“WE ARE PHYSICIANS, PHARMACISTS, DENTISTS TREATING PATIENTS IN NEED OF PAIN CARE WITH MEDICATIONS NOT STREET DRUG DEALERS AND TRAFFICKERS”
A Republication of the TRUTH: originally published August 2020
“Falsus in uno, Falsus in omnibus”
BY
NORMAN J CLEMENT RPH., DDS, NORMAN L.CLEMENT PHARM-TECH, MALACHI F. MACKANDAL PHARMD, BELINDA BROWN-PARKER, IN THE SPIRIT OF JOSEPH SOLVO ESQ., IN THE SPIRIT OF REV. C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., MBA., IN THE SPIRIT OF THE HON. PATRICE LUMUMBA, IN THE SPIRIT OF ERLIN CLEMENT SR., WALTER F. WRENN III., MD., WILLIE GUINYARD BS., JOSEPH WEBSTER MD., MBA, BEVERLY C. PRINCE MD., FACS., RICHARD KAUL, MD., LEROY BAYLOR, JAY K. JOSHI MD., MBA, ADRIENNE EDMUNDSON, ESTER HYATT PH.D., WALTER L. SMITH BS., IN THE SPIRIT OF BRAHM FISHER ESQ., MICHELE ALEXANDER MD., CUDJOE WILDING BS, MARTIN NDJOU, BS., RPH., IN THE SPIRIT OF DEBRA LYNN SHEPHERD, BERES E. MUSCHETT, STRATEGIC ADVISORS
THIS PRESENTATION IS A VIDEOS NARRATIVE THAT SUPPORTS THE FOUNDATION OF THIS ARTICLE
THE CONGRESS MUST INVESTIGATE AND DEFUND THE UNITED STATES DRUG ENFORCEMENT AGENCY (DEA)
THE PROBITY PART-TWO
Currently, there is a disturbing trend within DEA whereby medical practitioners are being targeted. A campaign of false information has been generated and disseminated to sway the public into believing that these medications are on par with street drugs; dangerous drugs that contribute to abuse and trafficking and the so-called ‘Opioid crisis’ in America.
According to Richard Lawhern Ph.D., an unpaid patient advocate, on public policy for the regulation of prescription opioid pain relievers and doctors who employ them.
The US faces a real public health crisis in addiction and overdose deaths. But this crisis was not caused by evil Pharma companies or doctors “over-prescribing” to patients. CDC published data prove this beyond contradiction. Before 2010, the crisis was partially fed by the diversion of prescribed drugs through pill mills. After 2010, there is no cause-and-effect relationship between prescribing versus overdose-related mortality. As acknowledged even by the DEA, the present opioid crisis is dominated by illegal street fentanyl, heroin, and Meth, not by prescription medications. Yet every week we see more suicides by pain patients whose doctors can no longer prescribe them the only medications that work.
DONALD SULLIVAN’S LONG HISTORY OF PROFESSIONAL, ACADEMIC FRAUD, AND JUDICIAL PERJURY
“FALSUS IN UNO, FALSUS IN OMNIBUS”
Donnie Sullivan is a Professor of Clinical Pharmacy at The Ohio State University College of Pharmacy. He received his bachelor’s, master’s, and doctorate degrees from The Ohio State University College of Pharmacy. He has been at The Ohio State University for 3 years. He also taught at Ohio Northern University for 17 years. He has taught in multiple courses in their module curriculum. His research interests include drug diversion analysis and education, future pharmacy practice initiatives, pharmacoeconomics, educational development of pharmacy students and pharmacists, and medication error prevention. (2)
EXPOSING THE SULLIVAN’S FRAUDULENT TESTIMONY
ORDER TO SHOW CAUSE AND IMMEDIATE SUSPENSION OF REGISTRATION OF PRONTO PHARMACY LLC AUGUST 23, 2020
Dr. Sullivan will testify that he reviewed dispensing and prescription logs and patient information maintained by Respondent and provided to him by DI Albert. He will testify that he also reviewed the Florida PDMP report of Respondent’s dispensing behavior. He will testify that he concluded that Respondent repeatedly filled prescriptions for controlled substances without resolving obvious red flags of abuse and/or diversion and in violation of the pharmacist’s “corresponding responsibility” under federal law. Dr. Sullivan will testify that Respondent violated the minimum standard of care for a Florida pharmacy and operated outside of the usual course of professional practice.
