Divide opens over L.A. cannabis social equity licenses, management contracts

Published July 22, 2020, by John Schroyer

Months of anger over prized marijuana social equity licenses in Los Angeles boiled over recently, when the California Minority Alliance (CMA) accused a Black cannabis executive and his company of exploiting other minorities through “predatory” business deals.

The CMA made the accusations against 4thMvmt in an email to the L.A. City Council and the Department of Cannabis Regulation.

4thMvmt, founded in 2018 to help applicants navigate L.A’s social equity program and fund their efforts, is headed by CEO Karim Webb, who is Black.

The dispute highlights just how competitive and vitriolic Los Angeles’ cannabis licensing has become, with applicants who share a history of discrimination finding fault with each other’s bids to obtain the coveted permits.

In its allegations, the California Minority Alliance charged that Webb and 4thMvmt “tried to take advantage of their social equity partners with predatory agreements.”
“Let’s be clear, (City) Council, if this was a White person taking advantage of a social equity applicant it would be thrown out,” the email read. “Predators can also come (from) within our own community.”

In an emailed statement to Marijuana Business Daily, Webb called the CMA’s allegations “unsubstantiated and false.”

And 4thMvmt spokeswoman Ralina Shaw provided MJBizDaily with detailed explanations about the situation as well as testimonials on behalf of the company.

The CMA provided a redacted copy of one of the agreements in question, which the organization said was signed by one of 4thMvmt’s social equity retail partners.

The company’s social equity partners are in line for at least 13 retail licenses from L.A.’s licensing round, which opened in September 2019 to award 100 retail licenses. The City Council recently doubled the amount of permits it will offer to 200.

In total, 4thMvmt submitted 32 business applications.

The California Minority Alliance noted several points in the redacted agreement that it claimed were objectionable, including:

The contract mandates that a management company run the retailer’s day-to-day operations and that, according to the CMA, the social equity applicant will therefore have no real control over the business.
The arrangement includes a buyout provision allowing 4thMvmt to purchase the social equity applicant’s share of the company for $200,000, which CMA argues is far below the fair market value of a majority share in an L.A.-based marijuana retail shop.
4thMvmt would be able to sell its interest in the business at any point in time. If the social equity applicant wanted to sell, however, that person would need written consent from other company stakeholders, making it an uneven situation.The CMA also alleges it learned from multiple social equity partners of 4thMvmt that they were given only one hour to review the proposed deal and either sign on or reject it entirely.

And, according to the Los Angeles Times, there was no real opportunity for an attorney to review the agreement.

Accusations disputed

Webb, 4thMvmt’s CEO, declined an interview request from MJBizDaily but issued a statement pushing back against the CMA’s accusations.

“The lack of Black social equity success stories in the media is stark and obvious,” Webb wrote.

“It is despairing to see respected members of the media knowingly print unsubstantiated and false accusations from questionable sources because (they) will get views, instead of the diverse stories of triumph and life-changing social equity progress,” he said. “Sadly, this is yet another example of the systemic racism that pervades all aspects of our society.”

Cat Packer, the executive director of the L.A. Department of Cannabis Regulation, didn’t address 4thMvmt specifically when asked if she’d seen the California Minority Alliance’s allegation-filled email.

Rather, Packer emphasized that new regulations adopted recently by the city have more stringent requirements about social equity shares and operational agreements such as 4thMvmt’s.

“We are aware of concerns that stakeholders have about predatory practices in agreements,” Packer said. “What Council voted into law … seeks to directly address concerns that stakeholders have raised about the equity share definition.”

4thMvmt’s Shaw noted that the redacted agreement is now outdated because the company altered its contracts based on multiple changes the City Council made to the social equity program.

But after seeing a copy of the updated agreement, CMA co-founder Virgil Grant said 4thMvmt’s changes were negligible.

The upshot, he added, is “still, the social equity applicant has no say over the business.”

Shaw disputed that claim, saying, “All of our (social equity) partners have the majority control over their businesses.”

She noted that the updated contracts conform with city regulations and many key provisions have been altered.

For instance, she said, the $200,000 buyout provision has been changed to require that “fair market value” be provided to the applicant if a buyout takes place.

The reason the agreements were originally structured that way, Shaw explained, was to deter social equity applicants who might have viewed the opportunity as a way to “get a quick payday” by selling the license, pocketing the profit and walking away – instead of working to build a solid business.

