THIS CASE IS BEFORE
THE SUPERIOR COURT OF THE STATE OF ARIZONA
COUNTY OF MARICOPA
Plaintiff and Appellant
ARIZONA DEPARTMENT OF HEALTH SERVICES, WILL HUMBLE, et al
Defendants and Respondents
|Case No.: LC2014-000443-001 DT
PLAINTIFF/APPELLANT RESPONSE TO DEFENDANT/RESPONDENTS ANSWERING BRIEF
The Honorable Judge
I, Arlin Troutt, (“the Plaintiff”) hereby submits his response to the Answering Brief (“AB”) on Appeal of Will Humble, the former head of Arizona Department of Health Services (“ADHS”). This AB was filed by ADHS with this Honorable Court on April 30, 2015 in response to Plaintiff’s Opening Brief (“OB”) filed with this Honorable Court on March 11, 2015.
Most Arizona voters did not read all 19,000 or more words of fine print in the Publicity Pamphlet. Most voters did not read the disputed definition of “medical use” or the disputed 37 words that construct A.R.S. § 36-2804.02(A)(3)(f).
However, a majority of Arizona voters approved a law that removed criminal penalties for cultivation of marijuana for medical use. The electorate realized that cultivation is the key to reducing the cost, crime and subsequent violence that creates the greatest risk to medical marijuana patients and threatens the safety, health and welfare of our citizens.
STATEMENT OF THE CASE
This dispute regards the interpretation and electoral intent of the Arizona Medical Marijuana Act (“AMMA”) as described to Arizona voters in the 2010 Proposition 203 Ballot Guide generated by the Arizona Secretary of State (the “Publicity Pamphlet”).
Will Humble directed ADHS to formulate and promulgate administrative rules that were unauthorized by the AMMA, unintended by the electorate and damaging to the Plaintiff and other critically ill patients. ADHS misrepresented material facts to Tammi Eigenheer the Administrative Law Judge for the Arizona Administrative Hearings Office.
ADHS, alleges as a Statement of Fact: “The Department regulates medical marijuana use in the State of Arizona under AMMA and the Rules.” (AB-Pg. 2, lines 13-14)
Pursuant to A.R.S. § 36-2801(9): “MEDICAL USE” MEANS THE ACQUISITION, POSSESSION, CULTIVATION, MANUFACTURE, USE, ADMINISTRATION, DELIVERY, TRANSFER OR TRANSPORTATION OF MARIJUANA OR PARAPHERNALIA RELATING TO THE ADMINISTRATION OF MARIJUANA TO TREAT OR ALLEVIATE A REGISTERED QUALIFYING PATIENT’S DEBILITATING MEDICAL CONDITION OR SYMPTOMS ASSOCIATED WITH THE PATIENT’S DEBILITATING MEDICAL CONDITION (AB-App-046)
AMMA, “medical use” is a defined term of “certain specific conduct” that only “relates” to a registered qualifying patient’s specific needs to “treat or alleviate” medical conditions or associated symptoms. AMMA “medical use” can only be authorized for critically ill patients by a certifying physician.
A.R.S. § 36-2801(9) “medical use” does not “relate” to AMMA requirements for ADHS to “establish and regulate dispensaries” with minimum oversight and issue identification cards to caregivers, dispensary owners and dispensary agents.
ADHS has improperly extended their limited authority to regulate dispensary owners and agents with “minimum oversight” to the over-regulation and restriction of qualified patient’s right to engage in the cultivation and or medical use of marijuana.
Pursuant to A.R.S. § 36-2801(1)(c) definitions: MARIJUANA THAT IS INCIDENTAL TO MEDICAL USE, BUT IS NOT USABLE MARIJUANA AS DEFINED IN THIS CHAPTER, SHALL NOT BE COUNTED TOWARD A QUALIFYING PATIENT’S OR DESIGNATED CAREGIVER’S ALLOWABLE AMOUNT OF MARIJUANA. (AB-App-045)
A.R.S. § 36-2801(1)(c) definitions” makes an exclusive exception for the “allowable” amount of marijuana that a “qualifying patient” can cultivate and possess for medical use.
