NORMAN J. CLEMENT RPH., DDS., MALACHI F. MACKANDAL PHARMD, JOSEPH SOLVO ESQ., BEVERLY PRINCE MD., JACK FOLSON RPH., NORMAN L.CLEMENT PHARM-TECH, REV. C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., MBA., WILLIE GUINYARD BS., BRAHM FISHER ESQ., JOSEPH WEBSTER MD., ESTER HYATT PHD., BERES E. MUSCHETT, STRATEGIC ADVISOR
“Retired Neonatologist Keith Kanarek MD, Tampa Florida points out they operate under think and feel rather than fact-based on a foundation of science.“
THE CONGRESS MUST INVESTIGATE AND DEFUND THE UNITED STATES DRUG ENFORCEMENT AGENCY (DEA)
Charles Ogletree Esq; Harvard Law Professor
…..from The Presumption of Guilt, the arrest of Henry Louis Gates Jr., …”I examine the race and class dimensions of the Gates arrest by looking at how other successful, prosperous, and noteworthy African American men (who are by no means alone in experiencing problems of racial profiling) have grappled with a wide range of encounters not only with police but with countless everyday citizens and found themselves being judged by the color of their skin rather than the content of their character.“…..
DONALD SULLIVAN’S LONG HISTORY OF PROFESSIONAL, ACADEMIC FRAUD AND JUDICIAL PERJURY
The year is 2010, the case docket 09-48, Columbus, Ohio The United States Drug Enforcement Agency vs East Main Street Pharmacy (‘‘Respondent’’), of Columbus, Ohio Harold Eugene Fletcher PharmD from the record it reads,
The Government called Donald Sullivan, R.Ph. and Ph.D., as its expert witness. Dr. Sullivan, who holds active pharmacist licenses in Ohio and Florida, obtained a B.S. in Pharmacy from The Ohio State University, as well as both an M.S. and Ph.D. in Pharmaceutical Administration, also from The Ohio State University.
Between 1997 and 2006, Dr. Sullivan was an Associate Professor of Pharmacy Practice at Ohio Northern University. Thereafter, Dr. Sullivan was appointed to the rank of Full Professor and has been Chairman of the Department of Pharmacy at Ohio Northern University for the last four years. (1)
During graduate school, Dr. Sullivan worked as a Registered Pharmacist at both retail and mail-order pharmacies. He testified that he has worked at ‘‘several different independents in the central Ohio area’’ and that he currently works part-time as a pharmacist for North Central Mental Health. Dr. Sullivan was offered and accepted as an ‘‘expert witness” on standard pharmacy
Before this Court Professor Dr. Sullivan testified that under both Ohio and Federal law,
there ‘‘is corresponding responsibility between the physician and the pharmacist.’’ He further explained that ‘‘a lot of pharmacists think that just because the physician wrote it, I have to fill it.’’ However, Dr. Sullivan stated that there is nothing in Ohio law that says you have to fill any prescription.’’ He then explained that ‘‘one of the first things we try to get the students and pharmacist to understand is that under Ohio law, and federal law 50 percent of the responsibility falls on the pharmacy, the pharmacist, 50 percent falls on the physician. Don’t just fill it because the doctor wrote it.’’
Similarly, in his report, Dr. Sullivan, after discussing the CSA’s prescription requirement (21 CFR 1306.04(a)), explained that:
The State of Ohio has similar language in its laws and regulations. Ohio Law states that: The pharmacist who fills any prescription has a corresponding responsibility with the physician to make sure that the prescription has been issued for a Legitimate Medical Purpose. The responsibility to ensure that a prescription is for a legitimate medical purpose in the usual course of a prescriber’s professional practice is equal for both the physician and pharmacist. (Fifty percent of this responsibility is on the pharmacist and 50% is on the physician). The argument that ‘‘Just because a physician wrote the prescription,
However the DEA Judge wrote in her observations of Dr. Donald Sullivan in 2010:
While the Ohio courts may have interpreted State law as described above, as explained below, Dr. Sullivan’s testimony that Federal law allocates fifty percent of the responsibility to the physician and fifty percent to the pharmacist is not a correct statement of the law, which has been amply explained in numerous decisions of the Federal courts and this Agency. To make clear, Federal law does not apportion the responsibility for dispensing unlawful prescriptions between a prescribing practitioner and a pharmacist. Rather, Federal law imposes separate and independent duties on the prescriber and the pharmacist.
