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 Jun 28 4:49 PM-18CV003043
0E215 - 117
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.
PLAINTIFF'S RESPONSE TO ANSWER
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. 1st
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!)
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 in sent a notice the | 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 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
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043
0E215 - 118
Licenses. Also filled too 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 not only | 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 that 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
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) That defendant's exhibit 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
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043
0E215 - I1
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 and 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 17CV0612 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 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 non of the references refer to 3796.11 of 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 therefore the State
Board of Pharmacy has broken the law. 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
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
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043
0E215 - 120
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 year. Immediately prior to the date
the criminal record check as requested. They could apply for all licenses. THAT IS BLATANT
DISCRIMINATION. | 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. 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. Without a shadow of
doubt 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.
| 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.
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.
Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043
0E215 - I21
/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
Document Filed Date
June 28, 2018
Case Filing Date
April 12, 2018
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043 0E215 - 117 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. PLAINTIFF'S RESPONSE TO ANSWER 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. 1st 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!) 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 in sent a notice the | 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 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 Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043 0E215 - 118 Licenses. Also filled too 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 not only | 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 that 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 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) That defendant's exhibit 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 Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043 0E215 - I1 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 and 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 17CV0612 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 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 non of the references refer to 3796.11 of 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 therefore the State Board of Pharmacy has broken the law. 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 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 Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043 0E215 - 120 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 year. Immediately prior to the date the criminal record check as requested. They could apply for all licenses. THAT IS BLATANT DISCRIMINATION. | 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. 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. Without a shadow of doubt 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. | 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. 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. Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jun 28 4:49 PM-18CV003043 0E215 - I21 /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