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NORMAN J CLEMENT RPH., DDS, NORMAN L. CLEMENT PHARM-TECH, MALACHI F. MACKANDAL PHARMD, BELINDA BROWN-PARKER, IN THE SPIRIT OF JOSEPH SOLVO ESQ., INC., SPIRIT OF REV. IN THE SPIRIT OF WALTER R. CLEMENT BS., MS, MBA. HARVEY JENKINS, MD, PH.D., IN THE SPIRIT OF C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., M.B.A., IN THE SPIRIT OF THE HON. PATRICE LUMUMBA, IN THE SPIRIT OF ERLIN CLEMENT SR., EVELYN J. CLEMENT, WALTER F. WRENN III., MD., JULIE KILLINGSWORTH, RENEE BLARE, RPH, DR. TERENCE SASAKI, MD LESLY POMPY MD., CHRISTOPHER RUSSO, MD., NANCY SEEFELDT, WILLIE GUINYARD BS., JOSEPH WEBSTER MD., MBA, BEVERLY C. PRINCE MD., FACS., NEIL ARNAND, MD., RICHARD KAUL, MD., IN THE SPIRIT OF LEROY BAYLOR, JAY K. JOSHI MD., MBA, AISHA GARDNER, ADRIENNE EDMUNDSON, ESTER HYATT PH.D., WALTER L. SMITH BS., IN THE SPIRIT OF BRAHM FISHER ESQ., MICHELE ALEXANDER MD., CUDJOE WILDING BS, MARTIN NJOKU, BS., RPH., IN THE SPIRIT OF DEBRA LYNN SHEPHERD, BERES E. MUSCHETT, STRATEGIC ADVISORS
ARUGUMENT
A Review and Analysis of the Fraudulent Testimony and Contradictions of the Ohio State University College of Pharmacy of Dr. Donald Sullivan, Ph.D., in the 2019 case D.E.A. vs Pronto Pharmacy, LLC et al. , Tampa, Florida 33612
David Edward Smith articulates in his April 14, 2025, filing NOTICE OF A REQUEST FOR AN ADMINISTRATIVE PROCEDURES ACT, SECTION 553(e), PETITION FOREVIEW OF THE RENEWAL OF THE DECLARATION OF A “PUBLIC HEALTH EMERGENCY” IN THE “OPIOID CRISIS”, to President Donald J. Trump, The White House – Office of the President, Robert F. Kennedy, Jr., Secretary, Department of Health and Human Services, Derek Maltz, Administrator, Drug Enforcement Administration, Pamela Jo Bondi, Attorney General, U.S. Department of Justice that;
“Overprescribing by physicians was never a causal factor in the increasing number of alleged ‘opioid deaths.” These falsehoods were first introduced into the official narrative during the legal battles against Purdue Pharmaceuticals, OxyContin, and the Sackler Family, which are still ongoing, 25 years after the alleged misconduct in advertising. (10)
Patients with chronic, intractable pain, cancer, end-of-life, and surgical pain, including children, the elderly, and military veterans, are being systematically denied access to necessary life-saving medications by these U.S. government policies that lack scientific support, not even aligning with the CDC’s own data. Furthermore, these harmful policies are not only failing to reduce the number of deaths from illicit fentanyl analog compound poisonings (the purported goal of the policies), but are also causing multiple tens of thousand of deaths of pain patients from medical complications or by suicide following the loss of access to life- saving opioid medication and other classes of controlled substances, and, some deaths after patients have been driven to the black market on the streets where they have purchased cartel medications tainted by illicit fentanyl analog compounds and other compounds in search of pain relief. These patient harms and deaths have not been acknowledged or tracked by any of the agencies or Congressional Committees involved.
The National Veterans Suicide Report published in December 2024 indicates that the number one thing associated with veteran suicide between 2020 and 2022 was pain!(11) What was not reported was that it is U.S. Government policies restricting access to proper, appropriate opioid pain relief that is causing the epidemic of untreated and undertreated pain, which is leading to these suicides.”
Also notably, from fiscal year (FY) 2002 through FY 2017, the U.S. government spent roughly $8.62 billion on counternarcotics efforts in Afghanistan. Despite this investment, Afghanistan remained the world’s largest opium producer, and opium poppy is the country’s largest cash crop.”