As for why 4thMvmt gave social applicants so little time to review the operating agreements, Shaw said that situation arose from the timing of the licensing round and a city requirement that applicants already have real estate lined up.

Many of the property sales closed only two days before the application window opened Sept. 3, 2019, she said, so that left 4thMvmt – which paid for all the real estate – little time to finalize paperwork before the application deadline.

“Everybody said, ‘We’ve been with you for two years, we trust you, we’ll sign (the agreement),’” Shaw said, noting that 4thMvmt began recruiting and working with equity candidates in 2018.

Shaw countered the CMA’s allegations by providing testimonials from four of 4thMvmt’s social equity partners, including three who are in line to receive retail permits from the fall licensing round: Phyllis Dorsey, Khadijah Allen and Cameron Hart.

Outside lawyers split over nature of contract

Two attorneys who have worked on similar social equity contracts for other companies disagreed on whether the CMA’s allegations were backed up by the redacted operating agreement.

Ilya Ross, a lawyer who’s worked on social equity deals in Los Angeles and Massachusetts, sided with the CMA’s views of 4thMvmt’s agreements.

“It’s certainly not the most equitable arrangement I’ve seen,” Ross said, “and there are provisions in there that take advantage of the social equity partners more so than your average partnership agreement.”

He called some of the provisions “super predatory” and added, “giving them an hour without really the flexibility to negotiate, that is predatory.”

But Michael Chernis, a longtime marijuana business attorney based in Los Angeles, said the agreement was “on the whole, not that unusual.”

“The reality is that this is the social equity deal. You have one party putting up all the money … and the party that’s putting up all the money wants to protect itself,” Chernis said, referencing 4thMvmt.

“Nobody is going to put up millions of dollars for 50% of interest in a business and not try to protect its investment.”

Although Chernis viewed some of the provisions as “aggressive,” he said it appears the CMA “cherry-picked” information from the agreement.

“A lot of this,” Chernis said, “goes right back to: Did (the social equity applicants) have a chance to have this reviewed with a lawyer, and what the circumstances of that were.”

John Schroyer can be reached at johns@mjbizdaily.com

Posted in News

Los Angeles proposes ‘major course change’ for cannabis business licensing, social equity

Published June 22, 2020 | By John Schroyer, MJBizDaily

In a series of recommendations to the Los Angeles City Council, L.A.’s Department of Cannabis Regulation proposed an immense overhaul of its marijuana business licensing structure and social equity program.

The DCR’s proposals are set to be taken up Tuesday by a City Council committee.

The recommendations, if adopted, could be far-reaching for many marijuana entrepreneurs hoping to win a city business license. The recommendations were both hailed and derided by industry officials after their release.

Supporters say the DCR’s recommendations represent a fulfillment of the city’s widely criticized social equity program.

But critics argue they will wreak further havoc in the industry by disenfranchising legacy operators who don’t qualify for social equity and haven’t yet obtained city permits.

The recommendations, sent to the City Council on June 16, are the first major move made by the DCR since the completion of an independent audit in March of its latest licensing round for 100 retail licenses last fall. City licensing has been on hold since then.

The recommendations include:

    • • Allowing applicants and businesses to relocate within the city; currently, applicants are required to find a location and stick with it through the licensing process.
      • Granting temporary approval for all social equity license applicants.
      • Limiting new storefront retail licenses and delivery licenses to social equity applicants until 2025.
      • Improving processes to minimize “predatory practices”in the social equity program.

    The proposals must still be approved by the City Council before being implemented, and it’s unclear whether the council will choose to rubber-stamp the changes or approve some and reject others.

    The recommendations will first be taken up on Tuesday morning by the council’s Rules, Elections and Intergovernmental Relations Committee.

    The DCR declined interview requests from Marijuana Business Daily to clarify or explain many of its recommendations.

    But, asked if the “temporary approval” for all applicants meant the DCR was suggesting an increase in the number of licenses available, an agency spokesman wrote in an email that “many licensing and social equity program stakeholders have expressed support for additional retail licenses to be made available, and the Department agrees that it’s an issue worth deliberate consideration by policymakers.”

    Still, many observers believe that’s a nonstarter based on the political dynamics of the City Council, which has been reluctant to significantly expand the number of legal marijuana business permits.

