vol1 - Page 319



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 I_I . STANDARDIZATION
 DEA initially argues modern science demands only pure
 chemicals be used for therapeutic purpoSeSo _-_/ DEA witness
 Raphael Mechoulam, PhoD., testified, #[M]arijuana cannot be
 defined-chemically [nor can it be_ standardized with ease_ #_/
 deflned DEA could
 This i_nonsense. If marijuana could not be _ " w
 not arrest individuals for possessing_ selling, importing or
 .......
 transpol_cing marijuana. Since DEA does arrest people for
 _marijuana _ it must be assumed marijuana cans in facts be
 defined. 2_/
 The Controlled Substances Act [CSA) requires that
 _druqs or substances _ be Scheduled° The fact that marijuana is
 scheduled defines it as either a drug or a substance. Since
 marijuana is a plant _= an organic_ comple x substance -- and does
 not fit into regulatory schemes designed to monitor the for_
 profit production of chemically simple, manufactured medicines
 (i____, drugs)_7/ the Alliance will acknowledge what is obvious;
 24/ DEA Brief _ 19-22 at 12_14_ 97°
 '_ .... 2_/ Affidavit of Raphael Mechoulam, Ph..D., at 9.
 __/ DEA Brief at 4.
 2__/ Affidavit of Dr. Denis Petro, _ 7S_80. Dr_ Petro, a
 former Consulting Clinical IHD/NDA Review Officer for the FDA_
 states:
 The IND/NDA system is not designed to
 scientifically assess the therapeutic utility
 of medicinal substances° Instead, this
 system is designed to requlate the commercial
 marketing of pharmaceutical products_ and to
 protect the public against manufacturers who
 (continued...)




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