in the court of appeals of maryland

IN THE COURT OF APPEALS OF MARYLAND ____________________________

September Term, 2017

No. 98

____________________________

JANE AND JOHN DOE, et al.,

Appellants, v.

ALTERNATIVE MEDICINE MARYLAND, LLC, et al.,

Appellees.

On Writ of Certiorari to the Court of Special Appeals (The Honorable Barry G. Williams)

________________________________

RECORD EXTRACT

Volume 2 of 3 ________________________________

Arnold M. Weiner, Esq. Michael D. Berman, Esq. Barry L. Gogel, Esq. Rifkin Weiner Livingston LLC 2002 Clipper Park Road, Suite 108 Baltimore, MD 21211 (410) 769-8080 [email protected] [email protected] [email protected]

Alan M. Rifkin, Esq. Rifkin Weiner Livingston LLC 225 Duke of Gloucester Street Annapolis, MD 21401 (410) 269-5066 [email protected] Attorneys for Appellants Jane and John Doe, Curio Wellness, LLC, Doctor’s Orders Maryland, LLC, Green Leaf Medical, LLC, Kind Therapeutics, USA, LLC, SunMed Growers, LLC, Maryland Wholesale Medical Cannabis Trade Association, and, the Coalition for Patient Medicinal Access, LLC

i

Record Extract -- Table of Contents

Pursuant to Rule 8-501(i), the date of filing of each paper reproduced in the extract is stated at the head of the copy in the extract.

Volume I

Certified Case Docket, 06/12/2017 ................................................................................ E 1 DOCKET #: 88/1, Order of Court [Order Appealed From], 06/02/2017...................... E 29 DOCKET #: 24/6, ORDERED, that the Proposed Intervening Defts' Motion

to Intervene (Pleading No. 24) is hereby DENIED, Williams, B., Judge [Order Appealed From], 02/21/2017 ........................................................................ E 33

DOCKET #: 38/2, Order of Court ORDERED, that the Proposed

Intervening Defendant Holistic Industries, LLC’s Motion to Intervene (Pleading No. 38) is hereby Denied, Williams, B., Judge [Order Appealed From], 02/23/2017 ................................................................................... E 36

DOCKET #: 101/1, Order of Court ORDERED that ForwardGro, LLC's

request to "govern itself as party" going forward in this matter is DENIED; etc., Williams, B., Judge [Order Appealed From], 05/31/2017 .............. E 39

DOCKET #: 1/0, Complaint for Declaratory Judgment and Preliminary and

Permanent Injunctive Relief, 10/31/2016 ................................................................ E 41 DOCKET #: 1/1, Answer to Complaint for Declaratory Judgment Filed by

DEF001Natalie M. LaPrade Maryland Medical Cannabis Commission, DEF002 Maryland Department of Health and Mental Hygiene, 03/10/2017 .............................................................................................................. E 64

DOCKET #: 20/0, Notice of Service of Discovery Material filed by

Alternative Medicine Maryland, LLC, 12/02/2016 ................................................. E 83 DOCKET #: 21/0, Defendants' Motion to Dismiss, or in the alternative,

Motion for Summary Judgment Filed by DEF001 Natalie M. LaPrade Maryland Medical Cannabis Commission, DEF002 Maryland Department of Health And Mental Hygiene, 12/12/2016 ........................................ E 85

ii

DOCKET #: 21/1, Pages 1 and 8 of Opposition To Defendants' Motion To Dismiss, Or In the Alternative, Motion for Summary Judgment, With Exhibits And Request For Hearing, 12/30/2016 ..................................................... E 89

Exhibit 1: Article by Michael Dresser – October 14, 2016 ............................... E 92

Exhibit 2: Article by Fenit Nerappil – August 26 [no year provided by author] ...................................................................................................... E 96

DOCKET #: 21/2, Supplement to Opposition to Defendants' Motion to

Dismiss, or in the alternative Motion for Summary Judgment, 02/17/2017 ............................................................................................................ E 103 Exhibit 1: Affidavit of Plaintiff’s Counsel Byron B. Warnken ....................... E 105

DOCKET #: 21/3, Order of Court ORDERED that the Defts' Motion to

Dismiss, or in the Alternative, for Summary Judgment (Pleading No. 21) is hereby DENIED, Williams, B., Judge, 02/21/2017 .................................... E 112

DOCKET #: 24/0 Motion To Intervene, With Exhibits (Entry Of

Appearance Attached But Not Entered) Filed by INT003-Doe, INT004-The Coalition For Patient Medicinal Access, LLC, INT005-Curio Cultivation LLC, INT002-Doe, INT008-SunMed Growers, LLC, 12/30/2016 ............................................................................................................ E 115

Exhibit 1: Motion to Specially Assign Consolidate, and Dismiss this

Action .......................................................................................................... E 125 DOCKET #: 30/0, Line Filed By Proposed Intervening Defendants

[REDLINES OMMITTED], 01/03/2017 ............................................................... E 133

Final Copy of corrected Exhibit 1 to Motion to Intervene filed on December 30, 2016 ........................................................................................... E 137

Final Copy of corrected entry of appearance ................................................... E 143 DOCKET #: 24/2 Response To Motion To Intervene Filed by

DEF001Natalie M. LaPrade Maryland Medical Cannabis Commission, DEF002 Maryland Department Of Health And Mental Hygiene, 01/05/2017 ............................................................................................................. E 148

iii

Attachment 1: Defendant's Initial Response to Motion to Specially Assign, Consolidate, and Dismiss the Action, 01/05/2017 .................................... E 151

DOCKET #: 24/3 Intervening Defendant’s Line Supplementing Motion To

Intervene, With Objection, And Rule 2-504 Request For Scheduling Conference, With Exhibits And Request For Hearing [REDLINES OMITTED], 01/12/2017 ........................................................................................ E 155

Exhibit A: January 12, 2017 Letter to The Honorable W. Michel

Pierson ............................................................................................... ……. E 164 Exhibit B: E-mail chain dated January 11, 2017 ............................................. E 167 Exhibit C: E-mail chain dated January 4, 2017 ................................................ E 170 Exhibit D: E-mail chain dated January 9, 2017................................................ E 174

DOCKET #: 24/4 Opposition to Motion to Intervene and Request for

Hearing filed by Alternative Medicine Maryland, LLC, 01/05/2017 ................... E 179 DOCKET 24/5 Cover Page and Exhibits to Reply Memorandum filed by

INT003-Doe, INT004-The Coalition For Patient Medicinal Access, LLC, INT005-Curio Cultivation LLC, INT002-Doe, INT008-SunMed Growers, LLC, 01/11/2017 ..................................................................................... E 188

Exhibit A: E-mail chain dated January 10, 2017 ............................................. E 190 Exhibit B: E-mail chain dated January 9, 2017 ............................................... E 194


Intervening Defts' Motion to Consolidate (Pleading No. 26 & 40) is hereby Denied, Williams, B., Judge, 02/21/2017 ................................................. E 199


Intervening Defendant’s Motion to Dismiss (Pleading No. 27 & 39) is hereby DENIED as moot, 02/21/2017 ................................................................... E 203

DOCKET #: 32/1, Page 1 of Intervenors’ Reply In Support Of Motion To

Specially Assign, and Signature Page, Filed by INT003-Doe, INT004-The Coalition For Patient Medicinal Access, LLC, INT005-Curio Cultivation LLC, INT002-Doe, INT008-SunMed Growers, LLC, 01/11/2017 ............................................................................................................. E 206

iv

Exhibit A: E-mail chain dated 01/10/2017 ....................................................... E 209 Exhibit B: E-mail chain dated 01/09/2017 ....................................................... E 213

DOCKET #: 34/0, Alternative Medicine Maryland, LLC’s Notice of

Service of Discovery Material, 01/05/2017 ........................................................... E 218 DOCKET #: 38/0, Motion to Intervene, Exhibits and Request for Hearing

filed by Holistic Industries, LLC, 01/25/2017 ....................................................... E 220

Exhibit A: Motion to Specially Assign, Consolidate, and Dismiss filed 01/03/2017 .......................................................................................... E 228

DOCKET #: 38/1, Alternative Medicine Maryland, LLC’s Opposition to

Proposed Intervenor Holistic Industries, LLC's Motion to Intervene and Request for Hearing, 02/09/2017 ........................................................................... E 233

DOCKET #: 39/0, Proposed Motion to Dismiss filed by Proposed

Intervening Defendants INT003-Doe, INT004-The Coalition For Patient Medicinal Access, LLC, INT005-Curio Cultivation LLC, INT002-Doe, INT008-SunMed Growers, LLC -- SEE ENTRY #27/3 FOR ORDER OF COURT [REDLINES OMITTED], 01/03/2017 .............................................. E 239

DOCKET #: 42/0, Order of Court, It is this 7th day of February 2017

Ordered this case is specially assigned to Honorable Barry Williams for all further proceedings, Pierson, J, 02/07/2017...................................................... E 246

DOCKET #: 45/0, Line with affidavits Filed by INT003-Doe, INT004-The

Coalition For Patient Medicinal Access, LLC, INT005-Curio Cultivation LLC, INT002-Doe, INT008-SunMed Growers, LLC, 2/20/2017 .............................................................................................................. E 247

Affidavit of Michael G. Bronfein dated 01/23/2017 ........................................ E 251 Affidavit of Jake Van Wingerden dated 01/23/2017 ...................................... E 255 Affidavit of ForwardGro, LLC dated 01/23/2017 ........................................... E 259 Affidavit of Parent of Jane and John Doe dated 01/23/2017 ........................... E 263

DOCKET #: 46/0, Alternative Medicine Maryland, LLC’s Notice of Service of Discovery Material, 03/10/2017 ........................................................... E 266

v

DOCKET #47/0, Appeal Order to COSA Filed by INT002 Doe, INT003

Doe, INT004 The Coalition For Patient Medicinal Access, LLC, INT005 Curio Cultivation LLC, INT006 ForwardGro LLC, INT007 Doctors Orders Maryland LLC, INT008 SunMed Growers, LLC 03/15/2017 ............................................................................................................. E 268

DOCKET #: 48/0, Appeal Order to COSA Filed by Proposed Intervening

Defendant, Holistic Industries, LLC, 03/16/2017 ................................................... E 272 DOCKET #: 49/0, Alternative Medicine Maryland, LLC’s Notice of

Service of Discovery Material, 03/17/2017 ........................................................... E 275 DOCKET#: 52/0, Amended Appeal Order to COSA Filed by INT002-Doe,

INT003-Doe, INT004-The Coalition For Patient Medicinal Access, LLC, INT005-Curio Cultivation LLC, INT006-ForwardGro LLC, INT007-Doctors Orders Maryland LLC, INT008-SunMed Growers, LLC [REDLINES OMITTED], 3/22/2017 ........................................................... E 277

DOCKET #: 54/0, Transcript of Proceedings held on 02/21/17 before Judge

Barry G. Williams for Case No. 24-C-16-005801, 02/21/17 ................................ E 281 Transcript of Proceedings held on 02/21/17 before Judge Barry G.

Williams for GTI Case No. 24-C-16-005134 ....................................................... E 324

Volume II DOCKET #: 55/0, Appeal Order to COSA Order To Proceed No. 00040

September Term, 2017, 3/28/2017 ........................................................................ E 363 DOCKET #: 57/1, Order of Court Denying #57, #58, and #59, 5/03/2017 ............... E 364 DOCKET #: 67/0, Appeal Order to COSA Filed by DEF001-Natalie M.

LaPrade Maryland Medical Cannabis Commission, DEF002-Maryland Department Of Health And Mental Hygiene, 5/08/2017 ...................................... E 367

DOCKET #: 68/0, Motion to Stay Circuit Court Proceedings Pending

Further Review Filed by DEF001-Natalie M. LaPrade Maryland

vi

Medical Cannabis Commission, DEF002-Maryland Department Of Health And Mental Hygiene, 05/08/2017 ............................................................. E 369

Exhibit 1: Notice of Appeal, 05/08/2017 ........................................................ E 373 Exhibit 2: Certified Docket, 05/08/2017 ......................................................... E 376 Exhibit 3: Affidavit of Commissioner Col. Harry Robshaw, III,

2/12/2016 .................................................................................................... E 395

DOCKET #: 68/1, Alternative Medicine Maryland, LLC’s Response in Opposition to Motion to Stay and Request for Hearing, 05/15/2017 .................... E 399

DOCKET #: 68/2, Order of Court, 05/26/2017 ............................................................ E 408 DOCKET #: 72/0, Alternative Medicine Maryland, LLC’s Motion for

Emergency Temporary Restraining Order and Request for Immediate Emergency Hearing, 5/15/2017 ............................................................................. E 409

Pages 1 and 22 of Alternative Medicine Maryland, LLC’s Memorandum of

Law in Support of Motion for Emergency Temporary Restraining Order and Request for Immediate emergency hearing ..................................................... E 415

Exhibit A: Complaint for Declaratory Judgment and Preliminary and

Permanent Injunctive Relief [Omitted; see Docket 1/0] ........................... E 418 Exhibit B: Affidavit of Professor F. Michael Higginbotham (with

exhibits) ....................................................................................................... E 419 Exhibit C: Affidavit of Dr. Gregory Daniel, Managing Member

Plaintiff Alternative Medicine Maryland, LLC (with exhibits .................. E 477 Exhibit D: Article by Erin Cox with the Baltimore Sun dated April

29, 2017 ...................................................................................................... E 493 Exhibit E: Transcript of Conference Call dated April 14, 2017 ...................... E 499 Exhibit F: Deposition transcript of Harry “Buddy” Robshaw dated

May 10, 2017 .............................................................................................. E 538 Exhibit G: Letter to Delegate West dated March 13, 2015 ............................. E 623 Exhibit H: Letter to Special Secretary Rhee dated April 27, 2017 ................. E 627

DOCKET #: 72/1, Opposition to Plaintiff's Motion for Emergency

Temporary Restraining Order and Request for Order to Show Cause Why a Preliminary Injunction Should Not be Granted, with Exhibits Filed by DEF002-Maryland Department Of Health And Mental

vii

Hygiene, DEF001-Natalie M. LaPrade Maryland Medical Cannabis Commission 05/17/2017 ....................................................................................... E 629

Exhibit: Affidavit of Mary-Jo Mather dated July 17, 2017 ............................. E 638 Exhibit: July 19, 2016 Letter from Maryland Department of Health

and Mental Hygiene ................................................................................... E 642 Exhibit: July 19, 2016 Letter from Alternative Medicine Maryland .............. E 646 Exhibit: Grower Applicant E-mail List ........................................................... E 650 Exhibit: Unique Identifier County List ........................................................... E 652 Exhibit: Comments for Regulations for June 14th, 2016 Meeting of

the Policy Committee ................................................................................. E 654 DOCKET #: 72/2, Commission's Supplement to Commission's Opposition

to Plaintiff's Motion for Emergency Temporary Restraining Order and Request for Order to Show Cause Why a Preliminary Injunction Should Not be Granted, with Exhibits Filed by DEF001-Natalie M. LaPrade Maryland Medical Cannabis Commission, DEF002-Maryland Department Of Health And Mental Hygiene, 05/24/2017 .................................... E 655

Exhibit 1: Affidavit of Jennifer Porcari, 05/16/2017 ...................................... E 658 Exhibit 2: Affidavit of Jennifer Beedie, 05/22/2017 ....................................... E 662

DOCKET #: 72/5, ForwardGro’s Memorandum in Opposition to

Preliminary Injunction, [Exhibit A Omitted See Dkt 54/0] 05/30/2017 [Printed in Vol. III] ........................................................................... E 1070

Exhibit B: E-mail from Alyson Kierzewski .................................................. E 1078 Exhibit C: Affidavit of Gail L. Rand .............................................................. E 1081 Exhibit D: Affidavit of Debra Kimless, M.D. ................................................ E 1087 Exhibit E: Affidavit of Gary Mangum ........................................................... E 1093 Exhibit F: Affidavit of Carol Loveless ........................................................... E 1100

Transcript of Proceedings on Motion for TRO Hearing Case No. 24-C-16-

005801 before the Honorable Barry G. Williams, 05/25/17 [Printed in Vol. III] ................................................................................................................ E 1017

DOCKET #: 72/3, Order Granting Pltf's Emergency Motion For Temporary

Restraining Order, 5/25/2017 ................................................................................ E 667

viii

DOCKET #78/0, Court of Special Appeals Order of Court, 05/19/2017 .................. E 670 E-mail Correspondence from Alyson Parker-Kierzewski, Law Clerk to the

Honorable Barry G. Williams, 05/25/2017 ........................................................... E 671 DOCKET #: 82/0, Line filing bond pursuant to Order Dated

May 25, 2017, 05/26/2017 .................................................................................... E 672 DOCKET #: 83/0, Motion to Shorten Time to Respond to Renewal of the

Motion to Intervene, Motion to Intervene in this Action, to Consolidate, for Stay Pending Appeal and Motion to Continue June 2, 2017 Hearing; and Opposition to Motion for Preliminary Injunction Filed by Jane Doe, John Doe, Curio Wellness, LLC, Doctor’s Orders Maryland, LLC, Green Leaf Medical, LLC, Kind Therapeutics, USA, LLC, SunMed Growers, LLC, Maryland Wholesale Medical Cannabis Trade Association, and, Coalition for Patient Medicinal Access, LLC, 05/30/2017 ............................................................................................................ E 678

DOCKET #: 84/0, Motion to Continue June 2, 2017 Hearing Filed Jane

Doe, John Doe, Curio Wellness, LLC, Doctor’s Orders Maryland, LLC, Green Leaf Medical, LLC, Kind Therapeutics, USA, LLC, SunMed Growers, LLC, Maryland Wholesale Medical Cannabis Trade Association, and, Coalition for Patient Medicinal Access, LLC [Exhibit Omitted See Docket # 89/0], 05/30/2017 .............................................................. E 686

Volume III

DOCKET #: 85/0, Emergency Motion to Dissolve or Modify TRO; for

Renewal of the Motion to Intervene; to Intervene in this Action; to Consolidate; for Stay Pending Appeal; and in Opposition to Motion for Preliminary Injunction, with Exhibits Filed by Jane Doe, John Doe, Curio Wellness, LLC, Doctor’s Orders Maryland, LLC, Green Leaf Medical, LLC, Kind Therapeutics, USA, LLC, SunMed Growers, LLC, Maryland Wholesale Medical Cannabis Trade Association, and, Coalition for Patient Medicinal Access, LLC, 05/30/2017 ................................... E 695

Exhibits A. 1 – A. 25: Affidavits in Support of Motion ................................... E 705 Exhibit B: Affidavit of Edward L. Weidenfeld ............................................... E 794 Exhibit C: E-mail Chain dated May 25, 2017 ................................................. E 813 Exhibit D: Senate Bill 1197 ............................................................................. E 815

ix

Exhibit E: House Bill 1443 ............................................................................. E 827 Exhibit F: Letter from DHMH dated March 29, 2017 .................................... E 843 Exhibit G: E-mail Chain dated May 26, 2017 ................................................. E 846 Exhibit H-1: Court of Special Appeals Briefing Order dated May 25,

2017 ............................................................................................................. E 849 Exhibit H-2: Court of Special Appeals Briefing Order dated

May 16, 2017 .............................................................................................. E 854 DOCKET #: 96/0, Line With Exhibits and Affidavits Filed by INT003-

Doe, INT002-Doe, INT005-Curio Cultivation LLC, INT007-Doctors Orders Maryland LLC, INT008-SunMed Growers, LLC, INT004-The Coalition For Patient Medicinal Access, LLC, 05/31/2017 .................................. E 859

E-mail chain dated May 31, 2017 .................................................................... E 863 Affidavits (Exhibit A.26-A.51) to supplement Exhibit A to Movants’

May 30, 2017 filing ..................................................................................... E 865 DOCKET #: 87/0, Renewed Motion to Consolidate, with Exhibits, filed by

Holistic Industries, LLC, 05/31/2017 .................................................................... E 952 [See Docket # 85/0] [Exhibit Omitted], 05/31/2017 ........................................ E 956 DOCKET #: 89/0, Motion to Continue June 2, 2017 Hearing filed by

Holistic Industries, LLC, [Exhibit Omitted; see docket #84/0], 05/31/2017 ............................................................................................................. E 957

DOCKET #: 88/0, Emergency Motion to Dissolve or Modify Temporary

Restraining Order, and Opposition to the Motion for Preliminary Injunction Filed by Holistic Industries, LLC, 05/31/2017 ..................................... E 962

Exhibit 1: Affidavit of Josh Genderson dated May 30, 2017 .......................... E 968 DOCKET #: 98/0,Temescal Wellness Consolidated Motion to Dissolve or

Modify TRO etc. with Exhibit 1 and Request for Hearing, 05/31/2017 [Printed in Vol. III] .............................................................................................. E 1103

Exhibit 1: Affidavit of Edward T. Rebholz, Jr. [Printed in Vol. III] ............. E 1108

x

DOCKET #: 90/0, Motion to Stay Pending Outcome of Related Appeal, with Request for Hearing, 05/31/2017 .................................................................. E 975

Exhibit A: Court of Special Appeals Briefing Order ...................................... E 980

DOCKET #: 91/0, Motion to Shorten Time filed by Holistic Industries,

LLC, 05/31/2017 .................................................................................................... E 985 DOCKET #: 93/0, Renewed Motion to Intervene and Request for Hearing

filed by Holistic Industries, LLC 5/31/2017 .......................................................... E 989 DOCKET #: 94/0, Notice of Withdrawal of Appearance of Rifkin Weiner

Livingston for ForwardGro, LLC, 05/31/2017 ...................................................... E 997 DOCKET #: 99/0 Bench Memorandum pages 1, 3, and 10 Filed by

Alternative Medicine, Maryland, LLC, 06/01/2017 ............................................ E 1001 DOCKET #: 101/0, Notice of Appearance of New Counsel, 05/30/2017 .............. E 1004

Exhibit A: E-mail chain dated May 25, 2017 ................................................ E 1007 DOCKET #: 103/0, Appeal Order to COSA Filed by INT007-Doctors

Orders Maryland LLC, INT001-Holistic Industries, LLC, INT002-Doe, INT003-Doe, INT004-The Coalition For Patient Medicinal Access, LLC, INT005-CurioCultivation LLC, INT006-ForwardGro LLC, INT008-SunMed Growers, LLC, INT009-TemescalWellness Of Maryland, LLC [Attachment omitted; see Docket #: 88/1], 06/01/2017 ........... E 1009

Order, In the Court of Appeals of Maryland, Petition Docket No. 148 (No.

40, Sept Term, 2017 Court of Special Appeals), 6/09/2017 ............................... E 1014 Writ of Certiorari, In the Court of Appeals of Maryland, Petition Docket

No. 148 September Term 2017 (No. 40 Sept. Term, 2017 Court of Special Appeals), 06/09/2017 .............................................................................. E 1016

Jane Ðoe et, al,vs.

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IN THECOURT OF SPSCTÀL ÀPPEÀIS

ALternatíve lledicine ilaryland LtC eL aJ"

No. 00040SepLember Term, 2At7

oRp.ER

TIre Court of speciat Appeale. pursuant to Maryl"and RuLe

8-2ç6(a)(1),ordersanddirectsthattheabovecaptionedappeal proceed wlthout a Prehearinç Conference'

ËY T}TË COURT

PETER B. KRAU CHT$F JUDGE

Ðate: March ?8, 291"7

I{ÀRTLYN BENTT.EY, CLERKTTRCUTÎ COURT E'OR BALTIMORË CITY{See attached FlaÍling Liat)

Dear Clerk: HitI ]rou kindlY P Iace thls order wlth the recordin this ëåusê (024C16Õ0580L) ' rhç da,tg of ,,þhis" Order

E 000363

vmckinley

Text Box

03/28/17

ALTERNATIVE MEDICINE MARYLAND,LLC,

Plaintiff

* IN THE

CIRCUIT COURT

BALTiMORE CITY

+

v *

*

FOR

NATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSION,et al., * Case No.: 24-C-16-005801

Defendants r'

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ORDER

Upon consideration of the Defendants' Motion for a Protective Order (#57), Motion to

Quash Subpoena for Deposition (#58) and Emergency Motion to Shorten Time for Response

Commissioner Harry Robshaw to their previously filed Motion to Dismiss and in the alternative

Motion for Summary Judgment, which included statements concerning the grower

subcommittee's selection process, and offered that affidavit in support of their motion, and

noting that Commissioner Harry Robshaw has made public comments concerning the grower

{.

subcommittee's deliberations and selection process, the Defendants cannot now invoke either the

deliberative process privilege or executive privilege to forestall discovery of information

concerning the grower subcommittee's deliberations and the selection process, it is this 3rd day

of May, 2017,by the Circuit Court for Baltimore City;

ORDERED that Defendants' Motion for a Protective Order (#57) is hereby DENIED;

and it is further

ORDERED that Defendants' Motion to Quash Subpoena for Deposition (#58) is hereby

DBNIED; and it is turther

E 000364

vmckinley

Text Box

05/03/17

ORDERED that Defendants' Emergency Motion to Shorten Time for Response (#59) is

hereby DENIED; and it is futher

ORDERED that Plaintiff Alternative Medicine Maryland, LLC be permitted to depose

Commissioner Harry Robshaw on May 10,201,7 .

Circuit Court for Baltimore City

TRUE COPYTE ST

lvtARiL\T'l B BNTLEY, CLERK

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May B, 20L7

Brian S Brown EsqBrown & Barron LLC7 St. PauI StreetSuite 800Baltimore, MD 21202

CIRCUTT COURT FOR BALTTMORE CTTYMarilyn Bentley

Clerk of the Circui-t CourtCourthouse East

111 North Calvert Street - Room 462Baltimore, MD 21-202-

410-333-3722 TTY for Deaf: (4tO)-:¡:-4389

Case Number: 24-C-1-6-005801- / OG /Alternative Medicine Mary1and, LLC Vs NaÈalie M

FOLD HERE

E 000366

ALTERNATIVE MEDICINEMARYLAND, LLC

Plaintffi

V

NATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMIS SION,et al.,

Defendants.

* .* +

* IN THE

* CIRCUIT COURT

* FOR

* BALTIMORE CITY

* Case No.: 24-C-16-005801

rk ,k + :1.*

*

+

NOTICE OF APPEAL

The Natalie M. LaPrade Maryland Medical Cannabis Commission, all individually-

named commissioners, and the Department of Health and Mental Hygiene, note an appeal

to the Court of Special Appeals in the above-captioned case.l

Respectfully submitted,

BzuAN E. FnosnAttorney General of Maryland

HpRrnBn BAssistant Attorneys General300 V/. Preston Street, Suite 302Baltimore, Maryland 21201Office: (410) 167-1871Fax: (410) 333-7894heather.nelson 1 @maryland. gov

May 8,2017

I This notice relates to the May 3, 2017 , Order

Attorneys for Defendants

E 000367

vmckinley

Text Box

05/08/17

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 8ú day of May,20IJ, a copy of the Defendants'

Notice of Appeal was electronically mailed and rnailed via first-class mail postage

prepaid to

Byron L. WarnkenByron B.'WamkenWARNKEN,LLC2 Reservoir Cir. #104Baltimore, MD [email protected]

John A. Pica, Jr.

John Pica and Associates, LLC14 State CircleAnnapolis, MD 21401jpica@johnpica,com

Brian S. BrownBrown & Barron, LLC7 St. Paul Street, Suite 800

Baltimore, Maryland 21202bbrown@brownbarron. com

Counsel for Alternative Medicine Maryland

øHeather B. Nelson

E 000368

NATALIE M. LAPRADEMARYLAND MEDICAL CANNABISCOMMISSION, el a/.,

Appellants,

ALTERNATIVE MEDICINEMARYLAND, LLC, et al.,

Appellees.

ll

+

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*

IN THE

COURT OF SPECIAL APPEALS

OF MARYLAND

September Term,2017

No.

* (Circuit Court for Baltimore City

* No. 24-C- 16-005801)

V

* {. * {< *,t * * {c * * r} * * + {r * *

MOTION FOR IMMEDIATE STAY OF CIRCUIT COURTPROCEEDINGS PENDING F'URTHER REVIEW

Pursuant to Rule 8-425 and the inherent power of the Court, the appellants, the

Natalie M. LaPrade Maryland Medical Cannabis Commission (the "Commission"), the

Department of Health and Mental Hygiene ("DHMH"), and the individually-named

commissioners, through counsel, move for an immediate stay pending appeal of the order

entered on May 3,2017 by the Circuit Court for Baltimore City in Alternative Medicine

Maryland, LLC v. Natalie M. LaPrade Mar,yland Medical Cannabis Commissíon, et al.,

Civil Case No.: 24-C-16-005801, and a stay of all further proceedings in that case. This

motion requires this Court's immediate attention because the circuit coult's order directs

that a deposition of a member of the Commission go forward on Wednesday, May 10,

2017, and precludes the Commission from invoking "either the deliberative process

privilege or executive privilege" during that deposition.

E 000369

vmckinley

Text Box

05/08/17

MEMORAI{DUM OF LAWEXCLUDED PURSUAI\T TOMARYLAI{D RULE 8-501(c)

E 000370

MEMORANDUM OF LAW EXCLUDED PURSUANT TO MARYLAND RULE 8-501(c)

E 000370

CONCLUSION

The defendants respectfully ask the Court to issue an immediate stay ofproceedings

in Alternative Medícine Maryland, LLC v. Natalie M. LaPrade Marylønd MedÌcal

Cannabís Commission, et al., Circuit Court for Baltimore City, No. 24-C-16-005801,

pending disposition of the appeal.


BrueN E. FNOSU

Attomey General of Maryland

He¡,rr-rpnB.Assistant Attomeys General300 W. Preston Street, Suite 302Baltimore, Maryland 21201Offrce: (410) 767-1877Fax: (410)333-7894heather.nelson 1 @maryl and. gov

Ìl1.ay 8,2017Attomeys for Defendants

9

E 000371

CERTIF'ICATE OF SERVICE

I certif, that on this 8th day of Muy, 2017, a copy of the Defendants'Motion for

Immediate Stay of Circuit Court Proceedings was electronically mailed and served via

first-class mail postage prepaid on:

Byron L. Warnken, EsquireByron B. Warnken, EsquireWARNKEN,LLC2 Reservoir Cir. #104Baltimore, MD 21208443-92t-1100Byron@warnkenlaw,com

John A. Pica, Jr., EsquireJohn Pica and Associates, LLC14 State CircleAnnapolis, MD [email protected]

Brian S. Brown, EsquireBrown & Barron, LLC7 St. Paul Street, Suite 800

Baltimoreo Maryland 21202b b rq:yn ffàþtp w u-l¿drro n . c om

Counsel þr Alternatíve Medícine Maryland

B. Nelson

10

E 000372

EXHTBIT 1

E 000373

EXHIBIT 1

E 000373

ALTERNATIVE MEDTCINETVÍARYLAND, LLC

Plaíntffi

v.

NATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSION,et al.,

Defendants.

f t *

* IN THE

* CIRCUIT COURT

FOR

BALTIMORE CTTY

r Case No.: 24-C-16-005801

{. fi ¡l¡ * *

r&

*

*

*

NOTICE OF APPEAL

The Natalie M. LaPrade Maryland Medical Cannabis Commission, all individually-

named commissioners, and the Department of Health and Mental Hygiene, note an appeal

to the Court of SpecÍal Appeals in the above-captioned case,l

Respectfu lly subrn itted,

BRnN E. FnosHAttorney General gf Maryland

Assistant Attorneys General300 W. Preston Street, Suite 302Baltímore, Maryland 21201Office: (410) 767-1877Fax: (410) 333-7894heather.nelson I @maryland.gov

May 8,2017

I This notice relates to the May 3, 2017, Order

Attorneys for Defendants

E 000374

CERTIFIC.A.TE OF SERVICE

I HEREBY CERTIFY that on this 8th day of May,2017, a copy of the Defendants'

Notice of Appealwas electronically mailed and mailed via frrst'class mail postage

prepaid to:

Byron L, \MarnkenByron B. WarnkenIWARNKEN,LLQ

2 Reservoir Cir. #104Baltimore, MD 21208443-921-r 100

Byron @warnken law. corn

John A. Pica, Jr.

John Pica and Associates, LLC14 State CircleAnnapolis, MD 21401jpica@johnpica,com

Brian S, BrownBrown & Banon, LLC7 St. Paul Street, Suite 800Baltimore, Maryland 21202bbrown@brownbarron. com

Counsel þr Alternatìve Medlcíne Maryland

øHeather B. Nelson

E 000375

EXTIIBIT 2

E 000376

EXHIBIT 2

E 000376

CTRCUTT COURT FOR BALTIMORE CITYMarilYn BenLleY

Clerk of the Circuit CourtCourLhouse EasL

l-l-l- Nort.h Calvert StreetRoom 462

Bal-timore, MD 2I202-(4r"0)-333-3122, TTY for Deaf : (410)-333-4389

os/oB/r7 Case Number t 24-C-16- 005801 OG DJDaLe Filed¡ 10 /tt/zotøSLatus: OPen/InactiveJudge Assigned: Williams, BarrY G'Location :

CTS Start : L0 /3L /1"6 Target I 04 /29 /IBLLC Vs Nat.alie M. Laprade Maryland MediAlLernative Medicine MarYland,

C}ISE HTSTORY

OTHER REFERENCE NT}MBERS

Description Number

l,; ï, ,' ,utu Fol der ID ci6005801\/04

T}IVOI,VEÐ PARTIES

Type Num Name(Last,Fjr"st.Mìd,Title) Addr str/End Pty. Dìsp. Entered

' Addr UPdate

PLT . 001 Alternatìve Medjcìne Mar^vland, LLC 10/31116

Party iD:5260349

11/01/16 AAt^l70/3t/16Mai'l: 14 State CircleAnnapoìis, MD 21401

/-\ttorney: 0008326 Pìca, John A

Royston, Mueller, McLean & Reid, LLP

102 l,l Pennsylvania Avenue

102 l.J Pennsylvanìa Ave, S

Suite 600, l'40 21204-4570(410 ) 823- 1800

0008964 Brôwn, Bnran S

Brown & Barron LLC

7 St. Paul StreetSuìte 800

Appear : 10/31/2016 11/01/ 16

03120/ 17

r, M ¡ r¡ lylf lfål'il -$l'*Tå?F årt t,* c i rr- r ¡ i r { t{} u r tlirr Bultin¡orc (ìir¡', herr:lry {Érr¡ly thirt tl¡is i:*

;r ntttr cn¡ry fr*rlr tltg resrrrcl. ilt ¡his cal¡rt.\Vitlress tlre hand ¡nct act oft thc utrrhrsignrd

úús *ffi,,lit¡,,t*Htul* lrt lUd

./.,,\'¡"'¡r*x,J/.ç¿

,fi"

: CLtìi't. {t,; Ieiltimore City, Ma:ylandE 000377

CIRCUIT COURT FOR BAI,TIMORE CTTYMarilYn BentleY

Clerk of the Circuit CourtCourthouse East

111 North Calvert StreetRoom 462

Baltimore, MD 2I2A2-(4r0)-333-3722, TTY for Deaf: (410)-333-4389

os/08/r7

Al-ternative Medicine Maryland,

Case Number: 24-C-16-005801 OG D,J

Date Filed: 10 /zt/zotaStatus: OPen/Inactive,Judge Assigned: Wil-l-iams, Barry G.Location :

CTS Start : Io/3L/r6 Target : 04/29/LBLLC Vs Natalie M. Laprade Maryland Medi

Descrìpti0n

Mail: 14 Stale CircleAnnapolis, MD 2).401

At.torney; 0008326 Pìc¿, John A

Royston, Muel I er, Mclean & Reì d ' l..LP

102 l..l PennsYlva.nia Avenue

1.02 ll PennsY l vani a Ave , S

Suite 600, t'lD ?.1204-4510( 4i0 ) 823- 1800

0008964 Brown, Brian S

Brown & Ba¡'¡ on Ll-C

7 Sl. Paul SlneetSuìte 800

CÀSE HISTORY

OTHÉR REFERENCE NIJMBERS

Number

10/31 / 16

Case Folder iD c16005801V04

T}WOLVED PARTIES

Type Num Name(Last,First,Mjd.Title) Addr Str/tnd i|;,^ i;å:r"

[ntered

PLT 001 Alternative l'ledicine Maryland, LLC i0/31/16

Party ID: 5260349

i1/01i 16 AA{'l

Appear: l0/31 /201 6 1t/0.t/16

Appear^: 03/16/2077 c3/20/77

E 000378

2,4-C-16-005801- 05 / og / 77 Time : 11 :28 Page; 2

Beltimore. l4D

Gr0)547 -0202

0012294 l¡larnken, Byron L

l^larnken, LLC

2 Reservior CircleSuite 104

Pìkesvílle, MD 27248( 443 ) 921 - 1100

Appear: 10/31/2016 1 1/01/16

Type Num Nûme(Last.Fjrst,t{ìd,Title) Addr str/tnd Pty. Dìsp. [nteredAddr Update

DËf- 001 Nalðlie M. Laprade l'laryland Medical Cannabis Commission 10/31/16

Party ID:5260350

Date:

21202

Capacìty : ClO The NalalÌe M. laPr¿de

Maìì I l'4aryìand Medical Cannabis Comrriissìon

4201 PaLterson Avenue

Ba I ti more , l'40 21215

fli:F 004 Broccol i no, Dario, [sq.

Attorney: 0823322 Nelson. Heather B

" Attonney General's Offìce300 l¡J Preston StreetSuite 302

Baltimore. MD 2120I

u1"0)767 -1546

n:o 002 Maryland Department 0f Health And Mentar f::iiir, s260351

Mail: 200 Saint Paul Street 10/31/161r'. Baltimore. M0 21202

Serve 0n: Brian E. Frosh, Attorney Genenaì

.i.;, Màj l: 200 Saint Paul Place 10/31/16

Baltìmore, MD 21202

" Serve 0n: Brian E. Frosh, Atlorney General

Attorney:;, A8n322 Nelson, Heather B

' Attorney General's Office300 l,l Preston StreetSuite 302

Baltimore, i-10 2I20I

Ø70)767 -7546

Dï:i 003 Davies, Paul 1..l.. M.D'

Appear: I2lI4l2A16

Appear: 72/1412016

P¿rty ID: 5260353

r0/3r/1.6

11/01/16 AAt,{

ar/06/17

i0/31/16

11101/16 AA|/

0I/a6/r7

10/ 311 16

11/01/16 AAbl

¡i

Capacity : C/0 The Natalie f4. l-aPrade

Panty ID: 526C354

10t3U16

E 000379

21-C-16-005801 Date: Os/oT/t1 Time: 11:28 Page: 3

Maìl: Maryland l'ledical Cannabìs Conrmissiort 10/31/16 11/01/16 AAì'l

4201 Patterson Avenue

Saltimor"e, MD 2L215

Type Num Name(Last,Finst,Mid,Tltle) Addr Str/tnd Pty' Disp' tntered

Addr Updôte

DIF 005 Charles, Pharm.D. , hlill iam C. 10/31116

Party ID: 5260356

nt!: 006 Chen. Kevi n l',l. , Ph , D

Capacìty : C/0 The Natalie M. LaPrade

f4ail¡ Maryland Medical Cannabìs Con¡ission


Baltimore, MD 2I2L5

[tEr 007 Gontrum, John T., Esq.

Capacity : C/0 The Natal ie M. LaPrade

l"laìì.: Maryland Medìcal Cannabis Cünmissi0n

4201 Patterson Avenuen. Balt.imore, l.4D 27215

DEF 008 Gouin-Paul. Cnistìnô

Capacity : C/0 The Natalìe M. LaPrade

l4a jlt l-laryland l"ledical Cannabis Cornmìssion


Baltìmor"e, MD 2I?I5

Capacity : ClO The Nataiie l'1. LaPr"ade

t4ail: Manyland Medical Cannabis Cotn¡nissi0n


Baltìmore, t4D 21215

r0/31176

Party ID:5260357

1 0/31/16

Party ID:5260358

r0/3UL6

Pariy ID:5260360

t0t3r/16

FIDSA, |4ichael A.

Party ID: 5260362

1t/01/16 AAl,l

10 / 31/ 16

11/01/16 Mhi

10/31 / 16

11/01/16 AAtl

10/31.116

11/01/16 Mbl

10/3i / 16

11/0i116 AAl.¿

r0131"116

DtF 009 llor"ber"g, }4.D. , |'tAS, FACP

i''Ìa i I

Capacity : C/0 The Natalie 14. LaPrade

Maryiand Medic¿l Cannabis Ccmmissicn


Balt.ìmore, MD 27215

I 0/31/16

Part.y ID: 5260364

rli:i: Cl0 L.¡vin, Robel'r 4,,l'1 .0.

Capac i [y : C/0 Tho Nala I ie l'1 LaPr'ôde

Ma iI : l*lar.yl and l.ledica'i Cannebi s Commì ssion I0l3I/164201 P¿Lterson Avenue

11/0r/16 AAl,l

E 000380

24-C- l-6-005801 Date:

Baltimore. MD 21215

Type Num Namo(Lasl,First,þlid,Tit'le)

iflÉi- 011. Marshal I , Jean Gi ìmor, R.N.

05/0 I / I7 Tíme : l1 :28

Addr Str/[nd

Page: 4

Ply. Disp.Addr Update

Entered

Party ID: 5260366

10137/16

Party ID: 5260367

1013i /16

Party ID:5260368

Party ID: 5260369

Party lD: 5260370

Party ID: 5260371

n/31/16

i1/01/16 AAI¡

10/31/ 16

11/01/16 AAl^,

1.0/3u16

11/01/16 AAt¡

i0/31 / 16

11/01/16 MW

r0/3r/16

11/01/16 AAr¡l

r0/3u16

Capacity : C/0 The Nalalie l"l. LaPradeitiaìi : Maryland Medìcal Cannobis Cornmissìon


Baltimore, f"l0 2I2I5

D[F 012 t¡lashi ngton, Saundra

Capac]ty : C/0 The Natalie M. LaPra'le

Mailr l'1aryland l,ledìcal Cannabjs Conrnìssion


" Baì linnre. MD 21215

i;';; lr.

Df i: í113 l4oore. Shannon K '

Capacìty : C/0 The Nalalje M. l-aPnade

14¿ i j,: i'4aryl and l"1edi cal Cannabi s Conrmi ssi on 10/3I/16


i Baltimore, }40 2l?15

DfF 014 Robshaw, Colonel HarrY, III

Capacity : C/0 The Natal'ie M. LaPracle

Hai1,l Maryìand Medical Cannabis Commissìon 10/31/16


Baltìmore, MD 2I2I5

lliF '015 Rosen-Cohen, Nancy, Ph.D

CapaciLy : C/0 The Natalie M. L.aPrade

i4ai j: |"]aryland Medìca1 Cannabis Conm'ission 10/3i/164201 Patterson Avenue

Êaltimore, MD 2\215

DIF 0:.6 Sterling, trìc E., tsq

Côpacily : C/0 The Natalie M LaPrade

l"lai I : Maryiand l4edìcal Cannabis Cornmiss'ion 10/31/16

4201 Pdtterson Avenue

B¡ I ti more , lulD 2f 215

I t./ 01 / 16 AAt,¡

E 000381

''2:4-C-16-005801 Date: 05 /08/L7 Time: l-1:28 Page: 5

Type'Num Name(l-ast,First,Mid,Title) Addr St,r/tnd Pi.y. Disp. Entered

Addr Update

DEF 017 Tayl or", Al I i son l,l. I0/3Ilt6Party ID: 526A372

Capacìty : CiO The Natalie M. LaPr"ade

l,4ail : l".laryland Med.ical Cannobis Cormission

420L Pattenson Avenue

Baltimore, MD 21215

Dtf 018 Traunfeld, Jon, M.S,

Cöpacity : ClO The Nalal.ie M. LaPrade

. Mail: tlaryland Medical Cannabis Conunission:l.i -'(:, - . ¿Aot patterson Avenue

BalIinore. MD 23.215'ì',¡l:* 'i

INT 001 Holistìc Industries, LLC

L0/3r/16

Party ID: 5260373

r0/31/16

Party lD: 5295780

i1/01/16 Mlll

10/31 /16

11/01/i6 AAtl

07/2sl17

01./27 /17

0r/27 /r7

0L/27 /77

0t/27 lLl

Attorney; 0012751 Marcus, Bruce L

MarcusBonsjb, L L C

6411 lvy Lane

Suite 116

Greenbelt, MD 20770( 301 ) 441 - 3000

0022799 Jones, Gany R

Baxter, Baker, S'idle, Conn & Jones, P A

120 E Baltimore StreetSuite 2100

Baltimore, MD 21202-1643(410)230-3800

0816717 Vnanian, Danielle M

Baxter, Baker, Sidle. Conn & Jones PA

120 East Baltinnre StreetSuite 210C

Balt'ìnpne, HD 2120?(410 ) 230-3800

0820837 Patterson, Sydney M

Law Office 0f l'.larcusBonslb, LLC

6411 Ivy Lane

Suite 116

Greenbelt, l''10 20/70( 30i ) 441 -3000

Appear: 0I/25/2017

Appear: AU25l2017

Appeanr 01/2512017

Appear: 0I/25/2017

1Nî 0û2 Doe. JaneParty ID: 5299903

02/08/r7

E 000382

24-C-16-005801 Date: 05 /oa/Ú Time:

Attr:rney:. 0814637 Berman, Michael D

Rifkin, hieiner, Livingston' Levìtan & Silver2002 Clìpper Park Road

Suite 108

Ba.ltimore. MD 2I27I(410 ) 206-5049

]-l.:28

a2/0812017

Appearr 02108/2017

LLC

Appear: A2/08/2017

Levitan & Silver, LLC

Page

02/08lrl

02/08117

02/08117

02/08/17

02t08t17

02/0Bl17

02108117

t)? / 0B/L7

6

Attorney; û814637 Berman. Michael D Appeôn

Rifkin. hle'iner, L'ivingston, Levitan & Silver. LLC

2A02 C1 ipper Park Roaci

Suìte 108

Bal bimore, |'1D 272LI(410)206- 5049

.i.'yr;e: ,\u¡:r Name(Last,Fìrst,Mìd,Title) Addr Str/tnd Pty' Disp' tntered

" Addr UPdate

auaSl17INI 003 Doe. JohnParty ID: 5299904

INT 004 The Coalition Fon Patìent Medicinal Access' LLC

Party ID: 5299909

Attorne:yr 0814637 Berman, Mjchael D Appear: 02/0812017

Ri fki n, l,,leÌ ner, L ivì ngsLon.' Levi Lan & Sì I ver, LLÇ

. 2002 Cì-ipper Park Road

Suite 108

Baltimore, MD 21'2L1'

' (410)206-5049

If{I 005 Cur io Cultìvation LLC

Party ID: 5299911

Attorney: 0814637 Berman, Michael D Appeðri AU08/2077

R¡fkin, l¡leiner. Lìvjngston, Levitan & Silver' LLC

2002 Cìipper Park Road

Suite 108

Baltimore, i'4D 2I27I( 4r0 ) 206- 5049

INT 006 ForwardGro LLC

Party I0: 5299913

Attorney 0814637 Berman, l.lichael D

Ri f ki n, l¡iei ner, L j vì nçlston

20A2 Cl ipper Park Road

Suite 108

Baltìmore. MD 21271(410)205.5049

iNI 0û7 Duciors 0rders f4ar.ylond LLC

Party ID: 52999L4

02/ 0€t/ 17

E 000383

24-C-16-005801 Date: 05 /Oa/n Time

Àppea rLtc

]-7:28

02 / aB/ 2011

Text SA Jds Day 0f Notice Usen ID

Rec

Page:

02t0Bl17

auaE/û

1

Atlorneyr 0814637 Bermôn, Michael D

Ri fki n , We'i ner , Li vi ngston , Lev'itan & Si l ver

2002 Cljpper Park Road

Suite 108

Baltimore, MD 2I2II(410)206-5049

Tyoe Num Name(L.ast,F.irst,Mid.Title) Addr Str/Ênd P1.y. Djsp. Entered

Addr UpdaLe

INT 008 SunMed Grou¡ers, LLC 02/AUI7

Part.y ID:5299915

Aì.t:orney:: 0814637 Berman, Michael D Appear: 02/AU2017

Rìfkin, l,{einer, Llv'ingston;, l-evitan & Silver' LLC

2002 Cììpper Park Road

iì., Suite logBaltìmore, l'1D 21211.

': (410)206-5049

CALEIIDAR EVENTS

02/21/17 02:00P 528 I'lotìon Hearing (Civìl) Y BGtd A1" /0I 02/10/17 DLI

Hel<l/Concluded 02/24/17 E B'Ililliaßs N

Dð iL, T ime Fac' .

.,,,:Resu.l t

,ltrÐ':t ASSlGtitD

fvent DescrìptìonResultDt By Result Judge

JIIDGE HISTORY

Type Ass'jgn Dale Removal RSI'I

ùiìr¡1

4i li¡{

liilliamsl,]ìlliams

Barry G.

Banry G"

07t0s11.7

a2/a7 /I70r/06t11J

J

RR

DOCUMENT TRACKING

Num/Seq Descripticn Fìled tntered Party Jdg Rul ing Closed Usen ID

t0001000 Compìñjnt for^ Declaratory Judgment and 10i3il16 11/01/16 PLT001 TBA MhI

Preliminary and Permanent Injunct'ive Re-

Li ef wi Lh txhi bi t.s

00í1t1001 Answer to Complaint for Decla¡atory

J udçrnent

ß/ñl17 03t15l17 DtF001 TBA Pl4l Pl,l

E 000384

24-C-l-6-005801- Date: 05 /oA/fl Time : LL:,28 Page

Fìled by DËF001-Natalie M. L.aprade Maryland l'4edical C¿nnaLiìs

Comnissìon, OtF002-Maryìand Department 0f Health Ancl Menla.l

Hyg i ene

Num/Seq Descriptìon Filed [ntered Par[y Jclg Rullng closed user ID

00002û00 Return of Service - Served 17114/16 11128/16 DtF005 TBA Moot LIl28/16 LAH LAH

WRIT'0f SU$'10NS (Prìvate Process) served 11/04i16

I

000ò3000 Retunn of Servìce - Served I7/14/i6 ll/28/16 DËF016 TBA Moot

l,lRIT 0F SUMM0NS (Prìvate Pr"ocess) served 11/04/16

00004000 Return of Service - Served 11114176 Il/28/16 DtF018 IBA Moot

hIRIT 0F SUl'lt"lONS (Private Process) served ll/04/16

00û05000 Return of Service - Served 7I/!4/16 17128/16 DtF017 fBA Moot':ì,'';' " I,JRIT 0F SU|'1|.4ONS (Private Process) served 11104/16

00006000 Return of Service - Served II/28/16 11128116 DEF015 TBA l'{oot

hJRII 0F SUi4MONS (Private Process) served 11/04/16

0000/000 Return of Service - Served 11174/16 11./28/1'6 DtF014 TBA Moot

tJRtT 0F SUi,1|"1ONS (Private Process) served 11/04/16

00008000 Return of Service - Served 11'/L4116 1I/28/)'6 DtF003 TBA Moot

!,lRIÌ 0F SU|4MONS (Privôle Process) served 11/04/16

00Ö09000 Return of Service - Served 11114/16 Il/28/16 DEF004 TBA Moot

HRIT 0F SUMM0NS (Private Process) served 11/04/16

0d0d000 Return of Service - Served Ii/I4/7€' IL/281'16 DtF010 TBA Moot

hIRIT 0F SU¡{MONS (Private Process) served 11/04/16

OO0iIOOO Return of Service - Serverl Ll/I4ll6 71128/16 DtF002 TBA Moot

I l,lRIT 0F SUMMONS (Private Process) served 11/04/16

000].2000 Return of Senvice - Served 11/14116 71128/16 Dt¡001 TBA l4oot

I,JRIT 0l- SUI'|}4ONS (Private Process) served 11/04/16

00013000 Return of Serv'ice - Ser"ved 1l/74116 71/28/ i.6 DEF007 TBA I'loot'

bIRIT 0F SUMM0NS (Private Process) served 111G4/16

00014000 Return of Service - Served lI/14/16 1I/28/f6 DtË008 IBA Moot

l¡IRIT 0F SUI'11'|0NS (Private Process) served l1/04i16

000li5000 Return of Service - Served 11/74/16 17l?8/16 DtF0ll TBA Moot

TJRIT 0F SUMM0NS (Private Process) senved ']1104/16

110016000 Return of Service - Served ILl74l76 i1/28/16 Ûtf009 I'BA l400t

hJRIT 0F SUMI'1ONS (Prìvale Prccess) selved 11/04/16

00ù1,7000 Return of Servìce - Served 1I/74/16 Ii/29/I6 DtF012 TB¡\ l4oot

l¡lRlT 0F St Ml'i0NS (Private Process) served 11i 04i 16

T1/28/T6 LAH LAH

IT/?81T6 LAH LAH

11,/28/16 LAH LAll

1.r/28/76 LAH LAll

1.1128/T6 LAH LAH

LLI28/16 LAH LAH

TI/28/1,6 LAH LAH

TL/28116 LAH LAH

1112811.6 LAH LAH

lll28lt6 LAH LAH,

T1,/28/T6 LAH LAII

1T/28/16 LAH LAH

lII2BI16 LAH LAH

TL128I16 LAH LAH

11t28/16 i'AH LAH

E 000385

24-C-16-'005801 Date: 05 /oe/Ú Time: 11:28 Page:

Filed [rrlered Parl;y Jclg Ruìing Closed User I0

:T:i::: :::::t::t::00qi8000 ReLurn of Service - Served 71114/!6 11128/16 DtF013 TBA Moot

I,JRIT 0F Sillu1M0NS (Prìvate Process) served 11/04i16

1T/28,T6 I.AH LAH

00019000 Return of Service - Served IL/14/i6 11/28/16 DtF006 ÏBA Moot

l,.lRII 0F SUM}4ONS (Pr"ìvate Pnocess) served 11/04i16

11/28/T6 I.AH LAH

t

0002.0000 Notice of Service of Discoveny Material 12/051L6 17107/16 PLT001 TBA Pl^J

o

00û?1000 Defendants' l{otion to Dismiss, or in lhe 12/12/76 l2/14/L6 DtF001 BGIJ Denied

alternative, MoL'ion for Sunlmat'Y

Judgment, l4emonandum, txhibitsFiled by lltF001-Natalie M. Laprade Maryìand fledical Cannabis

Coilmission, DtF0O2-l4aryland lJeparbment 0f Health And Mental

HYqì ene

0002100r cpposìrion To Del'endarrls' Motion To 12/30/16 úlA3/Ú PlT001 TBA

ì ¡ Dismiss, 0r In the Alternative, Motion For

Surmnry Judgment, hJit.h txhibjls And Request For Hearing

00021.002 supplernerrr to 0pposiLion to Defendants' 02/17/17 02/21/77 PLT001 TBA

Motion to Dismìss, or in the alternative,!,":; llotìon for Summary Judgment, txhibits

C0021003 0rder of Court 02/23/17 0?/23/17 00A BGl,l

,':''..:; ORDERED that the Defts' Molion bo Dismìss, or in the Alternative,for Summary Judgment (Pleading No. 21) ìs her"eby DINIED.

i' ,,i'. . ìnlil l ì anìs , B. Judge

00021004 Copies l''ta i led 02/23/17 0?l23lr7 000 ÏBA

00022000 Line to sunpìement 1?/23/16 1?/27/1,6 D[F001 TBA Moot

Ëiìed by DtF001-Naialie Þ.l. Laprade Maryland Medical Cannabìs

Conmission, DtF002-Maryland Department 0f Health And Mental

Hyg i ene

00024000 Motion To Intervene, l^JìLh txhìbits And 12/30/).6 01/03117 000

Memorandum (Entry 0f Appearonce Atlachedi,, .,, But r,rot Entered)

BGtl Denied

00024001 Request for Hear'ìng on Seìec[ûd MoLj0n 12/30/16 01/03/17 000 TBA

üÐ024002 Resp6nse T0 Molion To Intervene 0I/051I7 AU06l\7 D[F0Q] ÏBA' Fì led by DIF00] -Natalie 1"1. L.apracle l{aryìand þledical Cannabjs

Commission, DtF002-Maryland Department 0f lleaìth And Mental

Hygi ene

00024003 IntenvenìnE tlelenclanls ljne ai/I2/17 0l/13/17 000 ÏBA

Si-rpir'ìenrent.irtg Mcticrr To Inî.ervene.'ilìth 0b¡ectìon.' And Ruìe ?-504 Requesl Frtr Scherhil ing Conference, l¡lith [.xhibits

And Request For lleat"ìng

02/21/17 HK DG

DG

12/27 /76 rP

02l2IlI7 l\S DG

AS AS

AS

HK

DG

A)

AS AS

E 000386

24-c*16-005801 Date: 05/08/L] Time: l-1:28

lrl¿mlSeq Descr.iption Fjled Entered Party Jdg Ruling Closed User ID

,-^:¿----;.,--*Ò0024004 Oppositioìl t0 motion to intervene. 01./05/17 A2/02/17 Pt-T001

'lBA VT VT

memorandum of law and req for hearing

Page: 10

AS

00024ù05 Reply in support of motion t0 intervene 0I/n/I7 02/02117 040

filecl by proposed defs

02t23/r7 02123/17 A00

12/30/16 01/03/17 000

TBA

ÏBA

DGì*l Deni ed

VT

DG,00024006 0rder of Court 02/23/77 02123/17 000 BGllJ

0RD[R[D, that the Proposed Jntervening Defts' Motion to Intervene(Pieadinq No. 24) 1s hereby DENItD, hlilljams, B. Jttdge

00024007 Copies Maìled 02/23/17 t2/23/17 000

12/30/16 01/03/17 00000025000 l,lotion For Speciaìly Assìgn, l,lìthMemorandum

00025001 Initial Response To Motion To Specìal1y A1./05/17 0I106/17 DtF001 ÏBA

,. t],.r,ì, AsSign

' Filed by DEF00l-Natalìe l\4. l-aprade l4aryland Medical Cannabis; ;ì rr' Commìssion, DtF002-Maryland Department 0f Health And Menlal

Hygi ene

00026000 Motion to Consolìdate, l¡lith Memorandum 12/301L6 01/03/17 000 BGl,.l Denied

00026001 lnitjal Response To Consolidate 01105/17 07106/17 DEF001 TBA

Filed by DEF001-Natalìe M. Laprade Maryìand Med"ical Cannabis

Commissjon, DtF002-Maryland Deparlmerrt 0f Health And Ì4ental

Hygi ene

00026002 0rder of Court 02/23/77 02/23117 004 BGhl

0RDtRfD, that the Proposed intervening Defts' Motion to,.,;, Consolidate (Pleading No. 26 & 40) ìs hereby Denied, !'Ji'llìams, B.

Judge

TBA

tB^

DO

AS

AS

ri0{126003 copies Mai led

00027000 Motion to llismiss This Action, l¡Jith

Memorandum

00c2ìi001 Request for Hcaring on Sclccted Motion 12/30/16 01/03/17 000 IBA

00027002 lniiiôl Response To lulot.ion To Dismiss M/A5/71 0UA6/17 DFfOCi TBA

The Actiontiled by DËF001-Natalie i"l. Laprade l4aryland Medical Cannabis

Con:mission, Dt[002-Maryland DeparLment. 0f l-lealth And Mental

l-¡yg iene

00027003 Order oí Cour[ 02/23/T7 0212U17 AA0 BG!'l

ORDIRED, that lhc Proposed lntenvening Defls' Motictl t.o lJismiss

(Pl eadi nq No. 27 & 39) i s hereby llENI tD a.s moot , l'li l ìj ams B

Judge

A2/2I/T7 AS DG

AS

OG

DG

O2/2I/T7 AS DG

AS

AS

Utl

E 000387

24-C-16-005801 Date: 05 /OA/Ú Time: 11:28 Page:

Nurn/Seq llescrìptìon Flled tntered Party Jdg Ruling Closed Usen ID

'-é¿

ûq------

11

00027004 Copies Mailed 02/23t77 02t2yr7 a00 TBA

72/30/i6 ülAU17 PlT001 ÏBA

01/03/17 0l/04/17 000 TBA

00028000 Designatjon of [xpert l'rJitnesses

Ncll)2gOO(J SUPPLTMTNTAL CTRTIF]CATT OF STRVICI

FILT BY PROPOSTD INTIRVTNING DTFTS

,JÎl'IflOOO LiNI FILTD BY PROPOSED INTTRVÊ:NING

D[FTS

0I/03117 01/04/17 000 TBA Moot

00031000 ATYENDID ENTRY 0F APPTARANCT 0f ATTYS'

FOR PROPOSTD INTTRVENI16 DTFTNDANTS

AND RIDL]NTD

0I/03/77 01/04/17 000 TBA Moot

OOO32OOO HOT]ON TO SPTCIALLY ASS]GN AND REDL]NTD C.II03/17 OIi04l17 OOO

FILID BY PROPOSTO INTIRVTNING DTFTS I,IIIH A RTQUTST FOR HTARING

OOO32OO1 RIPLY IN SUPPORT OF MOTION 'iO SPTCIAI-LY OI/71/L7 A1'/171T7 OOO

ASSIGN

IXHTBITS AND RËQUTST HEARINO FILTt) BY THT PROPOSTD ]NTTRVENING

TBA

TBA

$01133000 Cornespondence To the Judge 0U05/17 0L/06/17 PLT001 TBA

al/aglfi 01/10117 PLl001 TBA

01/r2t17 01/13/17 000 TBA

0r/1.2/17 01/1.3/17 000 TBA

0llÍt34000 Not'ice of Service of Discovery Material,;l.rtì¡,,

iì11-?5000 lntervening Defendants' Correspondence

To Judge Pierson

00036000 Inter"vening Defendants' Cornespondence

To Judge hli IIiams

0r/?5/77 0L/77l\7 IN1001 TBA

[xhibìts 0\125/17 0I131117 INT001 BG|/l Denìed

DG

AS

BLB

01/04/17 BLB

01./O4IT7 BLB BLB

BLB VT

BLB VT

AS

M|l

02/2ï/t7 BLB DG

U'.1

AS

KLF

AS

A)

00037000 tntry of Appearance

00038000 Mot.ion tc lntervene l'lemorandum

and Request HearÍng

00038001 Opposit'ion bo Propcsed Intervenor A2.i\gl17 02/I0lI7 PLT001 TBA

Hol'istÌc Indusbies. LLC's liotion to lntervene

and Rec1uesl. for Hearìngl.l í¡ ¡;";..

,,101-18002 0rder of Court 0?"/?-3/17 021?3/17 000 BGl,¡

a ijijj'' ORDrRID, that the Prcposed In'rer"ven ing Defl's l"10tiorì Lo Iniervene(Pleadinq No. 3B) is hereby Denied. l'JiIIiâms. B , Jutìge

00C:ì8003 Copies Maìled A2123117 02/?3/77 C1A TBA

ûmiì'!r000 Moti0n to Disrniss w/redlineci copy, ¡1i03/77 02/A2/Ú AA0

memcln¡ndilm ônd necl for he,rrìng frìr'td by

proposed inlervening clels*** PLTAST STT ENTRY IIZi13 IOR ORûIR Of: COURT ***

HK

DG

BGI¡J llen ied 02/21./17 Ur DG

E 000388

2,4,-C-16-005801 Date: 05/OA/n

¡,tl:r/Seq Descri ptì on Fì I ed

Time: 11:28

En'lered Parly Jdg Rul ing

Page

Closed User ID

72

.!:1i.L -.: - -

rlC{1.10C00 Motion to Consclìclate w/redlined copy, AI/A3/û 02/02/17 00A BGl,/ Denied 02/27/17 Uf DG

mernorandum and ned for hearing

" filed by ¡:roposed intervening parties**** PLEASE S[[ INTRY #26/2 TOR OROER OF COURT ****

'0q:41OOOt Reply ìn support of motion to 07111/17 02/a2lÛ 0a0

consoljtiate w/req for hearjng filed by proposed'intervening pôrties

¡ûii4l rili)

nni,nr*ou,i,,.i: '

-..1 ,t,r l;'

i)'".:;i:l|j3û

TBA

Suppìemental Motìon to Consoljdat.e 02106117 02/A8/I7 INT003 TBA

Filed by INT003-Doe, INT002-Doe, INT001-Holistic Industries, LLC,

INT00B-SunMed Growers, LLC, INT004-The Coalìtìon For PatientMedicinal Access, Ll-C, INT005-Curio Cultivation LLC,

INT006-ForwardGrô LLC. iN1007-Doctors Orders l4aryland LLC

Onder of Court 0?108/17 A2/A8/I7 000 hll'lP

It is this 7th day of February 2017 Or"dered this case isspecìaìly assigned to Honorable Barry Nilliams for all furtherproceedìngs Pjerson, J

Notice Motion Hearing Sent 02/10/17 02/10/17 000 TBA Moot

Event: l'40TN Block Date: A2/21,/17 Facility: 528

PARTITS:

Nelson, Heather 300 l^l Preston Street Suite 302, Baltìmore, l'lD'

21201

Davies. P¿ul Mar.yland fledical Cannabis Cornl[ission 4201 PaILerson

Avenue. Baltimore, Ytt. 27215

Broccoljno, Darìo Maryland Medical Cannabìs Conmission 4201

Pattenson Avenue, Baltimore, MD, 21215

Charles, Pharm.D., lÎill iarn I'laryland |4edica.ì Cannabis Conunissiort

4201 Patterson Avenue, Baltimone. MD, 21215

Chen, Kevin Maryland l'ledical Cannabis Comm.jssion 4201 Pabterson

Avenue, Baltimore, MD, 21215

Gontnum, John l'4aryland Medical Cannabis Commìssion 4201 Patterson

Avenue, Baltìmore, f'1D, 212i5

Gouin-Paul. Cristina l'4aryland Medical Cannabis Commission 4201

Patterson Avenue, Saltinpre. MD, 21215

Hor-berg, M.D., l'44S. FACP, tlDSA, Michael l''laryland Medìcal

Cannabis Comm.ission 4201 Patterson Avenue, Ballimore, MD' 21215

Lavin, Robert Mar.yland Medical Cannabis Connìssìon 4201 Patterson

Avenue. Baltimore, l4D, 21215

l'lanshall, Jean itlaryland Medìcal Cann¿bìs Conrnli ssion 4201

Patterson Avenue, Baltìmore, MD, 21215

l.jashìngLon, Saundra Meryìand |4edìcal Cannabis Cornmission 4201

Patterson Avenue, Baitimore, l'4D, 21215

f''loore, Sharrnon Maryland Medjc¿l Cannabls Courmission 4201

Patterson Avenue. Baltimore. l'40, 21215

Robsiraw, Colonel Harr.y l4arylarld Medical Cannal¡is C<¡r¡mission 4201

Patterson Avenue, Baltimore, MD, 212i5

Rosen-Cohen, Naricy lfar^yland i'ledìcal C¿nnabis Comntíssjon 4201

Pdllerson Avenue, Ballimore, MD, 212i5

VT VT

VB VB

VT

02t70t17 DLl

E 000389

24-C-16-005801 Date: 05/08/11 Time: 7L228 Page: 13

l" ":

Slerling, är'ic Mar"yìand l'ledìcal Canrrabis Conrmission 4201

Patterson Avenue, Balt'imcre, llD, 21215

Taylor", A.llìson Manyland Medìcal Cannabis Commìssìon 4201

Patterson Avenue, Baltimore, l'lD, 21215

Traunfeld, Jon |4aryland i'{edical Cannabis Comnrission 4201

patterson Avenue, Baltìmore, MD. 21215

l"iarcus, Bruce 6411 lvy Lane Sujte 116, Greenbelt, MD, 20770

Patterson, Sydney 6411 lvy Lane Suìte 116, Greenbelt' l4D, 20770

Jones, Gany 120 Ë Baltimore StreeL Suite 2100' Baltimore. I'lD.

