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MATTHEW PAPPAS (SBN: 171860) CHARLES SCHURTER (SBN: 174261) LEE H. DURST (SBN: 69704) 22762 Aspan Street, Suite 202-107 Lake Forest, CA 92630 Phone: (949) 382-1485 Facsimile: (949) 242-2605 Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION

GREEN EARTH CENTER, INC.; DANK CITY PATIENTS GROUP INC.; NATURECANN, INC.; INDUSTRY GREEN COLLECTIVE, INC.; KAI KEM INC.; CHRONIC COLLECTIVE; COMPLETE ALTERNATIVE MEDICINE; PATIENTS REPUBLIC COLLECTIVE; 562 COLLECTIVE; DEMITRI WOODARD and CHRIS WOODARD, Plaintiffs, v. CITY OF LONG BEACH, CALIFORNIA; DAVID STROHMAN; OSCAR VALENZUELA; ALDO DECARVALHO; CHRIS VALDEZ; DOUGLAS LUTHER; and DOES 1 to 10, Defendants.

No.: SACV 13-0002 AG (JPRx)

PLAINTIFFS EXHIBITS (VOL. 3) IN SUPPORT OF APPLICATION FOR T.R.O. AND O.S.C. RE: PRELIMINARY INJUNCTION

Date: May 9, 2013 Time: N/A Courtroom: D10, Judge Guilford

EXHIBIT VOLUME #3

PLAINTIFFS EXHIBITS (VOL. 3)

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TABLE OF EXHIBITS (VOLUME 3)

EX. #: 43

DESCRIPTION DECLARATION OF JOSE BUSTAMANTE DECLARATION OF ADRIAN DIAZ (MAR. 8, 2013) DECLARATION OF ADRIAN DIAZ (APR. 11, 2013) DECLARATION OF A. GONZALEZ (MAR. 8, 2013) DECLARATION OF A. GONZALEZ (APR. 11, 2013) DECLARATION OF CAROLINA LOPEZ (MAR. 8, 2013) DECLARATION OF C. SEGOVIA (APR. 11, 2013) DECLARATION OF CLAUDIA PARRA (OCT. 31, 2012) DECLARATION OF EDGAR SANCHEZ (MAR. 8, 2013) DECLARATION OF MCCABE KAINOA (APR. 11, 2013) WARRANT FOR SEARCH AND SEIZURE CONDUCTED OCTOBER 4, 2012 (FOURTH ST. COLL.) WARRANT FOR SEARCH AND SEIZURE CONDUCTED MARCH 5, 2012 (FOURTH ST. COLL.) WARRANT FOR SEARCH AND SEIZURE CONDUCTED APRIL 12, 2013 (FOURTH ST. COLL.) WARRANT FOR SEARCH AND SEIZURE CONDUCTED APRIL 23, 2013 (FOURTH ST. COLL.) WARRANT FOR SEARCH AND SEIZURE CONDUCTED OCTOBER 31, 2012 (WILLOW COLL.)
PLAINTIFFS EXHIBITS (VOL. 3) - II

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DECLARATION OF YVONNE SCHAFFER DECLARATION OF JUAN HUIZAR DECLARATION OF MARK MALAN LONG BEACH WARNING THAT WATER WILL BE SHUT-OFF TO FOURTH STREET COLLECTIVE DECLARATION OF LARRY PARKS LETTER FROM ATTORNEY MATTHEW PAPPAS TO ATTORNEY PAUL VIOLAS RE: FOURTH STREET COLLECTIVE MANAGING PATIENT LARRY PARKS

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ADDITIONAL EXHIBITS ARE INCLUDED IN VOLUMES 1, 2, 4, 5, 6, & 7

PLAINTIFFS EXHIBITS (VOL. 3) - III

EXHIBIT #43

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DECLARATION OF JOSE BUSTAMANTE 1. 2. 3. 4. I, JOSE BUSTAMANTE, declare as follows: I am a resident of Los Angeles CA. I volunteer at the 4th St. Collective front

through our

On March 5th, 2013 the Long Beach Police Department slammed door rushing into the second where they all They demanded we open the

had weapons drawn pointing them at us.

