Blog - Page 51 of 54 - Arizona Medical Marijuana Law

Arizona Attorney General Calls for a Tax on Medical Marijuana

Arizona Republic: “Attorney General Tom Horne opposed a ballot measure to legalize medical marijuana but now he’s calling for it to be taxed. State tax collectors say that’s exactly what they plan to do.”

The Republic missed the big story on taxing medical marijuana. On January 26, 2011, a group of legislators introduced House Bill 2557 (aka the “Don’t Divert Money from the Drug Cartels Act”) that would tax the sale of medical marijuana at the rate of 300 percent. See “Arizona Legislators Introduce HB 2557 to Overturn Voters Approval of Proposition 203.”

By On the Net|2014-01-05T09:52:27-07:00January 28th, 2011|Tax Issues|Comments Off

Arizona Medical Marijuana Dispensaries Need Commercial Insurance

No business should operate without insurance, especially a business in which the owners have invested a lot of money. Bad things happen in business no matter how careful people are. All businesses need appropriate insurance first to pay the legal cost to defend a lawsuit and second to pay the amount of a judgment or settlement.

All Arizona medical marijuana dispensaries need appropriate commercial insurance for all of their activities. I feared that perhaps the industry might not be able to buy insurance because the business involves the possession and sale of marijuana, a substance that is illegal to possess and sell under federal law.

Fortunately my fear is unfounded. My long-time good friend Dan Ellington, a commercial insurance agent with BBVA Compass Insurance in Phoenix, tells me that he and his firm are able to advise prospective Arizona medical marijuana dispensaries and dispensaries with licenses on the types of commercial insurance needed and the coverage amounts and purchase the desired insurance for the dispensaries.

Hee are a few of Dan Ellington’s comments to me about insuring an Arizona medical marijuana dispensary:

Insurance coverage can be obtained for professional liability associated with dispensing.
Insurance coverage can be obtained for general liability associated with the dispensing location.
Coverage cannot exceed what is allowed under Arizona law.
Products / completed operations can be insured only if the marijuana sold by the dispensary is grown by the dispensary.
Products-stand alone coverage may be offered under products line of business.
If the dispensary or cultivation site has armed security, the insurer considers the insured to have a very high hazard situation.
Coverage will be denied if the insured does not comply with all applicable laws, statutes, regulations, ordinances and other federal, state and local restrictions governing the dispensing of medical marijuana.
Minimum policy premium $2,750
Maximum limits: $1 million per claim; $3 million aggregate.
Minimum deductible: $2,500.

For more information about insuring your dispensary or to purchase insurance for your dispensary, call Dan Ellington at 602-956-7800. BBVA Compass Insurance is located at 2002 East Osborn Road, Phoenix, AZ 85016.

By On the Net|2011-01-29T14:32:18-07:00January 27th, 2011|Dispensary Insurance, Stories & Articles|Comments Off

Medical Marijuana in Community Associations – A Smoking Hot Issue

My friend Beth Mulcahy is one of the premier homeowner association (HOA) attorneys in Arizona. What follows is the text of a January 27, 2011, email message she sent to her clients and others in which she discusses issues Arizona’s new medical marijuana law creates for HOAs.

In late 2010, Arizona residents voted via Prop 203 to legalize medical marijuana. This new law will allow qualifying patients with certain debilitating medical conditions (such as cancer, HIV/AIDS, hepatitis C and multiple sclerosis) to receive up to 2 1/2 ounces of marijuana every two weeks from dispensaries or cultivate up to 12 marijuana plants if they live 25 miles or farther from a dispensary. Arizona became the fifteenth (15) state to approve medical marijuana. The approval of Prop 203 was a surprise, having passed by approximately 4,300 votes out of 1.67 million votes cast and being behind by 7,200 votes on Election Day in November, 2010.

The state health department released its first draft of medical-marijuana rules in December, 2010. The rules outline who may qualify for medical marijuana, establish operating criteria for dispensaries and provide strict guidelines for doctors who may recommend marijuana. The state health department must finish drafting the rules by April 13, 2011.The agency will then review applications from people who want to use medical marijuana or operate a dispensary. The program should be fully functioning by summer 2011, when dispensaries have had time to grow the plants.

Our firm has received questions regarding how this law will apply to community associations. At present, it is our firm’s opinion that this is a complicated issue and as association rules conflict with a unit/lot owners’ use of medical marijuana the issue will become more entangled. A major concern is that marijuana is not legal under federal law.