272021643

Vranian, Danielle 120 East Ballirnone Street Suite 2100,

Ba I ti more , VtD , 21202

Berman, Michael 2002 Clìpper Park Road Suite 108, Baltimore, MD

21211.

l,Jarnken. Byron 2 Reservior Circle Su]te 104, Pikesville, MD,

2T2OB

Pica, John 102 l'l Pennsylvaniô Avenue 102 H Pennsyìvania Ave, S,

suite 600, ¡4D, 212044510

I'lL¡r'liSeq Descript'ion Filed tntered Party Jdg Ruling Closed Use¡" ID

00044000 Open Court Pnoceeding 0212I/L7 02/2I/I7 000 TBA l"lc tLJ

?-/2I/1.7 Defendants motion to ìntervene in Alternative l'ledicine

Maryland, LLC is hereby heard and "Denìed".(lrlilììams, J)2/2I/I7 Defendant,s motì0n to d.ismiss, or ìn the alternative forsunmary iudgment in Altennative Medjcìne lularyland Lt-C

'i s hereby heard and "Denied''. (l¡l.j ll.jams' J)

C0045000 Line with Affìdavits A2/21/17 02122/17 lNT003 TBA Moot

Filed by INT003-Doe, INT004-The Coalition For PabìenI Medicìnal

Access, LLC, 1NT005-Curio Cultivation LLC, INT002-Doe,

INT008-SunMed Growers, LLC

100,ì6000 Notice of Servjce of Discovery Materìal 03/I0/77 03/73/I7 PLT001 TBA

crl3,!70û0 Appeal 0rder to coSA 03/15/17 03116/17 INT002 TBA

I'i-:ir': Filed by INT002-Doe. INT003-Ooe, INT004-The Coalition For Patjent

Medicinal Access, LLC, INT005-Curio Cultivation LLC'

. INT006-ForvardGro LLC, INT007'Doctors Orders l''laryland LLC,

INT008-Sr-rnMed Gro¡¡ers, I I C

00048000 Appeal 0rder r.o cÖSA 3116/17 03l|7ll7 INT0O] IBA

00Q/i4000 Not.ice of Service of Discovery I'laLer"i al 03/77 177 03120117 Pl.T001 l'BA

',r00f:c000 l\lotice Lo Enter Appearance 03/16/17 A3/20/17 PLT001 îBA

i:t,;' , ..,'

îf.rlìf,l 000 Qbjection To Subpoena For- Deposi lion 03/23/17 A3124/17 DEr:002 TBA

;¡fìiì'.')000 Amenrjed Appeaì 0r der to COSA A3/22 117 AU24/77 INT002 IBA

f:iled by INT002-Dr:e, iNT00-?-Doe, lN'|"004'The Coalition For Palienti.,'. " l4edicìnal Access, LLC, INT005 Curio Cu.ltivat.i0n iLC,

02/22/17 AAW

GI

W

l^JZ

til

AS

TP

N¿

E 000390

24-C-l-6-005801 Date: 05/08/L7 Time: 11¡28

INT006- ForwardGro t..l-C, I NT007 -Doctors Orclers l'1ar.y1 and LL C,

INI'008-SunMed Growers, LLC

,,,Nr'rrt/Seil Descr ipl ion Filed Ëntered PartY Jdg Ruling

Page: 14

C.l osed User i D

.r1il63000 Correspondence 03127117 A3128/17 A00

before Judge BarrY G. l¡¿i I l'Ìams

. Cost: $34,00

00056000 Court of Specìa'l Correspondence 04103117 04/05/Ú 400

' ', March 28, 2017 Civil Appeaì ìnformatìon Report Received forAppellant's Amended Notìce of Appeaì noled on March 22' 2017 '

This ìnf'ormation Report will be rnade a part. of the fi'le:.. previously establjshed for the appeal noted on March 15, 2017 and

the cross appeal noted March 16, 2017, all will be assigned No'

:. :'. 40 September Term, 2017

TBA

TBA

JT JT

|4KTBA

0f 0r-.:s000 Appeal Order to C0SA 03131/i7 03/31/1i 000 TBA

ORDTR TO PROCTTD NO. OOO4O STPTTMBIR TIRM, 2017, DUT MAY 30' 2017

ASSIGN TO J.FORTIJNI

JT

AS AS

AS

AS AS

BI

TP IP

JF

r-irr,lls7pOO l'lo.Lìon for Protective Order, with 04/1.7 /I7 04/78/17 D[F002 TBA

l''lemorandum

l::i.,¡,r. Filed by DËf-00I-Natalìe M. Laprade l'4aryland l4edical Cannab.i s

Commission, DEF002-t'laryland Oepartment 0f Health And Mental

. Hygìene

Flled by DEFO02-Maryìand Department 0f Health And Mental Hygìene,:j',ri::': DtF001-Natalie M. Laprade Maryland l'ledìcal Cannabis Commission

00û58000 Motion to Quash Subpoena for Deposìtion,04/77/17 C4/I8/I7 DtF001 TBA

with Mernorandunt' Filed by DtF001-Natalje M. L.aprade Maryland Medjcal Cannabis

Commission, DEFOO2-l4ar"yland Departrnent 0f Health And Mental

Hyç i ene

00059000 [mergency Motiçn to Shorten Tìnte for 04/\7/17 04/I8/i7 DtF002 TBA

Respons e

' Fì led by DtF002-Maryland Departmcnt 0f' Heall.h Antl l'lent¿l Hvgiene,

DtF001 Natalje M. Laprade l'laryland l"ledic.rl Cannahis Commiss'ìnn

îtiiifi0|O0 Notice of Servìce of Dìscovery Materìal 04118/17 04119/17 PLl001 IBA

r]lf¡iì1000 Aff.idavir of Servìce AS T0 A SUBPOËNA 0N 04/28ii7 05/01/17 000

SANDY HlLLMAN ON 4/20/17

TBA

1016200c Mct.ìon to compel and Requesl Fcr 051C1i1.7 05/A2/11 PLI001 TBA

l'learing, proposed ordcr.menr¡ and Ixhii;itsAttachet'l

ßt

00063000 Qbject.jon to Subpoenas for Depositìon 05/01/17 0ÚlCZlIT D[F002 TBA VB

E 000391

?,4,-C-t-6-005801j.i, | ,_

f ir:',i/i'rq iìç,'s¿i jpl itxr

os/08/L7

l.iIed

Time: 11:28

tntered Parly .Jdg Rulìng

Page

Closed User ID

Date 15

Of:OiaO00 l,lotice of Service of Discovery Materi¿l 05/A2/17 05/05/17 PLT001 TBA

,q0:j65000 Objecllon io Subpüenðs l"or <ieposilion 051()4117 05105/17 D[F001 IBA

Fìled by JtF001-Natalie M. Laprade l'4anyìand Medica'l Cannab'is

Co¡nmìssion, DtF002-llar.yland Departnrent 0f Health And Mental

Hyg i ene

00066000 Subpoena Issued 05/05/17 05/08/17 PtT001 TBA

IP

Pì¡l

GT

'ro"t¡ NaiÍtc

SERVICE

lssued Response Served Retunned Agency

iJf¿i,í 0F SWM(]NS (Private i:rocess) 11./01/1612104/76 I1'/44/ßi:r¿'di ¡¡utulie t1. i.-aprade Maryìand Med.ic

ù¡n iir.r6|.' suMiloNS (prì vate process)

il[ f :002 l'la ry] and Depa rtment 0f Hea ì th And

! ':'"

iruti' or su¡,li'40Ns ( pri vate Pr"ocess)

D[Ë003 l]avies, Paul

LI I 01, / 16 r2l t4 I 16 17 / 04 I 16

11 / 07/ ï6 12t 04 /76 11, / 04 / 1.6

l¡IRIT 0Ë SUl,li*lONS (Private Process)

D[F004 Broccolino, Dariot1. / 0r / 16 12/ 04 t 16 1I / 04 / 16

',¡¡RIT 0Ë SUMf40NS (Private Process)

DEF005 Chanles, Pharm.Ll., l^lilliamlii 01/16 12l04l16 11104/16

l.lll'l 0F SUMI1ONS (Prìvabe Procoss)

itir0.16 Chen. Kevi n

1li 01/16 rua4/r6 ï7/04116

f(.;T 0F SUMMCNS (Private Process)ilttr ri¡, nnnrrum, John

1il01/16 12 / 04 / 16 n/ A4/ 1.6

iln';.i fiF SUM|"10NS ( Pr i vate Process )

:Xs',q08 Gouin'Paul . trìslìna

ìiîii' ûF sul"1f,]û¡ls (Private Process)

)ËË0{i9 Horbers. l'1. D. . l1AS. I-ACP, i luSA

ú/01t16 72/04/16 11/04i 16

t1/01¡'16 L2/ 04 /16 Ir / t4 / 16

'lRi I 0F SUI'1|,IONS (Private Process)

D[i01Ð Lavin. Rcberl

ú / 0I / 16 72 / 04 / 16 li I t4 i'r6

ilRtT 0l- SUþ1¡ICNS (Private Fnocess)

)EFûi1. ¡larstiall . Jean

tr / 01 i 16. lu a4 / L6 n / a4 i i6

Pri vate Process

Private Process

Pri va L,e Process

Pri vate Process

Private Pnocess

Private Process

Pri vate Process

Private Process

Pri vôte Process

Pri vate Process

Fri \,,lte Process

ital-i ûl' sul'1l"l0Ns (Private Process)

ilfirl! 2 l.l¿lshìriglor. Saundra

Ili ¿

: "_. .:.

lçir' ¡

7r / 07 / 76 12 I 04 / 16 II I 04 I 16 Prìvate Process

E 000392

2î,, -C- 16 - 0 05I01

Form Name

os/08 /r1 Time r

issued Response Servcd

1"1:28

Retunned Agency

Date: Pagel. 16

l,lR i I 0F SUM|'{ONS ( Pri vate Process )a t.'D[Ft)13 Hoore, Shannon

t...hlRI ï 0Ë SUl',1|',1c}NS (Pri vate Process )

'lri.ctq Robshaw, Colonel Harry

lìitr'lt or SUMMONS (Pr'ìvate Process)

':-,.fÍj.'15 Rosen-Cohen, Nancy

i'1;: i'ì' 0f SLh4f40NS ( Pri vate Process )

firr-il.l 6 Ster'ì i ng, [ri c

IdRIT 0F SUM|40NS (Private Process)tìii:0-t,7 Tayl or" , Al I i son

''. ,:,

'IRIT 0F SUM|"jONS (Private Process)

DEF'O18 Trôunfeld, Jon

,!.,1llS lsl Ansrver Tickle 0PtN 03/15/17tÌf. r

:i¡iltllZO,Days Lack 0f Jur CANCEL 03107/17

t'¡riij 120 Days Lack 0f Jun CANCEL 03/07/17

1,1ì!-iV 120 Days Lack 0f Jur CANCEL 03/07/I7ii.i , :

l-,S?V'120 Days Lack 0f Jur CANCTL 03/07/I7

i:SRV 120 Days l.ack 0f Jur CANCTL 03/07/77

LSRV 120 0ays Lack 0f Jur CANCTL AU07/77

i S'iV 120 Days Lack 0f Jun CANCEL 03t07/17

r.SRrt 120 Da.ys Lack 0i'Jur CÀNCIL 03/07/17

ri:l¡i[ 120 Days Lack 0f Jur CANCIL. 03107/17

r:ìâr./ 120 Oays Lack 0f Jur CANCft.03/07 11.7

i\*;,i{rr 120 Da.ys Lack 0f Jur CAN0IL 03/07/17

r:':ti!t 12¡ Da'/s t¿ck 0f Jur CANCÉL 03/07/17

Lr I 0r I 76 \2/ A4 t $ 7r/ 04/ 16

11/01/16 r?/04 t16 r1/04/1ö

1i/0i116 1.U A4 / b rt / 04 / I{)

11/01/16 rzt 04 I 16 rr/ 04 / 16

11/01/16 12/ 04 / 76 l7 I 04 / 16

17/ 01 /L6 n/ A4 I 16 rU 04 / 16

Private Process

Private Process

Private Process

Pr"ivate Process

Private Pnocess

Privat,e Process

TICKLE

'eode Tìckle Name Status txpires #Days Autotxpile GoAhead tronr Type Num Seq

l,ii.:¡ --------

0

126

126

126

t26

126

12b

I?6

t26

L¿Ô

1)A

L26

r26

)'¿f)

DANS D

SMNS F'

SMNS F

sl4Ns l=

SMNS T

Sl,lNS F

S|'INS F

SMNS F

SÞ1NS F

SMNS F

SllNS t:

SI.INS F

SMNS Ë

SMNS F

1 001

0 000

c 00c

t 00c

0 000

0 000

0 000

0 000

0 c00

0 û00

0 000

0 000

0 000

0 000

n0

n0

no

no

il0

no

no

no

n0

no

no

n0

n0

no

n0

n0

n0

n0

n0

no

n0

n0

n0

n0

n0

no

rìrj

nùilriri l20 llays L¿ck 0f Jur CAl.lC[L ù3/07 /17

E 000393

24-C- l-6-005801- Date I 05/08/r 7 Time: l1:28 Page: I7

{..cCç

.- Jr.,

: lfrv:...-r.: i ,

i.1ìlì\i

i..,: Iì ( nv

I S!:iV

I 5iìV

Tickle Name

120 Days Lack 0f Jur

120 Days Lack 0f Jur'




::ï:::" i::l:03tù7 tr7 126

03/07 /r7 126

03/07 /r7 1?6

03/07 /77 126

a3/a7/u 126

Status

CANCTL

CANCEL

CANCIL

CANCTL

CANCTT

AutoËxpine GoAhead From l'ype Num

no nc SI4NS F 0

no no S|'4NS F 0

no no SMNS l- 0

no no SMNS F 0

nono0

Seq

000

000

000

000

000

Sl f'!lì Set List For Motions

i:flit set List For' Motions

::j,i'.'Îi Set List For" Motions

l1l$i Motion To Extend/Sho

Sl llR Set List - Discoveny CANCTL 05/A8/I7

SL.DR Set List - Discovery 0PEN A5/22/17

Sl.l.lH Set List For l4otions CANCTL 01i04/1i

tli'{i Set List For l"lotìons CANCTL 01/20/17..l

2I no

2I no

5no

21 .yes

21 yes

39 yes

43 yes

1 yes

1 yes

Loca I i on

Room 462 Courthouse [astRoom 462 Counthouse [ast.lìoom 462 Courthouse [astRoom 4í:2 Courl-house tast

CANCEt.

CANCEt.

CANCTL

cANCfl

01.t20t17

01./20/1.7

02/15/17

t2t37t16

MPRT D

MCOP D

DHRR D

|4OPH D

}4CON D

DHRR T

I4OPH D

DSPC D

MTST I')

57 000

62 000

24 001

?7 000

26 000

21 000

32 000

25 000

59 000

n0

n0

n0

n0

n0

n0

n0

n0IlfÍ |4otion To Extend/Sho CANCEL 04/18/17

a.¿ i*t

1)

2)

3)

4)

5)

DTFFERENTIATED CASE I'TATVAGEMENT

TRACKS AND MILESTONES

PUBT,IC NOTE TITLES

I/17/I7 #321i SENT TO JUDGI BARRY I,']ILLIAMN FILE IS WITH HII4

I/I7/17 #24/3,35 & 36 SËNT TO JUDGT BARRY I,'ILLA|\,IS [II.I IS

CLTRK NOTIS ?!23/77 PLIADINGS HAND DttlVÊRID T0 JUOGI !'IILLIA]4S

Arrswer ül Conpl a inl for Der'iara l-ury Judgment

Clerk Notes 4l?-6/17. Pleadìngs 57, 58, & 59 Sent To Judge ljilliams

CÀSE FOTJDER HTSTORY

í)atc Time Type User Cl e¡"k Reason

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E 000394

EXHTBIT 3

E 000395

EXHIBIT 3

E 000395

AL:I]ERNATIVE MËDICINEMARYLAND, LLC

Plaíntffi

NA]ALIE M. L,APRÄDE MARYLANDMËDICAL CANNABI S COMMISSION.el ul,,

Defendanls,

*

{r IN THE

CIRCUIl'COURT

* IIOR

* I]ALT]MORIi CI]'Y

* Case No.; 24-C-ló-005801

* ,1. r¡i¡ ,t * **f t

ATI'IDÄVIT TF'COMMISSIONER COL. HARRY ROBSHAW, TII

1 . I am over I I years of agc, a rcsìclcnr of Maryland, competent to testify, ancl have

pörsonal knowledge ot'tl¡e facts set forth herein.

2. I am a Commissioner of the Natalie M. LaPrade Maryland Me<ticnl Cannabis

Co¡nmission ("Commission").

3. On July 12,2016, the Commissio¡r voted to adopt a (irorver Evaluatio¡r Cuidance

("Guidance") document to support Commissione¡s' efl'orts in the review process. T'he

Guidance, atlached hereto, advised conrmissiorìers as to the information available fbr

them to consider, and guidcd Comrnissioners on how to conform their review to current

regulations.

4. 'l'he Guidance did not indicate that Commissioners should consider race or

ethnicity as a scoring or ranking criteria.

5. On August 5,2016, the Commission met in open scssion to consider issuing pre-

approvals f'or medical cannabis grower and processor licenses.

E 000396

6. During that meeting, the Commission receivcd rccommendations flom the (jrower

Evaluation Subcommittee and the Processor lìvaluation Subcommittce and discussecl

those recommendations.

7 ' The Commission then voted on tlte Commission's raaking of the top 20 applicants

for a medical cannabis grower ticense and votecl to issue pre-approvals to the top l5

applicants, subject to satisf¡ctory examinations of good moralcharacter and compliance

wirh tax obligations.

I' At the August 5, 2016 meeting, the Commission also voted on a Commission

ranking of the top 30 ranked applicants for a medical cannabis processor license ancl

voted to issue immediate prc-approvals to the top l5 of those applicants, also subject to

satisfactory examinations of good moral character and compliance with tax obligations.

9. 'fhe Comnlission has not yet issued nny medical cannabjs grower licenses.

10. 'l'he Colnmission is continuing its rvork to seek to achievc racial and cthnic

diversity ând intends to retain a diversity consultanr to support these ef1orts.

I TTEREBV DECLARE OR AFFIRM UNDER THE PENALTIES OT PERJURYTHAT THE CONTENI'S OF THE FOREGOING AFFIDAVIT ARE TRUE ANDCORRECT BASED UPON MY PERSONAL KNOWLEDGE.

t2-tz- l bD¿tc Col. Flarry aw, I

E 000397

NATALIE M. LAPRADEMARYLAND MEDICAL CANNABISCOMMISSION, et al.,

+

)ß

{.

4{

*

IN THE

COURT OF SPECIAL APPEALS

Appellants, OF MARYLAND

September Term,2017

ALTERNATIVE MEDICINEMARYLAND, LLC, et al.,

No'

*' (Circuit Court for Baltirnore City

Appellees' * No .24-c-r6-oo5sol)

{. * {c 4( * tF * {< * * * t * {<,¡ * * *

ORDER

Upon consideration of Appellants' Motion for Immediate Stay of Circuit Court

ProceedingsPendingFurtherReview,itisonthis-dayof-

2017, by the Court of Special Appeals of Maryland,

ORDERED that Appellants' motion is GRANTED; and all proceedings in the

Circuit Court for Baltimore City in the matter of Alternative Medicíne Maryland, LLC v.

Natalie M. LaPrade Maryland Medícal Cannabis Commìssion, et al., No. 24-C-16-

005801) are hereby STAYED pending further order of this Court.

.IUDGE

V

11

E 000398

ALTERNA]'IVE MEDICINEM,/"\RYLAND,LLC

Plaintiff,

NA'I'AtlË M. LAPR¿\DE MARYLANDMEDICAL CANNABIS COMMISSION, e/ n/.

ïff,cou,il $*¡ti,F,Ê,,,*

+

'} FOR

ll

+

BALTIMOIIE CITY

Case No. : 24-C-i6-005801Juclge: Balry G: Williams

d.

* *t**+*fd<*'l''**

PLAINTIFF'S RESPONSE IN OPPOSITION TO DEtr'ENDA'NTS' MOTIONTO STITY CIRCUIT COURT PROCEITDINGS PBNDING FURTHER II'EVTE1il

ÀNDRtrOUIiST TOR HBARING

COMES NOW the Plaintiff, Alternative Medicine Maryland, LLC, b)' and through

counsel, Brian S. Brown, Clu'istopher'I". Casciano, Btotrn & Barron, LLC, Byron L' W'arnken,

Byro¡ B. Warnken, Warnken, LLC, John A. Fica, Jr., ancl John Pica and Associates, LLC, and

hereby r:esponds in opposition to Defenclants' M<ltion to Stay Circuit Court Proceedings Pending

Furf¡er Reviewa¡d appeal of this llonorable CouLt's May 3, 2017, discovery ordet, and in suppolt

tliereo:f, states as follol.vs:

IN,TRODgCTIOI'l

As I)efendants' Norice of' Appeal to the Court of Special Appeals of Maryland is

pîematurô, inrproper and moot, it stancls ln reason that Defendants' collateral Motion to Stay

Circuit Court proceeclings Pencling Further Rcvier.v must be summarily denied on the same

grourrds.

f)efenclants'interlocutory appeal, clatecì N4ay 8,2017, sought immediate and energency

revierv of, ancl relief from, this I-Tonorablc Court's MeLy 3,2017 discovely order clenying

Defbnclants' Motion for prolective Oxler. ¿incl otheru'isc precluding'Defèrrdants fì'om invoking

1

E 000399

vmckinley

Text Box

05/15/17

"either the deliberative process privilege or executive privilege to forestall the discovery of

information concerning the grower subcommittee's deliberations and selection process" during the

course of Commissioner Harry Robshaw's discovery deposition. InterestinglY, and despite the

purported urgency of Defendants' request for "immediate" reliefhere, Defendants' counsel elected

not to file a Motion to Shorten Time for Response with this Honorable Court, so as to effectuate

and obtain a prompt and timely ruling prior to the commencement of Commissioner Robshaw's

deposition, until after the completion of Commissioner Robshaw's Deposition.

At this late juncture, and now that Commissioner Robshaw's May 10, 2017 discovery

deposition has already transpired, the "further revie\ry" and "immediate" relief sought by

Defendants (i.e., aprotective order precluding Plaintifffrom compelling Commissioner Robshaw

to provide testimony concerning the deliberations underlying the Commission's discretionary

decisions)I, and the noted Appeal, is nowmoot. Essentially, Defendants are now asking this Cou¡t

for leave to undo something that cannot be undone.

Furthermore, Defendants' interlocutory appeal is categorically premature and improper.

Generally, appellate review must ordinarily await the enbry of a final judgment disposing of all

claims against the parties. However, the collateral order doctrine provides for a limited exception

to this general rule where, among other things, (a) the interlocutory order resolves an issue that is

completely separate from the merits of the action ancl (b) the issue would be effectively

unreviewable if the appeal had to await the entry of a final judgment. Here, the instant appeal fails

I Plaintiffasserts that the foundation of Defendants' Appeal, and the instant Motion to Stay Circuit

Court Proceedings Pending Further Review, is invalid as Defendants acknowledge that the

deliberative procãsr privilege only applies to the Commission's "discretionary decisions", as

opposed to ä mandátory lègislative directive. Therefore, because the Maryland Legislature

unätnUiguously required and mandated that the Commission "actively seek to achieve racial, ethnic

and geolgraphic diversity when licensing medical cannabis growers", a discretionary decision is

not ai isJue-here and the deliberative process privilege is not implicated in the first instance.

2

E 000400

to satisff these two critical requirements of the collateral order doctrine, and therefore, is an

impermissible interlocutory appeal-

Finally, should Defendants wish to pursue appellate review of this Honorable Court's

reasoned determination that they waived their right to assert either the deliberative process

privilege or executive privilege in connection with Commissioner Robshaw's discovery

deposition, they must now wait until the conclusion of the case, when final judgment is entered

because a determination that a party has waived a recognized privilege (whether it be a deliberative

process privilege, an attorney-client privilege, or the like) is not an exception to the general rule

that interlocutory orders are not immediately appealable'

For these reasons, as well as those detailed herein, Defendants' Motion to Stay Circuit

Court proceedings Pending Further Review is unnecessâry and moot, and therefore, must be

summarily denied.

ÞACKGROUND AND PROCEDURÄL POSTURE

ptaintiff, Alternative Medicine Maryland, LLC (hereinafter "AMM'), an aggrieved and

unsuccessfif applicant for one of the fifteen (15) medical cannabis grower licenses issued by the

Defendant, Maryland Medical Cannabis Commission (hereinafter "the Commission'), filed a

Complaint for Declaratory Judgment and for Preliminary and Permanent Injunctive Relief with

this Honorable Court on October 31,2016, asserting, among other things, that the Commission

acted contrary to its legislatively-mandated statutory directive to "actively seek to achieve racial

and ethnic diversity" in implementing and administering Maryland's Medical Cannabis Program,

and that the Commission's intentional and/or negligent failure to take the steps necessary to

affirmatively seek to achieve racial and ethnic diversity amongst the applicants and pre-approved

3

E 000401

medical cannabis licensees, contrary to its enabling statute, was illegal, arbitrary and/or capricious.

It is undisputed that the Commission did not comply with this legislative mandate.

On or about March 17,20L7, Plaintiff issued and served a Subpoena and Notice to Take

Deposition of Colonel Harry "Buddy" Robshaw, III, a Commissioner with, and Vice Chairman of,

the Maryland Medical Cannabis Commission, compelling Commissioner Robshaw to appear for

a discovery deposition on May 10,2017.

On April 77,2017,Defendants filed a Motion to Quash Subpoen4 a Motion for Protective

Order, and an Emergency Motion to Shorten Time for Response, wherein Defendants requested

that the subpoena for Commissioner Robshaw's discovery deposition be quashed, and that a

protective order be issued precluding Plaintifffrom compelling Commissioner Robshaw to provide

deposition testimony conceming the deliberations underlying the Commission's discretionary

decisions throughout the Medical Cannabis Program's application and licensing process.

On May 3,2017, this Honorable Court summarily denied Defendants' motions, and in

doing so, ordered that (a) Plaintiff be permitted to depose Commissioner Robshaw on May 10,

2017, and (b) during the course Commissioner Robshaw's discovery deposition, Defendants be

precluded from invoking the deliberative process privilege and/or executive privilege to forestall

the discovery of information conceming the grower subcommittee's deliberations and selection

process. (See Judge Williams' May 3,2017 Order, attached hereto as EXhibit l).

On May 8,2017 , Defendants filed a Notice of Appeal with the Court of Special Appeals

of Maryland seeking an interlocutory appeal ofthe May 3,2017 discovery order. (.See Defendants'

Notice of Appeal, attached hereto as Exhibit 2). Concurrent with their Notice of Appeal,

Defendants also filed the instant Motion to Stay Circuit Court Proceedings Pending Further

Review, as well as a Motion for Immediate Stay of Circuit Court Proceedings Pending Further

4

E 000402

Review in the Court of Special Appeals of Maryland.2 Strikingly absent from Defendants' May

gth filings was a Motion to Shorten Time for Response with this Honorable Court and/or the Court

of Special Appeals of Maryland, so as to effectuate and obtain a prompt and timely ruling prior to

the commencement of Commissioner Robshaw's May 10, 2017 deposition.

Absent rulings from both this Honorable Court and the Court of Special Appeals of

Maryland concerning Defendants' two respective and aforementioned Motions to Stay, the May

lO,2017 discovery deposition of Commissioner Robshaw proceeded as scheduled. During his

deposition, and pursuant to the }y'ray 3,2017 discovery order, Commissioner Robshaw was asked

and permitted to answer (albeit, under a continuing objection from Defendants' counsel) questions

concerning, among other things, deliberations of the Commission and the Commission's Grower

Evaluation Subcommittee, the evolution of draft and final regulations, the evaluations,

recommendations, and applicant scoring of the Regional Economic Studies Institute (hereinafter

,.RESI.), the grower license pre-approval seleotion process, and the Commission's efforts (or lack

thereof) to ,.actively seek to achieve racial and ethnic diversity" in implementing and administering

Maryland's Medical Cannabis Program. (See, generally, the Deposition Transcript of

Commissioner Robshaw, attached hereto as Exhibit 3)

As it currently stands, (a) given that Commissioner Robshaw's discovery deposition was

permitted to move forward on May 10,2017, and (b) given that Commissioner Robshaw was

asked, and permitted to answer, questions concerning the Commission's decision-making and

other programmatic processes, purportedly implicating the deliberative process privilege and/or

executive privilege, the requested relief and review sought by way of Defendants' Notice of

2 As of the filing of Appellee's instant Motion in Response, the Circuit Court for Baltimore City

had not yet ruléd on^Åppellants' Motion to Stay Circuit Court Proceedings Pending Further

Review, nor is the responsive pleading yet due.

5

E 000403

MEMORANDUMOFLAWEXCLUDED PURSUAI{T TOMARYLAND RULE 8-501(c)

E 000404

MEMORANDUM OF LAW EXCLUDED PURSUANT TO MARYLAND RULE 8—501(c)

E 000404

ARNKEN, LLC2 Reservoir Circle, Suite 104

Baltimore, Maryland [email protected]: (443) 921-1 100F: (aa3) 921-l 1 I ICounselþr Plaintif

A. Pica, Jr.Plcn a¡lp LLC

14 State CircleAnnapolis, Maryland 21 [email protected]: (al0) 990-12s0F: (a10) 280-2s46Counselþr Plaíntif

REOUEST FOR FIEARING

Plaintiff, Altemative Medicine Maryland, LLC, respectfully requests a hearing on

Defendants' Motion for Immediate Stay of Circuit Court Proceedings Pending Further Review.

Dated: May 15,2017

13

Brian S. Brown

E 000405

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 15th day of May ,2017, copies of the forgoing Plaintiff s

Response in Opposition to Defendants' Motion to Stay Circuit Court Proceedings Pending Further

Review, Request for Hearing, and a proposed Order were sent via electronic mail and by hand-

delivery to:

Heather B. Nelson, EsquireAssistant Attomey General300 \M. Preston Street, Suite 302Baltimore, Maryland 21201Email : heather.nelson I @mar.vland. eovCounselþr Defendants

with courtesy copies hand-delivered to:

The Honorable Barry lWilliams

Circuit Court for Baltimore CityCourthouse East - Room 534111 N. Calvert StreetBaltimore, Maryland 21202

Brown

t+

E 000406

v


{. INTIfr

* CIRCUIT COURTPlaintiff, * FOR

* BALTIMORE CITYNATALiE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSION, ¿¡ ai. Case No.: 24-C-l 6-005801

Judge: Bany G. Williams¡1.

¡S)t***{.¡t{.¡t*{.**

ORDER

UPON CONSIDERATION of Defendants' Motion to Stay Circuit Court Proceedings

Pending Further Review, Plaintiff s Response in Opposition thereto, and any argument of counsel,

it is this day of

City, Maryland, hereby:

2017,by the Circuit Court for Baltimore

ORDERED, that Defendants' Motion to Stay Circuit Court Proceedings Pending Further

Review be, and hereby is, DENIED.

Judge, Circuit Court for Baltimore City

Copies to: ALL COUNSEL OF RECORD

,ß

L5

E 000407

ALTERNATIVE MEDICINE MARYLAND,LLC,

Plaintiff


T IN T}IE

* CIRCUIT COURT

* FOR

* BALTIMORE CITY

{, Case No.: 24-C- I 6-005801

i/,v

Defendânts *

***{(*it{(*}l.,1r*{.*

ORDER

Upon eonsideration ofthe Defendants' Motion to Stay Circuit Couri P:'oceeclings

Pending Further Review (#68) and Defendants' Motion to Shorten Time For Response (#71) and

. -. 1ly- oppgliqg-L1þerglg!-i1 !s1hisJ6tr day of May ,2017,by the Circuit Court for Baltimore City:

ORDEREIJ, that l-ieicnda¡ts' lr{otion to Stay Circuit Court-Proceedings Pencilg Frrrthr:r

Iteview (#68) is hereby DItrNIEIJ; and it is further

OFJ)ERED that Defendantsr Motion to Shorten Time for Response (#71) is hereby

DENIED as moot.

,È\- 1

Judge: sìguaturé Appeørs onOriginat Document

Judge Barry G. WilliarnsCircuit Court for Baltimore City

TBUE COPïTAsÏ

MÀRILYN BDNTLEY'

t-r9s$

ôÌ

Notice to Clcrk: Please rnail copies to all parties,

CLEI\K

E 000408

vmckinley

Text Box

05/26/17


CIRCUIT COURTPlaintifl

FOR

* BALTIMORE CITYNATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSION, e/ a/ Case No.: 24-C-16-005801

Judge: Barry G. WilliamsDefendants.

********r'**PLAINTIFF'S MOTION F'OR EMERGENCY TEMPORARY

RESTRAINING ORDER AND REQUEST FOR ORDER TO SHO\ryCAUSE \ryHY A PRELIMINARY INJUNCTION SHOULD NOT BE GRANTED

ANDREOIIEST F'OR IMMEDIA EMERGIÙNCY HEARING

COMES NOW the Plaintiff, Alternative Medicine Maryland, LLC (hereinafter'.AMM"),

by and through counsel, Brian S. Brown, Christopher T. Casciano, Btown & Barron, LLC, Byron

L. Warnken, Byron B. Warnken, Warnken, LLC, John A. Pica, Jr., and John Pica and Associates,

LLC, and pursuant to Maryland Rules 15-501, et seq., hereby moves this Honorable Court for an

Emergency Temporary Restraining Order and respectfully requests that the Court issue an Order

to Show Cause as to why a Preliminary Injunction should not be granted against the Defendants,

Natalie M. LaPrade Maryland Medical Cannabis Commission (hereinafter "the

Commission"), et al., and respectfully requests an expedited hearing with regard to the above,

and in supporl thereof, states as follows:

l. The Maryland Rules expressly provide for the issuance of a Temporary Restraining

Order, prior to the opportunity for a full adversarial hearing on the propriety of a Preliminary

Injunction, upon a showing from specific facts, supported by statements under oath, that

immediate, substantial and ireparable harm will result to the party seeking the order. Md. Rule

15-501, et seq.

*

,k

IN THE

V

*

*

E 000409

vmckinley

Text Box

05/15/17

2, The record is clear from the facts and sworn testimony in this case, as set forth more

specifically in the attached Memorandum of Law in Support, that unless and until a Temporary

Restraining Order is granted, AMM will suffer immediate, substantial, and irreparable harm before

a full adversarial hearing can be held on the propriety of a preliminary injunction.

3. AMM has a strong likelihood of success on the merits of its Complaint for

Declaratory Judgment and Preliminary and Permanent Injunctive Relief filed with this Honorable

Court on October 31,20t6 (Docket No. 1/0), and attached hereto as Exhibit A.

4. The harm to AMM if a Temporary Restraining Order is not granted strongly

outweighs any potential harm to the Defendants if a Temporary Restraining Order andlor a

Preliminary Injunction are granted.

5. In the event that injunctive relief is not granted, AMM has in the past, and will in

the future, suffer immediate, substantial, and irreparable injury for which there is no adequate

remedy at law.

6. A Temporary Restraining Order andlor Preliminary Injunction are necessary to

pteserve the "status quo" while fuither facts are developed by way of discovery and to definitively

prevent the accrual of further irreparable harm to the Plaintiff.

7 . The public interest is best served by granting a Temporary Restraining Order and/or

a subsequent Preliminary Injunction.

L ln further support of Plaintiff s lVlotion for Emergency Temporary Restraining

Order and Request for Order to Show Cause Why a Preliminary Injunction Should Not Be Granted,

this l-Ionorable Court is respectfully referred to the accompanying Memorandum of Law in

Support, the Affidavit of Professor F. Michael Higginbotham, attached hereto as Exhibit B and

the Afficlavit of Dr. Gregory Daniel, AMM's Managing Member, attached hereto as Exhibit C, all

E 000410

of which the Plaintiff incorporates by reference and attachment hereto, as if fully set fofih herein.

9. Plaintiff also represents that Heather B. Nelson, Esquire, of the Maryland Attomey

General's Office, and counsel of record for the Defendants, has been provided with notice of and

served, via electronic mail and hand-delivery, with copies of the instant Motion, along with all

supporting do cumentation.

WHEREFORE, Plaintiff respectfully requests that this Honorable Court:

A. Issue a Temporary Restraining Order so as to maintain the "status quo," and

ORDER that the Defendants, Natalie M. LaPrade Maryland Medical Cannabis

Commission, et al., by and/or through their duly-authorized commissioners,

agents, servants, and/ot employees, be temporarily:

(1) RESTRAINED and ENJOINED from authorizing, granting and/or issuing

any final licenses to cultivate and grow medical cannabis in Maryland

prior to a full adversarial hearing on the propriety of granting a

Preliminary Injunction;

(2) RESTRAINED and ENJOINED from taking arry additional action

pursuant to and in furtherance of the Commission's Stage 2 medical

cannabis grower licensing scheme, including the immediate suspension

of inspections of and for the fifteen (15) pre-approved medical cannabis

growing fäcilities, prior to a 1ìrl1 adversarial hearing on the propriety of

granting a Preliminary Injunction;

B. Issue a Show Cause Order requiring the Defendants, Natalie M. LaPrade

Maryland Medical Cannabis Commission, et al., by and/or through their duly-

authorized commissioners, agents, servants, and/or employees, to affirmatively

E 000411

C.

D

E.

show cause as to why the Court should not issue a preliminary injunction, prior to

a fuIl and final adjudication on the merits;

Issue a Preliminary Injunction in order to maintain the "status quo," and ORDER

that the Defendants, Natalie M. LaPrade Maryland Medical Cannabis

Commission, et al., by andlor through their duly-authorized commissioners,

agents, servants, and/ot employees, be preliminarily:

(1) RESTRAINED and ENJOINED from authorizing, granting and/or issuing

any final licenses to cultivate and grow medical cannabis in Maryland

prior to a full trial on the merits and propriety of granting a Permanent

Injunction;

(2) RESTRAINED and ENJOINED from taking arly additional action

pursuant to and in furtherance of the Commission's Stage 2 medical

cannabis grower licensing scheme, including the immediate suspension

of inspections of and for the fifteen (15) pre-approved medical cannabis

growing facilities, prior to a full adversarial hearing on the propriety of

granting a Permanent Injunction;

Waive and dispense with the requirement of surety or other security for a bond,

pursuant to Md. Rule 15-503(c) and the Court's discretionary powers, as one of the

parties is a govemmental entity and the Plaintiff otherwise seeks to enforce an

important legally recognized and mandated right well within the purview of the

public interest; and

For such other and fuilher relief as the Court deems appropriate and just.

Dated: May 15,2077

E 000412

Byron B. WWenNrpN, LLC2 Reservoir Circle, Suite 104

Baltimore, Maryland 21208b)¡¡[email protected] aw. c omP: (aß) 921-1100F: (443) 921-1111Counsel for Plaintiff


S. BrownChristopher T. CascianoBnowN & BannoN, LLC7 St. Paul Street, Suite 800Baltimore, Maryland 21202bbrown@brownbarron. comccasciano @brownb arron. comP: (a10) s47-0202F: (410) 332-4s09Counsel for Plaintiff

A. Pica, Jr.JonNPlcaaNo14 State CircleAnnapolis, Maryland 21 [email protected]: (a10) 990-12s0F: (410) 280-2546Counsel for Plaintiff

-)

BLLC

I HEREBY DECLARE AND AFFIRM, UNDER THE PENALTIES OF PERJURY, THATTHE CONTENTS OF'THE FOREGOING PLAINTIFF'S MOTION FOR EMERGENCYTEMPORARY RESTRAINING ORDER AND REQUEST F'OR ORDER TO SHOWCAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT BE GRANTED, ANDMEMORANDUM OF LAW IN SUPPORT THEREOF, ARE TRUE, ACCURATE ANDCORRECT TO THE BEST OF MY KNOWLEDGE,INFORMATION AND BELIEF.

DAlt

BRiAN S. BROWN, ESQ

E 000413

REQUEST FOR EXPEDITED HEARING

Plaintiff, Alternative Medicine Maryland, LLC, hereby requests an expedited hearing on

the foregoing Plaintiffs Motion for Emergency Temporary Restraining Order and Request for

Order to Show Cause Why A Preliminary Injunction Should Not Be Granted.

CERTIFICATE OF' SERVICE

I HEREBY CERTIFY that on this 15th day of May ,2Ol7,copies of the forgoing Plaintiff s

Motion for Emergency Temporary Restraining Order and Request for Order to Show Cause Why

A Preliminary Injunction Should Not Be Granted, Memorandum of Law in Support thereof,

Exhibits, Request for Expedited Hearing, and proposed Orders, were sent via electronic mail and

by hand-delivery to:

Heather B. Nelson, EsquireAssistant Attorney General300 W. Preston Street, Suite 302Baltimore, Maryland 2I20IEmail : heather.nelson 1 @mar.vland. eovCounselfor Defendants

with courtesy copies hand-delivered to:

The Honorable Barry WilliamsCircuit Courl for Baltimore CityCourthouse East - Room 534111 N. Calvert StreetBaltimore, Maryland 21202

The Honorable Althea M. HandyCircuit Court for Baltimore CityCourthouse East - Room 529I l1 N. Calvert StreetBaltimore, Maryland 21202

E 000414

ALTERNATIVE MEDICINEMARYLAND,LLC

*

*

IN TI{E

v

CIRCUIT COURTPlaintiff; * FOR

* BALTIMORE CITYNATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSION, er a/. Case No. : 24-C-1 6-005801

Judge: Bany G. WilliamsDefendants.

{<***{.***{<**{<

MEMORA.NDUM OF LA\ry IN SUPPORT OFPLAINTIFF'S MOTION FOR EMERGENCY TEMPORARY

RESTRAINING ORDER AND REQUEST FOR ORDER TO SHO\ryCAUSE \ryITY A PRELIMINARY INJUNCTION SHOULD NOT BE GRANTEI)

COMES NOV/ the Plaintiff Alternative Medicine Maryland, LLC (hereinafter "AMM"),

by and through counsel, Brian S. Brown, Christopher T. Casciano, Btown & Barron, LLC, Byron

L. Wamken, Byron B. Warnken, Warnken, LLC, John A. Pica, Jr., and John Pica and Associates,

LLC, and pursuant to Maryland Rules 15-501, et seq.,1-351 and 2-31 l(c)-(d), hereby submits the

foregoing Memorandum of Law in Support of PlaintifPs Motion for Temporary Restraining Order

and Order to Show Cause why a Preliminary Injunction Should Not Be Issued,

INTRODUCTION

AMM seeks the remedies of a temporary restraining order and subsequent preliminary

i4junction to address the Defendant Maryland Medical Cannabis Commission's (hereinafter o'the

Commission") illegal, arbitrary, capricious and unreasonable actions, omissions and patent

missteps in implementing and administering Maryland's Medical Cannabis Program.

Specifically, the record is clear that the Commission intentionally and/or negligently

ignored its legislatively-mandated duty and directive to "actively seek to achieve racial, ethnic,

and geographic diversity when licensing medical cannabis growers." Mp. Coop A¡w., HEALTH

t

E 000415

vmckinley

Text Box

05/15/17

B. The Balance of Convenience Weighs In Favor Of Immediate Iniunctive Relief.

There is little potential for harm to the Defendants in granting AMM's request for a

Temporary Restraining Order and subsequent Preliminary Injunction, as the requested relief will

merely preserye the "status quo," and otherwise reinforce the Defendant Commission's

legislatively-mandated duty to "actively seek to achieve racial, ethnic, and geographic

diversity when licensing medical cannabis growers;" an unambiguous legislative directive

which the Commission intentionally and/or negligently disregarded, in direct contravention

of its authorizing statute.

Furthermore, Defendants are not market participants, so they do not stand to lose

economically in the event that the licensing process is halted andior re-initiated in accordance with

Maryland law. Pursuant to statute, Defendants have until June 1, 2018 to license the first 15

medical cannabis growers. (,9ee Health Gen. $ 13-3306(a). Ittookthe Commission approximately

ten (10) months to review and rank the initial 145 medical cannabis gro\üer applications.

Reconsidering Stage 1 applicants in accordance with the proper and legislatively-mandated

statutory criteria will take substantially less time than the initial ten-month review process because

the Commission already has before it extensive information about each applicant. Thus, there is

every indication that the Commission has arnple time to redo the Stage 1 approval process in the

12* months before the June 201 8 statutory deadline to award the first 1 5 licenses.

C. AMM Has Been and Will Continue To Be Immediately and Irreparably Harmed.

Irreparable harm is a o'pliant term adaptable to the unique circumstances which an

individual case might present." Commission on Human Relations v. Talbot County Detention

Center,370 Md. 115, 140 (2002). As explained by the Maryland Court of Appeals:

[A]n injury is ineparable, within the law of injunctions, where it is of such acharacter that afair and reasonable redress may not be had in a court of law, so that

22

E 000416

MEMORAI{DUM OF LAWE,XCLUDED PURSUANT TOMARYLAI{D RULE 8-50 1 (c)

E 000417


E 000417

Exhibit A Omitted

Please see Docket ll0(Cornplaint)

E 000418

Exhibit A Omitted

Please see Docket 1/0

(Complaint)

E 000418

trXHIBIT B

E 000419

EXHIBIT B

E 000419

ALTERNATIVE MEDICINEMARYLAND, LLC * CIRCUIT COURT

PlaintiflFOR

* BALTIMORE CITY

NATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSION, e/ a/ Case No. : 24-C-1 6-005801

Judge: Balry G. \üilliams

Defendants

******+*{<{<**

1. I am over 18 years of age, a resident of Maryland, competent to testify, and have

personal knowledge of the facts set forth herein'

2. I am currently the Dean Joseph Curtis Professor of Law and the former Interim

Dean at the University of Baltimore School of Law.

3. I am the co-founder of the Fannie Angelos Program for Academic Excellence and

the former president of the Public Justice Center, the former chair of the Maryland Attomey

General's Task Force on Electronic Weapons, and the former chairperson of the Association of

American Law Schools Committee on Recruitment and Retention of Minority Faculty'

4. I have authored numerous publications in the areas of Constitutional Law, Equal

protection, Human Rights, and Race Relations, including "Ghosts of Jim Crow: Ending Racism

In post-Racial America", published in February 2013, and "Race Law: Cases, Corrunetttary, aud

Questions", published in June 2015.

5. A copy of my curriculum vitae is attached hereto as Exhibit 1.

6. I have been retained by the Plaintiff, Alternative Medicine Maryland, LI-C, as an

expert witness in the areas of Constitutional I-aw, Equal Protection, Human Rights, and Race

Relations.

+ IN THE

*

*

E 000420

7. My opinions are based upon my knowledge, training and experience in the areas of

Constitutional Law, Equal Protection, Human Rights, and Race Relations, as well as my review

of the relevant materials relating to the racial and ethnic diversity aspects of this case, including

(a) the Maryland Medical Cannabis Commission's authorizing and governing statutes, Mo. Coup

ANIN., Hnalru GnN. $13-33000, et seq., (b) COMAR 10.62'08'05, et seq., (c) Commission

regulations, (d) federal and state laws on affumative action, (e) federal and state judicial decisions

on affirmative action, and (f) and other relevant materials.

8. It is my opinion to a reasonably degree of constitutional certainty that the

Defendants (hereinafter collectively "the Commission") had actions available to it which would

have enabled the Commission to comply with its authorizing and governing statute, and that could

have been implemented without violating state or federal constitutional law, and therefore, the

Commission should not have abandoned its affirmative legislative mandate to "actively seek to

achieve" racial and ethnic diversity when licensing medical carurabis growers. More specifically,

but without limitation, I offer the following:

a. On January 23,2015,the Comrnission initially issued proposed regulations

that considered "racial, ethnic, and geographic diversity," and minority

business enterprise status in the scoring criteria for Stage 1 grower license

pre-approvals. (See Complaint, at fl 36).

b. During the 2015 legislative session, Delegate Christopher 'West

t'ecluested

advice from the Attorney General's (AG) office about the constitutionality

of the requirement for the Commission to "actively seek to achieve" racial

and ethnic diversity, and to "encoulage" minority business enterprises to

apply. (,See Complaint, at n37)

2

E 000421

c The AG responded to Delegate West on March 73,2015, by letter authored

by Kathryn Rowe, an Assistant Attorney General, and the letter was

provided to the Commission. The letter stated, in part, that "constitutional

limits, howevet, would prevent the Commission from conducting lace or

ethnicity-conscious licensing in the absence of a disparity study showing

past discrimination in similar proglams." The AG also advised that absent

a study, "the efforts of the Commission to seek racial and ethnic diversity

among growers and dispensaries would have to be limited to broad publicity

given to the availability of the licenses and encouragement of those from

various groups." (,see the March 13,2015 Correspondence from Assistant

Attomey General Kathryn M Rowe to Delegate Chris 'West,

attached hereto

as Exhibit 2).

On September 14,2015, the Commission removed all references to and

mention of racial and ethric diversity from its regulations . (Su, Complaint,

at tf 38). The final version of COMAR 10.62.08.05 provides, among other

things, that the Commission may consider geographic diversity for scoring

purposes within the Stage 1 rating system, (Søe COMAR 10.62.08.05,

attached hereto as Exhibit 3). After this final COMAR version, none of the

Commission's regulations mention consideration of racial or ethnic

diversity in the licensing process. ,Id.

on August 26,2015, the Washington Post printed an article wherein it was

noted that "[n]one of the businesses [pre-]approved fby the Commission]

for cultivation are led by Afi'ican Americans, even though the legislature

d.

e.

J

E 000422

f.

seeks to create a racially diverse industry in a state where nearly a third of

the population is black." (,See Fenit Nirappil, Hogan, Frosh concerned

about lack of diversity in Maryland's tnedical pot licenses, The Washington

Post, August26,2076, attached hereto as Exhibit 4). In the same afticle,

Delegate Cheryl D. Glenn (D-Baltimore), who was reportedly "instrumental

in passing the bill that legalized medical marijuana," stated that "[w]e are

not going to accept licenses being awarded and people getting an unfair

advantage in this billion-dollar industry with no minority participation'"

Id. (Emphasis added). The article goes on to state that "[a]fter fDelegate]

Glenn and other black lawmakers raised concefns, the attomey general's

offrce said the commission should not have concluded from the [March 13,

20151letter ffrom Assistant Attomey General Kathryn Rowe to Delegate

West] that it would be wrong to take the race of prospective marijuana

business owners into account." Id. Raquel Coombs, a spokeswoman for

Attomey General Frosh, indicated that "the commission could have

researched whether there is evidence of racial disparity in industries similar

to medical marijuana" and "fi]f there is...the commission would be justified

in taking race into accolìnt." .1d. Ms. Coombs was further qgoted as saying

that "[t]he attomey general strongly believes that this lmeclical cannabisl

industry shouid reflect the diversity of the sIate." Id.

In a lelter from Paul Davies, M.D., Chair of the Commission, posted on the

Comrnission's website in response to the AugusT.26,2016 Washington Post

article on racial cliversity, Davies claims that the Commission had a "strong

4

E 000423

belief that minority inclusion is of paramount importance" to the

medical marijuana growing industry in Maryland. (^9ee Davies Letter,

attached hereto as Exhibit 5). Notably, Commissioner Davies also states

that "[the commission] realize[s] that this emerging [medical cannabis]

industry creates numeïous possibilities for growth and economic

opportunity for many in Maryland;" that "the commission is committed

to seeking and promoting racial diversity and minority inclusion;" and

that the Commission "believefs] that diversity is in the best interest of the

industry and an important responsibility." Id. If Commissioner Davies'

statements were, in fact, true, one would expect that abandonment of racial

and ethnic diversity as a weighted component in the licensing selection

process would have been done only after careful consideration. At a

minimum, one would have expected a request to the Attomey General to

make certain that every possible method to satisfy the legislative mandate

was being implemented, parlicularly if the Commission members had any

doubts as to what methods could be utilized after receipt of the March 13,

2015 letter from Assistant Attorney General Rowe' Yet no requests or

inquiry appears to have been macle. Instead, based upon an erroneous

reading of the March 13,2075letter, the Commission simply abandoned all

race-conscious cfforts to achieve racial ancl ethnic diversity in the selection

of medical marijuana licenses for growers, and accordingly, "thete were no

requirements to disclose race on the appltcation." Id.

After the selectiott of the 15 Stage 1 grower license pre-applovals were

5

É.

E 000424

h.

identified, much criticism was forthcoming from members of Maryland's

Legislative Black Caucus for the lack of racial and ethnic diversity in the

designated licensees. (See Pamela'Wood, Panel awards licenses for 102

Marijuana dispensaries, The Baltimore sun, December 10, 2016, at¡ached

hereto as Exhibit 6).

Govemor Larry Hogan and Attomey General Brian Frosh also criticized

this lack of diversity. (See Exhibit 4). Specifically, Attorney General Frosh

indicated he thought more could have been done to foster racial diversity

and Governor Hogan assigned two top staff members to help address these

diversity issues. (,See Fenit Nirappil, Medical-pot regulators in Maryland

blast AGfor conflicting advice on racial diversity, The Washington Post,

September 7,2016, attached hereto as Exhibit 7).

Subsequently, the Commission hired a diversity consultant to advise on the

feasibility of conducting a disparity study at this stage in the process, as well

as providing guidance on what actions, if any, may be undertaken to satisfu

the legislative directive to the Commission to "actively seek to achieve"

racial and ethnic diversity. (See Etin Cox, Maryland medical marijuana

panel v,ill hire clilersity c¡n.,rultant, The Baltimore Sun. November 28,

2016, atTached hereto as Exhibit 8).

Hiring a diversity consultant at this late stage in the plocess indicates a

recognition that much more could have and should have been do¡e by the

Commission from the outset to foster racial and ethnic diversity when

iicensing medical cannabis growers.

1.

6

E 000425

g. It is my opinion to a reasonably degree of constitutional certainty that there were

several actions the Commission should have taken to satis$r its legislatively-directed duty to

,,actively seek to achieve" racial and ethnic diversity when licensing medical cannabis growers

within the cument constitutional restrictions on the utilization of government mandated racial

identification to achieve diversity in government contracting: (a) the Commission should have

conducted a racial disparity study; (b) even without a disparity study, there were certain race-

conscious methods that should have been utilized; and (c) even without a disparity study, there

were certain race-neutral methods of fostering racial and ethnic diversity that should have been

employed.

10. It is my opinion to a reasonable degree of constitutional certainty that the

Commission could have and should have conducted a racial disparity study in furtherance of the

legislative mandates set forth in their authorizing and governing statutes. More specifically, but

without limitation, I offer the following:

a. Even though race-based affirmative action programs are subject to the

strictest jucticial scrutiny when subject to Fourteenth Amendment Equal

Protection Clause challenge (Ciry of Richmondv. J.A. Croson Co.,488 U.S.

469 (Ig8g)), in ceftain circumstances they are constitutionally permitted.

Adarancl Constructors, Inc, v. Pena ,515 U.S. 200 (1995). The Adarand

Courl explained that strict scrutiny does not prohibit govemment remedial

action. 'Writing for the majority opinion, Justice Sandra Day O'Connor

stated: "We wish to dispel the notion that strict scrutiny is 'strict in theory,

but fatal in fact.' The unhappy persistence of both the practice and lingering

effects of racial discrimination against minority groups in this country is an

7

E 000426

b

unfortunate reality, and govemment is not disqualified from acting in

lesponse to it." Adarand,515 U.S. at237 -

Following the Supreme Court's decision in Adarand, the Justice

Department issued guidelines to govern the use of race-conscious remedies.

(see 48 C.F.R.$ 19.201(2005). The guidelines provided: "The mere fact

that there has been generalized, historical societal discrimination in the

country against minorities is an insufficient predicate for tace-conscious

remedial measules; the discrimination to be remedied must be identifìed

more concretely. The federal government would have a compelling interest

in taking remedial action in its procurement activities, however, if it can

show with some degree of specificity just how 'the persistence of both the

practice and the lingering effects of racial discrimination' - to use Justice

O'Connor's phrase in Adarand- has diminished contracting opportunities

for members of racial and ethnic minorþ groups." Adarand,515 U.S. at

¿)/

As the Justice Depafiment indicated, in order to provide the requisite

justification f'or race-conscious remedies, the first requirement of strict

scrutiny is that a goveriment entity, state or federal (Adarand,5l5 U.S. at

235), must have a "compelling" reason. one way to satisfy this requisite

compelling interest is to establish the exìstence of present-day

discrimination or the ongoing effects of past racial or ethnic discrimination

within an industry/market of a particular sl:ate. Cro5on' 488 U.S' at 485-486,

4g2, 50g. Such a finding must be supporled by a strong basis in evidence.

c

8

E 000427

d

Croson,488 U.S.at 510. Disparity studies can provide such a strong basis

in evidence, and, therefore, a compelling reason should the studies establish

a showing of present discrimination or present effects of past discrimination

in the industry/market or similar industries/markets within the state.

Croson,488 U.S. at509.

Maryland Assistant Attorney General Kathryn Rowe's letter to Delegate

Chris West of March 13, 2015 indicates that, absent a disparity study, no

race-conscious selection plocess would be appropriate. (See Exhibit 2).

The letter did not indicate any legal prohibition against conducting such a

disparity study. Id. The letter did not provide any expless or implied

preference by the Attorney General, or his designees, that no study be

conducted. Id. The letter indicated only that Assistant Attorney General

Rowe was unaware of any disparity study that would cover grower licenses

or licensing in general. Id.Yet, the Commission chose to proceed without

investigating whether any studies had already been done that would shed

light on the racial disparities that might exist in the industry/market under

review or whether other studies existed of related oI similar

industries/markets in other states. Notably, at this time, 29 states (and the

District of Columbia) have legalized medical marijuana. (,See www.rnedical

maflluana. con.ors)

in fact, two disparity studies had already been completed in two recently

created Maryland markets, the gaming industry and wind enelgy industry.

(See Exhibit 4). Therefore, just becattse an industry may be newly created

9

E 000428

f

in the state would not provide the requisite justification for preventing a

disparity study examining the medical marijuana growing industry in

Maryland. Similarly, a disparity study could have been done on marijuana

growing industries in other states. Moreover, disparity studies could have

been conducted for industries /markets within Maryland that were similar

in nature to marijuana growing such as various agriculture growing

industries/markets or drug manufacturing industries/markets- Such

disparity studies would likely shed light on conditions for minorities trying

to get into the medical marijuana growing business in Maryland-

Since use or growing of marijuana, even for medical purposes, has been

completely prohibited in the state of Maryland until recently, no disparity

studies had been conducted for that particular market. With the passage of

legislation creating a commission to conduct a process for permitting the

growing of marijuana by designated businesses, a disparity study should

have been authorized by the Commission to determine if it could fulfill its

statutory obligations. This is particularly clear when considering the

Maryland Assembly legislative directive of 2014 that expressly directecl the

Commission to "actively seek to achieve" racial and ethnic diversity ancl the

Maryland Assistant Attorney General's indication that such a ilisparity

study would be needed before any race-conscious selection remedies could

be implemented.

The Commission did incorporale a geographical diversity component into

the process consistent with the legislative directive to actively seek

ots)

10

E 000429

h.

geographic diversity, but it did not include a racial or ethnic one. The letter

from Paul Davies (see Exhibit 5), Chair of the Commission, indicates the

Commission removed all references to racial and ethnic diversity on

september 14, 2015. It is apparent therefore that the commission

erroneously believed, based on its misinterpretation of the Assistant

Attorney General's letter of March 13, 2015 (see Exhlbit 2), that race-

conscious remedies could not be implemented even after a diversity study

had been completed. The Commission did not conduct any study or research

whether other studies had been done in similar industries/markets' The

Commission refused to follow the law as provided in Adarand and The

Justice Department guidelines. As a consequence, the Conrmission ended

up with a racially disparate result. The Commission's determination not to

conduct a racial disparity study constitutes a patent failure to satisfy the

legislative mandate to "actively seek to achieve" racial and ethnic diversity.

Notably, on April 27,2077, Govemor Larry Hogan formally requested that

the Governor's Office of Minority Affairs (GOMA) "initiate a disparity

study of the state's regulated medical camabis industry and market" and

direcl-ed that the study be complcted "as expeditiously as possible in order

to ensure diversity in Maryland's medical cannabis industry...as the issue of

promoting diversity is of great impoflance to [the Governor] and fhis]

administration." (See April27,2077 LelLet'Íìom Govelnor Larry Hogan to

Special Secretary of Minority Affairs, Jìrnmy H. Rhee, attached hereto as

Exhibit 9).

11

E 000430

11. It is my opinion to a reasonable degree of constitutional certainty that, even without

a disparity study, there were certain race-conscious methods and remedies that should have been

utilized and employed by the Commission. More specifically, but without limitation, I offer the

following:

a. As the Maryland Assistant Attorney General Kathryn Rowe's letter to

Delegare Chris West of March 13, 2075 indicates (see Exhibit 2), the

Commission, without conducting a disparity study, could have encouraged

minority-owned businesses to apply to participate in the selection process'

This type of race-conscious effort, often characterized as "outreach

p ograms," are constitutionally permitted even without a disparity study

demonstrating past discrimination within the industry or similar industries

or the present effects of such past discrimination. Aside from encouraging

applications, such typical outreach efforts include training plograms,

resource allocation, information gathering, and adoption of goals and

timetables

Since Adarand,Ihe Supreme Court has not decided an affirmative action

case involving govemment contracts. Yet several affrrmative action cases

dcaling with education provide guidance on constitutionally permissible

race-conscious methods absent a racial disparity study. In a concurring

opinion in Purents Involved in Community Schools v' Seattle School District

No. l,Justice Anthony Kennedy provided some suggestions on how school

districts can constitutionally use race-conscious measures to achieve

diversity in the absence of evidence of historical discrimination within the

b

t2

E 000431

c.

particular industry/market. 551 U.S. 701, 789 (2007). Justice Kennedy

suggested several race-conscious approaches such as strategic site selection

of new schools, drawing attendance zones with recognition of the

demographics, allocating resources for diversity pfograms, recruiting

students and faculty on atargeted fashion, and tracking enrollment and other

statistics by race for informational purposes. Parents Involved,55l U.S. at

188-790.

Applying Justice Kennedy's suggestions in the education arena to

government licensing merits consideration, Justice Kennedy's list suggests

two easily identifiable and readily transferable race-conscious methods:

recruitment and statistical gathering for informational purposes. Although

the Commission claimed to have implemented race-conscious recruitment

methods to foster racial diversity in grower license applications, it

abandoned any efforts at statistical gathering by race or ethnicity for

informational purposes by prohibiting the identification of race on the

license applications. Supreme Court decisions do not require such

prohibition. The Commission has since tried to correct this mistake by

requesting, on a voluntary basis, that those awarded growel licenses provide

racial and ethnic ownership information. This should have been required

fi'om the outset. The Commission's failure to adopt all race-conscions

outreach efforls is indicative of the mistaken lack of value, whether

intentional or negligent, it placed on satisfuing the legislative mandate to

"actively seek to achieve" racial and ethnic diversity'

T3

E 000432

12. It is my opinion to a reasonable degree of constitutional certainty that, even without

a disparity study, there were certain race -neutral methods fostering racial and ethnic cliversity that

should have been utilized and employed by the Commission. More specifically, but without

limitation, I offer the following:

a. Due to the country's long history of racial and ethnic discrimination, and

continued racially segregated housing patterns throughout the state of

Maryland, race- neutral factors could have been utilized in license selection

criteria that would have fosteredtacial and ethnic diversity in the process,

even without the benefit of a disparity study.

b. First, the Commission could have added to its Stage 1 scoring of grower

applications under "Additional factors that will be afforded 15 percent

weight," two factors to the four provided. One factor could have been

,,overcoming historical discrimination" including "racial, ethnic, gender,

religious, economic, social, cultural, and other related factots." Another

factor could have been close ties to geographic areas within the state with

high poverty and/or unemployment rates. Applicants that satisfy one of

these factors would be awarded 15 percent weight. Since higher percentages

of minority-owned businesscs may satisfu one or more of these factors,

incorporation of either or both race-neutral factors may have increased the

likelihood of a more diverse selected group of applicants'

o. Race-neutral affirmative action programs that foster racial or ethnic

diversity are subject to the lowest level of judicial scrutiny, and are

generally permissible as long as the govemment has a legitimate interest,

14

E 000433

and the classification is rationally related to achieving that interest. Croson,

488 U.S. at 485-486. Because the commission was empowered by the

Legislature to "actively seek to achieve" racial and ethnic diversity when

organizing the selection process under Maryland law, it was empoweted,

and, in fact, required, to utilize tace-neutral methods of selection, if it

believed that race-based methods were forbidden.

d. The Commission could have identified and utilized ceftain race-neutral

selection criteria to increase the likelihood of the selection of a more diverse

group of applicants. The letter authored by commissioner Davies (see

Exhibit î claims that the Commission "took every step possible to include

racial diversity as a weighted component in the selection plocess" and that

the Commission has a "strong belief that minority inclusion is of paramount

importance to this new industry ." Id. Yet the letter makes no mention of

any race-neutral factors to foster racial and ethnic inclusion that were

adopted by the Commission after the Assistant Attorney General's letter to

Delegate chris west on March 13,2015. The failure to adopt such race-

neutrai measules seriously undermines Chairman Davies' claim that the

Corrunissio¡'s selection ploccss valued racial and ethnic diversity,

13. Finally, it is my opinion to a reasonable degree of constitutional cefiainty that the

f)efendants failed to abide by and otherwise fulfill their legisiative mandate to "actively seek to

achieve,, racial and ethnic diversity. More specifically, but without limitation, I offer the

following:

a. The Commission's seleclion process violated its statutory obligations

15

E 000434

because it failed to actively seek to achieve racial and ethnic diversity.

b. There are two ways to proceed moving forward, consistent with the

Commission's legislative mandate to "actively seek to achieve" racial and

ethnic diversity when licensing medical cannabis growers.

c. The first is to reject the entire Stage 1 preliminary approval selection

scheme and begin a new bidding process after the Commission conducts a

racial and ethnic disparity study. Based on the hndings of this study, the

Commission may then proceed with appropriate race-conscious remedies'

d. Altematively, the Commission could conduct a racial and ethnic disparity

study and, based upon the findings of the study, add additional licenses

consistent with race-conscious remedies. While this approach does not

cleanse the original flawed process, and may create other equality concerns,

it does allow for the Commission to satisfu its legislative mandate to

"actively seek to achieve" racial and ethnic cliversity.

14, This Affidavit is not a comprehensive recitation of all of the opinions and the bases

for those opinions that I hold with regard to this matter, but rather, merely represents a broad

summary of my opinions.

I HEREBY DECLARE AND AFFIRM LINDER THE PENALTIES OF PERruRY THAT THE

CONTENTS OF THE FOREGOING AFFIDAVIT ARE TRUE, ACCURATE AND CORRECT

TO THE BEST OF MY KNOV/LEDGE, INFORMATION AND BELIEF.

F'DA/7

E 000435

HIGGNB OTHAM AFF'IDAVITtrXHIBIT 1

E 000436

HIGGINB OTHAM AFFIDAVIT EXHIBIT 1

E 000436

REV.211"1

CURRICULUM VITAE OF F. MICHAEL HIGGINBOTHAM

PERSONAL

Business Address:

University of Baltimore School of Law1401 North Charles Street, Angelos Law Center Room I I l5

Baltimore, MD 21201410-837-4649 (Voice)410-837-4560 (Fax)

[email protected] (E-mai l)fm ichaelhi gginbotham.org (Website)

@professorhi gg (Twitter)

EDUCATION

LEGAL

Degrees:

Cambridee University Cambridge, England (GB)

Master of Laws Degree awarded June 1985 (lnternational Law) (Human Rights)

Yale University New Haven, Connecticut (USA)

Juris Doctor Degree awarded June 1982 (Constitutional Law) (Civil Rights)

Honors:

yale BALSA Citation of Merit Award. Master of Laws Degree awarded with Honors.

Rotary Scholar (Cambridge University). Hawks' Club (Cambridge Athletic Honor Society).

First ever Full-Blue awarded in Basketball by cambridge university.

Activities:

Student Representative, Yale Law School Admissions Committee. President, Cambridge

University Basketball Club. Captain, British Universities Basketball Team.

NON-LBGAL

Degrees:

Brown University Providence, Rhode Island (USA)

Bachelor of Arts Degree awarded June 1979 (Classics and Ancient Greek History)

Honors:

Bachelor of Arts Degree awarcled Magna Cum Laude. Bachelor of Arts Degree awarded

with Honors in Classics.

E 000437

Activities:

Member, Varsity Football Team. Representative, University Council of Students

Counselor, Residential Life Program.

EXPERIENCE

University of Baltimore School of LawJoseph Curtis Professor of Law,2013-Present(Endowed Professorship Awarded 20 1 3)

Un of Bal ore School Law

lnterim Dean, 201 1-2012

University of Pennsylvania Law School

Visiting Professor of Law, 2011

University of Baltimore School of LawProfessor of Law, 2007-2011

University of Baltimore Schoolof LawWilson Elkins Professor of Law, 2004-2007

(Endowed Professorship Awarded 2004)

University of MiamiLaw School

Visiting Professor of Law,2004

University of Baltimore Schoolof Law

Professor of Law, 1995-2004(Promoted 1995)

New Y I lniversitv School

Adjunct Professor of Law, 1991-2010

University of Baltirnore School of Law

Associate Profcssor of Law, 1991-1995

(Promoted and Tenured l99l)

tln of Baltimore School ofLawAssistant Professor of Law, 1988-1991

University of Pennsylvania Law School

Lecturer in Law, 1986-1988

Davis. Polk & W well

Baltimore, Maryland (USA)


Philadelphia, PennsYlvania (U SA)



Miami, Florida (USA)


New York, New York (USA)

Baltinrore, Maryland (USA)


Phi ladelphia, Pennsylvania (USA)

Associate, 1983- 1984

2

Washington, District of Columbia (USA)

E 000438

United States Court of AppealsLaw Clerk to Judge Cecil Poole,1982

San Francisco, California (USA)

SELECTED PUBLICATIONS

BOOKS

Teacher's Manual, R¡cp Lew: CASES, Cotvttr¡¡nreRY, AND Ques'rtoNs (Fourth Edition),

Carolina A c Press (July 2015)

Casebook, RACE LRW: CASIS, COvvpNrRRY, AND QUeSTtONS (Fourth Edition), Carolina

Academic Press (June 2015)

lnstructor's Guide, Guosrs oF JIM Cnow: Enonc Raclstr¡ IN Posr-RaclAL AMERICA, New York

University Press (April 2014)

Book, Gsosrs oF JrM Cnow: ENonc Racrsvr IN Posr-RActAL AMERlca , New York Universit)¡

Press (March 2013)

Teacher's Manual, Racp Law: CASES, CovltENreRY AND QuesrtoNs (Third Edition), Carolina

Academic Press (August 2010)

Casebook, R¡c¡ L¡w: CASES, Cotr¡vBNtRRY AND Qurslotls (Third Edition), Carolina

Academic Press (May 2010)

Teacher's Manual, R¡.ce Lew: CASES, Cot'¿lr¡pNraRY AND QuesrloNs (Second Edition),

Carolina Academic Press (January 2005)

Casebook, Recs Lew: CRSES, CovrveNreRy AND QuesloNs (Second Edition), Carolina

Academic Press (January 2005)

Teacher's Manual, Racp Law: CASES, Covlir¡gNreRY AND QuESrtoNs, Carolina Academic Press

(September 2001)

Casebook, R¡cr Law: CASES, Covrl¿sNteRy AND QuestloNs, Carolina Academic Press

(September 2001)

ARTICLES

An Open Letter From Heaven To Barack Obama, 32 Universit)'of Hawaii Law Review I (April

20r 0)

An Open Letter From Heaven To Justice Samuel Alilo,23l-larvard Blackletter Law Journal 9

(February 2007)

3

E 000439

A Dream Revived: The Rise of the Black Reparations Movement, 58 Annual Survey ofA Law 447 (February 2003)

Soldiers For Justice: The Role of the Tuskegee Airmen in the Desegregation of the American

Armed Forces, 8 William & Mary Bill of Rights Law Journal 273 (June 2000) (reprinted in I

Nota Bene l9 (Spring 2001)

Affirmative Action in the United States and South Africa: Lessons From the Other Side, l3

Temple Intemational & Comparative Law Journal l0l (February 2000) (reprinted in Portuguese

in 3 Cademos Do PPG Dir./UFRGS 197 (March 2005)

Affirmative Action and the Mistakes of Adarand, I 995 Annual Survey of American Law 401

(February 1996)

The Price of Apaftheid, 38 Howard University Law Journal 371 (May 1995)

Sins From the Past and Lessons For the Future: Elirninating Apartheid In South African Public

Accommodations and the Chaltenge To An Enlightened Judiciary, l2 Boston University

International Law Journal I (January 1995)

,,Yearning to Breathe Free": Legal Barriers Against and Options In Favor of Liberty In

Antebellum Virginia, with A. Leon Higginbotham, Jr., 68 New York University Law Review

401 (June 1994)

De Jure Housing Segregation in the United States and South Africa: The Difficult Pursuit For

Racial Justice, *itn n. Leon Higginbotham, Jr. and S. Sandile Ngcobo, 1990 University ofIllinois Law Review 763 (March I 99 i )

InternationalLaw, the Use of Force ln Self-Defense, and the Southern African Conflict,25

Columbia Journal of Transnational Larv 529 (December 1987)

,,See No Evil, Hear No Evil, Speal< No Evil": Developing A Policy For Disclosure By Counsel

To Public Corporations, 7 Journal of Corporation Law 285 (January 1982)

EDITORIALS

Voting Trump A Big Risk, Baltimore Sun A1B (September 21,2016)

America's Racial Soul, Baltimore Sun 415 (June 9,2016)

Saving The Dream For All, soI-o l8 Q\overnber/December 201 4)

Race-Based Affirmative Action Still Necessary, New York Times (Online)( Aptil27,2014)

Jackie Robinson, the Moderate Radical, Baltimore Sun A2l (April 15,2014)

4

E 000440

Ending Racial Disparities, Islamic Monthl)' 20 (Spring 2014)

Valuing Black Life, Baltimore Afro-American A8 (February 21,2014)

congress Must Act To Guard Our Most Important Right, orlando sentinel 414 (August 16,

2013)

Access and Fairness in the Fisher Affirmative Action Case, Baltimore Afro-American A7 (June

8,2013)

Action That's Still Needed, Baltimore Sun 419 (June 7,2013)

Ghosts of Jim Crow Haunt Us Still, Baltimore Sun 419 (January 24,2013)

The Case of the Missing Post-Racial Election, Baltimore Afro-American A7 (Novembet 6,2012)

A Request From Heaven to the President, Daily News 415 (January 31, 2010)

Is America Finally Ready To Elect A Black President?, Desert Sun B8 (October l6' 2008)

Racism Less Pervasive More complex, Baltimore Sun A2l (April 4,2008)

Recognition Long Overdue, Washington Afro-American A9 (March 31,2007)

worst Supreme courl Decision Ever continues To Haunt, washington Afro-American A8

(March 9,2007)

Setting the Record Straight, Washineton Afro-American A 1 1 (January 28,2006)

Hard-won victory Must Be Secured, Baltimore Sun c5 (August 7,2005)

Bush and the Black Vote, Washinston Afro-American 413 (October 30, 2004)

The courl Has Granted wide Deference To Colleges, chronical Review B11 (March 28,2003)

(reprinted in 63 Louisiana L¿wÅey.þy 697 (December 2003)

Townsend- The Clear Choice, Baltimore Afro-American A7 Q"ìovember 2,2002)

Democrats For Ehrlich? What A Confused Group!, Prince George's Journal Al I (October 31,

2002)

William Gosnell: Brov,tt's Unsung Hero, Baltimore Afro-American A6 (July 6, 2000)

Drum Majors For Justice, Baltimore Sun 417 (February 18, 1999)

Clendening-The Clear Choice, Baltimore Afro-American A5 (October 31, 1998)

5

E 000441

Bar Group Rolls up welcome Mat, Crisis Magazine l2 (September 1998)

A Military strike Against Racism, Boston Globe 415 (July 25,1998)

An American Tragedy: The Endurin gLegacy of Plessy,Baltimore Afro-American A5 (May 25,

19e6)

On Gender and Racial Issues Justices Suffer From Rare Disease, 2 Universib¡ of Baltimore

Alumni Masazine 21 (Fall 1995)

And Now The Hard Work Begins In South Africa, Boston Globe A14 (May 16,1994)

TRIBUTES

Judge Robeft Bell and,Racial Equality ln Jury Selection, 72 university of Maryland Law Review

1106 (October 2013)

Judge Harry Edwards, contained in Anruca¡l-AptEnlcau Ltvps 266, Oxford university Press

(February 2004)

Speaking Truth To Power,20 Yale Law and Polic)' Review 341 (July 2002)

11 (July 2001)Promises Kept, 6 fri can

who will carry The Baton?, 33 Loyola Los Anseles Law Review 1015 (August 2000)

A Man For All Seasons, l6 Harvard Blackletter Law Journal 7 (July 2000)

Saving Tlre Dream For All, Human Rights Maeazine 23 (May 1999)

Judge Higginbotham Will Be Sorely Missed, National Law Journal 426 (December 28, 1998)

Thurgood Marshall: Legal Strategist For The civil Rights Movement, 1997 Association for the

Study of Afro-American History 14 (November 1996)

SELECTED MEDIA APPEARAN CES

Guest, CNN Tonight (Discussing Presidential Power), CNN Television (February 6,2017)

Guest, CNN Tonight (Discussing Muslim Ban), CNN Television (February 3,2017)

Guest, CNN Tonight (Discussing Trump Inauguration), CNN Television (January 23,2017)

Guest, CNN Tonight (Discussing King Legacy), cNN Television (January 16,2017)

6

E 000442

Guest, CNN Tonight (Discussing Trump Transition), CNN Television (Januaty 5,2017)

Guest, CNN Tonight (Discussing Trump Victory), CNN Television (November 18,2016)

Guest, CNN Tonight (Discussing Trump Candidacy), CNN Television (September 16, 2016)

Panefist, Book TV (Discussing Racial Equality), C-SPAN Television (August 23,2016)

Guest, I I TV Hill (Discussing Black History), WBAL Television (February 28,2016)

Guest, 1 I News Sunday (Discussing Police Trials), WBAL Television (December 13, 2015)

Guest, CNN Tonight (Discussing Clinton Candidacy), CNN Television Q',lovembet 24,2015)

Moderator, After Words (Discussing Politics with Joy Reid), C-SPAN Television (September 12,

20r5)

Guest, Weekends with Alex Witt (Discussing Baltimore Riots), MSNBC Television (May 3,

2015)

Guest, Direct Connection (Discussing Freddie Gray Incident), MPT Television (April 27,2015)

Guest, CNN Tonight (Discussing Racist Language), CNN Television (April 22,2015)

Commentator, NBC News Election Coverage (Discussing Maryland Governor's Race) WBAL

Television Q.trovember 4, 2014)

Panelist, Book TV (Discussing Race Relations), C-SPAN Television (September 21,2014)

Guest, The Last Word (Discussing Voting Rights), MSNBC Television (May 21,2014)

Guest, Smerconish (Discussing Donald Sterling), MSNBC Television (April 30,2014)

Guest, The Cycle (Discussing Voting Rights Act), MSNBC Television (August 28,2013)

Guest, Piers Morgan Live (Discussing State of Florida v. Zimmerman), CNN Television (July

29,2013)

Guest, On Time (Discussing Shetby County v. Holder), WJZ Television (July 28,2013)'

Guest, The Cycle (Discussing Voting Rights), MSNBC Television (July 16, 2013).

