On April 12, 2018 a
Motion-Secondary
was filed
involving a dispute between
and
for OTHER CIVIL
in the District Court of Franklin County.
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043
OE257 - K5
IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO.
Case No. 18CV003043
JUDGE: MICHAEL HOLBROOK
RENEA MURNAHAN-TURNER
Plaintiff.
VS.
STATE OF OHIO BOARD OF PHARMACY
Defendant.
RESPON N FOR JUDGMENT ON THE PLEADINGS
i
Since the first injunction was filed The Ohio Board of Pharmacy accepted applications for
dispensaries. They were accepted online | went online they gave me a password so that | could
fog in and fill out 5 appileations. | logged in multiple times got through so much of the application
process was never able to complete a single application. Their automated system kept kicking
me out several times for the whole period of time that they were accepting applications. First
they don't accept my application at the Ohio Department Commerce in person due to a COR
that was Not on either application lists. During another court hearing in Columbus Franklin
County Common Pleas Civil Court Case No 18CVH'1505 plaintiff CANNASCEND OHIO,LLC vs
JACQUELINE T WILLIAMS( OHIO DEPARTMENT OF COMMERCE} Justin Hunt Who was
Overseeing the Cultivation Application process and accepting them and scoring them. Justin
Hunt Stated on the witness stand that he was advised to destroy important documents that
could have helped some of the licenses that were scored low that could have helped them be of
a higher score therefore receiving a license instead they were denied. Justin Hunt is alse the
person who rejected my Cultivator Level 1 Application due to it not having a COR( This is a CD
@ recording of the paper form application) which wag not on either of the 2 checklist for the
application process. While there is proof that other applications were accepted and had required
documents missing. They also awarded out of state licenses Hegaily. In the most recent as of
last week July 12th the Ohio Department of Commerce allowed one of the cultivator licensees
that were denied to correct some of their paperwork which in turn allowed them to receive a
cultivator license. Do you to A119 appeal process. | had asked If | could bring a COR(my
application recorded on a CD, of the original hard paper copies that! handed in) back the next
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043
OE257 - Ké
business day and was refused and denied. Therefore since my application was not accepted |
am not eligible for A119 appeal process.
Then the Ohio Board of Pharmacy online application process continuously kicked me out never
allowing me to even put in a single application for any dispensaries. Both entities knew that |
was going to be filing for all 3 different licenses Cultivating, Processing and 5 Dispensers but
not be able to turn in a single one of them, (Coincidence obviously not!) ff they can 1. Remove
Women from House Bil 523 being considered Economically Disadvantaged
Minoritles(ILLEGALLY). 2. Discriminate against Economically Disadvantaged Minorities. 3. Not
only Accepting but Granting non Compliant due to{ 3796.11 and 3796.12 of the Ohio Revised
code as stated in House Bil 523) out of state Applicants . They Absolutely can make it so that !
nor Cannabis For Cures are NOT successful in putting in any Applications at all.
Plaintiff is Demanding 5 Dispensaries Licenses. As documented and all of Plaintiff Renea
Murnahan-Turner. testimonies at the state house My goals and business plans or completely
clear | was planning on filing for Cultivator, Processing and Dispensaries. That Plaintiff was
400% going for all Licenses and continuously done due diligence to tried to put in an online
application continuously being kicked off the system. Plaintiff also went on to board a
pharmacies page and sent notices from (my personal email)! was continuously having
problems getting my application through to be able to complete filling it out on asking if there
was a problem with their system. | never received a response. Though | did continus to try to
put in my application not only as Cannabis for Cures LLC also tried to do under Renea
Murnahar-Turner using the same Password that the Board of Pharmacy gave me. The reasons
for this Injunction filing is due to a Realistic $ 100 Million dollar business revenue loss due to not
being awarded § Dispensaries that Plaintiff CONTINUOUSLY tried to Apply for and kicked out
of the online system. That was pul in place by the State of Ohio Board of Pharmacy. Plaintiff ls
Demanding 5 Dispensaries Licenses. | also filled too allow myself and State of Ohio Board of
Pharmacy could sit down and Stop completely a corrupt system as currently in place and enjoin
it with the governing entities that all other 30 states have in place. Another reason | fled these
Injunction | was hoping Ohio Department of Commerce and the State of Ohio Board of
Pharmacy would want to make it right for ohioans. Both INJUNCTIONS that | filed against Ohio
Department of Commerce and State of Ohio Board of Pharmacy. Filed to PROTECT OHIOANS
from the many lawsuits that were coming, are here and still will be coming due to the blatant
CORRUPTION in our GOVERNING ENTITY'S when it came to the Marijuana Industry. We will
also have many lawsuits coming from people that have been pulled over since June a 2016 with
Marijuana or paraphernalia due to the fact that they were prosecuted as a schedule 1 drug that
according to John Kasich it's that made Marijuana a schedule 2 drug controlled substance for
the State of Ohio. When federally marijuana is a schedule 1 drug. John Kasich had Hegally
made Marijuana a schedule 2 drug for the State of Ohio to allow Pharmaceutical companies and
Pharmacies to own the licenses and participate in the marijuana industry otherwise ff it's a
schedule 1 drug Pharmaceutical companies and Pharmacies CAN NOT Participate in a
schedule 1 drug.