A few questions association boards should consider and discuss:

1. Should association boards allow residents to smoke medical marijuana on association common areas?

It is our firm’s position that association boards can pass rules pursuant to their association documents to prohibit smoking of medical marijuana on association common areas. It is important to note that under Arizona law, an owner would be allowed to smoke medical marijuana within the confines of their unit or lot.

2. Should association boards allow owners to grow medical marijuana on association common areas?

It is our firm’s position that growing of medical marijuana on association common areas can be prohibited by the association so long as rules to that effect are passed by the board.

3. What can the association do if neighbors complain about medical marijuana use by another owner within that owner’s unit?

This is a complicated situation and will need to be evaluated on a case by case basis. Is the medical marijuana use prohibiting the peaceful enjoyment of the use of their unit by the complaining owner?

4. Can a commercial space, in mixed use communities, be used as a medical marijuana dispensary?

Medical marijuana dispensaries may try to rent space in mixed use associations. Will other tenants complain about the type of individuals who patronize them? It is our firm’s opinion that an association would NOT have the right to prohibit the rental of space to medical marijuana dispensaries.

These are all tough questions. As this issue comes to the forefront for associations our firm suggests that boards and managers consult with our firm to discuss options and risks regarding use of medical marijuana within associations.

Articles that appeared in the November and December Arizona Republic were the source for this article.

The author, Beth Mulcahy, is the founder and senior partner of the Mulcahy Law Firm, P.C. See the firm’s website for more information about the firm.

By On the Net|2011-01-27T19:14:24-07:00January 27th, 2011|Legal Issues|Comments Off

Arizona Legislators Introduce HB 2557 to Overturn Voters Approval of Proposition 203

The voters of Arizona spoke when a majority approved Proposition 203. Now a group of elected elites who know what is best for the people of Arizona introduced House Bill 2557 (aka the “Don’t Divert Money from the Drug Cartels Act”) on January 26, 2011, for the sole purpose of killing Arizona’s medical marijuana industry before it begins. Maybe the goal of the elites is to kill the dispensary industry so that under Proposition 203 nobody will live within 25 miles of a dispensary so all licensed patients can grow their own throughout the entire state.

Yesterday Arizona’s Attorney General Tom Horne issued a press release that said Arizona could impose a sales tax on medical marijuana and he estimated Arizona would collect $40 million in badly needed revenue. If HB 2557 passes, Arizona can kiss the medical marijuana industry good bye, which means no need for the 125 would be dispensaries to hire thousands of employees, security personnel, growers, transporters and the many other types of ancillary jobs that the industry would generate.

Here is the key language in HB 2557. It will amend Arizona Revised Statutes Section 42-5010 by adding the following as new subsection A.5 to read:

The tax imposed by this article is levied and shall be collected at the following rates:

THREE HUNDRED PER CENT OF THE TAX BASE AS COMPUTED FOR THE BUSINESS OF EVERY PERSON ENGAGING OR CONTINUING IN THIS STATE IN THE NONPROFIT MEDICAL MARIJUANA DISPENSARY CLASSIFICATION DESCRIBED IN SECTION 42-5077.

HB 2557 will add the following new section 42-5077 to Arizona’s statutes:

42-5077. Nonprofit medical marijuana dispensary classification

A. THE NONPROFIT MEDICAL MARIJUANA DISPENSARY CLASSIFICATION IS COMPRISED OF THE BUSINESS OF SELLING OR DISPENSING MEDICAL MARIJUANA TO QUALIFYING PATIENTS PURSUANT TO TITLE 36, CHAPTER 28.1.

B. THE TAX BASE FOR THE NONPROFIT MEDICAL MARIJUANA DISPENSARY CLASSIFICATION IS THE GROSS PROCEEDS OR GROSS INCOME DERIVED FROM THE BUSINESS.

C. IF A PERSON WHO IS ENGAGED IN BUSINESS AS A NONPROFIT MEDICAL MARIJUANA DISPENSARY ALSO SELLS OTHER TANGIBLE PERSONAL PROPERTY AT RETAIL, THE PERSON’S BOOKS MUST SEPARATELY ACCOUNT FOR SALES OF THE OTHER TANGIBLE PERSONAL PROPERTY, AND IF NOT SO KEPT THE TAX UNDER THIS SECTION APPLIES TO THE TOTAL OF THE PERSON’S ENTIRE GROSS PROCEEDS OR GROSS INCOME FROM THE BUSINESS.

