 

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Given the Defendants’ sophisticated ability to perpetrate fraud, conceal unlawful conduct, 

and defy government authorities, and their exposure to long prison sentences, the Defendants pose 

a serious risk of nonappearance and threat to public safety, especially in the current health crisis.

B. The Weight of the Evidence

The evidence proving the Defendants conspired to violate the FDCA is overwhelming. 

Indeed, the District Court presiding over the parallel civil case has already found that the “United 

States has demonstrated a substantial likelihood” that the Defendants violated the FDCA, the same 

offense that underlies the criminal conspiracy charged here. Ex. 3 at 3-5.

There is no question that MMS is a “drug” subject to regulation under the FDCA, because 

the Defendants have claimed on countless occasions—including in newsletters, articles, podcasts, 

and video interviews written by and/or featuring the Defendants—that MMS is intended for curing, 

mitigating, treating, and/or preventing a litany of serious diseases and disorders, including 

COVID-19, cancer, Alzheimer’s, autism, Parkinson’s, multiple sclerosis, and HIV/AIDS. See 21 

U.S.C. § 321(g)(1). 

There is no question that MMS is misbranded, because: (1) its labeling does not, and 

logically cannot, bear directions under which a layman can use MMS safely and for the purposes 

for which it is intended—e.g., to “cure” diseases that are incurable, such as COVID-19, 

Alzheimer’s, autism, Parkinson’s, and multiple sclerosis, see 21 U.S.C. § 352(f)(1); and (2) MMS

is manufactured in an establishment not duly registered with FDA, to wit, a shed in the backyard 

of Defendant Jonathan Grenon’s house, as can be seen in videos recorded by and featuring 

Jonathan, see 21 U.S.C. § 352(o).

There is no question the Defendants introduced MMS into interstate commerce, as billing 

invoices and shipping records reveal thousands of interstate shipments of MMS from Jonathan 

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Grenon’s home in Bradenton, Florida, to consumers across the country—including interstate 

shipments for MMS initiated by undercover law enforcement officers, through documented 

communications with Jordan Grenon.

And there is no question the Defendants—all immediate family members—conspired 

together to commit these violations of the FDCA, as all of the Defendants openly acknowledge 

their participation in the conspiracy. Mark and Joseph Grenon publicly broadcast themselves in 

Genesis-affiliated podcasts and interviews touting the myriad diseases that MMS can cure; 

Jonathan proudly posts videos of himself to Genesis-affiliated websites showing the MMS 

manufacturing facility that he operates in his backyard; and Jordan holds himself out to the public 

on Genesis-affiliated websites as the point of contact for consumers interested in purchasing MMS. 

Likewise, the Defendants have admitted in numerous recorded statements that they operated 

Genesis as a family for the sole purpose of shielding their unlawful manufacture, promotion, sale,

and distribution of MMS from government regulation—plain admissions of their fraudulent intent, 

and their guilt.

That the Defendants also have committed criminal contempt is similarly beyond dispute. 

As mentioned above, and as detailed in the criminal complaint, the Defendants’ actions in 

continuing to label and distribute MMS plainly violate the TRO and the PI. All of these actions 

are deliberate and willful; there is no confusion or uncertainty. Considering the Defendants’

repeated proclamations that they will not comply with the injunction, and their public boasting that 

they are violating court orders, the government’s proof of criminal contempt is overwhelming.

In sum, the strong weight of the evidence heavily favors pretrial detention.

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C. The Defendants’ History and Characteristics

The Defendants’ past travel practices, financial resources, and history of nonappearance 

make it even more unlikely that any combination of conditions will reasonably assure their

presence at future proceedings. Equally or more significant, however, is the Defendants’ plain and 

admitted intent to obstruct justice.

In addressing a pretrial detention request, courts consider whether the defendant presents a 

risk of obstructing justice, and a court may detain a defendant if it finds that the defendant will 

obstruct justice once released on bond. See, e.g., 18 U.S.C. 3142(f)(2)(B) (allowing the 

government to seek detention if the case involves “a serious risk that such person will obstruct or 

attempt to obstruct justice”); United States v. Esformes, Case No. 16-cr-20549 (S.D. Fla.), ECF 

No. 68 (detaining fraud defendant in part based upon “serious risk that he will attempt to obstruct 

justice as per 18 U.S.C. § 3142(f)(2)”). The “willingness to obstruct justice evinces a lack of 

respect for the rule of law and weighs heavily towards a finding that Defendant is a flight risk and 

a danger to the community.” United States v. Burstyn, 2005 WL 2297605, at *4 (S.D. Fla. March

18, 2005). Accordingly, “obstruction of justice, an attack on the rule of law, is a traditional ground 

for pretrial detention.” Id. See also United States v. LaFontaine, 210 F.3d 125, 134 (2nd Cir. 

2000) (similar); United States v. Hannah, 2010 WL 2628653, at *3 (S.D. Cal. June 29, 2010) 

(defendant’s “demonstrated disregard for the integrity of the legal system and the orders of the 

court” are significant consideration in determining whether pretrial release is appropriate).

