As you may know we called for the Resignation or removal of Mr. Humble last week, (See April 11th 2011

On April 15 2011 Mr. Humble was questioned by the Arizona Business Journal concerning our removal demands. His peculiar response raises legitimate questions of his competency.  When asked about our resignation demands Mr. Humble responded;

“My staff screens a group’s reputation before accepting any engagements, I have received numerous requests for speaking engagements but there is one group I have rejected: the Arizona Association of Dispensary professionals, Inc. led by Director Allan Sobol”.

Now Mr. Humble did not elaborate on his reasons but in contradiction to that statement he did acknowledge that he agreed to speak at the Green Relief Expo, an event whose primary sponsor was Marijuana Marketing Strategies, llc, also Directed by yours truly, Allan Sobol. What Humble failed to tell the press was that when he was first asked to speak at The Green Relief Expo back in February he REFUSED.  Only after we accused him of special treatment for his friends at MPP and AZMMA did Humble reverse himself and agree to speak.  However, his offer to speak was made with conditions, (conditions not required with MPP and AZMMA).

Apparently afraid of what might be asked from a group not controlled by his friends; his terms to attend the event were that he would not take any verbal questions from the audience. (The only speaker at the EXPO with that condition).  Instead, Humble stated, he would only answer written questions submitted by the audience, AND ONLY after the questions were screened and censored by his handlers.  Humble’s behavior and  comments are further evidence of his bias.  Clearly these comments were intended to promote the interest of his friends at AZMMA.

Let’s get the facts straight.  In November 2010 I asked Mr. Humble to speak at a FREE educational seminar.  The response I received from his staff was that Humble would not meet with anyone who has a financial interest in the Dispensary program. ( Although I explained to them that we would not be applying for a license.)

The Arizona Association of Dispensary Professionals, Inc is a legally formed legitimate Association authorized under the laws of the State Of Arizona.  We are in fact Arizona’s largest Medical Marijuana Industry Trade Association consisting of over 7000 members.

On the other hand, The Arizona Medical Marijuana Association, AZMMA, is an offshoot of MPP, and  the only action ever taken by that Association was when, on March 8th 2011, Joe Yuhas reserved the name of the proposed entity with the Arizona Corporation Commission.  This name filing was submitted two (2) days after  we filed a complaint with the Arizona Attorney General’s office alleging that the AZMMA was committing criminal fraud by charging seminar fees and claiming that the monies collected were tax deductable. This was fraudulent:  AZMMA is not a legally registered corporation, and surly is not a 501c3 (not for profit entity ).  The act of reserving a name with the Arizona Corporation Commission  in no way establishes AZMMA as a legal entity authorized to do business in Arizona.  It is merely a precursor to filing Corporate Documents.  AZMMA’s representations that they are authorized to do business in this state, or that they are a Not-for-profit entity may very well represent criminal fraud.

It appears that Mr. Humble needs a new PR Company!   Let us all understand what is taking place here.  Mr. Humble tells the press “that his staff screens the reputation of a group before accepting any engagement”, nevertheless, he will speak with, and associate with a fee based function promoted by AZMMA, (illegally operated by his long time friend and and former MPP operative Joe Yuhas),    which is an unlicensed, unauthorized non-entity making fraudulent claims. However, he refuses to speak at a FREE function sponsored by a legitimate Arizona Industry Association.  This clearly creates an appearance of impropriety.  Additionally, It appears that we must question the competency of his staff’s ability to review these agenda requests. If that is so, how can we trust this same staff to review applications for Dispensary operators!!!   Will the same bias apply?
It should also be noted that at that same event,  Mr. Humble’s other close friend, Andrew Meyer, was plying the trade of a new, also unregistered, illegal company called 203organics.
It appears to me that the Director of a AZDHS was endorsing and associating himself with a number of  schemes not authorized to do business in this State.  Is this the guy we want regulating the Medical Marijuana Industry?

It’s obvious that Mr. Humble is uncomfortable with the truth we bring to this process. His remarks are without merit and solely intended to damage the good work and reputation of our Association.

Mr. Humble does not need an army of security guards to protect him from us; we are a professional organization merely attempting to assure fairness in this process.  Instead of fearing us he should embrace us.  Associations like ours and many others across the state can bring a wealth of knowledge, information, positive impute and balance to this process.  It is truly unfortunate that Mr.  Humble is too biased to understand that.

Not to be distracted, there is one significant issue in the Final Rules which still needs immediate clarification.  In order to provide a level playing field for all potential applicants Mr. Humble, or his replacement, must identify who will actually choose the Dispensary winners.  Will it be the local zoning jurisdictions or the AZDHS?   Mr. Humble continues to do the CHA CHA with respect to this very important question.  While the final rules dictate that you will only need a letter from the local zoning jurisdiction stating that the proposed dispensary location meets the required zoning rules. What happens if you cannot get that letter??   Humble has already stated that you will not need a Special Use Permit ( SUP) or Temporary Use Permit, (TUP) with your initial Dispensary Application.  However, What Humble has consistently ignored and danced around is the  important question; what happens if a local jurisdiction refuses to give you such a letter?  Many of you may be aware of the fact that some jurisdictions have conducted “pre-zoning-registrations”.  In some cases these “Pre-zoning-registrations” were conducted without advance public notice. Certain select applicants with “inside” information were first in line months ago to  pre-register.  Some local jurisdictions are refusing to accept other applicants, or have indicated they will not write letters of compliance for those that did not “pre-register”.  I believe that this is a pre-mediated effort on the part of some influential individuals to win dispensary licenses for their clients.  If that local jurisdiction does not provide you with a letter  stating that your property meets the requirements of local zoning requirements, will the AZDHS deny your application solely on that basis???.   If that is the case then only applicants previously approved by their local zoning authority will be granted AZDHS Dispensary Licenses.  In that event AZDHS is acquiescing to local jurisdictions it’s authority under Title 36 to select the Dispensary Applicants.

So, Mr. Humble,  we know you are reading this, we are asking you to clarify this issue.

We believe AZDHS has no authority to assign it’s authority under Title 36 to Local Zoning Jurisdictions.  In fact, to do so would be actionable by any applicant damaged by that process.   A simple solution to this issue would be to forgo any zoning requirements till after the Dispensary Applicants have been chosen.  It is very likely at that time many of the approved applicants may elect to move their facility to better locations within their CHAA.  These new better locations will become available when the non-selected applicants terminate their lease agreements.

Additionally,  considering all the rumors , allegations, and other suggestions of impropriety surrounding this process  it appears that the only fair way to review and select Dispensary Applicants would be establish a review board comprised of  members from the general public, the legal community, the Medical Marijuana industry and of course AZDHS.

In the interest of making this a fair and equal process to all we encourage Mr. Humble to work with all legitimate Organizations.



Allan Sobol, Director
Arizona Association of Dispensary Professionals, Inc.