Pursuant to A.R.S. § 36-2801(15). “USABLE MARIJUANA” MEANS THE DRIED FLOWERS OF THE MARIJUANA PLANT, AND ANY MIXTURE OR PREPARATION
THEREOF, BUT DOES NOT INCLUDE THE SEEDS, STALKS AND ROOTS OF THE PLANT…” (AB-App-046)
A.R.S. § 36-2801(1)(c) and A.R.S. § 36-2801(15): can only be interpreted as provisions that authorize and protect the right of the qualifying patient to engage in the cultivation of marijuana for beneficial and “uninterrupted” medical use. (see A.R.S. § 36-2812(A)(2) @ AB- App-052) (AB-App-045, App-046 and)
ADHS concedes: “AMMA decriminalizes the medical use of marijuana for registered qualifying patients.” (AB-Pg. 1, lines 3-4), ADHS acknowledges that the Plaintiff: “is a qualified patient and holder of a card.” (AB-Pg. 1, line 10)
Plaintiff was issued a cultivation identification card in 2011 and renewed this card in 2012 and 2013. Plaintiff paid fees, provided required requests for information and properly demanded ADHS to renew Plaintiff’s cultivation identification card on April 29, 2014.
On May 2, 2014 ADHS sent Plaintiff a “Request for Information” stating: “The patient date of birth listed on the “physician certification form does not match the date of birth listed in the application and/or the identification document submitted. Please re-submit the corrected information and /or documents to the Program via the Department’s online application system”.(EXHIBIT B)
ADHS confirmed that this May 2, 2014 “Information Request” had been resolved on May 2, 2014. (EXHIBIT A- Pg. 3, footnote 3)
On May 8, 2014 ADHS sent a second “Request for Information” stating: “Your application for a Qualifying Patient Registry Identification Card (Registry Application #AZQP0016870000161953) has been received by the Medical Marijuana Program (‘Program’), Arizona Department of Health Services (‘Department). The following issue(s) with your application was/were identified by the Program: 1. The residential address you have listed in the application is within 25 miles of an operating dispensary. The qualifying patient cannot cultivate. Please resubmit your application. During resubmission, you may make changes to your address or withdraw the request to cultivate to help resolve this issue.” “If you do not resubmit, the cultivation request will be denied.” (EXHIBIT B)
Both the May 2, 2014 and the May 8, 2014 Requests for Information were clearly titled “Request for Information”. However, ADHS made an error on the May 8, 2014 Request for Information that the Plaintiff could not respond to because of the “Department’s online application system” did not allow registering patients to respond. (Exhibit C)
Plaintiff immediately filed a 33 page complaint with ADHS on May 10, 2014 regarding this error; and the matter of the Plaintiff getting sick from contaminated dispensary marijuana and being threatened for reporting the contaminated marijuana and dispensary to ADHS.
On May 14, 2014 Robert Lane of the ADHS issued: ORDER DENYING REQUEST TO CULTIVATE AND NOTICE OF RIGHT TO APPEAL (the “Denial”) (EXHIBIT A).
ADHS Denial states “REASONS FOR DEPARTMENT’S DENIAL OF APPLICANT’S REQUEST TO CULTIVATE: “The Application, submitted to the Department on April 29, 2014, included a “request for authorization” to cultivate marijuana plants based on the “Applicant’s Residence”.” (EXHIBIT A-Page 2, lines 13-15)
On May 17, 2014, Plaintiff received an altered and unauthorized identification card from ADHS via United States Postal Service. The authority to cultivate indication that is required by AMMA and demanded by the Plaintiff had been excluded from the 2014 identification card, but ADHS included Plaintiff’s name and residential address on the card.
A.R.S. § 36-2804.04(A)(7) requires ADHS to clearly indicate the card holders AMMA cultivation authorization but nothing in the AMMA requires a qualified patient to disclose the secured and confidential location of the patient’s cultivation site. (AB-App-049)
A.R.S. § 36-2804.04 certainly does not give ADHS authority to deny a specifically defined immunity, a privilege and a preference only offered to a qualified patient by AMMA.
According to A.R.S. § 36-2808(A): Notifications to department; civil penalty: “it is the registered qualifying patient that must notify ADHS of the patient’s change in his “preference regarding who may cultivate marijuana”. (AB-App-051).
If ADHS fails to issue a registry identification card in a legal and timely manner after demand by a registering qualified patient or a registered qualifying patient’s ADHS application becomes the patient’s authorization to use medical marijuana.