___________________________________________________________/
9 Peppin, J. F., & Coleman, J. J. (2021). CDC’s Efforts to Quantify Prescription Opioid Overdose Deaths Fall Short. Pain and therapy, 10(1), 25–38. Page 1. Available Online At: https://doi.org/10.1007/s40122-021-00254-z
10 Ibid .
11 2024 National Veteran Suicide Prevention ANNUAL REPORT, Part 2 of 2: Report Findings, Office of Suicide Prevention. December 2024, U.S. Department of Veterans Affairs. Affairs Available Online at: https://www.mentalhealth.va.gov/docs/data-sheets/2024/2024-Annual-Report-Part-2-of-2_508.pdf
CRITICISMS OF DEA JUDGE MARK D. DOWD
While Judge Dowd’s findings reveal inconsistencies and weaknesses in Sullivan’s testimony, the source criticizes Dowd for perceived bias and an “unbalanced application of the facts.”
Dismissal of Patient Travel as a “Red Flag”: Judge Dowd rejected Sullivan’s claim that the 38-mile roundtrip distance from a patient’s home to the pharmacy was a “red flag,” stating it was “not overly suspicious on its face.” However, he accepted the 134-mile distance from the patient’s home to the doctor’s office as a red flag. The source suggests Dowd was “so busy trying to be a bigot, so busy trying to be a racist” that he “couldn’t be fair.”
Disregarding His Own Findings on Sullivan’s Credibility: Dr. Joseph Webster, MD, points out Judge Dowd’s statement that “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.”
Dr. Webster interprets this as Dowd asserting Sullivan’s “subpar attempt to discredit Dr. Clement was carried out with honesty and strong moral principles,” despite earlier questioning his expert opinion.
Clinical Psychiatrist Dr. Muhamed Aly Rifai, MD (also a litigant and victim found not guilty of DOJ_DEA Abuses) in disbelief, stating, “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 … 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.”
Dismissal of Patient Travel as a “Red Flag”: Judge Dowd rejected Sullivan’s claim that the 38-mile roundtrip distance from a patient’s home to the pharmacy was a “red flag,” stating it was “not overly suspicious on its face.” However, he accepted the 134-mile distance from the patient’s home to the doctor’s office as a red flag. The source suggests Dowd was “so busy trying to be a bigot, so busy trying to be a racist” that he “couldn’t be fair.”
FINALLY
DONALD SULLIVAN: ORDER TO SHOW CAUSE AUGUST 29, 2019, PRONTO PHARMACY MILAGE AND DISTANCEMoneyballing Justice: How Data Scientists Crushed Anecdotal
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.
DEA Judge Mark D. Dowd writes in his recommended order May 05, 2020:
“I am not accepting Dr. Sullivan’s testimony that the round-trip 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 that 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)
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REFERENCES
The Probity and the Hubris: An Analysis of DEA Practices and Expert Testimony
Executive Summary
This document synthesizes a critical examination of the U.S. Drug Enforcement Agency’s (DEA) administrative legal processes, expert witness testimony, and underlying drug policy enforcement. The source material presents a central argument that the DEA engages in systemic practices rooted in racial bias, utilizes “junk science” from paid experts, and operates with a “presumption of guilt” that disproportionately targets Black medical professionals.
The analysis focuses on two DEA cases involving its expert witness, Dr. Donald Sullivan, whose testimony is characterized as fraudulent and perjurious. In a 2020 case, DEA Administrative Law Judge Mark D. Dowd is heavily criticized for simultaneously acknowledging the speculative and flawed nature of Dr. Sullivan’s opinions while paradoxically affirming their “probity” (honesty and moral principle). This contradiction is presented as evidence of “white privilege” controlling drug policy.
The document contrasts the DEA’s punitive approach and its “red flag” system with recommendations from the American Medical Association (AMA), which calls for more compassionate, individualized pain care and warns that the nation’s drug epidemic is now driven by illicit substances, not prescription opioids. The source culminates in a direct and urgent call for the U.S. Congress to investigate and defund the DEA to end what is described as “medical apartheid.”
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I. Central Figure of Contention: Dr. Donald Sullivan
The source document levels severe accusations of professional fraud, academic dishonesty, and judicial perjury against Dr. Donald Sullivan, a key expert witness for the DEA.