2. Several of the Dispensaries Licenses ilegally went to out of state applicants according to
3796.11 of the ohio revised code (Defendant Exhibit page 24 number (5) “Demonstrates that
the applicant is in compliance with the applicable tax laws of this state", The scoring system
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043
OE257 - K6é
(Exhibit K) in place is discriminatory towards Ohioans, the out of state Applicants received 84
points out of 200 for already being in the Medical Marijuana Industry. This making OHIO
applicants 84 out of 200 in the negative. The qualifying scorers are above 160 range. Scoring
process was scored by a convicted drug dealer. The reason for hiring a convicted drug felon to
do the scoring was to use him as the fall guy when this Corruption gets publicized. The Ohio
Department of Commerce and State of Ohio Board of Pharmacy. is required to do background
checks on everyone involved in the Marijuana industry. So either of the Ohio Departments did
Not due the required diligence and do a background check on the felon that was during the
scoring or they did do a background check and knew his background and put him in the position
for fall guy.
Renea Murmahan-Turner is. This is a perfect example of another injustice created and trying to
be enforced by Ohio Department of Commerce and State of Ohio Board of Pharmacy. | can't
represent my 100% owned of Economically Disadvantaged Minority Company and | can't
represent myself. There are NO Attorneys in the whole State of Ohio that are Certifiably
Educated in the Medical Marijuana industry ( Example tax attorneys, Workers comp attorneys
common personal injury attorneys and many more) that are specific to their industry that knows
everything about it. (Other states do have them) Obviously shows is true due to the 40 plus
attorneys at the hearings for the other injunctions lawsuits that were dismissed from other
Companies that were represented by Attorneys some Attorneys where the top 10 Attorneys in
Ohio but they were still unsuccessful and being able to get their injunctions they were
dismissed. They are all great Attorneys but lack the Marijuana industry Educational part that
other states have in place. Therefore | am doing this on my own. Based on exhibits and |
presented theirs were to show my role in the Medical Marijuana Industry. {am Certified to
Create, Build and run the Marijuana Industry from seed to sale in the Marijuana Industry. i also
am a business Entrepreneur | also completely build businesses from the ground up fo turn key
20 years experience. | current liquor license holding establishment that | have been in for over
20 years now. So the guidelines and rules. The entities thal are in place for the Medical
Marijuana and entities | have been going by those guidelines for 20 years. Due to this being a
new industry in Ohio there are no Attorneys Specifically educated in the marijuana industry.
Therefore leaving ohioans unprotected and very easy prey for the Corrupt Entities that are
currently paving their way over top of Ohioans.
3. The board did illegally accept Dispensaries Application's from Pharmacist. Federally itis a
schedule one drug. Federal Government will shut the dispensary is down revoke the licenses
revoked the license of the pharmacists and put the pharmacist in prison. Many more Lawsults
will come from that action, The State Board of Pharmacy is absolutely aware of this. The State
of Ohio Board of Pharmacy knowingly and willingly causing licensed Pharmacists
IRREPARABLE HARM.
The State of Ohio Board of Pharmacy was notified May 30th that a Hearing is Scheduled in the
Second Appellate District Court for July 24th . The case 17CV0612 Cannabis For Cures LLC
injunction against State of Ohio Board of Pharmacy that was dismissed solely due to Renea
Murnahan-Tumer not being an Attorney. Therefore at this time the Attorney for the Board put
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043
OE257 - K6é
together this answer of absolute denial of everything. Full well knowing that case is set for
Hearing. Also proves that they are willing to lle and misrepresent the many true fact of this
ease. This court does have jurisdiction.
in the process of all of the denials none of the references refer to 3796.1 tof the Ohio Revised
Cade. Stating Tax Compliance as a Ohio Resident. Reference Defendant's Exhibit of House
BIL 523. The board admitted to accepting non Tax Compliant Residents of Ohio. 3796.12
Criminal Background Checks This court doss have Jurisdiction. Exhibits S are pages 24 thru 27
stating every Applicant has to be an Ohio Resident for 5 years prior to putting in any
applications.