If you want Arizona to have legalized medical marijuana, you must tell your legislators to impose a reasonable tax on medical marijuana of 5% – 7%. Here’s the contact information for the Arizona legislators who introduced this bill (more…)

By On the Net|2017-02-11T17:28:53-07:00January 27th, 2011|AZ Legislation, Legal Issues, Tax Issues|Comments Off

Arizona’s Three Universities Will Ban Medical Marijuana on Campus

East Valley Tribune: “federal law prohibits possession and use of marijuana, even for medical purposes. And the penalty for schools that don’t enforce that . . . is loss of any federal aid, including student participation in the guaranteed student loan program.

By On the Net|2011-02-16T18:35:44-07:00January 26th, 2011|Stories & Articles|Comments Off

Medical Marijuana Will be Taxed Says Arizona Attorney General Tom Horne

Here is the text of a January 26, 2011, press release by Arizona Attorney General Tom Horne:

HORNE TO RECOMMEND TAXATION OF MEDICAL MARIJUANA

Phoenix (Wednesday January 26, 2011) – Attorney General Tom Horne today announced that he is recommending to the Arizona Department of Revenue that medical marijuana, made legal in a recent initiative, be taxed by the State.

Horne stated, “I was opposed to the medical marijuana initiative during the 2010 election, but it was passed by the voters and the issue now presented is whether it should be taxed under existing law.”

He added, “Normally, there would be no tax on prescriptions. However, the legislation refers to doctors giving a ‘written certification’ rather than a prescription, an apparent effort, copied from other states, to protect doctors from discipline for giving prescriptions of substances prohibited under federal law. Since these are ‘written certifications’ rather than prescriptions, the sale of the substance can be taxed by the State, and we are recommending to the Department of Revenue that it tax the sales accordingly. We are informed by the Department of Revenue that they will take this advice, and tax the sales.”

The taxes are estimated to yield revenues to the State of Arizona in the approximate amount of $40 million per year. This number is projected, on a pro rata basis, to the Arizona population the statistics for Denver County, as reported by the Denver Post using the Phoenix sales tax rate.

By On the Net|2011-01-26T21:09:26-07:00January 26th, 2011|Legal Issues, Tax Issues|Comments Off

Must All Dispensary Owners, Officers & Directors be U.S. Citizens?

Question: Must all owners, officers and members of the board of directors of an Arizona medical marijuana dispensary be a citizen of the United States?

Answer: Apparently “the principal officer” or one board member must be a U.S. citizen as of today, January 26, 2011. It appears that no other owner, officer or director must be a U.S. citizen, except for the one “principal officer” or board member selected by the insiders to give proof of U.S. citizenship to the Arizona Department of Health Services.

Although Proposition 203 does not contain U.S. citizenship or Arizona residency requirements, the first draft of the Arizona Department of Health Services rules contain both requirements. Rule R9-17-107.F.1.d.v(1) requires that after a dispensary applicant receives the written notice of preliminary approval from DHS, the applicant shall submit to DHS “a copy of the principal officer or board member’s Arizona driver’s license or identification card issued before October 1, 1996, and one of the following:

(1) Birth certificate verifying U.S. citizenship,
(2 ) U. S. Certificate of Naturalization, or
(3) U. S. Certificate of Citizenship.”

My take from reading this poorly worded rule is that only one person who is an owner, officer or board member of an Arizona medical marijuana dispensary must be a United States citizen. The term “principal officer” is used 47 times in the rules, but the term is not defined.

By Richard Keyt|2011-01-26T21:00:21-07:00January 26th, 2011|DHS Rules, Legal Issues, Questions People Ask|Comments Off

New Daily & Weekly Vistor Record

The number of visitors to Arizona Medical Marijuana Law continues to grow. On January 24, 2011, we had 604 visitors, a new daily record. For the week ending at midnight on January 23, 2011, this site had 2,750 visitors. Not bad for its fourth week of existence.

Thanks for stopping by. Please send a link to this site at www.arizonamedicalmarijuanalaw.com to your friends and people who you think might have an interest in Arizona medical marijuana. Don’t forget to send suggestions for articles. If you have an original article you think would be of interest to our readers, please send it to me.

By On the Net|2015-04-06T18:49:23-07:00January 25th, 2011|Miscellaneous|Comments Off

How Can a Non-Arizona Resident Who Wants to Own an Interest in an Arizona Medical Marijuana Dispensary Participate Before Becoming a Resident?

Question: Arizona Department of Health Services’ first draft of the medical marijuana dispensary rules requires that all officers and directors of Arizona medical marijuana dispensaries be Arizona residents for at least three years. I don’t satisfy the residency requirement so how can I be involved in a dispensary now and become an owner when I qualify?

