It is well known by now that HHS Secretary Robert F. Kennedy, Jr. has appointed his long-time associate David A. Geier to conduct a study of a possible association between autism and vaccines.
It is well known that David Geier and his father, the late Mark Geier, are “researchers” who claim to have found a causal association between vaccines and autism, and that their work has been widely criticized within the scientific community.
It is also well known that in 2011, the Maryland Board of Physicians summarily suspended Mark Geier’s license to practice medicine and charged David Geier with the unlicensed practice of medicine.
“Egregiously violated basic medical standards”
These charges arose from their promotion of Lupron in combination with chelation drugs as an autism “treatment,” which relied on the hypotheses that autism is a form of mercury poisoning, and that testosterone binds to mercury, thereby making it more difficult to remove. During its investigation, the Board found that Mark Geier
egregiously violated basic medical standards in his treatment of these patients by not evaluating them properly, lying about which drug he was prescribing, and failing to evaluate in any realistic medical way whether his intensive and very expensive treatment was effective.
Additionally, the Board found that Mark Geier
…had parents sign a consent form that falsely implied that he was conducting an experimental protocol approved by an Institutional Review Board when in fact that review board was […] a facade covering the intentions of a group that did not believe that they were bound by federal or state law and had no intention of being so bound.
In due course, Mark Geier’s license to practice was permanently revoked, a decision affirmed by Maryland’s highest court.
“Misleading, evasive and implausible”
A separate investigation found that rather than serving in solely an administrative capacity at his father’s practice, as he had claimed, David Geier diagnosed at least one child, evaluated a parent questionnaire about that child, and selected and ordered laboratory tests for that child, all without Mark Geier’s supervision. The Board found that “David Geier’s testimony was not reliable, and […] he was not a credible witness”; the Board further characterized his and his father’s testimony as “misleading, evasive and implausible,” and stated that they “contradicted each other and the documentary evidence. Often times, their testimony was self-contradictory.” David Geier was subsequently sanctioned and fined $10,000, a decision that was also affirmed upon appeal.
Partner in crime
Additionally in 2013, the license of Mark Geier’s practice partner, Dr. John Ling Young, was summarily suspended following the discovery by the Maryland Board of Physicians that shortly after the suspension of Mark Geier’s license, Dr. Young obtained a permit allowing him to dispense drugs directly to patients, then began to
[write] prescriptions for Lupron and leuprolide for patients of Mark Geier whom he himself had never examined or even met; that he doubled and even tripled patients’ dosages without reviewing their medical records or documenting his rationale for doing so; that one Prior Authorization he submitted cited to diagnoses of ‘central precocious puberty’ and ‘pituitary dysfunction’ that were not supported by the patient’s medical records; that his notes indicated that he would ‘check with David’ before prescribing leuprolide to another patient; and that when questioned about his reasons for increasing Dr. Geier’s patients’ dosages of Lupron after Dr. Geier’s license to practice was summarily suspended, he replied that he ‘was probably just following Dr. Geier’s recommendation.’
Dr. Young’s sole reliance on Mark Geier and his need to “check with David” for guidance in the administration of Lupron to autistic children is particularly concerning. Mark Geier had no training in endocrinology, and no experience in the diagnosis, care or treatment of either autistic children or mercury poisoned patients prior to his involvement in thimerosal litigation, and David Geier’s credentials to offer medical advice were only aspirational—a fact of which Dr. Young, who had known his business partner’s son since infancy, must certainly have been aware.
It is also concerning given the fact that in spite of his apparent inability to make independent decisions about the care of his young patients, in 2006 Dr. Young had advertised that he administered “Lupron injections” to autistic children at his practice. Dr. Young eventually persuaded the Maryland Board of Physicians to allow him to continue practicing in the field of obstetrics and genetic counseling.
Fresh start in the Sunshine State
Little has been written about Mark and David Geier’s activities since their move to Jupiter, Florida in late 2011. The Florida Board of Health had suspended Mark Geier’s license to practice medicine in October 2011 and permanently revoked it in August 2012. This attention from the Florida Board notwithstanding, Mark Geier began to engage in the unlicensed practice of pharmacy almost immediately upon his relocation to the state in December 2011.