7

E 000443

SELBCTBD AWARDS

Black Law Student's Association Award (2014 Outstanding Faculty Member)

Joseph Curtis designation (Endowed Professorship awarded 2013 by the University of Baltimore

School ofLaw

Power 100 List (100 most inf'luential blacks in law in2012) (OBABL Media)

Leadership In Law Award (25 most influential leaders in law in Maryland in20ll) (Daily

Record)

Educator of the Year (awarded 2009 by the Minority Business Summit)

Wilson Elkins designation (Endowed Professorship awarded 2004 by the University of Maryland

System)

Honorary Doctor of Humanities (awarded 2004 at Shenandoah University)

Women's Bar Association Award (2002 Outstanding Faculty Member)

Brown University Athletic Hall of Fame (2001 Group Inductee) (Member 1976 Varsity Football

Team)

Distinguished Faculty Award (2000 University of Baltimore Teacher of the Year)

James May Award of Excellence (1995 University of Baltimore School of Law Recognition of

Outstanding Teaching)

SBLBCTED SPEECHES

Keynote Speaker, "post-Racial Realities," Cornell University Diversity Lecture, Ithaca, New

York, March 15,2011

Keynote Speaker, "Hopeful Dreams," FEMA Black History Month Lecture, Washington' DC,

February 28,2017

Keynote Speaker, ,.peace With Justice," Social Security Administration King Memorial Lecture,

Baltimore, Maryland, January 1 1, 2017

I(eynote Speaker, "Race and Politics," Heman Sweatt Symposium at the University of Texas,

Austin, Texas, APril 28, 2016

Keynote Speaker, "Keeping Thurgoocl's Promise," Thurgood Marshall Lecture at the University

of Maryland Law School. Baltimore, Maryland, Apr\|7 ,2016

8

E 000444

Keynote Speaker, "Keeping the Dream Alive," James Campbell Matthews Lecture at Albany

Law School, Albany, New York, February 10,2015

Keynote Speaker, "Cause Lawyering," La Verne Law Review Symposium, Ontario, Califomia,

February 28,2014

Keynote Speaker, "Hopeful Dreams and Post-Racial Realities," University of Notre Dame

Diversity Lecture, South Bend, Indiana, November 14,2013

Keynote Speaker, "Ending Racism In Post-Racial America," Cleveland Marshall Law School

Constitution Day Lecture, Cleveland, Ohio, September 17,2013

Keynote Speaker, "saving The Dream For All," Delta State University's James Madison Center

Nellie Nugent Sommerville Lecture, Cleveland, Mississippi, September 11,2013

Keynote Speaker, "Dr. King's Dream Revisited," Widener Law SchoolDean's Diversity Forum,

Harrisburg, Pennsylvania, March 26, 2013

SELECTED AFFILIATIONS

Member, District of Columbia Bar

Member, NAACP

Member, National Bar Association

Member, Council On Foreign Relations

Member, Brown University Athletic Council

Former Chair, Maryland Attorney Ceneral's Task Force On Electronic Weapons

Former Co-Chair, O'Malley/Brown Transition Team Minority Affairs Working Group

Former President, Public Justice Center

Former Chair, AALS Committee on Recruitment and Retention of Minority Faculty

Co-Founder, Fannie Angelos Program For Academic Excellence

SBLECTED INFORMATION

References, Letters of Recommendation, Employment Evaluations, and Writing Samples

available upon request.

9

E 000445

HIGGINB OTHAM AF'F'IDAVITEXHIBIT 2

E 000446

HIGGINB OTHAM AFFIDAVIT EXHIBIT 2

E 000446

Bnr¡r.¡ E. FnosuÁI'TORNËY G[NI;RAL

Errz¡ssrrr F. Hlnn¡sCHìÈI DE}UIY,\T1'0RNEY GENERAL

Ts ¡ nuv¡:t urux VrcNln-e.¡eu

DEPUTY AT1'ORNIY CËNERAI"

Sn¡l on.r Br¡¡soN Bn¡.¡.¡rlnv

COUNSÊL TO 'I'HE GENEnaL ASSEMALY

K,rrrrnvN M. l(ovtDEPU Y COUNSIIL

Jrruvv M. McCovASS¡STANT ATTONDY GENÈML

Dav¡o \ù(/. Sr¡rwprn

^SSISlANT ATTORNEÎ GËNEMT.

THE ATTORNEY GENERAL OF MARYLAND

OFFICE OF COUNSEL I'O TI]E GENERAL ASSEMBLY

March 13,2015

The Honorable Ch¡is West303 House Office BuildingAnnapolis, Maryland 21 401 - 1991

l)ear l)elegate West:

You have asked for advice conceming the validity of certain provisions of the Nataiie lr4.

I-aPrade li4edical Marijuana Commis'sion Law' Specitìcallv' YoLì have asl<ed whether these

provisions are unconstitutional, It is my view that these provisions must be administered in

ãccorclauce with the United States Constitution, but, in the event that they were fcrund to be

Lurconstitutional, the;,t would be severable from the remainder of the lau"

liealrir - General Article, $ l3-3309(aX9Xi) provides that, in licensing growers of medical

rnarijna,na, tire Medical Marijuana Commission ("the Commission") shall:

l. Actively seek to achieve racial, etlmic, and geographic divcrsity 'when

iicensing rredical marijuana grorvers; and

2, Encclurage applicants who quali$' as a tninority brrsiness enterprise, aS

clefìnecl in $ l4-301 of the State Finance and Procurerncnt Artiole'

Ftrealth - General Article, $ 13-3310(c), urhich relates to ',hc licensing of dispensaries, provides that

the Comrnission shall:

(2) Actively seek to achieve racial, ethnic, and geographic diversity when

I icensirrg dispensarics.

ln rhe bill revicw lctter on House Bill 88'1 (Chapter 240) and Senate Bill 923 (Chapter 256)

of.2074,the Attorney Gencral advised "that these prcvisions be implemented consistent with the

provisions of the tlnited State s Constitution as clescribed tn llichmond v. -1,A. Craso¡r Co., 488 U'S'

+Ol if 989) ancl Fisher t'. University of Texos crt At'tstin,133 S.Ct. 2411 (2013)"' See Form Bill

Rcview letter.clated April I "t,2014. It is well-established that a race-conscious affiimativc acticn

program is subject to srrict scrr.rtiny ancl will be upheld by the courts only if it is nanowly tailored

io url1i*.,r. a cor¡pelling p¡blic purpo se. 91 Opinions of'the AlÍorney General I 81 ' I 82 (2006), citing

AdaranclconsÍructorl''lnc' v'7'ena' 5 t 5 tJ's' 200 (l 9c)5): cin'o'f Richmonclv' 'l''7' Croson co''488

ro4 r.EGIsr.AfrvE sERvtcEs BUÌLDING . 90 sl'ÂTE alRcl-r . ^NN^PoI.IS,

Ií^RYLIND 2t4ot-r99r

4ro-946-56oo . 3or-97o-56oo . ttx 4to-r46-i6ot . îru 4to'946-54ot ),ot'g7o-rlor

E 000447

The Honorable Chris West

March 13,2015Page2

U.S. 469 (19S9). The Croson case helcl that a governmental entity has a cornpelling interest in

reme{ying i,Jentified past and present race discrimination. Id. at 492,509, For this interest to be

.on.'p.¡ing, the government nlust be able to identify discrimination in the relevant market in which

the entity is a paiticipa nL. Id. at 501-504. ln acldirion, there must be a "strong basis in evidence" of

that discrimination at the time the program is established' Id' at 500, 510' in the context of

government contracting, which *ut ttt" subject of Croson, this requires a study showing a

;significa't statistieal jirpurity', belween the availability of qualified, willing, and able minority

subcontractors and the utilization of such subcontractors by the governmental entity or its prime

contractors, HB Rayve Co., Inc. v. TippetÍ,615 F.3d 233,241(4th Cir. 2010)' The Fisher case, for

our puïposes, confìrms that the tesl set out in croson still stands, and that a court will closely

scrutinize a government's justification of a racc-conscious plogranr and its evidence in support of

that program,

The provisio ns of Crçson and Fisherapply to ethnicity in.the same way as race' They do not,

however, apply to geographically consciout piog.u*t' Thus, the law should be read to have full

fbrce tç the extent that iireqri.es ih" Commission to seek geographic diversity to the extent possible'

Moreover, it is not unconititutional to encourage businesses of any type, including those in the

rninority business cnterprise program, !o apply to participate in any type of govetnment proglam'

Constilutional limits, hàw"uår, would prevént the Comr¡ission from conclucting race- or ethnicity

conscious licensing in the absence of a disparity study showing past discrimination in similar

programs. I am aware of no study that wollld .ou., gro*.r or dispensary lice nsees, oI even licensing'in

g"n"rul. Most State licensing programs license everyone who meets the licensing qualifications,

onã th6 woulcl not give rise to the abìlity to pick some and not othels. As a result, the efforts of the

Commission to seek raci¿l and ethnic cliversity among growers anrl dispensaries would have to be

limited to broacl publicity given to the availabiliry of the licenses and encouragement of those from

various gl'oups,

Even if the provisions are implcn,ented in a way that leads to a determination ol their

invaliclity, however,lt ìs my view thar they are severable fiom the remainder of the law' The primary

inquiry in tnis determinatiôn is what would have been the intent of the legislature had they larown

rhat therse provisions could not bc given effect. Davis v. State,294 Md' 370, 383 (1982)' Generally

courts will assume "that a legislative body generally intends its euactments to be severed ifpossible'"

Id; see a/so Article l, S 2i("[t]hc proviiions of'a1l statutes , ' are severable unless the statute

specifically provides that its prouirion, aïe not sevcrable."). Thus, "when the dominant purpose of

a statute may largeìy be canieã out notwìthstanding the invalicl provision, cotlrls will ordinarily sever

the statute and enforce the valid portion." Itt. al 384. In this case, it is clear that the program is

,,complete and capable of execuiìon," ¡higdal. v. slute,358 Mcl 308,324 (2000), without the

cliversity provisions. 'llreref-ore, it is our view that, ilibunct invalid, the diversity provisions would

be tleated as severable and the remainder oJ'the lalv would remain in ef-f'ect'

E 000448

'l'hc l-lonolabÌe Chr'ìs \\/est

March 13. 2015

Page 3

KMRikrnrwcstOl ,rvpcl

S tlcere v

.' '=*f'(.: I-.' I

l(athr'jn M. RoweÄssistant AttorneY General

E 000449

HIGGINB OTHAM AFF'IDAVITtr IT3tt

E 000450

HIGGINBOTHAM AFFIDAVIT EXHIBIT 3

E 000450

05 Application Review., MD ADC 10.62.08.05

. KeyCite Yellow Flag - Negative Treatment

Proposed Regulation

Code of Maryland Regulations

Title ro. Department of Health and Mental Hygiene

Subtitle 62. Natalie M. Laprade Medicaì Cannabis Commission

Chapter o8. Medical Cannabis Grower License (Refs & Annos)

COMAR 10.62.o8.05

.o5 Application Review

Currentness

A. The burden of proving an applicant's qualifìcations rests on the applicant

B. The Commission may deny an application that contains a misstatement, omission, misrepresentation, or untruth

C. An application shall be complete iu every material detail.

D. The Commission may request any additional information the Commission determines is necessary to process and

fully investigate an application'

E. The applicant shall provide requested additional information by the close of business of the l4th business day after

the request has been received by the applicant.

F. If the applicant cloes not provide the requested information within 14 business days, the Commission may consider

the application to be susPended.

G. The Commission intends to award the licenses to the best applications that most effìciently and effectively ensure

public safety and safe access to meciical cannabis.

H. The Comnrission shall provicle guidelines ancl detailed instrttctions lor subnritting the application lbrm fbr the

( ion-rmission's consideratlon

I. The Commission, or a Commission independent contractor, shall review for a pre-approval for a license the submitted

applications as ¿escribe<1 in Regulations .028 and .05E of this chapter. The applications shall be ranked based on the

lollowing u,eighted criteria:

(1) Operarional laclors will be afforded 20 percent weight, including:

(a) A detaile<i operational plan for the cultivation of medical cannabis; and

E 000451

.05 Application Review', MD ADC 10.62.08.05

(b) Summaries of policies and procedures tor:

(i) Cultivation;

(ii) Growth;

(iii) Processing; and

(iv) Packaging;

(2) Safety and Security factors will be afforded 20 percent weight, including:

(a) Detailed plan or information describing the security features and procedures;

(b) Detailed plan describing how the grower will prevent diversion; and

(c) Detailed plan describing safety procedures;

(3) Commercial horticultural or agricultural factors will be afforded l5 percent weight, including, experience, knowledge

and training in:

(a) Horticultural production; or

(b) Agricultural Production;

(4) Production control factors will be afforded l5 percent weight' including:

(a) A detailed quality control plan;

(b) A'detailed inventory control plan; and

(c) A detailed n-redical cannabis waste disposal plan;

(5) Business and economio factors will be afforded 15 percent weight, including:

.r .r-rl. .ir1i ;'; .: . jfl.::'ii"::l :':- :-\ j'ì:r';ii

E 000452

05 Application Review., MD ADC 10'62.08.05

(a) A b¡siness plan clemonstrating a likelihood of success, a suft'icient business ability and experience on the part of

the applicant, and providing for appropriate employee working conditions, benefìts and training;

(b) Demonstration of adequate capitalization;

(c) A detailed plan evidencing how the grower will enforce the alcohol and drug lree workplace policy

(6) Additional factors that will be afforded 15 percent weight, including:

(a) Demonstrated Maryland residency among the owners and investors;

(b) Evidence that applicant is not in a.rrears regarding any tax obligation in Maryland and other jurisdictions;

(c) A detailecl plan evidencing how the -erower will clistribute to dispensalies and prooessors; and,

(d) A list of proposed medical cannabis varieties proposed to be grown with proposed cannabinoid profìles,

including:

(i) Varieties with high cannabidiol content; and

(ii) Whether the strain has any demonstrated success in alleviating symptorns of specific diseases or conditions.

J. For scoring purposes, the Commission may take into acÇount the geographic location of the growing operation to

ensure there is geographic diversity in the award oflicenses'

Credits

Adopted Sept. 14,2015

Conrplete through Marylantl Register Vol.44, Issue 7, clatcd March 31,2011

coMAR 10.62.08.05, MD ADC 10.62.08.0s

irr l[)l .7 lhörrs()n lìr:itte rs. Nc cl;¡itll t,l irri-¿ìn¡l TJ S. (]rt-rvt:rlllncnt \liollts.lÌld ul'f)uetttntttt

,]

E 000453

HIGGNB OTHAM AF'F'IDAVITE,XHIBIT 4

E 000454


E 000454

Hogan, Froshconcerned about Ïackof d"iversÍty inMaryland.'s rtl ed-icalpot licensesDarryl Hitl, 72, a lifelong advocate for minorÌty advancement in

business and the first Ãfrican American on the University of

Maryland football team, was part of a team that applied for a

medical marijuana grow licenso and was denied' (Jabin

BotsfordÆhe Washington Post)

By Fenit NiraPPil Aususl26

Maryland Gov. LarryHogan (R) andAttorney General

Brian E, Frosh (D) have joined black state lawmakers in

expressing dismay about the lack of diversþ in

Maryiand's burgeoning medical-marijuana industry'

At the same time, the head of the legislative black

caucus is calling for legislation to ban elected officjals

from taking jobs in the industry' Del' Cheryl D' GIenn

(D-Baltimore), who was instrumentai in passing the bili

that tegalized medicai marijuana, said she's angrlrthat

another ieader in that effort later joined a company

secking a lícense to glow, plocess and sell the drug,

without publicly making clear his dual roles'

The controversies are the latest snags for Marylands

p otentially lucrative medical-mariju an a in dus Lry' which

has been plaguedby muttiple delays and missteps since

legíslation to legalize cannabis for medical use passed in

2O13.

E 000455

' r Lt¿ Lrù Lt t'J

(

Blectcbusíness le

This month, state regulators cleared 15 companies to

grow marijuana and 15 cornpanies to process the plant

into medical products. None of thebusinesses approved.

for cultivation are led- by African Americans, even

though the legislation seeks to create a racially diverse

industryin a state where nearly a third of the

population is black'

Glenn raisedDelegate Dan K. Morhairn (D-Baltimore

Couñty) has drawn crilicism for working on the iSs'e in amedical-marijuana legislation withoutdisclosing his role with a company applying Thursday

for a license io sell the drug' (Algerina meeting withPerna/Baltlmore Sun)

Hogan. She

pushed the governor to call for a special legislative

session this fall to address minority ownership, perhaps

by a¿thorizing regulators to award additional licenses to

mi n 61i1y-ewned cornpanies'

The legisiature's nexl legular session begins in January'

"We are not going to accept licenses being award"ed and.

people getting an unfair advantage in this billion-dollar

indrrslry with n o minority participation, " Glen-n s aid'

i-Iogan spokesrnal Doug Mayer says the governor

agrees that racial diversþ in the new industry is

impoltant bnt will not call a special session' Instead, the

governor has d.eployed his chief lobbyist, Chris ShanÌ<,

and. adviser l(eiffel Mitchell to explore options to

address the issue.

E 000456

The Maryland Medical Cannabis Commission operates

Índepend.ently of the govetnor's office, whichhas no say

in u¡ho gets marijuana licenses but appoints the

commission's members and executive director'

medical cp11_ld b e bis b-¿s-Utç-qq fn

MsrvþTILl

Thrii¡;.g1,6+glùçrhW,\ïii.åiii'grt#rËi¡dTiilIf &úrli,gËdWiir€$;t"-'

shrii.:.ierhô'rijjtla*ìrrnarlfuftnat.Íti*tt¡:" -¿'sr*i'¡i, r:'åiiit-: :'ltrii

g.,,¡ar$fl l"VJð;ti\.dMhlË{U/i"Gffi /r\,HH:rl'Çl;i':'.

Here's who wants to profit from growíng medical marijuana in

Maryland

The commission award.ed- preliminary licenses b ased on

rankings from outside reviewets, who read and scored

application materials with the nameÉ of people involved

red acted.,Ihe commission did consid.er geographic

diversity, m oving up lower-ranked applications to

approve licenses for growers in Prince George's and

Worcester counties in an effort to ensule that

cultivators weïe spread out across the state'

But the commission did not provide extra weight to

minority-owned companies, citing a2cl5 advice letter it

received frnm the Rttornew sere'r"¡l's n'ffice thnt sairl

E 000457

¡vqu a¡vvÁÀu auvquÉJ

hiåtory of racial disclimination would probablybe

unconstitutional

Afler Glenn and other black lav¡makers raised concerns,

the at[orney general's office said the commission should

not have concluded. from the letter that it wouid be

wrong to take the race of prospective marijuana

business owners into account.

Instead, Frosh spokeswoman Raquel Coombs said, the

commission could have researched whether there is

evidence of racial disparity in industries similar to

medical rnarijuana.

If there is, she said, the commission would be justified

in taking race into account.

Coornbs said simiiar efforts have ledto the state trying

to expand rninorityparticþation in other new

industries, including off-shore wind farming and

gaming.

"The attorney general shonglybelieves that this

industry should reflect the diversity of the state,"

Coombs said- of medical cannabis.

But Col. Harry Robshaw III, vice chairman of the

commission, saidthis proposed approach to achieve

racial drversitywas news to the cornmission. He said the

message from the office was crysta1 clear: It was too

early to grant raciai preferences.

E 000458

"It's ft'ustrating that somehow we should have

interpreted the letter differently, " Robshaw said'

Co ombs said Frosh's office has cleared marijuana

regulators to develop outreach programs to aLiract

applications from minority-owned companies'

ttçltuWlsgt,p.I.o-P\tsbçdrtrertípq!p-9! jspgft-sf j-e-qn,

to selltlæ

On a separate issue, Gienn said she is consi'ilering

iegislation to bar lawmakers from wori<ing with

medical-marijuana companies afler learning that Del.

Dan I(. Morhaim (D-Baltimore County) had agr:eed to

act as ciÌnical directorfol one such company'

Local Headlines newsletter

Daily headlines about lhe WashingtonSign up

|-e_s.leL- .". ..

Glenn says the dual roles, r'evealed by The Washington

Post last month, marle her "livid' and tainted the

process,

"f wasn't pushing tbr medical marijuana to fatten my

pockets, and,I am disappointed that it is evidently

E 000459

uv¡¡rv !¡,¡¡r¿l ^¡v

Y r sv svarrb ur¡ É¡v:¡¿f ,

l{,rong. It's just wtong."

Morhaim, a physician, says he's not a formal ernployee

or owner of Doctor's Orders, which was granted

preliminarylicenses to grow and process the drug in

Dorchester County and has dispensarylicense

applications pending.

Marylandlaw does not forbidlawrrakers fiom

sponsoring or voting on legislation affecting industries

inwhich theywork, ild Morhaim said.he clearedhis

posÍtion with the General Assembiy's ethics adviser.

Morhairn, who has advocated for medical marijuana for

more than a decade, did. not return a call or email

Friday seeking a response to Glenn's criticism.

30 Comments

Fenit Nirappil covers politics and government in Maryland,Virginia and D.C, He previously covered the Californ[a statehouseand suburban government outside Portland, Ore. Follow @FenitN

E 000460

HIGGI}{B OTHAM AFF'IDAVITtrXHIBIT 5

E 000461


E 000461

A Letter from the Chairman of the Maryland Medical Cannabis Commission:

I am writing in response to a recent Washington Posf news.article, in which the Maryland Attorney General's

office made public statements regarding the"Maryland Medical Cannabis Commission's licensing process' The

áàvice given to a client by its lawler shóuld be complete, confidential and thorough.

When drafting the original law for issuing licenses to grow, process, and dispense medicinal cannabis in the

state of Marytand, ¡-rË Cãmmisii"ñ lÀitiãrrv took everf step possible to include racial diversity as a weighted

component ót tne rrgrlátiôÀr, ih. rp""ifíc legislativi; inténi required the co.mmission to, "actively seek to

achiäve racial, ethniã, àÀo g"ogruphi'c diversit! when licensing medical marijuana growe_rs; and encourage

àpplicants who qualify ás a-miñor¡iy business ânterprise.. ." Heatth-General, Annotated Code of Maryland,

sections 1 3'3306(a) (i) (1 ).

The commission deliberately supported this language in the original statutory.language because of a.strong

belief that minority inclusion is oi þaramount imfortãnce to this new industry. After requesting the customary

tãgàt review, the öommission subsequenfly recbived thorough and compleie legal advice from the Maryland

Office of the Attornry G*n"rul statinj that ?ace-based mandãtes would violate the United States and Maryland

Constitutions. Based on tt.," Attorney"General's opinion to Delegate Chris West concerning this issue, the

Commission found it necessary to remove the provisions from the final regulations'

To be specific, an opinion letter dated March 1g,2015 to Delegate Chris West, written by Assistant Attorney

General Kathryn M. Rowe, stated:

.The provisions of Croson and Fisherapply to ethnicity in the same way as race' They do not, however,

apply to geographically conscior" ptogiáni s. Thus, the law should be read to have full force to the

àitónt tnatít requireê the Commission to seek geographic díversity to the extentpossíble tempñãsi" uào"ol. Moreover, it is not unóonstitutional to encourage businesses of any type,

including tnose in the minoiity business enterprise program, to_apply to participate in any type of

government p.érår. Consíitutíonal Iimits, howevel, would prevent the Commission from"conducting'ruã"- or ethnicity conscious licensing ín the absence of a disparity study showingpast discrimination in simílár programs: I am awa-re of no study that would cover grower or'dispensary

1icànses, or even iiceñsing in ge_nera.l[emphasis added].. Most State licensing programs

license everyone who meets the licensin"g quãtiticatioñs, ànd thus would not give rjse to the ability to pick

some and not others. As a result, the effórt's of the Commission to seek racial and ethnic diversity

among gro*"rÃ ãnd dirpun.uries would have to be limited to broad publicity given the availability of the

licenséJ and encouragement of those from various groups'"

The Attorney General,s office at the time of that opinion admitted that there was no such disparity study known

to exist nor did they promulgate other novel remedies'

l, as the Chairman, along with all of the other Commissioners, followed strict regulations and guide.lines defined

át tne neginning of'the aþplication process as required by law, to ensure a fair and objective selection process.

The Commission enlisted Towson University's Regional Êconomic Studies lnstitute ("RESl")to conduct the

evaluation of applicants through a double-biinded-process. Due to the Attorney General's opinion and the

chànge in the leþislative langùage as notecl above, there were no requirements to disclose race on the

ãppliõation. ln aäd¡tion, att iðeniífying information such as individual, entity, investor, and employee names was

réáacted. The Commissioners voteO only on coded and retJacted RESI applications.

We all know thaÌ this process was extremely competitive. The Commission received 145 Grower applications,

but could only grant up to l5 Grower pre-afprovais because of statutory limitations implemented by the

i"girtutrr". Áoäitionãilv, *" rãát¡." that thib'emerging industry creates numerous possibilities for growth and

"önori" opportunity fär many in Maryland. we tat<e our resþonsibility extremely seriously to ensure that

qù"iitv¡ng päiients, tñe sick and suffering of Maryland,.are provided wi{h a process to receive the most safe and

etrectiveïedicine possible. We remain dedicated to this mission and are confused to see the Attorney

General's office recent public statements regarding their position.

Finally, I would like to reiterate that the commission is committed to seeking and promoting racial diversity and

r¡norliy inclusion. We believe that diversity is in the best i.nte.rest of the industry and an important

,.uiponêinirity. The Commission will continu'e to work with the legislature to help solve these complex problems.

Paul Davies, M.D., ChairMaryland N/edical Cannabis Commission

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5t1?,2017 Panel awards licenses for 102 marijuana dispensaries - Baltimore Sun

g¡r^t

Panel awards licenses for Lozmarijuana disPens aries

Medical cannabis won't be available till lat e 2oL7 or 'LB

By Pamela Wood The Baltimore Sun

Maryland moved. another step closer to making medical marijuana available to patients

with the announcement Friday of preliminary licenses for roz dispensaries across the

state.

The companies picked to run the dispensaries now must undergo additional review by

the state and pass inspections before opening. They'll also have to wait for Maryland's

growers and processors to produce medical cannabis products, a process that has been

complicated by litigation and political wrangling'

Maryland's medical marijuana program - already off to a slow start - might still be a

year or more away.

"patients probably won't be served until late zotT or early 2018," said Darrell

Carrington, executive director of the Maryland Cannabis Industry Association. "That's

the reality."

The Maryland Medical Cannabis Commission selectetl the preliminary dispensary

licensees in late November, but didn't unveil their identities until Friday. The list was

posted on the commission's website.

One company selected is connected to state Del. Dan K. Morhaim, who faces a

legislative ethics inquiry for advocating for the industry while also working for a

company seeking a lucrative License.

Morhaim, a Baltimore County Democrat, agreed to be clinical director for Doctor's

Ord.ers, which secured preliminary licenses to grow and process cannabis this year. The

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S¡Z2O1T panel awards licenses lor 102 marijuana dispensaries - Baltimore Sun

company won a license Friday to operate a dispensary in Southeast Baltimore.

Morhaim, a physician, has said he should have disclosed his relationship with Doctor's

Orders more publicly. He declined to comment Friday'

Ten of the dispensary licenses announced Friday went to companies that have

preliminary licenses to grow the drug.

The 15 companies that received preliminary licenses to grow cannabis were also eligible

to apply for dispensary licenses. AJI ro that sought a preliminary dispensary license

received one.

The other 92 companies are scattered across the state. Up to two stand-alone

d.ispensaries were allowed in each of Maryland's 4T legislative districts.

In most districts, two companies were awarded licenses. Two districts - District z in

Washington County and District 4r in Northwest Baltimore - had only one company

win a preliminary license.

Some districts had more than two companies receive preliminary dispensarylicenses.

Companies that hotd a preliminary grower license and also sought a dispensary license

d.id not count toward the two-per-district total'

preliminary dispensary licensees were awarded to four companies in District t7 in

Montgomery, which includes Gaithersburg and Rockville. Seven other districts saw

three companies receive licenses'

The commission listed the winning dispensary licensees only by name and legislative

district. The companies' addresses won't be made public until they receive any

necessary local approvals and the proposed sites are inspected and approved by state

regulators.

Company or¡mership information was not immediately available'

Many of the companies used. wordplay in their names. In Baltimore County, one is

named. Cannavations MD and another is called Chesacanna. MaryLeaf and PharmaCann

plan to do business in Montgomery County'

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S.12J2O17 panel awards licenses fol,l02 mari.iuana dispensaries - Baltimore Sun

The commission picked.winners of preliminarylicenses based on appÌications that

shielded the identities of the applicants.

Towson University's Regional Economic Studies Institute was directed to rank each

applicant without regard to its identity. Towson's rankings guided the commission's

vote.

Dr. paul W. Davies, the commission chairman, said the panel received more than 8oo

applications to open dispensaries'

The number was inflated because some companies applied to open a dispensary in every

single legislative district. By law, an applicant can hold only one dispensary license.

Davies said announcing the dispensary licenses will help keep momentum going for the

fledgling industry.

But the effort still faces obstacles.

Three companies that were passed over for preliminary growing licenses have sued the

commission. with those lawsuits pending, none of the prospective growers and

processors granted preliminary licenses have secured final licenses.

Black lawmakers in the General Assembly have criticized the commission for not taking

racial diversity into account when awarding the licensees. Some lar¡,tmakers have

d"iscussed introducing tegislation on cannabis licenses during lhe zotT General

Assembly session, which opens Jan. tt'

Maryland's med.ical marijuana program, first authorized in zo14, has been one of the

slowest in the nation to launch.

Davies said the state can now focus on setting up the software programs and staffing

that will be needed to regulate the cannabis industry, in spite of unresolved legal and

legislative challenges.

He said the commission also will work to educate doctors and patients about the pros

and cons of medical cannabis'

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5¡272017 panel awards licenses for 102 marijuana dispensaries - Baltimore Sun

The commission plans to hire a consultant to review what steps - if any - it could take

to improve diversity in the state's nascent medical marijuana industry.

"It's very much at the forefront of our efforLs to make sure we have ethnic and racial

diversity throughout the industry," Davies said.

Carrington, of the industry association, said the dispensary license announcements were

important. Now, he said, the winners can nail down their locations, refine their

operating procedures and hire and train employees. That will allow the dispensaries to

be ready to sell once growers and processors begin producing cannabis products.

Carrington said anticipation was high waiting for the state's announcement.

He refreshed his browser all afternoon, and as soon as the list was posted, his phone

began ringing with calls from companies that won licenses.

"It's great we have these things moving forward," he said'

[email protected]

twitter. com/pwo o drePorter

Article 19 of 77 NEXT ARTICLE >

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HIGGINB OTHAM AF'FIDAVITEXHIBIT 7

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Uhc hln"rhington ffoCItMaryland Politics

Medical-pot regulators inMutyland blastAG forconflictin$ advice on racialdiversity

By Fenit Nírappíl September I,2016

Medical marijuana regulators on Thursday released a letter criticizing Maryland Attorney General Brian B' Frosh (D) for what

they caìled conflicting information about whether the state should consider racial diversity when awarding licenses to

prospective cannabis businesses.

The Maryland Medical cannabis commission is facing outrage from policymakers and some prospective companies because

minorities lead f'ew of the 3o businesses that the commission approved to grow and process marijuana for medical purposes'

The state law legalizing medical marijuana in Maryland requires the commission to "actively seek to achieve" racial and ethnic

diversity in the inclustrY.

But r.egulators ultimately decided against giving pr-eferences to minority applicants, citing a zo15 advice lettel flom the

attorney ge'eral,s office that said such a move would be unconstitutional unless there was a demonstrated history of racial

disparities in the industrY.

In recent weeks, Fr.osh and his office have backecl away from that letter, telling The Washington Post that the commission had

ways to take race into account after all'

officials in the attomey general,s office said it would be possible to justify racial preferences if the commission conducted a

study shor,r.i¡g racial disparities in industries similar to medical marijuana'

The letter to Frosh from paul Davies, chairman of the cannabis commission, sairì the attorrey general's office did not propose

such "noveì remedies" when it warned against race-conscious licensing'

E 000469

.The commission is cornmitted to seeking and. promoting racial diversity and minority inclusion," the letter said' "we believe

that diversity is in the best interest of the industry and an important responsibility'"

Davies told the Baltimore sun on Thursd.ay that he was planning to meet with Frosh to cliscuss ways to increase racial cliversity

when awarding as many as 94licenses for medical malijuana clispensaries. Frosh's office confirmed a meeting next Tuesday but

declined to comment on the letter.

The lack of minority involvement in the nascent ind.ustry has prompted threats of legal challenges and proposals for legislation

that would offer ways to include more minority-owned businesses.

Gov. Larry Hogan (R) has assigned two top staffers to look at ways to address the issue

Fenit Nirappil covers politics and government in Maryland, Virginia and D.c. He previously covered the california

statehouse and suburban government outside Portland, ore' v Follow @FenitN

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HIGGINB OTHAM AF'FIDAVITITBtt

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5t1212017 Maryland medical marijuana panel will hire diversity consultant - Baltimore sun

Maryland medical marijuana panel witl hirediversity consultant

B)'Erin CoxThe Baltimore Sun

SHARE THIS fwFollowing criticism, Maryland's medical marijuana panel plans to hire a diversity consultant

NOVEMBER 2A, 2016, 7 :23 PM

T he Maryland Cannabis Commission announced Monday it will hire a consultant to review what steps -if any - it could take to improve diversity in the state's nascent medical marijuana industry'

The consultant will determine if it is feasible to conduct a study of whether minorities have been unfairþ

excluded from the industry among other tasks. Such a determination would allow Maryland to consider race

when awarding ìicenses to grow, process or distribute marijuana for medical use.

The announcement follows the filing of a lawsuit alleging the commission improperþ ignored race when

evaluating applicants for licenses, and caìls by African-American lawmakers to halt the licensing process.

Nearly all the firms that have won preliminary licenses are owned by white men'

A state law requires the commission to "actively seek to achieve" racial diversity'

The commission has said it was following the advice of the state attorney general's office when it declined to

include race-based sclcction criteria in applications'

The attorney general's office had said it would be unconstitutional to do so without first completing a disparity

study.

Hiring a consultant will not delay the licensing process, officials said. The commission expects to award final

licenses to grow, process and dispense the drug in time for the entire program to be up and running this

summer

pìans to hire the consultant were announced at a meeting in Ellicott City, where the commission also selected

' I l'j r"'' : ''

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.

htto://www.baltimoresun.com/news/marvland/bs-md-medical-marijuana-diversity-2016112&story.html1t3E 000472

S.1Z2O17 Maryland medical marijuana panet will hire diversity consultant - Baltimore Sun

patrick Jameson, the commission's executive director, said Monday the consultant wilt review "the whole big

picture" of diversity in medical marijuana'

It was not immediately clear what steps the consultant would take. Jameson said he was not sure it was

possible to do a disparity study on a new industry'

It was unclear whether the consultant would study Maryland's industry as it stands now, the medical

marijuana industry in other states, or review data from other industries that could shed light on conditions for

minorities trynng to get into the medical cannabis business in Maryland.

Del. Cheryl Glenn, leader of the Legislative Black Caucus and an architect of the medical cannabis law, called

talk of studying the feasibilþ of a disparþ study "ridiculous'"

"It shouldn't be any question in anyone's mind," said Glenn, a Baltimore Democrat. "obviously, marijuana is a

new industry for Maryland. There's no disagreement about that. But you don't have to look at marijuana to see

disparities.

"Look at the current pharmaceutical industry. Look at the issues for blacì< farmers.

"This commission never ceases to amaze me'"

Alternative Medicine Maryland filed a lawsuit in Baìtimore Circuit Court last month alleging the commission

illegally disregarded racial diversity when selecting applicants.

Jameson declined to discuss the lawsuit but said companies selected to receive the 15 preliminary licenses to

grow and r5 preliminary licenses to process marijuana have "significant minority participation" in their ranks'

The commission discussed the lawsuit in a closed-door meeting.

Jameson also said the commission is "highly encouraging" businesses to "engage and recruit minority owners'

investors and employees where practical"'

Glenn and other members of the Black caucus argue that working for a cannabis company is not eqrtivalent to

owning a company that holds one of the lucrative licenses'

She said Monday that the caucus would not accept the results of a study conducted at the commission's behest'

,,If they're hired by the commission, then we don't trust them," she said. "\Me don't trust the commission at this

point."

Darrell carrington, executive director of the Maryland Cannabis Industry Association, said he would "wait and

http://www.baltimoresun.com/news/maryland/bs-md-medical-marijuana-diversity-2016112&story htmI 213E 000473

St12l2O17 Maryland medical marijuana panel will hire diversity consultant - Baltimore Sun

separately, the commission said it used a Nobel Plize-winning optimization algorithm to heþ determine which

of the more than 8oo dispensary applicants would receive a license.

several companies applied to open dispensaries in all of Maryland's 4T legislative districts. No company can

hold more than one dispensary license.

Ten of the 15 companies that were awarded preliminarylicenses to grow marijuana also won dispensary

licenses, Commissioner Shannon Moore said.

Maryland,s medical marijuana program has been among the slowest in the country to get off the ground' The

law first passed in zor3, was reunitten in 2014, and was then expanded to allow a wide range of medical

professionals, including dentists and podiatrists, to recommend the drug'

The state allows medical professionals to recommend marijuana to treat a long list of ailments. It limits how

many licenses can be issued to grow, process and dispense the drug'

The prospect of a market with broad demand and limited supply sparked intense interest from investors, who

submitted more than three times as many applications as regulators expected'

commission chairman Dr. paul Davies said Monday that Maryland would not have been inundated with

applications if it had not set up a good program'

,,we have moved as fast as possible," Davies said. "The only delay that we have seen is because of our success'"

ccor @ ba lf .sLtt'¿. cotl 7

ftaitt er . c om / E r in atThe Su n

Copyright A2017,The Baltimore SLrn, a Baltirrore Sun l\4edia Group publication lPlace an Ad

This article is related to: Nobel Prize Awards

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HIGGINB OTHAM AF'F'IDAVITtrXHIBIT 9

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STATE OF MARYLANDOFFICE OF THE GOVERNOR

LARRY HOGANGOVERNOR

April21,2017

Jimmy H. Rhee

Special Secretary of Minority Affairs

100 Community Place, 3d Floor

Crownsvi 1l e, ÌvD 213 02

Dear Special Secretary Rhee:

pursuant to Maryland State Government Article, Section 9-305, I am directing the Governor's

Offrce of Minority Affairs (GOMA) to initiatc a disparily study of the state's regulated medical

cannabis industry and market. GOMA should work together with the Natalie M. LaPrade

Medical Can¡abis Commission and the Maryland Department of Transportation to complete a

disparity study as expeditiously as possible in o¡der to ensure diversify in Maryland's medical

cannabis industry'

while a disparity study was contemplated during this past legislative session, there is no

approved bill for me to sign that would initiate this process. As the issue of promoting diversity

is of great importance to me and my administration, your office should begin this process

immediately in order to ensule opporlunities for minority participation in the industry'

Thank you for your assistance and leadership in addressing this important matter'

FIogan

r

STATE HOUSE, ANNAPOLIs, MARYLAND EI40I(4¡o)974-3901 l-soo-all-4336

TTY USERS CALL VIA MD RELAY

E 000476

E,XHIBIT C

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EXHIBIT C

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Plaintiff,

NATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSION, ¿/ ø/

Defendants

IN TIIE

CIRCUIT COURT

FOR

BALTIMORE CITY

Case No.: 24-C-16-00580 I

Judge: Barry G. Williams

*

i.

*

*

*

*

t< {< * * {< d< * *l< + * {<

AFFIDAVIT OF DR. GREGORY DANIEL, MANAGING MEMBER'

1. I am over the age of 18 years, a resident of New York, competent to testiff, and

have personal knowledge of the facts set forth herein'

Z. I am the managing member of Plaintiff Alternative Medicine Maryland, LLC'

3. Plaintiff Alternative Medicine Maryland, LLC has raised and/or secured

commitments for in excess of Ten Million Dollars ($10,000,000) in capitalization to be

utilized and invested in a medical cannabis growing operation in Easton, Maryland'

4. plaintiff Alternative Medicine Maryland, LLC is also actively seeking to secure

medical cannabis research parlnerships with several companies in Canada i¡ an effort to

optimize the efficiency and effectiveness of any future medical camabis product'

5. plairtiff Alternativc Medicine Maryland, LLC filed a tìmely application to

grow medical cannabis pursuant to the Defendant Natalie M. Laprade Maryland Medical

cannabis commission's scheme to license medical cannabis gro\^/ers in Maryland'

6. plaintiff Alternative Medicine Maryland, LLC was not awarded a Stage 1 pre-

approval to obtain a license to grow medical cannabis in Maryland.

7. Subsequent to plaintiff Alternative Medicine Maryland, LLC being informed by

E 000478

the Defendant that it had not been awarded a Stage 1 pre-approval to grow medical cannabis'

Plaintiff came to believe that the law was not followed in the stage 1 licensing process'

8. Thereafter, Plaintiff Alternative Medicine Maryland, LLC hired counsel who

investigated the aforementioned allegations, filed a complaint, and is currently active in the

discovery process.

g. In light of the decision not to award Alternative Medicine Maryland, LLC a

stage 1 pre-approval to obtain a license to grow medical cannabis in Maryland' Plaintiff

currently is not permitted, and has no prospects, to grow medical cannabis in Maryland for

the foreseeable future.

10. In light of the decision not to award Alternative Medicine Maryland, LLC a

Stage I pre-approval to obtain a license to grow medical cannabis in Maryland' Plaintiff

currently is not permitted, and has no plospects, to benefit economically from growing

medical car¡rabis in Maryland for the foreseeable future.

11. I am aware of a recent media repoft, attached as Exhibit 1, which states that one or

more stage 1 pre-approved growing licensees have applied to receive final Stage 2 approval and

growing licenses. This media repofi also indicates that the Defendants have scheduled inspections

for one or more medical cannabis grow facilities; a necessary step in issuing the final licenses to

grow.

12. I have also read the letter from Chainlan Paul Davies of the Maryland Medical

Cannabis Commission, attached as Exhibit 2, stating that Maryland's medical cannabis "industry

creates many possibilities for growth and economic opportunity," which is consistent with my

understanding the of economic impact of obtaining one of the I 5 stage 1 license pre-approvals

to grow medical cannabis in Maryland'

2E 000479

13. If and when Stage 2 final licenses to grow medical cannabis are issued, Plaintiff

Altemative Medicine Maryland, LLC will be immediately, substantially and irreparably

harmed, and otherwise forever precluded from obtaining one of the first 15 licenses to grow

medical cannabis in Maryland.

14. I have reacl an aÍicle, attached as Exhibit 3 and am now aware that, in

alignment with Plaintiff Alternative Medicine Maryland, LLC's claims, Maryland's

Legislative Black Caucus has taken issue with the lack of racial and ethnic diversity amongst

the Commission's 15 Stage 1 pre-approved licensees. The article I read indicated that

..fl]awmakers and several advocates said fthat] letting other businesses move forward while

leaving African-American [businesses] behind - even if they are later awarded licenses - was

unacceptable" in that "[t]hose minority-owned companies...would be put at a disadvantage if

they didl't start at the same time in u4rat"s expected to be a multibillion-dollar national

industry...with national sales of legal marijuana [projected] to hit $21.8 billion by 2020,

generating as much or more revenue annually as the National Football League-"

15. The economic harm to Plaintiff Alternative Medicine Maryland, LLC, in not

being awarded one of the 15 Stage 1 pre-approvals, in not being awarded one of the a Stage 2

final licenses to grow medical cannabis, and/or in potentially receiving a growers license more

than 12 months after the initial 15 Stage 2 licenses are issued, will result in immediate.

substantial and irreparable harm to Plaintiff Alternative Medicine Maryland, [,LC

I HBREBY DBCLARE AND AFFIRM UNDER THE PENALTIES OF PERJURY THATTHE CONTENTS OF THE FOREGOING AFFIDAVIT ARE TRUE, ACCURATE AND

CORRECT TO THE BEST OF MY KNOWLEDGE,INFORMATION AND BELIEF.

é. u-

DA GREGO L, M.D.

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trXHIBIT 1

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EXHIBIT 1

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Despite controversY, Maryland medicalmaryuana grower on brink of starting cultivation

Taking a tour of ForwardGro, one of the 1 5 pre-approved medical marijuana growers in the state. (Kim Hairston / Baltimore sun)

iìy Ììrin Coxlhe Baltrmore 5ull

APRIL 29, 2017. 8:iB Plvl

S ince lay¡makers approved medical marijuana in Maryland, the nascent industry has been mired in legal

and political controversY'

A judge is deciding whether the state improperþ awarded licenses to grow and process the plant' Black

lawmakers said minorities didn't have a fair chance of getting those licenses. Now the governor has ordered a

study.

ForwardGro isn't waiting to see how it all turns out'

E 000482

ForwardGro is one of z3 companies licensed to grow or process marijuana in Maryland for patients suffering

from cancer, ep¡epsy and other conditions. Amid the uncertainty that has slowed the development of the

industry, most are forging ahead with costþ prans to build elaborate growing operations that could have crops

ready as soon as August.

,,we,re very excited that some of our members are 30 days away from pranting their first plants," said Jake van

wingerden, chairman of the Maryland whoresale Medical cannabis Trade Association. "You'll see product in

the marketplace bY this fall"'

van wingerden, president of sunMed Growers in cecil county, said his company expects to finish construction

of its facilþ in Jury. At a meeting this month of his association's 13 growers, he said, "everybody expressed

optimism that they are on sched'ule'"

ForwardGro and its sprawling 2-acre compound in southern Anne Amnclel county is poisecl next week to

receive finai inspection to secure a license to grow medicai marijuana, company executives said'

As early as next month, the Maryland Medicar cannabis commission courd ailow them to turn on the lights

and begin growing the first med,ical marijuana plants - more than four years after the state made it legal'

on a recent afternoon, the ForwardGro executive team navigated around electricians and painters, chatting

with countybuilding inspectors and envisioning what the massive cavern would look like once workers in

medical scrubs and hairnets finaþ begin growing the potent pot for patients'

,,I,m going to be a mess when we start growing," chief Financial officer Gail Rand said'

Rand spent years lobbying the regislature to regalize medicar marijuana to herp children rike her son, Logan,

who has epilepsy. one of the company's first products will be a strain she picked out for him'

,,I'm looking to give this to my 7-year-old son," she said' "That's my standard of quality'"

The facility wil be capable of generating g,ooo pounds of medicar marijuana each year, with a retail value of

roughly g45 million. ForwardGro and other growers will selì their products wholesaie for less than that to a

processor who will turn them into oils, tinctures or topical creams. or they will prepare it to be inhaled fÏom

vaporizers or smoked the old-fashioned way'

up to 94 dispensaries will sell medical marijuana to registered patients who have had the drug recommended

by a certified physician. The Arcview Group, a marijuana industry research group, estimates Maryland's market

wiìl be worth |tzg.Z million by zozo'

whire ForwardGro is not certain how big the market will be - 4,673patients have registered in the past three

E 000483

It also built the sheil of a processing center, which company executives said can be an active lab within six

weeks of getting the green light from the state'

And the 1s3-acre property has enough rand to accommodate up to z4 acres of greenhouses, which theoretically

could grow zt6,ooo pounds of marijuana a year'

The complex is set off a rural road, below the embankment of the former mine. Its address is marked in spray

paint. There are no signs for ForwardGro. A dilapidated trailer at the entrance belies the multimillion-dollar

operation being built.

,,\Me d,on't mind that it,s hard to find," Rand said. "we'll never have a lot of people come through here'"

By law, the operation is encircled by razor wire and patrolled z4 hours a day by two armed guards'

Inside, each acre cost eight times more to build than a traditional greenhouse'

An elaborate cümate-control system detects the intensþ of sunlight and the floor temperature, and

automaticaþ ad.justs to produce the optimum warm, s*nny growing conditions favored by pot plants.

water, kept at a brisk 55 degrees, trickles down a cooling wall at the end of greenhouse' The system is poised to

blow moist, cool air across the room if the summer sun heats the room half a degree too hot'

A series of overhead fans simulate a natural breeze to strengthen the plant stems, because stronger plants can

support larger marijuana flowers and give a better yield. The floors can radiate heat upward to promote faster

root growth.

water drarrrn from on-site springs is treated, oxygenated, and filtered in a specialized system, then infiltrated

with a mix of fertilizers that is automaticaþ dripped onto the plants. A series of screens can be drawn across

the ceiling to adjust the light intensity, and overhead lamps can simulate natural sunlight during the darker

winter months.

,,Everything in here is controlled.," said Austin Insley, ForwardGro's director of cultivation' "we can reaþ

manage this on our Phones."

Data about the growing conditions are fed into a computer, which is connected to an app on Insley's iPhone' If

the humidity unexpectedly dips at 2 a.m. on a Tuesclay, for instance' Insley will get an alert'

so much of the greenhouse is automated that when the compound is fuþ operational' it will employ only about

r5 people.

Marvlanrì forbids srowers from rsins nesticirìes or firnsicides- so worì<ers will lreat lhe srow snace like an

E 000484

,,They,re using more stuff on food you buy in the supermarket than we're allowed to use on the cannabis,"

Insley said.

Huge fans recycle the air in the greenhouse every minute. outside, copper coils ringed with a spongelike

material emit essential oils that darnpen the pungent scent of marijuana plants as that air is released'

other operations are ramping up around the state. Phil Goiclberg, chief executive of Green Leaf Medical in

Frederick county, said the company will produce 32o pounds of "high-quality" cannabis at its 45,ooo-square-

foot facility each month, plus 6o pounds of lower-grade "trim" to sell to processors'

He said his firm is about eight to ro weeks from being ready for inspection. He hopes to have medical cannabis

products on the market bY Oct. r.

Goldberg said Green Leaf has lined up 3r prospective dispensaries to distribute its prod'ucts statewide' He said

the company would like to be first to the market, but doesn't see that as essential'

"We want to make sure it's done right," he said'

ForwardGro, Green Leaf and the other growers will be required to send off samples for testing at a state-

certified lab such as Steep Hill Maryland in Columbia'

"We will be ready for them," saicl Dr' Andrew Rosenstein, Steep Hiìl Maryland's CEO'

The company has built out a 2,ooo-square-foot lab in a business park, Rosenstein said, and will have all its

testing equipment delivered next week'

steep Hill Maryland will test for the presence of eight heavy metals, any pesticides, and an array of solvents

used in processing the marijuana.

"It's a very regulated market," Rosenstein said'

The courpa'y, which has labs across the country, has a location in washington that tests medical marijuana for

patie'ts and users. such testing is not required in washington, but helps companies market their products'

Labs must be inspected and certified by the state. But unlike medical marijuana growers' processors and

distributors, they are not required to seek a license'

Rosenstein said the company endured extra expenses and setbacks from a year of uncertainty stemming from

legal chailenges to the state's licensing process and political debate in Annapolis about over whether to make

adjustments.

E 000485

The commission had awarded ricenses to two companies that had ranked rower in the state's scoring system'

The commission said it awarded those ricenses to achieve greater geographic diversity in the industry'

The Legisrative Black caucus has demanded that extra ricenses be awarded to create greater minority

participation in the industry. No African-American-owned company received a preriminary license to grow

cannabis

The Genei.¿rl Assenbry urtimateþ did not pass legislation to change the industry. But the ìawsuits are moung

forward. Theoreticaþ, a judge courd decide the commission needs to start the entire process over again'

,,It's been a big stress for the businesses that are trying to get ready," Rosenstein said' "we couldn't exactþ be

sure when we had to be readY

,,It,s probabry cost us severar hundred thousand in carrying costs and derays while we're waiting' It's been tough

to swallow."

ForwardGro executives say they,re ready but stüÌ uncertain about ali the next steps before they can bring in

plants and start cultivating'

,,\Me d.on,t know, because no one in the state has done this before,'' Rand said'

A spokeswoman for the Maryrand Medical cannabis commission wourd not sayhow many companies have

requested final inspections or when the agency would grant final licenses'

The company wi* not say where the initiar batch of prants wi[ come from. It's a ferony to transport clones

across state lines.

"It's immaculate conception," Rand said'

BaltimoreSunreporterMichaelDressercontributedtothisarticle.

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E,XHIBIT 2

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EXHIBIT 2

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A Letter from the chairman of the Marytand Medical cannabis commission:

I am writing in response to a recent washingto_n Posf news article, in which the Maryland Attorney General's

office made public.tui"rnãÃìr regarding trJnrtãrytand Medical cannabis commission's licensing process' The

áOu¡"" given to a client by its law"yer shóuld be complete, confidential and thorough.

When drafting the original law for issuing licenses to grow process, and dispense medicinal cannabis in the

state of Maryland, tnã Commission initiãlly took everi step possible to include racial diversity as a weighted

component of the rugulutiänr,-irl" "p".ifíc

legislativá inteni required the co.mmission to, "actively seek to

á;hiu"à racial, e¡rniË, anfgéogrãph¡'c diversitlr when licensing medical marijuana growers; and encourage

äópiúunt" *rro quar¡ivä" u"miñoriiy business ánterprise.. )' Health-General, Annotated Code of Maryland,

sections 1 3'3306(a) (i)(1 )'

The commission deliberately supported this language in the original. statutory^language because of a.strong

nätieittr"t minority inclusionis oiþarumount impärtãnce to this ñew industry. After requesting the customary

l";; r;;þ*, the óommission "ubsequenity

rá"b¡u"o thorough and complete legal advice from the Maryland

Office of the Attorney General stating thaiiace-based mandätes would violate the United States and Maryland

constitutions. Basej oÁirl" Ãttornuy e "neral's

opinion to Delegate, chris west concerning this issue, the

Commission found it necessary to remove the provisions from the final regulations.

To be specific, an opinion letter dated March 1g,2015 to Delegate chris west, written by Assistant Attorney

General KathrYn M. Rowe, stated:

,,The provisions of Croson and Fisherapply to ethnicity in the same way as race. They do not, however,

appty to g"ogiáph¡ðállv ãoniciou" piogiänir . Tht1s, the law should be read to have full force to the

extent tnat ii läqtiirei tne Comniission to seek geographic diversity to the extentpossible turpñãri" áão"o], Moreover, it is not unðonãt¡tút¡onal to encourage businesses. of any type,

including tfrosã in ttre m¡noiity business enterprise program, to _apply to participate in any type of

government õróiàr. Cõi"i¡trt¡onal limits,' however, would prevent the Commission from

conducting race- or ethnícity coisc¡ous lícensing in the absence of a dispa.rity study showing

past díscr"imiiation in símilár progrqms: I am aware of no study that would cover grower or

dispensary ii""ni"", or even iiceñsing in ge_neral [emphasis added]., Most State licensing programs

license "u"ryonã

who meets the liðeñsin"g quätiiicatioñs, ànd thus would not give rise to.the ability to pick

some and not others. As a result, tre efiórt's of the commission to seek racial and ethnic diversity

among growers and dispensaries would have to be limited to broad publicity given the availability of the

licensäiand encouragement of those from various groups."

The Attorney General,s office at the time of that opinion admitted that there was no such disparity study known

to exist norã¡d they promulgate other novel remedies'

l, as the chairman, along with all of the other Commissioners, followed strict regulations and guidelines defined

ät iñ" beginning ot'tÀe a"pplication process as required by law, to ensure a fair and objegt]v_e selection process'

The Commission enlisteà'Towson Úniversity's Regional Économic Studies lnstitute ("RESl") to conduct the

evalualion of applicantr irlrougl"' a double-bíindedþrocess. Due to the Attorney General's opinion and the

ãf..,ärg" ir tñe tãgistative langùage as noted above, there were tro requirements to disclose racc on the

áóôiiãot¡on. In uäo¡tion, uìi iã"niítying informarion such as individual, entity, investor, and employee names was

rååacted. The Commissioners voied only on coded and redacted RESI applications

We all know that this process was extremely competitive. The Commission received 145 Grower applications,

but could only grant up to 1S Grower pr"-ufprouais because of statutory limitations implemented by the

legislature. Add¡tionãily, we realize_that ilrii'emerging industry creates numerous possibilities for growth and

""äñóri, opportunitf iär rãnl ¡lMárytand. we iáke our resþonsibility extremely seriously to ensure that

õ"áiitv¡.õ pãiì"nt", tÉe sick and suffering of Marytand, are provided wíih a process to receive the most safe and

effective medicine possible. we remairidedicatäd to this mission and are confused to see the Attorney

General's office recent public statements regarding their position.

Finally, I would like to reiterate that the commission is committed to seeking and promoting racial diversity and

,.ninð,íiv inclusion. we believe that diversity is in the best i.nte.rest of lhe industry and an important

,ä"pónä¡uil¡ty. The commission will continu'e to work with the legislature to help solve these complex problems'

Paul Davies, M.D., ChairMaryland Medical Cannabis Commission

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Black caucus pledges to halt Maryland medicalmarijuana licensing

The Legislative Black Catlcus is challenging the medìcal marijuana licensing process' (WJZ)

By Erin Cox,j The Baltimore Surr

fÞ¡SHARE THIS

Black leaclers in Annapolis refuse lo let Marylancl's nrecJical pot prograrn trrove forward without diversity

SEPTEMBER 9, 2016, 7:10 PN4

7Tt h. Legislative Btack Caucus plans to use any means necessary to stop Maryland's medical marijuana

I commission from issuing final licenses untiì more are awarded to minority-owned businesses'

,,we will not be acceotins crumbs." Del. Cher-vl Glenn. chair- of the caucus. said Fridav at a forum in Annaoolis.

E 000490

The Baltimore Democrat presided over nearþ three hours of testimony from African-American, Hispanic and

female business owners who were not among the preliminary winners of 3o lucrative licenses to grow or process

medical marijuana in the state.

The caucus has not decided on a single course of action, but it is weighing filing an injunction against the

Maryland Medical cannabis commission, expanding how many growing licenses are available, scrapping the

entire application process and introducing emergency legislation to strip authority from the commission'

,,This is a fast-moving train," said Glenn, who was one of the architects of the state's long-delayed medical

marijuana program. She later added that the caucus would primarily relY on poiitical pressure and not the

Maryland court sYstem.

The black caucus has 45 members and represents a substantial political force in the r88-member Genei'al

Assernbly. Republican Gov. Larry Hogan has promised to clo what he can to help, but he has no direct authority

over the medical marijuana commission'

Although a state law required the medical marijuana panel to activeþ seek racial diversity, the commission

ultimately relied on a ,,blind,' process that did not. It did give significant weight to geographic and other factors

that failed applicants said were discriminatory'

Most of the preliminary licenses to grow or process mar$uana went to companies led by white men' More than

goo preliminary licenses to dispense the drug are still pending, and commission chairman Paul Davies has

promised to work with the attorney general's office to better ensure diversity moving forward'

But the black caucus said Friday that members will stand in the way of any of the preliminary licenses getting

final approval.

The promise to fight the process drew some concerns about whether it would further delay getting the dmg to

patients, who have been waiting for years. The state's first attempt to create a medical marijuana program, in

zor3, failed, and was replaced by a zot4law that is still not implemented' The national Marijuana Policy

project advocacy group ranks Maryland's program as thc slowest to get off the ground'

,,we have to come up with something that moves quickly," said Darrell carrington, executive director of the

Maryland cannabis Industry Association and a consultant for some companies who won licenses and others

who lost. ,'I don't know if starting all the way over again from scratch is fãir to the patient'"

Baltimore Del. Nathaniel Oaks, a Democrat, replied, "Fairness is out the backdoor already'"

La,nrmakers and several advocates said ìetting other businesses move forward while leaving African-American

ones behind - even if they are later awarded licenses - was unacceptable'

E 000491

california-based research group Arcview projects national sales of legal marijuana to hit $zr.B billion by zozo,

generating as much or more revenue annuaþ as the National Football League'

some companies that lost out on Maryland licenses complained Friday that unfair regulations stacked the deck

against them. They said some required unnecessary experience that is uncommon for black business owners'

others suggested they were expected to have access to huge amounts of capital'

,'The notion that we have to be multimillionaires to enter this industry is ridiculous," said Ovetta White, who

said her company, Sugarìoaf Enterprises, did not win a preliminary license to grow marijuana in Montgomery

County.

The commission has not released all of the detaüs about how it made ranking decisions, a process that took

months longer than many anticipated.

Glenn and other caucus leaders on Friday debated the best way to increase minorþ-owned businesses in the

industry. They said they would seek more oversight of the commission in the future, regardless of the outcome

of the licensure issue.

,,The process was flawed," Said Del. Darryl Batnes, a Democrat from Prince George's county'

The medical marijuana commission relied on a double-blind ranking system that it outsourced to the Regional

Economic studies Institute, known as RESI, at Towson universþ. Top companies were selected without regard

to the identities of the applicants.

since preliminary licenses were announced last month, leaders of the commission acknowledged that they

should have found a way to increase diversity among the winners of growing and processing licenses' They are

working with Maryland's attorney general to determine a legal way to do so when they now turn to awarding

dispensary licenses.

Two companies that wer-e originally ranked in the top r5 of grower applicants by RESI were bumped out as

winning bidders to make room for others who would add geographic diversity among growers'

One of those companies, GTI Maryland LLC, has 3o percent Ærican-American ownership' The group's general

manager said Friday that the commission let geographic diversity trump merit'

"We were passed over for a lower-scoring company," Said Sterling Crockett' the general manager'

¡¡cor (rr,' ba lf.stu"t.cül1

twttier . c o m / Er in a tThe Sun

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EXHIBIT D

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Despite controversy, Maryland medicalmarijuana grower on brink of starting cultivation

S''+i". .l

Taking a tour of ForwardGro, one of the 'l 5 pre-approved medical marijuana growers in the state. (Kim Hairston / Baltimore Sun)

ByErin CoxThe Baltimore Sun

APRll.29,2017,8:18 PM

S ince lawmakers approved medical marijuana in Maryland, the nascent industry has been mired in legal

and political controversy.

A judge is deciding whether the state improperþ awarded licenses to grow and process the plant. Black

lavrmakers said minorities d.idn't have a fair chance of getting those licenses. Now the governor has ordered a

study.

ForwardGro isn't waiting to see how it all turns out.

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ForwardGro is one of z3 companies licensed to grow or process marijuana in Maryland for patients suffering

from cancer, epilepsy and other conditions. Amid the uncertainty that has slowed the development of the

industry most are forging ahead with costly plans to build elaborate growing operations that could have crops

ready as soon as August.

,,we,re very excited that some of our members are 30 days away from planting their first plants," said Jake van

Wingerden, chairman of the Maryland" wholesale Medical cannabis Tïade Association. "You'll see product in

the marketplace by this fall."

van wingerden, president of sunMed Growers in cecil county, said his company expects to finish construction

of iis facility in July. At a meeting this month of his association's 13 growers, he said, "everybody expressed

optimism that they are on scheclule."

ForwardGro and its sprawling 2-acre compound in southern Anne AruncLel county is poisecl next week to

receive final inspection to secure a license to grow med.ical marijuana, company executives said'

As earty as next month, the Maryland Medical cannabis commission could allow them to turn on the lights

and begin growing the first medical marijuana plants - more than four years after the state made it legal'

on a recent afternoon, the ForwardGro executive team navigated around electricians and painters, chatting

with countybuilding inspectors and envisioning what the massive cavern would look like once workers in

medical scrubs and hairnets finaþbegin growing the potent pot for patients'

,,I,m going to be a mess rvhen we starL growing," Chief Financial Officer Gail Rand said'

Rand spent years lobbyins the legislature to legalize medical marijuana to help children like her son, Logan,

who has epilepsy. one of the company's first products will be a strain she picked out for him'

,,I'm looking to give this to my 7-yeal-old son," she said' "That's my standard of quality"'

The facilþwill be capable of generating 9,ooo pounds of medical marijuana each year, with a retail value of

roughly $45 million. ForwardGro and other growers wilt sell their products wholesale for less Lhan that to a

processor who will turn them into oils, tinctures or topical creams. or theywill prepare it to be inhaled from

vaporizers or smoked the old'-fashioned way'

up to 94 dispensaries will sell med.ical marijuana to registered. patients who have had the drug recommended

by a certified physician. The Arcview Group, a marijuana industry research group, estimates Maryland's market

will be worth $tzg.Z million by zozo.

While ForwardGro is not certain how big the market witl be - 4,67g patients have registered' in the past three

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It also built the shell of a processing center, which company executives said can be an active lab within sx

weeks of getting the green light from the state'

And the ls'-acre properly has enough land to accommodate up to z4 acres of greenhouses, which theoretically

could grow zt6,ooo pounds of marijuana a year'

The complex is set off a rural road, below the embankment of the former mine. Its address is marked in spray

paint. There are no signs for ForwardGro. A dilapidated trailer at the entrance belies the multimillion-dollar

operation being built'

"we don,t mind that it's hard to find," Rand said. "we'll never have a lot of people come through here'"

By law, the operation is encircled by razor wire and patrolled z4 hours a day by two armed guards'

Inside, each acre cost eight times more to build than a traditional greenhouse.

An elaborate climate-control system detects the intensity of sunlight and the floor temperature, and

automatically adjusts to prod.uce the optimum warm, sunny growing conditions favored by pot plants'

water, kept at a brisk 55 degrees, tricHes down a cooling wall at the end of greenhouse. The system is poised to

blow moist, cool air across the room if the summer sun heats the room half a degree too hot'

A series of overhead fans simulate a natural breeze to strengthen the plant stems, because stronger plants can

support larger marijuana flowers and give a better yieid. The floors can radiate heat upward to promote faster

root growth.

water drawn from on-site springs is treated, oxygenated, and filtered in a specialized" system, then infiltrated

with a mix of fertilizers that is automaticaþ dripped onto the plants. A series of screens can be drawn across

the ceiling to adjust the light intensity, and overhead lamps can simulate natural sunlight during the darker

winter months.

,,Everything in here is conüolled," said Austin Insley, ForwardCro's director of cultivation. "I{e can reaþ

manage this on our Phones,"

Data about the growing conditions are fed. into a computer, which is connected to an app on Insley's iPhone' If

the humidity unexpectedly clips at z a.m. on a T\resclay, for instance, Insley will get an alert'

So much of the greenhouse is automated that when the compound is fuþ operational, it will employ only about

15 people.

Marvìand forhirìs srower,q from usine nesric.ides or funsicides- so workers wilì treat the srow snace like an

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E 000496

,,They,re using more stuff on food you buy in the supermarket than we're allowed to use on the cannabis,"

Insley said.

Huge fans recycle the air in the greenhouse every minute. outside, copper coils ringed with a sponge-like

material emit essential oils that dampen the pungent scent of marijuana plants as that air is released'

other operations are ramping up around the state. Phii Golclberg, chief executive of Green Leaf Medical in

Fred.erick County, said the company wül produce g2o pounds of "high-quaþ" cannabis at its 45,ooo-square-

foot facilþ each month, plus 6o pound.s of lower-grade "trim" to sell to processors.

He said his firm is about eight to ro weeks from being ready for inspection. He hopes to have medical cannabis

products on the market bY Oct. r.

Goldberg said Green Leaf has lined up 3r prospective dispensaries to distribute its products statewide. He said

the company would like to be first to the market, but doesn't see that as essential.

"We want to make sure it's done right," he said'

ForwardGro, Green Leaf and the other growers will be required to send off samples for testing at a state-

certified lab such as Steep Hill Marytand in Columbia'

"we will be ready for them," said Dr. Andrew Rosenstein, steep Hill Maryland's cEo.

The companyhas built out a 2,ooo-square-foot lab in a business park, Rosenstein said, and will have all its

testing equipment d.elivered next week.

Steep Hill Maryland will test for the presence of eight heavy metals, any pesticides, and an array of solvents

used in processing the marijuana'

"It's a very regulated market," Rosenstein said'

The company, which has labs across the counbry, has a location in washington that tests medical marijuana for

patients and users. Such testing is not required in Washington, but helps companies market their prod'ucts'

Labs must be inspected and certified by the state. But unlike medical marijuana growers, processors and

d.istributors, they are not required to seek a license'

Rosenstein said the company endured extra expenses and setbacks from a year of uncertainty stemming from

legal challenges to the state's licensing process and political debate in Annapolis about over whether to make

adjustments.

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E 000497

The commission had award.ed licenses to two companies that had ranked lower in the state's scoring system'

The commission said it awarded those licenses to achieve greater geographic diversity in the industry'

The Legislative Black caucus has demanded that extra licenses be award.ed to create greater minority

participation in the industry. No African-American-owned company received a preliminarylicense to grow

cannabis.

The Ge'erai Assembly ultimateþ did not pass legislation to change the industry. But the lawsuits are moving

forward., Theoreticall¡ a judge could decide the commission needs to start the entire process over again.

,,It,s been a big stress for the businesses that are trnng to get read¡" Rosenstein said. "we couldn't exactþbe

sure when we had, to be readY'

,,It,s probably cost us several hund.red thousand in carrying costs and delays while we're waiting. It's been tough

to swallow."

Forward.Gro executives say they're ready but still uncertain about all the next steps before they can bring in

plants and start cultivating.

"We don't know, because no one in the state has done this before," Rand' said'

A spokeswoman for the Maryland Medical cannabis commission would not say how many companies have

requested final inspections or when the agency would grant final licenses.

The company will not say where the initial batch of plants will come from. It's a felony to transport clones

across state lines.

"It's immaculate conception," Rand said'

Baltimore Sun reporter Míchael Dresser contributed to this article'

[email protected]

ttuitter . c om/ Erina(The Sun

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E,XHIBIT tr

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EXHIBIT E

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Ptanet Depos"\,!e ¡!l{¿ìke li hr-\ppeû"

Transcr¡pt of Gonference GallDate: April 14,2017

Gase: Maryland Medical Cannabis Commission Telephonic Meeting

Planet DeposPhone: BBB433-3767Fax: BBB-503-3767

Email: transcripts@planetd epos.com

www.planetdepos.com

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TRANSCRIPT OF

Maryland Medical Cannabis Commission

Fríday, April 14, 20I'1

l-0:05 a.m.

Conducted by Conference Call

Baltímore, Maryland

Job No. : ]-41636

Pages: 1 - 26

Reported by: Katherine Schílling, RPR, CA CSR #L4L6322

E 000501

APPEARANCES

Paul Vrl. Davies, M. D . (Chairman )

Dario Broccolino, J.D.