DEA’S expert Dr. Sullivan’s courtroom testimony has been troubling, fraudulent, and appears to rely solely upon the abuse of his white privilege and probity as the foundation for his credibility. Don Sullivan has failed basic standards of care as a Pharmacist.
Dr. Sullivan’s methodologies are wrong, in that it doesn’t capture sufficient information to conclusively establish the illegitimacy of a prescribing practitioner’s reasoning for issuing a specific prescription to a patient for a specific disease state.
- He freely admitted in his testimony he had not reviewed any prescriptions. Yet, he opined repeatedly in the Pronto Pharmacy Order To Show Cause; “The DEA’s expert (Dr. Donald Sullivan) reviewed the above-referenced prescriptions and concluded that they presented numerous red flags that were highly indicative of abuse and diversion.”
- If Dr. Sullivan, reviewed no prescriptions, then how could he have drawn any conclusion indicative of abuse and diversion?
- Dr. Sullivan presents with a long history of fraudulent testimony. Dr. Sullivan false testimony in 2010 DEA vs Harold Eugene Fletcher Columbus, Ohio sent Fletcher to prison for nearly 2 years.
Dr. Donald Sullivan is a super defrauder of the United States taxpayers’ money. No evidence can be found in Dr. Donald Sullivan’s evaluation, or his court testimony was he had performed the minimum requirements of a licensed Florida registered pharmacist under Florida, Law 64B16-27.831 to:
- Initiate communication with the patient or the patient’s representative to acquire information relevant to the concern with the validity of the prescription,
2. Initiate communication with the prescriber or the prescriber’s agent to acquire information relevant to the pharmacist’s concern with the validity of the prescription.
According to GovTribe, a website that tracks payments to federal contractors, like Donal Sullivan who is paid $300 an hour by the DEA. However, oftentimes their testimony relies upon tacit bias as they fail to get consent to order a second opinion examination, review radiographs (X-rays) of the patients, or in so much as interview the prescribing practitioners.
These so-called experts then base their conclusions on sloppy scientifically flawed evidence methodologies which in many cases are similarly equivalent to the discredited bite mark evidence protocols, once used by forensic dentists in courtroom proceedings.
More importantly, the taxpayers of the United States of American paid for Dr. Sullivan’s travel to Tampa, Florida in January 2020, wherein sworn testimony he perjured himself. Dr. Sullivan has monetarily defrauded the United States Government and the American people.
“FALSUS IN UNO, FALSUS IN OMNIBUS”
DEA DON SULLIVAN ON DISTANCE TRAVELED
“FALSUS IN UNO, FALSUS IN OMNIBUS”
Dr. Don 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. (3)
“FALSUS IN UNO, FALSUS IN OMNIBUS”
DEA’S DONALD SULLIVAN RED FLAG OF DISTANCE TRAVEL
In the below video (img-9157) Mr. Gerald R Kiley identifies himself and states he has been coming to Pronto Pharmacy for nearly 2 years. Mr. Kiley, further states he has difficulty getting his prescription fill for narcotic analgesic medication because pharmacists would frequently tell him they don’t have the medication and are not getting it in. Mr. Kiley states he travels to Pronto Pharmacy because he is treated with dignity and respect.
In the below video Gerald R. Kiley states were referred to Pronto Pharmacy by a friend who has his prescriptions filled (at Pronto Pharmacy). The friend also had difficulty getting their medications filled at other pharmacies because of availability.
Mr. Kiley is shown the August 23, 2020, Order to Show Cause and we discuss with him cash payments. Mr. Kiley states he has to pay in cash because he has no insurance.
However, the DEA’s expert Donald Sullivan opined that “traveling long distances 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”. The facts to support the probable cause cannot be justified by mere suspicion. Walter R. Clement, a law enforcement experts states:
“DEA’s expert Donald Sullivan opined “that it can be a red flag of abuse.” This Cannot support an express intent that a crime is or was afoot. Thus, it cannot establish probable cause. In fact, the DEA statements that ‘long distances using GOOGLE MAPS “can be” a red flag of abuse and diversion,’ is a clear application that fails to supports Responsible Suspicion.
