vol1 - Page 329

 Agency explains that, Since marijuana has no benefit, there is n_
 benefit to balance against risk and marijuana musts therefore_ be
 very risky indeed ands _unsafe for use under medical super-
 vision.-_/
 This sophistic syllogistic approach trivializes the
 important in favor of the insiqnificant and reveals the ethical
 and intellectual paralysis at the heart of the goverr_entSs cases
 Which is to say DEA's arguments lack balance.
 The State of New York recognized this tendency to
 exaggerate marijuana_s effects and emphasized the need for
 balanced assessment.
 It was extremely interesting to note that in
 the context of concern over the effects and
 side effects of [marijuana_ the fact that
 standard compounds have their own
 sidE6
 effects had largely been disregarded_ _/
 DEA fails to heed this advice and disregards the need
 to assess the safety of therapeutic substances relative to other
 treatments and against the certain conse,_ences of withholding
 treatmento k/
 _5_/ Id. at 120. (kiT]he risk/benefit ratio [for marijuana] is
 overwhelmingly negative. _)
 ___/ ACT Official State Reports, Vols IX_ Exhibit 16-C,
 _Impressions from the National Conference on the Therapeutic
 Applications of Cannabinoids_ x at 5.
 _7/ Rebuttal Affidavit of John Merritt_ _ 7o
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