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 petitioned the Bureau of Narcotic and Dangerous Drugs 2 to remove
 marijuana from the Controlled Substances Act schedules ore in the
 alternatives to transfer marijuana from Schedule I to Schedule Vo
 There followed a series of agency proceedings, agency decisions
 and remands by this court relating primarily to treaty issues.
 See National Orqanization for the Reform of Marijuana Laws v.
 inqersol!6 497 Fo2d 654 (DoC. Cir. 1974); National_Or_anization
 for the Reform of Marijuana Law_s vo Dru_ Enforcement
 Administrations 559 F.2d 735 (DoC. Cir. 1977) [hereinafter NORML
 v. DEAl.
 In 1979, the Administrator again denied NORML_s petitionf and
 this court remanded the case to the DEA and to DHHS for
 reconsideration of the relevant issues. National[ Orqanization
 for the Reform of Marijuana Laws vo Drug_ Enforcement
 Administration and Department of Health_ Education and Welfaret
 Noo 79-1660 (D.C_ Ciro Oct. 16, 1980).
 In 1983, after public hearings_ DHHS recommended to the DEA
 that all marijuana plant material remain in Schedule Io In 1986,
 the DEA published a notice of hearings on NOP_L_s original
 petition to reschedule marijuana and its components. In 1987,
 administrative hearings commenced on NORML':s amended petition to
 transfer the marijuana plant from Schedule I to Schedule II.
 Petitioner on appeal, Alliance for Cannabis Therapeutics (ACT) _
 joined NORML_s petition in the administrat:Lve proceedings. All
 2 Prior to establishment of the DEA_ the Attorney General
 had delegated his administrative authority under 21 UoS.Co 5 811
 to the Director of this Bureau. See 36 Fed° Rego 981-82 (]971).
 3




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