The Red Flag of distance serves as a discussion point in pharmacy. Primarily there are absolutely no State or Federal laws that limit a patient to 30 to 35 miles to fill any prescription by any licensed pharmacy and the DEA, very well knows that fact. We see this in the cross-examination of DEA Diversion Investigator Richard James Alpert, by Dale Sisco in an Administrative court hearing held January 28, 2020, in Tampa, Florida;
Mr. Sisco: Based upon your training, education, and experience, is there a federal statute or regulation that geographically limits the area in which a pharmacy can dispense?
DI Albert: Not to my knowledge.
Mr. Sisco: To your knowledge based on your training, education, and experience, is there a Florida statute that limits the geographic area in which a Florida pharmacy can dispense prescriptions?
DI Albert: Not to my knowledge.
Richard Albert’s testimony was a stunningly profound admission of wrongdoing because each Black-owned pharmacy business that was raided, had their Federal Control Registration removed and suspended, charged as being a threat to public safety, along with the recommendation for revocation, based on non-existent distance travel laws. (4)
This is further evidence that supports Congressional Investigation by the House Committee on the Judiciary, House Government Operation Committee which will expose DEA’s waste, fraud, and abuse, and most important, The House Government Committee on Homeland Security.
WARRANT FABRICATION
DI Alberts admission further undermines the testimony of DEA Pharmacy expert Donald Sullivan who testified to a limit of 35 miles on the January 29, 2020 hearing in the matter of Pronto Pharmacy.
The State of Florida is a big player in the practice of Mail Order Pharmacy and as such provides medications (controlled and non-controlled) to patients in other states. This in and of itself should invalidate the red flag of distance since this practice is condoned and supported by the Florida State Legislature and the Florida Board of Pharmacy. To discriminate against Florida Pharmacies treating Florida patients is grotesque.
LISTEN TO THE WORDS OF RONALD MYERS MD IN THIS INTERVIEW FROM PAIN PATIENT ADVOCACY WEEK IN 2017
Dr. Ronald Myers was a leading advocate for health care to the poor and disenfranchised. The founder and chairman of The American Pain Institue and the Myers Foundation For Indigent Health Care and Community Development.
A 1985 graduate of the University of Wisconsin Medical School and residency in Family Practice at L.S.U. Medical Center, Doc Myers was a leading national advocate for health care to the poor and disenfranchised. In 1990 he became the first ordained and commissioned medical missionary to serve in America’s poorest region, the Mississippi Delta, in the history of the African American church. Dr. Myers provided health care to the poorest Americans through clinics in Tchula, Belzoni, Yazoo City, Indianola, Greenville, and Tupelo, Mississippi. He went on missions outreach to Kenya and Israel.
Yet in the eyes of the United States, Drug Enforcement Agency and the Department (DEA), this brilliant medical clinician was another uppidity-arrogant N-word who needed to be taught a lesson, criminalized, and imprisoned. Listen to this 2017 interview with Linda Cheeks, MD., from “Doctors with Courage.” of our hero Ronald Myers MD.
WITH LINDA CHEEKS MD
Rev. Ronald V. Myers, Sr., MD was a family practitioner in Mississippi. He lost his license because of attacks on him by the state of Oklahoma. The charges were dropped, but his license was never restored to active status because of fines levied on him by the Board of Medicine for the unfounded investigation they led against him. In other words, “Pay us for attacking you without just cause.”
DEA’S Donald Sullivan EXCESSIVE CASH PAYMENT
The DEA’s expert opined that this is a significant red flag 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.
DR. SULLIVAN WILL TESTIFY THAT CASH CAN BE RED FLAGS OF ABUSE AND DIVERSION
Dr. Sullivan will testify that patients willing to pay such extremely inflated prices in cash for controlled substances are a potential red flag for abuse or diversion because customers taking prescriptions for legitimate medical needs would not pay such extreme prices for medication that can be purchased elsewhere for a fraction of the amount. Dr. Sullivan will testify that Respondent nevertheless repeatedly dispensed controlled substances to such cash-paying patients without resolving or addressing this red flag.
THE DEA’S GOES BEYOND THEIR SCOPE TO REGULATE COMMERCE THEN LATTER DROPS THIS CHARGE IN THEIR COMPLAINT AGAINST PRONTO PHARMACY
The DEA’s expert Donal Sullivan opined that cash payments can be a red flag of abuse or diversion because patients typically have to pay very high prices for drugs that are not covered by insurance.