last door. As we opened it they rushed the security guard by

putting a handgun to his face and forcing him to the floor. The second officer ran to me with a shotgun screaming to get on the floor. As I got on the floor they handcuffed me and all of the other volunteers and patients in the room. They sat us on the floor while they integrated the patients. They then brought in

volunteer in from outside that was going home . They then stated to take one by one out side so the undercover could verify us . They then interrogated us and asked questions as they placed us one by one in police cars. They then began to take us to the station.

I declare under penalty of perjury under the laws of the State of California personal knowledge and is true and correct. EXECUTED this 22nd day of October, 2012: that the aforementioned statement represents my

/S/
_____________________________________________ JOSE BUSTAMANTE

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DECLARATION OF ADRIAN DIAZ I, Adrian Diaz, declare as follows: 1. I am a resident of Long Beach, CA. 2. I am a volunteer at The Willow Collective. 3. To whom it may concern; On March 8, 2013 LBPD rushed into The Willow Collective around 1:30 pm while I was volunteering. They came in with guns drawn very aggressively in an unlawful manner. I was sweeping the floor when I seen the first officer get buzzed in through our secure door yelling at the other volunteers and Patients we all put our hands up. Once I heard the officer say that I quickly put my hands up in the air cooperating. Then the second officer behind him rushed towards me because I was the nearest to him and forcefully threw me up against the wall handcuffing me right away. After the handcuffs were on the officer started screaming in my face asking me how long I've been volunteering and also stated that I was going to a prison for a very longtime. When he told me that I clearly stated to him that I was practicing my Fifth amendment rights and that I wasn't comfortable answering any questions till my lawyer was present. That's when he took me to the lobby to sit me down and take my information. He then took my id from my pocket with all my info on it and started to question me after I stated that I was remaining silent. The officer asked me basic questions like whats my name ? and address? and I just replied all my info is on my id and stood silent. After that he kept harrassing me trying to get me to talk but I just stood quiet and then he stated out loud " OH YOU'RE ONE OF THOSE FUCKING GUYS". I felt like my rights were being violated. Then they placed me in the back of one of the vehicles with two other volunteers with no seat belts. On the way to the station I didn't feel safe the officer was speeding a little while on his phone not keeping his eyes on the road. During the whole process I felt as of all my rights were completely thrown out the window. I declare under penalty of perjury under the laws of the State of California and United States that the aforementioned statement represents my personal knowledge and is true and correct. DATED: April 23, 2013 ___________________________________________ Adrian Diaz

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DECLARATION OF ADRIAN DIAZ 1. 2. 3. 4. I, Adrian Diaz, declare as follows: I am a resident of Long Beach, CA. I am a volunteer at The Willow Collective. To whom it may concern; On April 11th, 2013 LBPD burst into The Willow Collective around 2:30pm in a disrespectful and unlawful manner with guns drawn while I was volunteering. As the officers were busting into the collective our security guard mentioned on the walkie-talkie that we were getting raided. So knowing ahead of time before the officers were inside I had already put my hands in the air. Once the officers got inside they came in screaming for all of us to put our fucking hands up and swearing a few other words. Then they quickly put the handcuffs on me tight using excessive force. I knew that I wasn't doing anything wrong because I was cooperating with them they were being really disrespectful and rude from the start. After that they sat me down and thats is when one of the cops in uniform recognized me from the previous raid and stated a little remark " you haven't learned your lesson" while laughing with other officers. Then one of the detectives in street clothes took a patient that they had in custody and I to the back outside in the alley for about 20 sec without saying anything to us. I'm guessing they were trying to identify us or take pictures of us but it seemed a bit weird. After that they placed me in the backseat of a vehicle with another volunteer and again with no seat belts I didn't feel safe on the ride to the station. The officer was on his phone the whole way there. Then after the officers finished booking me and were about to hand me