More specifically, the prescriber must act within the usual course of professional practice and have
a legitimate medical purpose to lawfully issue a controlled-substance prescription. 21 CFR 1306.04(a). As the Supreme Court and numerous Federal courts have made plain, to lawfully prescribe a controlled substance the physician must act ‘‘in accordance with a standard of medical practice generally recognized and accepted in the United States.’’
The DEA Judge further notes
” By contrast, a ‘‘pharmacist is not required to practice medicine.’’ United States v. Hayes, 595 F.2d 258, 261 (5th. Cir 1979). ‘‘What is required of [a pharmacist] is the responsibility not to fill an order that purports to be a prescription but is not a prescription within the meaning of the statute because he knows [or has reason to know] that the issuing practitioner issued it outside the scope of medical practice.’’
However, Dr. Sullivan’s statements that: (1) A pharmacist is not required to fill any prescription, and (2) it is not an excuse that because a doctor wrote the prescription, it can be legally filled, are consistent with Federal law. According to Dr. Sullivan, as part of the prospective drug utilization review, a pharmacist is required to check a patient’s profile for the following: ‘‘(a) over-utilization or under- utilization[;] (b) therapeutic duplication[;] (c) drug-disease state contraindications[;] (d) drug-drug interactions[;] (e) incorrect drug dose or duration of treatment[;] (f) drug-allergy interaction[;] (g) abuse/ misuse[;] (h) inappropriate duration of treatment[; and] (i) documented good/nutritional supplements- drug interactions.’’
DONALD SULLIVAN’S LONG HISTORY OF PROFESSIONAL, ACADEMIC FRAUD AND JUDICIAL PERJURY CONTINUES
The year is 2020, the case docket 09-42, Tampa, Florida the United States Drug Enforcement Agency vs Pronto Pharmacy LLC., Norman J Clement RPh, DDS from the record it reads,
DEA Judge Mark D. Dowd writes:
“I question the sufficiency of the factual foundation for Dr. Sullivan’s expert opinion that the above prescriptions were an apparent attempt to mask scores of improper opioid prescriptions. The relevant medical records were not reviewed, the prescriber’s justification for the prescriptions were not considered by Dr. Sullivan, nor was the patient’s input as to the subject prescriptions considered. I find Dr. Sullivan’s subject opinion, on the basis of this record, to be improperly speculative and unjustified as an expert opinion.”
“This finding does not affect the probity of Dr. Sullivan’s opinions as to the therapeutic effect of the subject medications, their contraindication with other prescribed medications, or the justification of their prescription.”
CDUJOE WILDING BS. POLITICAL SCIENCE, STRATEGIC ADVISOR
Here we are in the year 2020 and the overwhelming effects of “White Privilege” are still being levied unjustly and on the side of the privileged group. The above statements made by Administrative Law DEA Judge Mark Dowd are clearly reflective of his unbalanced application of the facts as it pertains to Dr. Sullivan’s questionable and problematic efforts. Judge Dowd himself indicates that Dr. Sullivan’s claim to be an expert in the subject matter is not supportable.
However, Judge Dowd failed to give any just consideration to the pharmaceutical practices and procedures of a real expert with well over 40 years of experience.
………“This finding does not affect the probity of Dr. Sullivan’s opinions as to the therapeutic effect of the subject medications, their contraindication with other prescribed medications, or the justification of their prescription.”………..