As written in H.B 523 Page 24 Section 3796.11 of the Ohio Revised Code Demonstrates that
the applicant is in compliance with the applicable tex laws of this state. Tax laws of this state
meaning has to be an Ohio current and consecutive tax paying residents 5 years prior to
submitting an application in the Medical Marijuana Industry.
Economically Disadvantaged Minority license applicants had to be Ohio tax paying Resident for
§ Current and Consecutive before being qualified to put in any Applications in the Medical
Marijuana industry. The Department of Commerce and the State Board of Pharmacy granted
licenses to out of state applicants and therefore making them void and and eligible to receive
thelr Ohio license in the Medical Marijuana industry. Summary for this section is non-compilant
out of state applications were acospted and Provisional Licenses were granted. To Pharmacist
that by FederalLaw pharmacies Cannot participate in a schedule 1 federally scheduled drug
therefore they will not only lose their dispensary licenses they will lose their pharmaceutical
licenses and prison time. Economically Disadvantaged Minority’s had to be 3796.11 Of the
Ohio revised code Compliant but the 3786.12 Of the Ohio revised code H.8.523 also states on
page 26 thru 27 section 2,) if A person subject to the criminal records check requirement does
not present PROOF OF HAVING BEEN A RESIDENT OF THIS STATE FOR THE 5 YEARS.
IMMEDIATELY PRIOR TO THE DATE THE GRIMINAL RECORD CHECKS IS REQUIRED.
Therefore all out of state Applicants are Void and have to be revoked due to EVERY
APPLICANT WERE REQUIRED to have BACKGROUND CHECKS. Exhibit S page 27 section
8 thru (2). Providing additional proof of 5 year Residency in this state of Ohio.
i was asked to a meeting with Senator Yuko in his office. The meeting just before H.B 523
was on the Senate side floor to be voted on. He had stated for me to ELIMINATE WOMEN as
Minority, Economically Disadvantaged from my Testimony due to the fact that we would LOSE 4
VOTES in favor of HB 523 therefore HB 523 WOULD NOT PASS . | had asked him whe the 4
was he replied you was unabie to give that information. In Exchange they would allow the 500°
rule from any school, church, playground and day care that | had been Referring to in ail of my
testimony. In the original H.B 523 it was 1000" | was asking for 500’ and gave explanations why
to revitalization. Exhibits 1 thru E all of my testimony and see what | was wanting . | was also
fighting for women, minority, economically disadvantaged to be able to participate the Medical
Marijuana industry. | told him that it was a federal guideline women being economically
disadvantaged minorities that | had no control over that and f would NOT if! did. There is an
overwhelming amount of evidence to prove ail of this including witnesses, My Exhibits with my
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043
OE257 - Ké
Testimony and H.B 523 Where it States that description of the qualified candidates for the
economically disadvantaged. Therefore Discriminating against and Removing Women from be
able to Qualify as Economically Disadvantaged Minority Applicants and being awarded a not
jess than 15% of all Medical Marijuana Licenses. The Ohio Department of Commerce and
State of Ohio Board of Pharmacy had removed women from H.B 523 when federally women are
considered in minority economically disadvantaged groups. This is one of the reasons my
applications beth cultivator 1 level was refused by the Ohio Department of Commerce and my §
dispensary licenses were never able fo complete a single one of them after being continuously
kicked out of the system through the Ohio board of pharmacy online process, Here is more of
this court's subject-matter. Page 5 second paragraph of the Defendant's MEMORANDUM IN
SUPPORT admitted the Board had problems with there online application process so they
extended the time for 48 hours. Other had succeeded that tried the first time.
{ continued fo try and complete 5 applications and was still unsuccessful in completing a single
application. in both Cannabis for Cures LLC and Plaintiffs name Renea Murnahan-Tumer. Also
due to not being able to complete a single Dispensary application | am not able to file Ina 119
Appeal process.
Defendant has caused and DEMONSTRATES IMMEDIATE AND IRREPARABLE DAMAGES to
Plaintiff . Therefore Plaintiff is ENTITLED to RELIEF under applicable statutory jaw, that this
injunction is necessary to prevent irreparable harm, and no adequate remedy al law exists. As
stated in Exhibit X page 4. $1.25 million plus 25,000 is a minimum that Plaintiff has lost
damages due to not being able to complete any Dispensary Application. { lost my team of
Investor's that were 100% capabie of financially supporting 5 dispensaries and all of the
financiai backing required.
Exhibit W Section 1. Refers to pharmacist not being able to participate in having licenses for
dispensaries, Page 4 and 5 refer to the selected members of the advisory commiltiee selected
by current Governor John Kasich and more details.