    The DCR’s recommendations were also announced on the heels of a motion that, if adopted, would restart the licensing process for the 100 retail winners from last September’s social equity retail permit round. The motion was submitted by L.A. City Councilman Marquees Harris-Dawson.

    Those 100 have been in limbo for more than nine months while the licensing process has been on hold, meaning they haven’t been able to open their stores.

    Harris-Dawson’s motion will also be considered Tuesday by the Rules Committee, making it unclear what the full council will do with the DCR’s proposals.

    Spokespeople for Harris-Dawson and the other two members of the committee did not respond to a request for comment.

    Mixed reactions

    “I think it’s fantastic,” industry consultant Lynne Lyman said of the DCR’s recommendations. She’s been active for years in L.A. cannabis politics and now works with industry clients.

    “It’s like this big omnibus fix for the whole ordinance, and it really re-creates the social equity program to make it work, because it has not worked.”

    Others, however, said the recommendations would disenfranchise anyone who isn’t a qualified social equity applicant, since the DCR proposes to give all future retail permits only to social equity recipients.

    That would leave out many legacy dispensary operators who have been waiting for more than two years for their chance at a permit, since the current licensing window – Phase 3 – was supposed to have a round open for the general public.“This is a major course change, because you’re saying, if you’re not a social equity applicant, you can’t get a license, at least until 2025,” said attorney Michael Chernis, who has clients both in the social equity program and outside it.Chernis emphasized he supports the social equity program but said this approach would “cut off any chance for anyone but a social equity applicant to get a retail license, a non-storefront retail license or, as far as I can tell, any license for five years.”“My initial reaction is it’s really unfair to people who are not social equity applicants, because there are a lot of people who were waiting patiently to be licensed … resisting the temptation to operate illegally in the hopes of becoming licensed,” Chernis said.Adam Spiker, the executive director of the Southern California Coalition, echoed Chernis’ point and said it would be unfair to ask legacy operators who had run medical marijuana dispensaries in the city for years before 2018 to give up at least 51% ownership in their companies in exchange for a social equity partner – a requirement to get a permit if the City Council adopts the DCR proposals.

    If that’s the case, Lyman said she’s fine with it. She said much harm was done to minorities during the war on drugs, so granting permits only to social equity applicants would be tantamount to affirmative action.

    “This is what affirmative action looks like in practice, and it’s the right thing to do,” Lyman said.

    Lawsuit still a possible factor

    Another issue the council might have to consider while pondering the DCR’s recommendations is an ongoing lawsuit from one of the social equity applicants who’s asking the courts to force L.A. to redo last fall’s licensing and throw out the 100 retail winners.

    That suit has the potential to upend the licensing process in an even more disruptive way if the plaintiff in the case, actor Madison Shockley III, wins.

    Currently, the case is set for a July 9 hearing for a requested preliminary injunction against the city, and an injunction could mean further licensing delays until the case is finished.

    The case is scheduled for a trial conference in September.

    “The fact that we have this injunction hearing is … the first recognition of our argument we’ve been making the last eight months – that this wasn’t a fair process,” Shockley said.

Posted in News

Los Angeles: Phase 3 Update

By Michael Chernis, December 17, 2019

The path towards a legal adult-use cannabis market in Los Angeles has been littered with obstacles and challenges, and in November 2019, another roadblock emerged, as the City announced an audit to its commercial cannabis program and suspended further licensing pending that audit.

After processing license application for certain pre-existing cannabis operators in Phases I and II, on a priority basis in 2018, for both retail and non-retail, Los Angeles first opened applications for new cannabis retailers with Phase III in September 2019. The Phase III round 1 application window started at 10 a.m., September 3, 2019 and ended September 17, 2019. 100 licenses were available in Round 1 to verified social equity applicants, first-come first-serve to those who were first able to submit a complete application on DCR’s Accela portal for a compliant location. The application was extremely competitive; 300 applications were received within 93 seconds of the Accela portal’s opening. 802 total applications were received for 100 available licenses.

After the close of the Phase III round 1 application window, stakeholders raised concerns about the fairness of the application process, specifically about alleged early access to the Accela portal and DCR’s response to these deficiencies. On October 24, 2019, DCR Director Cat Packer presented at the Cannabis Regulation Commission meeting about this issue, and reported that while all applicant access to Accela was supposed to have been disabled from August 28, 2019 until 10 a.m. on September 3, 2019, two applicants obtained several minutes’ early access to the Accela portal by resetting their passwords and were able to submit applications before 10 a.m.