DEA Judge Dowd clearly indicates Dr. Sullivan’s subpar attempt to discredit Dr. Clement was carried out with honesty and strong moral principles. Yet, Judge Dowd gave absolutely no consideration to the thoughts of morality, honesty, and basic human decency that Dr. Clement has displayed in his pharmaceutical practices for over 40 years.
THE ARROGANCE OF HUBRIS
WHY THE HOUSE JUDICIARY COMMITTEE MUST INVESTIGATE AND SHUT DOWN THE DEA COURT SYSTEM
DEA Judge Mark D. Dowd writes:
Dr. Sullivan demonstrated a commanding grasp of pharmacy practice and of the distinctions between pharmacy compounding and manufacturing. However, there were several matters for which he had diminished credibility. For one, he was unaware that Florida had codified the standard of care for medical personnel.
Although I later determined the statute in question did not apply to pharmacists, it was somewhat surprising he was unaware of it, as he teaches Florida pharmacy law, More problematically, he quickly agreed that it was consistent with his understanding of the standard of care for pharmacists in Florida, which was somewhat surprising, as the standard of care for medical personnel is a highly generalized standard, a prudent healthcare provider standard.
While the standard of care for pharmacists in Florida, as set out in the relevant Florida regulations, is highly specific in listing particular responsibilities and duties.
He arguably conceded an alternate generalized standard of care for pharmacists in Florida, which is not consistent with Florida law or regulation.
DEA Judge Mark D. Dowd writes:
Secondly, he gave inconsistent testimony regarding unresolvable red flags. He described several red flags as unresolvable, that no explanation could warrant the filing of the subject prescription. Later, he conceded that those same red flags could be resolved. At one point he suggested no single red flag was unresolvable, rather it was the combination of red flags which made them unresolvable. Accordingly, because of these inconsistencies, in the absence of a reliable principle or method employed by Dr. Sullivan, I reject his conclusions regarding his claim that certain red flags were unresolvable. For each of the red flags, he testified were “unresolvable,” I accept his alternate opinion that each of those red flags went unresolved in this matter, a finding clearly supported by the evidence.
DEA Judge Mark D. Dowd writes:
“An expert, however, must base his knowledge on more than “subjective belief or unsupported speculation.” Daubert, 509 U.S. at 590 (discussing Federal Rule of Evidence 702). Without additional supporting evidence I am unable to rely on Dr. Sullivan’s opinion regarding this red flag. The same will be true with respect to the other patients as to whom he raised a similar red flag to this one. I will, however, accept his opinion that prescriptions for opioids and low-dose non-controlled drugs raise a red flag to the extent that a low-dose non-controlled medication “doesn’t make sense” alongside a high-dose opioid. In other words, I accept his testimony that low doses of non-controlled drugs are suspicious because they do not make medical sense when prescribed with high doses of opioids, but I do not accept his testimony that any doctor prescribed those non-controlled drugs with the intent to cover illegitimate treatment”
In contrast The American Medical Association wrote on June 16, 2020:
While the AMA understands that the apparent goal of the CDC Guideline was to reduce opioid prescribing, we believe the proper role of CDC is to improve pain care. It follows that a dedicated effort must be made to undo the damage from the misapplication of the CDC Guideline.
Recommendations to improve the CDC GuidelineS
Accordingly, the CDC Guideline could be substantially improved in three overarching ways. First, by incorporating some fundamental revisions that acknowledge that many patients experience pain that is not well controlled, substantially impairs their quality of life and/or functional status, stigmatizes them, and could be managed with more compassionate patient care.
Second, by using the revised CDC Guideline as part of a coordinated federal strategy to help ensure patients with pain receive comprehensive care delivered in a patient-centric approach. And third, by urging state legislatures, payers, pharmacy chains, pharmacy benefit management companies, and all other stakeholders to immediately suspend the use of the CDC Guideline as an arbitrary policy to limit, discontinue or taper a patient’s opioid therapy.