Exhibit X. introduction paragraph 2 Defendant states to avoid unnecessary duplication. There Is
absolutely no unnecessary duplication issue. Page 4 starting if second paragraph plaintiff has.
stated over and over again was unable to answer all of these questions that the defendant is
referring to that was a part of the application process that the plaintiff was never able to
complete therefore not able to answer.
in Defendant's ANSWER dated June 13 along with Exhibit House BH 523.
Reference from Answer Document number 2. “The Board admits that it accepted applications to
operate provisional dispensaries from entities that are owned outside of Ohio. The Board
expressly denies that this was unlawful.” Refer to Exhibit provided by the Defendant House Bil
§23, page 24 number (5) thru page 27 number (2). Defendant states on several numbered
answers refer “only to the Department of Commerce”. When in fact it states both the
Department of Commerce and State board of pharmacy.
Section Unnumbered Paragraphs.
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043
OE257 - K6é
ard Board denial. Reference Exhibits T, U and V. Professional and Negligent Tort Lawsuit
That was filed October 25th 2017. The same day | filed the Injunction against Ohio Department
of Commerce and State of Ohio Board of Pharmacy . Also Discrimination lawsuit against Ohio
Department of Commerce. in the court of Common Pleas Clark County, Ohio. Look what all
has happened since then. Those injunctions were filed to protect Ohioans from the lawsuits
that were coming and boy did they come and they still will be.
Fact: The State of Ohio Board Of Pharmacy is just as responsible as the pharmaceutical
companies for the drug addiction and overdose problem that Ohio is plagued with and has been
plagued with for years. Now Governor John Kasich gives them contral over the Medical
Marijuana Dispensaries which they can Revoke all of the dispensary licenses and shut down
any and all Dispensaries. Forcing Patients to go back to Pharmnaceutical drugs. There are ail
kinds of conflicts of interest. Refer to Exhibit W section 1.
Doctors that are License te do referrals for patients are also not allowed to own any Marijuana
licenses due to conflict of interest.
in summary Plaintiff want's 5 Dispensary Licenses. Plaintiff is not asking this court to eliminate
the Board of Pharmacy from the Dispensary process of the Medical Marijuana industry. | am
asking this court to rule in Plaintiff's favor to grant this Injunction. This will allow Plaintiffto
work with the state representative to request positive changes and presentation fo JACARR for
approval. This process has already been used in making changes in the House Bill 523. It
takes time to start and complete this process.
Obviously there is a blatant conspiracy that the plaintiff is a victim of. First nol even being able
{o put in an appileation for cultivation 1 license due to something that was not on either required
application list therefore not able to not only be considered but not able to file a 118 appeal
process. Then Board of Pharmacy has a glitch in there system not allowing me fo putin a single
application not only under cannabis for cures but not even under my own personal name.
Therefore causing me to lose my investors and millions of dollars. Also not being able to apply
for the 119 appeal process for those licenses either so they have completely and Hterally
eliminated me from being able to participate in any form of Licensing in the medical marijuana
industry. Knowing full weil at the beginning while writing the house bil what my full intentions
were and they completely was successful In eliminating me from being able to do a single thing
that | wanted fo do for Research and Development, keeping pricing low so patients can afford
their medications and Chio patients in the medical marijuana industry. Therefore | am not even
able to participate in any appeal process.
Exhibit ¥ Is my official notification of running for Governor of Ohia due to the fact that the
corruption in this state needs to stop and they have provoked me to take this to another evel.
Where | can make the difference and allow Ohioans to Rebuild Ohio.
4 i the Plaintiff should not be the one to have te file Injunctions and lawsuits to protect
Ohioans from the damages that are occurring. The Attorney General's office is supposed
te be fighting and protecting Ohioans. For the Ohio Attorney General's office to be
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043
OE257 - K6é
fighting for the State of Ohio Board of Pharmacy, Pharmaceutical companies and
Pharmacist against the Plaintiff who is trying to protect Ohioans and make things right.
The Attorneys General Michael Dewine should have advised John Kasich's that it was
iilegal to change marijuana from a federally schedule 1 drug to a schedule 2 drug for the
state of Ohio.
Federally marijuana is a schedule 1 drug therefore pharmaceutical companies
pharmacist and Board of Pharmacy can not participate in a Federally scheduled 4 drug
industry. There for another reason why this court should rule in Plaintlff's favor.
Plaintiff is Praying that this court to rule in favor for Plaintiff.