According to: A.R.S. § 36-2818(B). Enforcement of this act; mandamus: IF THE DEPARTMENT FAILS TO ISSUE A REGISTRY IDENTIFICATION CARD WITHIN FORTY-FIVE DAYS OF THE SUBMISSION OF A VALID APPLICATION OR RENEWAL, THE REGISTRY IDENTIFICATION CARD SHALL BE DEEMED ISSUED, AND A COPY OF THE REGISTRY IDENTIFICATION CARD APPLICATION OR RENEWAL IS DEEMED A VALID REGISTRY IDENTIFICATION CARD.
A.R.S. § 36-2804.05(A) gives ADHS a very limited authority to deny an application for registration or renewal demands qualified patients for an AMMA identification card. ADHS has no authority to limit or restrict the medical use or immunities granted to the Plaintiff by AMMA.
ADHS added 35 words that do not exist in the Publicity Pamphlet to the 37 words that actually construct A.R.S. § 36-2804.02(A)(3)(f) to create a 72 word interpretation that is unintended by the electorate and unauthorized by AMMA.
According to Arizona’s laws regarding the negligent misrepresentation of material facts and Arizona Rules of Professional Conduct ER 8.4 MISCONDUCT (a)(b)(c)(d)(f) the misrepresentation of material facts are a very serious concern in the pursuit of justice.
The following is an unauthorized and damaging misrepresentation of a material fact by ADHS: “Pursuant to A.R.S. § 36-2804.02(A)(3)(f), a qualifying patient applying to the Department for a qualifying patient’s registry identification card must submit an application that includes “[a] designation as to who will be allowed to cultivate marijuana plants for the qualifying patient’s medical use if a registered nonprofit medical marijuana dispensary is within twenty-five miles of the qualifying patient’s home, neither the qualifying patient nor the qualifying patient’s designated caregiver may be granted authority to cultivate marijuana plants.” (EXHIBIT A- Pg.1, line 21-23 to page 2, lines 1-5)
If A.R.S. § 36-2804.02(A)(3)(f) was intended to be a “restriction” or a “request for authorization” it would have said that, but it did not “say” that. ADHS had to create and add 35 extra words to “Pursuant to” to make A.R.S. § 36-2804.02(A)(3)(f) say that.
Plaintiff would respectfully remind this Honorable Court that ADHS told your Court in their December 8, 2014 Response: “The Department interpreted A.R.S. § 36-2804.02(A)(3)(f) to mean exactly what it says: “If you live within twenty-five miles of a dispensary, you are not authorized to cultivate marijuana.”(ADHS Response, December 8, 2014- Page 7, lines 21-25)
There is a distinct difference in a request for information and a request for authorization and a wide line of legality that ADHS crossed before Will Humble’s surprise resignation.
FACTS OF THE MATTER
According to the Preamble of the AMMA found in the Publicity Pamphlet at Section 2. Findings (A.), the intent and purpose for repealing criminal statues and removing civil penalties for the “cultivation” and or medical use of marijuana is crystal clear: “The People of the State of Arizona found and declared that: Marijuana’s recorded use as a medicine goes back nearly 5,000 years, and modern medical research has confirmed beneficial uses for marijuana.” (AB-App-045)
According to Section 2 (D.): “Consequently, changing state law will have the practical effect of protecting from arrest the “vast majority” of seriously ill patients who have a medical need to use marijuana.” (AB-App-045)
According to Section 2 (E.): “Arizona removed state-level criminal penalties for the medical use and cultivation of marijuana for the health and welfare of its citizens.”(AB-A-045)
According to the clearest language of the Publicity Pamphlet for the AMMA in Section 2. (G): “State law should make a distinction between the medical and nonmedical uses of marijuana. Hence, the purpose of this act is to protect patients with debilitating medical conditions, as well as their physicians and providers, from arrest and prosecution, criminal and other penalties and property forfeiture if such patients engage in the medical use of marijuana.” (AB-App-045)
According to A.R.S. § 36-2801(18)(a),(b): As defined, a written certification includes more than a physician’s professional opinion. It requires the physician to complete a full assessment of the patient’s medical history, specify the patient’s debilitating medical condition, and sign and date the certification “only in the course of that relationship” and only after completing that assessment. (AB-App-046)
The Legislative Analysis in the Publicity Pamphlet states: ” If the qualifying patient is under 18 years of age, the patient’s custodial parent or legal guardian must submit written certifications from two physicians and the custodial parent or legal guardian must consent in writing to control the patient’s medical use of the marijuana.”(AB-App-055)
In no clearer terms could the Legislative Analysis have explained the physician’s traditional authority to “control” and “regulate” the quality, quantity, form and method of administration for medicine that the “physician and patient” believes is most beneficial to the patient.