Cristina Castro

Michael A. Horberg, M.D., MAS, FACP,

Robert A. Lavi-n, M. D.

Vanessa Lyon

Jeanie Gilmor Marshall, RN, BSN

Shannon K. Moore

James R. Pyles

Colonel Harry Robshaw' III

Nancy

Eric

Rosen-Cohen, Ph.D.

FIDSA

E. SterIing,

Traunfeld, M.

Esq.

Jon

Saundra Washington

Mary Jo Mather

Patrick Jameson

Transcript of Conference Call

Conducted on April 14, 20Il

PI¿.NET DEPOS8 88.43 3. 3767 | WWV/.PI-A.NETDEPOS. COM

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Conducted on April 14, 2077

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PROCEEDINGS

CHAIRMAN DAVIES: Right. Vüell, f 'm Pauf

Davies. I'm Chairman of the Maryland Medical

Cannabis Commission, and f'm a physician.

Dario/ can you can introduce yourself?

DARIO BROCCOLINO: Yeah. f'm Dario

Broccolino. I'm the Howard County state's attorney

and representative of the Maryland State's

Attorneys' Association on the Commission.

NANCY ROSEN-COHEN: I'M NANCY

Rosen-Cohen, representing National Council on

Alcoholism and Drug Dependence for the State of

Maryland as commissioner.

SHANNON MOORE: Shannon Moore. I'm a

patient advocate sorrY, Doctor.

MICHAEL HORBERG: Oh/ no üTorries . I 'm

Michael Horberg/ representing physicians and

researclìers.

ROBERT LAVIN: Robert Lavin, representing

the University of Maryland and physícian.

JON TRAUNFELD: John Traunfeld

representing University of Maryland Extension.22

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Transcrþt of Conference Call

Conducted on April 14,201'l

JEANIE MARSHALL: Jeanie Marshall,

hospice nurse.

SAUNDRA VüASHINGTON: Sandy Washington,

community member, patient advocate.

CHAIRMAN DAVIES: Any other commissioners

on the phone?

ERIC STERLING: This is Eric Sterling

from t.he Criminal Justice Policy Foundation. I'm

the lawyer member.

JAMES PYLES: Good morning- Maryland

Department of Health and Mental Hygiene.

CHAIRMAN DAVIES: AnY other

commissioners? Vüe have a quorum. Mary Jo, we do

have a guorum

MARY JO MATHER: Yeah- lVe have more than

a quorum.

CHAIRMAN DAVIES: How many members?

MARY JO MATHER: 11 memhers har¡e

introduced themselves .

CHAIRMAN DAVItrS: Okay. And we've got

HeaLher on the line, Vanessa/ Patrick, and Mary Jo?

MARY JO MATHtrR: Yes.

PT-A,NET DEPOS

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CHAIRMAN DAVIES: Vanessa, are you on the

fine? Okay.

Buddy,

NANCY

have you joined the call? BuddY?

ROSEN-COHEN: I'lI send him

another --

CHAIRMAN DAVIES: OkaY. Thank You,

everyone, for the in1-roductions. Welcome to the

public to this meeting of the Medical Cannabis

Commission. First order of business is the

executive director's rePort.

Patrick, do You want go ahead and get

that ?

PATRICK JAMESON: YCAh

hold on one second until BuddY was

I just wanted to

able to get on

couple more

to call in right

the line, but I'll just give it a

seconds. T know that he's trYing

don't know how long that's going to be

now

CHAIRMAN DAVIES: Buc|1y, have yolr j oì ned

the call- ?

DARIO BROCCOLINO: I propose that we get

started, Patrick, because I know you want to rdTe

E 000505



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PATRICK JAMESON: Vüell, I was just on the

phone with him, so he should be dialing in right at

t.his time.

DARfO BROCCOLINO: Well, a lot of us have

very hard stops,

to g-et

and we left other meetings, so

you've got moving.

JAMESONPATRICK AII right. f'm trying

to qet started right

All right.

now.

Good morninq, everybody.

Patrick Jameson. I'm

As

I just introduced, I'm

executive director.

And I am very optimistic

this industry off the ground. You

a.l-L the commissioners to realize

about getting

know, f just want

everyone to

realize this is a new and chanqing industry, and

take a couple years unt.ifit'L1 probably, you know,

maturity.

I afso hope

it reaches full

And that everybody also

on supply andunderstands that it is dePendent

demand. As I think many entrepreneurs know, being

the first one to the market has its advantages and

sometimes inherent financial risks. And it may not22

E 000506


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be the most advantageous position 1-o be in.

This industrY realIY needs the

opportunity to get up and running immediately. You

know, despite aIl the politics, it's critical that

rîe really get this industry up and runni-ng. There's

so much discourse that's been out there no\Î and a

lot of false narrative that's beingi promulgated.

At the Commission, w€'re making

tremend"ous progress. We're makíngi great progress on

getting this whole process going, and we're movíng

forward at a good rate.

lrle're now in Stage 2 of the application

process. And as a reminder to everybody, that's

where the preapproved applicants complete their

financing, zon|ng, construction, hiring, and

training and are in the process Lo prepare to be

open.

The Commission wants ns to qain the

applicant's financial background- And the financiaf

due diligence wilt be done on principals, directors,

investors of 5 percent or more. They have 365 days

to get all of t.heir operations ready.22

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The

of when theyrre

Commissíon

t.heír SOPs

goes and ínspects

in training. So

then advise the Commission

inspection. The

the and reviews

it's incumbent upon the

applicants

ready for

applícants that they receive a -- you know, to all

the commissioners and anybody who may be listening,

ít's incumbent upon all the applicants that they

receíve all of their occupancy and building permits

and zoning approvals prior to requestíng final

inspection from the Commission.

We highly recommend that an appJ-icant --

any applicants that have not submitted their state's

two applications do so in a timely manner.

Just so there's no mystery how this

once final- inspections haveprocess will work

completed. The Bureau of Enforcement and Compliance

of the Commission will come out, do the ínspec't-ion-

If the applicant has passerC the inspectìon at. l'hat

point, the Commission the Bureau of Enforcement

and Compliance witl submit its report to the finaf

review subcommitl,ee. That subcommittee will review

the report from the Bureau of Enforcement and22

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So under the operational aspect -- I

mean/ now in the process' as I said, of doing these

things to -- background investigations. We're doing

financial due diligence on roughly 700 people in

this process. And we're completing all of our

backgiround investigations, and we are moving

forward. So it's very critícal that \^/e move forward

Compliance, and then

their recornmendation

voting on l-icensure.

for the patients, Yoü know,

And f iust want

know, every day this office

week, this office recej-ves

from patients. And I

one that we got.

A Patient

that giroup will then submit

to the full Commission for

in this process.

to say one thing. You

or t actually, every

heartbreaking storíes

want to read a part of

dcgcncrative

operations,

next month.

basically saying

mercy on us for

j ust

has written in that theY have

arthritis and that theY'r¡e had 41

and they have another one schedul-ed for

they are asking -- theY are

they're sayíng, Please have some

those people that are suffering so

And

22

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that they can allewiate their pain.

And f think that's the critical el-ement

of what u/e're doíng here and why we need to get this

program up and runnang

think

immediately

ò() r f hope that

extremel-y happyone thing that we're

we've rolled out a brand-new website. And that

everybody knows

about is that

websíte is

very/ very

-- \^ras built to make sure that it is

customer- and user-friendly. So f hope

everyone has had

website, which is

patient registry

So the

the opportunity to go see the new

t.he fronL-facing portal for our

rollout.

some information. It was still in a

It was a pretestíng roflout. And we

t-he website what t.he rol-l-out will be .

began on

We used a

r¡7ere giving us

testing stagie.

have listed on

patient registry rol-lout actually

\^re díd a sof t rollout.March 31st, where

focus group of some advocacy groups that

So what's transpired since Monday is that

we've allowed patients to register with the last

names of A through L. On April I'll-h' we'll let

patients reqisLer M through Z. And on Monday,a.)

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April 24th, all of the website will be open for

general open enrollment.

And what r¡/e've done is

places around the

that really need

that there may be

reg'istering, and we

and make sure that

patients around the

state that wilI

help registeríng.

some people that

also set up some

allow for patients

Vrle understand

have problems

wanL to make ourselves available

we provide access to all of those

state.

On May 1st, we'11 be at the Eastern Shore

Hospital Center in Cambridge -- all of this

information ís listed on the website. On May 2nd,

we'll be in Kaplan University in Hagerstown. On May

3rd, we'lI be in the Charles County Government

building ín La Plata. On the 4th, we'll be at the

Department of Health and Mental Hygiene here in

Baltimore. And then we have a couple more dates

that arÊ comintl trp. And it witl be listed on the

website in Prince George's County.

As it stands now, we have roughly 7'200

patients that have provided applications, and we

have 42 caregívers that also are applying on 1-he22

E 000511

Transcr'þt of Conference Call


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site. So vre're having some good numbers that are

coming in. As you-all know, this is a rollingt

pïocess that this is iust beginning to get

started, and the rollout so far is goíng well.

We have approximately 250 physícians that

have registered at this time. So \^/e are making very

grood progress on this. And this is a criti-cal,

critical element to gettíng this whole industry up

and going.

So I encourage everybody to go to the

website. We have a lot of quick links on there of

where people can purchase their ID cards. Our

Commission meel-ings are tisted on there. And aII of

the information that's there -- we want everybody to

read the information on the website prior to them

registering because Lhe the registering process

there is a sequential order that has to be put in

place. And it's importanL for everybocly to read

what's on the website.

We've also put some industry information

on there as weff as qetting our -- our -- our other

dispensary information will be put on there- Once22

E 000512

we -- once we get a1l these back locations of the

dispensaries. Again, I encourage any of the

industry people to please qet Lheir supplementary

applications in, because the clock is ticking on

that right now.

So with that, that's all I have right

n OI¡/

HARRY ROBSHAW, IIf: I'm on the line if

you can hear me.

NANCY ROSEN-COHEN: Thanks,

HARRY ROBSHAW, III: Yeah,

I could hear everyone. Apparently, I

the right button for the code.

If you're done, Patrick, I

comments to make.

PATRICK JAMESON: YCS. SO

Buddy.

I apologize.

didnrt press

have some

that rs my

executive direct.or's report at this time.

HARRY ROBSHAW/ III: OkaY.

Commission members, members of the

public, thank you

tefeconference.

months there have

for attendinq today's

As you know, the last several

been both positive and negatrve



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ne\¡rS swì-rling

On

recognized as

hand, there's disparaging

corruption.

and sel-f-serving

For me, Itve been a

around the Comm-ission.

one hand, good work has been

it should have. And on the other

been

words and hints of

police officer for 43 years. At the end of the day,

my reputation and credibility mean everything to me.

I can absolutely assure everyone that I would do

nothínq to endanger either -- nor would any other

current member of this Commissíon.

We have always and will always remain

committed to bringing medical cannabis to the

residents of Maryland who so desperately need it.

Now, \Á/e are going to make a response to the requesL

of the Speaker of the House. Regarding that

request, I would like to reiterate something that I

said the day that we made the growers sel-ecLions as

thc growcrs selections subcommittee chairman.

The subcommittee considered geographic

diversity in accordance with

regions map of Maryland,

Western Maryland, Central

the agricultura-l

which there are five:

Maryland, Southern

for

22

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Maryland, the Upper

Eastern Shore.

I¡le took

and overlaid them over

you would see thal- there was

six of which were clustered

Eastern Shore, and the Lower

t.he 15 resident applicants1-op

that map. And if you did,

10 in Central Maryland,

in the western counties

There htere three inof Washington and

the Eastern Shore,

Southern Maryland,

Eastern Shore.

At the

had not commítted

Frederick.

one in Western Maryland, one j-n

and none or zero in the Lower

t-ime of our initial

to the county that

to be placed ín. We had a subsequent

growers subcommittee. We reconvened,

to repJ-ace the bottom-rank applicants

Washington -- Washington and Frederick

the top-ranked appllcanLs in Southern

and we voted

an

meeting,

they \^/ere

meetingr

s l_x

goíng

of the

County with

Maryland and

the Lower Eastern Shore. Thìs creaf.ecl a more

equitable and f-air distribution.

The full Commission voted on thi-s to

adopt these alterations from the initial breakdown,

which was 10 ín the Central, three in the Eastern

E 000515



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Shore/ one in l¡lestern

Maryland, and zero in

fina.l- breakdown, which

Maryland, one in Southern

in Eastern

the Eastern

.hTA S eight

Shore,

Shore, to the

in Central

two in SouthernMaryland, three

Maryland/ one in Western Maryland,

in the Lower Eastern Shore. This

gro\^7ers covered 16 counLies and

and finally, one

assured that our

Bal-Limore City.

some words about thisbeen

that that's how the sefection

I know there's

and some misunderstandíng

there are no comments on

a report from the final

rest of the Commission.

to clarify

was made. If

And I want

proces s

I wouldthat,

review

like to make

subcommittee to the

The final review subcommíttee, over the

last several months, has been discussing ways that

r^re could handfe problems on investigatíons that

started in the Commission and investigate them or

help ín thc investigation in a \^7ay that would not

only bring clarity to the subjects we were talking

about, but it would also be a way for us to make

recommendations as to what we should do.

And I wanted to make the rest of theaaZZ

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Commission al^/are just

we discussed in hopes

of some basic principles that

that other members of the

Commission would think about those and forward any

requests to us. Or if anyone in the public had any

comments, that they would have the abílity l-o

forward their written recommendations to the

Commission in the next seven days, starting today.

Some of our original thoughts l/vere -- r¡Ias

that if an applj-cant requested to l-he Commission the

opportunity to relocate, that the Commission

could -- should consider this and evaluate it based

not only on the facts presented but also on a number

of premises that we think are important.

, One, the applicant should be able to

carry out its preapproved operations at a nevT

location consistent with its original application.

That the applicant is a gro\^/er -- the location is in

the same aqricultural- z,Qnet if the applicant is a

gro\¡/er. Or if the applicant is a dispensary, that

the location be should be in the same senatorial

district..

We came up with some ideas that there,/ ,/

E 000517


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should be a busíness necessity to relocate - And

some examples of that are the inability to obtain

zoning- or other permíssions; the community

opposition to the location of the licensee; the

damage or d.estruction of the former premises ì or t

compared to a former focation, that the proposed

location provides signíficant economic advantages,

such as reduced expenses, improved patient access/

improved operations for a greater l-ikelihood of

zoninq approval or communit.y welcome. And, finally,

that there should be no substantial reason why the

request should not be granted.

Those are ideas that the final review

subcommíttee came up with. I request that other

members of the Commission give that due

consideration and offer any suggestions as to how

that should be carried out or what they l-h j-nk. And

r^re afso offcr t.hc public the opportunity to commenL

on those as well.

Absent any questions on those, I'd like

to move to Eric Sterting -- Commissioner Erlc

Sterling for a review on the policy subcomm-it-tee.22

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ERIC STtrRLING: Thank You, BuddY.

Mr. Chairman, members of the Commission,

the -- what f've been working on and I've shared

with members of the policy committee are first

drafts of amendments to the requlations to a -- the

additional health care providers that \^/ere

authorized by Chapter 414 of the active of 2016:

dentists, podiatrists, certified nurse

practitioners, and certificated nurse midwives-

These would require amendments to

Chapter 1, definitions, Chapter 3, certifying --

cert.ifying physícians which have become certifying

providers. Chapter 5, giving a written

certification, and Chapter 6, giving the

identification cards.

In addition, with Shannon Moore and our

chemist and others, r'm working on and having

comments from the public regarding proposals of Iast

fall on clarifying 1-he quality control and testing

requirements and Lhe registration of independent

testing laboratories. And those mal,eria-Ls will be

moved forward more formaÌly and so that the policy))

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committee can meet and address these necessary

regulatory changes.

Thank you.

HARRY ROBSHAVü/ IfI: Thank you, Eric.

Is there any ne\^/ business that -- while

we have all the commíssioners on the phone, any ne\¡i

items to discuss?

DARIO BROCCOLINO: This is Dario. I have

a questíon about t.he Bureau of Inspection and

Enforcement.

Have we gotten any requests to come out

and be examined?

PATRICK JAMESON: We have one request,

yes. One company.

DARIO BROCCOLINO: Now, could you give me

an idea of the timeline l-hat we foresee? I mean,

how long does ít

long wiIL it tal<c

take the inspection, and then how

Enforcement to prepare their

of Inspection and

report, send it to the

subcommittee, the subcommittee reviews iL and then

reporLs to the entire Commission? f mean, is

that -- I'm hoping that thaL's really a condensed

tho Bureau

ZZ

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period of time.

PATRICK JAMESON":".

Absolutely.

timeline on that,mean, it's hard to give you a

therebecause we won't know if are elements of the

inspection that have

there's several other

all been passed. As you know,

dj-fferent departments that are

involved in this process, i.e., the local zoning

boards/ occupancy -- you know, occupancy and

dwelling permits that have to be obtained. There's

the Department of Ag'riculture that's involved in

different types of nutrient management plans -

There's the fire marshal's office that's involved.

So there's several- other entities that

I

are involved, but as far as wetre concerned, when we

to do our best to make

t.his process very

finding any problems or

of their inspectíon

get out there, t¡/etre g"oing

suïe that we move through

expeditiously if we're not

if the companics have all

procedures in place already, and they've fulfilled

all of those requirements prior to us gett.inq out

there.

DARIO BROCCOLINO: VieIf, aIl those22

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requírements from outside agencies/ aren't they done

before we even go out there?

PATRICK JAMESON: TheY should be.

DARIO BROCCOLINO: OkaY.

PATRICK JAMESON: But we won't -- hle hope

that they are. But we won I t know until

of

we go out

thethere. And that's

businesses to make squared al^7ay on

their end.

DARIO BROCCOLINO: Okay. So let's assume

all that's done and everything's in order- Then we

are going to send it to a subcommittee of this

Commission, which wj-ll review it and then get it

I mean, I just really want to keep this moving, Yoü

know -- keep the fire under everyone to make sure

this doesn't giet stalled down and that it adds to

the lens of this rollout.

PATRICK JAMESON: We're not stal I ìng

anything on our

Wetve -- rdetre

the background

forward. Wetre

end. We're actuallY

of

incumbent upon aII

sure t.hat they're

caug'ht up on a lot.

investigations, and

as you know, I

ready to go.

almost alI

\re're moving

think that there's22

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a general perception

industry will be up

This is a

that on X date, the whole

runnr-ng.

you know, more of a complex

to build their buildings,

Some will be at

and

probJ-em for the industry

do their construction.

certain times; some will be comrng on

concerned,

comrng on

aL other

times . But as f ar as vIe're we t re not

going to be holding that process up at all -

DARIO BROCCOLINO: OkaY. Thanks.

HARRY ROBSHAW, III: Any other comments

from commissioners or any other new business?

Hearíng none, can I get a motion to

adjourn this meeting?

SAUNDRA WASHINGTON: This is Saundra. I

make a motion to adj ourn.

HARRY ROBSHAW, III: Can I get.

ERIC STERLING: I object-

IIARRY ROBSHAW/ III: Eric --

trRfC STERLING: It's my ímpression that

the Commission

to adj ourn but

legal guidance

is seekíng

is planning

on a number

to have

to recess

of matters

is not pJ-anning

in order to get

)1

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I t.hink that our request to go into to

session for receiving legal-

of business and can't be done

go in an executive

matter is a matter

afLer we adjourn.

HARRY ROBSHAVü, III Okay.

Shall I withdraw theSAUNDRA WASHINGTON

motion?

PATRICK .IAMESON: Buddy, it's mY

understanding that that issue has been wíthdrawn at

this moment and will be reconsidered and will be

reconsidered at the next meeting.

HARRY ROBSHAW/ fII: An issue that was

going to requi-re us

been put off untíl

wil-l not require us

conversation, Eric.

clear. So this

havc a conversation

put off to t-he nex1,

to go into that postPonement has

the next general meeting, which

to go into a secondary

I apologize for not making that

u/e're going tothat aspect where

with our Ìegal staff has heen

general meeting.

Very wellERIC STtrRLING: I withdrar^/ my

HARRY ROBSHAW, IIf: Okay. I apologize

obj ection

/. /.

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can I have the second now to

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the

SAUNDRA WASHINGTON: f second.

meeting?

This is

Sandy.

HARRY ROBSHAW/ III: Okay. Then in the

mind of the vice-chair, thís meetingi is adjourned.

Thank you, everyone, for attendi-ng. Thank you, both

to the public and for the commissioners as well.

ERIC STERLING: Thank You, BuddY.

SAUNDRA WASHINGTON: ThANKS, BUddY.

(Meeting adjourned at tOz32 a.m.)

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CERTIFICATE OF SHORTHAND REPORTER _ NOTARY PUBLTC

I, KATHERINE SCHILLING, Court Reporter and

NoLary Public, the offícer before whom the foreqoing

tefeconference was taken, do hereby certify that the

foregoing transcript is a true and correct record of

the tesLimony g'iven; that said testimony I¡/as taken

by me stenographically and thereafter reduced to

typewriting under my direction; that reading and

siqninq was not requested; and that I am neither

counsel for, related to, nor employed by any of the

parties to this case and have no interest, financj-al

or otherwise, in its outcome.

IN WITNESS WHEREOF, I have hereunto set my

hand and affixed my not.arial seal this 16th day of

April 2011.

My commission expires April 30, 2020.

-I"1.,7<4 ?þzzh

NOTARY PUBLIC ]N AND EOR

THE COMMONWEALTH OF VIRG]NIAaa

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trXHIBIT F

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EXHIBIT F

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ALTERNATIVE I'ÍEDICïNE

¡4ÀRYLAND, LLC

Plaintiff

vs.

NATALIE M. LAPRADE MJA,RYL]IND

MEDICAL eANNABIS COMMISSION

et a1.

Defendants

Ttre deposition of HARRY

III, was held on I¡Iednesday, MaY 10,

at 9t47 a.m., ât the Law Offices of

Seven Saint, Pau]. SÈreet, Suite 800,

2L202, before Dawn L. Venker.

"BUDDYI¡ ROBSHAW,

201-7, commerrcing

Brown & Barron, T'T'C,

Baltímore, Maryland

ÏN THE

CIRCUIT COURT

FOR

BÀLTTMORE CTTY

Case Nr¡¡nber:

24-C-L6-005801,

REPORTED BY: Dawn L. Venker

Gore Brothers Reporting & Videoconferencing410 837 3027 - Worldwide - www.gorebrothers.com

E 000539

Alternative Medicine Maryland, LLC vs'Natalie M. MMCC, et al.

Harry 'Buddy' Robsharv, III - Vol' IMaY 10,2017

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INDEX

Deposition of HÀRRY DBUDDYT RoBSIIÀW' III

May L0, 2017

No. Marked

l" Notice of Deposition 9

2 grillims order 3 6

3 Àffidavit of Robshaw 46

4 Letter - 4-27-L'1 51

5 Letter - 3-13-15 80

6 Traoscript of Open Meeting-8-5-16 100

? Àrèicle L26

I Unique ldentifier L39

9 ÀrÈic]e 191

Page 4

1

t

3

Page

< ,?t

227

4 ExminaEion By:

5 Mr. Brom

6 Ms. Nelson

ExhibiÈ

Exhibi t

Exhibi t

Exhibi t

Exhibib

Exhibi È

Exhibi b

Exhibi t

Exhibi t

Exhibi t

1_

¿

3

4

5

6

7

I9

10

11

r2

L3

L4

15

l-6

L7

18

19

20

2L

ÀPPEÀRÀNCES:

ON BEIÍALF OF TgE PLÀIMTTF'F:

BRIÀN S. BROWN, ESQUIRE

Brom & Barron LLC

Seven Saiut PauL Street

Suite 800

Baltimore, Maryland 2l-202

Telephone¡ 4IO.547.0202

hrail : bbrom@brombarron. com

and

BYRON IVARNKEN, ESQUIRE

Warnken LLC

lwo Reservoir Circle

suitê 104

Pikesvil-Ie, Maryland 21208

Telephone¡ 443.92f'fLO0

Ênail : [email protected]

ÀPPEÀRÀNCES (Continued on the Next Page)

Page 2

ÀPPEÀRÀNCES COI{IINI]ED :

ON BEIIÀI,F OF TIiE DEFENDÀNTS I

HEÀTEER NEI,SON, ESQUIRE

office of Ehe Àttorney General

State of Mary1and

300 WeEt Preston St¡eet

BaLtlmore, Maryland 2!202

Telephone: 4L0.76'1.7546

Eoail : hneLÊon@oag'state.md.us

1

)

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Page 3 Page 5

r. PROCEEDINGS

2 Whereupon,

3 HARRY "BUDDY" ROBSHAW, III,

4 called as a wilness, having been first duly sworn to

s tell the truth, the whole truth, and nothing but the

e truth, was examined and testified as follows:

7 EXAMINATION BY MR. BROWN:

I Q. Would you state your name for me, please?

s A. Harry Robshaw.

r.0 Q. And what is your business address?

11 A. Didn't expect that question.

12 Q. That's okay. lf --13 A. No. That's all right. 640'l Forest Road,

14 Cheverly, Prince George's County, Maryland.

r.s Q. Zip code?

15 A. 20785.

r"7 Q. Mr. Robshaw, have you ever been deposed

r-s before?

r.e A. Yes.

2o Q. Okay. So just very briefly, you're aware

2r, that I'll be asking you questions. You'll be giving me

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r- answers to the questions, correct?

2 A. Yes.

3 Q. You understand you are under oath under the

a penalty of perjury just like you would be if you were

s in court, correct?

a A. Yes, sir.

z Q. Just very briefly, I know the reporter will

a appreciate this. We'll be here a little while. And it

9 may seem like you or I are engaging in a conversation,

r.0 but it's very important that only one of us speak at a

rr time.

tz A. Okay.

rs Q. Because the reporter has to take down

i.4 everything that we say. And she only has two hands.

r"s So even if you think that you know what my question is

15 going to be, let me finish, then answer. And even

rz though I think I know what your answer is going to be,

1B I'll let you fìnish and then l'll ask my next question.

r.e Okay?

zo A. Okay.

z r Q. lf you don't understand my question, if you

Page I

r found we didn't do anything wrong.

z The second one was a case where I was

s ordered by the deputy chief of police to engage in a

e surveillance operation on a critical missing person

s that was supposed to being - being held against her

e will by a friend of their family.

z Q. Friend of whose family?

e A. The -- the friend of the missing person's

s family.

ro Q. Okay.

rr A. Engaged in surveillance all day.

12 Eventually stopped the subject. The subject said he

r.3 didn't know where the girl was. Took us to a few

r.4 locations he thought she could be. We took him home.

rs Called us the next day and said he was kidnapped by us.

re And we went to trial. They determined he was suffering

u from bipolar. And his treatment would cost $72,000.

re And the jury found for $72,000.

rg Q. Okay. Do you remember when that was?

zo A. 1997. Something like that.

zr Q. Other than those two cases, have you ever

Page 7

r think it's vague or unclear, please let me know and

z I'll rephrase the question as best I can. Okay?

s A. Yes, sir.

¿ Q. Can you tell me under what circumstances

s you have been deposed in the past?

s A. Civil litigation in federal court when I

7 was with the Prince George's County Police. And civil

a litigation in the federal courts while I was - while

g l'm with the town of CheverlY.

ro Q, Okay. And what sort of - what - what

r"1 kind of litigation was it? Civil litigation is a very

12 broad term.

r¡ A. Work-related lawsuits brought against

r+ either employees in Cheverly and against me and olher

ls police oflicers with Prince George's County.

re Q. When - what circumstances - what was the

r7 cause of action against You?

ra A. The first one was a K9 bite, which I was

r.e patrol supervisor. And I'm not sure of the

zo terminology. I say not guilty, but don't know how

21 you - what the term you use in civil court. They

Alternative Medicine Maryland, LLC vs.Natalie M. Laprade MMCC, et al.

Flarry'Buddy'Robshaw, III - Vol. IMay 10,2017

Page I

r been deposed in any other circumstances?

z A. That was for the county. ln Cheverly -s I'm not sure if I ever have in Cheverly. I have been

¿ involved in suits, but not deposed as a result of them.

s Q. Okay. Allright.

o A. Can I add one caveat? I don't -z Q. Sure.

a A. I don't -- you'll find out I don't add

s anything. But Prince George's County is - their

i.0 Office of Law handles all litigation.

rr Q. Right.

tz A. On many occasions they don't bother to tell

r.3 the respondent officer that there even is litigation,-J-4 or that they even settled the case. So there may be

1s something out there I'm not aware of, but those are the

15 ones that I am.

rz Q. Okay.

i.8 MR. BROWN: Would you mark this?

1e (Robshaw Exhibit 1 was marked for purposes

2o of identification.)

zr Q. Mr. Robshaw, I'm showing you what we've

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1 marked as Deposition Exhibit Number 1. And if you turn

z to Page 3, you'll see it's a subpoena, correct?

3 A. Right,

+ Q. And Page 4 and 5 are a notice to take

s deposition. Have you seen this document before?

e A. Yes.

z Q. Okay. And it's your understanding that you

s are here pursuant to the subpoena and notice to take

s deposition?

ro A. Yes.

rr Q. Okay. Thank you. As we get started, I

rz would like to ask you some basic questions about you -r¡ A. Okay.

r¿ Q. -- your background, how -- how you got to

rs where you are today. Okay. So tell me your education

15 after high school. You graduated high school. What

!7 happened after that?

ra A. I got a bachelor's degree in social science

r.e from the University of Maryland University College.

zo Q. What year was that?

zt A. I think I graduated 2006.

Page 12

r Q. Yeah. l'll get to your employment in a --

z ina minute. So-¡ A. But I'm -s Q. Yeah.

s A. - that training was in that. Yeah. Other

e than regular in-service training and police academy,

7 no.

e Q. Okay. Do you have any military service?

g A. No.

ro Q. Okay. So you graduated high school in

tt 1971. Tell me about your employment history from the

L2 day you graduated high school and thereafter?

r¡ A. After high school I worked for Columbia

L4 Rubber Corporation in Beltsville. lt was manufacturing

15 conveyor belts. And then joined the Prince George's

r.6 County Police Department in March of 1974.

rz Q. Okay. And how long were you a member of

1B the Prince George's County Police Department?

rs A. I retired in October : October 31st, 2001 .

zo Q. And was your employment with the Prince

2! George's County Police Departmentfrom'741o'O1

Page 1 1

r Q. Okay. What year did you graduate high

z school?

¡ A. 1971.

a Q. Okay. And after your Bachelor of Science,

s do you have any further degrees?

e A. I am currently in the master's program for

z criminal justice management at University College as

s well.g Q. ln the intervening years, between the time

ro and what .- you said '19 what you graduated college --

i.r. high school?

tz A. 1971.

r¡ Q.'71. So in intervening years between 1971

ta and 2006 when you obtained your bachelor's degree, did

r-s you have any kind of professional training where you

r-6 received certificates or any other kind of indications

L7 of attcndance or comPletion?

re A. I was certified by the Maryland Police

rs Training Commission as an instructor. I have about 600

20 hours of training. Testified, most of it related to

21 narcotics. I was a narcotics officer for 13 years.

Alternative Medicine MarylaNatalie M. Laprade MMCC,

nd, LLC vs.et al.

llarrv 'Buddy' Robshaw, Ill - Vol. 1

M.ay 10,2017

Page'13

1 continuous?

z A. Yes.

¡ Q. Okay. Tell me about your employment

e history within the police department. I assume you

s started off as an entry level officer?

e A. Right.

z Q. Tell me what happened after that?

a A. I spent the first nine years in patrol. I

9 went to narcotics. Went to narcotics. Stayed there

r-0 until I got promoted to sergeant. Went back to patrol.

i"1 Went back as a sergeant in narcotics. Stayed until I

!2 got promoted to lieutenant. Went back to patrol. Went

13 back to narcotics as a lieutenant. Stayed there as a

14 captain, and then shortly thereafter I retired.

rs Q. During the time that you were employed by

L6 the Prince George's County Police Department, were you

17 ever subject to any internal discipline where yolt were

1s suspended or reprimanded in any way?

le MS. NELSON: Objection. Go ahead.

zo A. Yes.

2'r- THE WITNESS: l'm sorry.

Gore Brothers Reporting & Videoconl'crencing410 837 3027 - Worldlvidc - wwrv.gorebrothers.cour

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E 000542

Page 14

r. Q. Tell me about - more than once or --

z MS. NELSON: Objection. Go ahead.

: A. Departmental accidents are considered

+ discipline in the county police.

s Q. When you say "department," you mean like a

e car accident?

t A. Car accident involving a town -- or a

e county vehicle.

s Q. Okay.

ro A. I had a few ofthose.

rr Q. Okay.

tz A. Especially young - in my younger part of

13 my career.

r¿ Q. Okay.

rs A. Was disciplined for - I'm trying to

16 remember -- it was failure to supervise. We changed

L7 our hours to an off-duty assignment that wasn't

i.s authorized by the police department. Paid a fine.

rs Q. You paid a find to the police department?

zo A. Right.

zr Q. Other than that, any other disciplinary

Page 1 6

r Q. So l'm assuming by you stating that, after

2 you finished with Prlnce George's County, you began

: employment with Cheverly?

a A. That's correct.

s Q. When -- was that immediately thereafter, or

6--t A. Unfortunately, yes.

a Q. Okay. So also in 2001?

e A. I retired from the county on Friday and

r.o started Cheverly on the following Monday.

rr Q. Okay. And are you still employed there?

rz A. That's correct.

rs Q. Okay. Sothat's been 16years, give or

L4 take?

rs A. Right.

re Q. So tell me about, again, your career from

L7 the day you started until today?

ra A. I was a deputy chief for the first four

r.s years. And I have beenthe chief of police sincethen.

zo Q. So since 2005,2006 you have been the

2r chief. How many members in your department?

Page 17

r A. Authorized strength is 17, but we -- we

z have 15, and we are full.

¡ Q. Okay. And this may sound like an obvious

a question, but what are your responsibilities as chief

s of police?

o A. I run -- I run -- administratively I run

z the department. I write all our -- our general orders.

a I do all the budgeting. I do all the planning. And I

s do all -- most of the community interaction work.

ro Q. Okay. All right. So you are a member of

rr the Medical Cannabis Commission here in Maryland; is

'J.2 that correct?

r: A. Correct.

r¿ Q. And for the purpose of this deposition, so

15 I don't have to say the whole name the whole time, I'm

15 just going to refer to it as The Commission. ls thal

17 okay with you?

re A. Yes.

rs Q. All right. Great. Have you been a member

20 of The Commission since its inception?

zr A. Yes.


Page '15

r actions against you?

z A. No.

¡ Q. The car accidents and that one incident?

¿ MS. NELSON: Objection -s A. No.

6 MS. NELSON: - just for the record.

r MR. BROWN: I understand.

e A. The kidnapping thing.

g Q. Yeah.

ro A. The alleged kidnapping, I like to word it,

1r- was investigated by lnternal Affairs, but I was cleared

12 of that.

r¡ Q. Okay. ln 200'1 you retired from the

14 PG County - I'm sorry. Some people don't like -rs A. That's all right. No, that doesn't bother

1,6 me.

L7 MR. BROWN: Off the record.

1s (A discussion was held off the record.)

rg Q. You mentioned a moment ago the Cheverly

20 Police Department.

zt A. Right.

Gore Brothers Reporting & Videoconl'erencing410 837 3027 - Worldwide - www.gorebrothers,com

I{arry 'Buddy' Robshaw, III - Vol. 1

May 70,2017

:,r]¡ .'-il..,1:- ll; ìi!:i (4) Pages 14 - 17

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Alternative Medicine Maryland, LLC vs.Natalie M. Lapratle MMCC, et al.

I{arry 'Buddy' Robshaw, III - Vol. 1

MaY 1'0,2017

Page '18

1 Q. Okay. So when was that?

2 A. October of 2013.

3 Q. Okay. Do you have a specific title at The

¿ Commission?

s A. I'm the vice chair.

e Q. You are the vice chair. Have you been the

7 vice chair since its incePtion?

a A. I - I think for the first we didn't -g didn't have that position. That the chair created that

10 position because he has occasion to travel frequently.

11 So I fill in for him when he's not there.

rz Q. Other than that role, the role of filling

13 in for the chair person when he or she is not around,

L4 do you have any other responsibility as vice chair that

15 other members of The Commission who are not chair or

16 vice chair don't have?

tt A. I'm on different subcommittees that perhaps

1s other people aren't on.

rs Q. I was going to get to that in a minute, but

20 since you answered that way, I'll just ask you now'

zr There is lots of different subcommìttees in

Page 20

r Maryland chiefs, and he called me'

z Q. What's his name?

¡ A. MichaelWynnyk.

+ Q. Okay. Can you spell his last name for me?

s A. W-Y-N-N-Y-K.

s Q. Okay.

t A. He asked me to, with verY little

a information, represent the Police Chiefs Association on

g The Commission.

ro Q. Do you know if the enabling legislation

r:- which created The Commission provided that there be a

L2 slot for a law enforcement representative?

r¡ A. Yes.

r¿ Q. And did it?

rs A. The slot was to be chosen by the Maryland

16 Chiefs. That's how I got the slot.

rz Q. Okay. And so Mr. Wynnyk called you and

r.B said do you want to fill this slot and you said sure?

rs A. He asked if he would do me -- do him a

20 favor, and I said yes.

zr Q. Okay. So prior to that time when

Page 1 9

r the committee - at The Commission; is that correct?

z A. Correct.

: Q. And different commissioners are -- comprise

¿ the different committees; is that correct?

s A. Correct.

e Q. So my more narrow question is are there any

z committees that you are on because you are vice chair

I as opposed to being on a committee just because

9 commission members are on committees, if you understand

1o my question?

rr A. No.

rz Q. Okay. No, you are not on any committees

r: just because you are vice chair?

r+ A. That's correct. I'm not.

rs Q. Okay. Yeah. Can you tell me in your own

16 words how you came to be on The Commission? And by

L7 that I mean did you scck out the position? Did

r.B somebody seek you out? How did that happen?

rg A. A friend of mine who is another chief, we

zo served together on the Prince George's County Police

2r Chief Association, he was also the president of

Page 21

r Mr. Wynnyk called you, were you even aware there was

z such a thing as The Commission?

s A. No.

¿ Q. Okay. Do you remember about when that call

s came to you, give or take?

6 A. I would think it was three weeks before the

z first meeting, which I think was in October of 2013.

e Q. So I'm making some assumptions here, and

s please correct me if I'm wrong. Mr. Wynnyk called you

10 and said will you do this. You said yes. Do you know

lL how you were formally appointed? Did somebody give you

12 a certificate from the governor, or something like

l-3 that, that says you are now a member of The Commission?

14 How did that happen?

rs A. I was notified to go to the clerk of the

16 court for Calvert County, because I live in Calvert

ri County. And I was presented a certificate from the

1s governor appointing me to The Commission.

rs Q. Okay. Other than talking to Mr. Wynnyk,

20 did anybody interview you or call you at -- or vet you

2L in any way prior to your appointment?

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L received anything from the state, even reimbursements'

z The town has paid for everything that I have been

: involved in.

¿ Q. Who has?

s A. The town.

e Q. The town?

t A. I drive their vehicle.

e Q. Okay. The Town of CheverlY?

g A. Right.

ro Q. Okay. So you drive their vehicles to and

1t from commission meetings, even though that's not really

r-2 town business. I'm not saying it's anything wrong with

13 it. I'm sure -- I'm sure you have permission from the

14 town lo do that.

rs A. Right.

rs Q. But - so you don't -- because you drive a

L7 town vehicle, you don't, of course, submit mileage or

1s anything like that?

as MS. NELSON:Objection. Go ahead.

zo A. No, I don't,

zr Q. Okay. How about meals? You ever --

Page 24

r A. No.

z Q. Okay. Who was chairman when you were made

¡ vice chairman?

+ A. Dr. Paul Davies.

s Q. Okay. Do you know how it is that he

6 selected you to become vice chairman of The Commission?

z MS. NELSON:Objection. Go ahead.

e Q. Well, let me ask you this question in

s response to the objection' Prior to the time of your

10 appointment, did you and Mr. Davies have

r.1 conversations -- or Doc --

Lz MR. BROWN: Excuse me' I'm sorry.

r¡ Q. Did - sorry about that. I'll rephrase the

L4 question.

15 Prior to your employment as vice chair, did

15 you and Dr. Davies have conversations about you

r7 becoming vice chairPerson?

re A. No.

rg Q. Okay. So one day he said to the - he just

zo said okay, you are the vice chairman now. I mean, how

zt did that haPPen?

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r A. He would jokingly tell you because I carry

2 a gun. I'm not - I'm not sure -- I hope he had

3 more -- | - I guess because I was there all the time

¿ and took an interested role in everything that The

s Commission was doing, he chose me' He never formally

e told me why I was going to be vice chair,

z Q. Okay. Did -- when he appointed you, did he

a discuss what your role would be with you?

e A. Essentially would be just to run the public

1o meetings when he wasn't there.

rr Q. Okay. Otherthan that, otherthan running

12 public meetings when he is not around for whatever

13 reason, do you have any other role as vice chair that

L4 other commissioners don't have?

rs A. No.

ro Q. Okay. I'm correct, you and all the other

li commissioners are not paid a salary from the state in

1B return for your service as commissioner; is that

19 correct?

zo A. I collect nothing. Other - I don't

2L collect mileage. I don't -- I don't -- I have never

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MaY 10,2017

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r A. No.

z Q. lf I were to ask you, Mr. Robshaw, I wóuld

¡ like to see a log of every place you have been on

+ commission business, would you be able to provide

s something like that to me?

e A, Not without the help of the staff.

z Q. The staff of The Commission?

a A. Right.g Q. So is it fair to say, based on your

10 understanding, that if - if you : that the staff

rr would be able to compile something for me of that

L2 nature?

r¡ A. Well, I -- I would think they would have a

\4 history of all our public meetings.

rs Q. Okay. And you know what, and I : I asked

16 you a poor question because I -- I can find out when

t7 the public meetings were. Okay. What l'm trying to

l-B find out is when you went on commission business other

19 than public meetings -- for example, but not limited

zo to, community outreach, would I be able to find out

z t from some source somewhere where you were and when?

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r. final decision maker --

z Q. No. no. Final review committee --

¡ A. Subcommiftee.

+ Q. * which makes - subcommittee, which makes

5 a recommendation to The Commission which then has the

e finalsay?

z A. That's correct.

e Q. Okay. Do the members of the final review

g committee, who made the recommendation to the full

to commission, also vote themselves on that same issue for

rr which they made a recommendation when the whole

rz committee votes?

r¡ A. Yes. But I - I should tell you that we

14 never -- we haven't had anything coming from the whole

i.5 commission yet.

re Q. Okay. But if that were to happen - so

L7 you -- how many members are on the fìnal review

1B committee, including Yourself?

rg A. Five.

zo Q. Okay. So the five of you would make a

21 recommendation, and then the same five, along with the

Page 28

r A. No.

z Q. Okay. Well, tell me, what - other than

: serving as vice chair and standing in for the chairman

¿ when he's not around, what do you see as your role?

s What's your understanding of your job, so to speak, as

e a commissioner?

t A. For the first year I was involved in

e writing the regulations. Hundreds of hours spent on

s that.

ro Q. Okay. What else?

11 A. Since then I'm the chair person of two

L2 subcommittees. And I am in -- in - involved in a

13 third subcommittee.

r¿ Q. Okay. Okay. I want to ask you questions

r.s about what you just told me.

re A. Yes.

rz Q. What subcommittees are you chair of?

ra A. I was chair of the grower selection

19 subcommittee.

zo Q. Okay.

zr A. Which is already - that's transpired or

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Alternative Medicine Maryland, LLC vs.Natalie M. MMCC, et al.

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r expired I should say. And I'm currently the chair of

z the final review committee.

¡ Q. Final review of what?

¿ A. Complaints made to The Commission.

s Requests for relocation. Any request that The

s Commission investigates that has to be voted on the

z entire commission comes to us first.

a Q. So when you say "final review," you

g would -- for example - this is a for example, a grower

10 was approved for Location A, now the grower wants to

r"r. move to Location B. That would be something the final

12 review committee would look at?

r: A. The Commission would investigate that and

14 then send the reports to us. And we would look them

15 over and perhaps request more documents if it was

r-6 necessary. And then ofler an opinion to the rest of

a7 The Commission.

ra Q. Okay. And then The Commission would vote

r-9 one way or the other?

zo A. Right. This final review is not a --

2r end - | know it sounds like final review -- we are the

Harry 'Buddy' Robshaw, III - Vol' IMaY 10,2017

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t rest of the committee -- commission, sorry, would also

2 vote, correct?

¡ A. Correct.

a Q. Okay. You said you were involved in a

s third subcommittee, but not a chair. Which committee

e is that?

z A. That's the executive committee.

e Q. And I've -- | am familiar from

s Ms. Robshaw's - Ms. Robshaw's -- Ms. Mather's

i-0 deposition of what the executive committee is. So I'm

1r. not going to go into that. Just very, very briefly,

12 what - what's your understanding of what the executive

r.3 committee is?

r¿ A. I think it's a sounding board for the

1s director and for the staff where we offer suggestions

r.6 and we talk about issues that -- as a -- as a means of

1-7 providing information to The Commission staff before

r-B they present it to the rest of The Commission.

ls Q. Got it.

zo A. lt's a sounding board.

zr Q. Got it. The first thing you told me about

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r. your understanding of your job as a comm¡ssioner was

z that for the first year you were involved in writing

: the regs?

¿ A. Correct.

s Q. Okay. Who else was involved in writing the

5 regs with you?

r A. Besides me, Eric Sterling. These are all

a commissioners.g Q. OkaY.

ro A. Eric Sterling. Debbie Marin. Debbie

1r. Marin, excuse me. I'm sorry I said that.

rz Q. That's all right.

rs A. Chris Charles. And Christina Paul.

r¿ Q. And all four of them are commissioners in

r-s it as : as well you said?

ro A. That's correct.

rr Q. To your knowledge, does any -- do any one

18 of them have any particular expertise in the technical

19 writing of regs?

zo A. Yes.

zr Q. Which one?

Page 32

r that you just told me, chair of subcommittees,

z involvement in the execulive committee, and writing the

3 regs, what other role do you have, if any, as a

¿ commissioner?

s A. I spend an awful lot of time dealing with

a all kinds of commission issues because I speak with the

z executive director all the time.

a Q. And who is that now?

g A. Patrick Jamison.

ro Q. Okay.

rr A. The chairman is involved in some issues now

L2 that calls for him to travel. So I think he calls me

13 because simply I'm the easiest --

r¿ Q. ls that still Dr. Davies?

rs A. Yeah.

re Q. Okay.

rr A. Because I'm the easiest to get in touch

1B with.

rg Q. Okay. Tell me about The Commission issues

zo that you talk to the executive director about' Give me

2L outline of what some of them are.

Page 33

r MS. NELSON: l'm going to object for the

z record. Go ahead.

¡ A. We are in the process of requesting the

+ legislature to change some of the regulations or the

s law to enable the regulations to be more effective.

e Q. Okay. Let me stop you right there. I'll

r take it one at a time. Okay. So you're asking for

e change -- let me make sure I have it right first.

e A. Okay.

ro Q. lt's my understanding that the legislature

11 passes laws. Governor signs them. They become law.

rz And then The Commission would draft and then enact

r-3 regulations to implement the law. ls that a fair

14 summary?

rs A. Correct.

re Q. Okay. So you just told me that you are

ri going to request that the law be changed, or you are

1B discussing that the law be changed in certain aspects;

1e is that correct?

zo A. Correct.

zr Q. And by the way, when we say the law, I

Älternative Medicine MarYlandNataìie M. Laprade MMCC' et

, LLC vs.al.

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r A. Eric Sterling wrote regulations when he

z worked for the federal government.

¡ Q. Okay. Did you -- who was the -- I guess

e the leader of the group, if there was one, as far as

s their drafting of the - of the regs?

e A. Wasn't one.

z Q. Okay. Well, did allof you actually like

I put pen to paper and give it a shot and then you edited

g each otheis works? Describe for me how the process

r.o worked?

rr A. We took the legislation as the - the

L2 skeleton of the regulation we wrote and then fleshed

i.3 them out from there. Eric spent a great deal of time

14 revising them because they had to be written in a

1s certain format.

16 Christine or Tina took the notes on a daily

1-7 basis on a computer. And then the rest of t-ts

1B contributed to the writing of it. And then

r.e subsequently sending it out to other commission

20 members.

zr Q. Okay. So other than those three things

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Page 34

r think we know what each other is talking about, the -z the enabling of the legislation which created the

s Medical Cannabis Commission --

¿ A. Right.

s Q. -- and everything that stemmed from that,

e right?

r A. Correct.

e Q. So what are you talking about -- what areas

e are you talking about changing the law?

r.0 MS. NELSON: I want to just pose a standing

1r- objection if I can. Obviously The Commission has

1-2 asserted the deliberative process privilege and ís

13 mindful of Judge Williams' order on that subject.

14 I will not be instructing the witness not

r-5 to answer, however, we've noted an appeal, and would

r.6 like the record to reflect a standing objection to any

Li testimony that relates to deliberations on policy or

r"s recommendations on policy decisions.

r.e MR. BROWN: And I have no problem with you

20 having a standing objection. The only - the only

2r request that I would make is that if any question that

Page 36

r MR. BROWN: Yeah. Sure. Okay. And just

z for the record, so we are all on the same page, what I

¡ would like to do is make a copy of Judge Williams'

¿ order an exhibit to the deposition.

s MS. NELSON:Sure.

a (Robshaw Exhibit 2 was marked for purposes

z of identification.)

a Q. So I was asking you what areas of the law

s you and the executive director and/or the chairman are

r.0 discussing requesting the legislature change?

11 MS. NELSON: This is where the objection

rz was, right?

r.3 MR. BROWN: Yeah, that's correct.

1-4 MS. NELSON: OkaY. Thank You.

rs A. After writing the regulations, we looked at

16 a few -- the legislations initially were directed at,

tz for example, hospitals. So we had to -- when hospitals

1s refused to be involved in - with medical cannabis

19 because offederal government, we had to request

20 changes so that doctors could be added to it' Then

21 we've had changes that go along to add nurse

Page 37

r practitioners and podiatrists and other things.

z Those changes had to be written -- we -- we

r provided information on what they should be in and sent

¿ them to the legislature to add that legislation, or to

s make sure that legislation shows up in the regulations

e in the right manner.

z Q. So in that example, the requests you were

s making of the legislature was that the type of

s providers who were able to prescribe or recommend

r,o medical marijuana to his or her patients needed to be

1r. expanded and in the law so that regs could be written

12 reflecting that expansion; is that fair?

r¡ A. Correct. That's fair.

r+ Q. Okay. Any other areas that - of law that

i.s you were requesting the legislature to change other

r.6 than the breadth of providers that were able to

r't participate in the program?

re A. There - I am not on that legislative

1"9 subcommittee. I'm not even sure what the exact name

20 is. I know there is other changes that we've talked

2L about. Off the top of my head, I don't know exactly

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I ask you believe encompasses both deliberative process

and another objectionable ground, I would ask that you

state this * the - you object on the separate ground

so you don't have the * to do that later.

So if you think there is a second basis or

a third basis to one of my questions other than the

deliberative process, I ask -- and I will make that a

condition of my granting the continuing objection, that

you state the additional objection for the record.

MS. NELSON: Thank You. And with that

understanding, I think both the court and The

Commission have referred to the executive privilege and

deliberative process privilege together.

MR. BROWN:Yeah. Yeah.

MS. NELSON: And so both of those

privileges would be asserted in the standing objection.

MR. BROWN: That's fine.

MS. NELSON: Thank You.

MR. BROWN: Okay. We -- we agree with my

condition?

MS. NELSON: Yes. Thank You very much.

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L what they are because I don't deaì with them every day.

z Q. Can you tell me who the chairperson is of

r the legislative subcommittee or whatever the --

4 A. The policy committee. lt's Eric Sterling.

s Q. Eric Sterling?

e A. Right.

z Q. So it's your testimony that sitting here

e today, other than the scope of providers or the breadth

s of providers, you -- you are not aware personally of

1 0 any other changes in the law that were requested of the

11 legislature?

tz A. I am - I am aware that there are proposed

13 changes coming, but that's the only ones that I -r¿ Q. But that - you don't know what they are?

rs A. l've heard discussions, but I don't - I

16 don't recall exactly what the -- I haven't been privy

!7 to those long discussions. I don't - I don't wanl to

r.s say something I'm unsure of.

rs Q. Okay. And I - and by the way, I don't

z o want you to say something you are unsure of --

zt A. OkaY.

Page 40

r Q. Okay. Do you have supervisory authority

2 over any other Commission member or any non Commission

¡ member employee of The Commission?

¿ MS. NELSON: Objection. Go ahead.

s A. No.

e Q. Okay. Mr. Robshaw, other than the cases

7 you told me about where you were parties to a lawsuit

e in your role as a police officer both in Prince

9 George's County and in Cheverly - and by the way, I'm

r.0 including in that the ones you say you might not know

r-1 about because --

tz A. Right.

r¡ Q. Other than those cases, have you ever been

14 a party defendant to a civil lawsuit?

rs A. I am now currently with the Town of

16 Cheverly over the dismissal of an employee'

rz Q. Okay.

rs A. Several employees, as a matter of fact'

rg Q. Okay. So that's like a labor law kind of

2o thing?

zr A. Well, they've appealed under the LEOBR up

Page 39

r Q. -- in response to any question that I ask

2 you. Okay. And if your answer to a question is I

¡ don't know, that's fine.

4 A. Okay.

s Q. Have you been to every public commission

e meeting?

t A. No.

a Q. How many -- do you -- I mean, I know that

9 one of your roles is to be around when the chairman is

10 not. So I assume you've been to the vast majority of

LL them because othenvise they would have somebody else in

12 that role, right?

r¡ A. lthink I - I missed one. I called in,

14 but the chairman was there.

rs Q. Okay. You know, I : if you called in, I

r.6 don't count that as missing it. So you don't have to

L7 be physically present to be there --

ra A. Okay.

rg Q. -- these days. Okay. So -- so you've been

zo at every meeting pretty much, correct?

zt A. Right.

Page 41

r through the Court of Appeals. And they've been denied'

z So I guess the final avenue is civil.

¡ Q. So you got sued in your capacity as chief

+ of police of the Cheverly Police Department?

s A, That's correct.

o Q. Okay. Other than -- and I'll rephrase this

z question. Otherthan employment related cases, police

e department, chief, have you ever been a party defendant

s to any lawsuit?

ro A. No.

rr Q. Okay.

i.2 MR. BROWN: Counsel, I'm just going to make

13 you aware as a courtesy that I'm going to get into

14 matters now that I know you contend are subject to your

1s continuing objection. And if you feel the need to make

16 a specific record about a specific question, go ahead'

1.7 BLrt I understand your continuing objection, and -- and

r,B that you have it for the record. Okay?

r.e MS. NELSON: Thank You.

20 MR. BROWN: You are welcome.

zr Q. Mr. Robshaw, it's my understanding that -

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Page 42

r. and we'll get to the process in a little bit. But it's

2 my understanding that the applications for growers'

3 l¡censes were submitted to - and Mr. Warnken can help

4 me out * RESI - I forgot what the acronym -- acronym

s stands by, Regional Economic Something lnstitute.

s MS. NELSON: Studies lnstitute. Studies

z lnstitute.

e Q. Studies lnstitute. I don't - Regional

g Economics Studies lnstitute for ranking - evaluation

ro and ranking and then return to The Commission. ls that

rr a broad statement of what occurred?

tz A. Yes.

r¡ Q. Okay. Do you know what AMM's rank was?

L4 MS. NELSON: So this is where I would

r.s object just for the record. The Commission does not

16 object and does not assert the privilege with

L7 descriptions of the process. And so which entities

18 performed which roles, there is no claim of privilege.

19 But the substantive recommendations

20 received from the independent consultant and conveyed

zr to The Commission are subject to privilege. But please

Page 44

r example, to go back, look at the records, could you --

z would the information be available to you if I asked

3 you where a specific grower was ranked?

¿ A. Yes.

s Q. Okay. By the way, my understanding that

6 the process is as follows. There was provisional

? approvals, right, and then after provisional approval,

a a license will be issued after certain requirements are

s met; is that correct?

10 A. Correct.

rr Q. To your knowledge, have any growers who

!2 have received provisional approvals requested issuance

13 of the Stage 2 license?

r+ A. Yes.

rs Q. Okay. Which grower?

16 A. I - I don't know that.

rz Q. Do you know if more than one grower has

1s requested issuance of their license, or is it only one,

19 to your knowledge?

zo A. I think one has - is * has either

21- requested or is very near, and another one is several

Page 43

r go ahead.

z MR. BROWN: ln Your view.

¡ MS. NELSON: Thank You. Thank You.

¿ MR. BROWN: Yes-

s A. Can you ask me that again? I'm -e Q. Sure. Each growerwas ranked; is that

I correcl?

a A. I would like to make a distinction here.

s Up until the time of announcement, the only thing I

10 knew about anybodY was a number.

rr Q. Okay.

tz A. I found out when everybody else found out

r"3 who actually got selected for a grower.

re Q. Right. At any time from the day - from

r-5 the day you got the evaluations back from RESI until

r.6 today, do you know where AMM, the plaintiff in this

L7 case, was ranked?

ra A. I saw the final ranking. So I don't - |

r-9 don't remember though. I don't know where they were

2o ranked.

zr Q. Okay. But if I were to ask you, for

Page 45

r months away. But I don't - off the top of my head I

z don't know specifically who they are.

¡ Q. Do you know if the one who was very, very

4 near has had an inspection scheduled to confirm that

s they are ready for issuance of a license in The

e Commission's view?

t A. I have seen no reports of that, no.

a Q. Okay. Do you know what county that grower

g is in which has requested issuance of the Stage 2

r-o license?

rr A. l'm not sure which one it is, so,

12 therefore, I -- I don't know what county it is either.

r¡ Q. Well, is there any county that has more

L4 than one license?

rs A. Grow license?

re Q. Uh-huh.

rr A. Yeah.

ra Q. So - but you wouldn't have to know which

1e grower it is to know which county it is in, would you?

zo A. lf you told me the name of a grower, I'm --

21- I'm not sure I could tell you what county they are

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Altcrnative Medicine MarYlandNatalie M. Laprade MMCC, et

, LLC vs.al.

Harry 'Buddy' Robsharv, III - Vol. 1

MaY 10' 2017

Page 46

r going in anyway.

z (Robshaw Exhibit 3 was marked for purposes

: of identification.)

4 Q. Mr. Robshaw, I'm showing you what has been

s marked as Exhibit Number 3. And I would like you to

6 turn to the second page, and ask you if that indeed is

7 your signature on the last Page?

e A. Yes.g Q. And you -- I understand this is an

10 affidavit and you signed it under oath under the

1r. penalties of perjury just like you're testifying here

L2 today, and just like you would be if you were

13 testifying in court, correcl?

r¿ A. Yes.

rs Q. Okay. Did you actually physically yourself

L6 prepare this affidavit?

L7 MS, NELSON: Counsel, I need to note for

r-B the record that you have a document at the end of

1s Exhibit 3 that was not Part of -20 MR. BROWN: I think you are correct. That

21- belongs attached 1o a different exhibit.

Page 48

r A. Yes.

z Q. Okay. What I want to know from you is

: precisely what was done from the day you became a

+ commissioner until the day you were sitting here to

s achieve racial and ethnic diversity in the application

e and selection process for a grower's license?

z MS. NELSON: I'm also going to raise an

a objection under deliberative process privilege as to

s discussions of recommendations received from

1o independent consultants or other third parties and

rr internal policy debate about what measures would be

L2 taken. ln light of Judge Williams'order, I'm not

L3 going to instruct the witness not to answer, however, I

t¿ want that to be a standing objection with regard to the

rs testimony.

L6 MR. BROWN:That's fine.

!7 MS. NELSON: Thank You.

ra A. Could you ask me the question again,

19 please?

zo Q. Sure, lcan. And I'm going to askyou a --

2L l'm going to strike the previous question.

Page 47

r MS. NELSON: Yeah.

z MR. BROWN: So we can detach those last

3 pages.

+ MS. NELSON: ThankYou.

s MR. BROWN: Okay. No problem. And the --

e Q. Beginning after Page 2, Mr' Robshaw. Can

7 you take those and hand them back to me?

a MS. NELSON: lt's the last two pages that

e were not part of the affidavit.

r.o MR. BROWN: Right. Correct-

11 THE WITNESS: Just these two?

L2 MR. BROWN. Yeah.

13 MS. NELSON: Correct.

r¿ Q. Thank you.

rs A. Uh-huh.

re Q. What I would like to ask you about is

'J.'t Paragraph 10 where it says * and I'm going to reacl it

ra to you. "The Commission is continuing its work to seek

19 and achieve racial and ethnic diversity, and intends to

20 retain a diversity consultant to support these

2r efforts." Did I read that correctly?

Page 49

r MR. BROWN: You don't need to restate your

z objection when I ask the question again.

¡ MS. NELSON: Thank You.

+ Q. And I'll ask you this question first. Are

5 you aware that the enabling legislation which created

e the medical cannabis program in Maryland requires The

z Commission to actively seek racial, ethnic and

a geographic diversity in the selection - in the

s application and selection process for a grower's

1o license?

rr A. Yes.

rz Q. Okay. So now I'm going to restate my

13 question, which is what precisely has The Commission

14 done from the day you became a member, which is its

1s inception, until today, to actively seek racial and

r-6 ethnic diversity in the application and selectlon

17 process for a grower's license?

re A. The only way I can answer that is to say

r-s that we talked about outreach to the * particularly to

2 o the African-American community by way of information to

2r black colleges, to magazines, and -- and other

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I-Iarry 'Buddy' Robshaw, III - Vol' 1

May 10,2017

Page 50

1 newsprint that reached out to the African-American

2 community. And to publications that are either

¡ initiated or are aligned with cannabis - medical

¿ cannabis use in the State of Maryland. And we have

s hired a -- a consultant, a diversity consultant, to

e help us accomPlish lhat.

z Q. I'm going to ask you about the last thing

I you said first.

s A. Okay.

ro Q. Your affidavit was signed on December the

11 121h,2016?

tz A. Right.

r¡ Q. Paragraph 10 of your affidavit says that

r+ The Commission intends to retain a diversity

1s consultant. Was the diversity consultant that you just

i.6 mentioned retained before or after Decemberthe 12th,

17 2016?

re A. After.

rs Q. Okay. When was the diversity consultant

2o retained?

zt A. I'm not sure what the date of their

Page 52

r Q. Okay. How is it that you became aware, in

z absence of seeing this letter, that a diversity or that

3 a -- bear with me one second. Let me get the term

+ exactly correct, a disparity study has been ordered by

s the governor if not from reading this letter?

e A. Discussed at an executive committee meeting

z not long ago.

e Q. Okay. Would You say it was after

s April twenty - this meeting of the executive committee

10 was after April2Tlh,2017?

rr A. Yes.

rz Q. Okay. Was the diversity consultant that

13 you mentioned in your affidavit, and you mentioned that

14 was retained and now it's on hold -- was the hold of

1s the diversity consultant contract placed on or after

rs April 27th,2017?

t7 MS. NELSON: Objection. Go ahead.

re A. I'm going to say yes, but it's -- I don't

19 know exact dates.

zo Q. Okay.

zt A. I didn't -- I wasn't involved in that

Page 51

r contract signing was.

z Q. Okay. Who is the diversity consultant?

¡ A. I don't know the name off the top of my

a head because it is on hold right now -s MS. NELSON: Objection. Go ahead.

s Q. lt's on hold right now?

z A. - pending a diversity study initiated by

e the state,

g Q. Yeah. And l'll get to that in a few

10 minutes as you might have expected.

rr A. Okay.

rz Q. Was - I'll do it this way. Make it

13 easier.

L4 (Robshaw Exhibit 4 was marked for purposes

r.s of identiflcation.)

rs Q. I'm showing you what's a letter to

li Mr. Jimmy H. Rhee, signed by Governor Hogan. We've

r-B marked that as Exhibit Number 4.

rg A. Uh-huh.

zo Q. Have you seen this letter before?

2t A. No.

Page 53

t conversation.

z Q. Well, is it - is it fair to say that a

¡ hold of the dis - of the diversity consultant's

¿ contract wasn't discussed until after the state study

5 was ordered?

s MS. NELSON: Objection. Go ahead.

z A. I don't know the answer to that.

e Q. Okay. Forgive me if I asked you this

s question. Did you tell me that you didn't know who the

1o diversity consultant was that you retained?

rr A. I don't know the name of the group. I met

L2 them for a - half an hour one time.

rs Q. Okay.

r+ A. And never had anymore discussions with

15 them. So I've heard it, ljust don't remember it'

rs Q. That's fine. Do you know if the contract

tl for the diversity consultant whom The Commission was

18 going to retain was put out for bid as a part of a

rs request for proposal, or tell me in general how the

zo selection process of the diversity consultant happened?

zt A. I don't know.

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Page 54

1 Q. Okay. Was there a subcommittee of The

2 Commission which was tasked with retaining the

: diversityconsultant?

+ A. Not that I'm aware.

s Q. Okay. Well -- and please - this is not

e meant to sound flip.

t A. No.

a Q. Okay? But they didn't just appear from the

g ether. I mean, there had to be some manner in which

ro the selection process occurred. You are vice chairman

i.1 of The Commission. ls it your testimony you have --

12 don't have any information to provide me with how that

13 selection process haPPened?

r¿ A. The selection process was done by staff

r.s members in conjunction with whoever the part of the

16 state government that grants contracts.

rz Q. Okay.

re A. I wasn't -- I wasn't involved in that

19 process.

zo Q. Do you know which staff member or members

zr at The Commission was tasked with dealing with state

Page 56

r has an office in the basement. I don't know the

z address - the address or the name of the building or

: anything like that.

e Q. Okay. Who else was there besides you and

s the-o MR. BROWN:Off the record.

r (A discussion was held off the record.)

a Q. Who else was there besides you and the

s diversityconsultant?

ro A. Vanessa and Sara -- I don't - I don't -rr Q. lf --

!2 MR. BROWN:And I'm going to ask Ms.

13 Nelson, if you know Sara's last name -- I know you are

14 not under oath, but if you could provide that, that

1s would be great.

16 MS. NELSON:Sure. HoYt.

r7 MR. BROWN:White?

r-8 MS. NELSON: HoYt.

r-e MR. BROWN:HoYt?

20 MS. NELSON:H-O-Y-T.

2L MR. BROWN: Thank You very much.

Page 55

r" procurement in retaining the diversity specialist?

z A. Yes. And the name escapes me right at this

: moment. Any other time I would be able to tell you.

¿ Q. Well, I understand. I have been there. So

s as we go on during this deposition, if it pops back in

6 your brain, please just tell me. Okay?

t A. Okay. I remember now. lt's Vanessa Lyons.

a Q. See. I knew that would haPPen.

g A. I knew the last name. I couldn't remember

1o the first.

rr Q. That's fine. Thank you very much. You

rz told me a minute ago that you had a meeting with the

13 diversity consultant. You don't remember who they are.

L4 lt lasted about half an hour. Do you remember when

rs that meeting was, give or take?

re A. About two months ago. I think it was in

r7 Annapolis. I don't rememher the specific date'

ra Q. Okay. Do you remember where -- where --

r,s like what building? Where were you?

zo A. lt was - they called it The Bunker. l'm

21- not exactly - its a government building of which DHMH

Alternative Medicine X{aryland, LLC vs.Natalie M. Laprade MMCC' et al.

Harry 'Buddy' Robshaw, III - Vol' 1

MaY L0,2017

Page 57

r Q. ls Ms. Hoyt on the staff of The Commission,

z or she's from someplace else?

¡ A. She was on the staff at that time. Now she

¿ works in another capacity for DHMH.

s Q. Okay.

a A. I'm not sure what.

r Q. Do you know what her title was at The

a Commission during the time that she was an employee

g there?

ro A. She had a -- she was the -- I don't know

r.1 what her title was. She went out and talked to

12 legislative members for The Commission.

r¡ Q. Okay.

r+ A. I don't know exactly *rs Q. Legislative liaison? Does that sound about

r-6 right?

rr A. Some -- somethinq similar to that.

rs Q. Okay.

rg A. Might - might be a different title, but

20 that was the -z r Q. But that was her role?

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Harry'Buddy'Robshaw, III - Vol. IMaY 10,2017

Page 58

1 A. Right.

z Q. Okay. Was the diversity consultant

3 retained - and we know it was after December the 'l2th,

4 2016 because it was after your affidavit. And your

s affidavit says a diversity consultant will be retained.

6 A. Right.

z Q. So we know it was after December the 12th,

e 2017. Was the diversity consultant retained before or

9 after this -- Stage I approvals were issued?

ro A. After.

11 MR. BROWN: Okay. So we've been going like

!2 a little - I want to take a five-minute break.

r.3 (A recess was taken.)

14 Q. So I asked you, Mr. Robshaw, subject to

r.s Ms. Nelson's objection, which still stands, about what

re The Commission did to seek racial and ethnic diversity.

L7 And we talked about the consultant. But getting -ra getting back to that for one second, you said you had a

ls meeting with them and two others?

zo A. Right.

zr Q. How many members of diversity consultant's

Page 60

r note of the fact back prior to the regulations actually

z being adopted, we didn't have a formal subcommittee

s structure. So when I say "we," it was whoever was

a available to come in and work that day'

s Q. Okay. But there were always commissioners?

e A. Just commissioners.

z Q. Just commissioners.

a A. And the executive director. We didn't have

g staff back in those daYs.

ro Q. Got it. What - eventually, once you had

11 regs, was there a specific subcommittee who had the

1-2 task of seeking racial and ethnic diversity in the

13 application and selection process?

r¿ A. No.

rs Q. Okay. Was that a task that was handled by

re The Commission as a whole, or better yet, describe for

a7 me the process by which The Commission sought to

r.8 achieve racial and ethnic diversity in the application

19 and selection process?

zo A. Those discussions were centered around the

zt arrival of a new executive director, Hannah Byron,

Page 59

1 company or firm were at the meeting? Do you remember?

z A. Three.

: Q. Three. Can you -- since you don't remember

4 the name of the company, do you remember the names of

5 any of the individuals that were there?

e A. No.

z Q. Men?

a A. l-l-twowomenandaman' l-l'vee seen their names. I just don't recall what they are

1o right now.

rr Q. Were they black, white, old, young?

rz A. All three African-Americans.

rs Q. Okay. Age range?

r¿ A. Not as old as me and You, but 30s.

rs Q. Okay. So you told me in addition to the

r-5 diversity consultant -- your words were "we" talked

L7 about outreach. And you gave me a list of different

i.B mechanisms of outreach.

rg A. Right.

zo Q. My first question is who is "we"?

zt A. Other commission members. I'lljust make

Page 61

r about what we could do to reach out to -- to -- to -z to actively seek racial and ethnic diversity. Those

: suggestions were provided to her, and it was her

a responsibility to follow up on those.

s Q. Okay. And were these selections that were

e provided to her the list that you gave me a little bit

z earlier before we took our short break, which included

e reaching out to black colleges, African-Americang centric magazines and newsprint, and publications and

1-0 magazines that were connected to the medical cannabis

1r- industry?

rz A. That's correct.

r¡ Q. Okay. So your testimony is that those

L4 suggestions were provided by Ïhe Commission members to

15 the chairperson, who at the time was Ms. Byron. Did I

r-5 paraphrase that correctlY?

L7 MS. NELSON:No. Objection.

ra Q. Okay. Well, Ms. Nelson says I didn't

i.9 paraphrase it correctly. I want you to tell me if what

zo I said was not a correct paraphrase and why?

zr A. Those suggestions were offered to her. And

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Page 62

1 she was responsible for following up on them.

z Q. Okay. By whom were the suggestions

: provided to her bY?

¿ A. Commission members.

s Q. Okay. Commission members. Was it an

e individual thing? And I don't mean this - | - would

z Mr. Rob, you, hey, Hannah, you know, why don't you try

e this, or was it actually a formal report that was

s provided by Commission members in writing, or by email,

r.0 or communicated formally in some way to Ms. Byron?

rr A. We discussed it at a meeting -- at -- at

L2 several meetings, but I - | don't -- I never wrote

r.3 anything.

re Q. Okay.

rs A. I'm not aware of anybody else writing

i.6 anything.

rz Q. When you say "we discussed it at several

1B meetings," you mean commission members?

rg A. Other commissìoners and Ms' :zo Q. Ms. Byron was there?

zr A. We didn't have all the staff that we do

Page 64

r A. I think that was an appointment by the

2 governor.

¡ Q. Okay.

