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 marijuana is not a drug as defined by FDA (___o a syntheticall>
 manufactured, discrete chemical entity), but a substance (_e_, _
 plant) . 2_/
 D_A's claim that marijuana cannot be defined is
 preposterous. Over millennia, society has amassed extensive
 knowledge of marijuanaSs botany, _/ pharmacology3-0/ and
 therapeutic utilityo _-I/ Jean Barnhart_ a glaucoma patient_ Alie_
 O _ Leafy, an expert witness _ Dr. Tod Mikuriya _ Norman Farnsworth,
 Ph.D. and Raphael Mechoulam_ Ph.D. speak of the cannabis plant i_
 the same way Dr. Andrew Weil does or the Ohio Medical Society ants
 Dr. O'Shannessey did a century earlier or the Chinese did 50
 centuries agOo Lay persons, experts_ physicians, researchers,
 pharmacologists, chemists are all able to identify marijuana.
 The DEA's argument that there is not enough pharma-
 cologic information, that more animal studies are required_ that
 2Jq/ (...continued)
 make false or misleading claims .... The
 IND/NDA system assumes that the term _drug N
 means a synthetically manufactured_ single
 chemical product .... _Z_ _ 78-79.
 28/ Affidavit of Dr. John Moz_an, I_ 19_21- Discussion of
 Rsimples# and _arcana u schools of thought on the therapeutic use
 of natural substances as opposed to synt_etic drugs. See _Iso
 Affidavit of Mahmoud Elsohly_ PhoDo, _ 7o nThe Cannabis plant i_
 an annual weed .... #
 2_/ Affidavit of Mahmoud Elsohly_ Ph_Do, _ 2-4. The witness
 has researched marijuana botany for eleven years. Id. at _ 5.
 _Q/ Affidavit of Raphael Mechoulam, PhoD._ passim. Mechoulam
 lists scores of articles on cannabis pharmacology_
 2ul/ NORML E_hibit, Marijuana: Medical Papers, Mikuriya, T._
 (ed), Medi-Comp Press, San Francisco, 1973; NORML, DEA Exhibit,
 _annabinoids as Therapeutic Substances; Mechoulam, R., CRC Pres_i_
 Boca Raton, 1986.
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