Pursuant to A.R.S. § 36-2813(C). Discrimination prohibited: “A REGISTERED QUALIFYING PATIENT’S AUTHORIZED USE OF MARIJUANA MUST BE CONSIDERED THE EQUIVALENT OF THE USE OF ANY OTHER MEDICATION UNDER THE DIRECTION OF A PHYSICIAN AND DOES NOT CONSTITUTE THE USE OF AN ILLICIT SUBSTANCE OR OTHERWISE DISQUALIFY A REGISTERED QUALIFYING PATIENT FROM MEDICAL CARE.” (AB-App-053)
The term “medical use” is used 39 times in the Publicity Pamphlet and only in the context of medical use by a certified patient. (AB-Pages A045 to A-060)
AMMA does not authorize or allow ADHS to regulate, restrict or limit medical use of marijuana or tell this Honorable Court: “The Department regulates medical marijuana use in the State of Arizona under AMMA and the Rules.” (AB-Pg. 2, lines 13-14)
ADHS admits: “The Legislative Council’s analysis of AMMA was included with the Publicity Pamphlet distributed to voters in 2010.” (AB-Pg. 12, lines 25-26)
The Legislative Council’s Analysis and the Descriptive Title of the Publicity Pamphlet explained the effect of a “yes” and “no” vote for AMMA. The Publicity Pamphlet explains: that a “yes” vote for the AMMA: ALLOWS THE USE OF MARIJUANA FOR PEOPLE WITH DEBILITATION MEDICAL CONDITIONS WHO OBTAIN A WRITTEN CERTIFICATION FROM A PHYSICIAN “AND” ESTABLISHES A REGLATORY SYSTEM GOVERNED BY THE ARIZONA DEPARTMENT OF HEALTH SERVICES FOR ESTABLISHING AND LICENSING MEDICAL MARIJUANA DISPENSARIES.
The Publicity Pamphlet clearly explains: “A “no” vote shall have the effect of retaining current law (of 2010) regarding the “medical use” of marijuana.” (AB-App-055 and App-060)
ADHS misguides and disrespects this Honorable Court by alleging: “The Legislative Council interpreted AMMA in the same way as the Department. The Legislative Council’s analysis is evidence of the intent of the electorate and cannot be ignored or disregarded. In light of the Legislative council’s similar reading of the statute, the Department’s interpretation is not plainly erroneous. It is therefore entitled to deference and great weight.” (AB-Pg. 13, lines 10-14)
The Legislative Analysis and the Descriptive Title of the Publicity Pamphlet clearly define the extent of immunity granted to certified patients. Both the Legislative Analysis and the Descriptive Title clearly limit authority of ADHS to establish and regulate dispensaries. Nowhere in the AMMA is ADHS given authority to regulate medical use of marijuana.
The following is another great example of how the ADHS goes on to disrespect and misguide this Honorable Court with this nonsensically constructed and erroneous statement: “Nothing in AMMA permits cultivation of marijuana plants if a qualifying patient resides within twenty-five miles of an operating dispensary.” (AB-Pg. 13, lines 21-22).
According to A.R.S. § 36-2811 Presumption of medical use of marijuana; protections; civil penalty: (A.) “There is a presumption that a “qualifying” patient is engaged in the medical use of marijuana”. (B.) “Registered patients are not subject to arrest, prosecution or penalty in any manner, or denial of any right or privilege, including any civil penalty or disciplinary action by a court, licensing board or bureau for a registered patient’s medical use of marijuana .” (AB-App-051 to App-052)
ADHS concedes the Legislative Analysis states: “Proposition 203 would generally provide that any person who acts in conformity with the requirements of the proposition is not subject to any governmentally imposed sanction relating to the medical use of marijuana.” (AB- App-055).
According to the AMMA and ADHS Rule R9-17-101, any registered qualified patient can simply choose to “acquire” marijuana for medical use from any source possible: (R9-17-101) Definitions: In addition to the definitions in A.R.S. § 36-2801: “Acquire” means to obtain through any type of transaction and from any source. (A.R.S. § 36-2801(9) and R9-17-101)
A.R.S. § 36-136 does not authorize or allow the ADHS to cultivate and sell or dispense contaminated products or artificial and or counterfeit or substitute marijuana products.
