“..Find out just what a people will submit to, and you have found out the exact amount of injustice and wrong which will be imposed upon them, and these will continue till they are resisted with either words or blows or with both. The limits of tyrants are prescribed by the endurance of those whom they oppress..” frederick douglas
from youarewithinthenorms.com
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, IN THE SPIRIT OF 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
Donald R. Sullivan, Professor at Ohio State University College of Pharmacy, never appears to have examined or interviewed either patients or prescribing physicians and relies on Junk Science in his Courtroom testimonies.
YouAreWithinTheNorms offers a strong critique of the Drug Enforcement Administration (DEA) and its use of expert witnesses, particularly regarding the controversial testimony of Professor Donald Sullivan, demonstrating his sheer incompetence in cases against pharmacists. We highlight a conflict between the DEA’s interpretation of federal law regarding pharmacist responsibility for prescriptions and Sullivan’s testimony, which a DEA Judge sometimes deemed speculative and inconsistent.
A kangaroo court is an informal pejorative term for a court that ignores recognized standards of law or justice, carries little or no official standing in the territory within which it resides, and is typically convened ad hoc. A kangaroo court may ignore due process and come to a predetermined conclusion. Wikipedia
Furthermore, the text frequently links the DEA’s actions and previous conflicting (concocted) testimonies of Dr. Donald Sullivan, lacking clinical knowledge or scientific foundation, perceived judicial bias, except that it is based solely on issues of “White Privilege” and systemic racism; more than suggesting that Black practitioners are unfairly targeted. Finally, our sources include arguments from the American Medical Association (AMA), which challenges the DEA’s “Opioid War” strategy, asserting that the focus should shift away from prescription opioids and toward a broader, more compassionate approach to pain management and addiction treatment.
Critiques of DEA Expert Witness Donald Sullivan
(*S (SQUARE)JSMS*= SPEAD SHEET JUNK SCIENCE MEDICINE SYNDROME)
INTRODUCTION
A significant portion of the document focuses on discrediting Donald Sullivan, highlighting his complete, sheer, willful incompetence as a DEA expert witness against Dr. Norman J. Clement(pharmacist/dentist) and Pronto Pharmacy LLC. We have accused him and, more specifically, in other cases where his testimony has been sought by the government, of being purely unadulterated and concocted Junk Science.
Most notably in this case, “PROFESSIONAL, ACADEMIC FRAUD AND JUDICIAL PERJURY” and more importantly, being part of the DEA’s “Cadre of Junk Science-tiers and SUPER DEFRAUDERS of the American Taxpayers’ Money.”
BACKGROUND OF DR. SULLIVAN’S FALSEHOODS AND DECEPTIONS TO STATE AND FEDERAL COURTS
Contradictory and Speculative Testimony: Pharmacist Responsibility: In a 2010 case (DEA vs East Main Street Pharmacy), Dr. Sullivan testified that “50 percent of the responsibility falls on the pharmacy, the pharmacist, 50 percent falls on the physician.”
However, the DEA Judge in that case explicitly stated that “Federal law does not apportion the responsibility… Rather, Federal law imposes separate and independent duties.”
“Unresolvable Red Flags”: In the 2020 Pronto Pharmacy case, DEA Judge Mark D. Dowd notes that Dr. Sullivan “gave inconsistent testimony regarding unresolvable red flags. He described several red flags as unresolvable… Later, he conceded that those same red flags could be resolved.” Judge Dowd ultimately rejected Sullivan’s conclusions on “unresolvable red flags” due to “inconsistencies, in the absence of a reliable principle or method.”
Lack of Factual Foundation for Opinions: Judge Dowd “question[ed] 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,” noting that “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 concludes, “I find Dr. Sullivan’s subject opinion, on the basis of this record, to be improperly speculative and unjustified as an expert opinion.”
“Overprescribing by physicians was never a causal factor in the increasing number of alleged ‘opioid deaths.”
Lack of Knowledge of Florida Law: Judge Dowd points out Sullivan’s “diminished credibility” because “he was unaware that Florida had codified the standard of care for medical personnel,” despite teaching Florida pharmacy law. Sullivan also “arguably conceded an alternate generalized standard of care for pharmacists in Florida, which is not consistent with Florida law or regulation.”
Failure to Review Patient and Prescriber Information: Critics, including Jack Folson RPh. and other commentators, highlight that Dr. Sullivan “never interviews the patients nor their prescribing physicians in his narrative of irrevocable flags” and relies on “Junk Science in their Courtroom testimonies.”
Profiteering from Expert Witness Work: The document alleges that DEA “medical practitioner hustlers such as Donald Sullivan RPh., Phd., Timothy Munzing, MD., in courtrooms who have been paid millions by the United States Federal Government.”
ARUGUMENT
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.”
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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 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.
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
MEDIA’S FAILURE IS THE STORY FROM PLATO’S ALLEGORY OF THE CAVE
A federal jury acquitted Dr. Lesly Pompy (center) of unlawful prescribing, healthcare fraud, and maintaining a drug-involved premises after a month-long trial. Dr. Pompy was represented by Ronald Chapman II of the Chapman Law Group and founder of Chapman Consulting Group. George Donnini and Joe Richotte of Butzel Long also represented him.
THE DEA-DOJ PRESCRIPTION OPIOID HOAX AND THE WEAPONIZATION OF PAIN CARE
DR. FOREST TENENT, MD NEUROGENIC AND CONNECTIVE TISSUE DIEASE SPECIALIST HOME AND OFFICE RANSACKED BY DEA-FBI