Nonpharmacologic therapy and nonopioid pharmacologic therapy are preferred for chronic pain. Clinicians should consider opioid therapy only if expected benefits for both pain and function are anticipated to outweigh risks to the patient. If opioids are used, they should be combined with nonpharmacologic therapy and nonopioid pharmacologic therapy, as appropriate.
With respect to specific revisions, and in addition to the suggestions provided above, the AMA recommends the following revisions to the first recommendation of the 2016 CDC Guideline:
“Non-pharmacologic therapy and non-opioid pharmacologic therapy are preferred for patients with pain. Providers should consider using opioid therapy only if expected benefits for both pain and function are anticipated to outweigh risks to the patient. If opioids are used, they should be combined with nonpharmacologic therapy, as appropriate. In order to achieve this goal, public and private payer policies must be fundamentally altered and aligned to support payment for non- pharmacologic treatments and multimodal, multidisciplinary pain care. In addition, more evidence must be developed to inform clinical decision-making on the use of nonpharmacologic approaches, and more clinicians need to be trained in their effective use.“
The AMA’s rationale for this revision starts with the fundamental principle that treatment decisions for patients with pain must be made on an individualized basis. Opioid therapy should only be used when the benefits outweigh the risks, but there is no question that some patients benefit from opioid therapy— including at doses that some may consider “high.” As noted above, CDC authors of the CDC Guideline recognize that it has been used to deny access to legitimate pain care and non-consensually taper patients. The AMA urges CDC to specifically address this in the revised CDC Guideline.
We further urge CDC to support patients’ access to a broad range of pharmacologic and non- pharmacologic options. Broad-based, effective implementation of this recommendation requires large scale changes in the public and private payer communities and better evidence to inform the most effective nonpharmacologic approach for various conditions. Furthermore, access to non-pharmacologic and non-opioid pharmacological treatments and reimbursement for them are often inadequate, especially for multidisciplinary care. The National Pain Strategy specifically identifies that a pressing need exists to assess insurer practices such as prior authorization, step therapy, fail-first protocols, specialty tier payment structures, and other limits on reimbursement for multidisciplinary care treatments that act as barriers to effective care. Telling physicians they must use non-opioid pain care options when payers and other make them financially or administratively unavailable is a Catch-22 that CDC needs to help end.”
Before starting opioid therapy for chronic pain, clinicians should establish treatment goals with all patients, including realistic goals for pain and function, and should consider how therapy will be discontinued if benefits do not outweigh risks. Clinicians should continue opioid therapy only if there is a clinically meaningful improvement in pain and function that outweighs risks to patient safety.
While we generally support the CDC Guideline’s second recommendation, some situations exist where patients may have intractable pain and sufficient disability such that functional improvement is not possible, and relief of pain and suffering alone is a supportable primary goal. In an analogous fashion, some patients may demonstrate functional improvement, with limited changes in pain scores.” (7)
DONALD SULLIVAN: ORDER TO SHOW CAUSE AUGUST 29, 2019, PRONTO PHARMACY MILAGE AND DISTANCE
Patients Travelling Long Distances to Fill Prescriptions at Pronto Pharmacy: The DEA’s expert Donald Sullivan opined that it can be a red flag of abuse and diversion if a patient travels a significant distance to a specific pharmacy, especially if the patient also travels a significant distance to a particular prescriber. Numerous Pronto Pharmacy customers traveled significant distances to obtain and fill their prescriptions.