Marijuana will be on the ballot for Recreational use (they are currently getting signatures} It will
pass. individuals will be able to grow process in their own homes will not need Hcensing
through the state therefore will not be governed or taxed and not help rebulld, revitalize or
create jobs. | am not for Recreational.
af RENEA MURNAHAN-TURNER
Plaintiff Renea Murnahan-Turner
CEO of Cannabis For Cures, LLC , CEO of Medical Marijuana Rebuild Ohio, Ohio Advocate for
Medica! Marijuana Research and Development, CEO of Veterans Clinics ( To allow Cannabis to
Treat PTSD)
42 North Fountain Avenue
SPRINGFIELD, OHIO 45502
937-215-0651
Document Filed Date
July 30, 2018
Case Filing Date
April 12, 2018
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043 OE257 - K5 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO. Case No. 18CV003043 JUDGE: MICHAEL HOLBROOK RENEA MURNAHAN-TURNER Plaintiff. VS. STATE OF OHIO BOARD OF PHARMACY Defendant. RESPON N FOR JUDGMENT ON THE PLEADINGS i Since the first injunction was filed The Ohio Board of Pharmacy accepted applications for dispensaries. They were accepted online | went online they gave me a password so that | could fog in and fill out 5 appileations. | logged in multiple times got through so much of the application process was never able to complete a single application. Their automated system kept kicking me out several times for the whole period of time that they were accepting applications. First they don't accept my application at the Ohio Department Commerce in person due to a COR that was Not on either application lists. During another court hearing in Columbus Franklin County Common Pleas Civil Court Case No 18CVH'1505 plaintiff CANNASCEND OHIO,LLC vs JACQUELINE T WILLIAMS( OHIO DEPARTMENT OF COMMERCE} Justin Hunt Who was Overseeing the Cultivation Application process and accepting them and scoring them. Justin Hunt Stated on the witness stand that he was advised to destroy important documents that could have helped some of the licenses that were scored low that could have helped them be of a higher score therefore receiving a license instead they were denied. Justin Hunt is alse the person who rejected my Cultivator Level 1 Application due to it not having a COR( This is a CD @ recording of the paper form application) which wag not on either of the 2 checklist for the application process. While there is proof that other applications were accepted and had required documents missing. They also awarded out of state licenses Hegaily. In the most recent as of last week July 12th the Ohio Department of Commerce allowed one of the cultivator licensees that were denied to correct some of their paperwork which in turn allowed them to receive a cultivator license. Do you to A119 appeal process. | had asked If | could bring a COR(my application recorded on a CD, of the original hard paper copies that! handed in) back the next Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043 OE257 - Ké business day and was refused and denied. Therefore since my application was not accepted | am not eligible for A119 appeal process. Then the Ohio Board of Pharmacy online application process continuously kicked me out never allowing me to even put in a single application for any dispensaries. Both entities knew that | was going to be filing for all 3 different licenses Cultivating, Processing and 5 Dispensers but not be able to turn in a single one of them, (Coincidence obviously not!) ff they can 1. Remove Women from House Bil 523 being considered Economically Disadvantaged Minoritles(ILLEGALLY). 2. Discriminate against Economically Disadvantaged Minorities. 3. Not only Accepting but Granting non Compliant due to{ 3796.11 and 3796.12 of the Ohio Revised code as stated in House Bil 523) out of state Applicants . They Absolutely can make it so that ! nor Cannabis For Cures are NOT successful in putting in any Applications at all. Plaintiff is Demanding 5 Dispensaries Licenses. As documented and all of Plaintiff Renea Murnahan-Turner. testimonies at the state house My goals and business plans or completely clear | was planning on filing for Cultivator, Processing and Dispensaries. That Plaintiff was 400% going for all Licenses and continuously done due diligence to tried to put in an online application continuously being kicked off the system. Plaintiff also went on to board a pharmacies page and sent notices from (my personal email)! was continuously having problems getting my application through to be able to complete filling it out on asking if there was a problem with their system. | never received a response. Though | did continus to try to put in my application not only as Cannabis for Cures LLC also tried to do under Renea Murnahar-Turner using the same Password that the Board of Pharmacy gave me. The reasons for this Injunction filing is due to a Realistic $ 100 Million dollar business revenue loss due to not being awarded § Dispensaries that Plaintiff CONTINUOUSLY tried to Apply for and kicked out of the online system. That was pul in place by the State of Ohio Board of Pharmacy. Plaintiff ls Demanding 5 Dispensaries Licenses. | also filled too allow myself and State of Ohio Board of Pharmacy could sit down and Stop completely a corrupt system as currently in place and enjoin it with the governing entities that all other 30 states have in place. Another reason | fled these Injunction | was hoping Ohio Department of Commerce and the State of Ohio Board of Pharmacy would want to make it right