According to a complaint issued by the Board in May 2013, on four different occasions between December 30, 2011 and February 2, 2012, Mark Geier compounded lots of leuprolide acetate powder at Prescription Depot, a “community pharmacy,” then dispensed it to 39 patients of three doctors identified only by their initials—initials that happen to correspond to the names of doctors associated with his businesses Genetic Consultants of America and ASD Centers LLC:
Google, “Streetview,” digital images, Google Maps (http://maps.google.com),
photograph of 8225 N Pine Island Rd, Tamarac, FL 33321, taken December 2024.
A final order in the case was issued in May 2015, with Mark Geier essentially pleading no contest to the allegations. He was reprimanded, fined $1,500, required to reimburse DOH for the cost of the investigation, required to take an ethics course, and barred from applying for a medical license without first undergoing a professional evaluation.
Setting up shop
Google, “Streetview,” digital images, Google Maps (http://maps.google.com),
photograph of 1408 N Killian Drive, Ste. 210, Lake Park, Florida, 33403,
taken January 2024
On October 18, 2011—the same month that Mark Geier’s license to practice medicine in Florida was suspended, and shortly before his family’s move to that state—David Geier established a Florida firm called DAP Pharmaceuticals, LLC (FEI #3010166882). In the articles of organization, the firm’s address was identified as 1408 N Killian Drive, Ste. 210, Lake Park, Florida, 33403; its registered agent was identified as Patrick E. Riley of Palm Beach Gardens, and its manager was identified as David A. Geier of Jupiter, Florida. Florida Board of Pharmacy records indicate that neither Patrick Riley nor David Geier hold a license to practice pharmacy in that state.
Import records indicate that on August 7, 2014, two capsule filling machines addressed to Kartzinel Wellness Center—the Jackson, Tennessee practice of Dr. Jerry Kartzinel, who testified in support of Mark Geier at his Maryland license revocation hearing—were delivered from China to David Geier’s Jupiter, Florida address.
Also in 2014, David Geier filed a FOIA with FDA for applications and correspondence about the approval, safety and effectiveness of cyproterone acetate—i.e., Androcur, a testosterone suppressant often prescribed by Mark Geier as part of the “Lupron protocol” that is not FDA approved for sale in the United States. Cyproterone acetate is available in powder form.
FDA Inspection: “Official Action Indicated”
On September 9 and 10, 2019, FDA investigators Vivin George and Jennifer L. Huntington conducted an inspection of DAP Pharmaceuticals LLC’s Lake Park, Florida facility. FDA’s 483 Inspectional Observations report was issued on September 11, 2019. The establishment was characterized as an API repackager, that is, a firm that repackages active pharmaceutical ingredient for dispensing. The report redacted the name of the API, recommended storage conditions and lot numbers. The report lists eight different categories of failure to establish adequate practices and procedures to ensure operational safety.
- OBSERVATION 1
Failure of your quality unit to ensure that there is stability data to support retest or expiry dates and storage conditions of the API.
Specifically, your firm has failed to perform stability testing to justify the use of the manufacturer’s expiration date for your repackaged (redacted), which is maintained at room temperature. The manufacturer’s expiration/retest dating is based on a storage condition of (redacted). - OBSERVATION 2
Failure to test the identity of each batch of incoming production material or appropriately qualify suppliers to rely upon their Certificate of Analysis.
Specifically, your firm has failed to perform at least one test to ensure the identity of the API prior to release for repackaging. In addition, your firm failed to qualify the supplier of (redacted), Lot (redacted), used in the repackaging of (redacted), Lot (redacted). - OBSERVATION 3
Failure to prepare and use production and control records for each API batch.
Specifically, your firm has failed to establish master packaging records and labeling used for the repackaging of (redacted). In addition, your firm does not prepare a batch record containing a representative label for each lot of repackaged (redacted). - OBSERVATION 4
Failure to establish written procedures describing the receipt, specifications, examination, and release of packaging and labeling materials.
Specifically, your firm has failed to establish procedures describing the receipt, specifications, examination, and release of packaging materials used for the repackaging of (redacted). In addition, your firm has failed to establish written procedures for the examination and release of labeling produced for repacked (redacted). - OBSERVATION 5
Failure to provide the manufacturer’s Certificate of Analysis with shipments of repackaged API to your customer.