* A. l'm not 100 percent positive, but -s Q. Would The Commission members have any input

e in the selection or the application of the selection

z process?

e A. I willjust I didn't.

s Q. You didn't. OkaY.

ro A. I can't speak for --

rr Q. But you can say, and you have said here

rz today, that Ms. Byron was present at the meetings with

1: various commissioners at various times, and the issue

L4 of seeking racial and ethnic diversity was discussed

15 and suggestions were made by the commissioners to

16 Ms. Byron. And that your testimony was it was then

L7 Ms. Byron's responsibility to act on those

1s recommendations. ls that fair?

rg A. That's fair.

zo Q. Okay. Toyourknowledge, what, ifany, of

zr those suggestions, in addition to any other actions

Page 65

r which you didn't suggest, were taken by Ms. Byron or

2 anyone etse on behalf of The Commission to actively

s seek racial and ethnic diversity in the application and

+ selection process for growers' licenses?

s A. What actions did she take? ls that what

6 you are asking?

z Q. l'll tell you what. I'm going to be very

e specific. So I'm going to ask -- I'm going to ask --

g slowdown. I'm goingtoaskthe court reporterto read

10 to you exactly what my last question was.

r.r. (The reporter read back as requested.)

tz A. I don't know.

rs Q. Did you, in your capacitY as a

L4 commissioner, or in your personal life, ever see any

15 specific advertisements, notifications, public notice

16 of any kind specifically seeking racial or ethnic

J-7 diversity in the seleciion process for growers'

1B licenses?

rg A. No.

zo Q. Did you ever see in your capacity as a

z1 commissioner, or by coincidence in your personal life,

Alternative Medicine Maryland, LLC vs.Natalie M. Laprade MMCC' et al'

Page 63

z Q. OkaY. I understand.

¡ A. So essentially just the executive director

¿ and Commission members. I'm not - I can't tell you

s exactly who it was because that group rotated based

5 upon availabilitY.

z Q. Now, at the time Ms. Byron - when these

e discussions were going on, Ms. Byron was the chair

9 person; is that correct?

ro A. She was the executive director.

rr Q. You are right. My mistake. Thank you for

12 correcting me. She was the executive director?

r¡ A. That's correct.

r+ Q. And is it fair to say that the executive

1s director acted at the direction of the Commissioners?

re A. Yes.

rz Q. Okay. ln fact, it will be -- if there came

1B a time -- and I know it dìd happen -- that The

19 Commission needed a new executive director, it would be

zo The Commission who woutd seek and retain its executive

zr director; is that correct?

Harry'Buddy' Robshaw, III - Vol. 1

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1 misstating your testimony, tell me. But I believe you

z stated a moment ago that the - to your knowledge, The

¡ Commission took no action to actively seek racial,

a ethnic and geographic diversity. I'll rephrase the

s question.

e Took no action to actively seek racial and

z ethnic diversity in the selection and application

I process; is that correct?

e A. For clarity, I don't know that they did,

10 nor do I know that they didn't.

rr Q. Okay. Well, as a vice chairperson, if they

L2 did, do you think you would know that?

r-3 MS. NELSON: Objection. Calls for

L4 speculation. Go ahead.

rs A. I don't know.

re Q. Okay. You've testified earlier - and for

J"7 the purpose of this question I'll include attended, to

18 include the time that you had to call in, you attended

r.e every public meeting of The Commission; is that

2o correct?

zt A. Correct.

Page 68

1 any advertisements or notifications that were

z different - I'm sorry - targeting racial and ethnic

: diversity that were different from the notifications or

¿ advertisements that were given to the public at large

s notifying them of the application and selection process

e for growers' licenses?

t A. No.

a Q. Okay. Sitting here today, can you tell me

s specifically any action The Commission took to actively

10 seek racial and ethnic diversity in the application and

11 selection process for growers' licenses?

tz A. ls this in consideration of the memorandum

13 to Delegate West?

r¿ Q. I can't answer questions to you. And

1s I'll - I promise you I'll give you a chance to talk

15 about Delegate West's letter.

tt A. Okay. Then my answer is no.

re Q. Okay. I believe you told me a moment ago

r.e that you were aware that the law, as written by the

20 legislature, states that The Commission shall actively

zL seek racial, ethnic and geographic diversity in the

Page 66

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Page 67

r application and selection process. You are aware of

z that, correct?

s A. Correct.

+ Q. Can you tell me why it is that if that's

s the law, you have just testified that you are not aware

s of any action that The Commission took to implement

z that part of the law?

e MS.NELSON:Objection.g A. Regarding the discussion we've had to this

i-o moment?

rr Q. Yes, sir.

tz A. I have - I can't answer that.

r¡ Q. So the answer is you don't know why The

!4 Commission took no action to actively seek racial and

r.s ethnic diversity in the selection and application

r-5 process?

L7 MS. NELSON: Objection. Mischaracterizes

LB his prior testimonY.

rg Q. Well, I'll - I'll go back. And forgive me

zo lor asking the question again, but I want to answer

2L Ms. Nelson's dep - objection, which is - and if I am

ÉIarry 'Buddy'Robshaw, III - Vol. 1

MaY 10,2017

Page 69

r Q. During any of those public meetings, do you

z recall any discussion whatsoever concerning the active

: seeking of racial and ethnic diversity in the selection

¿ and application process for a growers' license?

s A. I don't recall.

a Q. Okay. There was also private meetings of

z The Commission which commissioners and the executive

s director and maybe some staff members would attend

g in - in addition to the public meetings; is that

Lo correct?

rr A. Correct.

rz Q. During those private meetings, do you

13 recall any time when the issue of actively seeking

L4 racial and ethic dìversity in the selection process and

r-s the application process was discussed?

re A. No.

rz Q, Okay. So not to mischaracterize your

r-B testimony. I want to make sure I get it right.

1s Sitting here today, it's your testimony that you do not

20 recall any instance, whether public meeting or in

zt private session, where The Commission raised ihe issue

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1 and discussed actively seeking racial and ethnic

z diversity in the selection and application process; is

s that fair?

+ A. Well, we had - we had discussions about

s that, as I described to you earlier. Where those

e discussions went after Ms. Byron, I don't know.

z Q. Okay. So I'm going to rephrase my last

a question just so we - just so --

s A. Okay.

ro Q. Because I want to be clear for the record,

rr and I don't want to be putting words into your mouth'

L2 I really don't. Okay. So I'm going to rephrase the

r.3 question.

1-4 Other than the conversation we already had

ts concerning suggestions that were made to Ms. Byron and

16 we -- I gave you the list that you told me about, black

L7 cotleges, magazines and the like, other than those

i.B discussions, is it your testimony that you do not

19 recall any private or public meeting of The Commission

z o where the issue of actively seeking racial and ethnic

z r diversity in the selection and application process was

Page 72

1 recommendations between intergovernmental -z MR. BROWN: Yeah. I know You have -- |

¡ know you feel the visceral need to keep stating it, but

4 you don't have to.

s MS. NELSON: ThankYou.

a Q. I'm going to ask you some questions about

z last part because you added the MDOT. And to be laid

e on the table, Ms. Mather talked about MDOT in her

s deposition,

10 By the way, did you read Ms. Mather's

11 deposition that I took of her in this case?

tz A. No.

r¡ Q. You mentioned that at one of the meetings

r¿ at which MDOT was present, they mentioned a diversity

r-5 study, correct? That was one of their possible

15 suggestions?

rz A. We were interested in the possibility of

ra doing a diversity study and became aware that MDOT is

r.s the state agency that does that type of work. So we

20 had a meeting with them.

zr Q. To your knowledge, to this very day that we

Page71

r discussed?

z A. There was discussion, a great deal of

3 discussion, between Commission members and the Maryland

a Department of Transportation about diversity studies

s and about outreach. And they offered a number of

s suggestions that were essentially the same as we had

z offered in that original conversation.

e Q. To Ms. Byron?

g A. Right.

ro Q. Okay. But You --

rr A. I forgot MDOT was there. I don't want to

L2 leave them out.

rs Q. I : and I appreciate that. And, again,

r+ just to be clear, this is not a memory test, lf you --

1s if you answer a question of mine and 20 minutes later

16 you think of something you need to add, just say, hey,

J-7 Mr. Brown, could I acld something to one of my prior

1B answers. That's totallY fine.

rg A. Okay.

2o MS. NELSON: And, Counsel' I appreciate

21 your honoring the standing objection with regard to

Page 73

r are sitting here at this deposition, has a diversity

z study been conducted at the request of or on behalf of

¡ The Commission or DHMH regarding the medical marijuana

4 growers' license, medical cannabis growers' license?

s A. We discussed at that meeting the

e possibility -- or the -- the actions that would be

z needed to start that type of process.

e Q. That wasn't quite my question. So I'm

s going to ask it again.

10 A. Okay.

rr Q. And I - I understand, but I have to - |

L2 need an answer to this question.

r¡ A. Okay.

r+ Q. Which is up until today when we are sitting

15 here, notwithstanding the discussions that you said you

16 had, has a diversity study actually been conducted on

17 behalf of or at the requesi of The Commission or DHMH

i-s with regard to the medical cannabis growers' licenses?

rg A. Not to mY knowledge.

zo Q. Okay. ln your capacity as a commissioner

zr and as vice chairperson, if such a study had been

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Page 74

1 commissioned, do you think you would know about it?

z A. I believe so.

¡ Q. Okay. You also mentioned that MDOT

¿ discussed various outreach programs that they could

s help The Commission out with in reaching out to the

e minority, racially and ethnic diverse communities.

z A. Right.

e Q. To your knowledge, after MDOT told you what

9 they could and could not do, did The Commission request

r.o their assistance in actively seeking racial and ethnic

11 diversity in the application and selection process for

L2 growers'licenses?

rs A. MDOT suggested that we hire a diversity

L4 consultant.

rs Q. Okay.

re A. And I think they were consulted on the one

t7 that we actually hired, but I'm not positive of that.

ra Q. Okay.

Ls MR. BROWN: Ms. Byron [sic], I understand

20 that you are not under oath, but I'm going to ask you

2r if --

Page 76

t requested that you provide, and you said you would, and

z I haven't received them yet. I know it's - it hasn't

: been that long, but I would ask that you try to get

e that stuff to me as soon as You can.

s MS. NELSON:Sure.

o MR. BROWN: Thank You.

7 (A discussion was held off the record')

a Q. Do you remember when the MDOT meeting was?

g Well, I shouldn't: that's a bad question. Was there

10 more than one MDOT meeting?

rr A. There was more than one. There was only

t2 one that I attended. And within the last several

13 months, last six months. I don't -r¿ Q. Okay.

rs A. I don't know the exact date.

rs Q. So would that be before or issue -- before

!7 or after the issuance ofthe Stage 1 approvals?

ra A. After.

rg Q. Okay.

zo A. Preapprovals.

zr Q. You are right. Preapprovals. Term of art,

Page77

r and I should have that right. So thank you.

z Was it MDOT that provided the commissioners

¡ with the list of possible outreach methods other than

¿ the diversity consultant that you all gave to

s Ms. Byron?

s A. No. We gave them to Ms. Byron before we

z met with MDOT.

s Q. Okay. So other than suggesting a diversity

s consultant, can you tell me what other, if any,

10 suggestions MDOT made to the commissioners with regard

rr to assisting them with actively seeking racial and

12 ethnic diversity in the selection and application

13 process for a medical marijuana grower's license?

re A. There was discussion about a diversity

15 study. And maybe I'm not using the right term there.

re Q. You are * that's fine. Disparity study?

rz A. Disparity study. Excuse me.

re Q. That's okaY.

rg A. And the discussion centered around costs

zo and the mechanism to get that going and the lack of

2r comparatives, for lack of a better term. That

Alternative Medicinc Maryìand, LLC vs

Natalie M. Laprade MMCC' et al.

Page 75

THE WITNESS: Ms. Nelson.

MR. BROWN: I called You Ms. BYron.

MS. NELSON: That's okaY.

MR. BROWN: I'm - Ms. Nelson' Sorry.

MS. NELSON: No Problem.

MR. BROWN: Do You know the name of the

diversity consultant, and if you do, will you tell me

it, that information?

MS. NELSON: I - I can -- the name is

rather difficult to pronounce. And so I think it's

A-t-l-O-V GrouP.

MR. BROWN:Group?

MS. NELSON:Yes. But I can confirm that

for you and provide that to You.

MR. BROWN: Okay. lwould ask you to also,

if there is a written request for proposal, and/or a

contract with that group, that you provide that to me

as well.

MS. NELSON:Sure.

MR. BROWN: And just for the record, there

was a list of items from Ms. Mather's deposition that I

Harry 'Buddy' Robshaw, III - Vol' IMaY l0'2017

L

t

3

4

5

6

7

I9

L0

11-

L2

13

!4L5

16

L7

18

19

21

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Page 78

r discussion was ongoing. I understand that it's an

z expensive proposition. So that -- that information had

: been going - ongoing this :+ Q. So other than suggesting possibly retaining

s a diversity consultant and possibly conducting a

e disparity study -- two different things.

z A. Right.

e Q. -- were any other suggestions made by MDOT

g to the commissioners concerning the active - actively

10 seeking ethnic and racial diversity in the selection

rr and application process for a medical cannabis grower's

L2 license?

rs A. They provided essentially the same

L4 information that we had given to Ms. Byron.

rs Q. Okay.

r.6 (The reporter asked for clariflcation.)

rz Q. Does The Commission have a budget?

ra A. Yes.

rs Q. Do you know if there is a line item in the

2o budget for advertising?

zt A. No.

Page 79

r Q. You don't know or --

z A. I don't know.

s Q. - there isn't one? You don't know.

+ A. I don't know.

s Q. Okay. Did you, in your capacity as a

e commissioner, and/or your other capacity as vice

z chairman of The Commission, ever go out and speak to

a community groups concerning the selection application

9 process in general?

ro A. I have knowledge that other commissioners.

r.r- For myself, no.

rz Q. Okay.

r¡ A. I have other - I have knowledge that other

14 commissioners have attended a great deal of meetings

r.s upon request from many, many people in the medical

16 cannabis industry.

rz Q. Okay. Do you know if any commissioners

1B specifically went to any groups or organizations to

19 speak about any kind of program or policy of The

20 Commission to actively seek racial and ethnic diversity

2L in the selection and application process for a medical

Page 81

r exhibit to the transcriPt?

z MR. BROWN: Sure. We can do that. We are

: going to change the mark -- the mark -- make that 5

¿ instead.

5 (A discussion was held off the record.)

e Q. You : you mentioned to me earlier, Mr'

z Robshaw, the letter from Delegate - to Delegate West

e from Ms. Rowe; is thal correct?

g A. That's correct.

ro Q- Okay. Based upon your mentioning to me

i.r. prior to me asking you about it, I assume you've seen

L2 it before; is that correct?

r: A. That's correct.

r+ Q. Tell me the circumstances around which you

15 came to become aware of this letter?

re A. lt was the topic of discussion at a number

r7 of executive meetings.

re Q. Okay. And tell me about why was it the

r.e topic of discussion?

20 MS. NELSON: I'm going to object to the -2L on the deliberative process privilege, but also on

Alternative Mcdicine Maryland, LLC vsNatalie M. Laprade MMCC' et al.

Harry 'Buddy'Robshaw, III - Vol. 1

MaY 10, 2017

Page 80

r marijuana grower's license?

z A. I don't know.

: (Robshaw Exhibit 5 was marked for purposes

a of identification.)

s Q. I am - | have shown you what we've marked

e as Exhibit Number 5, which is a letter to Delegate

z West - and by the way, there is two pages at the end

a that should come - my assistant accidentally attached

s to Ms. Mather's deposition - affidavit to that.

i"o MR. BROWN: Thank You.

rr Q. A letter to Delegate West. And it's now --

L2 apparently this is not the complete letter. I will -13 I will - I think the last Page is -14 (A discussion was held off the record')

rs Q. I will - I will represent to you,

16 Mr. Robshaw, and Ms. Nelson, that the last page of this

!7 letter only has the signature of Kathryn Rowe. There

1B is no text whatsoever. lt just has her signature. So

1s l'm going to just make that the exhibit and I'll state

20 for the record that the last page -2L MS. NELSON: Would that one be used as the

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Page 83

r. heard the explanation, so -- but I have seen the

z letter -- suggested that there was a constitutionality

3 issue with trying to put in the legislation the racial

+ and ethnic part of it. And in addition to that * as

s it was explained to us.

e Q. Who was it doing the exPlaining?

z A. Ms. Byron. And I don't know if there was

I a -- an AG explanation in there or not.

g Q. Okay.

r.o A. I - I don't -- I'm not sure.

rr Q. Okay.

12 MS. NELSON: That's where we would object

r.3 on attorney-client privilege.

i"4 MR. BROWN: Well, right now he just said

1s Ms. Byron and he's not sure if there was an attorney

16 there. So if he's -- there was no attorney there,

r7 there is no attorney-client privilege.

r"B MS. NELSON: lt seems unlikely that the

i-9 executive director was offering legal advice on

2o constitutionality.

zr A. There was an attorneY there.

HarrytBuddy' Robshaw, III - Vol. 1

May 10,2011

Page 85

t requested changes in the law that Ïhe Commission was

z making to the legislature, and you told me that one of

s them that you recall is expanding the breadth of

+ professionals that will be allowed to recommend the use

5 to a patient of medical cannabis; is that correct?

e A. Correct.

z Q. Okay. After we've had this discussion now,

I do you recall whether The Commission requested the

s legislature to change the law so that the requirement

10 of The Commission to actively seek racial and ethnic

11 diversity be removed?

tz A. I'm not aware of that.

r¡ Q. Okay. You're aware, I believe, that this

!4 letter to Delegate West from Ms. Rowe was requested by

1s Delegate West and not The Commission; is that correct?

re A. That's correct.

rz Q. Okay. To your knowledge, without telling

1B me what the advice was, if it existed, did The

i.9 Commission ever seek its own legal advice concerning

20 the constitutionality of the provision of the enabling

2L legislation which requires The Commission to actively

Iili-:1.-¡, I i,.1 ii¡i' Gore Brothers Reporting & Videoconlèrencing410 837 3027 - Worldwide - wrvrv.gorebrothers.com

r Q. Okay. But -- I understand. So - but

z basically it was your understanding that this letter

3 from Delegate - from Ms. Rowe -- Rowe to Delegate West

¿ raised issues concerning constitutionality?

s A. Correct.

e Q. Okay. Did anyone * is it - was it this

7 concern about constitutionality which caused The

s Commission to remove rac¡al and ethnic diversity from

s the regs?

ro A. That's my understanding.

rr Q. To your knowledge, the legislation

12 requiring The Commission to actively seek racial and

13 ethnic diversity in the application and selection

14 process is still law to this day as we sit here; is

1s that correct?

re A. Yes, I - I suppose. I'm -rz Q. Okay.

ra A. I'm not positive. That's a legal question.

r-s l'm not positive of that.

zo Q. Okay. Well, Iet me ask you this question.

zr We talked a little bit earlier about suggested or

Page 84

r attorney-client privilege to the extent that this was

z the subject of advice received by counsel.

s MR. BROWN:Well-4 MS. NELSON: At this - not to say that the

s letter is attorney-client advice. To the extent that

e it was discussed in that context, obviously we would

7 assert the attorney-client privilege.

a MR. BROWN: I understand.

9 Q. You can answer the question.

ro A. Can you ask me the question again?

rr Q. Sure. Sure. What about this letter caused

L2 it to be the topic of discussion at an executive

13 committee meeting?

14 A. The original regulations included the

15 terminology actively seek racial and ethnic and --

16 diversity in addition to geographic diversity.

rz Q. Well, he said the original legislation?

re A. The original regulation -rs Q. Regulation. OkaY. Got it.

2o A. -- had all that terminology in there. An

2! explanation of this letter -- I saw this letter after I

Page 82

(21) Pages 82 - 8s

E 000560

r the Black Caucus.

z Q. Give me one second. Sorry about that.

: Anyone else you can recall being there?

¿ A. May I ask counsel just the name of that

s delegate? I know her. I just cannot think of her

6 name.

z Q. lf Ms. Byron -- did it again. lf

a Ms. Nelson knows, that's fine.

g MR. WARNKEN: ls it Cheryl Glenn? Sorry.

ro A. CherylGlenn.

rr Q. Okay.

tz A. That's - that's who it was.

rs Q. Thank you. Anybody else that you can

L4 recall being there?

rs A. I don't know any of the other people.

re Q. Okay. Other than yourself and the

L7 delegates or the senators, was -- was anybody else

18 there at that meeting?

rs A. Myself. Allison Taylor. And there was a

z o third commissioner I don't remember off the top of my

2r head.

Page 88

r seek racial and ethnic diversity in the application and

z selection process?

s A. l'm not : | - I can only answer that by

+ saying that I'm not certain.

s Q. Okay. But you are certain that Exhibit 5,

e the letter to Delegate West, was discussed either at a

z Commission meeting or at an executive committee

a meeting; is that correct?g A. lt was discussed there as well as at a

1o meeting we had with the Black Caucus. We had the same

rr discussion.

rz Q. Okay. When was the meeting with the Black

13 Caucus?

r¿ A. I don't -- I don't know the date.

rs Q. Was the meeting with the Black Caucus -re well, let's go back because I didn't say the date. So

L7 Exhibit Number 5, the letter to Delegate West was

18 written on March 131h,2015?

rs A. That's right.

zo Q. You would agree with me that March 'l3th,

zt 2015, was before Stage 1 preapprovals were issued,

Page 86

Alternative Medicine Maryland, LLC vsNatalie M. Laprade MMCC, et al.

Page 87

r correct?

z A. That's correct.

¡ Q. Was the meeting with the Black Caucus

¿ before or after the letter from Delegate West?

s A. After.

e Q. Okay. Was the meeting with the Black

z Caucus before or after the issuance of the Stage 1

a preapprovals?

g A. After.

ro Q. Do you remember -- when you say "with the

1r. Black Caucus," that's a group of state senators and

tz delegates, Afrìcan-American members who comprise the

13 legislative Black Caucus; is that correct?

r¿ A. Correct.

rs Q. Can you tell me, sitting here today, if you

r.6 recall any of the specific legislators, whether a

L7 senator or a delegate, that were at this meeting with

re the Black Caucus?

rs A. The only person I remember -- the only

20 person I even knew was -- I'm terrible with names. I

zr apologize. She is the head of -- or the chairman of

Harry'Budtly'Robshaw, III - Vol. 1

MaY 10,2071

Page 89

r Q. Okay. And what was discussed at that

z meeting, which was after the Stage 1 preapprovals were

s issued?

+ A. Essentially the Delegate West decision.

s Because that had to have been forwarded to all -e both -- all members of the senate and the delegation.

z Q. When were the Stage '1 preapprovals issued?

e What date?g A. I don't know the exact date.

ro Q. Do you remember --

rr A. August - August Sth.

rz Q. What year?

r¡ A. 2016.

r+ Q. Okay. So the Stage 1 preapprovals were

rs issued more than a year after Ms. Rowe wrote the letter

16 to Delegate West; is that a fair statement? Because

r-7 that * August o'Í 2016 is more than a year after March

r-B of 2015.

rg A. Wait a second now. I'm now -- they were

20 announced August Sth. So ask me the question again. I

2r apologize.

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(22) Pages 86 - 89

E 000561

1 MS. NELSON:Effective October 1st.

z THE WITNESS: Oh, okay.

s MR. BROWN:Okay. That's correct. Off the

e record.

s (A discussion was held off the record.)

e Q. Did you read -- go back. I'm sorry. Was

z there any committee or subcommittee of The Commission

e that was tasked specifically with regard to addressing

s potential constitutional issues with the language of

ro the legislation which says that The Commission shall

11 actively seek racial, ethnic diversity in the issuance

rz and selection of medical cannabis growers' licenses?

r¡ A. I don't know.

r¿ Q. Okay. Did you read Delegate - the letter

ls to Delegate West from Ms. Rowe?

re A. At some time, Yes.

rz Q. Okay. ls it your understanding that the

1e letter indicates that The Commission cannot conduct

1s race or ethnic conscious criteria in the selection

2O process?

zr A. That's the explanation provided.

Page 92

r Q. Sure. So it's fair to say - just math and

z a calendar - that the Stage 1 preapprovals were issued

3 more than a year after Ms. Rowe's letter to Delegate

¿ West?

¡ A. Somewhere in that time frame, correct.

e Q. March 13th, 2015. August 5th, 2016.

z That's more than a Year, right?

e A. Okay.g Q. Yes?

ro A. Yes.

rr Q. So it's your testimony that in that one

L2 year, approximately five-month interval, no one from

13 The Commission met with the legislative Black Caucus or

L4 its members to discuss the contents of the letter to

1s Delegate West?

i"6 MS. NELSON: Objection. Mischaracterizes

1-7 his prior testimonY.

r-B MR. BROWN: lthink it states it precisely.

rg Q. But if I misstated it, go ahead'

zo A. I don't know of anY meeting.

zr Q. Okay. Are there any attorneys actually who

Page 90


Page 91

t are members of The Commission? I'm not talking about

e AG - the AG's office, you know, having a lawyer for

: you from - bul l'm talking about actual members of The

¿ Commission who are actually themselves attorneys?

s A. I think three.

e Q. Okay. Can you tell me who they are?

t A. Eric Sterling who I understand to be - is

B a nonpracticing attorney.

g Q. Okay. But he's a member of the bar' But

10 go ahead.

rr A. I don't even know if he's a member of the

L2 bar. I can't -- don't know that.

r: Q. Okay.

r+ A. John Gontrum I believe is an attorney.

15 Works for the comPtroller,

re Q. Okay.

rr A. And Allison Taylor I believe is an -- she

r-8 was with The Commission during this time period. Now

1e has a different function at -- within the Department of

20 Health and Mentaì Hygiene. Or its got a new name now.

2L I don't know.

Harry 'Buddy'Robshaw, III - Vol' IMay 10,2017

Page 93

r Q. Would it be more accurate in your

z understanding that that would be true in the absence of

: a disparity study, but if a disparity study were

4 conducted, then, in that instance, The Commission could

s consider race and ethnic conscious criteria given the

e results of the disparity study in the selectlon and

r application process?

e A. That is my understanding.g Q. But sitting here today -- as we sit here

10 today, to this day, a disparity study has not been

i.r. conducted; is that correct?

tz A. Not to my knowledge, no.

r¡ Q. Okay. Notwithstanding the fact that the

L4 law specifically states that racial and ethnic

1s considerations -- strike that.

16 I'm going to state it precisely. That The

1.7 Commission shall consider and actively seek racial and

r.B ethnic diversity in the application and selection

19 process --

20 MS.NELSON:Objection.

2r MR. BROWN: I haven't even finished my

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(23) Pages 90 - 93

E 000562

r. other way you want to phrase it, and say, hey, wait a

z minute, we got a problem, we haven't - and I'm

r paraphrasing here obviously -- we haven't considered

+ racial and ethnic diversity in the licensing process,

s that could raise a problem for us? Did that happen, or

e anything like that?

z A. No. ln light of the West letter, for lack

a of a better terminology -g Q. Right.

ro A. - that - that subject was not discussed

r-r. again.

rz Q. Well, doesn't the West letter talk about

13 conducting a disparity studY?

r¿ A. The West letter also alludes to the fact

15 that the capability to conduct a disparity study in the

16 absence of - and I really don't know the terms that

rz describe what - whal some of the problems here are.

18 ln the absence of -- because this is a new

1s growth or an upstart industry, in the absence of

20 comparables - and that may be the wrong word,

2r unfortunately, is why it could not be done at that

Page 96

r question yet.

z MS. NELSON: lt's - but you are misstating

: the statute.

¿ Q. Okay. You would agree with me that the

s statute states that The Commission shall actively seek

s racial and ethnic diversity in the application and

z selection process?

a MS.NELSON:Objection.g MR. BROWN: OkaY.

10 MS. NELSON: That's not what the statute

r"r. says.

i-2 MR. BROWN: Tell me what you think the

13 statute says.

14 MS. NELSON: Shall actively seek to achieve

15 racial and ethnic diversity in licensing.

16 MR. WARNKEN: That's not what it says

r7 either.

18 MS. NELSON: Do You have it handY?

1s MR. WARNKEN: "The Commission shall

zo actively seek to achieve racial, ethnic and geographic

2r diversity when licensing medical cannabis growers'"

Page 94


Page 95

r MS. NELSON: ThankYou.

z Q. Okay. Why is it, if you know, that The

s Commission was advised that it could make -- that the

+ law requires those considerations to be made when in

s the licensing process, that The Commission received

e advice that they could make those considerations if a

z disparity study was conducted? No disparity study was

g conducted, but nonetheless, Stage 1 preapprovals were

g issued. Why is - why did that happen?

ro A. I don't know.

rr Q. Who made the decision to issue Stage 'l

lz preapprovals, notwithstanding the facts that I just

13 outlined to you in my last question?

ra A. I don't know the - | don't know the

i-s individual that brought that issue up. I don't know

16 that. I know we voted on those preapprovals as a

ri commission.

re Q. At any time during the vote when -- we'll

re get to RESI in a little bit - when you got the

zo rankings and you were going to come to vote, did anyone

zr speak out, raise their hand, express concerns, any

Ilarry 'Buddy' Robshaw, III - Vol. 1

lIaY l'0,2017

Page 97

r time.

z Q. Did The Commission ever talk about putting

¡ on the brakes on the issuance of Stage 1 approval --

a approvals pending the disparity study?

s A. I'm not certain of that.

e Q. Well, is -- you are not certain. Was it

z discussed?

e MS. NELSON: Objection. Asked and

g answered.

ro A. I don't know specifìcally if it was

11 discussed or not.

rz Q. So I was asking you about Stage 1

13 preapprovals. But now Stage 2 licenses are getting

t4 ready to be issued; is that correct?

rs A. Sometime in the near future.

ra Q. Right. Well, now that the governor -- and

17 we have it as an exhibit -- has ordered a disparity

1B siudy to be conducted, has The Commission discussed

1s halting or delaying the issuance of Stage 2 licenses

2o until such time as a disparity study is conducted,

2r completed and reported to The Commission?

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r- A. Not to my knowledge.

e Q. Okay. ln your capacity as a commissioner

¡ and as vice chair of the commissioner [sic], if such a

+ discussion were taking place, you would know about it'

s wouldn't you?

s A. I guess I should clarify my position. The

z explanation regarding the West letter was about

a constitutionality issues. And about the fact that a

s disparity study could not be conducted at this time

10 because - I say comparables, and I apologize forthat.

i.1 I don't know the terms --

rz Q. I understand.

rs A. - by which you gather information to see

r¿ whether there is a disparity or not. I don't know that

1s terminology. That - that - that those two things is

re what caused the removal of that from the regulations.

rz Q. Were the -- was there a discussion made

r"B about possible -- made. Was a discussion had about

1e possible comparables for a disparity study purpose?

zo A. Yes.

zr Q. Well, medical marijuana is medicine.

Page 1 00

r. completion of the study which the governor has ordered

z to take place?

s MS.NELSON:Objection.

+ A. Not withstanding the fact that the Cannabis

s Commission is committed to getting medical cannabis to

e patients in Maryland as soon as possible, I don't know

z why that - that - I can't answer your question. I

e don't know the answer.

s (A discussion was held off the record')

ro Q. I should have said it at the beginning. lf

rt at any point you need a break, tell me and we'll take a

1-2 break. Okay?

r¡ A. I'm fine.

14 (Robshaw Exhibit 6 was marked for purposes

i"5 of identification.)

re Q. Mr. Robshaw, I'm showing you what I've

L7 marked as Exhibit Number 6. And this is a transcript

ts of an open meeting of The Commission that was held on

rs August the 5th, 2016. And as you see on the very first

20 page, you were the first person to begin speaking' Do

2r. you see that?

Page 99

r That's what they call it, medical cannabis, correct?

z A. Right.

¡ Q. So were -- was the possibility of comparing

+ medical cannabis to the pharmaceutical industry, for

s example, considered as a comparable for disparity siudy

e purposes?

z MS. NELSON: Referring back to my standing

a objection. Thank You.

s A. I - I believe so. And I believe also that

10 MDOT felt that that wasn't a comparable. And that

r-1 MDOT, as far as I know, are the specialists in this

L2 field. lt's certainly not my specialty.

r¡ Q. But now the governor has ordered a

14 disparity study to take place, hasn't he?

rs A. That's how: that's how I understand it.

ro Q. So now that a disparity study has been

r7 ordered to be -- to take place, and it is a disparity

1B study which would allow The Commission to consider

19 racial and ethnic diversity in the issuance of

20 licenses, why is it that The Commission hasn't halted

2L the issuances -- issuance of licenses pending the

Page 101

r A. Correct. Yes.

z Q. Okay. Have you ever seen this transcript

¡ before?

+ A. I believe I have.

s Q. And I'm going to ask you to trade with me

e because I have my highlighted notes on that one'

z (A discussion was held off the record.)

e Q. And I would like, if you would, to -- turn

s to Page 3, about two-thirds of the way down.

ro A. Okay.

rr Q. And it says - the line that starts with

!2 "Cannabis Commission." Do you see that?

r¡ A. Yeah.

r+ Q. Okay. So I'm going to go up a little bit

15 because I'm going to start from the first sentence.

L6 The beginning of that sentence. You said, "ln Phase 2

L7 we took a different perspective and looked, because the

1B statute, the superseding statute of the legislation for

Ls Medical Cannabis Commission, stated specifically in

20 133306(AX9)(i)1 'The Commission shall actively seek

zr geographic diversity when licensing medical marijuana

Alternative Medicine Maryland, LLC vs.Natalie M. Laprade MMCC' et al.

Harry 'Buddy' Robsharv, III - Vol. IMaY 10,2017

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Page 1 02

r. growers."' First of all, did I read your testimony

z correctly?

3 A. That's correct.

¿ Q. Okay. ls there a reason when you gave that

s testimony you omitted the section or the words of the

e legislation which also speak to racial and ethnic

z diversity in licensing medical marijuana growers?

e MS. NELSON: Objection.

s Mischaracterization, but go ahead. lt's not the

ro testimony.

rr A. Was there a reason, no.

rz Q. Why didn't you refer to racial and ethnic

13 diversity when quoting directly from this statute and

14 only refer to geographic diversity?

rs A. I guess l'm repeating myself in - in light

16 of the lest -- West memorandum. lt was not under

L7 consideration at that time.

re Q. Okay. But the legislation didn't change,

Lg to your knowledge, correct?

zo A. Correct.

2L (A discussion was held off the record.)

Page 1 04

r Q. lt's in the same sentence of the law,

z right?

¡ A. Yes.

¿ Q. Okay. Did The Commission ever receive

s direction from anyone to cease consideration of racial

e and ethnic diversity in the licensing process?

t A. I don't like the word "cease," but we were

e given legal advice not to consider that.

g MS.NELSON:Objection.

ro Q. And I - and just so you know for the -rr for the record - and I -- I know we are on opposite

L2 sides of the table, but I mean this sincerely because

13 I - I don't want you to tell me what your lawyers told

L4 you. Okay?

rs A. Okay. Then I -re Q. So -- and we can -- when I asked you did

L7 you ever receive instruction from anyone, that doesn't

18 include your lawyers.

rs A. Okay.

zo Q. Okay?

zr A. Thank you for that.

Page 1 03

r Q. You went on to say in your testimony, which

2 you still have in front of You --

¡ A. Uh-huh.

¿ Q. - that, "We interpreted that to mean from

s the legislation that" -- I'm sorry. I'm going to start

5 over again because I misstated it. "We interpreted

z that to mean from the legislature, that they thought

a that was pretty important, and as a result, we thought

g it was pretty important too." Do you see that?

ro A. Yeah.

rr Q. Okay. So you thought that "you" being The

12 Commission, and you particularly as a commissioner,

r-3 thought that - the legislature thought that it was

14 pretty imporlant to have geographic diversity in the

r-5 licensing process; is that correct?

rs A. That's correct.

rz Q. But the legislature also thought,

1B therefore, that it was pretty important to have racial

r.s and ethnic diversity in the licensing process; isn't

20 that correct?

zr A. Yes.


Harry 'Buddy' Robshaw, lll - Vol. 1

M.aY 10,2071

Page 1 05

r Q. That's - that's fine.

z A. So my answer is no.

¡ Q. Okay. And I'll - I'm going to rephrase

¿ that a bit. Okay. I have the right to know that

s you're not answering a question because it's based on

e legal advice. Okay. So don't just answer no in the

r future saying I'm not going to say something like -- in

e a paraphrase, I'm not going to answer that question

9 because it's based on result -- advice I received from

10 counsel. Okay. Because I have the right to know

11 you're asserting a privilege because I have the right

!2 to challenge a privilege that you are asserting.

i-3 So don't -- so other than from lawyers, did

14 you ever receive advice from anyone, or direction from

r.s anyone, to stop considering racial and ethnic diversity

r.6 in the licensing process?

rz A. As I described, Hannah had discussed this

r,B too.

rg Q. Okay.

zo A. And I'll stop there.

zr Q. Okay. I'm asking these questions because I

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1 number of growers and dispensar¡es that are allowed?

2 A. No.

¡ Q. Okay. Did you have any involvement in the

a amount of processors that would be permitted by

s regulation?

e A. No.

z Q. ls there a limit on the number of

e processors?

g A. No.

ro Q. So that as far as that is concerned, the --

rr The Commission issues processors' licenses; is that

a2 correct?

rs A. Correct.

r¿ Q. And there is no limit on that as - like

ts there is for growers and/or dispensers -- dispensaries?

re A. We imposed a -- not a cap of any measure.

L7 We imposed a limit of 15 as a starting point because

18 our concern was that with growers coming up, processor

19 coming online, and dispensaries, we wouldn't have the

20 compliance and inspection capabilities to all those

zr things at one time.

Page 1 08

r don't know the answer. Does the legislation limit the

2 number of growers and processors, or is that something

¡ that's set forth in regs that are promulgated as a

+ result of the legislation?

s A. The legislation limits the number of

5 growers and the number of dispensaries. lt has no, no

7 Cap on -- on processors.

a Q. Did you have any input into the legislation

s itself, or did you get involved after the legislation

i"o was already enacted? Not the regs, the actual

i,i. legislation?

tz A. I had no involvement in that.

r¡ Q. Okay. So when you became a commissioner,

L4 the limits on the numbers of growers and distributors

15 was already in effect?

re A. On growers and dispensaries.

rr Q. I'm sorry. You are right.

ra A. Right.

rg Q. That was already set in the law. You had

20 nothing to do with the number whatsoever?

zt A. Correct.

Page 1 06


Page 107

r Q. Okay. Are you aware of any efforts by The

z Commission or any of its members to modify or change in

3 any way the number of growers and dispensaries that are

+ currently provided for in the legislation?

s A. No.

e Q. Okay. ls there a difference between a

7 grower and a processor?

e A. Yes.g Q. And there is also a difference between a

10 grower, a proÇessor, and a dispensary, correct?

rr A. Correct.

rz Q. What's the difference between a grower and

l-3 a processor?

r¿ A. A grower actually produces medical

r-s cannabis.

re Q. Okay.

rz A. A processor takes that medical cannabis in

r-B the leaf form and converts it into oils and aerosols

19 and other means of aPPlication.

zo Q. ls there a limit in the legislation to the

zt number of processors that are allowed as opposed to the

Ilarrv 'Buddy' Robshaw, III - Vol. II\{ay 10, 2017

Page 1 09

r So the * the processor limit of 15 was a

z temporary stay, if you will, in order to get - allow

s The Commission's compliance process to come up and

+ running.

s Q. Okay. I want to get to the -- the

e application process itself for a moment. What, if any,

z role did you have in designing the application that

I growers, processors and dispensary applicants would

g need to complete in order to apply for a license?

ro A. I played a small role in the security

11 aspect of the application.

rz Q. And you, I suppose, drew from your law

13 enforcement experience in doing so?

ra A. That's - that's why I was on The

1s Commission to start with, from the security aspect.

re Q. Right. Other than the security aspect, did

17 you have any role in the design of the application?

re A. No.

rs Q, Can you tell me what research or

20 investigation you conducted in order to become aware of

z:- what security procedures would need to be present at

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Alternative Medicine Maryland, LLC vs.Natalie M. Laprade MMCC' et al.

Ilarry 'Buddy'Robshaw, III - Vol. 1

MaY 10,2017

Page 110

r. a -- the various types of facilities?

2 A. First of all, 43 years of experience as a

3 police officer. But I had been trained and I conduct

4 home and commercial security surveys, specifically in

5 our town, but when I was with the county, I did them in

6 environmental design. And I've also had the

z opportunity to visit an existing grow location.

a Q. Where?

e A. ln Washington, D.C.

ro Q. Did you attend any courses, seminar, online

rr education concerning specifically the security needs of

L2 growing facilities, dispensaries and processing

13 facilities?

r¿ A. No.

rs Q. Okay. I understand that you have over 40

r.6 years of law enforcement experience, but would you

r7 agree with me that given the nature of these

18 businesses, the security concerns of -- may be

1e specialized to the industry?

zo A. No.

21 Q. WhY not?

Page 112

r in D.C.?

z A. I don't know the name of the company. lt

3 was in southeast.

¿ Q. lf I asked you through counsel to provide

s me with the location, would you be able to look back on

5 your logs and tell me that?


a A. I don't - I don't know.

g Q. Let me ask you this question.

ro A. I didn't arrange the meeting. I just went.

u Q. Did anybody go with you from The Commission

L2 or from anyplace else?

r¡ A. I believe Eric Sterling went. And I

i.4 believe Debbie Marin went.

rs Q. Was it prearranged.

re A. Debbie Marin arranged.

rz Q. When did you go?

re A. Probably a year and a half, two years ago

1s probably.

zo Q. So before the issuance of Stage 1

2r preapprovals?

Page 111

r A. You are securing a product, whether it's

z medical cannabis, whether it's valuables.

¡ Q. So it doesn't make a difference whether you

a are talking about a cell phone store or medical

s cannabis, it's all the same?

e A. Well, I think the -- let's compare the

z security of a bank with the security of a 7-Eleven

s store. I mean, there is -- you can argue they - they

s say they need the same security. I would disagree with

i.o that statement.

rr Q. Right. So I guess my question -- how is it

r.2 that you made yourself aware of the security needs for

13 this particular type of business?

r¿ A. Like I said, I have had particular training

1s in home - residential and commercial security. I

i.5 visited a grow location in D.C. without speaking to

Li them about their security issues. I noted those things

1B myself. And then I applied what I know and what I have

r.e observed into the best protection that I think is

20 possible for a grow location.

zr Q. Where - which grow location did you go to

Page 1 '13

r A. That's correct.

z Q. Okay.

s A. Before the regulations were written --

¿ written regarding security.

s Q. Right. Because that's - you used your

5 expertise and the visit that you made to this facility

z to assist you in putting together the security portion

e of the application, right?

g A. Right.

ro Q. Okay. This is going to sound like - if

r.1 I ask you * if we got in a car right now, could you

!2 drive me there from memory?

r¡ A. No.

r¿ Q. Okay. All right.

15 MR. BROWN: l'm at a bit of a breaking

15 point. lf you want to take a little bit.

17 (A recess was taken.)

re Q. So I wanted to circle back. I checked my

1e notes a little bit over lunch. You stated that the -20 there is no longer a medical or a grower's licensing

2L subcommitlee because the preapprovals have been issued.

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Page 114

r ls that - is that fair?

z A. That's fair. The limit has been reached

r set by the legislature.

¿ Q. So there is no need for the subcommittee

s anymore?

e A. Well-r Q. Let me ask You a different waY'

e A. Five additional licenses were granted to

s make a total of 20. Unless that got exceeded.

ro Q. Okay.

rr A. I can't imagine why we would have a growers

L2 subcommittee meeting again.

rs Q. Right. So my question to you is, is there

14 a subcommittee that's been established to regulate or

15 oversee the growers themselves as opposed to the

i.6 potential licensees? I know there is an enforcement

L7 division. I getthat. But is there - I'm talking

1B about a subcommittee within The Commission that's

r.9 overseeing the - the future growers?

zo A. I would say absent the compliance structure

zr within The Commission, no.

Page 116

r buffered that out with five.

z Q. They are waiting in the bullpen in case

s something fell apart?

a A. That's - that's a fairly good analogy, I

5 guess.

e Q. Okay. All right. So I'm just making this

z up. I know there is no -- nothing hidden in this

a question.

e A. No.

ro Q. lf, for example, Grower X for whatever

r"1 reason wasn't able to qualifu for a Stage 2 approval'

rz then in that instance Number 16 would step up and be

r.3 in - fill that spot? ls that a fair way to put it?

r¿ A. That's correct.

rs Q. All right. Are those - go back. There

16 were two growers who were in the top 15 who then got

r7 bumped out in lieu of two growers who were in the top

r-s 20, but not in the top 15; is that correct?

1e MS. NELSON: I'm going to object again.

20 lnvoking my prior deliberative process privilege. Also

2! relevance. But go ahead.

Page 117

r Q. Go ahead.

z A. I'm not sure of that. I think one of the

: six -- it was either the 20th or the 2 'l st position. I

¿ don't recall which one got moved down.

s Q. So was it your testimony that no one in the

o top 15 who were initially informed that they received

7 preapproval were then informed that they did not have

e that preapproval?g A. I - you'll have to say that again. I

1o didn't understand You.

rr Q. Sure. You received -- "you" being The

12 Commission, received the rankings from RESI, right?

r¡ A. Correct.

r+ Q. And l've read testimony from you or

15 statements from you where you said that The Commission

r.6 as a body accepted unanimously without change the

Li recommendations from RESI; is that correct?

r-s MS. NELSON: Objection. Go ahead.

rs A. Based on the face, it was no substantial

20 reason based on evidence to do so.

zr Q. Right. And I know you had discussion about

Alternative Medicine l\llaryland, LIC vs'Natalie M. Laprade MMCC, et al.

Page 1 '15

r Q. Okay. So you said there was 15 initial,

z right? And there was five additional licenses awarded?

¡ A. Right.

¿ Q. When were the additional -- not licenses,

s the additional preapprovals awarded?

6 A. Preapprovals. At the same time'

z Q. At the same time. So there was 15

e license -- preapprovals -- don't look at Ms. Byron *s look at Ms. -

10 MR. WARNKEN: Nelson.

rr Q. - Ms. Nelson. I'll stop - stop doing

rz that. Look at me, please. lt was 15 preapprovals and

13 there was five additional preapprovals?

r¿ A. No.

r¡ Q. What was there?

re A. There was 15 PreaPProvals.

rz Q. Okay.

re A. There was an additional five selected. ln

r.9 the case that in that secondary approval process

2o someone failed, The Commission would not have to meet

2L again just to have to vote for one or two. We -- we

Harry 'Butldy' Robshaw, III - Vol' 1

May 10,2017

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Altcrnative Medicine Maryland, LLC vs.Natalie M. Laprade MMCC, et al.


MaY 10,2017

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the word "substantial" and all that. So -A. Okay.

a. Okay. So - but after that, there came a

time, because of considerations of geographic

diversity, that two growers who were initially in the

top 15 got moved out of the top 15, and two growers

that were not in the top 15 got put into the top 15; is

that correct?

MS. NELSON: Objection again to relevance.

MR. BROWN:OkaY.

MS. NELSON: This has nothing to do with

this case, and so I'm wondering --

MR. BROWN: Well, geographic diversity is

parl of our complaint.

MS. NELSON: -- on relevance.

MR. BROWN: Geographic diversity is part of

our complaint. Not just racial and ethnic diversity.

li's alleged in the complaint that our client's

geographic diversity was not considered in the awarding

or lack of awarding of our license.

MS. NELSON: Your -- I'm sorry. Where in

Page 1 20

race and ethnicity throughout the licensing process in

clear contravention of the authorization -authorizing" -- sorry: "statute. Then, The

Commission compounded it's failure by replacing top

ranked applicants with lower ranked applicants in the

name of geographic diversity, but gave no consideration

to the ethnic and racial diversity of its applicants."

So, indeed, part of our allegation is that

The Commission failed to consider geographic diversity

in addition to racial and ethnic diversity in the

awarding of licenses.

MS. NELSON: Where does it say that The

Commission failed to consider geographic diversity?

MR. BROWN: And even if you believe it's

irrelevant, and we can argue that before a court, it is

not a ground, like privilege, where you can instruct

your client not to answer the question.

So I understand your objection. But if

you're going to instruct our -- your client not to

answer the question, we can call a judge.

MS. NELSON: Your client took a position -

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the complaint is that?

MR. BROWN: Mr. - for the record,

Mr. Warnken is pointing Ms. Nelson to the relevant

portion of the comPlaint.

MS. NELSON: This has nothing to do with

your -- your clienl.

MR. BROWN: How so?

MS. NELSON:This relates to the GTI

litigation. This doesn't refer to your entity.

MR. WARNKEN: That's directly from our

complaint.

MS. NELSON:Yes. And the allegation

doesn't relate to your client; isn't that right? There

is no allegation that your client's geographic

diversity was or wasn't considered.

MR. BROWN: This is the allegation. I'll

read it for the record. "First" - Paragraph 2,

"First, The Commission was derelict in it's

legislatively mandated duty to actively seek and

achieve racial and ethnic and geographic diversity when

licensing cannabis growers. The Commission ignored

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MR. BROWN: Look, I'm not going to argue

with you.

MS. NELSON: - that consolidation --

MR. BROWN: Make -- make -- make --

MS. NELSON: - of this case with GTI was

inappropriate.

MR. BROWN:-- make your -- sorry. Make -wait a mlnute.

MS. NELSON: And now the questions being

asked relate to the GTI litigation.

MR. BROWN: I'm not asking at all about the

GTI litigation. I'm asking about this litigation. And

you have your every right, and I respect it, to make an

objection for the record, but it is not an objection

like privilege -- I'm repeating myself -- where you

are -- would be correct in instructing your client not

to answer the question. So if you are going to do

that, I'll go - l'll get the judge on the phone. I'm

not going to argue with you anymore. So if you -MS. NELSON: I would like to proffer on

relevance because I don't -

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E 000569

r diversity.

z MR. BROWN: I'm not --

: MS. NELSON: And you're inquiring about

+ deliberative process information, which I'm not going

s to instruct the witness not to answer, but which is

e relevant to GTI's case rather than yours.

z And so I'm -- I'm -- I am going to step out

s for a minute and ask for a break so that we can

g consider whether a call to chambers is - is warranted.

10 MR. BROWN: Okay. That's fine. Just so

1r- you know for the record, as you may have been aware

tz from an email that we all received from chambers, no

r.3 one is going to - Judge Williams is not around. There

14 is no one available. He - Judge Williams is not

r.s around this week.

1-6 l, in advance - in anticipation of not

L7 this particular dispute, but of a deliberative process

Ls dispute, I contacted the chambers of the judge in

1e charge of civil this morning just to find out what we

20 should do in the event we have a dispute.

2L MS. NELSON: Uh-huh.

Page 124

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MR. BROWN: The relevance is that the

complaint in general alleges failure of The Commission

to comply with the direction of the legislature to

actively seek racial, ethnic and geographic diversity.

And I have the right to ask my -- to ask your witness

questions about what The Commission did or did not do

to achieve that - those goals.

MR. WARNKEN: lf I may?

MR. BROWN:Sure.

MR. WARNKEN: We've asked for a preliminary

injunction, a permanent injunction, and a declaratory

judgment. This is relevant to all three of those.

And, again, just state the -- have a standing objection

on relevance.

MS. NELSON: ln - in what waY is this

relevant to the injunctions?

MR. BROWN:Well-MR. WARNKEN: We just read from our

complaint.

MR. BROWN: - wait. There is no

requirement under the rules for us to -- for me to

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Aìternative Medicine Maryland, LLC vsNatalie M. Laprade MMCC, et al.

Page 1 23

r debate you with regard to your objection. lf it's a

z privilege thing or other objection in that nature, I

r get it and then we would have to get -- you can

r instruct your client not to answer and then we can go

before a judge and let him or her just tell us whether

6 your objection is correct.

z For relevance or any other nonprivilege

e kind of objection - again, l'm repeating myself,

you -- you know, I'm not going to debate. Make your

objection and then we'll move foruard and we'll see

what the judge says.

MS. NELSON: l'm going to need a minute

because I'm not sure if we should call his Honor now to

sort this out.

MR. BROWN:Well, so --

MS. NELSON: l'm a little bit concerned

that your client took the position in open court that

consolidation of your case with GII was inappropriate

because the scopes of the litigation were very

different. And now we are looking at using as exhibits

discovery from the other case relating to geographìc

Harry'Buddy'Robshaw, III - Vol. IM.ay 10,2077

Page 1 25

r MR. BROWN: And I understand that we are to

z call Judge's - Judge Handy's chambers. She is the

r judge in charge of civil if we have a dispute.

a MS. NELSON: Thank you. My email from

s chambers indicated that no one would be in Judge

o Williams'office until today.

z MR. BROWN: Right. And it's mY

a understanding that his staff is there today to receive

s pleadings and hand deliveries, but Judge Williams

1o himself is not.

r.1 MS. NELSON: Thank you,

L2 MR. BROWN: Yes.

r.3 MS. NELSON: Okay.


r-5 MS. NELSON: We need to call Judge Handy.

i.6 MR. BROWN: You know what, I need to -- |

17 want to - I'm going to -1B THE WITNESS: ls this a signal for me to

19 leave?

20 MR. BROWN: No, it's not because I want to

21 see if we have time at the end of the day to call Judge

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1 made a similar request of that.

z Q. Without telling me the contents of any such

3 response to a DHMH request, are you aware of any other

4 correspondence from the AG's office directed to -- to

s The Commission or DHMH as opposed to Delegate West

e giving a legal opinion? Without telling me what's in

7 il, are you aware of the existence of such a document?

e A. I'm - I'm going to say no.

s Q. Okay. All right. There came a time when

10 The Commission retained a company called Hillman

11 Communications. Are you aware of that fact?

rz A. Yes.

r: Q. Why was Hillman Communications hired?

14 A. I don't know.

rs Q. Were - did The Commission vote on whether

r.6 or not to hire Hillman Communications?

rz A. I don't recall such a vote.

re Q. Okay. Do you know what Hillman

19 Communications -- what - what kind of services they

2o provided?

zt A. No.

Page 128

r Handy. I want to keep moving through this deposition.

z And I'll move on to something else.

¡ MS. NELSON:OkaY.

+ MR. BROWN: But mark that please so we can

s go back later todaY. OkaY?

e (Robshaw Exhibit 7 was marked for purposes

z of identification.)

e Q. Mr. Robshaw, I'm showing you what I've

g marked as Exhibit Number 7. lt's a printout of an

10 article from the Washington Posl from October --

rr October - August 26th,2016. Have you ever read this

L2 article before?

r¡ A. Not to my knowledge.

r¿ Q. Okay. Do you recall being interviewed by

rs the Washington Post on or about that time and giving

re the quotes that are attributed to you, beginning at the

L7 bottom of Page 2 of the exhibit, which begins, "But

1B Colonel Harry Robshaw"?

rg A. I remember talking to a Washington Post

20 reporter as set up by The Commission, but I don't

2r remember the date.

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Harry 'Buddy'Robshaw, III - Vol' Il\{ay 10,2017

Page 129

r Q. Have you ever met with anyone from Hillman

2 Communications?g A. Not to my knowledge.

¿ Q. Have you ever seen any work product that

5 was produced by Hillman Communications?

e A. Not that I recall at this time.

z Q. So is it fair to say that you were not

a involved in the decision making process to retain

g HillmanCommunications?

ro A. I've heard the name Hillman Communications.

r.1 I don't know what the specifics of that are.

rz Q. To your knowledge, and you've been in all

13 the meetings, one of which by phone, did Hillman

L4 Communications ever come to any public or private

15 meeting of The Commission and make a presentation which

16 you listened to or read from?

rr A. Not that I recall.

rs Q. All right. Let's get to RESI or RESI. I'm

19 not sure how they pronounce their acronym. Regional

2o Economic Studies -zt A. Economics.

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rr A.

Page 127

0. Okay. Do you dispute that you said, "lt's

frustrating that somehow we should have interpreted the

letter differently"?

A. I believe that to be accurate.

O. Okay. Were you aware : if you go up a few

paragraphs from your quote where Ms. Raq -- Raquel

Coombs -- C-O-O-M-B-S -- said, "The Commission could

have researched whether there is evidence of racial

disparity in industries similar to medical marijuana'"

Are you aware of that quote?

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No.

(The reporter asked for clarification.)

MR. BROWN: R-A-Q-U-E-L.

0. Okay. You understand, don't you, that The

Commission did not request the opinion letter that was

addressed to Delegate West, correct? Delegate West

requested that?

A. Yes, but l'm - I'm - I believe that DHMH

made the same request. But I don't -- I'm hesitant to

say that be - I've heard that, but I don't know that

to be true. But I was under the impression that DHMH

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1 should act like this. lt could be that, or this was

z the worst job ever and you have no idea which one of

3 those they are?

4 A. I would have to suspect. So I'm not going

s to -- I don't - can't answer that question.

e Q. Why was RESI retained to begin with?

t A. I have no idea.

e Q. Do you know what they were hired to do?

s A. They were hired to do the evaluation of

10 growers, processors and dispensaries.

rr Q. Okay. And who provided the criteria to

L2 RESI upon which to conduct the evaluatíon you just

13 described?

r¿ A. Some kind of a guidance subcommittee. I

15 wasn't a member of that.

re Q. Okay. Do you remember who the chairperson

L7 was of the guidance subcommittee?

re A. Not positive. I went to one meeting in

19 which we discussed the values relating to security.

z o Q. Values like points to be awarded or --

zt A. Percentages --

Page 132

r Q. -- Economics Studies lnstitute, correct?

z You are aware of who they are, right?

s A. Yes.

e Q. Okay. Were you involved in their -s their * the hiring process in which they were

e retained?

t A. No.

a Q. Are you aware that there has been media

s publications lately criticizing the hiring and auditing

1o procedures, views to -- to retain and - obtain

r.L services from RESI?

12 MS. NELSON: Objection. Go ahead.

r¡ A. I'm aware of an audit, yes.

r+ Q. Okay. Are you aware of what the - have

1s you seen the actual audit yourself?

re A. No.

rz Q. Okay. Are you aware of the general

r-B findings of the audit?

ls MS. NELSON: Objection. Go ahead.

zo A. No.

zr Q. Have you been present at any Commission

Page 1 30

r Q. Okay.

z A. - for security issues. But other than

¡ that, I don't - I don't know who - who was in charge

+ ofthat.

s Q. Other than the security concerns which went

o into the selection process, were you involved in any

7 way in determining the criterion which RESI used to

a evaluate the applications for the different categories

g of cannabis providers, either growers, processors or

1o distributors?

rr A. I went to one meeting in which that was

12 discussed, but like I say, my focus was on the security

13 issue. I didn't get into some of the other issues that

14 went into that application process.

:-s Q. Do you know how many applicants applied for

16 growers' licenses?

rz A. A little over a hundred, I believe.

ra Q. Okay. Did you personally review every

19 application for a grower's license?

zo A. lwould say -2r MS. NELSON: Going back to the standing

Page 1 33


Page 131

r meeting, public or private, which the findings of the

z audit were discussed?

¡ A. Yes.

¿ Q. Okay. What was discussed?


o A. I -- | -- | just know an audit was

z conducted. I didn't -- I haven't read the specifics of

a the audit.g Q. Okay. Did you hear a presentation? I know

1o you haven't read it, but did you hear a presentation

1r- or -- or discuss in general terms the findings of the

L2 audit?

r¡ A. No.

r+ Q. Okay.

rs A. I know there was an audit. That's --

r-6 that's agree.

rz Q. That's : that's all You know?

re A. That's all I know.

rg Q. So it could have been this was the best job

zo that we ever did for the entire state. lt was the

2! greatest thing. lt's a gold star audit. More people

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Harry'Buddy'Robshaw, III - Vol. 1

May 10,2017

(33) Pages 130 - 133

E 000572

L we know that some of the applications, based on what

2 you just told me, that were submitted to RESI were not

: scored because they had redaction errors. So let's put

e that in a pile over here. OkaY?

5 A. Okay.

e Q. What I'm trying to find out - and forgive

z me if I'm being repetitive, but I'm trying to make sure

a that we are getting the information -- you are

s answering the question that I'm asking. To your

ro knowledge, were there any applications that didn't even

11 get to that point, that is not scoring because of

L2 redaction errors because The Commission, for whatever

13 reason, didn't even send them to RESI?

r¿ A. I don't know.

rs Q. Okay.

16 MS. NELSON: Can we take a very quick

17 break?

r"8 MR. BROWN: Sure. lf You need to.

1s Absolutely.

20 MS. NELSON: Can you come with me?

2L MR. BROWN: Well, if you are -- there is no

Page 1 36

r objection.

z A. I would say nearly every one of them.

: Q. To your knowledge, was every application

¿ that was submitted to The Commission for growers'

s license also then submitted to RESI for scoring?

e A. I don't know that.

z Q. Okay. So I'm -- I'm just making up numbers

a for example purpose. Give you thatwarning in advance.

s Hypothetically speaking, if there were 1 '10

ro applicants - applications submitted to The Commission,

11 you can't tell me one way or the other whether all 1 10

12 of them were given to RESI or not?

r: A. I know - the only application I ever saw

14 was a redacted one. So I can't tell you -- | .. no,

r.s I - I can't tell you that. I don't know that answer.

re Q. Do you know how many scores you got back

!7 from RESI with regard to growers' licenses -- growers'

r.B license applications?

rg A. I don't know a sPecific number.

zo Q. Okay. And you can'ttell me if the number

2L ofscores you got back from RESI equaled the number of

Page 1 34

Älternative Medicine Maryland, LLC vs.Natalie M. Laprade MMCC, et al.

Page 135

r- scores - I'm sorry. Equaled the number of

z applications submitted to The Commission?

: MS. NELSON: Asked and answered.

q A. No, because some were - had redaction

s errors and stuff like that. So I * | don't know what

s that -z Q. What do you mean by that? What does one

a thing have to do with the other?

g A. Well, I -- some were not scored because of

1o redaction errors.

rr Q. To your knowledge, otherthan redaction

L2 errors, is there any other reason why an application

r-3 would not have been scored?

ra A. I don't - I don't know.

rs Q. So you can't tell me one way or the other?

ro A. I had nothing to do with that process. And

17 I - I can't give You an answer, no.

ra Q. Okay. I'm sorry if we are talking around

r"9 each other.

zo A. Oh, no.

zr Q. I'm not : I'm not trying to do that. So

Harry 'Buddy'Robshaw, III - Vol. INfay 10,2017

Page 1 37

r question pending at the moment, but I would object to

z counsel speaking with the witness about matters

r pertaining to the deposition while he's under oath. ln

+ my view, it's no different than we take a lunch break

s during trial and you go talk about his testimony while

6 he's still on the stand. He's under oath. And if

7 you -- if you need a - if you need a break to use the

e ladies' room or to discuss what time he's got to leave,

s no problem. But merits l've got a big problem.

i.0 MS. NELSON: We'll take care of it on

11 redirect then.

12 MR. BROWN: Okay.

r¡ Q. ls it your testimony that you were not

14 involved in any manner with ihe decision to hire RESI

1s as the Commission's consultant in this regard?


rz Q. Were there -- was there a subcommittee that

i.B was involved in doing that?

rg A. I don't know.

zo Q. Do you know -- can you describe at all how

21 RESI, as opposed to someone else or some other entity,

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(34) Pages 134 - 137

E 000573

exhibit to this deposition - it's our position that

the allegations in the complaint go directly to

geographic diversity as well as racial and ethnic

diversity.

And you can have your objection. lf you

would like, I'll make a copy of the complaint an

exhibit and then we can argue it in front of a judge at

some future time.

MS. NELSON: I think that's what we should

do. I think we should call Judge Handy about this line

of questioning. lt's not in dispute that The

Commission considered geographic diversity. Your

client's complaint vaguely alleges that it considered

geographic diversity, but did not consider racial and

ethnic diversity. The Commission does not dispute that

it considered geographic diversity, and this line of

questioning is not likely to lead to the discovery of

admissible evidence in your case.

MR. BROWN: Fine. I'll get Judge Handy's

phone number.

(A recess was taken.)

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Page 140

1 was selected to -- to perform this task?

z A. I'm not sure.

: Q. There came a time that RESI reported their

+ rankings for growers to The Commission; is that

s correct?

e A. Yes.

z Q. And you were present for that meeting?

e A. Let me be certain what you are asking me.

e I saw the rankings only by numeric identifier. I don't

10 know any ofthe -11 (A recess was taken.)

rz Q. When the rankings came in, they had numeric

13 identifiers, but you had no other information about who

t¿ was who?

rs A. Correct.

re Q. When you received the numeric identifier,

rz did you receive any information concerning where in the

1B state each provider was -- each potential licensee was

19 from?

20 MS. NELSON: ln addition to the continuing

zr objection on deliberative process privilege, we are

Page 1 38

r MR. BROWN: So first thing you should know,

z Your Honor, and if you object say so. This is a

r deposition and the court reporter is here, and she's

a taking down everything that's being said. And I'm here

s with my opponent, opposing counsel, Ms. Heather Nelson,

s and my cocounsel, Byron Warnken. The witness is also

z present with us.

e JUDGE HANDY: Okay.

g MR. BROWN: So Your Honor.

r.0 JUDGE HANDY: I had received your message

1r- this morning.

L2 MR. BROWN:Right.

r-3 JUDGE HANDY:And I asked my law clerk, and

14 he did, he called your office and asked you to arrange

1s a phone conference before the deposition took place.

r-5 MR. BROWN: That - and I realize that, but

L7 by the time I received that message, Your Honor, the

1B deposition was already taking place. And with regard

1e to the issue that I thought was going to be disputed

20 between us, Ms. Nelson had made a standing objection

zt for the record, but was allowing her witness to answer

Page 141

getting back to an objection on relevance.

The information relating to where people -applicants were located is not relevant to your

client's allegations, it's not likely to lead to

discovery of admissible evidence.

MR. BROWN: Mark this for me.

(Robshaw Exhibit 8 was marked for purposes

of identification.)

0. I'm showing You what's -MR. BROWN: Counsel, You have a coPY,

correct?

MS. NELSON: Yes.

O. I'm showing you what's been marked as

Exhibit Number 8. Can you identify that document for

me?

MS. NELSON: l'm going to continue to

object on relevance. I would like a proffer as to what

this relates to in your client's complaint.

MR. BROWN:Well, you've alleged standing,

and as l've reiterated, to -- and if you want, I'll

print out a copy and l'll make the entire complaint and

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Page 139

Alternative Medicine Maryland, LLC vs.Natalie M. ade MMCC, et al.

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[Iay 10,201'1

li ir'U i:l :'r-1,: ;iii' (35) Pages 138 - 141

E 000574

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Page 142

questions concerning the disputed area. Now -- now

we -- she hasn't instructed her witness not to answer a

question yet.

MS. NELSON: And I'm still unaware of the

subject of the prior call to chambers.

MR. BROWN: That was just - what I - |

called - just for the record, so Ms. Nelson knows, I

called chambers and made it aware of Judge Williams'

order. And I made it aware that I believed, and it

turns out incorrectly, that you may be instructing your

client not to answer questions concerning deliberative

process privilege.

JUDGE HANDY: All right. That wasn't the

message -- the message that I received states -- give

me a copy of the message, please, from Mr. Brown,

please. l'll -- I'll tell you exactly what the message

said.

I was at the court management meeting this

morning. When I returned to my office, my law clerk

gave me a message. Oh, you had it. Okay. lt says,

"To Judge Handy from Brian Brown, date 5/10, I o'clock.

Page 144

r than having to engage the court, Ms. Nelson thankfully

z said she just had a standing objection and would not be

: objecting or instructing her witness not to answer

+ based on the issues concerning the motion that Judge

s Williams had ruled upon.

5 Now we are at a different - totallY

z different issue. Nothing to do with Judge Williams'

e denial of the motion, but we need a discovery judge, or

g in this case Judge Williams because he's been

r-0 especially assigned to rule on a current dispute that

tt we have.

!2 JUDGE HANDY: Okay. So what's the issue?

r-3 MR. BROWN: The - the issue is this. Just

L4 to bring you up to speed, this is a case --

r.s JUDGE HANDY: Before you go on to that,

15 let's just say this. I - I do know that Judge

L7 Williams did make the court aware that this motion to

r.s stay was filed on - on May 8th there was a motion to

1e stay Circuit Court proceedings filed by the Attorney

20 General's Office, but, of course, it is not like there

21 was no motion to shorten time or anything else filed'

Page 145

So it's not even like for ruling. I just wanted to put

that out there.

MR. BROWN: Yeah. And just so -- so you --

so make the court fully aware because I want you to

have all the facts, that's correct, the motion to stay

was filed and our response is not yet due.

Ms. Nelson, on behalf of her client, has

also filed two pleadings in the Court of Special

Appeals. She noted an appeal of Judge Williams'

discovery order, and she fìled a motion to stay these

proceedings in the Court of Special Appeals asking them

to issue an order staying the proceedings.

The notice to take appeal is a notice to

appeal, fine. The motion to stay, our response to that

motion is not yet ripe. So there are two concurrent

motions to stay, neither of which are ripe at this

moment.

JUDGE HANDY: Okay.

MS. NELSON: Your Honor, mindful of our

obligations in light of Judge William's May 3rd order,

my client and I appeared here this morning for the

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Page 143

r Phone Number 410-547-0202. Judge Williams denied

2 motion to quash. Time sensitive issue. But especially

r assigned to him and he's out of town. Who should he

a speak with?" And then the case number.

s So I had my law clerk call Mr. Brown's --

e the number that he left and instruct the staff for him

z to schedule a conference call with all the parties on

e the line.

e MR. BROWN: Right. So the message was a

10 little bit more than that. I explained to your --

11 your -- your law clerk that the time sensitive issue

12 was a deposition that was occurring today, and we might

13 need the intervention of the discovery judge, but we

rq couldn't speak to the discovery judge because the case

i-s has been especially assigned to Judge Williams who is

16 ruling on all issues in the matter in this case. But

rz Judge Williams is not around. So who should I speak to

1s in lieu of Judge Williams if we need to contact a

1e discovery judge during this deposition. That's * that

20 was what I conveYed.

2r And then Ms. Nelson came in, and rather


M.zy 10,2017

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(36) Pagcs 142 - 145

E 000575


Harry 'Buddy' Robsharv, III - Vol' 1

May 10,2017

Page 146

L scheduled deposition and did make a standing objection

z on deliberative process privilege as we have noted an

s appeal on that issue. The client has cooperated in

a good faith.

s For full context, not only did Judge

e Williams deny a motion to quash on deliberative process

z privilege in this case, but also on May 3rd Judge

a Williams granted a motion to compel and denied a motion

s for protective order based on the deliberative process

i.o privilege in a companion case, GTI Maryland v. MMCC.

11 Counsel for AMM has previously taken the

12 position that consolidation should not be granted in

r.3 those two cases. The cases are not appropriate for

!4 consolidation because the allegations are very

1s different, and because the issues do not overlap.

15 Now, as we are here participating in the

!7 deposition in good faith and compliance with the

18 pending order from the court, we object on relevance to

19 questions being posed that are intended to discover

20 evidence relevant to GTI's complaint and not relevant

21- to Alternative Medicine Maryland's complaint.

Page 148

r MS. NELSON:Yes, that's right.

z MR. BROWN;Well, if I may interpose my

3 response to Ms. Nelson's comments. First, as a general

a principle, Your Honor, at a deposition, relevancy is,

s while an objection that can be made for the record for

e a judge to decide at some future point, is not a ground

z to, in my view, contact the discovery judge, or in this

I case the specially assigned judge who you are sitting

e in in lieu of. lt is you make an objection.

r.0 Relevance. And then the judge rules later if I want to

11 use it in a response to a motion or something like

!2 that. So I don't even understand why we are on this

r.3 phone call.

14 MS. NELSON: lf I maY -r.s MR. BROWN: But -- but - but - but

16 getting * getting to the merits, Your Honor, I dispute

rt vigorously Ms. Nelson's position that our complaint

18 does not go in addition to racial and ethnic - the

rg failure of The Commission to consider racial and ethnic

20 diversity. lt goes directly to The Commission's

zr failure to consider geographic diversity.

Page 147

r The allegations underlying their causes of

2 action are very different. And the detailed

r questioning that my client is now facing relates only

¿ to GTI's cause of action.

s The facts that theY are : that - when

a asked for a proffer, AMM noted an allegation in their

z complaint alleging that The Commission failed to

a consider racial and ethnic diversity, but did consider

s geographic diversity. That is not a fact in dispute'

1o The Commission has agreed that it considered geographic

r-1 diversity in the award of preapprovals.