for ohioans. Both INJUNCTIONS that | filed against Ohio Department of Commerce and State of Ohio Board of Pharmacy. Filed to PROTECT OHIOANS from the many lawsuits that were coming, are here and still will be coming due to the blatant CORRUPTION in our GOVERNING ENTITY'S when it came to the Marijuana Industry. We will also have many lawsuits coming from people that have been pulled over since June a 2016 with Marijuana or paraphernalia due to the fact that they were prosecuted as a schedule 1 drug that according to John Kasich it's that made Marijuana a schedule 2 drug controlled substance for the State of Ohio. When federally marijuana is a schedule 1 drug. John Kasich had Hegally made Marijuana a schedule 2 drug for the State of Ohio to allow Pharmaceutical companies and Pharmacies to own the licenses and participate in the marijuana industry otherwise ff it's a schedule 1 drug Pharmaceutical companies and Pharmacies CAN NOT Participate in a schedule 1 drug. 2. Several of the Dispensaries Licenses ilegally went to out of state applicants according to 3796.11 of the ohio revised code (Defendant Exhibit page 24 number (5) “Demonstrates that the applicant is in compliance with the applicable tax laws of this state", The scoring system Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043 OE257 - K6é (Exhibit K) in place is discriminatory towards Ohioans, the out of state Applicants received 84 points out of 200 for already being in the Medical Marijuana Industry. This making OHIO applicants 84 out of 200 in the negative. The qualifying scorers are above 160 range. Scoring process was scored by a convicted drug dealer. The reason for hiring a convicted drug felon to do the scoring was to use him as the fall guy when this Corruption gets publicized. The Ohio Department of Commerce and State of Ohio Board of Pharmacy. is required to do background checks on everyone involved in the Marijuana industry. So either of the Ohio Departments did Not due the required diligence and do a background check on the felon that was during the scoring or they did do a background check and knew his background and put him in the position for fall guy. Renea Murmahan-Turner is. This is a perfect example of another injustice created and trying to be enforced by Ohio Department of Commerce and State of Ohio Board of Pharmacy. | can't represent my 100% owned of Economically Disadvantaged Minority Company and | can't represent myself. There are NO Attorneys in the whole State of Ohio that are Certifiably Educated in the Medical Marijuana industry ( Example tax attorneys, Workers comp attorneys common personal injury attorneys and many more) that are specific to their industry that knows everything about it. (Other states do have them) Obviously shows is true due to the 40 plus attorneys at the hearings for the other injunctions lawsuits that were dismissed from other Companies that were represented by Attorneys some Attorneys where the top 10 Attorneys in Ohio but they were still unsuccessful and being able to get their injunctions they were dismissed. They are all great Attorneys but lack the Marijuana industry Educational part that other states have in place. Therefore | am doing this on my own. Based on exhibits and | presented theirs were to show my role in the Medical Marijuana Industry. {am Certified to Create, Build and run the Marijuana Industry from seed to sale in the Marijuana Industry. i also am a business Entrepreneur | also completely build businesses from the ground up fo turn key 20 years experience. | current liquor license holding establishment that | have been in for over 20 years now. So the guidelines and rules. The entities thal are in place for the Medical Marijuana and entities | have been going by those guidelines for 20 years. Due to this being a new industry in Ohio there are no Attorneys Specifically educated in the marijuana industry. Therefore leaving ohioans unprotected and very easy prey for the Corrupt Entities that are currently paving their way over top of Ohioans. 3. The board did illegally accept Dispensaries Application's from Pharmacist. Federally itis a schedule one drug. Federal Government will shut the dispensary is down revoke the licenses revoked the license of the pharmacists and put the pharmacist in prison. Many more Lawsults will come from that action, The State Board of Pharmacy is absolutely aware of this. The State of Ohio Board of Pharmacy knowingly and willingly causing licensed Pharmacists IRREPARABLE HARM. The State of Ohio Board of Pharmacy was notified May 30th that a Hearing is Scheduled in the Second Appellate District Court for July 24th . The case 17CV0612 Cannabis For Cures LLC injunction against State of Ohio Board of Pharmacy that was dismissed solely due to Renea Murnahan-Tumer not being an Attorney. Therefore at this time the Attorney for the Board put Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043 OE257 - K6é together this answer of absolute denial of everything. Full well knowing that case is set for Hearing. Also proves that they are willing to lle and misrepresent the many true fact of this ease. This court does have jurisdiction. in the process of all of the denials none of the references refer to 3796.1 tof the Ohio Revised Cade. Stating Tax Compliance as a Ohio Resident. Reference Defendant's Exhibit of House BIL 523. The board admitted to accepting non Tax Compliant Residents of Ohio. 3796.12 Criminal Background Checks This court doss have Jurisdiction. Exhibits S are