Specifically, your firm has failed to provide customers a copy of the manufacturer’s Certificate of Analysis (COA) with shipments of (redacted). - OBSERVATION 6
Failure to have a quality unit that is independent of production and fulfills quality assurance (QA) and quality control (QC) duties.
For example, the same employees that perform repackaging activities also released batches for distribution. For example, (redacted) was repacked and released for distribution by the same employee. This was observed a minimum of 12 additional times from 01/14/14 to 09/30/15. - OBSERVATION 7
Failure to establish a procedure for the training of employees and to ensure training is regularly conducted by qualified individuals and covers, at a minimum, the particular operations that each employee performs and cGMP as they relate to the employee’s functions.
Specifically, your firm has failed to ensure employees are routinely provided training on cGMP and procedures required to perform their duties. - OBSERVATION 8
Failure to ensure that your cleaning and sanitization methods for equipment used in the repackaging of API are effective.
Specifically, your firm has failed to provide sufficient evidence that the cleaning and sanitization procedures used to clean dedicated equipment used for the repackaging of (redacted), are effective at eliminating microbial contamination and removes residual cleaning agents.
The DAP Pharmaceuticals inspection was classified as OAI, “Official Action Indicated”—the highest level of noncompliance.
Like father, like son
In its order revoking Mark Geier’s license to practice medicine, the Maryland Board of Physicians found that
Dr. Geier failed to meet basic medical standards for evaluating patients and conducting medical examinations and keeping adequate records of treatments and diagnoses. He failed to conduct an adequate initial evaluation of any of these patients and failed to make an adequate record of an examination for any of these patients. He began treatment often without sufficient information about the patients’ physical condition. In many cases, [Dr. Geier] had no information at all about the Patients’ physical conditions.
The Final Decision and Order in the disciplinary proceeding against David Geier affirmed the pervasive lack of documentation and rigor at Mark Geier’s medical practice:
Genetic Consultants had no approved policies and procedures (and certainly none that were written) for the ordering of laboratory testing by unlicensed individuals. No such policies and procedures are in the record. And the lack of policies and procedures at Genetic Consultants was further established by David Geier’s testimony in the instant case in his response to a question about the seemingly random nature of the initialing and signing of documents at the clinic: ‘It’s a reflection of the way that it just happened. I mean, the answer is that thousands of patients, thousands of charts we’re talking about, there are just times when things happen. I mean, we don’t have a formal protocol in place in the office that says you will do it this way or that way. It’s simply what happened in the course of patient care.’
Taken together, David Geier’s own words, and the DAP Pharmaceuticals 483, reinforce the impression that Mark Geier’s well-documented habits of lax record-keeping, failure to establish internal protocols and procedures and contempt for professional regulation have been passed on from father to son.
DAP Pharmaceuticals LLC was voluntarily dissolved eighteen months after the inspection, on March 2, 2021.
Nonexistent qualifications
This chain of incidents gives rise to numerous concerns, and numerous questions that remain open due to legally mandated redactions in the 483.
David Geier’s qualifications for operating any sort of pharmacy are nonexistent. According to the Maryland Board of Physicians’ charges against him,
[He] never has been licensed to practice medicine or any other health occupation in the state of Maryland or any other State. [He] has a Bachelor’s of Art degree in biology from a Maryland State university. [He] has taken several graduate courses, but has not earned a graduate degree in any specialty or discipline (emphasis added).
His responsibilities in his role as President of DAP Pharmaceuticals, Patrick Riley’s responsibilities and qualifications for managing a pharmaceutical repackager, and the identity, responsibilities and qualifications of any other individuals who might have been employed by DAP Pharmaceuticals remain open questions.
Signs point to yes
Whether Mark Geier was directly involved in DAP Pharmaceuticals’ operations is a question that is likely correctly answered in the affirmative. Both the Florida Department of Health’s finding that he had compounded leuprolide on multiple occasions then dispensed it to numerous patients, and the Maryland Board of Physicians’ finding that Dr. John Young had enabled Mark Geier to continue practicing medicine following the suspension of his license, demonstrate that Mark Geier was determined to continue his pharmaceutical experimentation on the endocrine systems of disabled children in spite of any efforts by professional regulators to stop him, and in spite of criticism of his treatment hypotheses by pediatric endocrinologists, who he asserted “don’t know what they are talking about.”