\2 Not only is it a fact not in dispute in

r-3 this action, but those questions - detailed questions

l-4 into how and why The Commission considered geographic

r-s diversity are not likely to lead to the discovery of

r-6 admissible evidence in this case, which, instead,

L7 focuses on The Commission's acts or alleged omissions

r.B with regard to racial and ethnic diversity.

1e JUDGE HANDY: So wait. Were the questions

zo that were -- you are objecting to about geographic

2r diversity?

Page 149

r Furthermore, Your Honor, the issues at hand

z concerning - regarding this line of questioning goes

r directly to the issue of standing, my client's standing

+ to challenge The Commission's awarding or -- of

s licenses and not awarding my client a license.

o Therefore, for reasons of standing alone, it's

7 relevant.

e And so for those reasons, Your Honor, you

9 know, if the court at some future point says, Mr.

10 Brown, your question is not relevant, fine. But at

rr this point at a discovery deposition, which is far more

L2 broad than what may or may not be admissible at trial,

13 the court in this vacuum context, in my view, should

14 not get involved and rule on an objection which can be

i-s ruled upon at some further point.

r-6 I have no intention of conducting free

1-7 discovery for the GTI plaintiffs. I'm trying to get

18 discovery for my client, Your Honor, who is AMM.

1s MS. NELSON: Your Honor, the reason why it

2o is insufficient to simply note the objection and move

2r on is -- is found in the procedural -

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E 000576

don't -- you are not objecting to because it's not a

violation of the deliberative privilege?

MS. NELSON:Yes. And I have a standing

objection on deliberative process privilege. I have -JUDGE HANDY: Sorry. Deliberative process

privilege.

MS. NELSON:Yes, Your Honor. And I've not

instructed my witness not to answer because I am

mindful that there is no order to stay.

JUDGE HANDY: But because you didn't file a

motion to shorten time.

MS. NELSON: I'm mindful that there is no

order to stay.

JUDGE HANDY: But I said because we

couldn't rule on it because it's not ripe. He didn't

file a motion to shorten time. That's why we couldn't

rule on it, right, before this deposition?

MS. NELSON: Yes. I imagine so. And so we

are here in good faith to work through discovery in

this case, seeking only a court ruling to prohibit

counsel from conducting discovery in a separate case

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JUDGE HANDY: Hold on. Can you start that

over, please?

MS. NELSON;Yes. The reason whY it is

insufficient for The Commission to simply note the

objection and move on is because of the procedural

posture on the rulings of the deliberative process

privilege.

The Commission, much like the Board of

Physicians in Geyer v. Board of Physician's recently

ruled upon in July of this year by the Court of

Appeals -MR. BROWN: Last year.

MS. NELSON: -- is an executive high level

decision maker -- thank you - entitled to assert the

deliberative process privilege.

JUDGE HANDY:We haven't aPPlied anY

question they are asking.

MS. NELSON: I'm -- I'm --

JUDGE HANDY: Wouldn't your argument apply

to any question that they are asking?

MS. NELSON: My argument as to privilege or

Altcrnative Medicine Maryland, LLC vs'Natalie M. Laprade MMCC, et al.

Page 1 51

r relevance? What -- I'm -- I'm not.

z JUDGE HANDY:Well, if that's -- what we

: are talking about now is relevance, correct?

¿ MS. NELSON: Yes. Yes.

s JUDGE HANDY: And you are saying that the

6 reason that you - that you are objecting is because of

z this deliberative privilege?

e MS. NELSON: I'm objecting because right

now The Commission has - is facing a ruling that says

it cannot assert the deliberative proÇess privilege

Counsel in AMM, in this deposition here, is taking

opportunity to pursue immediate discovery of evidence

that is only relevant in the GTI case, knowing full

well that the adverse ruling on deliberative process

has been noted in a notice of appeal and is the subject

of a motion to stay. And knowing --

JUDGE HANDY: Well, that's what I'm saying.

Wouldn't that apply to any questioning of your witness?

No?

MS. NELSON: Your Honor --

JUDGE HANDY: Some of the questions

Harry'Buddy'Robshaw, III - Vol' IMay 10,20t7

Page 153

t where counsel has previously represented to the court

z that the cases are not appropriately consolidated.

s MR. BROWN: But the - but the

¿ consolidation has nothing to do with it, Your Honor.

s JUDGE HANDY: I understand that.

s MS. NELSON: lt does.

z JUDGE HANDY: Consolidation doesn't have

a anything to do with it.

s MS. NELSON: The representation to the

10 court was that the allegations were sufficiently

r.J. distinct, and they are. These cases, although both -1-2 JUDGE HANDY: That doesn't mean that

13 certain information may not be relevant to both cases.

14 MS. NELSON: This information is not

15 relevant to the allegations in AMM's complaints. There

16 is no --

r7 JUDGE HANDY: That's where I thought we

18 Were.

1e MS. NELSON: There is no dispute -20 JUDGE HANDY: Mr. Brown just proffered why

2L the information is relevant, and so that's what I was

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thinking you were going to respond to, why it is not

relevant.

MS. NELSON: Thank you, Your Honor. lt is

not relevant to standing in any way. The allegations

are that AMM has standing based on their status as an

-- as an applicant for a medical cannabis grower

license. And there is no dispute that they were an

applicant for a medical cannabis grower license. They

were an unsuccessful applicant. There is no dispute

that they were an unsuccessful applicant.

There is no dispute that The Commission

considered geographic diversity in selecting applicants

for preapproval. And the only allegation in all of

plaintiffls complaint that they can point to that

invokes the phrase geographic "diversity" broadly

alleges that The Commission failed to consider racial

and ethnic diversity, but did : but compounded that

error by considering geographic diversity.

The Commission does not dispute that it

considered geographic diversity. There is no

likelihood of leading to the discovery of admissible

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Page 1 56

r filling its statutory responsibilities -- and I'm -z I'm parenthetically saying racial, ethnic and

r geographic diversity. Exercise good judgment. Not in

¿ an arbitrary, capricious or unreasonable or illegal

5 manner and engage in reasoned decision making with will

o lay a groundwork for effective oversight in the

z industry - of the industry in the future."g lt's all laid out in our complaint, Your

g Honor. And as I said, this is a discovery deposition.

ro And we have the right to very broad leeway in our line

11 of questioning at a discovery deposition.

1"2 JUDGE HANDY: Well, I don't know that I

13 completely agree with what you are saying' I mean,

L4 see, you think you can just ask any question under the

15 SUn.

MR. BROWN: Well, I agree with that too,

Your Honor, but I'm not doing that. I'm limiting it to

the mandate of the legislation, which says that The

Commission shall consider -- or, I'm sorry, shall

actively seek racial, ethnic and geographic diversity

without giving more weight to one than the other in the

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issuances of licenses.

And, Your Honor, if they - if I'm - what

l'm trying to find out, among other thing, is whether

they gave more weight to geographic diversity than they

gave to other elements that they were required to

consider.

JUDGE HANDY: Well, why is that relevant?

You are saying they gave no --

(The reporter asked for clarification.)

JUDGE HANDY:Well, that's what the -- the

objection is I thought.

MR. BROWN:Yeah.

MS. NELSON:That's right. lt's not

relevant. The Commission has -- has a --

JUDGE HANDY: I'm sorry. Who is speaking?

MS. NELSON: This is Heather Nelson for The

Commission. The Commission - it's not a fact in

dispute that The Commission considered geographic

diversity in the selection of preapproved applicants.

And it's not a fact in dispute that The Commission did

not use racial or ethnic diversity as a selection

-¡\lternative Medicine Maryland, LLC vs.Natalie M. Laprade MMCC, et al.

Page 1 55

r evidence on that point by asking my client how, what,

2 when and why they considered geographic diversity when

¡ the client has already stated they did, in fact'

¿ consider geograPhic diversitY.

s MR. BROWN: But, Your Honor, if theY

e considered -- our allegation is if they considered

z geographic diversity at the expense of racial and

a ethnic diversity, then it goes directly to our

s allegations in the complaint. And we are at a

10 deposition, not a trial. lf I asked this question at

r.r. trial and Ms. Nelson said objection, we would approach

L2 the bench and Your Honor would make a ruling.

13 Furthermore, Your Honor, we allege

1"4 specifically in addition to the * the - the passage

1s that Ms. Nelson iust quoted to you, we allege at

i-5 Paragraph 87, "The public interest is also served by

17 unraveling and correcting a flawed administrative

r,B process at the outset.

1e The medical cannabis industry and

20 administrative oversight of the industry will expand in

zr coming years. Holding the Commission accountable for

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County -MR. WARNKEN: Correct.

MR. BROWN: : Talbot CountY, and Talbot

County is not listed as receiving a license. And we

have the right to know whether my client's geographic

diversity from Talbot County impacted the nonselection

of my client's business, AMM, in the selectiQn process.

Your Honor, the statute specifically says

The Commission shall consider these items, racial,

ethnic and geographic diversity. I have the right to

question this witness, who is the vice chairman of the

commission, Mr. Robshaw, about what process they went

through to consider these three items.

It doesn't matter if now The Commission

doesn't dispute that one was considered and two were --

I'm sorry -- two were not considered racial and ethnic

and one was considered geographic. I have the right to

question how geographic diversity was considered. Was

one county given preference over another county?

I know for a fact, and it's undisputed,

that in the name of geographic diversity, two initially

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criterion in considering preapproved applicants.

And so it -. it logically follows that one

was considered, one was not. lt's not a fact in

dispute. lt's not relevant in this case. And it's not

likely to lead to the discovery of admissible evidence.

JUDGE HANDY:Allright.

MR. BROWN: So your Honor, she -- you know,

Ms. Nelson says now that standing is not an issue. I

have two points to make. But in the answer to the

complaint, the defendant in this case, Ms' Nelson's

client, said we don't have standing. That's point one.

Point two, Your Honor, I'm standing, I'm

looking at Deposition Exhibit Number I, which I know

you don't have in front of me [sic], but it's a listing

of counties from which applicants -- successful

applicants for licenses come from. And there is a

redacted portion to the left of the list of counties

where they had a unique identifier number. So, for

example, the first county listed is Frederick County.

And to the left of it is a redacted identifier number'

And it goes through and it lists all the counties, some

Page 158


Harry'Buddy'Robshaw, III - Vol' 1

May 10,2011

Page 1 61

I successful applicants were removed and two unsuccessful

z applicants were stuck in. I have the right to ask

: questions about that. Why wasn't my client one of the

4 ones who were stuck in? All of these questions are

s relevant at the discovery phrase - phase to find - to

6 ferret out the facts of this case, and -- and litigate

z this matter, Your Honor.

e MS. NELSON: Your Honor, counsel has

g described what it's marked -- what he's marked as

r.0 Exhibit 8 to thìs deposition, which is not a complete

1r- list of all applicants, but rather is a list -L2 MR. BROWN: You are --

r-3 MS. NELSON. -- but rather is a list of 60.

L4 Those are not the successful applicants.

i.s MR. BROWN: Among --

r-6 MS. NELSON: Those were a listing of 60

L7 with 15 towards the top. There is nothing in the

i-B document to indicate where, if at all, your client's

r.e position is reflected on that list.

20 MR. BROWN: lt's not - Talbot County is

2L not on this list, Your Honor.

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Page 159

of which are duplicated, who were awarded licenses.

This is a public document.

MS. NELSON: That is a discovery document

produced from RESI to GTl, not produced in this case'

MR. BROWN:Okay.

MS. NELSON: That's not a public document.

MR. WARNKEN: That's not true.

MS. NELSON:That is not a public document.

MR. WARNKEN: Your Honor, this is Byron

Warnken.

MS. NELSON: That was produced by RESI to

GTI.

MR. BROWN:OkaY.

MR. WARNKEN: lt was filed in a motion by

GTI.

MR. BROWN: Right. lt's in the - it's in

the court, it's a publicly available document.

MR. WARNKEN: lt's publicly available'

MR. BROWN: lt's filed in a motion that

anybody can go to court and look at, Your Honor. And I

can see here that my client, who is from Taìbot

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AlternativeNatalie M.

vs

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Ilarry 'Buddy' Robshaw, III - Vol' IM.zy 10,2017

r. I was going to comply with the rules, 24151, or tell

2 you to if, in fact, you were instructing - your client

3 refused to answer. But based on what has been

4 presented, I am going to overrule the objection and

5 request your client to answer the questions.

6 MR. BROWN: Thank You very much, Your

z Honor.

a JUDGE HANDY:All right- Have a good day

9 everyone.

r.o MR. BROWN: You too.


rz Q. So I'm showing you what's been marked as

13 Exhibit Number 8. Counsel has a copy. And first look

L4 at it, Mr. Robshaw, and tell me if you know what it is.

rs A. No.

rs Q. Have you ever seen a document like that

ti before?

ra A. No.

rg Q. Okay. When you received a list of rankings

20 from -- and you being yourself individually and

2r. Commission as a body - did you receive a document

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MS. NELSON: Moreover, the allegations in

the complaint don't allege that The Commission failed

to consider AMM's geographic location, and failed to

consider geographic diversity in not selecting AMM for

a preapproval. lt is simply not a part of the

allegations of this complaint.

MR. BROWN: And for the reasons I've

already stated, Your Honor, Paragraph 2, Paragraph 87

and the request for relief all set -- make it within

the ambient of our requested relief and the allegations

in the complaint.

JUDGE HANDY: Okay. l, of course, am at a

disadvantage because I really don't have any

information about this case other than what you've just

stated to me. Judge Williams is the one with the

knowledge of the case. And, unfortunately, this was

scheduled while he is awaY.

Counsel, let me ask you this. ls - is --

are you telling your client not to answer the question?

ls the client refusing to answer the question?

MR. BROWN: No. To be fair -

Page I 62

r similar - similar to that listing the rankings in

z order - by - by county ofthese top ranked

: applicants?

e A. I received a list of a unique identifier

5 scores for RESI. And I think one of the other issues

6 was the county listed. I've never seen this document.

z Q. Okay. Have you seen something similar?

e A. Well, there is a lot of information missing

s out of the middle of this.

ro Q. Okay.

rr A. So I can't say 100 percent sure that the

!2 document I looked at and this - these counties line up

13 exactly.

r+ Q. When was the first time that you found out

15 the name of these successful applicants?

re A. August 5th.

rz Q. After or before The Commission had voted

18 on the --

rg A. Can --

zo Q. Sure.

zt A. I just - | -- I seem to recall August Sth

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MS. NELSON;The client has not - l- |

have not instructed my client to not answer the

question. I requested -JUDGE HANDY: Are you going to do that is

what I'm asking?

MR. BROWN: To be fair, and for the record,

Your Honor, Ms. Nelson asked for the court's

intervention before she gave -- wanted to give her

client instruction. And I consented to do that because

I thought it would be Productive.

JUDGE HANDY: So you're going to comply

with my decision and not instruct your client to refuse

to answer a question?

MS. NELSON: Your Honor, lwas requesting a

ruling prior to advising the client. I'm -JUDGE HANDY: Answer my question, please.

MS. NELSON: Sure. l-- I requested a call

to your chambers with the intent of following your

ruling, yes. lwould -- lwas requesting a ruling on

these objections.

JUDGE HANDY: OkaY. Then I : all right.

Page 1 63

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E 000580

Page 166

1 was the public announcement.

z Q. Okay.

s A. I'm - whatever the public announcement

a date is is when I found out what name was attached to a

s unique identifier.

e Q. Okay.

z A. I thought it was August Sth, but I could be

I Wrong.

s Q. Okay. But whatever date it was, it's your

ro testimony you found out the same day the public did?

rr A. That's correct.

rz Q. Okay. Can I see that for one moment,

13 please?

r+ A. Sure.

rs Q. ls it your testimony that in addition to

16 other information which is not on Exhibit Number 8,

rz that there was a unique identifier number and a county

i-B provided to the commissioners?

rg A. And additional information.

zo Q. I said in addition to other information.

zt A. Okay. I didn't see that.

Page 1 68

r geographic diversity of the top 15 to 20 successful

z applicants?

s A. l'm not sure I understand that question.

¿ Q. Sure. We've discussed at length today that

5 one of the requirements of -- excuse me -- one of the

6 requirements from the legislature to The Commission was

z that geographic diversity be considered in the

e application licensing process, correct?

g A. Right.

ro Q. My question to -- to you is prior to the

tt vote, was there any concern raised or discussion had

L2 concerning the geographic diversity, or lack thereof,

r.3 of the top ranked applicants?

r¿ A. I don't understand that question. I don't

r.5 know what you are asking me.

re Q. Okay. I'm asking you -- and I'll put in

17 sort of --

re A. Maybe l'm - I'm just not getting it.

rg Q. No, that's fine. lt could be me. I could

20 be asking a bad question. So I'll try it again. And

2L I'll ask it in conversational -- in a conversational

Page 1 69

1 way. Did anybody in the - at The Commission, or on

z The Commission, a member of The Commission look at this

¡ list and say, hey, wait a minute, we've got a

a geographic diversity problem, what are we going to do

s before the vote happens?

s MS. NELSON: We are going to continue our

z objection for the record.

a MR. BROWN: That's fine.

g A. Prior to the vote, we knew that we were

10 going to : there is a number of votes here. First

rr vote on the top'15, top 20.

rz Q. Okay.

r¡ A. The third vote was on the diversity issue.

r+ Q. On the what issue?

rs A. I'm -- I'm sorry. The --

re Q. Geographic?

tt A. Geographical - thank you. Geographical

1s diversity issue.

rg Q. Okay.

zo A. The discussion was how we were going to do

21 that. There was no discussion about what order these

Alternative Medicine Maryland, LLC vs

Natalie M. Laprade MMCC, et al.

Page 1 67

r Q. Okay.

z A. All right. Yes.

¡ Q. Okay. What other information -- because we

¿ know you didn't know the name when you voted, right?

s A. Right.

e Q. So other than identifying number, county,

z and score, what other information was provided to the

a commissioners prior to the vote?

s A. That's all.

ro Q. That's all. Was there any information

1r- provided to the commissioners prior to the vote

12 concerning the race or ethnicity of potential

i.3 applicants?

r+ A. No.

rs Q. Prior to the vote, was there any concern

16 raised at The Commission during the meeting where the

r't vote took place concernlng racial or ethnic diversity

r-B of the applicants?

rg A. No.

zo Q. Prior to the vote, was there any concern

z t raised by any member of The Commission concerning the

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r- each of the five regions on that map. Map chose them

z by the horticultural specialist on the board. As a --

3 as a minimum. And then that - we knew that we

¿ couldn't --

s Q. You mean you couldn't what?

6 A. I'm trying to think of the word I - that

z we couldn't uniformly space them across the entire

e state, but we would look to do so fairly. A fair

g distribution. Without those six counties known, it was

r.o impossible to come to any conclusion.

11 MR. BROWN: Excuse me one second.

L2 MR. WARNKEN:Take a break.


r¿ Q. Do you know if AMM was a ranked applicant?

rs A. I didn't know then. I -- I don't know now.

re Q. So not --

rz A. What--what;-rs Q. ln other words --

rg A. When you say "ranked," what do you mean

20 "ranked"?

zr Q. Well, what I mean is they received a score,

Page 172

r people were at that particular time.

z Q. Okay. Did there come a time when that was

¡ discussed?

¿ A. Yes.

s Q. When?

e A. After - the -- we are into -- we voted on

z the first two things. We are into the third vote,

e which is geographic diversitY.

s Q. Okay. What were the first two things?

ro A. The top '15 and the toP 20.

rr Q. Okay. Got it. So first one was top 15.

L2 Second one was toP 20.

r: A. Extra five to make the toP 20.

r¿ Q. Right. So you voted on the top 15' Then

15 you voted on the next five. And then you are talking

16 about geographic diversitY?

rz A. Correct.

ra Q. Okay. Do they all happen back to back to

r.e back on the same daY?

zo A. Yes.

zr Q. Okay. So what happened in that third vote?

Page 1 70


Page 171

r A. We - what happened was there was -- I have

z said on record, and I'm sticking with it because I'm --

r although I know I'm wrong now, I -- there was six or

4 seven blanks that didn't allow us to come to a complete

s vote on that. I know it's six now. At the time, I *s I thought it was seven. Six or seven' So there was

r six numerical identifiers who had not identified a

e county. So, therefore, we couldn't come to a vote.

g Q. So when did that vote eventually happen?

ro A. Two days later. Yeah. Two days later. By

l-i- then everyone had declared.

rz Q. When you say "declared," declared what?

r¡ A. Declared what county they - they were

a4 doing business in.

rs Q. Okay. So what -- what happened? Did The

re Commission say somethlng like wait a m¡nute, you know,

1-7 these six identifiers, where are you, and then they

1B responded, and then the committee -- The Commission

i.e took another vote? Something like that?

zo A. No. We looked at them. There was - the

2 L agreement beforehand was that we would put a grower in

Harry 'Buddy'Robshaw, III - Vol' 1

MaY 10, 2017

Page 173

r and you -- and you received, at least in part, a list

z of the topped - topped applicants, is that correct, in

¡ order?

¿ A. Right.

s Q. Right? Do you know what -- where in the

e rankings from 1 to -- let's say for hypothetical

? purposes it was 100 applicants that were scored. Do

B you know where from 1 to 100 AMM fell?

g A. No.

ro Q. Did you ever know that information?

rr A. I mean, I saw the list at one time after

rz the announcement August 5th, but I don't recall where

r-3 it was.

r¿ Q. So you saw a list --

rs A. Let me revise that.

re Q. Sure.

rz A. I saw the list 1 through 20 :re Q. Okay.

rg A. - identified. And I don't recall them

20 being in that.

zr Q. Okay. Did you ever see a list after 20

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1 with -- identified by entity or applicant name?

2 A. I don't think so.

¡ Q. Okay. You don't think so, or no?

¿ A. I -- | -- | - I recall the - seeing the

s list of 1 through 20. I don't recall ever seeing the

e list all the way through, which to me didn't matter at

z that juncture.

e Q. So there did come a time, though, and you

s told me already earlier that two applicants who were

10 initially in the top 15 came out and two applicants who

r.1 were not in the top 15 came in; is that correct?

12 MS.NELSON:Objection.

rs A. Correct.

r+ Q. How did -r.s MR. BROWN: That's fine.

15 MS. NELSON: Thank you.

17 MR. BROWN: That's fine.

re Q. How did that process happen? Describe what

t9 occurred, why it occurred. Was the vote the same day?

zo All of it, please.

2r MS. NELSON: Continuing objection.

Page 1 76

r chance that all six were in the same location, for

z example.

¡ Q. Okay.

¿ A. Unknown to us where they were.

s Q. Okay. So some of the six that were blanks,

e you didn't know where they were, were in the top 15 or

t lop 20?

e A. ln the top 15.

g Q. Okay. So six of 15 you had no idea, it's

r.o your testimony, where they were from?

11 A. Right.

rz Q. Okay. But nonetheless -- and I'm trying to

t¡ educate myself here -- nonetheless, you took a vote and

L4 said -rs A. No. No.

re Q. You didn't take a vote?

rz A. Did not take a vote.

re Q. Okay.

rg A. Ms. Marin said, "We have one in each

20 region." That was fine. At the time I didn't dispute

2L it. As it turns out it was wrong. But I wasn't going

Page 177

r to lead -- wasn't going to have a fìnal vote with six

z people undeclared.

s Q. So if what Ms. Marin was representing at

+ that time was that of the nine who you knew -- because

s 15 minus six is nine, right? Of the nine that you

6 knew, there was at least one in each of the five geo -z agriculturalregions?

e A. That's what she proffered.

g Q. That's what she proffered. Okay. So

10 that's - that happened and then what happened? You

r-r- said, "l'm not voting"?

tz A. No, I said, "We have six people

13 undeclared."

re Q. Right.

rs A. Until we have those declarations, you know,

r-6 not much we can do.

rz Q. And how long after did you get the

1s declarations?

rg A. Well, I called the executive directorthat

20 night to tell him the status. And * and he was able

2L at that time to tell me that we didn't have all regions


Page 1 75

r A. We looked at the top 20. After doing that,

z there was -- | didn't have a map in front of me. I had

: the listing. On of the commissioners, lbelieve itwas

¿ Debbie Marin, said, "We have one in each --

s geographical reasons -- regions," which was the first

e step, if you will. Which was fine, but it still :z Q. Can I -- can I interrupt you for one

a second? When you say "geographic regions," am I

g correct in assuming - and tell me if I'm wrong - that

10 groups of counties constitute a region?

rr A. lf you look at the agricultural map, it's

'J-2 divided into five regions.

r¡ Q. Okay. Got it. That's what - and so the

r+ first thing Ms. Marin said, we have at least one in

i-5 each region?

re A. That-yes.rz Q. Okay. Then what?

re A. Which was some relief that -- because that

19 was a concern from the beginning, but we still had six

20 unaccounted for. And I was not going to complele a

zr vote without knowing where those six were on the off

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r decision making process?

z A. We looked at the - having now knew -- knew

¡ all 15 had declared bythen, itwas easyto see thatin

4 two counties, two adjoining counties, Washington and

s Frederick County, there were three each, and no other

6 parts of the state were -- was there that accumulation.

7 So we decided to take the lowest score of those three

s each and move one to the lower or upper. l'm * I'm -g I'm not sure which one of the Eastern Shore's weren't

1o covered, and move the other down to Southern Maryland.

rr Q. Okay. And as a result, two entities or

12 applicants that were initially in the top 15 were no

r-3 longer in the top 15?

J.4 A. That's correct.

rs Q. And then after you did that, went through

i.6 that process, then was a final vote taken?

rz A. Yes.

ra Q. Okay. Was - at any time were the

rs initially successful top '15 - and I hope you know what

20 I mean by that. I'm saying it in an informal way.

zr Were they ever informed that they were successful

Page 1 B0Page 178

1 covered. And this was a Wednesday. I didn't get all

z six till Friday morning.

¡ Q. Okay. And then once you had all six of the

e previously unknown to you where they are from, was

s there then, and to your memory, one from each region?

6 A. No.

z Q. So even after you knew now all 15 ofthe

a top 15 locations, all five regions were not covered?

g A. That's correct.

ro Q. So then what haPPened?

rr A. Two things happened. One, we had to make a

L2 decision to put one in the - first of all, the region.

13 And I don't know if it was the upper Eastern Shore or

re the lower Eastern Shore block of counties.

rs Q. By the way, I didn't ask you. How many

16 regions weren't covered? One? Two? Three?

rz 4., One.

re Q. One.

rg A. One had none in it.

zo Q. One had none. Okay. And so you said

zr that's a problem?

Alternative Medicine Maryland, LLC vs

Natalie M. Laprade MMCC, et al.

Page 179

r A. That's a problem.

z Q. Okay.

¡ A. The other problem to me, and I offered this

¿ to the subcommittee, was the Southern Maryland region

s which comprised Anne Arundel, Prince George's, Calvert,

e Saint Mary's and Charles only had one. And that was in

z the upper part of Anne Arundel County, which to my

a point of view is not Southern Maryland.

g Q. Okay.

ro A. So I suggested we move one into that

lt Southern Maryland region. Whatever the next one was on

L2 the list, whoever it was, to even out that distribution

13 as far as we could make it.

r¿ Q. So basically -- and I'm paraphrasing, and I

rs want you to correct me if I'm wrong --

rs A. Okay.

rz Q. Okay. -. you had one region that wasn't

1s covered at all, and one region that in your view wasn't

1e covered sufficientlY?

zo A. Correct.

zr Q. And so what was decided based on that


May 10' 2017

Page 181

r before the vote was made public?

z A. Nottomy-¡ Q. Okay.

e A. I don't know that.

s Q. Okay.

e A. ldidn'ttell. I'll answerthatway.

z Q. Okay. Were -- were the -- so you -- you

8 were concerned because you didn't know who six -- where

g six of the applicants came from, right -ro A. Yes.

rr Q. -- countywise? And then the executive

rz director eventually provided that information 1o you?

r¡ A. I don't know if I got it from him or from

14 Mary Joe. One of those two provided me with that

J.s information.

re Q. Do you know where either the executive

1.7 director or Mary Joe obtained the information from?

1B MS. NELSON. Objection. Speculation. Go

r-9 ahead.

zo Q. lf you know?

zr A. I don't know.

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1 the reranking process we talked about who weren't --

z who did not receive licenses based on the initial

r ranking?

¿ MS. NELSON: l'm going to continue the

s objection and object again on relevance because it is

6 very difficult to understand how this could possibly

z relate to your case.

e Q. Can you answer the question?

g A. I don't know.

ro Q. Okay. Do you know who Gerald Evans is?

rr A. Yes.

rz Q. Who is he? What's his - how do you know

r.3 him?

14 A. All I really know him is if he was on the

1s same PTA board that I was in elementary school in the

r.6 1980s.

rz Q. Say that again. You were on the same --

ra A. His children and my children :rg Q. Okay.

zo A. -- went to the same elementary school. And

21 we served on the same PTA board.

Page 'lB4

r Q. Okay. Was the county of * the declared

2 county where the business would be conducted, was that

3 part of the application?

¿ A. I don't know.

s Q. So you don't know where the information

6 came from even from the people - where you did know -z the entities where you did know, you don't know where

a that information came from?

9 A. I know The Commission asked the growers to

r-o declare.

rr Q. Okay.

tz A. How that was carried out, I'm -- I'm not

r.3 certain.

r¿ Q. Hold on one second. Were any of the top 20

15 from Talbot County?

re A. I don't recall.

rz Q. So you -- you don't know?

re A. l-ldon'tknow.rg Q. Okay. Well, if we look at Exhibit Number

20 8, which I think is right there, can you tell me if any

zr of the - any of the applicants on Exhibit Number I are

Page 1 82

Alternativc Medicine Maryland, LLC vs.Natalie M. Laprade MMCC, et al.

Page 1 83

r from Talbot CountY?

z A. I never saw this document. So I - I'm -s I'm not willing to say that this document is the same

4 one I looked at that daY.

s Q. Okay. I'm going to ask you to assume for

o the purpose of this question -- just for the purpose of

z this question --

a A. Okay.

g Q. : if any of the applicants on that list

10 appear to you to be from Talbot County?

rr A. On assuming that these -- these counties

L2 are listed in the same manner that I saw the day that

13 we looked at those, I don't see anything from Talbot

t4 County.

rs Q. To your knowledge, has any -- is any of

16 our -- are any ofthe approved growers -- have any of

r7 the approved growers indicated that they are going to

1s be doing business in Talbot County, to your knowledge?

rg A. I have - I have no idea.

zo Q. You don't know? Okay. Can you tell me the

21 names of the entities that received licenses based upon


M.ay 10,2017

Page 1 85

r Q. Do you know the last time that you spoke to

z him?

s A. I'm guessing 20 years ago.

¿ Q. Do you have Facebook Page?

s A. Yes.

s Q. Are you Facebook friends with Mr. Evans?

z A. Yes.

a Q. Do you remember who friended who?

s A. I have no idea.

ro Q. Okay. Do you know Kathleen Evans?

rr A. Yes.

rz Q. ls she Mr. Evans'wife? Sister?

rs A. Actually, I know her - | know who he is,

L4 but I know her.

rs Q. Are they husband and wife? Are they

16 related?

tt A. I'm - I'm assuming that's so. But I

r-8 haven't seen her in 20 Years.

rg Q. Okay. But you said you know her more than

20 you know him?

zt A. Well, she was the State's Attorney in

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(46) Pages 182 - 185

E 000585

Commission acted in an arbitrary and capricious

fashion.

MR. WARNKEN: And illegal.

MS. NELSON: There was no allegation of

undue influence or misconduct in your complaint.

MR. BROWN: Arbitrary and capricious are

very --

MS. NELSON: CoincidentallY, it is

articulated in GTI and MCP pleadings. However, it's

not at issue in your complaint. And so I'm very

confused as to what value this could even theoretically

hold for your client.

MR. BROWN:Well, it's uP to me and

Mr. Warnken to decide our trial strategy. And what's

of value and what's of not. And you are free --

MS. NELSON:And at a certain Point it

becomes harassment.

MR. BROWN: You are free to disagree with

that and make objections. And if it's not relevant or

improper, then I'm sure a judge will not consider it

when we file our respective pleadings in this case.

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Page 1 88

r Prince George's CountY that -z Q. Okay.

s A. - and I -- she prosecuted - she didn't

+ prosecute. She did screening. Drug screening cases.

s Q. Okay.

e A. She screened drug cases.

z Q. So you knew her in your capacity as a

a police officer?g A. Yeah. I didn't -- we are not personal

1o friends or anything.

rr Q. Okay.

rz A. I knew her as a -- someone in the criminal

rr justice system.

r¿ Q. Facebook friends with her as well?

rs A. Yes.

ro Q. Okay. Do you remember who - who friended

L'i who?

re A. That would be more than 20 years ago. I

r.9 have no idea.

z o Q. Okay. So if I asked you if you had

z r discussions with Mr. Evans or Ms. Evans concerning the

Page 1 86


Page 1 87

r business that we are sitting here at this deposition

z here today, you would tell me no, I never talked to

: them about that?

¿ A. AbsolutelY not.

s Q. Okay. How about Vince Canales?

e MS. NELSON: I'm going to object and ask

t for a proffer on what this has to do with your

e complaint.g MR. BROWN: lt - let the witness step out

i-o of the room.

r.1 (Witness exited room.)

L2 MR. BROWN: lt has to go with : to do with

13 bias and favoritism in the selection process.

L4 MS. NELSON: That's not alleged in your

15 complaint. lt's alleged in MCP's complaint.

16 MR. BROWN: I don't even know what MCP is.

!7 MS. NELSON: GTI's coPlaintiff.

18 MR. WARNKEN: What was alleged is that we

1e did not receive a license, and the people who should

20 not have received a license got a license.

2r MS. NELSON: You alleged that The

Harry'Buddy' Robshaw, III - Vol. IMaY 10,2017

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Page I 89

MS. NELSON: I know that You - I

appreciate that you understand we appeared here this

morning in good faith, notwithstanding our dispute

about Judge Williams' order.

I'm not inclined to have mY witness

harassed or abused over irrelevant allegations' And so

I would ask that you please avoid irrelevant discovery

on someone else's pleadings.

MR. BROWN: Well, for - a couPle of

things. First of all, you know, you continually say

you are appearing here in good faith. You are

appearing here because I issued a valid subpoena and a

motion to quash was denied. You had no choice but to

appear here without being in violation of the court's

order and subject to sanctions. So don't try to act

holier than thou and say it's a great thing that you

appeared here in good faith. You appeared here because

you tried not to and the court told you you had to.

That's point one.

Point two, this - your client's bias or

ulterior motives is directly relevant to whether or not

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, ri i rJ - I I -:l ili t,iii:l (47) Pagcs 186 - r89

E 000586

t from - I'm trying to figure out the date, but I don't

2 see it on here. I don't see the date on here, but I

: will proffer to you that it's an article from The

+ Baltimore Sun -- there it is. October 141h,2016.

s A. Okay.

e Q. And you were quoted in the article as

z saying "They were really * they really were very close

I up to Number 30 or 40, Robshaw said." Do you remember

s giving that quote?

ro A. I don't remember specifically saying that.

11 Q. Okay.

tz A. This was a long conversation I had with -r¡ Q. Mr. Dresser?

r¿ A. -- Mr. Dresser.

rs Q. Having seen that quote and understanding

16 that you don't recall saying exactly that -rz A. Right.

ra Q. - would it -- does it refresh your

19 recollection that you may have seen at least the top 30

20 or 40 applicants, their scoring, on the day of your

zr vote?

Page 192

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The Commission acted appropriately as the statute

directed them to do. We allege that they acted in an

arbitrary, capricious manner. And acting to favor one

applicant over another applicant is certainly arbitrary

and capricious.

MS. NELSON: No, it's misconduct. lt's

different. lt is a totally different -MR. WARNKEN:We used the word "illegal."

We used the word "illegal" in our complaint.

(A discussion was held off the record.)

MR. BROWN: And you can parse words as much

as you would like. Arbitrary. Capricious. Mr.

Warnken points out illegal. Certainly encompasses --

MR. WARNKEN: Unreasonable.

MR. BROWN: - this line of questioning.

And that's my proffer. And if you want to give Judge

Handy a call, have at it.

MS. NELSON: I appreciate the court has

made time to hear our motions earlier today. We are

looking to complete the deposition. I would love to

hear what this has to do with your case, but I'm sure

Page 1 90

Altcrnative Medicine Maryland, LLC vs.Natalie M. Laprade MMCC, et al.

Page 1 91

r we'll get to that point some daY.


: Q. You testified a moment ago that you saw

¿ the - when making the vote, the top 20 applicants,

s correct?

e MS. NELSON: Continuing objection.

t A. You mean on the form that I had?

e Q. Uh-huh.g A. I think there was more than the top 20.

ro Q. So when You -rr A. I don't - I don't know what the * I don't

L2 know if it was the total number or just maybe the top

i-3 30 or so. I don't remember what the total number was.

r+ Q. So when you were presented with the list of

1s ranked applicants from RESI, do you recall how many

i-6 applicants were on the list that you saw in front of

L7 you the day you took the vote?

ra A. l'm not - I'm not certain of that.

1s (Robshaw Exhibit 9 was marked for purposes

2o of identification.)

zr Q. This is an article that I printed off


Page 193

r A. No. I wouldn't - I looked over the --

z the : I looked over every application and became aware

¡ that -- maybe 30 or 40. I don't know. Maybe that

e number, but that could very well be true. I guess the

s gist of what I was saying is the numbers were very

e close.

z Q. The scoring numbers?

s A. Scoring totals were very close among the

9 top contenders. I don't know if 30 or 40 is accurate,

10 but it's clear to me that the scores were fairly close

r-1 consistently until - I mean, the -- the other end of

l-2 the spectrum was some of those scores when -- when I

i-3 read them were -- were not close.

r¿ Q. Okay. When did you look at other scores

1s that were not close?

re A. I looked at every application.

rz Q. Okay. I want to make sure we are talking

18 the same language at this exact moment. When you say

ls you looked at every application --

zo A. Right.

z:- Q. - you looked at every fully completed

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(48) Pages 190 - 193

E 000587

Page 1 94

r- application, or you looked at every score from every

2 application?

3 A. I believe that I looked at the total

4 conglomerate of all of them as two separate issues.

5 One looked at each application trying to determine what

6 was a good application, and then on the other end what

z wasn't a good application. But when I looked at the

I scores, there was a scoring sheet I believe of all of

s them. I believe. I'm not 100 percent certain. The

r.o scoring was close.

r.1 Q. Do you recall if you ever saw AMM's score?

tz A. I don'trememberAMM. That'sthehonest

r.3 truth. I wouldn't -- I never heard of them until after

14 that announcement.

rs Q. When you looked at the applications as

16 opposed to the scores -- when you looked at the

J-7 applications themselves, was that before or after The

1B Commission took their vote?

rg A. Before.

zo Q. Okay. When you looked atthe applications

2L before The Commission took its vote --

Page 1 96

r A. That was one of the things.

z Q. What else?

s A. I looked specifically at security. Because

¿ I could read the SME comments and -- and get a feel for

s how they - unfortunately, there again, most of them

5 were bunched closely together. There wasn't a wide

z margin in most cases. But that was my concentration.

s I didn't look at every single category because I'm just

g not familiar with some of the information that would

10 have been in there.

rr Q. When you say "SME," just for the court

L2 reporter, that stands for subject matter expert?

r¡ A. Correct.

r¿ Q. And so you looked at the SME comments with

1s regard to security?

re A. That was my main focus, yes.

rz Q. Okay. Was there any -- was there ever a

re time that you looked at an application and you said to

i-s yourself this looks, great. And then upon reflection

20 you got - looked at the scores and you said, wait a

2L minute, I thought this looked great and they received a

Page 1 97

r terrible score from RESI --

z A. No.

¡ Q. -- or vice versa? This looks terrible and

+ they ended up getting a good score from RESI?

s A. No.

o Q. Okay. Did you ever go back and compare

7 your opinions to RESI's scores in any -- any way?

e A. No.

g Q. Okay. When you said you considered

10 security, did that include the location -- the proposed

11 location of the applicant's place of business?

rz A. No.

r¡ Q. Wouldn't a proposed location of an

14 application -- of an applicant's place of business play

r.5 a role in your view of whether the facility could be

i.6 secure or not.

tt A. No. I - I looked at the structure.

re Video. The alarm system. The construction. Not - I

rg don't even know where they were. Never an address or

20 anything of that nature.

zr Q. Okay. Are -- are you aware that one of the

Alternative Medicine Maryland, LLC vs.Nataìie M. Laprade MMCC, et al'

Page 195

r A. Right.

z Q. - did you know whose applications you were

: looking at?

+ A. No. All we had was a numeric identifier.

s Q. Okay. So it's your testimony that all

e identifying information had been removed from the

z applications that you were looking at?

e A. I never saw any identifying app -- any

s identifying information known to me --

ro Q. Okay.

rr A. - in any of the applications, but I know

L2 nobody in the industry. I knew none of these

L3 companies. lwould not have recognized something

L4 unless it was clearly just labeled Joe's Grow or

1s something of that nature.

rs Q. Okay. Okay. So was your revlew of the

L7 redacted applications prior to the time you took the

r-8 vote -- you were doing that to get an idea in your own

r-s mind what constituted a qood looking application, a

zo quality application, versus what in your mind was a not

2r so great application?

I'Iarry 'Buddy'Robshaw, III - Vol. IMaY 10' 2017

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E 000588

A.lternativc Medicine Maryland, LLC vs'Natalie M. MÌ\{CC, et al.

Harry 'Budd5" Robshaw, III - Vol' 1

M.ay 70,2017

Page 1 98

1 criterion for selection of an applicant is whether or

z not the proposed applicant or proposed licensee is

3 adequatelycaPitalized?

4 A. I know that * that is the requirement,

s yes.

e Q. What, if any, input or role did you have in

r evaluating a potential applicant for -- or potential

e licensee for adequate capitalization?

e A. No.

ro Q. Were you on any committees in - in your

r.1 role as vice chair? Did you sit in on a committee that

L2 was dealing with capitalization?

r¡ A. No.

ra Q. Are -- were you involved in any way in the

r,s scoring weight that was given to an applicant's

r.6 adequate capitalization or lack thereof?

rr A. No.

re Q. Was adequate capitalization - the criteria

19 for adequate capitalization discussed at public or

20 private meetings of Ïhe Commission which we -- where

2t you were presenl?

Page 200

1 we agree upon that?

z A. I would think so, Yes.

s Q. So is it your testimony that as the

4 chairperson of the growers selection subcommittee, you

s did not have any role with regard to consideration of

e an applicant's caPitalization?

z MS. NELSON: Objection. Go ahead.

e A. Other than seeing the scores related to

s that, I didn't -- I wasn't involved in any procedural

10 or'- or rule making or anything regarding

1i. capitalization.

rz Q. Well, tell me the criteria that you

13 believed to be imporlant as the chair of the growers

L4 selection subcommittee. ln other words, you are the

r-s chair of this committee, You have members on the

16 committee with you. You are in charge of, for lack of

L'7 a better way to put it, the growers selection?

re A. Not in charge of. I object to that.

rg Q. Okay. How would you say it? You were --

zo A. I am of the same rank or elevation as those

2L people.

Page 199

r A. No.

z Q. I assume that subcommittee meetings for

r varying areas of -- varying, varying subject areas were

+ held when the commissioners on that subcommittee

s couldn't make the meeting, correct?

e A. Yeah. Generally agreed before time who was

z going to be there, Yes.

e Q. Yeah. Okay. And it's your testimony that

e you - you didn't play a role in your role as vice

ro chairman or as a commission member in general in the

1r- capitalization question for applicants?

rz A. I didn't have anything to do with that'

r¡ Q. So you were -- you were the chair of the

14 growers -- and forgive me, I got lhe name wrong * the

15 growers subcommittee; is that correct.

ro A. Growers selection subcommittee.

rz Q. Growers selection subcommittee.

ra A. Yes.

rg Q. Okay. Part of the process, or part of the

20 criteria that an applicant for a grower's license must

zr satisfy is that they are adequately capitalized' Can

Page 201

r Q. But you were the chair of the committee --

z subcommittee?

s A. Only for reporting Purposes.

¿ Q. Got it. So what did you all talk about?

s What did you all believe to be important criterion

6 for - for growers to satisfy to have a successful

r application?

s A. We were giving the scorers in categories

g and a total composite score. As I suggested to you

1o earlier, I looked specifically at security.

rr Q, What were the other categories?

rz A. Let me finish answering my question,

13 please.

re Q. l'm sorry. Yep.

rs A. I looked at - specifically at security.

rs There was -- | don't remember the specific topic names,

17 but there was like business acumen. Growing

1B capabilities or horticulture. Security. Management.

t9 There was a bunch of different categories. I wasn'l

20 involved in those decisions on how those scores would

2L be developed, although I did look at them to get a

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E 000589

1 A. I made the - the comment that I hadn't

z spoken with them. I would change that comment to I

g haven't communicated with them because I was realizing

4 on my way out just because I didn't speak to them

s doesn't mean I couldn't write to them or text to them

6 or whatever. I had no communication whatsoever.

z Q. Okay. Thank you for that.

a A. Okay.g Q. I appreciate that.

ro A. Allright.

rr Q. I'm going to ask you some questions now

!2 about the marijuana or cannabis business in general,

13 and ask you what you know about that. And we'll go

t¿ from there. And hopefully this section of our

1s deposition will go relatively quickly. Okay.

16 What - can you tell me your understanding

L7 as a commissioner of the purpose behind this

i.s legislation which is creating a medical cannabis

1e industry in the state?


zt A. The purpose is to regulate the production,

Page 204

r" sense of how they did across the board. But I don't

z know the specific elements of each one of those.

¡ Q. What - you looked primarily at security.

¿ You told me that, right? That was --

s A. I looked at the SME comments referenced to

e security because I could recognize them.

z Q. I get that.

e A. Okay.

s Q. Was there another commissioner who had *10 like you have expertise in the security area based upon

1.1 your years of law enforcement experience. Was there

1z another commissioner who was on the growers' seleciion

r.3 subcommittee who you recall having expertise in

14 capitalization that helped compile criteria for that

L5 area?

re A. The - there was a commissioner in charge

L7 of the budget on the subcommittee.

re Q, The budget? Whose budget?

rg A. The budget for The Commission which

20 suggested to me she knew something about

2L capitalization.

Page 202


Page 203

r Q. Okay. What's her name?

z A. Nancy Rosen Cohen.

¡ Q. Okay.

4 THE WITNESS: Right?

s A. I just want to make sure I say it exactly.

e Q. That's fine. Do you recall the name of the

7 person or entity who was the subject matter expert on

s security?g A. No. I don't know any subject matter. We

10 were never told who theY were.

rr Q. Okay. So you don't know -- if I ask you

12 the same question for sub -- for adequate [sic]

r: .capitalization, you wouldn't know who that person was?

r¿ A. You can ask me who any SME was ever and I

1s don't know.

re Q. Okay.

rz A. Can I make one correction, please?

re Q. Always.

rg A. With regard to asking me about people I

20 might have known.

zr Q. Uh-huh.

Harry 'Buddy' Robshaw, lll - Vol' 1

May 10,207'1

Page 205

r distribution, manufacture, or any other word that you

2 can think of along those lines of medical cannabis, to

: reach patients in Maryland who have been identified by

+ virtue of their malady, for lack of a better word, that

s would fit the - the circumstances that take medical

s cannabis.

r Q. So would you agree with me that the purpose

e of : the purpose of the entire - the legislation and

s why we are sitting here today, is to deliver a *r-0 for - in a colloquial term, medicine to patients who

r.r. need it? ls that a fair way to put it?

tz A. Usable medical cannabis as a -- as a

13 medicine, yes.

rs Q. And the purpose of the RESI scoring system

15 was to identify growers, processors and distributors

16 who are capable of filling each of those roles to

L7 achieve the goal of the legislation, which is to

LB provide medicine to patients. ls that fair?

i.e MS. NELSON: Objection. Go ahead.

zo A. lt's dispensary, but, yes, that's fair.

zr Q. What did I say?

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(51) Pages 202 -205

E 000590

r the legislature.

z Q. Okay. That's fair response to my question,

: Do you, based upon your experience being a member of

¿ The Commission, have any - I'll rephrase that.

s Based upon your experience as a member of

e The Commission, what is your understanding, if any, as

r to why the number '15 was selected by the legislature?

e A. I have no idea.

e MS. NELSON: Objection.

1o Q. Say that again, please I didn't -1r. MS. NELSON:Well, I objected, but I'm not

Lz instructing him not to answer.

r¡ A. I have - I have no idea why that number

14 was picked.

rs Q. And the only reason I asked you to repeat

16 it because I thought you might have spoken over each

17 other.

re A. That's fine.

1e THE WITNESS: I'm sorry. I didn't mean

20 to --

2r MS. NELSON: Not at all. lt was not a

Page 208

r A. I don't know. But it wasn't dispensary. I

z know that.

¡ Q. Okay. Thank you. And this is not like

4 open up a pizza shop. lt's * it's a complex business,

s right?

e A. As lfound out, that's correct.

z Q. Okay. Would you equate this to : is it

a really any different than a company that's making an

g antibiotic or a vaccine or any other medication? Are

r.0 they * are they similar in that way?


L2 A. I don't know enough about that kind of

i.3 industry to -- to make that kind of -- answer that

L4 question.

rs Q. And getting to your expertise in security,

15 the facility has to be secure. The vehicle - it -L7 the facility where it's grown has to be secure. The

ls vehicles in which is transported have to be secure.

rs And the dispensaries themselves has to be -- have to be

20 secured, correct?

zr A. All through a chain of custody, correct.

Page 206

Alternative Medicinc Maryland, LLC vs.Natalie M. Laprade MMCC, et al'

Page 2O7

r Q. All through a chain of custody. And I

z believe you told me a moment ago that you didn't really

3 get your fingers too much in the adequate

+ capitalization portion of this?

s A. Correct.

e Q. But it's not an insignificant investment

z that it takes to become a medical cannabis grower, is

s it?


ro A. I would think not.

rr Q. And the number of growers was determined

rz because that's the number, 15, that was determined to

13 be needed to meet projected needs of the people of the

14 state; is that correct?

1s MS. NELSON: Objection. Calls for

16 speculation.

rz A. No.

ra Q. Why am I not correct?

rg A. The number 15 was decided by the

20 legislature. What they thought - I'm -- I'm

2t assuming * I don't want to assume. lt was decided by

Harry'Buddy'Robshaw, III * Vol. 1

MaY 10,2017

Page 209

r problem.

z Q. No. She's doing her job and that's fine.

: A. Okay.

4 Q. As a member of The Commission - strike

s that.

s Did The Commission commission any studies

z or ask for any studies that delved into the projected

B demand for medical cannabis in the State of Maryland?

e MS. NELSON: Objection. Go ahead.

ro A. No.

rr Q. So is it fair to say that The Commission

L2 was guided by the legislature saying award X number of

13 growers' licenses, X number of dispensary licenses, and

J"4 it was up to the commission to decide about processing

r.5 licensings,correct?

16 MS. NELSON:Objection. Go ahead.

rr A. The legislature put a cap of 15 on the

18 growers.

rg Q. Right.

z o A. Till 2018 or some -- some future date. No

2L cap on the processors --

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E 000591

1 A. Okay.

z Q. Which is without information about what the

¡ demand would be --

¿ A. Right.

¡ Q. - how is it that You came to the

e determination that all 15 licenses needed to be issued

z in order to meet the demands you just spoke about?


g A. I -- | -- | think we don't know if that's

10 going to be enough. And we would rather err on too

11 much medicine available than not enough.

rz Q. Okay.

r¡ A. That's the best answer I could give.

r+ Q. Was there ever a discussion upon - with

rs the members of The Commission concerning issuing less

i"6 than 15 licenses, or -- and this is not fìnding a

L't fault -- was it just taken as a given, the legislature

1B said 15 cap, so that's what we are going to do?

1-s MS.NELSON:Objection.

20 THE WITNESS: Objection?

2L MS. NELSON: I'm sorry. Objection just for

Page 212

r Q. Right.

z A. - in 2 percent natorial [phonetic]

¡ district on the dispensaries. Unless you were a

4 grower, then that number could be expanded.

s Q. My question, I guess, phrased differently,

o is did the commission -- since there was a cap of 15

I for growers, did The Commission ever delve into details

e and say, you know what, we don't need 15, we only need

g 10 or 11 or 12, but something less than '15? Or did

ro they just go from the beginning and say we are going to

11 issue 15 licenses?

L2 MS. NELSON: Objection. Go ahead.

rs A. I don't think that from my perspective of

L4 being on The Commission, the 15 was the 15. I don't

t¡ know why they developed that number. I don't know even

r.6 now if that's going to be sufficient or not. I * |

r7 don't think anybody knows, but I don't know what -- how

1B the number 'l 5 was arrived at.

rg Q. And l- and bythe way, lgetthat. You

20 already testified to that. And I understand your

z r testimony that you don't know why the legislature

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¡\lternative Medicine Maryland, LLC vs.Natalie M. L e MMCC, et al.

Page 211

r selected 15.

z A. Right.

¡ Q. My question is a little bit different'

a which is why did The Commission choose to choose 15?

s ln other words, choose to issue all the licenses

e altowed as opposed to some lesser number?

z MS. NELSON: Objection. Go ahead' lthink

s it was our belief - it was my belief - I'm not

s speaking for the rest of The Commission. I found I get

10 in trouble when I do that.

rr Q. Yeah.

tz A. lt was my belief that 15 would allow --

13 given the time period it takes to actually produce

14 usable product, that 15 would allow the - the

1s medicine -- medical cannabis to be equally distributed

r-6 around the state. Or be available to patients who had

Ll a particular request for a particular type of cannabis,

1s since each grower theoretically could have their own

19 particular brand.

zo Q. So now lwant to go back to the question I

zJ- asked you a few minutes ago.


MaY 10,2017

Page 21 3

r the record. Go ahead.

z A. There was no discussion of less. There was

3 some discussion of more. But I - | - to this day' I

+ don't think anybody knows whether it's going to be

¡ sufficient or not.

e Q. You mentioned January 1st, 2018 when --

z MR. WARNKEN:June 31st.

e MS. NELSON: June.

g MR. BROWN: I'm sorry?

10 MS. NELSON: June.

11 MR. WARNKEN: June. I'm sorry. Thank you

!2 very much.

rs Q. May 31st, June'l st,2018 when the cap is

14 removed; is that correct?

rs A. I believe that's the case.

re Q. Has there been discussion in The Commission

L7 about awarding additional licenses after May 31st,

i.B 2018?

r.s MS. NELSON: Objection. Go ahead.

zo A. There has been discussion of that in

2\ regards to what the market would bear at that time.

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Page 214

1 Q. Has there been discussion about announcing

z an application process for additional licenses, or how

3 those additional licenses, if any, would be issued?

e MS. NELSON: Objection. Could I ask for a

s proffer?

s MR. BROWN: I'll -- I'll move on.

z Q. Do you have any - did You have anY

a involvement in the yield that a given size of a

s facility would generate?

ro A. No.

rr Q. Or how much it would cost to operate a

12 facility or anything like that?

r: A. I don't know any of those.

r+ Q. Okay. Were there ever any information

15 provided to you, or did The Commission request any

rs studies, concerning what percentage of the population

rz of the state would actually be using medical cannabis?

re A. Not to my knowledge.

rg Q. With regard to seeking racial and ethnic

zo diversity in the licensing process, did The Commission

2r- ever look to other jurisdictions, states, in the MDC

Page 216

r diversity of grower licensees in other jurisdictions?

z A, Not to my knowledge.

s Q. Do you know what percentage of licensees in

+ other jurisdictions are of racial or ethnic diverse

s classes?

e A. No.

z Q. Do you know how many subcommittees there

I are at your commission?g A. No. Because we have -- we have created

1o some and disbanded them as their purpose was fulfilled

rr Q. Okay.

rz A. I don't know how many there are currently

13 right now.

r¿ Q. Was ever a subcommittee, to your knowledge,

r.s on racial and ethnic diversity in awarding licenses?

re A. Not to my knowledge.

rz Q. Okay. Were subcommittees formed as need

r.B arises? ls that pretty much what occurred?

rg A. lnitially, yes. Some have stayed in

20 existence because that need continues.

zr Q. Right.

Page 215

1 concerning their mechanism for awarding licenses and

z whether or not racial and ethnic diversity was

: considered in those other jurisdictions.

a (The reporter asked for clarification.)

s Q. Other jurisdictions.

e MS. NELSON: Objection. Same standing

z objection. Go ahead, Please.

a A. I don't know the answer to that.

g Q. Did you ever review materials about the

10 selection process in general used in other states in

n determining the awarding of medical cannabis license --

12 growers'licenses?

r¡ A. We inquired of other -- many states their

14 programs as a way to make ours better. The mistakes

rs they made.

re Q. Right.

rz A. We try to avoid them. But I'm not sure

r-s that that particular question ever came up to my

r-e knowledge.

zo Q. Do you know if any information was received

2r by The Commission concerning the racial and ethnic


Harry'Buddy'Robshaw, lll - Vol. IM.aY 10,2017

Page 217

r A. Like the educational subcommittee will

z probably always be an educational subcommittee.

¡ Q. Can you give me a list of the subcommittees

a that you can recall that are in existence today?

s A. I would have to go to The Commission to get

e that.

z Q. All right. Well, I'm not asking you -s l'm -- I'm not going to hold you to it as a firm list.

s I'm just asking you for what you can recall. What

10 subcommittees exist sitting here today. lf it's not a

i-i- complete list, it's not a complete list. I just want

!2 to know what you can recall.

r-3 A. We had grower, processor and dispensary

l-4 subcommittees. And then it was guidance subcommittees

r-s on the application process for those.

re Q. Okay. You mentioned educational

17 subcommittee?

ra A. Right. There is a legislative

rs subcommittee. A policy committee. Some of these

20 overlap each other. A final review committee. The

2L budget - I think there was a budget subcommittee.

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1 time, but it's changed and grown into its own entity.

z I'm not aware of any discussion about that.

: Q. Do you remember when you first became aware

+ of Delegate - the letter to Delegate West of March

s 2015?

e A. I think it was in the summer of 20015. I

z don't know the exact date, but I seem to recall the

I SUmmer.

g MR. BROWN:Give Mr. Warnken and lfive

10 minutes and go from there.

r.1 (A recess was taken.)

rz Q. Well, that sort of leads to my next

13 question, which is l'm - I'm not going to pull out the

14 affidavit, but I - you -- you testified in your

r.5 affidavit that part of the Stage 2 approval process is

re going through a moral -- moral character check; is that

r7 correct?

re A. Good moral character, correct.

rg Q. Okay. What's involved in that? Where --

20 where -- is moral character in the regs? ls it in the

2L legislation? Where is that found?

Page 220

r There still might be. I don't -- I'm not on that.

z Q. Okay.

s A. I don't have anything to do with that. I

¿ think that's all of them. The - some morphed into

s another thing, but I think that's all of them.

e Q. What does the policy subcommittee do?

z A. The policy subcommittee looks at

e regulations, how to adapl For example, legislature

g added podiatrists and dentists and how to write into

ro the regulations those adaptations. And then looks at

11 the current regulations and sees where they need to be

L2 modified or changed to enhance the capability of the

13 commission to do a better job on providing medicine

r¿ to -- to the communities.

rs Q. So is it fair to saY there is no

i.6 subcommittee that has jurisdiction, for lack of a

li better word, over ethnic and racial diversity in the

1s licensing process?

rs A. There is no subcommittee named for that

20 purpose that I'm aware of.

zr Q. Okay. And that's not quite what I asked

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Alternative Medicine Maryland, LLC vs'Natalie M. MMCC, et al.

Page 219

r you. l-z A. Well, any commissioner could talk about

¡ that. That doesn't -¿ Q. Right. I - but just because it doesn't

s have a name, racial and ethnic diversity, doesn't mean

e that that subcommittee isn't assigned with the task of

z considering racial and ethnic diversity.

a So, for example, the policy committee could

g be the committee that talks about and deals with racial

r.o and ethnic diversity. So my question to you is

r-1 notwithstanding what the subcommittee is called, is

.J-2 there a subcommittee that has within its purview the

13 consideration of racial and ethnic diversity in the

L4 licensing process?

r.s MS. NELSON: Objection. Go ahead.

re A. I would say that the policy is probably the

L7 closest to that, or would have dealt with that.

re Q. Okay. To your knowledge, have they ever

r,9 done that?

zo MS. NELSON: Objection. Go ahead.

zt A. I was on the policy subcommittee at one


MaY 10,20"1'7

Page221

r MS. NELSON: I'm going to object, but

z please go ahead.

¡ A. That's an advice of counsel thing.

a THE WITNESS: Can I saY that?

s MS. NELSON: Please stop. Yes. Yes. Yes'

e Thank you.

t A. I'm not sure how you're to respond to that.

a Q. That's fine. Let me ask you this question.

s And I don't want you to tell me anything your lawyer

10 told you or anything like that. Okay?

i-r- Are you aware of anything in the

12 legislation that refers to moral character as a

13 qualification to receive a grower's license? That's a

14 yes or no question.

rs A. I think -- I think the -- the legislation

L6 you say?

rz Q. Uh-huh.

rs A. Now I'm not certaln.

rg Q. ls there anything in the regs which - some

20 of which you helped promulgate -zr A. Yes.

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E 000594

1 Q. -- gave advice to The Commission based

2 upon, on this - on this issue. On the issue of racial

: and ethnic diversity. What I would like to know is -+ is between the time you all had Delegate West - the

s letter to Delegate West and the time that you received

e advice from your lawyers' offices, was there any action

z or lack of action that was taken based upon the letter

a from Ms. Rowe to Delegate West in that time frame?

g A. I would invoke the attorney thing.

:-o Q. Well, with -- with respect, the attorney

1r. thing doesn't apply because the time between the

!2 Delegate West letter and the time counsel started

13 giving you advice on that issue, you weren't acting on

14 the attorney-client thing to use your words. And not

r.s in a pejorative way. So I want to know what happened

i.6 between the time of the Delegate West letter and the

L7 time you got advice from counsel. What, if anything,

r.B did you do?

rs MS. NELSON: Counsel, the witness has

20 testified he recalls becoming aware of the Delegate

2L West letter in the summer o'f 2015 -

Page 224

r Q. - or drafted that speaks to good moral

z character in the licensing process?

¡ A. I believe so.

¿ Q. Okay. Now, without telling me what your

s lawyer told you, what is the process, what constitutes

e good moral character and what disqualifies one from

z having good moral character when you conduct an

s evaluation of one's moral character?

g MS. NELSON: Objection. Go ahead.

ro A. That - I - what's the word I used before?

rr That's attorney --

rz Q. Okay.

r¡ A. Whatever that phrase is, I would employ it

L4 here.

rs Q. Okay. Okay. Again, I don't want you to

re tell me anything your lawyer told you.

tt A. Okay.

ra Q. Or anything you did based - well, don't

le tell me anything your lawyer told you. But I want to

20 get back to the Delegate West letter for a moment.

er A. Okay.

Page 222

1 MR. BROWN: That's right. He did say that.

z MS. NELSON: - which is long after the

: letter is dated. And so it's not clear when - it

¿ hasn't been established when he was first given legal

s advice on the --

s Q. And when was that?

z MS. NELSON: -- on the issue.

a MR. BROWN: That's a good - that's a good

s point.

ro Q. When was that?

rr A. What brought about my knowledge of this was

L2 legal advice given to us. Before that I wasn't aware

13 of that letter.

r¿ Q. Excuse me. Have you ever heard a company

r.s named Holistic lndustries?

r-6 MS. NELSON:Objection. Go ahead.

tt A. I've heard of the name.

ra Q. Are you aware of the ownership behind

r.e Holistic lndustries?

zo MS. NELSON: Objection. Go ahead.

zt A. I'm aware of no owner of any grower.

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Alternative l\{edicine Maryland, LLC vsNatalie M. rade MMCC, et al.

Page223

r Q. Would you like a cuP of coffee?

z A. No, I'm fine.

¡ Q. Okay.

+ A. Sorry. lapologize.

s Q. That's okay. ls there any action or lack

e of action that The Commission took based upon the

z letter to Delegate West that was not a result of

a attorney-clientadvice?g MS.NELSON:Objection.

ro Q. And --

rr A. I understand the question.

12 THE WITNESS: Can I answer the question?

r¡ Q. And I'll -- even I'll say with the witness

L4 sitting here. Because it's undisputed that the letter

rs to Delegate West was not generated as a result of the

16 request of The Commission, it was requested by Delegate

17 West.

18 MS. NELSON: Correct.

rg Q. Okay. There came a time subsequently that

20 the Attorney's -- General's offlce --

2L MR. BROWN: Your office.

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r. A. Yes.

2 THE WITNESS: You are not going to tell me

s I can't answer that, right?

+ MR. BROWN: No.

s MS. NELSON: No, he's --

e THE WITNESS: I don't know how allthis

z works. I just want to be sure.

a MR. BROWN: Fair objection.

g Q. You testified a bit about redaction errors.

ro And I want to be sure that the testimony is clear. ls

r.r. it your understanding that applications that included a

L2 redaction error, that the instructions to RESI were

r.3 that if an SME uncovered a redaction error, that

t4 section should be scored azero.

r.s MS. NELSON: And I'm asking this question

16 in the event that my standing objection is overruled'

L7 Obviously the area of testimony is subject to an

r.8 objection.

rg Q. ls it your understanding that applications

20 were scored by RESI, but that sections that contained

zt unredacted identifying information was scored aszero?

Page 228

r Q. Okay. Prior to the time that you became

2 awate - let me go back.

¡ Was Holistic lndustries one of the two

a companies that were bumped up in lieu of two other

s companies?

e MS. NELSON: Continuing objection. Go

z ahead.

e A. I don't - I'm not sure what the -- what

9 the name of those two companies were.

ro Q. Okay. Prior to the time that the names of

rr the successful applicants became known, that is they

L2 were no longer just an identifier -r¡ A. Right.

r¿ Q. - had you ever heard ofthe company named

r.s Holisticlndustries?

re A. I don't recall. I don't recall having

L7 heard of them.

ra Q. Okay.

rg A. The - the - but I will say this. Having

20 been to all these meetings, I'm sure at one time or

2l- another it was all these growers there. And names were

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Alternativc Medicine Maryland, LLC vs'Natalie M. Laprade MMCC, et al'

Page 227

r bantered [sic] around. That doesn't -- I don't know

2 any of them. I didn't stick around after meetings and

g conversate with people. I didn't engage in any of

e that. Once the meetings were over, I was gone. lt's

s possible I heard that name during some of these

e discussions, but I don't know the -- that - I don't

r know that name.

a MR. BROWN: Okay. Mr. Robshaw, subject to

g further questioning after Ms. Nelson asks you

r.0 questions, I don't have anything else to ask you right

l-L now.

THE WITNESS:All right.

EXAMINATION BY MS, NELSON:

0. Thank you. I want to ask a very few

questions exclusively on prior testimony. And I'll try

to be very quick.

You were asked about evaluation criteria

the commissioners used to review applications. Didn't

The Commission put the complete evaluation criteria

into the regulations when they were promulgated?

MR. BROWN:Objectìon.


M.ay 10,2077

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r MR. BROWN: Objection. Form of the

z question, by the way, is the basis of my objection.

s A. Whereverthere was a redaction error

¿ discovered by an SME, every -- every component of that

s that the SME was to rate received a zero.

e Q. You were asked about commission votes

z without great distinction between subcommittee votes or

a full commission votes. So you described a series of

9 votes where you looked at the top 15, you looked at the

1o top 20, and then you considered geographic diversity.

L1 Were those subcommittee votes or full commission votes?

rz A. The subcommittee voted. And then told the

13 full commission what the subcommittee voted, then the

L4 full commission voted on whatever the issue was too'

rs Q. Okay. So the full commission only voted in

16 the open meeting on the recommendation of a

Li subcommittee?

r-B MR. BROWN:Objection. Form.

rs A. They - they voted to accept the

20 recommendation or -- or they were -- they could vote

z t whatever way they chose. They weren't bound by the

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r I have.

z EXAMINATION BY MR. BROWN;

¡ Q. ljust have two, three questions based upon

+ what Ms. Nelson asked you.

5 A. Okay.

e Q. So I just want to make sure l'm clear. The

z series of votes that we talked about earlier today

I where there was 15 and then moving two out and two in,

g that was a subcommittee vote?


rr Q. So the full committee conducted their vote

L2 after the reranking process had occurred? ls that a

r.3 fair statement?

r¿ A. After the recommendations were given by the

r.s subcommittee, the full commission voted on it.

re Q. Okay. So the full commission was not

L7 involved in the reranking process, only the

r"B subcommittee was involved in the reranking process,

rg then the subcommittee gave the recommendation to the

20 full commission, and then the vote occurred; is that

2L correct?

Page 232

r decision of the subcommittee.

z Q. And that was done exclusively in the

r opening meeting that they held for the purpose of

+ considering recommendations and grower and processor

s applications?

6 MR. BROWN:Objection. Form.

t A. Yes.

s Q. So the - the full commission voted once?

s A. That's correct.

ro Q. Before commissioners began their

11 deliberations when they were given evaluation

L2 materials, did all commissioners sign confidentiality

r.3 agreements before receiving those materials?

r¿ A. I didn't see everyone's. I was required to

ls sign as a commissioner for -- to obtain that

l6 information.

rz Q. And it's your understanding that that was

rB required not just of you, but of all?

rs A. We -- we spoke about that in meetings, but

20 I didn't actually see every person sign a form. But,

27- yes, it was required.

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Alternative Medicine Maryland, LLC vs'Natalie M. Laprade N{MCC' et al.

Page 231

r Q. Okay. Jumping back to the full commission

2 vote. When the full commission voted, those

: applications were blinded and identified by coded

¿ identification number, right?

s MR. BROWN:Objection. Form.

s A. Yes.

z Q. Okay. And so it was sometime after the

e full commission meeting that you understood who was

g who?

ro A. I think we voted on September Sth. I'm not

r-1 certain of these dates, but I think we voted on

1-2 September 5th. And it was announced ten days later.

13 Some -- somewhere around the 15th.

r+ Q. Okay.

rs A. No. No. I take that back. August 5th.

16 Not September. August Sth we voted and then I believe

L7 ten days later it was released to the public.

ra Q. Okay.

rg A. Or released to everybody because we found

20 out at the same time.

2L MS. NELSON: Thank you. Okay. That's all


May 10,2017

Page 233

1 A. But it was just a recommendation.

z Q. I understand.

s A. Okay. But no, I know you said that, but I

¿ want -- I wanted it to be understood that it was just a

5 recommendation.

e Q. You testified a moment ago that where there

7 was a redaction error discovered by an SME --

a A. Uh-huh.g Q. - the SME was directed to give that

i.0 portion of the application a zero, correct?

rr A. That's correct.

rz Q. Do you know if AMM's application received

t-3 any zeroes for that reason?

r¿ A. No.

15 MR. BROWN: Okay. That's all I have.

16 Thank you.

L7 (Deposition concluded at 3:19 p.m.)

18

l_9

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t

3 CERTIFICATE OF DEPONENT

4

s I hereby certify that I have read and

s examined the foregoing transcript, and the same is a

z true and accurate record of the testimony given by me.

a Any additions or corrections that I feel are

9 necessary, I will attach on a separate sheet of paper

10 to the original transcriPt.

(lf needed, make additional copies of the Errata Sheet

on the next page or use a blank piece of paper.)

Page 234

Harry "Buddy" Robshaw, lll

Date

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1 ERRJAT.A SHEET

2 Caee: ÀLtenative Medicine Maryl'aûd, LLC

3 vs. Natalie M. Laprade MMCC, et a1.

4 IIITNESS: I¡arry ¡BuddyÍ Robshaw' III DÀTE: 5-10-17

5 pÀcE/LrNE sHoul,D REÀD REÀsoN FoR cllÀNGE

6

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Altcrnative Medicine Maryland, LLC vs'Natalie M. Laprade MMCC, et al'

Harry 'Buddy' Robshaw, III - Vot. 1

M.ay 10,2017

Page 236

STATE OF MÀRYI,ÀND)

) ss

County OF HÀRFORD)

I, Dam L. VeDker, a Notary Public of the

State of Maryfand, Ilarford couty, do hereby certify

that Ehe within-nmed witness personally appeared

before me aE the bime and place herein set out, and

after having been duly gworn by ne, accordiag to law,

wae exmÍned by counsel.

I futther certify that the exmLnation was

recorded stenographlcally by me and thls transcr.lpt j.6

a true record of the proceedings.

I further certify that I m nob of cousel

to any of the partieE, nor in any way interested Ín the

outcame of thíE action.