DEA’s expert Donald Sullivan opined that both patients traveling long distances from their residences and patients traveling long distances from the medical practices of the prescribers to have their prescriptions filled are significant red flags that the prescriptions being filled by Pronto Pharmacy were being abused and/or diverted and that a pharmacist who was properly exercising his corresponding responsibility would have recognized this and refused to fill most of these prescriptions. (6)
DEA Judge Mark D. Dowd writes in his recommended order May 05, 2020:
I am not accepting Dr. Sullivan’s testimony that the roundtrip distance from M.M.’s home to the doctor’s office, and then to the Respondent, and then back home, is a red flag. There was no evidence M.M. ever made that round trip. The 38 miles from M.M.’s home to the Respondent is not overly suspicious on its face. I believe the Government withdrew its allegation as to that distance. I will, however, accept Dr. Sullivan’s testimony that the 134 miles from M.M.’s home to the doctor’s office. U.S. Administrative Law Judge Mark D. Dowd was so busy trying to be a bigot, so busy trying to be a racist, so busy reading you are withinthenorms.com toughest man he couldn’t be fair.
Sullivan prevails solely on privilege and not on science or fact,
Donald Sullivan, Mark D. Dowd vs American Medical Association
However, The American Medical Association (AMA) June 16, 2020, wrote to Deborah Dowell, MD, MPH Chief Medical Officer National Center for Injury Prevention and Control U.S. Centers for Disease Control and Prevention 4770 Buford Highway, NE Atlanta, GA 30341 undermines The DEA’s Prescription Red Flag Crusade “Opioid War” against license Physicians, Dentist, Pharmacist, the testimony and conclusion drawn by both DEA Pharmacist Expert Donald Sullivan, DEA Judge Mark D. Dowd:
The AMA writes:
“The nation no longer has a prescription opioid-driven epidemic. However, we are now facing an unprecedented, multi-factorial, and much more dangerous overdose and the drug epidemic is driven by heroin and illicitly manufactured fentanyl, fentanyl analogs, and stimulants. We can no longer afford to view increasing drug-related mortality through a prescription opioid-myopic lens. This is why the AMA continues its aggressive advocacy efforts in support of patients with pain and those with a substance use disorder as well as broad support for harm reduction policies and practices that address the wide range of factors affecting patients. “
The nation’s opioid epidemic has never been just about prescription opioids, and we encourage CDC to take a broader view of how to help ensure patients have access to evidence-based comprehensive care that includes multidisciplinary, multimodal pain care options as well as efforts to remove the stigma that patients with pain experience on a regular basis. CDC has a great opportunity to demonstrate its commitment to patients with pain through a detailed re-examination of the CDC Guideline, and the AMA urges CDC to work with physicians and patients to ensure that the revisions support patients with pain and the physicians who care for them.”
The AMA further writes:
“We are concerned that such a careful approach to identifying the precise combination of pharmacologic options could be flagged on a prescription drug monitoring program as indications wrongly interpreted as so-called “doctor shopping” and cause the patient to be inappropriately questioned by a pharmacist. The AMA strongly supports a pharmacist carrying out his or her corresponding responsibility under state and federal law, but the past few years are rife with examples of patients facing what amounts to interrogations at the pharmacy counter as well as denials of legitimate medication. The AMA urges CDC to provide strong guidance and support for physicians and pharmacists to work together rather than jumping to conclusions about a patient’s PDMP report.” (2)
” Clinicians are encouraged to have open and honest discussions with their patients so as to avoid stigmatizing the decision to start, continue, or discontinue opioids or non-opioid therapy. This discussion also must account for the treatment options accessible to the patient based on their health condition, social determinants of health (e.g. transportation, employment, childcare responsibilities, race, gender, age) and insurance coverage.” (2)
THE DEA’S CADRE OF JUNK SCIENCE-TIERS AND SUPER DEFRAUDERS OF THE AMERICAN TAXPAYER’S MONEY
They’ve (DEA) exploited the use of a network of medical practitioner hustlers such as Donald Sullivan RPh., Phd., Timothy Munzing, MD., in Court Rooms who have been paid millions by the United States Federal Government see GovTribe. (1),(2),(3) Their testimony which often relies on tacit bias without examining radiographs (X-rays) the patients or interviewing prescribing practitioners in many cases are equivalent to the discredited bite mark evidence once used in courtrooms.