The fact that the time period during which John Young was found to have written prescriptions to Mark Geier’s former patients corresponds to the time period during which Mark Geier was found to have compounded leuprolide acetate and shipped it to “J.Y.” suggests that the prescriptions written by “J.Y.” were intended for patients of Mark Geier, who he was continuing to treat via his business partner.
Whether DAP Pharmaceuticals ever shipped drugs direct to consumer, or to unlicensed individuals affiliated with ASD Centers, LLC, remain open questions, as does the ultimate destination and intended use of the capsule filling machines addressed to Dr. Jerry Kartzinel at David Geier’s home address.
DAP? TAP?
The similarity of the business name “DAP Pharmaceuticals” to TAP Pharmaceuticals, the now-defunct inventor of Lupron, is another point of interest. In September 2005, TAP and the Geiers jointly submitted an application to patent the “Lupron protocol” that included the fallacious assertion that “mercuric chloride binds and forms a complex with testosterone in subjects,” thereby making mercury more difficult to remove. A revised application submitted in October 2007 omitted this falsehood, and focused instead on the goals of reducing mercury and testosterone levels in autistic children.
Just what was that API and who was it aimed at?
Although the identity and source of the API or APIs repackaged by DAP remain unknown, Mark and David Geier’s patents and reports on the pharmaceutical treatment of autistic children primarily discuss drugs that suppress testosterone, with specific focus on Lupron and Androcur. The 483 report implies that a single API was handled by DAP at the time of the inspection. The investigators’ observation that the API was improperly stored at room temperature implies that it was supposed to be refrigerated. If the API was leuprolide acetate, it should have been stored at -20 ± 5°C (-4 ± 41°F). Storing an API at an inappropriate temperature—especially one hotter than recommended—creates significant potential for contamination and degradation; this is a matter of particular concern given the likelihood that the drugs dispensed by DAP were prescribed for administration to autistic children, who are entitled to special protections in research both by virtue of their youth, and by virtue of their disability.
Radical transparency?
Robert F. Kennedy, Jr. called for a new era of “radical transparency” upon his confirmation as Secretary of HHS. If David Geier failed to disclose his sanction by the Maryland Board of Physicians for the unlicensed practice of medicine, or his creation of DAP Pharmaceuticals LLC in whatever CV he might have submitted to HHS prior to being hired by Secretary Robert F. Kennedy, Jr. to lead a federally-sponsored investigation into possible associations between vaccines and autism, it would seem imperative to determine why. And if Secretary Kennedy is aware of David Geier’s sanction, of his involvement with DAP Pharmaceuticals, and of the damning inspection that preceded its dissolution, it would seem imperative to elicit why he would conclude that it just doesn’t matter.
Many thanks to Elizabeth Woeckner of CIRCARE for her help preparing this report.
SOURCES
Maryland State Board of Physicians
Maryland Board of Physicians (March 22, 2012). Final decision and order. In the Matter of Mark R. Geier, M.D., License No. D24250. Case Nos. 2007-0803, 2008-0454, 2009-0308, https://www.mbp.state.md.us/bpqapp/Orders/D2425003.222.pdf.
Maryland State Board of Physicians (August 22, 2012). Final decision and order. In the matter of Mark R. Geier, M.D. (License No. D24250). Case Nos. 2007-0803, 2008-0454, 2009-0308, p. 7, https://www.mbp.state.md.us/BPQAPP/orders/d2425008.222.pdf.
Maryland State Board of Physicians (May 16, 2011). Charges under the Maryland Medical Practice Act. In the matter of David A. Geier (unlicensed). Case Numbers 2008-0022 and 2009-0318, https://www.mbp.state.md.us/BPQAPP/orders/GeierCharge05162011.pdf.
Maryland State Board of Physicians (July 30, 2012). Final decision and order. In the matter of David A. Geier (unlicensed). Case Numbers 2008-0022 and 2009-0318, https://www.mbp.state.md.us/BPQAPP/orders/GeierOrder07.302.pdf.
Maryland State Board of Physicians (February 13, 2013). Order for summary suspension of license to practice medicine. In the matter of John L. Young, M.D. (License No. D23121). Case No. 2012-0497, https://www.mbp.state.md.us/BPQAPP/orders/d2312102.133.pdf.