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over to the correctional officers a detective approached me to read me my rights and tell me why I was being arrested. I declare under penalty of perjury under the laws of the State of California and United States that the aforementioned statement represents my personal knowledge and is true and correct. EXECUTED this 23RD day of April, 2013:

___________________________________________ Adrian Diaz

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DECLARATION OF ALEJANDRO GONZALEZ 1. 2. 3. 4. I, Alejandro Gonzalez, declare as follows: I am a resident of Long Beach, CA. I am a volunteer at The Willow Collective located at 726 I was present at The Willow when it was raided by the It was between 1:20-1:30pm

W. Willow St. Long Beach Ca. LBPD on Friday, March 8th 2013.

when I was sitting at the front check-in window talking with my friend Carolina when all of a sudden the police burst through the front door into the waiting area flashing to get in through the second door down. wall to. a warrant and with their guns drawn and pointed at us, demanding door or they would break the We faced the and with Once We were all being very cooperative.

and put our hands on our head before they even told us They cuffed all five of us very tightly the front lobby.

excessive force and placed us into we were all secured, all the They

officers were joking around

and talking down at us and calling us low-life drug dealers. brought us back one-by-one for questioning. The rights was When I refused to answer Strohmans to my lawyer, he gave me a dirty detective asking me questions and reading my Detective Strohman. questions and referred him

look and then took me back to the lobby. After attempting to question the rest of the detained he told us out loud that we will be forced to sign a stay away three year probation. be facing jail time. order that came with a He said if we didnt sign it we would I was taken away with two others in

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one squad car whi ile the two rema aining w were brought in after. a I declare under penalty p of perju ury unde er the laws of t the Stat te of Califor rnia and d United States of Amer rica tha at the aforementi ioned st tatement represe ents my persona al knowle edge and d is true an nd corre ect. EXECUTED this t 23rd day of o April, 2013:

__ _________ ________ ________ _________ ________ _______ Alejandro Gonzale ez

DECLAR RATION OF ALEJANDRO A G GONZALEZ (A APRIL, 2013) - 2

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DECLARATION OF ALEJANDRO GONZALEZ 1. 2. 3. 4. I, Alejandro Gonzalez, declare as follows: I am a resident of Long Beach, CA. I am a volunteer at The Willow. It was Thursday, April 11th 2013 around 2:20 to 2:30 pm. I was in the front

check in room and heard the walkie-talkie utter words very quickly. The next thing I know, my buddy said we are being raided then the cops burst in the door with weapons drawn yelling for us to put our hands up. They presented the warrant to the check in window, so therefore they were allowed in guns drawn made us face the walls put our hands behind our backs, then one by one they put on cuffs very tightly on each of us, then walked us to the lobby where we had no vision of what they were doing, Then one of the taller detectives in regular clothing walked three of us to the back as if he had somebody identify us from a distance and he told me" i recognize you, you are on the stay away order your fucked now" and i responded " I am under no stay away order what so ever i did not sign anything" he responded almost yelling i will make sure your are this time " and got all up in my face! Then they took us back to the front during so you could hear that they started to tear the place up i have some pictures from when i returned they made a huge mess counters moved everywhere, phone and internet wires disconnected broken jars on the floor, broken glassware as well, there was about five to six uniformed officers, and about 4 detectives in regular clothing, the whole time these police officers were joking around after they had secured us in cuffs, were making rude remarks about how they have seen us before, and that we do not learn our lessons, they were raising their voices as well, they took 2 of the volunteers first, along with a member of ours, they had my security guard outside, then they took about an extra half hour with me and my friend carolina hand cuffed, they read three of us our rights, then tried to question us one by one, i did not respond to any questions i told them to speak to my lawyer, i requested my single vehicle key along with its key chain about 5 different times the subject was changed about 4 times
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and the 5th time, was when we were exiting the store about to be put in the vehicle i asked again and they said no in a loud tone of voice, that they were not in my possession. then they took us to the station and we were booked. they handled this arrest and raid very poorly with no respect what so ever towards us, it was very unprofessional. I declare under penalty of perjury under the laws of the State of California and United States that the aforementioned statement represents my personal knowledge and is true and correct. EXECUTED this 23RD day of April, 2013:

_____________________________________________ Alejandro Gonzalez

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DECLARATION OF CAROLINA LOPEZ I, Carolina Lopez, declare as follows: 1. 2. 3. I am a resident of Long Beach, CA. I am a volunteer at The Willow Collective. To whom it may concern

This is a statement describing my experience during two unlawful raids that occurred on Friday March 8, 2013 and Thursday April 11, 2013. On Thursday March 8, 2013 Long Beach PD busted into Willow Medical Solutions at approximately 1:30pm demanding to be buzzed into the facility. Perhaps they had a signed warrant; however I never saw it. They came through the security doors with guns drawn and then came around the counter and instructed all of us to place our hands on our heads. A Caucasian officer aggressively slapped on a pair of handcuffs tightly on my wrists. He then grabbed me by my arm and led me to the patient lobby where they had four more volunteers waiting in hand cuffs. The Sergeant stated that we where all going to have restraining orders against us from the facility after we get bailed out. The officer who wrote down my information was rude and disrespectful demanding me to give him my ID number and personal information. When I refused to respond he replied "what, are you dumb too?! " They looked through all of my belongings without asking for my consent" While I was waiting in the lobby I could hear them rambling through all of the merchandise and looking to find hidden objects to confiscate. When we arrived to the booking facility I witnessed an officer looking through Alejandro Gonzalez phone demanding for him to say his IPhone password in order to turn it off. Alejandro responded that he could turn it off with out the password and the officer furiously responded that he would use it as evidence. If I could briefly describe the experience I would say it felt like a robbery by men in uniform because we returned to a destroyed dispensary with all funds and merchandise gone and tape placed over our surveillance cameras. On April 11, 2013 Long Beach PD made a forceful entrance into Willow for the second time at 2:30pm. Once again they demanded to be buzzed into the facility. The officers once again came through our security doors with guns drawn and aggressively yelling instructions for us to put our hands on our head just as they did the last raid, only that this time they had three of us go to the back where an SUV was parked. The Sergeant asked if we where on stay away, when we responded that we were not he stated that he would make sure we got
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restraining orders from the facility this time around. We where then led to the lobby while they took down our information. They selected three volunteers to be taken to Jail immediately and I waited with Alejandro in the Lobby. An officer pulled me aside to read me my Miranda rights and asked me how long I had been working at Willow and if I knew the owner. After refusing to respond he told me to return to the lobby. I saw the officers going through the register and collecting all of the merchandise. From the lobby I could hear their disappointment; they could not find any hidden merchandise. After a few minutes I heard an officer shout! "Ha Bingo! Display Cases, just like any other drug dealer. The only reason I could imagine that willow has hidden items is because of the Unlawful raids that continue to occur. I was never really told what it is that I am doing that is Illegal, the only thing I was told by the Officer was "you know what you are doing is illegal, now go sit down". Overall I would describe both raids as a traumatic experience because I was treated as a criminal and aggressively detained.