The DOJ, DEA idea is to starve us out of business through harassment, intimidation, and fraudulent misrepresentations by their network of so-called DEA experts like Timothy Munzing, MD. (1)
According to GovTribe, a website that tracks payments to federal contractors, Munzing is paid $300 an hour by the DEA. (1) In the past few months, Munzing has been paid over $250,000 by the DEA to review patient records and testify as an expert witness in DEA cases. (1)
Dr. Munzing who works with Kaiser Permanente and Donald R. Sulivan Professor at Ohio State University College of Pharmacy never appears to have examined or interviews the patients or prescribing physicians and relies conclusions on Junk Science in their Courtroom testimonies.
Jack Folson RPh., expert pharmacist Consultant from Michigan stated in his May 2020 report known as The Folson Amicus Brief:
Presently, because of the criminalization of pain management suffering has increased and has led, to an increase in Heroin use. Due to the dangers associated with heroin use this, more than anything else, in this case, is an immediate threat to public safety. To put it plainly the actions by the DEA are causing the thing that they are trying to avoid.
THE OHIO STATE UNIVERSITY PROFESSOR DONALD R. SULLIVAN IS AN ACADEMIC FRAUD AND SHOULD BE TERMINATED BY THE UNIVERSITY, WE RENEW THIS ARUGUMENT
DEA expert Don Sullivan must be brought before the Academic and Standard Review Committee at The Ohio State University for academic fraud. Donald Sullivan never interviews the patients nor their prescribing physicians in his narrative of irrevocable flags. Clearly his opinion was base on a tacit bias.
A group is renewing our complaint of Professional and Academic Fraud charges against the Ohio State University College of Pharmacy, DEA Expert, Clinical Professor Donald Sullivan. Who, in sworn testimony, admitted to not having interviewed any of the patients, nor their prescribing physicians, neither saw nor reviewed any of the patient’s prescriptions. Professor Sullivan opined every prescription to be illegitimate.
NATASHA DUVALL PHARMD, BLOOMFIELD HILL, MICHIGAN
I think for low hanging fruit, you are a scholar to be reckoned with. The court with their professional witness and the DEA should be embarrassed.
ELIZABETH GREEN DDS, MONTICELLO, FLORIDA
This unlawful practice of singling out black practitioners must stop. When will we be permitted to practice and provide for our families in the same way that white America does? As the Lord instructed Paul do not be afraid:
EUGENE RAVENEL SOUTH CAROLINA wrote:
It appears as if the judge believed Dr. Sullivans based upon two main points; 1. his position as a governmental position of status from DEA. 2. As someone whom he gave credence as the evidence for what was stated is not factual sound to bring charges. I am not an attorney but my understanding from reading this document supports my statements.
THE GORILLA THEORY
DEBRA H. GRANNY-NANNY BS, ANN ARBOR, MI
…….”I find Dr. Sullivan’s subject opinion, on the basis of this record, to be improperly speculative and unjustified as an expert opinion.”……..
When reading an excerpt from Judge Mark D. Dowd’s opinion, the fact that he bases his conclusion of law on Dr. Sullivan’s testimony that he found to be “improperly speculative and unjustified as an expert opinion …
……….”I question the sufficiency of the factual foundation for Dr. Sullivan’s expert opinion that the above prescriptions were an apparent attempt to mask scores of improper opioid prescriptions.“……..
…….“This finding does not affect the probity of Dr. Sullivan’s opinions as to the therapeutic effect of the subject medications, their contraindication with other prescribed medications, or the justification of their prescription.”……..
does not affect the probity of Dr. Sullivan’s opinions …” exemplifies the glaring reality that no matter what the scientific evidence says that supports a learned person of color, it’s not enough. White privilege supersedes it all.
DEB HARGROVE BS., THOMASVILLE, GEORGIA
Norm, this is another example of the verdict without fact, sense of justice, lack of academics, and total absence of righteousness. The foundation of THE SYSTEM is so eroded that a total defunding would aid rebuilding the brick and mortar basics that should have been, but not characterized in this case as of many others. I dare to say that the crumbling away of righteous judgment has brought us to the brink of self-annihilation.