AMMA does not allow ADHS to constrain the rights and specified immunities registering certified patients for engaging in the medical use of marijuana. AMMA does not allow ADHS to “impose” inferior products sold in high crime area based on a critically ill patient’s residence.
The Plaintiff does not use dispensary designer dope. ADHS does not have the authority to impose these products on Plaintiff’s religious beliefs. According to A.R.S. § 36-114. Limitation upon authority to impose treatment: “Nothing in this title shall authorize the department (ADHS) or any of its officers or representatives to impose on any person contrary to his religious concepts any mode of treatment,…”
These unauthorized and unintended ADHS regulations for “medical use of marijuana are damaging, arbitrary and capricious. These ADHS rules violate the intent of the AMMA, Arizona’s criminal statues and the CONTROLLED SUBSTANCE ACT Title 21, Subchapter I, § 802(1)(a)(b),(7)(21)
ADHS asks this Honorable Court to accord great weight to the agency’s interpretation of the Publicity Pamphlet unless it concludes the legislature intended a different interpretation. (AB-Pg. 6, lines 1-8)
ADHS concedes: “The primary objective in interpreting a voter-enacted law is to effectuate the voters’ intent.” (AB-Pg. 6, lines 12-14)
According to the Arizona Appellate Court in State v. Gear, regarding immunity of medical marijuana patients and their physicians: “in construing statutes, we apply a word’s “usual and commonly understood meaning unless the legislature clearly intended a different meaning.” In re Nelson, 207 Ariz. 318, 322, ¶ 16, 86 P.3d 374, 378 (2004). And, we apply this same principle when we interpret a voter-approved initiative. Sedona Grand, LLC v. City of Sedona, 229 Ariz. 37, 40, ¶ 11, 270 P.3d 864, 867 (App. 2012). “To determine the ordinary meaning of a word, we may refer to established and widely used dictionaries.” Stout v. Taylor, 233 Ariz. 275, 278, ¶ 12, 311 P.3d 1088, 1091 (App. 2013).” (No. 1 CA-CR 13-0852 State v. Gear-Arizona Appeal Court Division One ) http://www.azcourts.gov/Portals/0/OpinionFiles/Div1/2014/1%20CA%20CR-13-0852.pdf
ADHS admits: “If [a] statute is clear and unambiguous, [courts]apply the plain meaning of the statute.” (AB-Pg. 9, line 22).
However, ADHS refuses to admit that “medical use” is a defined term of “certain specific conduct” that clearly includes cultivation and these clearly defined immunities only “relate” to a registering qualifying patient’s specific needs to “treat or alleviate” medical conditions or associated symptoms.
The Plaintiff has demonstrated to this Honorable Court with a great preponderance of documented evidence that cultivation of medical marijuana was intended by the electorate, specifically defined and authorized for registering qualified patient’s personal needs to treat or alleviate medical conditions or associated symptoms.
The Plaintiff has demonstrated to this Honorable Court with undeniable documentation that ADHS has misrepresented the material facts. ADHS has denied that “medical use” is a defined term of “certain specific conduct” that includes and authorizes cultivation and only relates to the qualified patient.
The Plaintiff has demonstrated to this Honorable Court with the Evidence on Record that A.R.S. § 36-2804.02(A)(3)(f) can only be interpreted as an AMMA “request for information” and not a “request for authorization”.
Plaintiff complained on May 10, 2014 that A.R.S. § 36-2804.02(A)(3)(f) does not allow or authorize the ADHS to restrict or limit the Plaintiff’s immunity for engaging in the medical use of marijuana pursuant to AMMA. The intent of AMMA according to the Publicity Pamphlet was to authorize the medical use of marijuana for critically ill patients and reduce the crime and violence associated with marijuana prohibition.
Limiting critically ill patient’s options to driving great distances to high crime areas to buy artificial and contaminated marijuana for high profit was not the intent of the electorate.
Forcing qualified patients into protracted litigation with frivolous interpretations and unauthorized restrictions by ADHS was not the intent of the electorate.
Forcing our Superior Court Judges to drag out the Merriam Webster Dictionary over and over to protect medical marijuana patients and their physicians “from the state” was not the intent of the electorate.