Answer: There are several ways. If your goal is to own an interest in an Arizona medical marijuana dispensary, you must establish Arizona residency for at least three years so the sooner you move to Arizona, the sooner you will meet the residency requirement. The current DHS rules contain a three year Arizona residency requirement to be an owner, officer or director of a dispensary. Myself and others have suggested to DHS that it eliminate the residency requirement because the requirement is not contained in Proposition 203 and it is a violation of the equal protection clause of the United States Constitution. DHS could increase or decrease the residency requirement or eliminate it altogether before it issues the final rules.

A person who has not lived in Arizona for three years could become a paid employee or an unpaid volunteer of a dispensary. These positions are great learning experiences and can help to establish contacts and relationships with the dispensary owner that could lead to an ownership interest in a dispensary. However, without a legally binding written contract between you and the nonprofit entity or the owner(s) of the nonnprofit entity to acquire an ownership interest in the dispensary, you probably would never become an owner.

Make a Loan with an Option to Convert the Debt to Equity

A better way for a non-Arizona resident to acquire an ownership interest in an Arizona medical marijuana dispensary is by the non-Arizona resident loaning money to the nonprofit entity and having a written option to convert the loan to an equity (ownership) position after the non-Arizona resident establishes residency and each of the 17 other requirements of ownership currently in the DHS rules. For example, if you and another person want to own a dispensary and become equal 50/50 owners, the other person could loan or contribute $125,000 to the nonprofit entity and you could loan it $125,000. The other person would initially be the sole owner of the dispensary. Your loan documents would provide that once you satisfy all 18 requirements to be an owner of an Arizona medical marijuana dispensary, you would have the option to notify the entity and its owner that you exercise your option to purchase a fifty percent ownership interest in the entity in exchange for releasing the entity from its obligation to repay the loan. A condition to actually becoming an owner would be that DHS would have to approve you becoming an owner.

During the period of time before the lender becomes eligible to become an owner of the dispensary, the lender could be a paid employee of the nonprofit entity.

What Documents are Needed to Evidence a Debt to Equity Conversion Option

Here are the documents that must be prepared and signed by the appropriate parties do create and document a transaction where the nonprofit entity borrows money and gives the lender an option to convert the debt to equity:

Loan Agreement: This document sets forth all of the terms and conditions of the loan and the rights and obligations of the parties with respect to the option to convert the debt to equity. For example, it would state the conditions that must be satisfied before the borrower can exercise the option such as establish residency and each of the 17 other DHS requirements for ownership, state when the option would expire, require the borrower to become a signer on the entity’s governing document [Operating Agreement for an LLC and stockholders agreement for a corporation] and on a buy-sell agreement and state the conversion ratio for converting one dollar of debt into a specified percentage of ownership of the entity.
Promissory Note: The Note evidences the loan terms and repayment obligation of the nonprofit entity. It could be interest only for a period of time. If principal payments are made, the lender would receive a smaller ownership interest in the entity on converting the debt to equity.
Security Agreement: If the loan will be secured by any personal property of the entity, the lien is evidenced by a Security Agreement signed by borrower and lender.
UCC-1 Financing Statement: If the borrower obtains a lien on the entity’s personal property, the lender must file a UCC-1 Financing Statement with the Arizona Secretary of State
Deed of Trust on Real Property: If the nonprofit entity owns any real property, the loan could be secured by a lien on the real property.
Lender’s Title Insurance: If the loan is secured by a lien on the entity’s real property, the lender should obtain a policy of lender’s title insurance.
Personal Guaranty: The lender should require the other owners of the nonprofit entity to guaranty the Loan Agreement.
Resolutions of an Action by Unanimous Consent: The governing body of the entity (board of directors of a corporation or members of an LLC) must hold a duly called and noticed meeting and adopt a resolution authorizing the entity to enter into the Loan Agreement, the Promissory Note and any other documents and designating the person who has the authority to sign the documents on behalf of the entity. In lieu of holding a meeting, the governing body can sign an Action by Unanimous Consent that adopts all of the necessary resolutions, but all members of the governing body must sign the Action by Unanimous Consent or it will not be valid and the governing body must then hold a duly called and noticed meeting.
Employment Agreement: Needed if the lender will work for the nonprofit entity and be paid compensation before becoming an owner of the entity.
NonDisclosure & Confidentiality Agreement: The parties should sign this document to prevent either party from disclosing anything about the loan and to keep information confidential.