Dr. Sullivan will further testify that prices charged by the Respondent were excessive. Dr. Sullivan will testify that, according to the 2018 National Community Pharmacists Digest Financials, the average pharmacy makes a 22% gross margin (profit) on prescription drugs. According to their dispensing data, Respondent was making a 91% gross margin (profit) on every prescription it compounded and dispensed for hydromorphone 8mg capsules.
The below prescription shows the prescriber has noted this patient has no prescription insurance “[SAVING FOR UNINSURED PATIENTS]”, and is being treated for non-acute Pain. DEA Expert, Clinical Professor Donald Sullivan, 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.” (5)(6)
This testimony is an even more stunningly profound admission of wrongdoing on behalf of the DEA and Donald Sullivan and further exposes him as being noncredible. Pronto Pharmacy LLC’s business that was raided, had their Federal Control Registration removed and suspended, charged as being a threat to public safety, along with the recommendation for revocation, based on a non-existent review by Donald Sullivan and a nonexistent distance travel laws. (4)
Again, this is more evidence that supports Congressional Investigation by the House Committee on the Judiciary, House Government Operation Committee which will expose DEA’s waste, fraud, and abuse, and most important, The House Government Committee on Homeland Security.
Most importantly this type of deception, waste, fraud and abuse has gone on for years and is supported by the United States Attorneys Office warrant defunding of The United States Drug Enforcement Agency.
Pronto Pharmacy LLC Tampa, Florida, ORDER TO SHOW CAUSE AND IMMEDIATE SUSPENSION OF REGISTRATION, August 23, 2019:
18. The DEA’s expert Donald Sullivan opined that cash payments can be a red flag of abuse or diversion because patients typically have to pay very high prices for drugs that are not covered by insurance. The DEA’s expert noted that, on average, approximately 11 percent of all prescriptions filled by independently owned pharmacies in 2018 were paid for in cash nationally.
THE UNITED STATES DOLLAR VS. DONALD SULLIVAN, AND DEA
Jack Folson pharmacist expert writes:
The USD or United States Dollar, which is the fiat currency of THE UNITED STATES OF AMERICA has a statement on every denomination. It says, “THIS NOTE IS LEGAL TENDER FOR ALL DEBTS PUBLIC AND PRIVATE.” (14)
According to 31 U.S. Code § 5103, United States coins and currency (including Federal reserve notes and circulating notes of Federal reserve banks and national banks) are legal tenders for all debts, public charges, taxes, and dues. Foreign gold or silver coins are not legal tender for debts. The prevailing sentiment on this is that all United States money as identified above is a valid and legal offer of payment for debts when tendered to a creditor. (14)
There is, however, no Federal statute mandating that a private business, a person, or an organization is prohibited from accepting currency or coins as for payment for goods and/or services. (4)
RED FLAGS OF EXCESSIVE CASH AND DIVERSION
In the below video Mr. Kiley states “I take my medication and I take them as prescribed.” Mr. Kiley also states, ” I’m 61 years old and I’m falling apart.”
The American Medical Association writes June 16, 2020:
The AMA continues to support physicians’ use of effective PDMPs and offers new caution based on physicians’ and patients’ experience since the publication of the CDC Guideline in 2016. We continue to urge the CDC to recognize that PDMP data is only one type of information to help guide a physician’s clinical decisions. Moreover, it is only one piece of data available to pharmacists and any other authorized user of a state PDMP. Yet, PDMPs have been used to inappropriately tag physicians as “inappropriate prescribers” by pharmacy chains and patients as “doctor shoppers” by some pharmacists. The AMA does not support illegal activity, but a PDMP report, by itself, is almost always insufficient to identify illegal behavior. (13)
While PDMPs can help identify patients receiving multiple prescriptions from multiple prescribers or dispensers, and this behavior is a risk factor for unintentional overdose, we believe the steps to be taken after identifying such individuals are much more complex and require further research and attention. While it is an important variable to quantify, we are concerned that PDMP reports have been used to deny care to patients—by physicians and pharmacies. Physicians are understandably afraid that a PDMP report identifying them as a “top prescriber” will result in investigations by law enforcement or a medical licensing board without taking into account the physician’s patient population. In turn, a patient who has multiple prescriptions from multiple prescribers and/or pharmacies needs treatment, not law enforcement intervention. The AMA urges CDC to support this public health focus. (13)
GERALD KILEY VS DONALD SULLIVAN “I’M BEING PROFILE”
DRUG MEDICATION PROTOCOLS
Dr. Sullivan will testify that it is a well-known red flag that the dispensing of a disproportionate number of prescriptions for the highest strength available for a particular controlled substance is a sign of illicit activity.