Because these applicants received early access, DCR apparently adjusted their submission timestamps by adding the amount of time taken to submit their applications to a 10:00 a.m. baseline and reviewing those applications in the order they would have been reviewed after making the adjustment.

After the discovery that some applicants received early access, stakeholders became distrustful of DCR because DCR did not admit the early access or its adjustments. Concerns were raised that other applicants received early access, that timestamps were given arbitrarily, and that automated systems were used to submit applications. Demands were made for a do-over.

On November 18, 2019, DCR Director Cat Packer released a press statement about this issue, and reported that Mayor Eric Garcetti had called for an audit of Phase 3 Round 1’s application process and suspended future Phase 3 processing until the audit had been completed. According to the release, DCR will continue to review and process Phase 3 round 1 applicants in the released Review Order for eligibility to receive an annual license (e.g. whether the proposed location is acceptable for undue concentration and sensitive use), but will not move on to the annual application process until the audit is complete.

Then yesterday, on December 16, 2019, the Los Angeles Times printed an article https://www.latimes.com/california/story/2019-12-16/cannabis-activists-marijuana-licensing-applications-los-angeles  documenting at least a dozen other applicants who were able to access Acela early.  There is renewed outrage over the fact the DCR did not disclose this information sooner, and renewed demands for a “do-over.”

What this means for those persons seeking to apply for retail licenses, delivery-only licenses, and even non-retail licenses in Phase 3, is that the timing for those processes to begin are on an indefinite hold.  According to Ms. Packer, “the Department will not continue to the next phase of licensing until the audit process is complete.” The timing for completion of the audit is unknown, and then once the audit results are released there likely will be further delays while the results of the audit are processed and reviewed both by the City Council and the public.  There is also the possibility of lawsuits challenging the City Council decision, whichever way it goes.  Unfortunately, unless the City Council makes changes to the ordinance to allow non-retail aspects of Phase 3 to proceed, the whole process could be delayed at least 6 months, or longer should litigation ensue.

You are invited, however, to share your frustrations, and concerns, with the DCR by emailing them at cannabis@lacity.org.   In addition, the DCR ostensibly is exploring ways to make legislative changes to the application system and welcomes that feedback as well.

Obviously, this delay is a real setback, especially for those of you with real estate locked up.  One possible alternative is to seek licensing opportunities in other jurisdictions.

If we can help with this, or in answering any questions about Phase III, please let us know.

Posted in News

Important Information for Los Angeles Phase II Licenses

By Michael Chernis, December 12, 2019.

Upcoming Deadline Extended for Phase II Applicants:

All Phase II applicants: rest easy for the holidays, but plan and prepare big for the new year.

Los Angeles Department of Cannabis Regulation (DCR) on December 11, 2019 has granted every Phase II applicant who has not yet received Temporary Approval for Non-Retailer Commercial Cannabis Activity an extension of the deadline to request a DCR inspection, from December 13, 2019 to March 01, 2020. Furthermore, the deadline to pass the inspection has been extended from December 31, 20to March 31, 2020.  The full release by DCR can be accessed here https://cannabis.lacity.org/blog/dcr-grants-extension-phase-2-applicants-regarding-pre-licensing-inspection

DCR granted this extension after recognizing challenges Phase II applicants faced to pass a DCR inspection by the end of 2019. However, this extra time likely means DCR will have higher expectations when conducting its inspections.

Inspection Details: How to Request and Next Steps After Inspection

To request a DCR inspection, email dcrlicensing@lacity.org with the subject line “Request for Pre-Licensing Inspection. Application No. LA-C-18-XXXXXX-APP.”

After requesting a DCR inspection, within 1-2 weeks DCR will email back with potential inspection dates, and requesting you provide DCR the following:

1. A current premises diagram reflecting the facility as it is built-out, and
2. A lease or purchase agreement for your premises.

After you reply with the requested information, DCR will send a final email confirming the date, time and address for your appointment (your premises address).

To move onto the next step of Phase II licensing, you must complete TWO inspections: DCR and Los Angeles Fire Department (LAFD). You must complete both by March 31, 2020. Each inspection has a different focus, detailed below.