A. Professional Background
• Credentials: Dr. Sullivan is a Registered Pharmacist (R.Ph.) with active licenses in Ohio and Florida and holds a Ph.D.
• Academic Position: He served as an Associate Professor of Pharmacy Practice at Ohio Northern University (1997-2006) and was later appointed Full Professor and Chairman of the Department of Pharmacy. The source also identifies him as a Clinical Professor at The Ohio State University College of Pharmacy.
• Experience: Dr. Sullivan’s work experience includes retail and mail-order pharmacies, and part-time work for North Central Mental Health.
B. Allegations of Flawed and Inconsistent Testimony
Dr. Sullivan’s expert opinions are scrutinized across two separate DEA administrative cases, a decade apart, revealing a pattern of questionable legal and scientific assertions.
Case Study 1: DEA vs. East Main Street Pharmacy (2010)
In case docket 09-48, Dr. Sullivan testified on the concept of “corresponding responsibility” for pharmacists.
• Sullivan’s Incorrect Assertion: He claimed that under both Ohio and Federal law, responsibility is split evenly, stating, “50 percent of the responsibility falls on the pharmacy, the pharmacist, 50 percent falls on the physician.”
• Judicial Correction: The presiding DEA Judge in 2010 explicitly corrected this testimony, clarifying that Dr. Sullivan’s statement “is not a correct statement of the law.” The judge explained that Federal law imposes separate and independent duties, not an apportioned 50/50 responsibility. The ruling cited United States v. Hayes, stating a “pharmacist is not required to practice medicine.”
Case Study 2: DEA vs. Pronto Pharmacy LLC (2020)
In case docket 09-42 involving Norman J. Clement RPh, DDS, Judge Mark D. Dowd offered a multifaceted critique of Dr. Sullivan’s credibility and methodology, highlighting several significant flaws.
• Lack of Factual Foundation: Judge Dowd questioned the basis for Dr. Sullivan’s opinion that certain prescriptions were an attempt to mask improper opioid prescribing, noting, “The relevant medical records were not reviewed, the prescriber’s justification for the prescriptions was not considered by Dr. Sullivan, nor was the patient’s input as to the subject prescriptions considered.” He found the opinion to be “improperly speculative and unjustified as an expert opinion.”
• Ignorance of State Law: Judge Dowd found it “somewhat surprising” that Dr. Sullivan was unaware that Florida had codified a standard of care for medical personnel, especially since he teaches Florida pharmacy law.
• Inconsistent Testimony on “Red Flags”: Judge Dowd rejected Dr. Sullivan’s conclusions regarding “unresolvable red flags,” citing major inconsistencies. Dr. Sullivan initially described several red flags as impossible to resolve, only to later concede they could be resolved. Judge Dowd stated, “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.”
II. Judicial Scrutiny: The Rulings of DEA Judge Mark D. Dowd
The analysis of Judge Mark D. Dowd’s recommended order from May 2020 is central to the source’s argument of systemic bias. The critique focuses on a perceived contradiction in his assessment of Dr. Sullivan’s testimony.
A. The Contradiction of “Probity”
Despite enumerating multiple failings in Dr. Sullivan’s testimony—calling it speculative, lacking foundation, and inconsistent—Judge Dowd made a pivotal statement that the source frames as evidence of bias:
“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.”
Contributor Cudjoe Wilding argues this statement reflects an “unbalanced application of the facts,” suggesting Judge Dowd found Dr. Sullivan’s “subpar attempt to discredit Dr. Clement was carried out with honesty and strong moral principles,” while giving no such consideration to Dr. Clement’s 40-year career. Debra H. Granny-Nanny further contends this exemplifies that “White privilege supersedes it all,” regardless of scientific evidence.
B. Perceived Judicial Bias
The source posits that Judge Dowd’s actions are indicative of a deeply ingrained racial bias within the DEA’s judicial system. One passage asserts, “U.S. Administrative Law Judge Mark D. Dowd was so busy trying to be a bigot, so busy trying to be a racist… he couldn’t be fair.” The conclusion is that Dr. Sullivan “prevails solely on privilege and not on science or fact.”
