On April 12, 2018 a
Order
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 02 4:30 PM-18CV003043
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Franklin County Ohio Clerk of the Courts of Common Pleas
18CV003043
HONORABLE JUDGE HOLBROOK
RENEA MURNAHAN-TURNER
Plaintiff.
vs.
STATE OF OHIO BOARD OF PHARMACY
Defendant.
MOTION FOR JUDGMENT ON THE PLEADING
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
log in and fill out 5 applications. | 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 CDR
that was Not on either application lists. 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!) If they can 1. Remove Women from House Bill 523 being
considered Economically Disadvantaged Minorities(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 Bill 523) out of state
Applicants . They Absolutely can make it so that | or 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. testimony's at the state house My goals and business plans or completely
clear | was planning on filing for Cultivator, Processing and Dispensaries. That Plaintiff was
100% 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)l was continuously having
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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 continue to try to
put in my application not only as Cannabis for Cures LLC also tried to do under Renea
Murnahan-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 5 Dispensaries that Plaintiff CONTINUOUSLY tried to Apply for and kicked out
of the online system. That was put in place by the State of Ohio Board of Pharmacy. Plaintiff is
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 | filed 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 illegally
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 if it's a
schedule 1 drug Pharmaceutical companies and Pharmacies CAN NOT Participate in a
schedule 1 drug.
2. Several of the Dispensaries Licenses Illegally 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
(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. Just like our State Representatives like John Kasich that according to Michael
Dewine has Immunity thay feel they are above the law and accepted bribes and think they can
get away with it. These people also know how they got their licenses and they will go after the
Ohio Governed people that took there Bribes and gave them their licenses illegally to begin with
Renea Murnahan-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
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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. | also
am a business Entrepreneur | also completely build businesses from the ground up to 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 that 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 Lawsuits
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 25th . The case 17C\V0612 Cannabis For Cures LLC
Injunction against State of Ohio Board of Pharmacy that was dismissed solely due to Renea
Murnahan-Turner not being an Attorney. Therefore at this time the Attorney for the Board put
together this answer of absolute denial of everything. Full well knowing that case is set for
Hearing. Also proves that they are willing to lie and misrepresent the many true fact of this
case. This court does have jurisdiction.
In the process of all of the denials none of the references refer to 3796.110f the Ohio Revised
Code. Stating Tax Compliance as a Ohio Resident. Reference Defendant's Exhibit of House Bill
523. The board admitted to accepting non Tax Compliant Residents of Ohio. 3796.12 Criminal
Background Checks This court does have Jurisdiction.
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 tax laws of this state. Tax laws of this state
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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
5 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
their Ohio license in the Medical Marijuana Industry. Summary for this section is non-compliant
out of state applications were accepted and Provisional Licenses were granted. To Pharmacist
that by Federal Law 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 3796.12 Of the Ohio revised code H.B.523 also states on
page 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 CRIMINAL 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.
| 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 who the 4
was he replied you was unable 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 all of my
testimony's. 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’s 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 | would NOT if | did.
There is an overwhelming amount of evidence to prove all of this including witnesses, My
Exhibits with my 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 less 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 both cultivator 1 level was refused by the Ohio Department of
Commerce and my 5 dispensary licenses were never able to 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.
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| continued to 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-Turner. 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 law, that this
injunction is necessary to prevent irreparable harm, and no adequate remedy at law exists.
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 licensing
through the state therefore will not be governed or taxed and not help rebuild, revitalize, create
jobs.
s/RENEA MURNAHAN-TURNER
Plaintiff Renea Murnahan-Turner
CEO of Cannabis For Cures, LLC , CEO of Medical Marijuana Rebuild Ohio, Ohio Advocate for
Medical 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 02, 2018
Case Filing Date
April 12, 2018
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