vol1 - Page 338



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 I. Adequate Research, Including Double _
 Blind Studies_ Has Proven That Marijuana
 is Efficacious as an Antiemetic and in Some
 Cases Is More Effectiv_t__han Other Antiemetics.
 Sufficient and adequate research has been conducted to
 demonstrate marijuana_s antiemetic properties. These studies
 are thoroughly discussed in the Alliance's initial brief. 9-_/ DEA
 attempts to discredit this evidence by characterizing the
 research as primarily #loose and uncontrolledo mS/ DEA also
 argues that there are no double-blind studies showing marijuana
 to be more effective than any other antiemetic. 9-1/ These
 contentions are inaccurate and are discussed briefly, iD__%.
 a. State Studies
 DEA fails to comprehend the importance of the state
 studies in determining marijuanaes accep_=ed medical use in
 treatment as an antiemetic. DEA limits its discussion to trivial
 points on the implementation of these programs relating to
 #efficacy _ testing. What DEA fails to notice, however, is that
 these state programs were not intended to obtain NDA approval but
 rather ta provide critically ill patients with legal, medically
 supervised access to marijuana for use in treatment of their
 emesls,
 9__/ ACT Brief at 44-91.
 9__/ DEA Brief at 29.
 9// !Ao
 9__/ ACT Brief at III.
 _..i. _<9__-.




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