After DCR’s inspection, a copy of your DCR inspection checklist will be uploaded to your Accela portal, informing you of any noted deficiencies. Whether those deficiencies will be correctable depends on their severity (see the sample checklist for examples). However, you must later correct these deficiencies and schedule a subsequent inspection to confirm their correction.

After your LAFD inspection, LAFD will notify DCR. Any LAFD deficiencies will also have to be corrected, and another inspection scheduled with LAFD to confirm their correction.

Once you have completed both the DCR and LAFD inspection, DCR will email you a request to send DCR a copy of your State license. After you send DCR a copy of your state license, DCR will issue your Temporary Approval, allowing you to apply for and receive a Phase II annual license.

DCR Inspection: DCR has circulated a checklist of items (see below) they will be examining during inspection. We suggest you review it carefully. DCR’s primary focus will be on potential for crime or diversion of cannabis, so ensure your facility is built-out as described in the premises diagram given to DCR and your security system is functional.

On inspection day, DCR requests that you prepare the following for convenience of the inspectors:

1. Have a hard copy of your current premises diagram on hand at the facility.
2. Have your designated Point of Contact be on the premises.
3. Have the security camera room and footage be available for viewing.
4. Give timely, unrestricted access to the business premises.

Fire Inspection: LAFD’s inspection will focus primarily for your premise’s safety for its inhabitants and risk for fire.

Information about LAFD’s inspection, including an inspection checklist, can be found at www.lafd.org/cannabis. Email lafdcannabis@lacity.org for information about LAFD’s inspection, or Johnny Gatlin, an LAFD inspector for the San Fernando Valley, Johnny.gatlin@lacity.org. If permits or fire approval is required (e.g. for a CO2 extraction system), email LAFDDSS@lacity.org.

If you would like assistance with this process, or have any questions about Phase II, please let us know

 

Michael Chernis

 

 

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Not Quite Legal In All 50 States, Part 1

By Michael Chernis, Esq., Chernis Law Group P.C., Santa Monica, California

Cannabidiol (CBD) is the new rage in the alternative treatment of various health conditions. It is increasingly associated with treating serious illnesses, and alleviating ordinary symptoms of illnesses, without creating the high or psychoactive effect of its cannabinoid sister THC. And, unlike THC products, which will practically always violate the Federal Controlled Substances Act (CSA) there is a colorable argument as to why CBD products derived from Industrial Hemp are federally legal. In fact, in this past year, CBD products have become pervasive on the shelves of national retail supermarket and drug store chains, and of course in wellness spas.

The visibility of these products on the shelves of national retail outlets and leading spas leads one to conclude they must be legal. And indeed, it is common for purveyors of CBD products to market them as legal in all 50 states. The legality of these products is far more complex.

Historically, the federal government treated CBD no differently then THC, and thus considered it to be a Schedule I controlled substance. This was based on the premise that CBD could only be derived from the flowering portions of the Marijuana plant, as opposed to portions of the plant not considered illegal, and thus constituted illegal Marijuana under the CSA.

This changed in 2014 when Congress in the 2014 Farm Bill gave federal protection to “Industrial Hemp.” While Industrial Hemp is still a cannabis plant, it refers to strains of the plant that only produce .3% of THC or less, and thus do not tend to create any psychoactive effect. In 2014, it thus became federally legal to grow Industrial Hemp through a State approved program, known as a “pilot program.”

The 2014 Farm Bill, however, did not expressly provide federal protection for derivatives of State-approved Industrial Hemp, such as CBD or extracts containing CBD, as distinguished from the plant material itself. In the 2018 Farm Bill, Congress expressly made all derivatives and extracts of Industrial Hemp federally legal. While the 2018 Farm Bill still leaves it up to individual states to permit or prohibit the cultivation of Industrial Hemp, all states are prohibited from interfering with the transport across that State of Industrial Hemp or derivative products. However, to be clear, that does not mean it is legal to sell CBD products in every state, as an individual State may still prohibit cultivation and sale of CBD and Industrial Hemp products within its borders, even if it must allow the transport of the products across State lines. And a handful of states, including Idaho, still treat CBD no different from illegal marijuana and prohibit its sale.

Thus, the claim that a CBD product is legal in all 50 states is simply, untrue. It is thus incumbent on a retailer, including a spa owner, to ensure that the state they operate in does not regulate CBD products more stringently then the federal government. This is not difficult to ascertain, although it may require consultation with a lawyer.