Dr. Sullivan has testified that there are “red flags” that pharmacists need to recognize and consider before they dispense a prescription. ” As examples, he testified that pharmacists are “required to do drug utilization review on every prescription * * * before it is dispensed in the pharmacy” to determine whether “doses * * * are too high, duplicate therapy, potential use or misuse [sic], [and prescriptions are] being filled too soon.” Additional red flags include “[m]aximum doses being seen for every single patient, lack of individuation of therapy, certain patterns from physicians of potential abuse of seeing the same types of controlled substances over, and over, and over, again.”
THE CONSEQUENCES OF DEA’S DR. DONALD SULLIVAN’S FRAUDULENT DRUG UTILIZATION REVIEW AND TACIT BIAS OF GERALD R KILEY’S MEDICAL CONDITION
DONALD SULLIVAN RPH., PHD., AND THE FOLSON AMICUS BRIEF
Jack Folson pharmacist expert:
There are a plethora of double-blind studies that conclude that the combination of several combinations of oxycodone, hydrocodone, gabapentin, cyclobenzaprine, ibuprofen, ketoprofen, alprazolam, temazepam, oxazepam, baclofen, and others have increased efficacy in terms of pain management and the management of comorbidities commonly associated with pain, inflammation, and paralysis. There are competing step care protocols in use in hospitals, home infusion, and community Pharmacy and therefore to criminalize the ones being used in these cases without the benefit of the patient interview or prescriber input would raise serious doubts about this red flag. The current information that the DEA uses to evaluate the use of opioids in the treatment of chronic pain is geared towards primary care practitioners and not specialists. (14)
ORDER TO SHOW CAUSE AND IMMEDIATE SUSPENSION OF REGISTRATION OF PRONTO PHARMACY LLC AUGUST 23, 2020
ExcessiveDispensing of High Strength Controlled Substances: The DEA’sexpert Donald Sullivan opined that it is a well-known red flag that the dispensing of a disproportionate number of prescriptions for the highest strength available for a particular controlled substance is a sign of illicit activity. TheDEA’s expert noted that virtually all of the prescriptions for oxycodone and hydromorphone that Pronto Pharmacy “compounded” during that time frame were for oxycodone 30 mg immediate-release and hydromorphone 8 mg immediate-release (the highest strengths for these controlled substances).
Dr. Sullivan will testify that a common red flag of abuse or diversion is when a physician prescribes “cocktail medications,” which are combinations of controlled substances that are widely known to be abused or diverted, and which significantly increase a patient’s risk of morbidity or overdose. Dr. Sullivan will testify that Respondent repeatedly dispensed high doses of oxycodone or hydromorphone along with high dosages of other central nervous system depressant medications, such as benzodiazepines (e.g., alprazolam). Dr. Sullivan will testify that these controlled substances are dangerous when used in combination. For example, when opioids are combined with benzodiazepines, a patient’s risk of overdose by respiratory depression increases dramatically. Dr. Sullivan will testify that Respondent repeatedly filled prescriptions without resolving the red flag of “cocktail medications
The DEA has no supportive measures to apply further or support their claim that a crime was committed. Their tacit applications can be applied to any retail outlet. Whereby the acts and application and their idea of enforcement are so vague, that it strikes at the core values of our law. This agency can no longer be entrusted to protect and serve the citizenry. Their conduct throughout the nation strikes fears in that a law enforcement agency can act at will to claim that a citizen violated the law by merely stating that a specific law was violated. With no supporting facts and or articulations of how the citizens violated the law, this agency acts at will. With little and no restraints. (9)
In 2010, Dr. Sullivan testify in court East Main Street Pharmacy Dr. Sullivan admitted that he had probably not filled a pain medication prescription in approximately twelve years, id. at 977, and that this report represented his first determination that ‘‘a pharmacy is abusing controlled substances.’’ Id. at 990. However, he had previously filled ‘‘probably 1,000’’ prescriptions for oxycodone and thousands of prescriptions for alprazolam.