I declare under penalty of perjury under the laws of the State of California and United States that the aforementioned statement represents my personal knowledge and is true and correct. EXECUTED this 23RD day of April, 2013:

_____________________________________________ Carolina Lopez

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DECLARATION OF CHRISTOPHER ARTURO SEGOVIA

I, Christopher Arturo Segovia, declare as follows: 1. 2. 3. I am a resident of Long Beach, CA. I am a volunteer at The Willow. It was Thursday 4/11/13 between 2:20 and 2:30pm. I was tending to a patient when

I heard raid on the radio. I stopped what I was doing and waited for LBPD to walk in. We buzzed them in right away. With their guns out and pointed at the volunteers and patients we were told to put our hands in the air. Already with my hands in the air, the officer starts to search me and asks, " do you have any guns or grenades?" My response was unless we are in Iraq. I was arrested and took to the back of the dispensary to be asked if I have been served? After the question I was taken to the lobby of the dispensary. That's when the officers took down my info as well as the other volunteers. While taking down our info I hear the detective and the other officers moving things around. I heard them making fun of us. I would say it was four officers in uniform and two detectives not in uniform. They didnt have enough cars for all of us to get booked at the same time. Adrian and I go in one car in the back seat. I asked the officer to put my seatbelt on so Id feel safe but only received a smart remark in response by the officer. I thought it was police officers job to protect and to serve. So not only did I not feel safe without my seatbelt on but the officer was also swerving while driving while trying to run some license plates while driving. During the ride I asked, " why did you guys not come with your whole team?" The officer replied, " it was a low-key raid. " At booking its just Adrian and I. After about a half an hour of being there the detective came and called out my name. He pulled me to the side and quietly read me my rights. I believe he did this quietly because I was supposed to be read these before I am actually arrested. He tried asking me question but I replied by saying talk to my lawyer. On the way upstairs the other volunteers arrived about an hour after Adrian and I got into the station. When upstairs one out the four officers in uniform stared

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me e down with h intimidatio on as if he wanted w to fi fight. I fina ally was taken into the main cell wh here I awaite ed my bail. I de eclare unde er penalty of o perjury un nder the law ws of the St tate of Cali ifornia and United Stat tes tha at the aforem mentioned statement represents r m my personal l knowledge e and is true e and correct. EX XECUTED this t 23RD day d of April l, 2013:

___ ___________ __________ ___________ __________ _____ Chr ristopher Art turo Segovia a

DECLARATI ION OF CHRIS STOPHER AR RTURO SEGOV VIA (APRIL 2013)- 2

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DECLARATION OF CLAUDIA PARRA

I, Claudia Parra, declare as follows: 1. 2. 3. 4. I am a resident of Los Angeles County, CA. I am a volunteer at The Willow The Willow was raided on April 4th, 2013. It was Wednesday, on October 31st around 12:30p.m. I was

volunteering at Willows Collective dispensary in Long Beach, CA along with 3 other volunteers. While in the process of helping out a patient, I glanced to the cameras/monitors and saw a number of people, a majority of whom were in casual clothing, rush into the dispensary through both entrances. I stopped helping out the patient immediately and froze up, because I didnt know what to do at the moment. The men walked in and pointed their guns at us and told us to put our hands up. From what I remember, they identified themselves as police officers. Afterwards, they put the volunteers in handcuffs and searched each of us individually. They proceeded to move everyone to the waiting room, as well as the patients and the security guard. After a couple of minutes they allowed the patients to leave, but kept the volunteers and the security guard waiting for approximately 30 more minutes. Then one by
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one a private investigator called us to the next room to question us. After questioning us they took us all in to the Long Beach City Jail. I declare under penalty of perjury under the laws of the State of California and United States that the aforementioned statement represents my personal knowledge and is true and correct. EXECUTED this 24th day of April, 2013:

___________________________________________ Claudia Parra

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DECLARATION OF EDGAR SANCHEZ

I, Edgar Sanchez, declare as follows: 1. 2. I am a resident of Long Beach, CA. I am a volunteer at The Willow.