Maryland State Board of Physicians (September 26, 2014). Final decision and order. In the matter of John L. Young, M.D. (License No. D23121). Case No. 2012-0497, https://www.mbp.state.md.us/bpqapp/Orders/D2312109.264.pdf.
Court of Special Appeals of Maryland
Court of Special Appeals of Maryland (May 29, 2015). Opinion. Mark R. Geier v. Maryland Board of Physicians. No. 1095, Sept. Term, 2014, https://caselaw.findlaw.com/court/md-court-of-special-appeals/1702533.html.
Court of Special Appeals of Maryland (July 31, 2015). Opinion. David A. Geier v. Maryland Board of Physicians. No. 0709, September Term 2014, https://www.courts.state.md.us/sites/default/files/unreported-opinions/0709s14.pdf.
Florida Board of Medicine
Florida Board of Medicine (October 17, 2011). Administrative complaint. Department of Health v. Mark Robin Geier. Case 2011-07673. License No. ME0103406, https://mqa-internet.doh.state.fl.us/MQASearchServices/HealthCareProviders/LicenseVerification?LicInd=101411&ProCde=1501.
Florida Board of Medicine (April 12, 2012). Settlement agreement. Department of Health v. Mark Robin Geier. Case 2011-07673. License No. ME0103406, https://mqa-internet.doh.state.fl.us/MQASearchServices/HealthCareProviders/LicenseVerification?LicInd=101411&ProCde=1501.
Florida Board of Medicine (August 17, 2012). Final order. Department of Health v. Mark Robin Geier. Case 2011-07673. License No. ME0103406, https://mqa-internet.doh.state.fl.us/MQASearchServices/HealthCareProviders/LicenseVerification?LicInd=101411&ProCde=1501.
Florida Board of Medicine (May 24, 2013). Administrative complaint. Department of Health v. Mark Robin Geier. Case no. 2012-04248. License ME0103406, https://mqa-internet.doh.state.fl.us/MQASearchServices/HealthCareProviders/LicenseVerification?LicInd=101411&ProCde=1501.
Florida Board of Medicine (February 18, 2015). Settlement agreement. Department of Health v. Mark Robin Geier. Case no. 2012-04248. License ME0103406, https://mqa-internet.doh.state.fl.us/MQASearchServices/HealthCareProviders/LicenseVerification?LicInd=101411&ProCde=1501.
Florida Board of Medicine (May 1, 2015). Final order. Department of Health v. Mark Robin Geier. Case no. 2012-04248. License ME0103406, https://mqa-internet.doh.state.fl.us/MQASearchServices/HealthCareProviders/LicenseVerification?LicInd=101411&ProCde=1501.
Florida Division of Corporations
Florida Division of Corporations (accessed April 23, 2025). ASD Centers LLC: Application by foreign Limited Liability Company for authorization to transact business in Florida, https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2010%5C1119%5C87685971.Tif&documentNumber=M10000005067
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U.S. Food and Drug Administration
U.S. Food and Drug Administration (September 2024). Closed FDA FOIA log, September 2024, https://www.fda.gov/media/182385/download.
U.S. Department of Health and Human Services. Food and Drug Administration (August 19, 2019). Form FDA 483: Inspectional Observations: DAP Pharmaceuticals, https://www.neurodiversity.net/court/FDA%202019%20-%20DAP%20Pharma%20483%20(FOIA%202025-3642)%20(OCR).pdf.
U.S. Food and Drug Administration (accessed May 6, 2025). Firm Profile: DAP Pharmaceuticals, LLC (FEI Number 3010166882), https://datadashboard.fda.gov/ora/firmprofile.htm?FEIi=3010166882&/identity/3010166882.
World Intellectual Property Organization
TAP Pharmaceutical Products, Inc., Mark R. Geier and David A. Geier (September 13, 2005). WO2006033907: Methods of treating disorders having a component of mercury toxicity. Publication Number WO/2006/033907. World Intellectual Property Organization, https://patentscope.wipo.int/search/en/detail.jsf?docId=WO2006033907&_cid=P22-M91NXS-58917-1.
TAP Pharmaceutical Products, Inc., Mark R. Geier and David A. Geier (October 29,2007). WO2008055112: Methods of treating autism and autism spectrum disorders. Publication Number WO/2008/055112, https://patentscope.wipo.int/search/en/detail.jsf?docId=WO2008055112&_cid=P22-M91NXS-58917-1.