Not only is the moral fabric of this system decayed, but the soul of civilization has stepped back into the darkest depths of “humanity”.Look around you. Can you see it? Can you feel that the heart of mankind is throbbing its last gasp for life? Money has been the lifeblood for this failing system, and man’s neglect for our duty to God is cancer. Yes, starve cancer and there may be a chance for renewed life.
WILLIE GUINYARD BS.POLITICAL SCIENCE, WILD WOOD, FLORIDA
In Jim Crow America we fought what was in our means to fight WE REFUSE TO ADOPT 3 part principle GANDHI OF NONE CORPORATION WITH THE ENEMY.
- NON CORRPORATION WITH THE ENEMY (salt)
The old master, he does anything he wants to do without any repercussions but looks in the direction of a white woman, any action on a par of Blackman he deems inappropriate especially toward a woman any action he would be hung from a tree. So looking at is these ways have continued because they haven’t been forced to stop. (3)
We didn’t refer to as probity we called it the “the good ole boy network” and we knew exactly what meant and how it works and we reduce it to a common say if you wanted to get ahead or get out of jail you had to have a: “good ole white bot to sponsor you” and to recently the end result of that was every black community the white folks had a black family or a black sponsor that they controlled and that was the modern-day version of the house nigger and person within that community Knew exactly whose those people were.
THE CONGRESSIONAL COMMITTEE ON GOVERNMENT OPERATIONS, COMMITTEE ON THE JUDICIARY, CONGRESSIONAL BLACK CAUCUS MUST BEGIN INVESTIGATIONS TO PUT AN END TO MEDICAL APARTHEID IN THE UNITED STATES OF AMERICA AND STOP THE TARGETING OF BLACK PHARMACIST AND DEFUND THE UNITED STATES DEPARTMENT OF DRUG ENFORCEMENT (DEA) IMMEDIATELY
FOR NOW YOU ARE WITHIN THE NORMS
- DEPARTMENT OF JUSTICE Drug Enforcement Administration [Docket No. 09–48]East Main Street Pharmacy; Affirmance of Suspension Order
On April 23, 2009, the Deputy Assistant Administrator, Office of Diversion Control, Drug Enforcement Administration, issued an Order to Show Cause to East Main Street Pharmacy (‘‘Respondent’’), of Columbus, Ohio. The Show Cause Order proposed the revocation of Respondent’s DEA Certificate of Registration, BE5902615, as a retail pharmacy, as well as the denial of any pending applications to renew or modify its registration, ‘‘for reason that [Respondent’s] continued registration is inconsistent with the public interest, as that term is used in
2. Drug Policy Alliance, public notice, Scandal Ridden DEA, Everything you Need to Know https://www.drugpolicy.org/sites/default/files/DEA_Scandals_Everything_You_Need_to_Know_Drug_Policy_Alliance.pdf
3. AMERICAN MEDICAL ASSOCIATION JUNE 16, 2020, https://searchlf.ama-assn.org/undefined/documentDownload?uri=%2Funstructured%2Fbinary%2Fletter%2FLETTERS%2F2020-6-16-Letter-to-Dowell-re-Opioid-Rx-Guideline.pdf
4. Drug Policy Alliance: Its time to Dismantle the DEA https://www.drugpolicy.org/DEA
6. IN THE MATTER OF Pronto Pharmacy, LLC 1461 West Busch Boulevard Tampa, Florida 33612
Certificate of Registration Number FP2302076, U.S. Department of Justice Drug Enforcement Administration Springfield. VA 22!52, August 23, 2019 ORDER TO SHOW CAUSE AND IMMEDIATE SUSPENSION OF REGISTRATION PURSUANT to Sections 303 and 304 of the Controlled Substances Act, Title 21. United States Code. Sections 823 and 824.
7. Deborah Dowell, MD, MPH June 16, 2020