On Friday, March 8, 2013 at approximately 1:30 in the afternoon I was approached by officers from the Long Beach Police Department who entered through Willow Street with their guns drawn and proceeded to arrest me at a legal marijuana dispensary in the City of Long Beach. I stood by my right to remain silent as they took me to the back door where the officers made a phone call. The conversation was about me and it seemed as though someone had pointed me out. The detectives, in particular, had claimed that I was going to be forced to sign a "stay away order" stating that I could not be within 200 yard of a medical marijuana dispensary, implying that I had no choice. At approximately 1:45, I was taken into jail where I spent the rest of the day until my bail was paid and was not released until 10:20pm. My experience was an unpleasant one, considering that my treatment was that of an immoral criminal. I did not feel as though my punishment was justified and felt my stay in jail was uncalled for. Furthermore, having a loaded weapon pointed in my face was completely uncalled for, especially since I did not have a weapon on me, nor did I resist arrest, or make any threatening gestures at anytime to any of the officers. The

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situation could have been handled in a more professional matter without the overabundance of loaded firearms. I understand that there are some protocols to be followed, but given the compliant, non-threatening nature of my/our reaction, the police, in my opinion overreacted and put our safety and lives in danger. I declare under penalty of perjury under the laws of the State of California and United States that the aforementioned statement represents my personal knowledge and is true and correct. EXECUTED this 23RD day of April, 2013:

_____________________________________________ Edgar Sanchez

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DECLARATION OF MCCABE KAINOA 1. 2. 3. Ca. 4. To whom it may concern, on April 11th, 2013, while I was outside in the front of the collective talking with a patient's passenger from his car, I noticed in the corner of my eye at least 6 police in raid gear and helmets. I immediately got on the radio to warn the volunteers on the inside that we were about to get raided. After I shouted "raid raid raid!! Were getting raided!" Into the radio I put my hands up and one of the cops had his gun in my face and he said, "You think its real fuckin funny to warn them the boys are coming dont you!" He then told me to get on the ground and as I was lowering to my knees he kicks me in the back of my knee causing me to slam my knee on the ground and break open the wound from a previous surgery on my leg. (See attached photos as further exhibits A & B.) This wound would later get infected while I was in jail. He then said, "Put your chest on the ground and hands out in front of you," then he handcuffed me behind my back and started violently ripping my belongings out of my pocket throwing them around. As he was doing that he was telling me Im going to spend the weekend in jail and Im being charged with additional charges. At his point he stood next to me kicked me hard into my upper thigh. The same officer then saw my car keys and said, "Oh you have a Cadillac? How nice then he looked at his partner and yelled tow it!" Then looked at me and smiled. Then I saw a man walking up to the shop with a confused look on his face and I told him were getting raided not to go in and he smiled and pulled out a badge and said "good job buddy for warning them we were coming, " and walked by me and slammed his hand on top of my head twice and said if I act like a donkey their going to treat me like a donkey, thats why Im spending the most time in jail. He then walked in the collective and the cop who first approached me and slammed me to the ground came back out as I was now sitting on the concrete handcuffed and he was telling me Im going to be on a list to not be allowed anywhere near a dispensary in long beach. Then another undercover came
DECLARATION OF MCCABE KAINOA (APRIL, 2013) - 1

I, McCabe Kainoa, declare as follows: I am a resident of Long Beach, CA. I am a volunteer at The Willow Collective located at 726 W. Willow St. Long Beach

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out of the e collective and read me e my Mirand da rights as they were p putting Chri is and Adria an in the bac ck of a polic ce car. They y didnt even n bring enou ugh cars to t take us all to o the station n so they th hen put Caro olina and Al lex in the ba ack of anoth her police ca ar and they t then waited for a patr rol car to get t there for me m and they placed me i in the front seat and the en they took k us to the booking b roo om and book ked us.