There are two other points to be aware of regarding the legality of CBD products under the 2018 Farm Bill. First, the 2018 Farm Bill replaces State cultivation “Pilot Programs” with broader programs that must be approved by the US Department of Agriculture, and which must include among other things testing protocols for Industrial Hemp. However, the USDA is still in the process of passing its own regulations, and will not approve any State programs until federal regulations are in effect. Until then, 2014 Farm Bill Pilot Program Industrial Hemp is still legal federally. The distinction is not terribly important, except in those States, like Idaho, which take the position that while the 2018 Farm Bill mandates it must ultimately allow transport of Industrial Hemp across its border, Pilot Program Hemp does not merit the same protection. This is an uncommon position, is at odds with USDA’s own view of the law, and merely emphasizes the need to know the laws in place in your State.

The second and even more complicated nuance, is that the 2018 Farm Bill, while expanding federal protection for Industrial Hemp and derivatives, does not alter or pre-empt the FDA regulatory authority concerning CBD products. The FDA has taken the position that any ingestible product containing CBD is illegal. This issue will be addressed in Part 2 of this series

Posted in News

Feds Keep Seizing Lawful Hemp Imports, CBD Co. Tells Court

Law360 (October 21, 2019, 6:07 PM EDT) — U.S. Customs and Border Protection will likely continue to seize lawful hemp shipped from foreign countries, a hemp importer said in a brief filed Monday in California federal court, giving renewed urgency to its proposed class action seeking an injunction against federal authorities.

California-based Innovative Nutraceuticals told that court that its putative class action should proceed as a single case because, among other reasons, the CBP continues to restrict the import of hemp nationwide, despite the passage of two federal farm bills that broadly legalized the crop.

The 2014 farm bill legalized the cultivation of hemp, defined as cannabis with less than 0.3% concentration of THC on a dry weight basis, for limited, industrial purposes. The 2018 farm bill kept the same legal limit of THC, while expanding legal protections for hemp by removing it from the Controlled Substances Act.

“The seizures are part of a pattern of officially sanctioned behavior violative of the federal rights of [Innovative] and the class members,” the filing said. “Since the defendants have repeatedly engaged in these injurious acts in the past, and have continued to do so, there is a sufficient possibility they again will engage in them.”

The brief is the latest volley in a suit initiated in July 2018 after federal authorities seized four shipments of foreign hemp bound for Innovative at airports in California, New Jersey and Kentucky between 2015 and 2018.

The hemp, which had been intended for the processing of CBD, was in violation of the Controlled Substances Act because it contained trace amounts of THC, the psychoactive component of cannabis, authorities said at the time. But the seized hemp had THC levels that were within legal limits as dictated by the 2014 farm bill, Innovative said in court documents.

In their second amended complaint, filed in July, Innovative said that seizures of legal hemp and CBD have continued even after the passage of the 2018 bill.

Innovative is seeking injunctions granting the return of seized hemp and compensatory damages on behalf of any parties who had their hemp or CBD confiscated by CBP or its parent agency, the U.S. Department of Homeland Security, since July 2012. Innovative also sought an injunction barring the federal authorities from seizing shipments of hemp or CBD in the future.

The government moved in September to dismiss most of the claims in the second amended complaint, arguing that Innovative lacked standing or that the cases should be litigated separately in the jurisdictions where the seizures actually took place.

Michael Chernis, an attorney for Innovative, told Law360 in an email that the government’s assertions were flimsy “technical arguments, along the lines of our client failed to touch third base before heading home.”

“In this way, the government is advancing a policy of CBP being beyond legal review. Fortunately, we don’t believe any of their arguments have merit, and firmly believe that this case will proceed one way or another, despite the government’s stalling efforts,” Chernis said.

An attorney with the U.S. Department of Justice, representing the government entities, did not immediately respond to a request for comment Monday.

Innovative is represented by Michael S. Chernis of Chernis Law Group PC, Paul L. Gabbert of Paul L. Gabbert Law Offices and Eric Honig of the Law Office of Eric Honig PLC.

The government is represented by Jasmin Yang, David M. Harris and Joanne S. Osinoff of the U.S Attorney’s Office for the Central District of California

The case is Innovative Nutraceuticals LLC v. United States of America et al., case number 5:18-cv-01400, in the U.S. District Court for the Central District of California.

–Additional reporting by Diana Novak Jones. Editing by Alanna Weissman.

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