Às witnessed my hand chis 12ch day of uay,

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Dam L' venker

Nobary Public

My comí6sion expires october 28, 20L7

Èuurd ï.'*h,,r -

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Ilarry 'Iluddy' Robshaw, III - Vol. INIay L0,2077

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(237) $72,000 - amount

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Harry 'Buddy' Robsharv, III - Vol' 1

May 10,2017

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Altcrnative Medicine Maryland' LLC vs.Natalie M. Laprade MMCC, et al.

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Harry 'Buddy'Robshaw, III - Vol' IMaY 10,2017

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MaY 10,2017

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211 :1 5,17 ;21 4:71 ;21 5 : I Icap (7)

t06:7; 108: l6;209:17 ,21;210:6;212:18;213:13

capabilities (2)108:20;201:18

capability (2)96:15;218:12

capable (l)205:16

capacity (9)41 :3 ;57 : 4 ;65 : ) 3,20 ;7 3 :20 ;

19:5,6;98:2;186:7capitalizafion (12)

1 98 :8, 12,1 6,1 8 ,19;199:11;200 : 6,1 I ;202 :1 4,2 | ;203 : 1 3 ;

207:4capitalized (2)

198:3;199:21capricious (6)

1 56:4; 1 88: 1,6; 190:3,5,12captain (l)

13:14car (4)

14:6,7;153;113 11

care (1)137:10

career (2)14:131,16:16

carried (l)182:12

carry (1)23:1

case (34)8:2;9 :1 4;43 :1 7 ;7 2: I 1 ;

1 I 5: I 9; I 16:2;1 18:12;121 :5;123 :18,21 ;124:6; 1 40: I 8;

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188:21;190:21;213:15cases (12)

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1 3 ;1 53 .2,1 1,1 3 ;l 86 :4,6;1 9 6:7catcgories (4)

133 8;201:8,11,19category (1)

I 96:8Caucus (10)

86: I 0,1 3, I 5;87 :3,1,1 1,13,I 8;88: l;90: I 3

cause (2)7 :17 ;1 47 :4

caused (3)82:11;84:7 ;98:16

causes (1)147:1

124:19;125:3;133:3;200:16,18;202:76

Charles (2)30:13;179:6

check (1)220:16

checked (1)1 13:1 8

Cheryl (2)88:9,10

Cheverly (12)5 :1 4 ;1 :9,14 ;9 :2,3 ;1 5 :19 ;

1 6:3,1 0;24:8 ;40 :9,1 6 ;41 :4

chief (9)8:3 ;1 6:1 8,19,21 ;17 :4 ;19 :19,21;413,8

chiefs (3)20'.7,8,76

children (2)1 84:18,1 8

choice (1)1 89: l3

choose (3)217;4,4,5

chose (3)23:5;172:1;229:21

chosen (1)20:15

Chris (1)30: l3

Christina (1.)

30: l3Christine (1)

3l: l6circle (1)

1 13:18Circuit (1)

144:19circumstances (5)

I :4,1 6;9 :1 ;81 : 1 4 ;205 : 5

Civil (8)7 :6,7,1 1,21 ;40 : 1 4;4 1 :2;124:19;1253

claim (1)42:18

clarilication (4)1 8:1 6;127 :12;1 57 ;9 ;21 5 :4

clarify (1)98:6

clarity (1)68:9

classes (1)216:5

clear (7)7 0:10;7 1 :1 4;120:2; I 93 : I 0;

225:3;228:10;232:6cleared (1)

i5:11clearly (1)

195:14clerk (5)

21:15:141 13:'142:19;143:5,1 I

client (30)1 19 :6,13 ;1 20 :17,19,21 ;

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client's (10)I I 8: 18;l 19:14;139:4,18;140:13;149:3;160:5,7;1 61 :1 8;

189:20close (7)

192:7 ;193:6,8,1 0,1 3, 1 5;194:10

closely (1)196:6

closest (1)219:17

cocounsel (1)141:6

code (1)5:15

coded (1)231:3

coffce (1)223:7

Cohen (1)203:2

coincidence (1)65:21

Coincidentally (1)188:8

collect (2)23:20,21

College (3)l0: l9;1 1 :7,10

colleges (3)49:21;61:8;70:17

colloquial (1)205: I 0

Colonel (1)126:18

Columbia (1)I2:13

coming (5)28: 14;38: 1 3;1 08:1 8,1 9;

155:21comment (2)

204:1,2comments (4)

148:3;1964,14;202:5commercial (2)

ll0:4;ll1:15Cornmission (230)

1 1 :19 ;17 : 1 1,1 6,20;18:4,1 5;I 9 : 1,9,1 6;20:9,1 1 ;21 :2,13,1 8 ;

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Gore Brothet's Reporting & Vidcoconl'erencing410 837 3027 - Worldwide - wrvw.gorebrothers'corn

(240) cap - Commission

E 000602

10,14communitics (2)

74:6;218:14community (5)

17 :9 ;25 :20 ;49 :20 ;5 0 :2 ;7 9 :8

companies (4)195:13;226:4,5,9

companion (1)146: l0

company (7)59 : 1,4 ;1 12 :2;128 :1 0 ;20 6 :8 ;

225:14;226:14comparable (2)

99:5,10comparables (3)

96:20;98:10,19comparatives (1)

17:21compare (2)

lll:6;191:6comparing (1)

99:3compel (1)

146:8compile (2)

25:11;202:14complaint (30)

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Complaints (2)27:4;153:15

complete (9)80: l2; I 09:9; I 6 1 :10 17 I :4;17 5 :20 ;l 9 0 :20 ;217 : | 7,1 1 ;

227:19completed (2)

91:21;193:21completely (1)

1 56:1 3completion (2)

1 1:17;1 00:1complex (l)

206:4compliance (4)

108:20;109:3;114:20;146:1'l

comply (3)122:3:163:11;164:1

componcnt (1)229:4

composite (1)201:9

compounded (2)120:4;154:11

comprise (2)19:3;87:12

comprised (1)119 5

comptroller (1)

Alternative Medicine Maryland, LLC vs.Natalie M, Laprade MMCC, et al.

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74:1commissioner (20)

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62:10204:3communication (L)

204 6Communications (9)

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91:15computer (1)

31:1'7concentration (1)

196:1concern (6)

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214:76;215:1,21concerns (3)

95:21;1 I 0: 1 8; 133:5concluded (1)

233:17conclusion (1)

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145:15condition (2)

35:8,20conduct (5)

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182:2;232:11conducting (4)

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conference (2)141:15;1437

confidentiality (1)230:12

confirm (2)a<'^'7\.14

confused (1)1 88:1 I

conglomerate (1)194:4

conjunction (1)54:15

connected (1)61:10

conscious (2)92:19;93:5

consented (1)163:9

consider (21)93 : 5,17 ;99 :1 8 ;1 04 :8 ;120 :9,1 3 ;124 :9 ;1 40 :1 4 ;1 41 :8,8 ;

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153:2consolidation (6)

121 :3 ;123 : 1 8 ;l 46:12,1 4;153:4,7

constitute (1)175:10

constituted (1)195:19

constitutes (1)222:5

constitutional (1)92:9

constitutionality (6)83 :2,20;84:4,7 ;85 :20; 98 : 8

construction (1)197:18

consultant (27)42:20 ;47 :20 ;50: 5,5, I 5, I 5,

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78:5;137:15consultants (1)

48:10consultant's (2)

53'.3;58:21consulted (1)

74:16contact (2)

143:18148:7contacted (1)

124:18contained (1)

228:20contend (1)

41:14contenders (1)

193:9contents (2)

90:14;128:2context (3)

82:6;146:5;149:13continually (1)

1 89:1 0

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continues (1)216:20

continuing (8)35:8;41:15,17;41:18;

i,::' .. ,, ..,i, i'.:,li' Gore llrothers Reporting & Videoconf'erencing470 837 3027 - Worldrvide - rvrvw.gorebrothers'com

(241) commissioned - continuing

E 000603


Harry 'Buddy'Robshaw, III - Vol. IM.ay L0,20'1.7

| 3 8 :20 ;17 4 :21 ;l 9 1 : 6 ;22 6 :6

continuous (L)13:1

contract (5)5 1 :l ;52:1 5 ;53 :4,1 6;1 5 :17

contracts (1)54:16

contravention (1)120:2

contributed (1)31:18

conversate (1)227:3

conversation (5)6:9 ;53 :1 ;1 0 :l 4 ;7 1 :1 ;192 :12

conversational (2)168:21,21.

conversations (2)22:77,16

converts (1)107:18

conveyed (2)42:20143:20

conveyor (L)12:15

Coombs (1)72'l:'7

c-o-o-M-B-s (1)127:7

cooperated (1)146:3

copies (1)234:19

coplaintiff (1)187 17

copy (6)3 6:3 ;139 :10,21 ;l 40:6:142:15;164:13

Corporation (1)12:14

correcting (2)63:12;155:17

correction (1)203:17

corrections (1)234:8

correctly (4)47:21;61:16,19;102'2

correspondence (1)728:4

cost (2)8:17;214:11

costs (1)'17:19

Counsel (21)4 1 : 1 2;46 : 1 1 ;1 1 :20 ;82 :2 ;

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152'.21;1531;l 61 :8;1 62:1 8;

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39:16counties (10)

1 58'.1 5,17,27 ;l 65'.12;11 2:9 ;11 5 : I 0 ;17 B :1 4',1 80 :4,4 ;

183:11County (49)

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189:9course (3)

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41:13courts (1)

7:8court's (2)

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creating (1)204:18

criminal (2)l11;186:12

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227:17 ,19criterion (4)

133:1;158 l;198: I ;201 :5

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criticizing (1)130:9

cup (1)223:1

current (2)144:10;218:11

currcntly (5)1 1 : 6 ;27 :1 ;40 :1 5 ;l 01 :4;216:12

custody (2)206:21;201:1

degree (2)10:18;11:14

degrees (1)11:5

delaying (1)97:19

Delegate (3Q66: 13, 1 6;80:6, 11 ;81:7,1 ;84:3,3;85 : 14, 1 5 ;86:6,77 )87 :4,

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224:4,5,8,12,16,20delegates (2)

87:12;88:17delegation (1)

89:6deliberations (2)

34:11;230:lldeliberative (22)

3 4:12;3 5 : 1,7,13 ;48 :8 ;81 :21 ;1 1 6 :20 ;124 :4,17 ;

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deliveries (1)125:9

delve (1)210:7

delved (1)209:7

demand (2)209:8;212:3

demands (1)212:7

denial (1)144:8

denied (4)41 :1;143:1;146:8;1 89: 13

dentists (l)278:9

deny (1)146:6

dep (1)6'/:21

Dcpartment (15)12:16,1 8,21 ;13 :4,1 6;1 4:5,1 8, I 9; 1 5:20;1 6 :21 ;17 :7 ;41 :4,8;7l:4;91:19

Departmental (1)74:3

DEPONENT (1)234:3

deposed (4)5:17;7:5;9:7,4

Deposition (35)I 0 : 1,5,9 ;1 7 : I 4 ;29 : 1 0 ;3 6 :4 ;

5 5 : 5',1 2:9,1 1 ;1 3 : 1 ;7 5'.2 I ;

80:9',126:1 ;137 :3 ;1 40:1 ;14 1 :3, 1 5, I 8; 143:12,19;1 46:1,17;148:4;149:l I :l 5l :l I ;

i'ilì. .,, ri ;,'ili,rrr Gore Brothers Reporting & Videoconferencing410 837 3027 - Worldrvide - www.gorebrothers.com

D

daily (1)31:16

date (lQ50:21 ;5 5 : I 1 ;7 6 : 1 5 ;86:1 4,

1 6;89 :8,9 ;126 :21 ;1 42 :2 I ;1 66:4,9 ;1 92:1,2;209 :20;220:1;234:17

dated (1)225:3

dates (2)52:19.231:11

Davies (4)22:4,10,16;32:14

day (26)8 :7 7,7 5 ;1 2 :12 ;1 6 :17 ;22: | 9 ;

3 8 :1 ;43 : I 4,1, 5 ;48 :3,4 ;49 ;l 4 ;

60 : 4 ;7 2:21 ;84 :1 4 ;93 : 1 0 ;

1 25 :21 ;1 64 :8 ;1 66 :1 0 ;1 7 0 : 1 9 ;

17 4 : 19 ;783 :4,12;19 1 :1,17 ;

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39:19;60:9 ;1'7 1 : 1 0,10;231:12,17

DC (3)1 1 0:9;1 1 1:1 6;1 12: I

deal (4)3 1 : 13;38: 1 ;71 :2;79 :14

dealing (3)32:5;54:21;198:12

deals (1)219:9

dealt (1)219:l'l

debate (3)48:ll;123:1,9

Debbie (5)30: I 0,1 0; 1 12:14,16;17 5:4

December (4)50:10,16;58:3,7

decide (3)148:6;188:14;209:14

decided (4)1 7 9 :21 ;1 80 :7 ;207 :1 9,21

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decisions (2)34:18;201:20

declarations (2)177:15,18

declaratory (1)122:11

declare (1)1 82:1 0

dcclarcd (6)17 1 :11,12,12,13; i 80:3;1 82:1

defendant (3)40:14;41:8; I 58:1 0

(242) continuous - Deposition

E 000604

dispute (22)124 :17,78,20;125 :3 ;127 :1 ;

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176:20;189:3disputed (2)

141:19;142:1disqualilles (1)

222:6distinct (1)

153: 1 1

distinction (2)438;229:7

distributed (1)211:15

distribution (3)172:9;179:12;205:1

distributors (3)106:14;133:10;205:15

district (1)210:3

diverse (2)74:6;216:4

diversify (147)47 :19,20;48:5 ;49 : 8, 1 6;50:5,1 4,1 5

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53 :3,10,77,20 ;5 4:3 ;5 5 :1,13 ;

5 6 :9 ;58 :2,5,8,7 6,21 ;59 : 1 6 ;

60:12,18;61 :2;64 :1 4;65 :3,17 ;

66 :3,10,27 ;6'1 :l 5 ;68 :4,7 ;69 :3,1 4 ;7 0 :2,27 :7 1 :4 ;7 2 : 7 4,78 ;

7 3 :I,I 6;7 4:7 1,13 ;7 5 :7 ;7 7 :4,8,1 2,1 4 ;7 8 :5,1 0 ;7 9 :20 ;82 :1 6,

1 6;84: 8, i 3;85 : 11 ;86:l ;92:1 1 ;

93 : 1 8 ;9 4 : 6,1 5,21 ;9 6 :4 ;9 9 :1.9 ;

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1 48 :20,21 ;1 5 4:72,1 5,17,78,20 ; I 5 5'.2,4,7,8 ;l 5 6 :3,20 ;

1 51 :4,19,21 ;1 60:6, 1 0, 1 8,2 1 ;

| 62:4 ; I 67 : 11 ;1 68:1,1,12;| 69 : 4,13,1 8 ;17 0 :8,1 6 ;2 | 4 :20 ;

21 5 :2;21 6:1,7 5 ;21 8 : 17 ;219 :5,7 ,10,13;224:3;229:10

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Alternativc Medicine Maryland, LLC vs.Natalie M. Laprade MMCC' et al.


May 10,2011

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(246) giving - Hygiene

E 000608

Alternative Medicine Maryland, LLC vsNatalie M. e MMCC, et al.

Harry 'Buddy'Robshaw, III - Voì. 1

MaY 10,2017

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vs Harry 'Buddy' Robshaw, III - Vol' 1

M.ay 10,2017

i,'ìri. *.1,-:lr: ¡'i'' i'iì' (ìorc Brothers Reporting & Videoconf'erencing410 837 3027 - Worldwide - rvww.gorebrothers.com

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78:19;101 :1 I ; 140:10,1 6;

1 43 : 8 ;1 49 :2 ;1 5 6 :1 0 ;\ 6 5 : 12;1 90: l5

Iines (1)205:2

list (29)59 : 17 ;6 1 :6;1 0: I 6:1 5 :2 I ;

77:3;158:17;161:1 1, I 1,13,19,2l ;1 64:19 ;1 65 :4 ;I 69 :3 ;17 3 : 1,

| 1,1 4,11,21 ;17 4 :5,6 ;77 9 : 12;

1 83:9;191 : 14,1 6;217:3,8,11,11

listed (4)I 58: 19; 1 60:4; 1 65:6;183:12

Iistened (1)129:16

listing (4)I 58: 14; 1 61 : 1 6 ;165:1 ;17 5:3

lists (1)15 8:21

Iitigate (1)161 :6

litigation (11)7:6,8,1 l,l l;9:10,13;1 l9:9;121:10,12,12;123:19

little (14)6 :8 ;20 :7 ;42 : 1 ;5 8 : 12 ;6 1 : 6 ;

84:21 ;95:19 ;101 : 1 4; I I 3 : I 6,

| 9;123 : I 6;1 33 : I 7 :l 43 : I 0;

211:3live (1)

21:16located (1)

139:3Location (12)

2l :10,1 I ; Ì I 0:7; I 1. 1 :1 6,20,21 ;1 12: 5 ;I 62:3 ;1 1 6 : I ;1 97 : l. 0,

1 1,13

locations (2)8:14;178:8

log (l)25:3

logically (l)158:2

logs (1)112 6

long (7)1217 ;38:11 ;52:7 ;7 6:3;

7 4 ;l 49 : 12,1 2 ;1 53 :13 ;192 : 1 9 ;

213:13,1'1maybe (6)

69 :8 ;7 7 : I 5 ;1 68 :l 8 ;1 9 1 : 12;193:3,3

MCP (2)187:16;188:9

MCP's (1)187:15

MDC (1)214:27

MDOT (1O7 1 :1 1 ;7 2:7,8,7 4,78 ;7 4:3,8,13 ;1 6:8,1 0 ;7 7 :2,7,1 0 ;7 8:8;99;10,1 1

meals (1)24:21

mean (24)1 4:5 :1 9 :17 :22:20 ;39 :8 ;

5 4 :9 ;62: 6,1 8 ;1 03 : 4,7 ;1 0 4 : 12 ;

1 1 1 :8; I 35:7;i 53:12;156:13;172:5,19,21 ;17 3 : 1 I ; I 80:20;19 1 :7 ;193 : 1 1 ;204 :5 ;208 :79 ;219:5

means (2)29:16;101:19

meant (1)54:6

measure (1)108:16

measures (1)48:1 1

mechanism (2)77:20;215:1

mechanisms (1)59:18

media (1)130:8

Medical (42)17 :1 I;34:3;36:1 8;37: I 0;

49 :6 ;50:3 ;61'.10 ;7 3 :3,4,18 ;'1'l : I 3 ;1 8 :1 I ;7 9 : 1 5,2 I ;85 :5 ;

92:12;9 4:21 ;9 8 :21 ;99 :1,4;1 00:5; 1 01 : 1 9,2 1 ;102:1 ;

1 07 :l 4,17 ;1 I 1 :2,4 ;1 13 :20 ;

121 :9 ;1 5 4:6,8 ;l 5 5 :19 ;204 :18 ;

20 5 :2,5, I 2 ;207 :7 ;209 :8 ;

211 15;214:17 ;215:11medication (1)

206:9medicine (8)

98.21 ;1, 46:21 ;205 : I 0, 1 3, I 8;

211:15;212:11;218:13rneet (3)

11520;207:13;272:lmeeting (43)

2l :7 ;39 :6,20 ;52:6,9 ;5 5 :12,15;58: 19;59: 1 ;62:11;68:19;69 :20 :7 0 :1 9 ;7 2'.20 ;1 3 :5 ;7 6 :8,

I 0;82: I3;86:7,8, I 0,1 2,1 5;

87 :3,6,1 7 ;88 :1 8 ;89 :2 ;90 :20 ;

1 00: I 8;1 12:10;114:121,129:15;131: I ; 132: 1 8; I 33 : 1 1;

Gorc Brothers Reporting & Videoconferencing410 837 3027 - Wortdwide - wrvw.gorebrothers.com

(249) likelihood - meeting

E 000611

Älternativc Medicine Maryland, LLC vs.Natalie M. Laprade MMCC, et al.


May 10,2017

1 38:7 :1 42:1 8 ;1 61 :1 6;19 9 : 5 ;

229:16;230:3;231:8meetings (23)

23 : I 0,1 2 ;24 : 1 1 ;25 :7 4,77,19 ;62: 12,1 8 ;64 :72;69 :7,6,9,I 2;7 2: 1 3 ;7 9 : I 4 ;81 :11 ;1 29 : 1 3 ;1 9 8 :20 ;l 9 9 :2 ;226 :20 ;

227:2,4;230:19member (L7)

1217 ;17 :l 0,19 ;21 ;73 ;40 :2,3 ;49 :1 4 ;5 4 :20 ;9 1 :9,1 1 ;

1 32: 1 5 ;1 67 :21 ;1 69 :2 ;1 9 9 : | 0 ;

208:3,5;209:4members (28)

I 6:21 ; I 8: I 5; I 9 :9;28:8,11 ;

3 1 :20 ;5 4 : 1 5,20 ;57 :l 2 ;5 8 :21 ;59 :21 ;6 I :1 4 ;62:4,5,9,1.8;63 : 4;64:5 ;69 :8;'7 I :3 ;81 :12'89 :6;9 0 : 1 4 ;9 1 : 1,3 ;1 07 :2;200 : 1 5 ;212:15

memorandum (2)66:1210216

memory (3)11:14;113:121'178:5

Men (l)59:7

Mental (1)91:20

mentioned (L0)1 5:19 ;50:16;52:13,13 ;

7 2: 1 3, 1 4 ;7 4 :3 ;81 : 6 ;213 :6 ;217:16

mentioning (1)81:10

merits (2)737:9;148:16

rnessage (8)\ 4l : 10,17 ;1 42:l 4,14,7 5,7 6,

20;143:9met (5)

449 ;53 :1 1 ;7 1 :1 ;90 :13 ;

129 1

mcthods (l)17:3

Michael (1)20:3

middle (1)165 9

might (8)40: I 0;51 : 10;57:1 9,19;1 43 : 12 ;203 :20 ;208 :1 6 ;21 8 : 1

mileage (2)23:21;24:17

rnilitary (1)l2:8

mind (2)195:19,20

mindful (4)3 4:13 ;1 45 :1 9 ;1 52:9,12

mine (2)19:191'11:15

miniururn (1)112:3

minority (1)74:6

minus (1)L77:5

minute (10)12.'2;1 8 :19 ;5 5 :12 ;9 6 :2;121 :8;123 : 12 ;l 24 :8 ;l 69 :3 ;

171:16;196:21minutes (4)

5 1 : I O;1 1 : 1 5 ;21 I :21 ;220 :1 0

Mischaracterization (1)102:9

mischaracterize (1)69:17

Mischaracterrzes Q)67:17;90:16

misconduct (2)188:5;190:6

missed (1)39:13

missing (4)8:4,8;39:16;165:8

misstated (2)90:1 9;103:6

misstating (2)68:7;94:2

mistake (1)63:1 1

mistakes (1)215:14

MMCC (1)146:1.0

modified (1)218:12

modify (1)107:2

moment (14)1 5: 1 9;55:3;66: 18;67 :10;68:2;1 09 :6;131 :1 ;7 4 5 :17 ;

1 66 : 12 ;1 9 1 :3 ;1 93 : 1 8 ;207 :2 ;

222:20;233:6Monday (1)

16: 10months (4)

45 1;55:16;7 6;13,73moral (9)

220 : 1 6,1 6,1 8,20 ;221 : 1 2 ;

222:1,6,'/,8more (23)

1 4 : 7 ;7 9 : 6 ;23 :3 ;21 : 7 5 ;33 : 5 ;

44:11 ;45:13 ;1 6: 1 0, I 1 ;89: 1 5,

17 :90 :3,7 ;93 :1 ;13 7 :21 ;

1 43 : 10;1 49 :1 1 ;1 5 6:21 ;7 51 : 4;

185: 19;1 86:1 8 ;191:9;213:3Moreover (1)

162:lmorning (6)

1 24 : 19 ;1 41 :1 1 ;1 42:19 ;

14521;178:2;189:3morphed (1)

278:4most (4)

l120;17 9;196:5,7

4l : I 5 ;46: 17 ;49 :l ;7 | : | 6;

7 2:3 ;7 3 :12;100 :7 I ;l 09 :9,21 ;

1 I 1 :9; 1 14:4;723 :12;125 :75,1 6 ;13 6:18 ;131 :7,1 ;1 43 :13,18;1 4 4 :8;20 5 : 1 1 ;21 0 :8,8 ;2 1 6 : 17,20;218:11

needed (6)37 : I 0;63 :19 ;7 3 :7 ;207 :73 :212:6;234:19

needs (3)I l0: 1 1 ;1 11:12;207:13

neither (1)145:16

NELSON (213)I 3 :7 9 ;1 4 :2 ;7 5 : 4,6 ;22:7 ;24:19;33'.1 ;34:1 0;35 : 1 0, I 5,

1 8,21 ;3 6 : 5,1 1,1 4 ;40 : 4 ;41 : 19 ;

42: 6,1 4 ;43 :3 ;4 6 :77 ;47 :7,4,8,13 :48:7,1'7 ;49 :3 ;5 1. : 5 ;52 :11 ;53 : 6;5 6:13,1 6,1 8,20 ;61 :11,| 8;67 :8,11 ;68 : | 3 ;7 1 :20 ;1 2 : 5 ;

7 5:1 ,3,4,5,9 ,13,19;7 6:5;80:16,2l ;81 :20 ;82:4 ;83 : 1 2, 1 8 ; 8 8 : 8 ;

90: 1 6;92:l ;93'.20 ;9 4:2,8,10,1 4,18;9 5 :l ;97 :8 ;99:7; 1 00 :3 ;

1 02:8;1 04 :9 ;115 : 1 0, 1 1 ;

1 16:19;1 17:18;1 18:9,1 1,15,21 ;1 19 :3,5,8,72;120 :12,21 ;

121 :3,5,9,20 ;122 : 1 5 ;123 :12,1 6;124 :3,27 ;125'.4,1 7,1 3,7 5 ;

126 :3 ;130 :12,19 ;13 | : 5 ;

133 :21 ;13 5 :3 ;13 6:1 6,20;1 37: I 0; I 38:20 ;139:12,16;1 40 :9 ;1 4l :5,20;1 42:4,7 ;

1 43 :21 ;1 44:1 ;1 45 :7,19 ;1 48 : l,1 4;1 49 :19 ;1 50 :3,13,18,21 ;

1 5 1 :4,8,20;1 52:3,7,12,78 ;

153:6,9,14,19;1 54:3; I 55: 1 1,

I 5 ;1 57 :13,1 6,16; I 58:8; 1 59:3,6,8,1 1 ; I 6i :8,1 3,16;162:1;1 63 :1,7

"1 4,17 ;1 69 : 6;17 4 :12,

1 6,2 1 ;1 8 1 : 1 8; I 84:4;187 :6,14,17,21 ; I 88:4,8,1 6;l 89: l;1 90: 6, 1 8; 1 9 1 :6 ;200:'7 ;204:20;205 : 19 ;206: I I ;207 :9,1 5 ;

208 :9,1 1,21 ;209 :9,1 6 ;210 : 12;21 1 :7 ;212:8,1 9,21 ;213 :8,10,1 9 ;21 4 :4 ;21 5 :6;21 9 : 1 5,20 ;

22 ) : 1,5 ;222 :9 ;22 3 :9, I 8 ;224 :19 ;225 :2,7,1 6

"20 ;226 :6;

227 :9,1 3 ;228 : 5,1 5 ;23 1 ;21 ;

232:4Nelson's (5)

58 :1 5 ;61 :21 ;1. 48 :3,77 ;1 58: 10

nerv (4)60 :21 ; 63 : 1 9 ;9 1 :20 ;9 6 : | 8

nervsprint (2)50:1;61:9

ncxt (6)6:l 8;8: 1 5; 170:15;179:11 ;

220:12;234:20night (1)

J: ," 'i',i r', Gore Brothers Reporting & Videoconfcrencing4'1.0 837 3027 - Worldwidc - rvww.gorebrothers.com

motion (20)1 43 :2 ;1 44 :4,8,17,1 8,21 ;

145:5,1 0,14,1 5; 146:6,8,8;148: 1 1 ; 1 5 I : I 6 ;152:17,76;159:14,19;189:13

motions (2)145 16;190:19

motivcs (1)189:21

mouth (1)10:11

move (9)21:11;123:10;126:2;149 :20:l 50 :5;179: 1 0; 1 80: 8,

10;214:6moved (2)

117:4;118:6moving (2)

126:1;232:8much (13)

3 5 :21 ;39 :20 ;5 5 ; 1 7 ;5 6 :2 I ;| 50 :8 ;1 64 :6;11 1 :1 6 ;1 9 0 :1 1 ;207 :3 ;212: 1 1 ;21 3 : 12 ;2 I 4 : 1 1 ;216:18

must (1)199:20

myself (7)79:11;88:19;i02:15;1 1 I : 1 8; 121 : 15 ;1238;17 6:13

N

name (34)5 :8 ;1'7 : 1 5 ;20 :2,4;37 : 19 ;4 5 :20 ;5 1 :3 ;5 3 : I | ;5 5'.2,9 ; 5 6 :2,1 3 ;5 9 : 4 ;7 5 : 6,9 ;88 : 4,6 ;9 1 :20 ;1 12 :2;120 :6 ; 129 : 7 0 ; I 60 :2 1 ;1 65 :1 5 ;I 66:4;1 67 :4 ;17 4;1 ;

199 :14;203 : 1,6;219 :5 ;22 5 :17 ;

226:9;227:5,7named (3)

218:19;225:15;226:14names (7)

59:4,9;87:20;183:21;201:16;226:10,21

Nancy (1)203:2

narcotics (Q1 1 :2 1,2 I ;13 :9,9,1 1,13

narrow (1)19:6

natorial (1)210:2

nature (5)25:12;110:11;123:2;195:15;19'l:20

near (3)44:21;45:4,97:15

ncarly (1)1i4:2

necessary (2)21:16:234:9

need (26)

(250) meetings - night

E 000612

126:10"11;192:4off (22)

1 3:5;15: i 7,1 8;37 :21;45: l;51:3;56:6,7 ;7 6:7;80:14;81 :5;88:20;92:3,5 ;100:9; I 0 I :7;| 02:21 ;1 127 ;l 64:1 1 ;17 5 :21 ;1 90: 10;1 9 1 :21

off-duty (1)14:17

offer (2)27:16;29:15

offered (4)61:21;71:5,7;179:3

offering (1)83:19

Office (10)9 : | 0 ;5 6 :7 ;9 7 :2 ;725 : 6 ;

128 : 4 ;1 41, :l 4 ;1 42:1 9 ;1 4 4 :20 ;223:20,21

officer (6)9 :13 ;1 | :21 ;13 :5 ;40 : 8 ;1 10:3;1 86:8

officers (1)7:15

oflices (1)224:6

oils (1)107:18

old (2)59:11,14

omissions (1)147:17

omitted (1)102:5

once (5)I 4: 1 ;60: 1 0; 1 78 :3 ;227'.4;230:8

one (107)6:10;7 :18;8:2;9:6; I 5:3;22: 1 9 ;27 :19 ;3 0 : 1 7,2 1 ;3 1 :4,6 ;33 :7 ;3 5 :6;39 :9,13 ;4 4 :11,1 8,20,21 ;45 :3,1 1,1 4;52:3 ;53 : 12;5 8 : 1 8;7 1 :17 ;7 2:13,1 5 ;1 4:1 6;'l 6:1 0,1 1,12 ;7 9 :3 ;80 :21 ;85 :2;8 8 :2;90: 1 1,12;101 :6;108:21 ;

1 I 5 :21 ;1 17 :2,4,5 ;124 :13,1 4 ;

1 25 : 5 ;129 :1 3 ;1 32 :2,1 8 ;133 :1 1 ;134 :2,1 1,1 4;13 5 :7,1 5 ;

1 56:21 ;1 582,3,1 1 ;1 60 :1 5,11,19 ;1 61 :3 ;1 62:15; I 65 :5 ;1 66 :12;1 68 : 5,5 ;17 0 : 1 1,12 ;

112: I 1 ;17 3 :1 1 ;17 5 :4,1,1 4;11 6: 19 ;17 7 : 6;11 8:5,1 1,12,1 6,

11 ,18,19,20;179:6,10,11 ,11 ,1 8; 1 80:8,9; I 8 I :14;782:1 4;I 83:4; I 89: I 9;l 90:3;194:5;I 9 6: I ; I 9-l :2 I ;202 :2;203 : l7 ;219 :21 ;222:6 ;226 :3,20

ones (4)9: 16;38: 13;40: 1 0;1 61 :4

one's (1)222:8

ongoing (2)

13'7:3,6object (15)

33 : I ;3 5 :3 ;42; 1 5,1 6 ;8 7 :20 ;

83 :12;1 1 6:19 ;137 :1 ;139 :17 ;I 4 I :2;1 46:1 8;l 84 :5 ;1 87 :6 ;

200:18;221:1objected (1)

208: 1 1

objecting (5)| 44 :3 ;1 47 :20 ;l 5 1 : 6,8 ;

152:1

Objection (108)13 : 79 ;1 4 :2 ; 1 5 :4 ;22 :7,9 ;24: 1 9 ;3 4 :1 1,1 6,20 ;3 5 :8,9,1 6 ;3 6: 7 7 ;40 :4 ;41 :1 5,17 ;48 :8,1 4 ;

49 :2;5 I : 5 ;52 : 17 ;53 : 6 ;5 8 : 1 5 ;

61 : 7l ;61 :8,17,21 ;68 : 13 ;

7 1 :21 ;9 0 : 1 6 ;93 :20 ;9 4 :8 ;91 :8 ;

99:8;1 00:3; 102:8;104:9 ;

1 17: 1 8; I I 8:9; 1 20:18;121:14,1 4;122:13 ;123 :7,2,6,8,7 0 ;

130 :12,19 ;13 1 :5 ;13 4:l ;

138:21 ;139 :1, ;1 40: 5 ;l 41 :20 ;1 4 4 :2;1 4 6 :1 ;1 48 : 5,9 ;1 49 : 1 4,20;1 50 :5 ;l 52:4;1 5 5 : I I ;1 57 :1 1 ;l 64:4 ;1 69 :7 ;17 4 :12,21;181 :18;184:5;191 :6;200 :7 ;20 4 :20 ;20 5 : 1 9 ;20 6 : 1 1 ;

207 :9,1 5 ;208 :9 ;209 :9,1 6 ;

21 0 : 12;21 1 :7 ;21 2 ;8,79,20,21 ;

21 3 : I 9 ;21 4 : 4 ;27 5 ;6,7 ;2 1 9 : I 5,

20 ;222 :9 ;223 :9 ;22 5 : I 6,20 ;

226 : 6 ;227 :21 ;228 :8,1 6,1 8 ;

229 : 1,2,7 I ;23 0 :6 ;23 1 : 5

objectionable (1)35:2

objections (2)1 63:20; I 88: 1 9

obligations (1)145:20

observed (1)111:19

obtain (2)130:10;230:1 5

obtained (2)11:14;18i:17

obvious (1)11:3

Obviously (4)3 4 : | | ;82 : 6 ;9 6 :3 ;228 : 1 1

occasion (1)18:10

occasions (1)9:12

occurred (7)42:1 1 ;54:10 ;17 4:19,19 ;

216:18;232:12,20occurring (1)

143:12o'clock (1)

142:21October (8)

12:19 ,19;18:2;21 :7 ;92:1 ;

Altcrnativc Medicine Maryland, LLC vs'Natalie M. Laprade MMCC, et al.

Harry 'Buddy'Robshaw, III - Vol. IMay 10,2017

1'77:20nine (4)

13:8;177:4,5,5nobody (1)

195:12non (1)

40:2none (3)

178:19,20;195:12nonetheless (3)

95:8;176:12,13nonpracticing (1)

91:8nonprivilege (1)

123:7nonselection (1)

160:6nor (1)

68:1 0note (4)

46:17 ;60:1 ;1 49 :20 ;1 50 :4

noted (6)34: 1 5 ;1 1 I : 17 ;1 45 :9 ;l 46 :2;147:6;151:15

notes (3)31:16;101:6;113:19

notice (6)1 0:4,8;65: I 5; I 45:13,13;151:15

notifìcations (3)65;15;66:7,3

notified (1)2l:15

notifying (1)66:5

nofwithstanding (5)73:15;93:13;95: 1 2; I 89:3;219:71

Number (54)10: 1;43: 10;46:5;51 : I 8;

71 :5;80:6;8 I : 1 6;86:l'7 ;

1 00 : 17 ;1 Q 6 :2,5,6,20 ;107 :3,21 ;1 08: 1,1 ;l 1 6 : 12;126:9 ;

1 3 4 : 19,20,21 ;13 5 : 1 ;1 39 :1 4 ;

140:20;1 43:1,4,6; I 58: 1 3, I 8,

20;1 64:1 3 ;1 66:1 6,17 ;1 67 : 6;

1 69 : 10;1 82:1 9,21 ;19 1 : 12,13 ;

1 92:8;193 :4;207 :l 1 "12,19 ;

208:7,13 ;209 : 12,13 ;210:4,1 5,

l8;211:6;231:4numbers (4)

106:14;134:7 ;193:5,7numeric (4)

138:9,12,16;195:4numerical (1)

171:7nurse (1)

36:21

18:1,3online (2)

108:19;110:10only (28)

6 : | 0,1 4 ;3 4 :20,20 ;3 8 : 13 ;

43 : 9' ;4 4 : 1 8 ;49' : 1 8 ;1 6 : I 1' ;80: I 7;86:3;87: 19,19;1021 4;1 34: 1 3; 1 38 :9; I 46:5;747 :3,72;1 5 I : 13 ;l 52:20 ;l 5 4 :13 ;17 9 : 6 ;

201 :3 ;208:1 5 ;210 :8 ;229 :1 5 ;

232:17open (4)

100:18;12317;206:4;229:16

opening (1)230:3

operate (1)214:11

operation (1)8:4

opinion (3)27:16;121:15;128:6

opinions (1)197:7

opponent (1)141:5

opporfunify (2)110:7;151:12

opposed (7)19 :8;101 :21 ;1 1 4:1 5 ;128 :5 ;

137:21;194:16;211:6opposing (1)

141:5opposite (1)

104:11order (20)

3 4:1 3 ;3 6 :4 ;48:12; 1 09 :2,9,20 ;1 42 :9 ;l 4 5 :1 0,1 2,20 ;1 46 :9,1 8 ;7 52:9,13 ;1 65 :2;1 69 :21 ;173:3;189:4,15;212:1

ordered (7)8 :3 ;52:4 ;53 :5 ;97 :71 ;99 :13,17;1 00:1

orders (l)17:7

organizations (1)79:18

original (5)1 1 :7 ;82:1 4,17,1 8 ;23 4:1 0

others (1)58: 19

otherts (1)31:9

otherwise (1)39:1 1

ours (1)215:74

out (52)9 :8,1 5;19 :11,18 ;25 : 1 6, 1 8,

20 ;3 1 :13,1 9 ;42:4;43 :12,12;50:1;53:18;57:1 1;61:1,8;7 I : l2;1 4:5,5 ;7 9 :7 ;9 5:2 1 ;1 1 6:1,1 7 ;1 1 I :6;123 :1 4 ;l 24:1,

ooath (6)

6 :3 ;4 6 : 1 0 ; 5 6 : 1 4 ;1 4 :20 ;

i ',il i; ::i:,¡i,lt'ir' Gore Brothers Reporting & Videoconferencing410 837 3027 - Worldwide - tvww.gorebrothcrs'com

(251) nine - out

E 000613

1 38:1performed (1)

42:18perhaps (2)

18:17;21:15period (2)

91:18;21 l:13perjury (2)

6:4;46:11permanent (1)

122..11

permission (1)24:13

permitted (1)108:4

person (10)8 :4 ;1 8 :1 3 ;2 6:1 1 ;63 :9 ;

87 :1 9,20 ;10Q :20 ;203 ;7,13 ;

230:20personal (3)

65:14,21,;186:9personally (2)

3 8:9;133: l8person's (1)

8:8perspective (2)

101:17;210:13pertaining (1.)

13'7:3

PG (1)15:14

pharrnaceutical (1.)

99:4Phase (2)

101:16;161:5phone (7)

111 4;121:18;129:13;1 40.20 ;1 41 :1 5 ;143 :1 ;1 48:13

phrase (4)9 6: I ;1 54:1 5 ;1 61 : 5 ;222:13

phrased (1)210:5

physically (2)39:77;46:75

Physicians (1)150:9

Physician's (1)150:9

picked (1)208:14

piece (1)234:20

pile (1)136:4

pizza (l)206:4

ptace (10)25 :3 ;98:4;9 9 : 1 4,17 ; I 00 :2;1 41 :1 5,1 8 ;1 6'l :17 ;197 :1 1,14

placed (1)52:75

plaintiff (1)43:16

156:2parse (1)

190:11part (18)

14:12;46:19;41:9;53 : 1 8;

54:1 5 ;67 :'l ;1 2:7 ;83 :4 ;7 18 :7 4,1 6;120:8 ;1 62:5 ;11 3 :1 ;17 9 :7 ;

1 82:3 ;199 :1 9,19 ;220 : 1 5

participate (1)37:11

participating (1)146:16

particular (9)30: 1 8;1 1l 73,74;124:11;17 0: 1 ;21 I :17,17,19 ;21 5 :78

particularly (2)49:19;103:12

parties (3)40:1;4810;143:1

parts (1)i 80:6

party (2)40:14;41:8

passage (1)1 55:14

passes (1)33:1 I

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May 10,2011

Roscn (1)203:2

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128:19;130:lIserving (1)

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Harry 'Budtly'Robshaw, III - Vol. 1

May 10,2017

1 0 : 1 6,1 6 ;1 1 :2,1 I ;12: 1 0,12,13;184:15,20

science (2)10:18;11:4

scope (1)3 8:8

scopes (1)123:19

score (8)1 67 :7 ;17 2:21 ;180:7 ;19 4 :1,11;197:1,4;201:9

scored (7)135 :9,13 ;13 6:3 ;77 3 :7 ;

228:14,20,21scorers (1)

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19 6:20;197 :7 ;200 : 8 ;20 I :20scoring (9)

13 4: 5 ;1,3 6 :1 1 ;192 :20 ;793:1,8;194:8,1 0; I 98: I 5;

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186:6screening (2)

1,86:4,4second (11)

8:2;3 5 :5 ;46'.6;52:3 ;5 8 : 1 8 ;

88 :2;89 : 19 ;17 0 :12 ;17 2: 1 | ;115:8;182:14

secondary (1)1 15: l9

section (3)102:5;204:14;228:14

secfions (1)228:20

secure (4)197 16;206:16,17,18

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securing (1)111:1

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18;1 1 1 :7,7,9,12,1 5,77 ;1 73 :4,7 ;l 32: 1 9 ;1 33 :2,5,72 ;7 9 6 :3,15;197:10;201:1 0, I 5,1 8;

202:3,6,1 0 ;203: 8 ;206 : I 5

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20:72,15,16,18slow (1)

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222:1Special (2)

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55:1;172:2specialists (l)

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148:8specialty (1)

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speculation (3)68:14;181:18;207:16

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May 10, 2017

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Harry 'Budrìy' Robshaw, III - Vol. 1

M.ay 10,2017

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Harry'Buddy'Robshaw, III - Vol. IMay 10,2017

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trXHIBIT G

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EXHIBIT G

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BnlrN E, FnossATTORNEY CSNEML

Elrz¡¡rtn F. H¡,nnrsCHIEF DEPU:TT ÃTTORNNY GENERâL

Tn¡nw¡Non¡x V¡cnen¡IanDEPUTY ÀTTORNBY C-E NIRAL

S*wonr BrNso¡¡ Bn¡xtrBvCOUNSEL TO THE GBNBML ASSf,MBLY

K,trr¡nr¡¡¡ M. Row¡DBI'UTY COUNSBL

Jnænar M. McCoxÂSSISTÁNT ATTO RNSY GENEML

D.rv¡n \Ø Sr¡M¡snASS¡STANT J$TORNBY êPNEN-AI

THE ATTORNEY GENERAL OF MARYLAND

OFFICE OF COUNSEL TO THE GBNERÁL ASSBMBLY

March 13,2015


303 House Offrce BuildingArurapolis, Maryland 21 40 1 -199 I

Dear Delegate West:

You have asked for advice concerning the validity of certain provisiontì of the Natalie h4.

LaPrade Medical Marijuana Commission Law, Specificaliv, you have asl<ed whether these

provisions ate unconstitutional. It is my view that these provisions must be administered in

ãccorda¡ce with the United States Constitution, but, in thc event that they were found to be

unconstitutional, they Would be severable from the remainder of thc law.

Health - General Article, g 13-3309(a)(9Xi) provides that, in licensing growers of medical

marijuana, the Medical Marijuana Commission ("the Commission") shall:

1. Actively seek to achieve tacial, etlmic, and geographic rfiversity u'hen

ljcensing medical marijuana gtowers; and

2, Encourage applicanfs who qualiS as a minority business enterprise., as

, definçd in $ i4-301 of the State Finance and Procurement Article.

Health - General Articlo, $ 13-33.10(c), which relates to the licensing of dispensades, prcvídes that

tho Commission shall;

(2) Actively seek to achieve racial, ethnic, and geographic diversity when

licensirig dispensaries

.. ln the bill review lettcr'on lIouse Bill 88i (Chapter 240) and Senate Bill 923 (Chapter256)

of.Z¡l4,the Attorney General advised "that these þrovisions be implemented consistent with the

provisions of thç United Stæes Constitution as doscribed in Riohmondv, "l,A' Croson Co,, 488 U,S,

4AO çOSV¡ and Fisher v, Unit,ersity of Texas at Austin,133 S.Ct, 24II (20t3)Ì' See Form BillReview lettel dated April 1 7,2014, It is well-established that a race-conscious affirmative action

prograrn is subject to striot scrutin¡i and will be upheld by the court3 only if it is narrowly tailored

io uõhi*u" u ,ompellíng public purpos e, 91 Opinions of the Attorney General 1 8 1 , I 82 (2006), citing

AdarandConstructuti,\nc.v,Penta,5t5U.S,200(1995); CítyofRichmondv'J,A,CrosonCo',488

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E 000624


March 13,2015Page2

U.S. 469 (1989). The Croson case held that a governmental entity has a compelling interest in

remedying icteniified past and present race discrimination. Id. at 492,509, For this interest to be

.o*p.1lirig, the goveinment must be able to identis discrimination in the relevant market in which

theentitylsaparticipant,Id,at50l-504, Inaddition,theremustbea"sffongbasisinevidence"ofthat discrimination.at the time the program is established, Id. at 500, 510. in the context of

government contracting, which *ut th. subject of Croson, this requires a study showing a

;ßignificant statistical d-isparity" between the availability of qualified, willing, and able minority

subcontractors and the utilizaiion of ,such subcontraqtors by the governmentql entity or its prime

conlractors, HB Ro.we C6,, Inc. v, Tip.pett,615 F.3d 233,241(4th Cir,20l0)' The Físher case' for

our purposes, confirms that the test set out in Croson still stands, and that a Court will closely

*r*iinil" a government's justification of a race-conscious pïogram and its evidence in support of

that program,

The provisio ns of Croson and Fisher applyto ethnicity in the same way as race. They do not,

however, apply to geographically conscious piogtu-t. Thus, the law shouid be read to have full

force to the extent that ilrequires ihe Commission to seek geographic diversity to the extent possible'

Moreover, it is not unroo.titutional to cncourage businesses of any type, including those in the

minority business enterprise pïogram, io apply to particþate in any type of govemment proglam'

Constitutional limits, håwevår', would prevent the Commission from conducting race- ol ethnicity

conscious licensing in the absence of a disparþ study showing past discrimination ín similar

programs. I am aware of no study that would cover growff or dispensary licensees, or even licensing

in g-enerul, Most State licensingprograms license everyone who meets the licensing qualifications,

*ã thu, would not give rise toihe uUitity to pick some and not othels. As a result, the efforts of the

Commission to seek racial and ethnic diversity among gro\ryers and dispensa¡ies would have to be

Iimited to broad publicity given to the availability of the licenses and encouragement of those from

various groups,

Even if the provisions axe implemented in a way that leads to a determination of their

invalidity, however,lt is my view that they are severable from the remainder of the law. The primary

inquiry in ttt6 determinatiôn is what would have been the intent of the legislature had they known

thattheseprovisions couldnotbegiveneffect, Davisv. State,zg4Md.370,383 (1982)' Generally

courts wili assume o,that a legislative body generally intends its enactments to be severed ifpossible,"

Id; see atso Atticle 1, $ 2t ("lt]he provisions of all stahrtes . , , are severable unless the statute

specifically provides t¡át itr ptóuirió"r are not severable."). Thus, "when the dominant purpose of

Åtatutemâylargelybe carrieã outnotwithstandingthe invalidprovision, courts will ordinarily sever

the statute and enforce the valid portion," Id. at 384. In this case, it is clcar that the program is

"complete and capable of execution," Migdal v. State,358 Md 308, 324 (2000), without the

Oiversity provisions. Therefore, it is our viçw that, if fbuncl invalid, the diversity provisions would

be treated as severable and the remainder of the law would remain in effect'

E 000625

The Honorable Chris WesiMarch 13, 2015

Page 3

KMR/kmrwest0l,wpd

S

M. RoweAssistant AttorneY General

E 000626

The Honorable Chris West March'13, 2015

Page 3

KMR/kmr westO I ,wpd

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Assistant Attorney General

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EXHIBIT H

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ST,ATE OF MARYLANÐOFFICE OF THE GOVERNOR

LARRY HOGANGOVERNOR

Apri|27,2017

Jimmy H, Rhee

Special Secretary of Minority Affairs

100 Community Place, 3d Floor

Crownsville, MD 21302

Dear Special Secretary Rhee

Pursuant to Maryland State Governmcnt Article, Section 9-305, I am directing the Governor's

Ofhce of Minority Affairs (GOMA) to initiate a disparity study of the state's regulated medical

cannabis industry and market. GOMA should work together with the Natalis M. LaPrade

Medical Cannabis Commission and the Maryland Department of Transportation to complete a

disparity study as expeditiously as possible in order to ensure diversity in Maryland's medical

cannabis industry.

While a disparity study was contemplated during this past legislative session, there is no

approved bill for me to sign that woutd initiate this process. As the issue of promoting diversity

is of great importance to me and my administration, your offtce should begin this process

immediately in order to ensrue opportunities for minority participation in the industry'

Thank you for your assistance and leadership in addressing this important matter

Hogan

STATE HOUSE, ANNAPOLIS, MARYLAND zI4OI(4to)974-3901 l-Boo-all-e336

TTY USERg CALL VIA MD RELAY

E 000628

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coM M I l; S I ()N'S {} t} t¡OS I T I (} N T'C} I' L A I N"t' I tr F'S M f)'I' I () T{ F{) IlIiM Ii fIÜ IÌNCV'I'E M I'OITA II Y II ËS]'RA I N I N(; ()R D Tî II A N T)

RnQUnSl'FOR Orìt)ilr T() St{OW (:,rUSn W¡tìí.¿\ PIìELIMINARY INJI.JNC'I'ION S}IOULI} NOT' I}Ii GIIÁNTIII}

Altlfl4.s Motion lirr a 'l'nttp{rrítrt l{{,'stlaining {)¡'d*r ancl l}l'climirralr' lnlurì{ilion

{"',À.MM's [r'lotion"] sltctttltl lic tlenirrtl hcç¿lu,s'"-..,\Mlvl üilnnot sntis['r,iìtìr,ol'thc. liurr

lhrrr:rs rct¡uirr:d to ohlain ¡x*litnittit¡v irtiurtciivc r:r":lir:ll AMlvl Sç'rks âtl ordrr lì.*nr tlris

eottrt prohiLritirrg l)elhnrlallt¡- I'rcnt isstrin!r iuì)',ìnnl licr:nses t(r grïr\\ ntrdicirl c¡rrrnahis i¡r

Mitr,vlancl aricl ¡tr:trhihitirtg l)clbrtdartt:i lìrlnl tiikiirg rn'ç ael¿litinrì¿rl ¿tcti()n in liuth*r'atrçc ol'

{he Cunrtnissiott's littge 3 lltetlictrl r:¿tnnrtris glü\\¡cr liccrrsing schunrc. inclueling tlrc

irnnlediatr: sr¡spürls¡on ol' irts¡:eetiunri ttl' t'hc lÎliccn pre-üpllr(ivr-rcl lrrctli*irl cirrlnirlris

grorvilig lìrcititics. Afulivl's þlotíon *t i, 41"\'llvl sccks tlris ctìrer¡l.iitìc,y rcliel' clespitc

Ir'*virrg rr,uiter,l tlu'uri rìlrrnths alicr lltr: chnllellgerl irrrirrtl ül'l)r"{-ullptrlr,ulÉ tu lìle suit nrrrl

ncnrh,se\,Êrl rnrlnllis lionl thc tlirtc it liletl suit lsr $cek irliurrutivc: rclicf. ¡\Mlvl"s dcla_r'

ilndcrruincs bt¡th iis lili."'lihnud nl'suüurss nn ih* luerits ilrlrl ils ll:ilitr, ttr shrlrr,iln

ilnntetli¿ttc irre¡rirrlble irtirrlr .

E 000629

vmckinley

Text Box

05/17/17

['lot'ctlvr:¡'. ,'\lvlful lrolds nr) lr.rgirll¡'-cuunizit¡lc i¡tcresl in its ursuccessli¡l

flpl)licillion lìlt'lt rllcdicltl c*tln¿ibis *qrol\cr licrr:nsc. ¡\ñll\l is currcrrtl¡,*.,t srrlucterl lìlrpl'ri-¡lpllro\:al' llltl it ltas ¡rfJbred ttn lhcts or' irllr-'gltions lo riugsrist rh¡t it g,eru¡l lle an1,

clrlsct' tù t¡litailtirtg fl prc-;lp¡rtrrt,al lìlr lr nlcrlieal ci¡nrrabis licr:¡lsc il"thc llçrrrr \\¡{.:tc tù

crlioirt tlti: pttlccss attcl ret¡uite fïtllher: acli(xl hy thur (lgrrr¡rissirl¡" ¡\s a resuh. ,AMM

çtllìl"lÖt rlcntottstrittc thitl it ¡nccts tltu lcqttir*nrrlts r¡l'¡rnrvilrg illlllccliutc. irr.c¡;1ra5le hnr.¡r

ill tlre ahsensc ol'lltc issrrancr: oi"irn irtiunction or th¿tt,rhc hlrl¿r¡l{ic ol,lìanns u,r:ighs in its

li¡ r,trr.

l;innll¡'" M*r¡'lnnd paticnls l¡tnç bcçrl rvlrìtirig lì¡r ¿lççc".$ l() trc¿llnleitl çven longer

than ¡\l\4M'u'uitctl tu l)tesuìt tlris r'cquest to thc (lourr. "l'lre irr"irrnctiun AMM scçrks is

c{nl{rât} tu thc ¡xrhlic itrt{ir*st irr ¡rruvirlitrg slrlb ïrecess to nrcdicrl tfcntnrsnt to (r.jSg

¡)itticllts rvllc havr'ah'eutly l¡:¡llictl to llre Collrnrìssiurr to rc$istcr ils a patirïll i¡ t[c

Mhrl'l*llcl fulctlic¡rl Cat¡nahis progriìrn, As n rcsult. AMM' i\4çtiorr tilusr hc clenicd.

I}ACKü ROUN I)

Mtryltntl's Stn *xtory ttntl llrgnhr lorv Schcrus fo l' lVl crl ietl C¡r n n* þis

'l'hc Cotnntissiort is ut, irtrlc¡rcrtrlcrrt cn¡nnrissiun th¡rt liurctions u,ithin th*

De¡rurlm*ltt ol'lJaahh itntl Mentiil ll¡,giarrc" lVld. (lurle ¡\nll.. [-lc¡kh-(ic¡. is t]-3ji]?{b).

Ct:ttt¡rlaint ti 9, 'l'hc Ctluruis:titìn üon$¡$[ü ol' l 6l nlr;nrbers: orrc tlcsignee ol"rhe Sccrctary

nl llcaltlr and Mclttal ll¡'gictrc ¿r¡rtl l5 r¡renllrcrs o¡:¡loirrtcd ln'rhe (iovenlor, lvlql. Corle

Alltl." lleltlth-fic¡1"$ l3-i-ì0?" C*nrpltint'!l ll. 'l'l¡c (onlntissir)¡t'!í p¡rpo$c is tp "{cr.elç¡'r

¡lolicir":s. ¡rrttcc<lurus. guitlclincs. nrttl regulnlir¡lr¡- kr im¡rlcnri:rrt llt'(l{:rütìts tn nl¡ke rncclical

I l)ttc ltl t'itclltlcics. thcre ¿rrc çurrclllv l4 lllrrnihers rlf'thc L'o¡llllris.rion

-)

E 000630

cilrtnähis n\/âil{rblc tu r¡ualili,irrg ¡rltir-'rrrs i¡r ¿r slrli: ¿rld cfll,ctir.r: r.r¡iÌn'L:r... Ilçullh_(icn. g

I3-330?{c). Complainr 1i l(r.

'l"he Co¡rtr:tí.s.çioll is itlsr¡ csprcssl¡' irrrlhrlrizctl to ¿¡ç1 a* a liccrsirrg [rotl¡,. 'l'lrc

stüttltc 1:$'Ídcs th:rt thc Crlnuttissinn ".shlll liccnsc nledi*¡il c¿¡llllbis grCI\\içts tlrat nrçcr

all r*tþrirelìli:llls cstahlisllcil h¡ rhe Cotttr¡issir¡n to u¡rcnut ill thc Srrtc." llcalth-(ìc*.5\

l3-330{lin}(l)" {'um¡rlailtt r: 16. 'l'ltu (brrrrtii.ssir;n h,tii stal.utr)r'r, nutlurritr, to issuc a

llt¡txilllt¡llt ol' l5 lir;rlrtsii$ l(l llletlie¿tl i;¿rur¡this Sri)rvclli, l.lcalth-(icll, $ l3-33txr(aX2i(il.

Cortt¡tlaint tÌ l(¡, 'l'hc.nrùtli{Jitl citnr¡uhis gr'u\v*r licc¡lsine st¿ìtutr} ¡:rovir|:s rh¿rr the

Comniissi*rr "sl¡all aclive l), sc';k lo aehicr,c r*ci*1, i:tlrnic. lrrd gengrn¡rlric divrrsily l,herr

lictrtsing nretlierl ealrn;tbis sro\1:ürs.'" llcllth-("irrrr. $ l3-33{}ó(rl(tJ}tiX l}. eurnplnirrr 1 l(r.

ln *r¡fi¡r tc üxcrcise its liccnsin$ nuthi)ril.\,. tlrr: Ctrnltuissiolt \v¡s st¿l{ltorill' r:equir-e{ ttr

"¡lsfabli¡ilt tn rrlt¡rlieirtiott l'er ieu ¡rrtirJcss lirr grrrrttirrg rncclic*l ur¡lnuhis gt'{t\ver licenses itr

It,lliclt:r¡:¡tlicatitns l¡r{.: rcvierveel. ctulrr*t¡:cl. nlrr,l r¡rnkç:d l:ltscçl olr uritEri¡ est¿rblishcd hy

tlte C.onlrnis*ion."" lle¿rltlr-(jerr. g l -ì-i3üôt¡r t{ ?)tiii }" t'nrnplainr !i 1 6.

'l'ltu Cturr¡rtissitin lirllillr:rl tl¡*sr: st¿rlt¡lolr lrtrul(l¿rtes ht protrrul*intilg rcgulatiu¡s

go\rerning the critcria b"r'wlticlt a¡rplimttions lilr rncrlicrrl cillr¡irbis gt'()\ver liceilsrs rr,ouf{

[:le revier.'çtl lnd the rvcight ¿rl'liurk;rl tu ri¡çll uf'tlrr: cl'itcl'i¿1, l.]OM¡\lt ltl.ñ?"ült,ü5.

Cont¡rluirrt .!: 35. 'l'hc seuling elitcriir:ict r)rt irt tltcr rcgulntiurr.s do not inr:lud,r: r¿ìce ()¡'

ethnicily. ()rlrttplnirrt'!r 3S. l'hc ¡nrtlie¡tl c"irnn¿rlris Srr)\\0r'liccnsing l)r'nc*ss is u lrçr'r-st¡rSc

pr$ccst. CCrtttpltrílrt !] 3*. l¡ì slttgc otle. llìd ('r¡tt¡lliissiott ¡tllrnrie<l tr.l iSSue ¡tr.c-a¡:¡:rr"ot'als

to ttp ttl l5 tr¡l¡llir:it¡'tls Iilr utctliclrl ciutn¡rhis gl'{)\\ct' licçnses. "i¡r rrxlsi{er¿ìli(}n gl"thc

E 000631

r¡ìnki¡ltl t)l'tltc ap¡llicittiorts itr irceortlirrrl-{: rvith ltcguluti¡rr.05..' CüM/\lì

l(].ó2.il1{"(l(r^.f I ){ lrl. CorrrFlainr .i j4..

'f ltr r\¡l¡rlicr*rti o l¡ I¡ r'occsri

()rr Scprcnrh*r 28. 3()15.'thu Jonrrrrission relcos*d rlre Â¡ipliearion lìrr Medical

Cunnnhis (ìrtlrver l."iccnsc ¿ln(l iìnrìûnnecd tliat coffipletcd a¡rplirirtinrrs hntl tü hçr

sttbtnittcd [r¡'4;{X) pnt on Novcnrbcr û. 2(}15, ('oru¡rllint l] 43. 'l^lrc tpplicatiol cliii *ot

rcqtlir* ap¡rÌicarìts 1o ¡rr*tvirle thr; r¡ccr {)r ùthtìicit"v r:,1' tlmir e.u\,llsr$ tll<l invcstors.

Cornlrllint nt .!: 45.

'l'ltc (crllrtlissi*n cnterctl irttu ¡u.¡ ilgrcetìTunt rr,itll tlrc ltegitrrrul l,corrornic Studies

l¡rstitttle ("'lIL,,5l") irt'l'ou'soll (.lnivcrsit¡,to rssisl the Coinnlission ivith the nletlical

eannillri.s gr¡'o\\'cr license npplicutitrr ¡'ç.r,iert pr{)re"ss. Colnplirirrt !l .1.?. '['he Cr:rnnlisxion

ätttl lìl::lil tlcsiglrecl a "drluþlc.blinrl" Snbjùct Mattcir Lix.prrt-lr*serl ;ilruly'sis of '

*¡:plications. Corl¡rlnirrt !i 4?. .A¡rylicurr{ tìiulrË}- \\crc tx)t includc-il irr the rrnllu¡tiorr

lìl¿lf.$ri¿lls anel tltc Crltnntissirtn vr)led.ürì th'i toF-t'{tnkrJ(l ,gt'o\yr)r ilppliüntiöns c¡rl¡, b5,eoclcil

idcrrtil'icillion ntnlthcr. rvith rr¡l¡rlicnrl i(lent"itiüs concçirlud. Conr¡:laitìt li47.

On.lul¡' 12. l{)16. llrt Ctlrntnissio¡l voted to udr:¡rt ¡r (irrln'*r livtluatiorr (juida¡rcr-r

{"(ìtritlartcc") tlrruurncnt trt 51¡t1t,r,r'', Cntì'llnissiollers'*l'lorls in tltc rcvierr,pl'oces}i.

Cotii¡:llirrt !¡ 5{}. 'l'h* (iuitl*ttce udr'iscrl cor¡rnissiotìr..r!'r'ilrì to lhr: inlirnluitirtn or,lilablu fiil'

thcnl trl cnnsirlcr. irnd g,uirlcrl ConrntissilittL't's ()¡l hörl' lo crlnlìlrur thcir rcvicrr t('l curtcrll

rcgulittir"rtts. "l'lrc (iuidurrcu tlid not i¡rdieatc lhnl (*nlr¡rissitulrrs shrrultl r:rulsirlcr r'.¡cr r)¡:

stltttieil.r, a.t a sco¡'inu ul'r;ulkilrg crt'ituriil. t'utn¡:hint ! 5{).

.1.

E 000632

Olt l\rrgtlst 5. ?0lt). lltû ('otttlllission rìrrl irr u¡rcrr sessiorr to consirlu'r.ixsrripg ¡tt.c-

itpprrtvals lì¡r lncdic¡rl r:attltaliis gl:{l\\'st iltrl proc*ssur lic:*lrsrs. C'urrrplairrt ,!r $?. I)uring

tltat lneelilìg, tll{¡ Clonllltissinlt r.ecúÍr'ç:rl rcc¿ltulttrlllehticlts lì.unl llic, (irúr,çsr l,."r,alunrirln

5t¡bcolnnlitlcc llltl lhu l)rtlçcssttr l::r'itlnttlin¡t ätrhconlllritte ri ¿lntl di;rcussecl th(isii

l'cuollltttc.lìtlatitlrts. 'l'hg Crllntltissirln lltcrl totcd olr thr Cjolnnrissicu's r;ulking ol't¡c t*¡t

20 applicanls ltl¡" ¿l ttlrldicitl tilnntthis gro\\,cr licer¡sc arrd vot*d [n issrrc l]rç-itpprï\¡¿lls til

th* tr:p l5 a¡:plicnrrls. sulrieut lu satislìictcr-v ¡j\¡¡11i¡'¡¡ìliün$ nl'good nlur"a[ ûlrflrar:trrr"ilrrcl

ccrn¡:linnce u-illt t*x.oblig:rtions. ('nrnplirint ri 52"

AMM'.ç A¡rplicnfion

AMlvl is a lvl*q'l¿¡nd lilnitctl liahilit¡'conrl)¡ul)" ruith it..; ¡rrinci¡rnl nllicc ¿rt l4 St¡rtr¡

Circlc, Ânnapolis. M¿trll¡¡¡ttl ll4{ll. (ionrpluinr 11 l{. .{Mil,| applir:d lilr a rnctlical

tn¡rnabis gr{:rl'tl:'s licr:¡lse [rut *,¿*i t]()l ïnt't(xìg the lìl"lcr:lr cnnlp¡¡1i""g ¡lulcgtcrl ti-v tlrc

Clnnllrission lìrr thi.: lÌrst pr*-lr¡lprorruls. Çotrr¡:rhrilrt !: 5.

¡\MM süblnitte(l ¡ tittr*l). tpplicrrtinn filr n rlsclir:¿rl currlrnlris grurvcr licen**"

AMlt¡l's ap¡rlieatinrr inclurlctl pr*ol' ol' residene,r' lil' ll k:lst nine lt,lalvltnd rcsiclcrrls

r:c¡tresertlerï to hs ¡rÌrfi'rg AfvlM'x rr\\nrfr:$ nnd irn'eslurs. lrxhihit l. 'l'l¡c "4,¡r¡llícatio¡ \\/¿ts

clc¡r tlrnt thcr eltrcslio¡l ¡bottt M;tr'¡'litttrl rcsiclt:lc! rt'nt¡ltl he grlrlcrl ort ¿l ]*rrs ol no h¿rsis.

th¡tt is to sil)'tltat ¡n a¡rplictutt eitltr"rt'itluludctl ¿t iVlitn'littttl rcsirh-.nt" artrl thulchl,scored i.r

")'cs'" or *litl not i!1üludt a fular¡'lirrttl resident at¡tl rr'its lllr-rlchr scrrrctl it ""rtn."' ¡\Tr4N4 rr,ns

¡tttt mltkccl *,ithin lhc {lrnlltilsirxt's lr}p J(} ir¡r¡tlicitnls lìrr l nl*licll cunlllhis glu*,Êr

liucnsc:, l;xltihit l.

E 000633

MEMORANDUM OF LA\MEXCLUDED PURSUAI{T TOMARYLAI\D RULE 8-50 1 (c)

E 000634


E 000634

¡lublic ilìt$rcst is sttrtrtgl¡'' ilt lilvor rrl" ¡rnrvielirlg rhosc patiurrts u"ith s¿rlL, ¿rccsss ro this

nleili*rl treiutncnt as qtrickly as ¡rossihlu

Not onl¡r is tlrçr.r: utì ovcl-n,llclrrring ¡luhliu irrtr-rresl irr servingLhe ¡leeds nf.¡lilticlrrs.

htrl that itticrr¡st is crltllpt¡tlll¡h:cl tt'lterc. ¡rs heru thu irç¡ril¿rhility, 61"¡t li¡nc{,iorr¡l lncrlic¿rl

cnnnnlris ll¡:ogri¡tìl rvill be ll vttltu.thle trxil i¡l :iternutirrg th* otr:rusc antl n¡gse ol 6¡:i6ids.

Mtrrylilrttlpafielrls facing cltrottic paìn nttl sëi?-urlo rlisorrtcl,s n¡.c, clesp{,:prtcl¡r scçki¡g rlu¡*

opitlid allerltittiYcs to thci.l'cttrr*rìl trs¿rtntents. lixhibir l. 'l'lre Stntc is currerrlly using

e\¿sr)' atai'hrblc rt'iinul'cc to nnvigatu l ¡ruhlic l¡r:¿rlth crísis cteated hy lhc orncrusr: ¿rncl

abu*s of'trpitricls. Nott-o¡liriid nltcnruiires tu opioitl pitin arrrl scizurc rrtcdicatitn$ ¿r¡.e ¡t

clitic¿rl çotìlpünctlt ol'tltr: S{ntc's cl'lìlfls to lrdclrcss rltis crisis" lrol. tlrese rsilsons to$.

AMM's lnotitx sliould bc tlcniutl"

cONcLtJstON

Iror thc rcrìsotìs stilte(I. tltc Cottrt sltorrltl rlc¡r.r ¡\lVflVl's rnotiolt lilr n tcrn¡rorar¡'

re$trïinirlg ordcr ûtxl tlreir rr:t¡ui:st lirr ¡t ¡rrelirninnr¡' irriurrctitrn.

lles¡rcct lirl l¡, subrrtilrcrl,

l3ruÀN li.l;rrcrsr'rcner{l ol' Nrl nr:yl tncl

¡\ssistilllt .¡\ tlcrncvs ( isller:il1l{){} W. l)rcstolt litrc¡:t. $lit$ 3û?llitl¡intorc. Mnr¡'ltrnd ? l:{l I

()f liec; (41(l) 7{i7- l8T7l;ts: {4 l{}) j3l-7¡il)ilIr¡-:l thtr. IreI sotI I ¡ll:nlu r). IInd.gt:r'

A ttor¡rc-r's lirr l.)cJl'llrln lt ts

ilÌ

\4a1' 17.2(ll'/

E 000635

CTIIìïI FICÄ"J' Ii Or S ßR\/I CII l.IHt,l,il}\'clil{ I'll;Y {lra{ txr this lTrt'dl¡,ot,fuln¡".3{}l?_ ir cr¡r.r, çl.the

J)eluntlfirrts" O¡:positiott to lr¡luti<lrt lirr'l'cnrpornr¡" l{esrr;iirring ürrlcr n,irt {).r1.,, 1ç gl11r\\,Causc Wlt¡' lt Pr*linriltary lrtiurtutitrtt fihculil Nrl l3e (ìrirntctll'¿¡s *h:ctr.orricillly r'¡il{,,t1and ¡rtailecl vi* lil'sl'cl¡s:i ¡uaíl pilstflËte ¡lre¡lrìrl ru:

llyr'on l-. Wnrnkc¡rïlytun [ì. W¡tr¡tkcrrWARN.KL'N" T,I,I? ltesen,oir Clir, li It)4Bnltirnore, MP 2120Sr¡43-921- l l0{)ll yran#Èrr,n r,n liç n la rv.co rrr

.lerlrn A. l)iru" Jr.

"hlhrr []ic¿r rrrel Asstrcri¿rtcs- l.l,C'14

St¿rtu CirclcArtnnpolis. Ml) ? l40l

.i p ic¿r¡,$j rlhn pieit,cn n t

I3r'ínn $i. l:lrnrv¡rI3rorvn åþ []nr:nut. l-l.C? St. ['aul $tr'cút" Suitc tlü{lß¿rltiniorc. Mitr¡'lnrrtl ? Il{}l11l¡¡'1 rrr ¡ t*¡1. lr.t r.rr-'.*ì ri t;ti I i'i l. { r,. I,

{' o u n.s e l .fis t' ¿1 I I ç r n * t i v a ¡l,l u { i c' i n e lt l tu'.t' I u t n I

Ilr:tthcr' lrl. Nelson

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E 000636

E 000637E 000637

,4 l.'l'l-llN,'\l'l V¡ i l\4 t:t )¡t'Í NlM¡lltYl.¡\Nl).,.J {'l

I'laiuti/1.