I declare und der penalty of perjury under u the la aws of the S State of California and United Stat tes that the aforementio a oned stateme ent represen nts my perso onal knowledge and is t true and corr rect. EXECUTED E D this 23RD day d of April, 2013:

__ __________ __________ __________ __________ ________ McCabe M Kainoa

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EXHIBITS A & B Exhibit A photo was taken by a friend of mine on April 14th

Exhibit B photo was taken by a friend of mine on April 17th

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MATTHEW S. PAPPAS
A T T O R N E Y
(949) 371-7811 MAT.PAPPAS@MATTPAPPASLAW.COM 24611 SPADRA LANE MISSION VIEJO, CA 92691 LEGAL ASSISTANT: DIVINA MAGARIFUCHI

August 24, 2010 VIA E-MAIL AND FIRST CLASS MAIL Mr. Paul Violas Attorney 100 Oceangate Ste 1200 Long Beach, CA 90802 Re: Long Beach Medical Marijuana Ordinance 10-0007 Dear Paul: Ive talked with my dad regarding the phone conversation he had with you last week. Several months ago, I read a caustic unsolicited email sent by you to him. First, my goal in regard to the medical marijuana issue is to ensure disabled and seriously ill people who have been recommended medical marijuana by a physician have access to that medication. While patients who have been prescribed drugs like Vicodin and Oxycontin are able to have their prescriptions filled without worrying about police raids, arrests and inconsistent access, medical marijuana patients are not so fortunate. Since 1996, medical marijuana patients have been arrested, jailed, raided, and regularly worry about whether medication is available simply because the medication they use is effective for them instead of more dangerous drugs. After nearly fifteen (15) years, these barriers continue to hamper patients. After countless legal and political efforts, the disabled and seriously ill people who use medical marijuana to treat their conditions, many of whom have, over the same period, died from cancer and other sicknesses, are still faced with police raids, efforts by the cities to treat them differently, arrest, detainment, and a host of other obstacles. Im writing because Im concerned about a comment you made to my dad in the above referenced phone conversation you had with him last week. Specifically, the comment that you have contacts in City Hall and that you are not worried about eventual approval of your clients application. Normally, I would not spend any time on the kind of baseless threats and comments hurled at me like those included in your first unsolicited email to my dad. I certainly think he should have responded and I support his response -- especially in light of the threats of lawsuit and State Bar complaints you included. Your attack and threats were certainly not the first Ive received while working on behalf of the disabled and seriously ill. However, the comment you made to my dad about having contacts in City Hall concerns me because there are thousands of patients that belong to collectives that do not benefit from the type of special relationship

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Mr. Paul Violas August 24, 2010 Page Two that apparently will ensure approval of your clients license application. I understand the vitriol and positioning by attorneys that would prefer to maintain the status quo in order to keep extensive and continuous medical marijuana related business flowing. I represent disabled plaintiffs in a case that seeks to eliminate the vague rules and policies that provide this continuous flow of civil and criminal cases for a number of lawyers. Naturally, those attorneys will do all they can to creatively thwart our efforts and Im not going to deviate or lose focus as a result of rumors, attacks and threats. However, if people have special political influence because of contacts or through other mechanisms, then it is not only appropriate but very necessary for me to address potential foul play. If you are aware of any inappropriate influence peddling or special treatment by elected or administrative officials, I believe you must notify state or federal authorities. If you are involved in this kind of thing if the contacts are yours -- Im very concerned. On the other hand, there may be some prohibition in terms of reporting because of the attorney-client privilege. Im researching what my duties are in regard to this situation. It is very disconcerting that there is even an indication that something is awry in this area when such behavior affects people who are dying, seriously ill or disabled. Again, I am used to untrue statements made by people about me including rumors that I have been disbarred twice, that I have been subject to continuous bar discipline, and that Ive been disbarred in other states. Ive been subjected to attacks in the media alleging my clients case is frivolous and that the subject matter was already decided many times. I have been threatened by city politicians as well as by lawyers. I expect those kinds of comments, innuendo, threats and rumors. I did not expect to hear that special political access is being used in a way that ensures one group of patients will have access while other groups will be denied. Please clarify what special access and relationships exist in City Hall that will ensure license application approval? Thank you for your attention to this matter. Very truly yours,

Matthew Pappas MSP:dg

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