ADHS misled Judge Eigenheer and continues to mislead this Honorable Court. ADHS alleges: “The twenty-five mile rule (A.R.S. § 36-2804.02(A)(3)(f)) was intended to be a restriction on the personal cultivation of marijuana under AMMA.” (December 8, 2014- Page 10, lines 14-18)
ADHS “25-miles as the Crow Flies” rule that was attached to A.R.S. § 36-2804.02(A)(3)(f) is an unauthorized restriction on personal cultivation of marijuana that compromises a critically ill patient’s medical confidentiality and jeopardizes the patient’s health and safety. This “25-miles as the Crow Flies Rule” is a perfect example of the dangerous over-regulation ADHS relied on to obstruct the implementation of AMMA.
Complaints of ADHS obstruction of the AMMA program with over-regulation, excessive fees and threats for reporting contaminated marijuana have been buried with the ADHS refusal to admit that medical use includes cultivation and A.R.S. § 36-2804.02(A)(3)(f) is merely a “request for information”.
These 37 words that construct A.R.S. § 36-2804.02(A)(3)(f) can only be interpreted as an AMMA “request for information”. ADHS added 35 non existent words to make the “25-Mile As the Crow Flies Rule” a “required request for authorization”, obstructing the will of the electorate and the implementation of the AMMA Donation Program.
The State of Arizona has a history of violently arresting people, confiscating children, seizing property and sentencing people to long prison terms for cultivating and using medical marijuana. Will Humble has a long history of opposing medical marijuana that goes back to the first time voters approved medical marijuana in 1996. Will Humble still opposes medical marijuana after a questionable dispersal of 8.8 million dollars of medical marijuana money and a surprise resignation in March of 2015.
These disputed rules ADHS has formulated to usurp control of the cultivation cash for the “medical use” of marijuana is where Will Humble and the ADHS crossed the line of job description, moral responsibility and legality.
Now ADHS asks this Honorable Court to rely on an ALJ Affirmation of an ADHS Final Decision that was based on the same arbitrary and capricious rules and misrepresentations of material facts that the Plaintiff has presented to this Honorable Court.
ADHS request for ORAL ARGUMENT is nothing more than another delay of the inevitable and more obstruction of the process of law. Plaintiff objects to this Honorable Court granting Oral Arguments to ADHS at this late date. It is time for this Honorable Court to rule.
Plaintiff filed the original complaint against ADHS on May 10, 2014. ADHS took 50 days just to submit their final AB. This Honorable Court has issued over 2,350 Minute Entries since Plaintiff filed his Request for Judicial Review and Notice of Appeal on September 23, 2015.
ADHS made a Final Decision to over-regulate and overcharge charge critically ill patients for engaging in the medical use of marijuana. The medical use of marijuana includes cultivation and A.R.S. § 36-2804.02(A)(3)(f) is just a request for information.
ADHS has buried this matter under a protracted pile of frivolous administrative litigation. ADHS has shielded Will Humble from the damaging acts he chose to commit as head of the ADHS. This protracted administrative battle over the simplest interpretations of language, law and electorate intent was a distraction that covered up a multi-million dollar marijuana revenue robbery and resignation.
Whereas the Plaintiff respectfully requests this Honorable Court to overturn Judge Eigenheer’s Affirmation and the ADHS Final Decision in this matter.
Whereas the Plaintiff respectfully requests this Honorable Court to rule that “medical use” is a defined term of certain specific conduct in the AMMA that authorizes private cultivation of marijuana for medical use by registered qualified patients.
Whereas the Plaintiff respectfully requests this Honorable Court to rule that: A.R.S. § 36-2804.02(A)(3)(f) is a request for information and cannot be interpreted to be a request for authorization.
Whereas the Plaintiff respectfully requests this Honorable Court to rule that ADHS misrepresented material facts to Judge Eigenheer’s court and or to this Honorable Court.
Whereas the Plaintiff respectfully requests this Honorable Court to issue any sanctions, referrals for criminal investigation, or other punitive actions against Will Humble and ADHS for their misrepresentation and promulgation of such damaging and destructive information.
Whereas Plaintiff respectfully requests this Honorable Court to award Plaintiff any compensation for the costs and damages Plaintiff has suffered and is fairly entitled to receive.
Respectfully Submitted on May 18, 2015