The Grenons have demonstrated their lack of respect for the law by refusing to comply 

with court orders precluding the distribution of MMS, as well as by their strident and dangerous 

public pronouncements defying those orders and the federal judge issuing them. This is not only 

contempt, but shows a readiness to obstruct justice in every sense. In Esformes, the district court 

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affirmed the magistrate judge’s initial detention order in part because the defendant subsequently 

violated a TRO, just as the Grenons have been doing here with the TRO and PI in the parallel civil 

case here. See Case No. 16-cr-20549 (S.D. Fla.), ECF No. 133 at 26-27. As the district court 

explained in Esformes: “A court order releasing a defendant pending trial is predicated on the 

defendant’s credible promise to follow the Court’s orders – including all of the conditions of 

release. [] The pledging of monies for a bond, however substantial, and the promise of obeying 

conditions of release, however rigorous, are little assurance when the Court’s authority has already 

been flouted by the Defendant.” Id. The Eleventh Circuit subsequently upheld the detention order. 

See Case No. 16-16485 (11th Cir. Feb. 28, 2017). That is exactly the situation we have in this case 

for the Grenons.

Obstruction aside, the Defendants present a risk of flight. All of the Defendants have an 

extensive history of international travel, particularly to Colombia. Specifically, Mark Grenon 

owns a residential compound in Santa Marta, Colombia, where, as part of the Defendants’

conspiracy to market MMS, the Defendants operate what they call a “Restoration Center.” At this 

center, the Defendants offer MMS-focused retreats to consumers, for the price of $5,000 per 

month. All of the Defendants have traveled extensively to this Colombian compound. In fact, 

Jonathan was in Colombia as recently as February 2020, and it is believed that Mark and Joseph 

may be residing at the Colombian compound as of the date of this filing. Similarly, Defendants 

Jonathan and Jordan also frequently travel internationally to the Dominican Republic, including 

multiple trips by each Defendant in the last two years alone, as Jonathan’s domestic partner is from 

the Dominican Republic and it is believed the Defendants have close family ties in that country.

Furthermore, the Defendants’ financial resources indicate they present a high risk of flight. 

Although the government does not presently have access to current account statements, the 

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government does have financial records showing that, in the last year, the Defendants collected at 

least $500,000 in MMS-related sales revenue, including over $120,000 in March 2020 alone. 

While COVID-19 restrictions make some travel more difficult, airplanes continue to fly, other 

transportation options exist, and the Defendants’ financial resources would easily enable the 

Defendants to flee to Colombia, the Dominican Republic, or a country that does not extradite to 

the United States should they decide to flee rather than appear for future proceedings. 

Additionally, the concern is not merely whether these Defendants will escape overseas, but 

whether they will show up in court each and every time a federal judge orders them to do so. On 

this record, especially given their ongoing contempt, there is no basis to find with confidence that 

they will.

Indeed, not only do the Defendants have a history of violating court orders, they also have 

a history of failing to appear for court proceedings. In the parallel civil enforcement action, the 

Defendants were served with the TRO, the government’s complaint for injunctive relief, and 

summonses requiring the Defendants to answer the complaint. But the Defendants never 

responded, failed to appear in any capacity, and the clerk entered defaults against them. See Case 

No. 20-cv-21601 (S.D. Fla.), ECF No. 46.

D. The Nature and Seriousness of Defendants’ Danger to the Community

The Bail Reform Act directs the Court to consider also “the nature and seriousness of the 

danger to any person or the community that would be posed by the person’s release.” 18 U.S.C. 

§ 3142(g)(4). As the Eleventh Circuit has recognized, “[t]he term ‘dangerousness,’ as used in the 

Bail Reform Act of 1984, has a much broader construction than might be commonly understood 

in everyday parlance.” United States v. King, 849 F.2d 485, 487 n.2 (11th Cir. 1988). While 

“danger to any person” is intended to address physical danger to a particular individual, danger to 

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the community “refers to the danger that the defendant might engage in criminal activity to the 

detriment of the community.” Id. Thus, “the concern about safety [is] given a broader construction 

than merely danger of harm involving physical violence.” Id.

We are in the midst of an unprecedented national emergency, facing a viral pandemic that 

has claimed the lives of over 130,000 Americans. The Defendants capitalized on this crisis, and 

on the public’s fears of COVID-19, by marketing their toxic industrial bleach product as a miracle 

cure. Their actions directly endangered public health. The Defendants will undoubtedly continue 

to endanger public health by distributing MMS if they are not detained pending trial, as they have 

demonstrated by their unabated distribution of MMS in violation of the injunction. Given the 

certainty that the Defendants will persist in their pattern of dangerous criminal activity, to the 

imminent detriment of the community, pretrial detention is necessary.

CONCLUSION

For the foregoing reasons, the United States respectfully submits that the Court should 

detain the Defendants pending trial.

Respectfully submitted,

ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

BY: /s/ Michael B. Homer 

MICHAEL B. HOMER

Assistant United States Attorney

Court ID No. A5502497

JOHN SHIPLEY

Assistant United States Attorney

Florida Bar No. 0069670

99 Northeast 4th Street

Miami, Florida 33132-2111

Tel: (305) 961-9289

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