When asked on cross-examination if he knew what break-through pain is and whether he was aware that Dr. Volkman ‘‘practiced pain breakthrough type treatment,’’ Dr. Sullivan explained that there is no such separate specialty in pain management and that this ‘‘is when a patient is on a dose of medication and they are having flare-ups in pain, then another drug is given to help on a temporary acute basis to take care of that pain flare.’’ Tr. 1027.
He further stated that such treatment regimens were sometimes seen ‘‘in hospice patients and cancer patients.’’ Id. at 1028. Respondent did not establish that Volkman was legitimately prescribing multiple drugs for this purpose.”
In the video (img_9185-mov)Mr. Kiley states in the video he has other medical conditions that require the use of medications
In the next video (img_9189) Mr. Kiley asked, “is there any place he can go to get his medication filled.”
Mr. Gerald R. Kiley (IMG-9190-MOV) permitted me to use this video as he wants the world to see his suffering from DEA’s expert Donald Sullivan’s tacit bias.
THE GRAPHIC RESULTS OF DONALD SULLIVAN’S LONG HISTORY OF PROFESSIONAL, ACADEMIC FRAUD, AND JUDICIAL PERJURY
The last video (img_9191-mov) supports why DEA must be Congressional Investigation as they illegally redefine medical procedures and cause patients like Mr. Kiley to suffer unnecessarily because of stigmatization.
CONCLUSION
THE CONGRESS MUST INVESTIGATE AND DEFUND THE UNITED STATES DRUG ENFORCEMENT AGENCY (DEA)
LACK OF RESULTS
The DEA’s rogue practices have not only undermined the rule of law, but they have also failed to deliver their intended result, cutting off the supply of drugs. Even as its operating budget has swelled and it sent a steady stream of people to prison, increasing violence and instability at home and abroad, the supply of drugs entering the United States has never significantly declined. (12)
According to the DEA’s own “2019 National Drug Threat Assessment” the “opioid threat (controlled prescription drugs, synthetic opioids, and heroin) continues at ever-increasing epidemic levels, affecting large portions of the United States” and “The stimulant threat (methamphetamine and cocaine) is worsening and becoming more widespread.”
After billions of dollars spent on their futile drug war, drugs remain cheap, potent, and widely available.
A New Approach: Defund and Reinvest
For too long the DEA has abused its powers, misspent taxpayer funds, fueled mass incarceration, and ignored civil rights.
It’s time to dismantle and abolish the DEA. We need to pivot to a health-based approach to address addiction and improve social conditions that contribute to problematic drug use.
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 PHARMACISTS AND DEFUND THE UNITED STATES DEPARTMENT OF DRUG ENFORCEMENT (DEA) IMMEDIATELY
FOR NOW, YOU ARE WITHIN
THE NORMS
ENDNOTES
2. https://www.deadiversion.usdoj.gov/fed_regs/actions/2010/fr1027_3.htm
3. otsc-order-to-show-cause-immediate-suspension-of-registrationOrder to Show Cause Pronto Pharmacy “Imminent Danger to Public Safety
4. Exposing the Rise and Mission of the filter negroe, https://youarewithinthenorms.com/2020/06/18/of-role-models-and-invisible-men-exposing-the-rise-and-mission-of-the-filtered-negroes/
5. https://www.govinfo.gov/content/pkg/FR-2010-10-27/pdf/2010-27096.pdf, pg. 6157 Judges footnotes; Donald Sullivan background, testimony history of misrepresentation, case#09-48, East Main Street Pharmacy, Columbus, Ohio,
6. Pronto_Recommended-Rulings-copyJudge-down_recommended_ruling/may 5,2020
10. https://abcnews.go.com/US/wireStory/retired-dea-agents-agency-legacy-discrimination-71326557
https://docushare-web.apps.cf.humana.com/Marketing/docushare-app?file=3524820 Every Pharmacy system in America has the ability to track override codes.
11. https://www.nytimes.com/2018/09/17/opinion/drugs-dea-defund-heroin.html
12. https://www.drugpolicy.org/DEA
13. 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
14. https://youarewithinthenorms.com/2020/06/09/the-folson-amicus-brief/