pages 24 thru 27 stating every Applicant has to be an Ohio Resident for 5 years prior to putting in any applications. As written in H.B 523 Page 24 Section 3796.11 of the Ohio Revised Code Demonstrates that the applicant is in compliance with the applicable tex laws of this state. Tax laws of this state meaning has to be an Ohio current and consecutive tax paying residents 5 years prior to submitting an application in the Medical Marijuana Industry. Economically Disadvantaged Minority license applicants had to be Ohio tax paying Resident for § Current and Consecutive before being qualified to put in any Applications in the Medical Marijuana industry. The Department of Commerce and the State Board of Pharmacy granted licenses to out of state applicants and therefore making them void and and eligible to receive thelr Ohio license in the Medical Marijuana industry. Summary for this section is non-compilant out of state applications were acospted and Provisional Licenses were granted. To Pharmacist that by FederalLaw pharmacies Cannot participate in a schedule 1 federally scheduled drug therefore they will not only lose their dispensary licenses they will lose their pharmaceutical licenses and prison time. Economically Disadvantaged Minority’s had to be 3796.11 Of the Ohio revised code Compliant but the 3786.12 Of the Ohio revised code H.8.523 also states on page 26 thru 27 section 2,) if A person subject to the criminal records check requirement does not present PROOF OF HAVING BEEN A RESIDENT OF THIS STATE FOR THE 5 YEARS. IMMEDIATELY PRIOR TO THE DATE THE GRIMINAL RECORD CHECKS IS REQUIRED. Therefore all out of state Applicants are Void and have to be revoked due to EVERY APPLICANT WERE REQUIRED to have BACKGROUND CHECKS. Exhibit S page 27 section 8 thru (2). Providing additional proof of 5 year Residency in this state of Ohio. i was asked to a meeting with Senator Yuko in his office. The meeting just before H.B 523 was on the Senate side floor to be voted on. He had stated for me to ELIMINATE WOMEN as Minority, Economically Disadvantaged from my Testimony due to the fact that we would LOSE 4 VOTES in favor of HB 523 therefore HB 523 WOULD NOT PASS . | had asked him whe the 4 was he replied you was unabie to give that information. In Exchange they would allow the 500° rule from any school, church, playground and day care that | had been Referring to in ail of my testimony. In the original H.B 523 it was 1000" | was asking for 500’ and gave explanations why to revitalization. Exhibits 1 thru E all of my testimony and see what | was wanting . | was also fighting for women, minority, economically disadvantaged to be able to participate the Medical Marijuana industry. | told him that it was a federal guideline women being economically disadvantaged minorities that | had no control over that and f would NOT if! did. There is an overwhelming amount of evidence to prove ail of this including witnesses, My Exhibits with my Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043 OE257 - Ké Testimony and H.B 523 Where it States that description of the qualified candidates for the economically disadvantaged. Therefore Discriminating against and Removing Women from be able to Qualify as Economically Disadvantaged Minority Applicants and being awarded a not jess than 15% of all Medical Marijuana Licenses. The Ohio Department of Commerce and State of Ohio Board of Pharmacy had removed women from H.B 523 when federally women are considered in minority economically disadvantaged groups. This is one of the reasons my applications beth cultivator 1 level was refused by the Ohio Department of Commerce and my § dispensary licenses were never able fo complete a single one of them after being continuously kicked out of the system through the Ohio board of pharmacy online process, Here is more of this court's subject-matter. Page 5 second paragraph of the Defendant's MEMORANDUM IN SUPPORT admitted the Board had problems with there online application process so they extended the time for 48 hours. Other had succeeded that tried the first time. { continued fo try and complete 5 applications and was still unsuccessful in completing a single application. in both Cannabis for Cures LLC and Plaintiffs name Renea Murnahan-Tumer. Also due to not being able to complete a single Dispensary application | am not able to file Ina 119 Appeal process. Defendant has caused and DEMONSTRATES IMMEDIATE AND IRREPARABLE DAMAGES to Plaintiff . Therefore Plaintiff is ENTITLED to RELIEF under applicable statutory jaw, that this injunction is necessary to prevent irreparable harm, and no adequate remedy al law exists. As stated in Exhibit X page 4. $1.25 million plus 25,000 is a minimum that Plaintiff has lost damages due to not being able to complete any Dispensary Application. { lost my team of Investor's that were 100% capabie of financially supporting 5 dispensaries and all of the financiai backing required. Exhibit W Section 1. Refers to pharmacist not being able to participate in having licenses for dispensaries, Page 4 and 5 refer to the selected members of the advisory commiltiee selected by current Governor John Kasich and more details. Exhibit X. introduction paragraph 2 Defendant states to avoid unnecessary duplication. There Is absolutely no unnecessary duplication issue. Page 4 starting if second paragraph plaintiff has. stated over and over again was unable to answer all of these questions that the defendant is referring to that was a part of the application process that the plaintiff was never able to complete therefore not able to answer. in Defendant's ANSWER dated June 13 along with Exhibit House BH 523. Reference from Answer Document number 2. “The Board admits that it accepted applications to operate provisional dispensaries from entities that are owned outside of Ohio. The Board expressly denies that this was unlawful.” Refer to Exhibit provided by the Defendant House Bil §23, page 24 number (5) thru page 27 number (2). Defendant states on several numbered answers refer “only to the Department of Commerce”. When in fact it states both the Department of Commerce and State board of pharmacy. Section Unnumbered Paragraphs. Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043 OE257 - K6é ard Board denial. Reference Exhibits T, U and V. Professional and Negligent Tort Lawsuit That was filed October 25th 2017. The same day | filed the Injunction against Ohio Department of Commerce and State of Ohio Board of Pharmacy . Also Discrimination lawsuit against Ohio Department of Commerce. in the court of Common Pleas Clark County, Ohio. Look what all has happened since then. Those injunctions were filed to protect Ohioans from the lawsuits that were coming and boy did they come and they still will be. Fact: The State of Ohio Board Of Pharmacy is just as responsible as the pharmaceutical companies for the drug addiction and overdose problem that Ohio is plagued with and has been plagued with for years. Now Governor John Kasich gives them contral over the Medical Marijuana Dispensaries which they can Revoke all of the dispensary licenses and shut down any and all Dispensaries. Forcing Patients to go back to Pharmnaceutical drugs. There are ail kinds of conflicts of interest. Refer to Exhibit W section 1. Doctors that are License te do referrals for patients are also not allowed to own any Marijuana licenses due to conflict of interest. in summary Plaintiff want's 5 Dispensary Licenses. Plaintiff is not asking this court to eliminate the Board of Pharmacy from the Dispensary process of the Medical Marijuana industry. | am asking this court to rule in Plaintiff's favor to grant this Injunction. This will allow Plaintiffto work with the state representative to request positive changes and presentation fo JACARR for approval. This process has already been used in making changes in the House Bill 523. It takes time to start and complete this process. Obviously there is a blatant conspiracy that the plaintiff is a victim of. First nol even being able {o put in an appileation for cultivation 1 license due to something that was not on either required application list therefore not able to not only be considered but not able to file a 118 appeal process. Then Board of Pharmacy has a glitch in there system not allowing me fo putin a single application not only under cannabis for cures but not even under my own personal name. Therefore causing me to lose my investors and millions of dollars. Also not being able to apply for the 119 appeal process for those licenses either so they have completely and Hterally eliminated me from being able to participate in any form of Licensing in the medical marijuana industry. Knowing full weil at the beginning while writing the house bil what my full intentions were and they completely was successful In eliminating me from being able to do a single thing that | wanted fo do for Research and Development, keeping pricing low so patients can afford their medications and Chio patients in the medical marijuana industry. Therefore | am not even able to participate in any appeal process. Exhibit ¥ Is my official notification of running for Governor of Ohia due to the fact that the corruption in this state needs to stop and they have provoked me to take this to another evel. Where | can make the difference and allow Ohioans to Rebuild Ohio. 4 i the Plaintiff should not be the one to have te file Injunctions and lawsuits to protect Ohioans from the damages that are occurring. The Attorney General's office is supposed te be fighting and protecting Ohioans. For the Ohio Attorney General's office to be Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 30 10:40 AM-18CV003043 OE257 - K6é fighting for the State of Ohio Board of Pharmacy, Pharmaceutical companies and Pharmacist against the Plaintiff who is trying to protect Ohioans and make things right. The Attorneys General Michael Dewine should have advised John Kasich's that it was iilegal to change marijuana from a federally schedule 1 drug to a schedule 2 drug for the state of Ohio. Federally marijuana is a schedule 1 drug therefore pharmaceutical companies pharmacist and Board of Pharmacy can not participate in a Federally scheduled 4 drug industry. There for another reason why this court should rule in Plaintlff's favor. Plaintiff is Praying that this court to rule in favor for Plaintiff. Marijuana will be on the ballot for Recreational use (they are currently getting signatures} It will pass. individuals will be able to grow process in their own homes will not need Hcensing through the state therefore will not be governed or taxed and not help rebulld, revitalize or create jobs. | am not for Recreational. af RENEA MURNAHAN-TURNER Plaintiff Renea Murnahan-Turner CEO of Cannabis For Cures, LLC , CEO of Medical Marijuana Rebuild Ohio, Ohio Advocate for Medica! Marijuana Research and Development, CEO of Veterans Clinics ( To allow Cannabis to Treat PTSD) 42 North Fountain Avenue SPRINGFIELD, OHIO 45502 937-215-0651