III. Systemic Critique: Racial Bias and “White Privilege”
A core theme is that the DEA’s enforcement actions and administrative proceedings are a modern manifestation of systemic racism, described as “medical apartheid.”
• The Presumption of Guilt: Citing Harvard Law Professor Charles Ogletree Esq., the document argues that successful African American men are often judged “by the color of their skin rather than the content of their character.”
• “The Good Ole Boy Network”: Contributor Willie Guinyard equates the concept of “probity” in this context to the “good ole boy network,” where preferential treatment is given based on race and status, not merit or fact.
• Targeting of Black Practitioners: A quote from Elizabeth Green DDS states, “This unlawful practice of singling out black practitioners must stop.” Helena B. Hansen of New York University is cited to support the idea that drug use by people of color is governed by punitive systems, while addiction among whites is treated as a biomedical disease. The source notes that while Black Americans are no more likely to use illicit drugs, they are 6-10 times more likely to be incarcerated for drug offenses.
IV. The DEA’s “Red Flag” Doctrine vs. Medical Standards
The document juxtaposes the DEA’s rigid enforcement criteria with the patient-centric guidelines advocated by the American Medical Association (AMA), particularly in a June 16, 2020 letter to the CDC.
A. The American Medical Association’s (AMA) Position
The AMA’s letter argues for a fundamental shift in pain management policy:
• End the Prescription Opioid Focus: The AMA states, “The nation no longer has a prescription opioid-driven epidemic,” but now faces a more dangerous epidemic driven by illicit fentanyl and heroin. It criticizes the “prescription opioid-myopic lens” of current policy.
• Undo Damage from CDC Guidelines: The AMA recommends the CDC revise its 2016 guideline, which has been misapplied “to deny access to legitimate pain care and non-consensually taper patients.”
• Promote Individualized Care: The AMA advocates for treatment decisions to be made on an individual basis, recognizing that “some patients benefit from opioid therapy—including at doses that some may consider ‘high.'”
• Remove Barriers to Care: The AMA criticizes payers and policies that make non-opioid treatments financially or administratively unavailable, creating a “Catch-22” for physicians.
• Account for Social Determinants: The AMA states that treatment discussions must account for factors like transportation, employment, and insurance coverage.
B. Critique of “Red Flags” like Patient Travel Distance
Dr. Sullivan testified that patients traveling significant distances to a doctor and pharmacy is a “significant red flag” of abuse and diversion. However, Judge Dowd himself dismissed this in one instance, stating, “The 38 miles from M.M.’s home to the Respondent is not overly suspicious on its face.” The AMA’s position supports a more nuanced view, acknowledging that social determinants like transportation are valid considerations in a patient’s access to care.
V. The Use of “Junk Science” and Paid Experts
The source claims the DEA exploits a “network of medical practitioner hustlers” who provide testimony equivalent to “discredited bite mark evidence.”
• Methodology: These experts, including Dr. Donald Sullivan and Dr. Timothy Munzing, are accused of forming conclusions based on “tacit bias” without examining patients, reviewing X-rays, or interviewing prescribing practitioners.
• Financial Incentives: The document cites GovTribe, a federal contractor tracking website, to highlight the financial motivations of DEA experts. Dr. Munzing is reportedly paid $300 an hour and received over $250,000 in a few months to review records and testify for the DEA.
• Call for Academic Review: The document makes a direct demand that Dr. Sullivan “be brought before the Academic and Standard Review Committee at The Ohio State University for academic fraud.”
VI. Core Arguments and Calls to Action
The article consolidates its arguments through commentary from various contributors and concludes with a demand for radical institutional change.
A. Summary of Key Arguments
• Pharmacist’s Perspective: Jack Folson, RPh, argues that the criminalization of pain management has increased heroin use, making the DEA’s actions an “immediate threat to public safety.”
• Systemic Failure: Deb Hargrove describes the system’s foundation as “so eroded that a total defunding would aid rebuilding,” stating the “moral fabric of this system is decayed.”
• Ret. Neonatologist Keith Kanarek MD: States the DEA operates under “think and feel rather than fact-based on a foundation of science.”
B. The Central Demand: Investigate and Defund the DEA
The document culminates in an unambiguous call to action directed at multiple congressional bodies:
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.