NAf.A"l .l Ë M. 1.. Â ¡' li,¡{ å ) I r h.f ;1 it T I ¡\i¡Í I }M t{D}C,41_ {'ÂNN,{li I S Ç[)M M I sS ] {- )N.çt ttl..

í)t!anr{untx.

]N ; ut1

illl{u{ it'r {]{}lrtr I

å'{ ¡f{

ItlU. I 1tul{ }lr"J: i;t'l Y

Ctt'ic lrio,, l+.C- | l¡-01)5tf{} i

å

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¡

,þ 4 i j,,

I

*

Åri. ¡¡1".1 V åT tlF ;!t'llt Y-.J() MA't'üt 3:;t

L l anr ü\.ür lll ;-e*rS {ìl'ägr. ¿r ¡'üs¡dsnt ul'Mar¡;lantl, rjr:nFelolìT tr) fllstil"v. an¿l ïtlrrc

fr$rsr¡lräl knölvl*dgc oi' tltc firr:tr; .tct lïrrth lrcrcin,

7" I illn thc l.'lirer-rtr¡r ol'.4eJlntnisrr{rion {rl'thç l\utaliu fi4. l,¿i})r¡id* Milrvland lr4edical

Ç¡rn nirn-is {urn ln i :¡¡Íi r;n.

3. 'l hc ("rlntr¡lissiqrn sr,rrr.glit trr ¡r*llierrr tlívq¡xi¡y ¡r¡l{¡':$" ap$li*ii*t* lilf rlfc¿i¡;¿ri

e¿innabis gro!\iúr licllnscs l:.r' irr*¡¡tll.r' pirblie i"riug tht npportunilv i(¡ irucrtnrc ticc¡ssti,

4, ,4hhtli:gh ¡\ltunlatiçe M*di¿:ine M*r1,li*rtl suhmin*rl a rirn*l¡, ;rpplie*tion fhr *

mrcliçul c¿rnnabi"l gr()\rqr llcc¡irc" rjli r-ìr¡¡rlrlisrii¡ll tlicl trt,r{ r¡lnk ô,h'ìM i¡n¡riilg tll* t*¡r

twi:ot). äFfJl ici*l t$ lìrr ntcd i e*i rillr¡rrtr i s gr{ rrr,:ç¡ I i ccnsrrs.

}" In.luly slf':.lll{i lhc i-'rx¡¡lil:s*ii¡ti r{üt¡tislc{l litxt irpnlic¡irìts t{u lrcriierii c¿ulns1:is

grotrer lir:enscs inlìlr¡¡'¡ 1i¡t ("r.r¡:r¡r¡is¡inrl ¿¡l lhc r:oulltç in rvhici¡ cacir a¡i¡rlie¿l¡lt intcntis¿i iir

r)prrü{c.

{¡. Ðn Jtrtrl l}" ll: lr;, ¡\!!'1l.i ruh:t¡ilitd lh{.'¿iiiirr:l:ç{l r:r:rrcrpti¡¡dr..r:rce íll¿lic;riilrr¡ il.r

intcl¡{ t{t lr¡calc in Islì:rr i"'r}irtr..

E 000638

7. On Jul.r äÕ" ?tlló, {.ìur:r¡rissi*lt *r¡:l'!'sctll:¡conìpl*tc lisr i:l'rhe **ogranhie lnciltian

rsspo¡'lscli liont gr$rvilr itppli{:itnl$ to ltl:$1. 'l"har lisl inclr¡deei ÅMM and irs inicntled

lscatie¡n in'l'aibot Ltru¡¡t) a¡¡d ix*rttach*cj ilür{iic, (ir¡¡¡xlissînl stiìl'f irsk{:d lt.l;51 tocrsatrr

a sprtadsltcct th¿ll.rr.ll {)u[ t]rc appliciurts i¿ic¡rlilicd try enclcd ir|:nliiie¡riir:n *umbcr in

ç¡rdcr nf"tlrcir rcconrrlrcl¡da.d rilr¡kint rvith rl: l*rr:nütl.trs t:¿rch ir¡:¡llie *rri.s iûtr:ndüri

gr*graphic l¡rc¿ltion. "l'hat cnltrîl i¡ iiltacl¡crl hcrcto"

ti" ltl responxc. l{l:Sf prolidcd thc L'çrn¡ui5siL¡¡1 tr.ilh tirc ¿ttachr:rltioü.unrcnt an Ju}y

"2?.3lll{r.

ç. 'l'lte Ctlmrllìssit¡ll is nnrl'ï{l$istcriirg patiu:nl$ rvhn **c}e ìrçiìt*lrjnl rvith nri:clicill

ea¡rnithis. Ås ol"tndity's eltttc, sîx tllot¡srrlrrÌ, tive lrundred alld lîlly-¡rins {{r-559) propl*:

h*rie ¡¡pp¡¡*tl tn rcgister as n¡cdicul c¿rnn¿rhis pirtients. !u tlntÈ lrvli hu¡clred and tw*nt1,.

lr¡¡o {!?2} pcclpl* hute rcgislcrlrid til uct ils çarcgivt:r.T lr,u¡u{lienl eanrrubis palienl$. 'li}

ditlLr. t\\î ht¡ndrr:tl arrd sixty-ri,x Mirr¡,land dustttrs rtantl rcrtly l(] lrL.¿rI pilliuilt.y ln ttle

ntedicirI ca¡¡¡lirlris pr$granì.

Iti. 'l'l¡r¡ (.or:lmi:isir¡t¡ routillclv rcccivts r;*ncsprrndenur: llll$l lvlirr¡,lunr! F¿tlicnts ïyh(:

iìrL'ûaÈcl lbr tlte pt'()griln itl hct:nrne op*ralirtn{l st¡ that putistìls tï¡rl ilüccs$ treilttrlsilt

rvith incdiealeann¡ttris. !husc Ðuti{}r1s rr:ck nllurnutivcs rr-i r.rpi*ìd F:rin msriic¿rtinn$ Í}¡ì{l

clI'ectiv,: ireålnlcll{s lìrr Titns* *'ilh sciz"rrrc disnrrlcrs. i'h,r* rcccreis ¡il¡rchc¿l ltrtctr: re lìr:ct

.ius1. stlnc nl'lhc c{ullnlcnts rc**fved lly tlrr Stalc irrln irnej on irch¿r}f"ul"¡riltienls sr:cklng

lllcti i c* I trciì I ¡lì(lt I rr,i [h niceJ ie iri ¡;¡r¡ r llilh ix.

E 000639

I HERË}iY ¡)åCLARä {}it jlrfirË{tut tjtì{t}¡.:R .{.}{[ pF:ivÅL ftlis ö$ r]ER,rur¿yTH¡tïI'Htr cûN'I'ËN'l'"î {}r "¡l{it rri¡üuüriiroir T*")Åli,.r" ¡,RË .rR*fi Å,î,,*)cäRIìgCT ¡iA- r¡tl u å:üN ¡o¡ r, r gigrlNrr N, K \ t) lVI, fiÐ{; }ì.

"/l*r, ,/ 4. *'.r,.. ;îil¡"" -r- '¡ '

il4ilrr -¡n l\4¡lhcr

E 000640

E 000641E 000641

:ít'À't.ti otr [.]AttYlÄNt)

DHh{H ¡¡Â'firt,f n ill, [,¡1}R¡\ l)lillt 11 IIY f ,,tN $ ll{ l1 l¡ I Cil, l- { lÅ i\ N¡t lt | $ {:{}M }f I S¡^ I ü N

ful*rylnnd lJcpartment r¡1.I lcltlLh ¡ln¡l Me nfnl l-ì¡,giuncrl"anyll¡1gr,tr,(;ilr'att¿þ),' . !*r.ir!y,,,¡u,r,t,q\1,1,, l;ttt\:t!'rftt¡' - lr¡ln ,\!il.,h.,!i. ¡ll'i.?'r¡lrr¿,¡,

.luh la.¡, 1¡¡¡,;

Dcar {.1 rorvrtr .{ ll¡l I i er nt-.{ r¡th ori ¿i:tl À gr}n t :

'l'ltc Marylanil Mcdic¿¡l Cr¡¡nalri¡ f'nn¡uission {(ionr¡nissi*rr) is ¡:lrrrrrirrg rt'r issrr* Strrgc I ¡rlu-appro\'âls ti¡r'nlerlic¡¡l enrrnilbil gr{)wcr liecnsss irl ¡llt cr¡¡ltinS rvecks. (l()ir,l:\ft lç,rr3.tl8.tl{r strtesthil! lh* Contntissiolt iìti{v l¡tkù i¡tt$ acç$unl ¡frçr gti:gritpltiu lnclrlicrl *l't}re grfirvirrpr opcrrrtir:n,Ila.sürl an thi.t rcgrifation, tht (hmltlixsi*n çcukl like trr irrvil* yrur t{} lTr('¡Tidc inltrnnatislritlcntifyitrg rhc sçHrrry rvithirt rvhiclr I'0u Fn)lx)lì{: t{} {)l)sr¡rlr y{rur gr()rvËr lirc.ilíry,, il'krrorvr.

'frhcuglr ClCIlt4¡\[t ltl.lt?.05.(D-1"] *uthurh"cs urr rpplicirni tn prrrvidc thc rei:¡ucsted aclilitiorralirtltrr¡ni¡lirlr hy thr:.close *f'bu;iilrssx $f'tht l4tl¡ busirlr:ss ilir-v rtliur the rer¡ur-:st h¿s lrsc¡l r*ceil'çr!lly thc lpplicnnl, tlrc Coutnlissì*n wItuld v$ry ntuch appr*e iatt rccuiving lllis illthntstiçn rrt sntun$ p0s$ibIü.

Should ¡,uu havt r¡ny t¡lrcslinns* ¡:lersc scnil your int¡uiry to¡l!$: h¿ucdiç;¡ I cl*H:*hiu¡t nü,j.çrr*t $tfllxn ¡l lrd,gur

'f'lrank yotr ycry much in y$rrr ar(xr$idijrilt¡un

$irturrull.

Lkrr'¡'l urrrl ñlctl ic¿rl t l *n nubi s C.. r¡nr nl issic¡r

1.1{l I l'l}lttr:!¡1ì .1r e¡lr¡t, I l.rli ¡ltr,rrr:, l},r'! lntr,l ;l i "l{.i tloll l;rr.c 1-tii;.,1,\lll"l)ll\'1ll ¡lu"Ì{r.l.l(tS{1. I l\rll.¡r.rl¡rirrlitl*: }crrirr l^lirì¡."i¡..'.ì{'}

11'rlr5ilc: **t.rljrtnlr.¡¡r{rlir.rl¡¡l¡ilji¡r¡r;¡i,'¡l¡:¡¡irr*¡r,:'¡¡rõT¡ .... ¡,rilûctvihlCOiÌûrilÌíiil74

E 000642

E 000643E 000643

Allernative Mer.llcine Maryland8899 Main Street. Suit$ f7

W.illiam:villc, llY l"rr??1

{?16¡ 580"720S

M¡ryland Medíeal Cannal¡is ConmiSrlon42û1 Êatlerson Ar¡ênusBaltimore, MO ?.1?0X

Ûli0rlr,fiÊÅf fEô lce rìil¡ bili q1)li':o rit¡,í,T rU¡¡ yûU¡{,filrv

5snì!L{Emâilcnd*u[r5

July 19, l0t6

ñ[: ßespohrr tü Rrqüest for Ois¿los*rn neg*rding:(¡rinty of GrowingCpÈrãtion

Dear Malyland MedÍcal Cann*bi¡ Comnlission,

\ffe are ln recel¡lt of your correspondence dntecl Jtrly 18, i¡.016. The geographie lseatlcn ôf our growfngoperation ís withln Talhot Countï.

file¡se {eel ff ee tt rorllãët rne il you have irny que rtirn*,

{-, t.. ,

6regqry'F" ÐanielJtuu;Preildent ancl Ëfo

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E 000645E 000645

6rower Ernail

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E 000646

Grower Au oiicant Email List r": i" m

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E 000650

omoooo

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E 000651E 000651

U¡ìl{rrè lilBrìtlfler County

Frederlck CËuntyüörchc$ter Çounty

tounty

Baltlm6ré.Cûenly

Cor¡.rìty

County

County

çountyüeor6ets Côunty

eÉ Cþunty

Counìy

County

CounlyCorroll (ot¡ntY

rFrcdorlck counlY

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Cpunty

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Montgomery County

Cóunty

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CounÐ

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.:. , .l j t(ent CounlY. ',.'. ."How¿t'd Coulltv" ;Curroll County

E 000652

E 000653

Carroll County

Montgbmerv County

Bammore rciiv “Caroline County 'Bnitimore City "Cecil County

‘

1: Allegheny gummy '7' .Charles County

E 000653

ù2î{fr1ó li'liuyliuxl'r¡xLì¿;l -(ie¡rtrt¡rl*¡is,¡(/'lìil-jll,rtrrrìt;l.rJ¡r¡.f1,lti: if:Tlrillr,,:¡rì; rl i1:\:it¿,t:.tl:i.rrfrrrìt,"aJ,

tomments for Regulations für June 14th, 2016 Meeting of the policy commíttee

dhmh [email protected]¡¡t. .it¡rt ?5. ?01ti;rl t; t1 Fi!{

I am wriling you to voice tÌly corleenls lor llre l\4¿t'ylarrci ürrrtplssron¡¡te ¡r¡erliçll rrr:rri¡ya¡;l ifir.,, lhât r.raT påsstld sÕtìtû linlåaga. I have been a chronic pain palienl lÕr o'¿er 15 years nov¡ and hår¡e been prescribed rneclici6es over the years that asvou may hno| cot¡to älong with ln;Jny dângers s¡rd si(,e eflects. llarrtfy a day goes liy lhat I rlon.l r€ãd nbout hnrv pecpletvho are in my position havè br:err forcsd lo lilrn to he¡oin be¡¿use oí lhe clarrr¡rdo$¡n on prcsrytl¡lron painkillers. t rvitt iivtryou my story rT lriclr rnany other pain palents have eclroetj lo rrrs ¡s *ell. lvly lonçrlirrre p(1tlionâl'physiciarr v¡as acompassionale doclct'who started Þrescnltinfl nrc painkilleru. Âs t¡nìe vvenl on rrry lclerancr:r l¡uilt aitl built to lhs t¡oinlwhere I was gelting lhe nla¡inlum antoulit that o{ruh! bc lug¡all¡.0rvcn l{} mç. l'h(} rdrçle ì¡rnc ll),s fla¡ì going an I ,,vas

¡,r

l¡roCuctive dti?Ên y¡ho rvas gainfully enrployed in tlrÈ securit¡r €lerJrçrr¡r:s i¡Ìr,rJst¡.y, I ¿esrç¡nnd a¡C sofd OUr gevemn¡cntsysterns thal rvere fighting lhe "v¡ar on dru¡¡si' as well as liìÊ ntiddle €åst rxlnflicls. lr,,ty tlurlÛr rras ¡:rcssurcil þy tlìü D[Àand insurance cdrnpanies lo do something ahoul nts, lì cåfne l{n ä ,to}t]l lhal he hiìij lÕ ftl(:{?ntfnnnrj n¡e to a ,'¡:a,n clin,c': fo,lear of distfplínary aclions. I wetìl lo llre parn clllric whr: trnnlcrlialrly {:r¡t my $(:r¡f}ls lo rlrg pornt th¡ìt. they ,lo tüÀ nr r:"n("1.

-

The pain got to {hê point where I coulrl no lolg¡er work. I had to 0o on {¡s¡i¡¡¡¡iy ,rt thn y,t,,n1¡ sç.¡,r ol S0 iir¡o fo spirie anr.lncrve dâûlage, I nov¡ live in conslant pain bt"'r^ruse, l!¡r:¡ç rs lrr: dr¡r;tclr <tt l)ít*t d;n¡ç tilitt wltl r-'vcr prr.:scrìbe n* tire irm(Ì'niof leçal drugs thal vlill ovetçonls riry paitr ilnd lolcrarìilc. Rcç.ular itÕctÒrs v¡on't lrres¡:rrllc irny lrlrcolrr:s ílì irll rlue tö tlìeelampdortn and there is a sore lack of pairt clinics. Iire ¡rain Cliniru ;rr* ¡rack*rl r.¡jtlr l;çol:tC iít¿¡t ärû ln !he exatl l¡ôsiltor!thðl I irûì in,

I am beggÍttg you to please expedil* lþ rnrplenrenliìliÕr: ûf the Þrtnrylancl üornpassiûilarc rrrctlirf¡l nrnriiuärra la.¡/ anr! cperrlhe tlispensaríes thãl wsle proorisetl, whal seerr!s lo rix] lr) }e irg¡es ìrt)o, {ìltort of lhat, [lÌrÍrtj h¡rs t)L1Bn t¿¡lk of fl fe{¡procillilgreernenl with Washington DC tll allolç il4aryland ü{i?ânt lr¡ ¡rhlain lh+ slr¡rlns ui nranluarra thÐt r,an hclp me alr,^l ilrr:rn,îny. n)âny olhcrs in sinilar situalÍons.

Horv cruel il rs tn pass ã lå\T to hi;l¡r hul, 1¡ive rru \.1¿ì! tÕ lúqir,ly oLiarn lllir rrr$r,t,(:t

Thartk you ver¡, much lor your tinrc.rAnno Àrundel County

E 000654

ALTERNATIVE MEDICINI]MARYLAND, LLC

Plaintffi


Defendants.

'¡ IN THE

* CIRCUI'| COURT

* FOR

N BALTIMORE CITY

¡N

,k

Case No.: 24-C-16-005801

*rßrk*.b**1.*

COMMISSION'S SUPPLEMENT TO COMMISSION1SOPPOSITION TO PLAINTIFF'S MOTION F'OR

EMERGENCY TEMPORARY RESTRAINING ORDER ANDREQUtrST FOR ORDER TO SHOW CAUSE VvHy

A PRELIMINARY INJUNCTION SHOULD NOT BE GRANTED

Defendants, the Natalie M. LaPrade Maryìand Meclical Cannabis Commission (the

"Cornmission"), the Department ol Health and Mental Hygiene ("DHMH"), and the

individually-named cormnissioners, through counsel, in light of newly-received evidence,

subrnits this supplement to its Opposition, to Plaintiff's Motion for Ernergency Ternporary

Restraining Order and Request fbr Order to Show Cause Why a Preliminary Injunction

Should Not be Granted, which was fìled on May 17.2017 (Docket No. 72ll).

.The plaintifls request 1'or injunctive relief is contrary to the public interest. AMM

seeks to halt a legislatively authorized medical program clesigned to serve Maryland

patients who have been unable to fìncl relief from their.medical conditions through the use

of pharrnaceutical medications. The State interest lies in irnpleurentirig a well-reguiated

rnedical cannatris plograln to provide patients safè access to treatrnetÌt.

On May 19,2017,Maryland patierits came f'orward to share testimony. Tire first is

the mother of a child lvith iritractable epilepsy rvhich cloctors have been unable to control

E 000655

vmckinley

Text Box

05/24/17

with phannaceutical rnedications. Exhibit l, Aflìciavit. The phannaceuticals that have

been ofïered not only fàiled to control the seizures but also brought unwanted side effects

that irnpaired her daughter's ability to groiï and thrive. Exhibit 1. This witness has

registered her daughter to be a Maryland medical canuabis patient and intends to treat her

daughter with cannabis oil as soon as it is legally available in the State. Exhibit 1.

The second, a patient, has been prescribed large quantities of opioids to treat chronic

pain condition from the time she was fifteen years old. Exhibit 2, Affidavit. She has

suffered through treatment rvith opioid pain rnedications and sufTered unwanted side-

effects. Exhibit 2. She woulcl like to avoiclthe risk of opioid addiction. Exhibit 2. She is

eager to pursue medical cannabis treatment to alleviate her chronic pain and has already

registered to be a Maryland medieal cannabis patient. Exhibit 2.

. The public interest lies in serving the neecls of patients - that is precisely why the

legislàture created the medical cannabis prograln. AMM's request to halt the prograrn is

against the public interest and should fail lbr that reasoir. For these reasons, and those set

out .in the Comrnission's Opposition to Plaintiff's Motion tbr Ernergency Ternporary

Restraining Order and Request for Order to Show Cause Why a Prelirninary Injunction

Should Not be Granted AMM's rnotion sliould be denied.

CONCLUSION

For all of the fbrgoing reasons, and the reasons stated in the Commission's

Opposition to Plaintilïs Motion I'or Emergency Temporary Restraining Order and Request

for Order to Show Cause Why a Prelirninary Injunction Shoulcl Not be Granted, AMM's

E 000656

request for a ternporary restraining order should be denied and no injunction should issue.

The public interest requires that this legislatively-rnandated prograrn to bring rnedical

treatment to Maryland patients must move forward and patients should must not be baned

from accessing necessary'medical treatment.


BnraN E. FnosuAttoiney General of Maryland

t Attorneys General300 V/. Preston Street, Suite 302Baltirnore, Malyland 21201Office: (410) 767-1877Fax: (410) 333-7894heather.nelson 1 @rnaryland.gov

May 24,2017Attorn eys tbr Defbndants

E 000657

Exhibit 1

E 000658

Exhibit 1

E 000658


Plaintffi

v

NATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSiON,et al''

Defen,ants.

* IN TFIE

+ CIRCUIT COURT

* FOR

{. BALTIMORË CITY

* Case No.: 24-C-16-005801

* ,l + tr + {. t

AFFI-DAVI'I OF JENNII,'AR PORCARI

l. I am over l8 years of age, a resident of Marylancl,.conrpetent to testify, and have

personal knowledge of the lhcts set forth herein

2. My nine-year'-old daughter suffers from intlactabìe epilepsy. She was first

diagnosed at the age of 4 in 201 I .

3. Since that time, doctors have tlied to control hef seizures r.vith pharmaceuticals,

without success, Dcrctors have prescribecl a half-clozen pharmaceuticals, inclucling

Depakote, Ethosuxirnde, Larnictal, Keppla, Topamax, and Zonegran used alone aud in

various cornbinations, and still have been unable to offer a pharmaceutical solution to

control my daughter's seizures.

4. Eaoh new attempt to control my dauglrter's seizutes with phalmaceuticals resulted

in fäilure, I know that this Iitany of fhilure is a familiar one to parents and families of

epileptic children. F'or thirty percent <lf epileptic chilclren the available pharrnaceutical

medicines do not corltroì seizul'es. We are the face of that 30 percent. Theì'e is no

pharmaceutical relief û¡r ot¡r daughter.

*+

E 000659

5. I ancl rny farnily are also all too faruiliar rvíth the sicJe effeots of the drugs used to

try to.control seizules. I saw the Phannaceutical Haze that dulled the senses and clotrds

the eyes of my daughter. I saw hsr experience the outbursts, the rages, the lack of

appetite, and tbe lack of growth tliat arè cornrnon side elÏects of the pharmaceutical

rneclications. At one point during l'rer pharmaceutioal treatment, rny daughter went l8

rnonths without growing an inch or gaining a pound as a result of her nredications,

6, In February ot'2016. in auticipation of the long delayed medical cannabis prograrn

in Maryland, we began teating hel rvith a legal hernp oil ptocluct'that provides some, but.

not all, of the medical benefits olrneclical canrrabis. ln April ot'2016 rve titrated our

clarrghter off the last of her prescdbecl nleclications in an effort to rninimize the side

efïects of those pharmaceuticals that didn't recluce her seizure activity.

1. Since that tirnc, her cognitive abilities have imþroved dramaticttlly. The haze is

gone and her personality has rsturnecl and blossomed, She has glown Lwo inches and

gainecl l l pouucls, That's the good rlews, The other siclc of that coin is that on her rvorst

days, she ìnay still experience up to two dozen absence seizures. We believe that she rvill

have rnore success ivith rnedical cannabis.

8. Since 2014,lve have bcen waiting patierfly f'or the rneclical cannabis program to

be fully implementecl in Maryland. We have watched as otlier states have passecl and

implernented a successful program. We have stucliecl tlie chemistry ancl treatlnents th¿tt

epilepfic children are using in legal states iike lllinois. Maine, and Colorado. We have

followed the work of tlie Comrnission ancl testifiecl in Baltirnole. We have struggled to

E 000660

understand the long delays and are saddened that other states have options that our state

still denies our child.

g. I came fonvarcl to offer testirnony because m¡, daughter's health will suffer if her

access to medical cannabis is delayed.

10. Every clay that my daughter is clenied access to rnedical cannabis treatrnent is a

day losi. I am not na'rïe enough to believe that there is a 100 percent chance of suc..r, in

treating my daughter with rnedical cannabis, but as a mother, I have seen the

pharmaceutical options lail nry chiid and I need to provide my child with every option to

control her seizures enough to allorv her to thrive,

11. Every day that my claughter continues to seize, she falls further behind in school.

If her access to rnedical cannabis is delayecl, her health will remain at ¡isk, The neecls of

our daughter, and thousands of other patients lilce her, ueecl to be considered first.

I HARABY DECLARE OR AFT'IRM UNDER THE PENALTIES OT' PERJURYTHAT THE CONTßNTS OF THE F'OREGOING AFFIDAVIT ARE TRUE ANDCORRECT BASED UPON MY PERSONAL KNOWI,EDÇE.

bDate nil'er fl

E 000661

Exhibit 2

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Exhibit 2

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,,\t.'l'Ìilì.N^'l'l VL; M llD I CI N [:MAIIYI,AND. I.I.C

Plaintill.

NÂ'f A I,I H IV{, I.,A I)Iì¡\ D}'i M,A II Y f.,,A.N.T)

MED}CA I., CA N NA ii I S COIViN4"I SSÌON.et al.,

DeJcuiunrs.

IN i'tili

c'lììcìrlI1' coritì'f

'i [.'Oll

'ì' lì,4,1.I'lMoRLi clTY

Casu N0.: 24-C- I 6-005t101

ri:

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,d FIi.I D,,{VI'I' OF JANNI FËR Bü,8Ð I Ti

L l am over I.9 ycars o1'agc- a resitlent of'klar¡,lrncl. cornpeteni.lÕ tcstify, ancl har;e

personal knou,ledge tlf'the lìrcts ser f'orth hcrein.

2, I anl a paticnt seeking pronrpt açcssri to nrqdìcuJ cun¡¡airis.

3. I lrar,e sull.crcrl l'roln;r nr.rnrlrct ol'chnlnic p¿rin condifions ¡rll ol'rn-v lif'e.

4. Il¡'the ti¡ne I r.r'¿ts l5 \,r:¿rm olcl. rrr¡'cloclols \çtìrd prfscribiLrg rnc lhr:ce clil]'$renr

painkilleLs thal I tvas instruetctl tö tÍrkc ftround lhr'cloclt.

5. 'l'hc painkillcrs did nol. elirnin¿rtc rnr pain. brrl lhev lcÍi rnc t'ccling irrrpairecl ancl

ilrtclxicafcd so tlì¿ìr I rvl,r-s clisrrrctccl liorn ihcr p¿in. [,'ír,ruother rvatchcclhclplcssl-v as I

becanre a zornbic.

ó. As nr1,Lol.er¿urcrr grc\\j! so clitl thù ¿nrou¡ìl oi'pairikiilrìrs rìec(lcd. I Lrcgttn sccking a

rurlrr-o1:ioid rtl tc l'¡luti r,e I () ¡ n !' ¡ra i tt r rt r"rdìclt ior r.

7. I [rarncrl th¿ri ¡ucrliclrl clnn¿bis coulcl bc lrs cf i'cr:tivc as Laltinq ¿r .1.50 rlilligr:anr

Vicoclin 75t) trut u'ithour tho corrstipittion. lir et'clatttagc. iurtl ¡'ì:sli ol'o¡rirttc ¿cltliction.

E 000663

;\lthouglr I could casil-t,obtain ¡rrescrí¡rtions iirr l¿r'gc: cliranlitics rll'opiatcs. I could lror

legally ¿rcccsrulredic¡rl cennebis.

8. Finall¡: Lltc tinle c¡rLnc r.ilren nrtxi(rrn nrrrclicin* stirric<l valicl¡.rling thtr rrse rlf''¡netlical

cannabis ¿ts ?t ltou-opioirl ¿lternatil'r' ttl the rnainstrenm o¡lioicl pharntaceutical pain

tnsìdic¿ìtions. liinrll¡'I stil'tltc lr4¿rrylarrd rnedicttl crnnalris pt'ogrí¡n hcgin to tal(il shape.

9, On,,\pril t0.2017. I lbLurcia ni!'ol-ltu¡¡,.r.'l'hc Vtlr'¡,land i\,lctlícîl Cannabis

pl:ograut Pati¿rllt ltegistr¡'o¡rerrccl artrl alklll,r'tl ¡rnticnts liltcr nlcr to rceistcr rvirh thrr State

and rhcrcb,v t¿r.ke the lìrst ste¡: tou'ard bcr:t¡ntiut e lcgal r¡cdical canrrabis ¡latient ín the

State ol'Mar¡'lalr<1.

I0. I have registtrcrcl as a rncclical can¡rubis ¡rtrtient in thc Stat., o['ivlarylarrd. lanl

eagi.rly arviriting salc und lcgal acc*ss til nlcdic¿rl cannnbis {.rcltnrcr1t.

ll. I lva¡rt to auccss ¡ncdical carurnbis lr'ü¿ìtrilcrìt that rvill allcvir¡ts rl¡'pain enot¡sh tbl'

nre to lìnrction r.vif.lroul. r'el;-irr¡r i:n olriatcs {ltc rest ol'tn¡'iil'e.

-2. llcnorv trf'patients u.ho h¿ìt,c clicrtl. rnOvcrl ()rrl oi'st¿ttrr tö acces..i trealrner¡L and

continuecl to sufl'or filr lncli ol'¿:tcccss 1p lrigirl nrcijicrirl cannnbis hcl'e in fular'¡,land,

'l3. My cloctors hlrr,'c rcconrllenclccl that I hnvc a thilcl crrrvical s¡rirtal lirsiorr surger¡,. I

anl c.urrrntl¡'delbr:r:ing this proectlurc. I ;rrn irr scvclc pairi trrcnl.r:-lìrur hottm A dar,.

14. As s<¡t¡lr as I ¡r¡ll able to ¿rccrrss logal ntcclical eann¿his itt j\4¿r'r'l¿ntl, f intcncl to

incorporatc ¿r fì¡ll c.rtract eannabis oil iut,r ntr. lncclic¿tl tlcatlncrtt so ll¡rl I can lirlly'

Ir¡nctir¡n irt nr¡: daìl-r'liíc antl lct tit'i'clisabititr'.

15. Arlr,clcl.n 1o lhis prögfi.u'rì rvill tlcll¡,nrv irccoss to it lcgal itìtct'nativc ur opioid

meciic¿ition.s. anc[ ill ttu'n. u'illrlclai'thc roliel'l itrtri ¡:aticrits like rì1c call rçrccivc l¡oni this

E 000664

Irrerlir_rnl rrefìtl1ìct:tt. {)ela1,ccl ilccess Lo ¡ledical cannabis rvill c¡rrl), ssrve tu u<lrnpouncl tltc:

lny sulf'rrìng of'p¿ttirnts wlìsrì I har'.r alrcrtcl¡'r,r'aiteti too lonq tilrsalc uuces.s to this

tt'crìhìlent.

I TIIRIIBY DECìLARE OIT AFFIR¡VI UNDI,R THII PRNAIJTIIS OF PERJURYTI{AT TTIE CONTENTS (JF TI{E FORECOING AI'-FIDAVI] ARE TRI}E, ANDCORRECT BASED UPON MY I'EIìSONAI., KNÛWI-,IDCIi.

t\-

ã -cï.\.. \+ (ì ,j

Date

E 000665

CERTIFICATE OF SERVTCE

I HEREBY CERTIFY that on this 24tlì day of May , 2017 , .a copy of the

Defendants' Supplernent to its Opposition to Plaintiff s Motion for Ernergency

Terr-rporary Restraining Order and Request for Order to Show Cause Why a Preliminary

Injunction Should Not be Granted was electronically rnailed and mailed via first-class

rnail postage prepaid to:

Byron L. WarnkenByron B. WarnkenWARNKEN,LLC2 Reservoir Cir. #104Baltimore, MD [email protected]

John A. Pica, Jr.

John Pica and Associates, LLC14 State CircleAnnapolis, MD [email protected]

Brian S. BrownBrown & Barron, LLC7 St. Paul Street, Suite 800B altimore, Maryland 2 1202[r b lo u,n lÐtrre$rþiure[ c o t n

C ouns el for Alte rnatíve MeclicÌne Maryland

B. Nelson

E 000666

v

ALTERNATIVB MEDICINE MARYLAND,LLC,

Plaintiff

NATALIE M, LAPRADE MARYLANDMEDICAL CANNABIS COMMIS SION,el al.,

Dcfendants

+ $

this order' $hi¡ll

v

* IN THE

* CIRCUIT COURT

*. FOR

T BALT]MORE CITY

+ Case No.: 24-C-16-005801

+

;È

*ri4r+*tt{'*'{t*

os,pER GRANjfINc PLAINIITIF' S EMERGENCY MOTION

¡t

FoR TEh4ORILRY.BPSTR.4.INT:Tç ORDER

Upon considerafion of Plaintiffs Emergency Motion for Temporary Restraining Order(#72), Defendmts,t response, affidavits filed, arguments presented at the hearing, and for the

reasons stated on the ¡êcord, it is this 25thday of Ma¡', 201.7, ^13110

p.m., by the Circuit Court forBaltimore City,

ORDERED that the Plairrtiffls Emergency Motion for Temporary Reshuining Order (#72)

be, and the same hereby is, GRANTED conditioned on posting of bond in the a¡nount of $ i00.00and pursuant to Matylarrd Rule $ 15-504 on the grounds that irreparable harm will result to Plaintiffin the fonn ofloss ofability, once all licenses a1e issued, to seek redless to resolve a potentiallyarbitrary and capricious or unconstitutional first time application of the applicable statutes to themedical cannabis industry, ifthis order is not issued; and it is further

ORDERED that Defendants, the Natalie M. LaPrade lvfaryland Medical Cannabis

Com¡nission, et al., including their pgents, servsnts and/or employees, are hereby RESTRAINEDand ENJOINED from authorizing, gtanting and/or issuing any final lice¡rses to ctrltivate and grow

medical cennabis in Maryland ptior to a full adversarial healing on the propriety of granting aPrclimiuary Inju:rcüon; and it is fi¡*her

ORDERDD that any persorl affected by this ordet may apply for a modification or

dissolution of the order on two days' notice to thc pnrlv who obtained tlre ordvr; and it is furttrer

ORDERED fhat a firll adversarial hearing on the propriety of granting a PreliminalyInjrurction will be held in front of this Court on Friday June 2, 20L7

^t 10:00arn; arrd it is firfher

' l:l¡Éln i44!,expire in ten (tO) days time, on Jule 4th,20|7,

: til'ffiHfrþi,JYr'irslg'"documen\¡¡J.*dge Bany G. 'Williuns

tr,\/dR tl )r,,y ß,r ,rvr/

. /i').: (': t,/iR(

for Baltimore City;îú$

E 000667

vmckinley

Text Box

05/25/17

Notice to the Clerk:Ple¡se Mcil Copies to All Psrlies

[.q[ Dt{tribuTiôù Þ,ls!

Couwe|for Alternqtive Medicine Maryland, LLC:

Byron L. WamkenByron B. TVarnkenWARNKEN, LLC2 Reseruoir Circle, Suite 104Baltimore, MD 21208Tel: (443) 921-1100Fax: (4a3) 921-ttL1,bVl'onf&'rvdr',nk¿ntnw,çom

John A. Pics, Jr.JO}TN PIC¿. AND ASSOCIATES, LLC14 State CirclsAnnapolis, MD 21401Tel: (4i0) 990-1250Fax: (410) 28a2s46inicn{&iohnpign,oorn

Brian S. BrolvnBrowu & Barron, LLC7 St. Paul Street, Srúte 800Baltímorc, Maryland 2 l20ZTel; (410) 541-A202Fax: (410) 332-4s09l:[email protected], co ¡U

Counselþr Defendants

Heather B. NelsonAssistant Attorney GeneralOfficc of the Attorney General300 West Preston Street, Suite 302Baltimore, Ivf aryland 2l2Q ITel: (410) 767-7546Fex: (410) 333-7894Hþatho¡';nel so¡lJ,J@in árlül and go I

E 000668

Countelfor Fortard Gro, LLC

Amold M, WcÍncrMichaelD, BemanRIFKIN V/EINER LTVINGSTON, LLC2002 Clipper Park Road, Suitc 108

Baltimore, MD 21211Tek 410-769-8080Fax: 410-769-8811

Alan M. RifkinRIFKIN WEINER LIVTNGSTON, LLC225 DukE of Olouce¡ter SûsetAnnapolis, Izfatyland 21 401

ffifm@nilltHriqi$l

E 000669

JANE DOE, et al.,

Appellantp/Cross-Appe lleest

ALTERNATIVE MEDICINEIVÍARYLAND LLC, et al,,

Appellees/Cross-Appellants.

* IN THE

COURT OF SP'ECIAL APPEALS

OF MARYLAND

September Term, 2017

No.40

(Cir, Ct. No. 24C16005801)

CHITF JUDGE'S SIGNATURE

,APPEARS 0N ORlûlNAt.0RDERr

t

*

*

t

v

ORDER

Upon consideration ofthe oMotion for Immcdiate Stay of Circuit Court Proceedings

Pending Further Review' filed by Natalie M. LaPrade Maryland Medical Cannabis

Commission, the Department of Health and Mental Hygiene, and the individually named

commissioners, Alternative Medicine Maryland, LLC's opposition thereto, and the

scheduled deposition ofHarry Robshaw III having been hcld and concluded, it is*ir lE(

day of zÙn, by the Court of Special APPeals,

ORDERED, that the motion be, and is hereby, denied as moot.

(-\ -t

***,¡*tl**t¡1.***

E 000670

vmckinley

Text Box

05/19/17

From: Alyson Parker-Kierzewski Imailto:Alyson.Kierzewski @ mdcourts,gov]

Sent: Thursday, MaY 25,20L7 6:08 PM

To: John Pica <[email protected]>; Brian Brown <bbrown@brownbarron'com>; Byron Warnken

<[email protected]>; Heather Nelson -DHMH- <[email protected]; Michael Berman

<mberman@rwllaw,com>; Alan M. Rifkin <[email protected]>; [email protected]

Subject: Order from May 25, 2017, TRO hearing

Counsel,

please be advised that, I have faxed out the TRO Order to all parties. The original has been filed with the Clerk's office

and you should receive a time-stamped copy from them,

Mr. Berman and Mr. Rifkin,lhave included you in this message becausethe Court, attheTRo hearing, invited counsel

for only ForwardGro, LLC, to briefly argue at the Preliminary lnjunction Hearing scheduled for June 2,2017 at 10:00am in

Courtroom 52gE, only on the issue of if the preliminary lnjunction is granted whether or not the license issued to

ForwardGro, LLC should be suspended. To that end, I have sent you a copy ofthe TRO order as well.

Best,

Alyson Parker Kierzewski

Law Clerk to the Honorable Barry G. Williams

Baltimore City Circuit Court

111 N. Calvert Street, 534E

(410) s4s-3516 (office)

a lvson. kierzewski [ô mdcou rts.eov

1

E 000671

vmckinley

Text Box

05/25/17

ALTERNATIVE MEDiCINE MARYLAND,LLC,

Plaintift

NATALIE h{. LAPRADE MARYLANDMEDICAL CANNABIS COMMISSION, et al.,

BALTTMTRË CTTY

Case No.¡ 24-C-16.005801

IN THg

CIRCUIT COIJRT

FORv.

Defendants,

LA{E rrLrNG ABSU,.ß:HRSUANITq. ORDETqDATB} 1vfAY,25. 2017

Clerk:

Fursuant to this Honorable Court's Order dated May 25, 2017, attached hereto is

evidence of a sureff bond in the amount of One Hundred Dollars (S100.00).

BrianBrown & Barron, LLC7 St. Paul Sheet, Suite 800Baltimore, fvfJ;.21202E-Mail : [email protected]{owqt a{ron. co{rnPhone: (410)547-02A2Facsimile: (4 I 0) 332-4509

E 000672

vmckinley

Text Box

05/26/17

CERTIFICATß OF SERVICE

I hereby certiff that, on this 26tl'day of May ,2AI7, a copy of the foregoing Notice to take

Deposition was served by first-class mail, poslage prepaid and emajled to:

Heather Nelson, EsquireOffice of the Attorney General300 W. Preston Street" Suite 302Baltimore, Maryland 21201heather. nelson I @maryland. gov

Arnolrt M. V/einerMichael D. BermanRIFKIN WETNER LIVTNGSTCIN, LLC2002 Clipper Park Road, Suite 108

Baltimore, MD 212i1Te l; 4 10-?69-8080Fax:410-769-8811aweine¡úÐrlvlls,sonlrnberæaü@¡wlls.coln

S. Brown

-?-

E 000673

v

STATE OF MARYLA}IDIN THE CIRCUIT COURT FOR BALTIMORE CITY

ALTERNATTVE MEDICINEMARYLAND, LLC

Plaintiff

lJN DERTAKING ON TEMPOÍT.ARYRESTRAININO ORDER

NATALIE M. LAPRADE, MARYI-AbIDIvÍEDICAL CAI{NABIS COMMISSION,et al.

Defendanrs

Case No.: 2+C-lÉ005801BOND POA#6159y2067

IüHEREAS, the Plaintiffbas applied for a TEMPORARY RESTRAINING ORDER in the

above entitled actiorl reshaining the Defendants, from doing cerlain thinæ as rnore firlly set forthin tlre oder about to be signed.

Now, trepfore United St¿tes Fire Insr¡rance Company, having an office and principal place ofbusiness in the Stato ofTexas, with certiñcate of authority in the State of Maryland, as Suety,does hereby pursuant to the stahÍ{s) in such case made and provided, r¡ndertalce that the

Plaintitrwill pay to ttre Defendants so enjoined/restrained, such damages and costs notexceeding

the sum of ONE HITNDRED DOLLARS ($100), as Defendants may sustain by reason of the

temporary restraining order, ifthe Court shall finally decide that the Plaintiffwas not entitled

ther€to; such darnagæ and @sts to be ascertained by a reference, or othe'lsrise as the Cowt may

direct.

This¿gdayof Ma]¡,2017

s14 I.JNITED co.

Maryland Insurance Lic. 149000

))))))))))))

Underwri tin g@S uretyOne.corn

E 000674

hb epacity ss Vlcs Preddenl

UN¡TED STÂ'I'E; FIRE INSURÀ¡{CECOMPANY aon¿r6JS992!6lPû 80¡1æ7. HorrstoD. Tss

7 r3Ð54.838. 801Þ388.19

gï.lh, sPEcIALPo\ryERoFArroRNEYt4 F/Lf

KnowÂll Men By Thosc PrcscnB;

Thst Uo¡Ed Stgtes Fia lnsurance Comlrunyr hcrcin¡ftcr æfir¡ql lo us ùc Compun¡ in pursuoncc olauthority gtantcd by ttcsotutlon adopted by the

8o¡¡i ofDlncors, docs hereby nomhärc,-oonsirutc ¡nd ¡ppolot iB truo

and lorvful agørl and Attomcyfn-Fact to makc. cxccuo, ¡cal ¡nd dcllrær, for ond on lts bcholfsad ß lu ast o¡rd dcc{ os sucty. bon& ond contncls

olsuætystriito bo given to oil obligees pm"¡d€d |trat no bond o¡ cont¡acl of ¡urctyship otoouled undúr thig outlpdly ¡hall e.rceed lhc sum oll

Oos Hundred Thous¡¡rd Doll¡n (.t100.000.00)

Cc¡tllicaæ of Re¡olullo¡:

This pontr ofatrome¡r ls granted and ls sig¡r€d snd scalcd by focslrnltc undcr and by thc luthorls of thc lollorriag B¡larw adoptcd þ thc Eoad ofDircåorofthc Compa¡¡y Uy ¡¡ uno¡ris¡ow rwittcn conær¡t datcd 0s oftte ltb day o[Deccmbcr2ü!3'

Exccpr os rhc ¡o¡¡d of Diacrors nuy urrhoriæ by rcsotution, tlr¡ Chsir¡¡¡o-of ths 8oard, P¡esi&nt' ¡ny Vice-Prcsidag ony AssissntVlcÊ.Prcsidcnlrhc Sccrcrary, or o¡y Assiron¡ Seouary *ratt traúc poncr on bchdf of the Corporubn: (s) ¡o ttscülc. ofll:t tlrc coçontc rcal munnlþ or- by

fts¡inite ro, ådooiv¡øæ, vcri$ aud dâlvcr rny oontrucls, obl¡galior¡c insrrumrnu ¡nd documenls rvù¡lsocrær in connecttb¡ wi¡h its bus hcss

¡".idútütilut l¡m¡dig rhß túngohg sny búô, gusrsnr€, ündcrin¡¡n$. rcco¡nlancc* porwn ofallomcy orævocottonrôfany gor,vcrofsuomeyStpu6ltonq potiães of insrance, úee¿s, tcoses, mongogcC rclcas¡t sotlsftcrlonl and sqncf agrccmc¡¡$ (b) lo sppolnt' ln s¡l{ng onc ormoro úLoris for uryõr a[ ofthc purposes mcnrioncd in ùc prcocdhg pragnpt (a]. includlng ufxing the sed of tha Corponrlon.

In lVimsss Whcr€ofthe Company hæ c¡r¡scd lts ofl¡clol scsl to bc l¡¡¡rcunto

Pltsidq¡t ¡nd ouesed by irr Ass¡ehnt Sccreb¡y lùis l9Úr day of Fcbnnry. 2016.

&*,8*,,,affue4 ond tftese Frcacnts lo bc sigËd by ic Assisottt Vicc

ßË¡sNl¡.ù¡Éltt!Ëdl

STATEOFTEXAS,s¡.:

COUNTY OF }TARRJS

Ð/ fu-Coútlfltdú, t¡sofl6f¡y Corùpo8çb¡ ¡É q{ ¡ale

l, thc undcnþd s¡r Ass¡srunt Ssciilt¡ry of United St¡tes Fhe l¡uur¡ncc Compon¡ DO HEREBY CERfiFY th¡t thc lbrcgolng and auo¡hcd Porver

oiÀuo*"y tJ*ins in ñ¡lt to¡cc snd hæ'not bean revokcd. and ñ¡rtlrcrmorc th¡t thc Rcsolut¡on ol¡hc Bo¡¡d of Dlrsclo¡s, set fbnh ln lhe sold Porwr

of A[omsy, ls norv ln fo¡rcc.

ndsesr¿d n ëdor ìg*!^zo?

¡t¡t lP

s. oårcl¡tEüÞ\ tr.,rr*¡c.3tcedrø¡h, rùÔrfrüloaftDùûtV ' Juiùot. ætt

U4708US (Rcv.8/12)

lrrF¡rsYoMdl

E 000675

L&.ú¡¡No:2120478

bqlal¡&dbehú¡labtbmebbEüry

Ff,ODUCER

rluDIP

,øh'ø

Fhr¡.lroyo¡¡'¡gs¡¡.c!¡û¡uùla ruqoo ¡¡llr¡Døosysg¡lcgrq æ¡ttpSocblSant!¡erNdøtn¡¡b¡s¡Ù¡ùg¡..rr¡ån¡¡6gúbro Êcù$Uæaæiú@aeo.ery# b fbb@prldaóoof¡r"tl-tTdla¡-rúbt*dùalbÉln¡f¡¡¡tm¡¡ rt¡UønrnnOryp¡¡6"n ôt6!úûSÊ

tlqÐEÉüq,'trIEE!¡lr!!b.srdcq, doæpvEfq¡!l Altl¡C¡Slôclt3oo¡q!Ù@¡ Sts!üÍ.lfl!¡!r¡¿lhlr¡tþ¡¡¡s¡o&f-íElold.BalDpthsferÍ!!¡! G8æSÉdhú¡reü[¡

So¡Ut6ùõyô¡¡ çldærorccæ¡oe¡¡d¡gtq¡!¿lt¡ûalúqq¡rñ¡ls¡lrdôrto.!t¡oü!BÍ@¡srtcË!ûüstm$rå{átgsb.tt.!Sûâ¡rõút¡mrBsr}iooúVûmßt¡¡dryr6frb!oúotûOl!!üe¡¡E¡oâdûb¡ü¡tq,árE¡loûcellocoh¡ 200 $ edH!.t'&úþzfq' EdËElql/o¡t2ü

dÉarìtúûútt¿¡lde¡mæAddh¡ùtl¡o!

Dcr¿&l¡¡c¡¡

8!rMbrtlsl¡¡r!¡g

¡0O So¡sf Pû¡¡ lüq, 8¡ûo 2?008!übsq Àf!¡tesdz¡zø'

&,ngrroNBINcP.O.EOXÍt?84RAI¡FTT'¡ICZIE¿?

E 000676

Sr EiuRtrv En ¡s

^MS{¡rrOtÍ{! PO¡ND&IRGEoUPOF @$lAlüÊl

{u¡üErD¡\DEr oNÍmn6¡.1r08 Swlllßosrsn¡sr,fiüRooRtAr¡rt

^¡t Pf(þ90l n^LactL NC?6Û¡

FEDERAT TREASURY LISTTNG (T.LISÐ OF QUALITIEÐ SURETIES

United State¡ Firo Insurânce Company (NAIC #2f 113)

BUSINESS ADDRESS: 305 Madison Avenue, Morristown, NJ 07962. PHONE: (973) 490-

6600. UNDERWRITTNC LIMITATION b/: $76,088,000. SURETY LICENSES c,f/: AL, AIÇAZ, AR, CA, CO, CT, DE, DC, FL, GA, HI,ID, L,IN, LA, KS, KY, LA, ME, MD, MA, MI,MN, MS, MO, MT, NE, NV, NI{, NJ, Nl\4 NY, NC, ND, OI{, OK, OR" PA, P& RI, SC, SD,

TN, TX, UT, VT, VA" VI, WÁ, WV, WI, WY. INCORPORATED IN: Delaware.

PLEASE DIRECT ACCOUNTTNG ENQIIIRIES TO:

SURETY ONE,INC. (HQ)P.O. Box 37284,Raleig[ NC27627

Underrv¡[email protected] m(800) 373¿804

PLSASE DIRDCT UNDERWRITING ENQUIRIES TO:

SURETY ONB,INC.404 Ave. de la Consitución, Suite 708, San Juan, PR 00901W

Tlr.lDltoNEfltnæßtø2a8æ)123-280t

prcslu¡u(etÐæ4-?G¡ll

llt¡BSíEr.vwvrsu¡¡rroNgcoÀÂ

Surety One, lnc., " " .nøtional saretyleøder!

E 000677

ALTERNATIVE MEDICINE MARYI-AND,LLC,

IN TI{E

crRcurr a¡fûirriPlaintil'f, ., l;. i''"r'i¡

FOR BALTIMOR.ECITY

Case No. 24:C- 16-005801

NATALIE M. I,APRADE MARYLANDMEDICAI. CANNABIS COMM'N., et al.o

Defentlants

MOTION TO SHORTEN TIME TO RESPOND TORENE\ryAL OF TIIE MOTION TO INTARYflNtrJ,

MOTION TO INTNRVNNE IN THIS ACI'ION, TO CONSOLIDATN,FOR STAY PANDING ÄPPEAL AND MOTION TO CONTINT.IE JUNE 2,2017

IïEARING:,AND OPTOSITION Tp MOTION FOR PRELIMINARY IN.IUTNÇTIpN

Jane Doe, .Iohn Doe, Curio Weliness, LLC, Doctor's Orders Maryland, LLC, Green Leaf

Medical, LLC, Ki¡d Therapeutics, USA, LLC, SunMed Growers , LLC, Maryland Wholesale

Medical Calurabis Tracle Associatiolì, and, Coalition fol Patient Meclicinal Access, LLC, by the

unclersigned counsei move, pursuânt to Marylancl Rule 1.ZAA@), to shorten the time fbr Plaintiff

to respond to Movants' Motion to Continue June 2, 2017 Hearing; Emergency Motion to

Dissolve or Modify TRO; Motion for Renewal of the Motion to Intervene; Reconsideration of

February 21,2017 Ruling to Intervene in this Action; To Consolidate; Fol Stay Pending Appeal;

ancl In Opposition to Motion for Preliminaly Injunction, antl stale as follows:

1. On May 25,2017, at 3:10 p.rn., this Courl. issued an Order Granting Plaintiff's

Emergency Motion for Temporary Restraining Order ('"TRO").

Z. Movants, many of whom hacl previously been denied leave to iutervene in this

rnntter, wet.g not given notice of PlailtifÏ's tnotion for TRO and, thcretbl'e, could not pârticipate

in the hearing on that rnotion.

.' r¡r¡ !. iÌr i'i , ;: l/' -'

E 000678

vmckinley

Text Box

05/30/17

3. The TRO was conclitionecl upon posting of a bond in the amount of only $100.00'

ancl that 6oncl was subsequently postecl. For reasons sel f'orth in the separately filed Motion to

Dissolve the TRO ancl the memoran<lum of points and authorities and additional affidavits ilt

support tlrereof, incorporatecl herein, fhe TRO should be rlissolved.

A. In the TRO, the Court further orclered that arry person affected by the TRO rnay

apply for a moclification or dissolution of the order on two days' notice to the paÍty who ob,tainecl

the TRO.

5. The Movants are persons affected by the TRo itr that they afe: growersl who have

been granted Stage I awards for licenses to grow medical cannabis who have the granting of

their licenses rhreatenecl by the TRO and subsequent potential preliminary injunction; and,

patients who have their receipt of nredicine threâtened to be h¿lted or delayed by the TRO and

any subs equent potential prelìminary irrj unction.

6. The Movants have given tirnely notice to the Plaintiff that they have applied for

dissolution and modification of the TRO.

7. Movants will be prejuclicect if Plaintiff does not respond to that motion at the

hearing. Specifically, and without limitation, Movants requested that AMM be tlirected to

procluce its financiai recorcls, upptication, anci rauking at that hearing. Plaintiff will not be

prejudiced if it is orclered to produce that infonrration'

8. In the TRO, the Court set a tull aclversari¿rl hearing on the propriety of granling a

prelirninary ¡rjunction for June 2, ?0I7. Movants have timely movecl for perrnission to

participate in lhat hearing (and to postporie it).

I Also inclrriled are certain elrtities also re¡lresentative clf growers as a cìaSs.

2

E 000679

g. If the Movants âre not allowecl to pâl'ticipate in the June 2, 2017 hearing, they will

be greatly prejudicecl in their ability to present theil interests and harms that are clirectly

threatened by the TRO and subsequent potential preliminary injunction.

10. Despite the fact rhat Movants have acted tirnelY, absent an order shortening the

time to respond to the rnotion, it rnay be asserted that Movants' requests to participate in the June

2,2077,hearing are not ripe. That would be prejuclicial to Movants.

11. Plaintiff has opposecl intervention ancl likely will continue to do so'

'IZ. Having requested emergency relief, Plaintiff will not bc prejudiced by an order

shortening the time to respond to the intervention request'

IVFIEREFORE, the Movarts respectfully request that this Cour:t shorten the tirne for

plaintiffs to respond to Movants' Motioir to Continue June 2,2017 Flearing, Motion to Dissolve

of Modify TRO, Motion to Intervene in this Action, To Consolidate, Fol Stay Fending Appeal

and Motion to Continue June 2, 2017 Hearing, and Opposition to Motion for Prelirninary

Injunction until the close of business on Jutre L,2017 .

J

E 000680

RES PECTFULLY S UB MITÏEÞ,

Arnold M. WeinerMichael D. BermanBarry L. GogelRIFKIN TVEINER LIVINGSTON LLC2002 Clipper Park Road, Suite 108

Baltimore, Maryland [email protected]@[email protected](410) 769-8080 Telephone(410) 769'881 1 Facsimile

Alan M. RifkinRIFKIN WEINER LIVINGSTON LLC225Duke of Gloucester SheetAnnapolis, Marylancl [email protected](410) 269 - 5066 Telephone

Øß)269-1235 Faosìmile

Counselfor Movants

4

E 000681

CERTIF'ICATE OIT SEBVICN

I HEREBY cefiify thar on this 30th clay of May 2017, a copy of the foregoing was $erved,

by first-class mail, postage prepaid, ancl via enail, on:

Heather B. NelsonRobert D. McCraY

Office of ths AttorneY General

Maryland Þepartment of Health & Mental Hygiene300 West Preston Stteet, Suite 302

Baltimore, \td¿1:Yland ?LZAII{eather.nelsorr I @ maryland. gov

Robert. mcctaY @ marYland. gov

AuorneYs for Deþndants

Byronl-,WamkenByron B. War¡ken

Warnken, LLC2 Reservoir Circle, Suite 104

Baltimore, Maryland 21208

John A. Pica, Jr.

Jottr.t PIcn AND AssocIA'tES, LLC14 State Circle

Arurapolis, MarYland 2140L

Brian S. BrownCfuistopher T. Casciano

Brown & Barron, LLC7 St. Paul Street, Suite 800


Attorneys for Plctintiff Alternutive Me¡licine Maryland, LLC

5

E 000682

Phillip M. AndrewsChristopher C. Jeffries

Sheila R. GibbsLouis P. Malick

Kr"amon & Graham, P.A.One South Stleet, Suite 2600Baltimore, Maryland 21202

[email protected]@[email protected]@kg-law.com

Anarneys for Plaintiff GTI Møry\ønd, LLC

Alfrecl F. BelcuoreLaw Offices of Alfred F. Belcuorc

888 17tl'Sfteet, N-W, Suite 904Washington, DC 20006

Alfi'ed.belcuore @ belcuorelaw. com

Edward WeidenfeldThe V/eidenfeld Law Firm, P.C

888 17th Sfieet, NV/, #1250V/ashington, DC 20006

edward @ weidenfeldlaw.com

Attorney for P laintiff M aryland Cultívatíon & P ro c e s sitt:g, LLC

Bruce L. MarcusSydney M. Patterson

6411 IvY Lane, Suite 116

Greenbelt, MarYland ?;0770

bmarcus @ lnarcusbonsib'comspatterson @ matcusb<lnsib. corn

Anameys, fo r P ropos e d Int ervenin g D eþndant, H olistic I ndusTries, LLC

6

E 000683

Paul D. Bekman300 V/ Pratt Street, #450

Baltimore, Maryland 2I20Ibekman @ bmalawfimr. conr

Robert B. Schulman

Schulman, Her:shfielcl & Gilden, P.A.

One East Platt Street, Suite 904

Baltimore, MarYland 2l2ïzrù[email protected]

Attorneys for Proposed IntervenQr, Temescal Wellness of Maryland, LLC

Ira KasdanAllan V/einerBezalel Ster¡:

Joseph D.lü/ilsonKelleyDrye & Wanen LLP

3050 K Street, NW, #400'Washillgton,,Dc 20007

IKasdan @ KelleyDrYe.comA.Weiner @ KelleyDrYe'cotnBStern @ KelleyDrYe'com

J Wilson @ KelleyDrye. com

Attorneys frsr Proposed InÍervenor; ForwardGro, LI.C

+'t**-,--Ð 6**Michael D. Berman

7

E 000684

ALTERNATIVE MEDICINE MARYLAND,LI,C,

CIRCUIT COURT

Plaintiff,FOR BALTIMORE CITY

Case No. 24-C-16-00580 I

NATALTE M. LAPRADE MARYLANDMEDICAL CANNABIS COMM,N,, CI UT,,

Defenclants

oRpsR GRANTING MOTION rO STTORTEN TIN!q

After review of all related motions, it is this

- day uf . "... , ,2017, by the

Circuit Coult tbr Baltimore City, ORDERED:

1. The Movants' Motion to Shorten to Respond to Motions for Renewal of

the Motion to Interveneo To Consolid¿te, For Stay Pending Appeal and Motion to

Continue June 2, 2017 Hearing, and Qpposition to Motiòn for Preliminary hrjunction, be

and hereby is GRANTED; and

Z. plaintiff shall respond to Movants' Motions for Renewal of the Motion to

Intervene, To Consolidate, For Stay Pencling Appeal and Motion to Continue June 2,

Z0I7 Heaúng, and Opposition to Motion for Preliminaty Injunction on or before June 1,

2017.

Juclge, Circuit Court for Ballimore City

IN TI{E

8

E 000685

ALTERNATIVE MEDICINE MARYLAND,LLc'

']i'li

Plaintiff,

NATALIE M, LAPRADE MARYLANDMEDICAL CANNABIS COMM'N.', et aL,

TN THEtlr l i !

OURTr I l:.

FOR iiAl--rrrviônu cn'Y

Case No. 24-C-16-005801

IMARING REQIIESTEN

v

Defendants.

MOTION TO CONTINI-IE JTJNE 2.2017 HEARING

Jane Doeo John Doe, Cutio'Wéllness, LLC, Doctor's Orders Maryland, LLC, Green Leaf

Medical, LLC, Kind Therapeutics, USA, LLC, SunMed Growers, LLC, Maryland TVholesale

Meclical Cannabis Trade Association, and'the Coalition for Fatient Medicinal Access, LLC

t (',Mou*tsl'), by the undersigtred counsel, Move,to Continue the June 2,2017 hearing, and state

as follbws:

1. On May 25,20L7 at 3:10 p.rn., this Court issued an Order Granting Plaintiffs

Emergency Motion foi Temporary Resüâini¡rg Order ("TRO") and setting a prelirninary

injunction hearing for June 2,2017' at l0 olcloclç a.m.

Z. At the hearing, Plaintiff will ask the Court to enter an injunction that will bring a

halt to a State-sponsored industry, for which many of the Movants (the "Grower Movants") have

investerl hundrecls of millions of dollars in reliance upon the issuance of licetlses that were

conditionally awar:cled to those Movants nearly a year ago. Sce Affidavits filecl herewith. Other

Movants (the "Patients") are threatened with delay of needecl cannabis therapy, which the

General Assembly has declared to be impot'trtnt ancl valuable to them. 1d,

3. For those reasons and for the reasons set forth in the other related motions,

rnemoranclurm, ancl affìclavits filecl contemporaneously herewith antl incorporatecl herein Movants

E 000686

vmckinley

Text Box

05/30/17

will be inevocably ancl substantially prejucliced if the hearing proceeds as scheduled and without

adecluate time for'Movants to plepare to present their significant interests in there being no

injunction.l

4, For: the reasons stated above ancl set forth in Movants' related filings; Movants

have clir.ect and vested interests in this proceecling that arc aclversely being impacted, and ale not

adequately representedby any other party.

j,. Movar:ts are preju{icecl in presenting and protecting those itüerest$. on such short

notice.

6. Rule 2-508 stâtesi "On mofion of any pafly or on its own initiative, the court may

co¡tinue a trial or other proceeding as justice may require"'

, 7, Justice requires a çontinuance. There are times where "[!]he need for soundness

in the result outweighs the need for speed in reaching it." Youngstown Sheet &. Tube Co. v.

SaWer,34A U.S. g37,938,72 S, Ct. 775 (1952) (concurring op.) (subsequent history ornitted).

B¡ Movants incorporate by leference their February 3:,2A!7 Supplement to Motion to

consolidate, That paper clemonstrates that counsel for Altemative lvledicing Marylantl, LLC

. (¡,AMM,') refusecl to provide eopios of discovely [o Movants' counsel. As noted therein at page

2: ..The proposed Intervenors unsuccessfully requested copies of AMM's discovery." Movants

noted that ,,AMM has rçfusecl to provide intervenors with copies of its discovery in this case."

Exhibit B to that filing is an email chain confirrning some of these facts'

g, Movants' counsel have since been exclucled fì'orn key depositions, such, as that of

Commissioner Robshaw, a copy of which is attached to AMM's rnotiott; Movants' counsel wete

not notified or pennitted to attend, not permitted to pose follow-üp qrestions, or ntake

I It is requested that the Court jrrclicially notice the three<lay Menlorial Day holiclay weekend.

2

E 000687

objections; clo not know if other depositions have been taken; and, do nol have transcripts of any

other deposition that mey have been taken in tliis case. Based on information and belief, anolher

depositio¡ of a Commission official is schedule<l for today, and Movants have no right to attend.

Under these circumstances, Movants have been unfairly deprived of the factual predicates of the

pending matter.

10. Additionally, Movants' counsel have not been servecl wittr all pleadings or

discovery ïesponses, if any, since the denial of intervention on February 23,2,A17, Dkt. 38/2.

The ¿ocket reflects that a motion for protective orde¡ was filed and decided without notice to the

Movants, Moreover', a motion to quash subpoena, emergency'motion, to Shorten time, nrotion to

compel with,exhibits, opposition with doeuments from Mary Jo Mather; objection to subpoe¡as

for deposition, üotices of service of discovery material, objection to subpoenas fol' deposition,

subpoenas, motion to stay circuit court proceedings pending further teview, response in

opposition io that motion, motion for protective order, ancl motion to strike testimony of expeft

winress, have been filed but not serr¡ed on Movants.

11. Those filings are relevant to the June 2,2017 hearing. For example, basecl on

info'nation a¡cl belief, the Motion to Shike Testimonl, of Expert Witness, Dkt. 7?10, is relevant

to the objection Movants have filecl to the Affidavit of Prof. Higginbotharn. That motion to

strike, howevef, has ¡lot been served on MOvants. Movants are prejudiced.

lZ. Movants' counsel have hacl insufficient time to aüange for witnesses attd

tlocumentary eviclencc on the short notice provi<led. AMM tìled this action on October 3l,2A16

an¿ has hacl ¡ronths to prepare. It waiteci approximately seven months to file this motion' There

is no emer.gency, ancl any allegecl injury suflfereil by AMM is both self-inflicted and speculative.

Movants i¡colporate by reference their other nlotions, memoranda, and attitlavits filecl helewith.

-1

E 000688

13. Movants have contemporaneously requested that AMM produce itrì RESI rarrking

and Application .for Grower License to rJetermine if AMM has standin g. See other memoranda

filed herewith. Movants are piejudiced without it.

14. Movants have requested that AMM bring financial statements and data necessary

to rleternrine a reasonable bond, if relief is granted, to the hearing. AMM's affidavit states that it

is capitalized at $10 million. ,S¿¿ other memoranda filecl herewith and affidavit of AMM'

Movants are prejudiced without those docutnents and data.

15. Under Rule 2-508(b), a matter generally cannot'be continued because discovery is

incomplete,."except upon goocl cause såo.wn." Movants have shown good causg. They have

i:

been bar:red frorn discovery.and AMM h¿s refused inforlnal coopemlion'

16. For r.easons, set forth in the contemporaneous other filings, AMM has failed to

demonslrate an emetgency, injurX, standing or a right to relieJ.

L.l , Therefore, AMM will not be prpjudiced if this co¡rtinuance is granted.

18. The June 2 ,2017 hearing should be postponed, copies of pleadings and discovery

provi.ded to Movants' counsel, a scheduling conference sêt in, with a dissussion of any needed

discovery, exchange of wìtness lists, setting a date to exchange hearing cxhibits, and, discussio:r

of stipulations of authenticity should be had before the hoaring.

MTIMQRAND-IIM OT POINTS AND aUTTI9RIIIES

Rule 2-311 (rnotions)

Rule 2-508 (continuance).

REOUEST TOR HEARING

Movants fequest a irearing on their motion for a cotitinuance. On the facts presented, this

is a flnctionally, if not in form, dispositiVe of claitns and delinses, and Movants have a right to a

4

E 000689

hearing. Rule 3-311(Ð.

Wherefore, the Mova¡ts request tllat this Coun postpone the June 2, ?0'I7 hearing, ancl

enter the proposed ordor attaehed hereto.

RES PECTzuLLY SU B MITTED,

M.Michael b. BermanBany L. GogelnIpúIÑ.SdINER LfVINGSTON LLC2002 Clipper Park Roacl, Suite 108

Baltimore, Maryland'2I21,IAIVeiner,@[email protected]@rwllaw.com(41 o) 769-'8080 Teleptrone(410) ?69-881 1 Facsimile

Alan M. RifkinRTFKIN' :WEINER LIVINGSTON LLC225 Duke of Gloucester Street

Annapolis, Maryland 21401ARifkin@r:wllaw.com(410) 269-5066 Telephone(4LO) 269 -123 5 Facsimile

Coansel.for Movants

5

E 000690

CERTLFICATE OF SERVICq

I HEREBY cerlify that on this 30th clay of May 2017, a copy of the foregoing was served,

by first.class mail, postage prepaid, and via email, on:

Fleather B. NelsonRobertD. McCr:aY

Office of the 'dttorneY General'Maryìand Deparl¡nent of Health & Mental Hygiene ,

300 WestPreston Street, Suite 302

Baltimore, MarYland 2L20LHeather.nelsonl @rnarYland. govRobefi .mecraY@marYland. gov

Att o r neys for D efendant s

Byron L.WarnkenByron B, Warnke¡r

Warnken, LLC2 Reservoir Circle, Suite 104

Baltimore, Maryland, 2L208

John.A. Pic¿, Jr.

Josrq Prcn¡.wp AssocllTrs, LLC14 State Circle

Annapolis, Maryland 2L4,0t

Brian S. BrownCluistopher î. CasciánoBrown & Barron, LLC

7 St. Paul Street, Suite 800


Attorneys for Plaintíff Altentative Medìcine Maryland, LLC

6

E 000691

Phillip M. AndrewsChlistoPher C. Jeffi'ies

Sheila R. GibbsLouis P. Malick

Kramon & Graham, P'4,One South Streef, Suite 2600Baltimore, Maryland 21202

[email protected]@kg-law,[email protected]òk@kg'law-com

Attorneys for P\aintiff GTI Maryland, LLC

Alfred.F, Belcuoretaw Orffices of Alfred F, Belcuore

888 l?ih Street, N\V, Suite 904'Washington, DC 20006

Alfred.belcuore @ belcuorelaw. com

Edward \ileidenfeldThe Weidenfeld Law Firm, P.C.

888 17tt'Sfieet, Nw, #1250Washington, DC 20006

edward @ weidenfeldlaw.com

Anomey for' Plaîntíff''Maryland Cultí¡tation' & P ro ces sing, LLC

Bruce L. MarcusSydney M. Patterson

6411 Ivy Lane, Suite 116

Greenbolt, Maryland 2077 0

bmarcus @ marrcusbonsib. comsPatterson @ marcusbons ib' corn

Attorneys for Proposed Inlervening Defendant, Holìstic Intlustries, LLC

7

E 000692

Paul D, Bekman300 W Pratt Street, #450

Baltimore, Maryland 21201bekrnan @ bmalawfirm.com

Robert B. Schulrnan

Sc&ulman, Hershfield & Gilden' P.A.One'East Pr:att Street, Suite 904

Baltimore, Maryland [email protected]

Attorne¡ts for PropOsed. Intervenor, Tenesca,l Weillness of Maryland, LLC

haKasdanAllan \ffeiner

Bezalel StemJoseph D. Wilson

Kelley Drye & Walren LLP3050 K Sireet; NW, #400'Washingtonr DC 20007

IKasd¡n.@ KelleyDrYe. com' [email protected]

BStern @ KelleyDrYe.comJV/ilson @ KelleyDrye.com

Attorneys for P rop o sed' I nterv enor, Forweird'Gro, LLC

+?*-*-*},&**-Michael D. Bennan

I

E 000693

ALTERNATIVE MEDICINE MARYLAND'LLC,

IN TI-IE

CIRCUIT COI"IRT

FOR BALTIMORE CITY

Case No. 24-C- 16-005801

Plaintilf:,

v.

NATALIE M. LAPRADE MARYLANDMEDICAL CANNABIS COMM'N., et al.,

Defendants.

It is this ** clay of May, t,8L7,b¡¡ the,Circuit Court f.or Baltimore City' ORDERED, thât:

1. The Motion to Continue June 2, 201? Hearing be, ancl hereby is, GRANTED;

2. Movants and all parties shall appear ¡-efore the Court on the -

pa¡r of

20T7, at _ o'clock *,üt., with calendar$,,for a schecluling conference;

3. A.ll pleadings filed, and all discovery taken or exchaqged, since denial of the

motion to intervens shall be served on Movantst counsel no later rhan the -

day of

,2A77, at _* otclock, *'tn,;

4. At the scheduling conference, parties shall be prepared to discuss any needed

cliscovery, exchange witness lists, set a date to exchange hearing exhibits, ancl, discuss

stipulations of authenticity; and,

5. A copy of this order sh¿ll be transmitted to ali parties and persons who have

appeared.

Barry O. WilliamsJudge, Circuit Court for Baltimore City

I

E 000694

in the court of appeals of maryland

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