By Richard Keyt|2014-01-05T09:33:44-07:00January 25th, 2011|Legal Issues, Questions People Ask|Comments Off

Should I Loan Seed Money to My Medical Marijuana Dispensary or Should I Give it to the Entity as a Capital Contribution?

Question: I estimate that my Arizona medical marijuana dispensary will need $250,000 to open its retail store. Should I loan the money to the nonprofit entity or should I pay it to the entity as a capital contribution?

Answer: You should discuss this question with your accountant. There are significant differences in the two primary methods (debt vs. equity) of inserting money into a business. Here are some pros and cons associated with each method.

Debt: You could loan the entity $250,000. The loan should be evidenced by a Promissory Note signed by an authorized agent of the entity. The governing body of the entity (members of an LLC or directors of a corporation) should hold a meeting (or sign an action by unanimous consent) and vote to approve the terms and conditions of the loan and designate the person who has the authority to sign the Promissory Note on behalf of the entity. The loan should be commercially reasonable as to the interest rate, payment terms and maturity date. If I were representing the lender, I would recommend that the Promissory Note be secured by a Security Agreement that encumbers all of the assets of the borrower. If I were representing the borrower, I would suggest the loan be unsecured.

There are several advantages for the lender / owner who capitalizes the entity using a loan. First and foremost, the entity becomes indebted to repay the loan according to its terms. A loan creates a greater likelihood of being repaid before a capital contribution because the law of Arizona prohibits an Arizona entity from paying its owners and not paying creditors. A loan may also be a better way to capitalize a medical marijuana entity because presumably Arizona’s medical marijuana laws and the Arizona Department of Health Services rules do not consider the entity’s repayment of a loan to be inconsistent with the require of the law and rules that the entity be operated on a nonprofit basis.

One problem with debt vs. equity is that although the entity has the funds, the infusion of capital does nothing for its balance sheet. The assets of the entity increase by $250,000, but so does the entity’s debt, which means the loan does not increase the net worth of the entity.

If an owner does make a loan to the entity, it is critically important the the loan be properly documented with a good Promissory Note, Security Agreement and a UCC-1 Financing Statement filed with the Arizona Secretary of State (if the loan will be secured by a lien on personal property), and resolutions or an action by unanimous consent of the entity’s governing body. If your entity needs to document a loan, call KEYTLaw business and contracts attorney Jeana Morrissey at 602-906-4953, ext. 4.

Equity: Instead of loaning $250,000 to the entity, you could pay the money to the entity as a capital contribution. Capital contributions have a lower priority the debt on the repayment totem pole. The last people to be paid and recover their investment when a business goes bad are the owners. Some organizational documents such as an Operating Agreement may provide that the owner does not have the right to demand that capital contributions be repaid. Usually capital contributions do not accrue interest although it is possible to accrue interest if company documents provide for the accrual.

Because Arizona medical marijuana dispensaries must be operated on a nonprofit basis, it may also be more difficult to repay a capital contribution than a loan. Currently the DHS rules do not give us any guidance as to whether an entity may freely repay owners their capital contributions so we do not know if a capital contribution in year 1 followed by a total repayment in the same year would be considered an improper use of entity profits contrary to the nonprofit character of the entity required by Arizona law.

An owner could also fund the entity with debt and equity. In the above example, the owner could loan $125,000 to the entity and also make a capital contribution of $125,000.

By On the Net|2015-04-06T18:49:25-07:00January 24th, 2011|Legal Issues, Questions People Ask|Comments Off

Arizona’s Medical Marijuana Law

Phoenix Magazine: “A dazed new world? Could the new medical marijuana act and its ‘cannabusinesses’ create a sixth ‘c’ for Arizona, or will it devolve into California’s reefer madness?”

By On the Net|2015-04-06T18:49:25-07:00January 24th, 2011|Stories & Articles|Comments Off

Pot Meets Pop: Entrepreneur Plans to Market Line of Smartly Branded Medical-marijuana Soft Drinks

Santa Cruz Sentinel: “How strange is the emerging world of medical-marijuana entrepreneurship? Consider Clay Butler, who may soon be marketing a food product that he’s never tasted, and that he would never buy. The product is called Canna Cola, and it’s a soft drink that contains THC, the psychoactive ingredient in marijuana, aimed at medical marijuana dispensaries.”

By On the Net|2019-06-14T08:24:51-07:00January 24th, 2011|Stories & Articles|Comments Off

Alan Sobol Questions Propriety of Phoenix Planning & Zoning

On January 23, 2011, I received an email from Alan Sobol and the Consiglieri Group that raises some interesting questions about alleged conduct by the City of Phoenix with respect to “pre-registration of dispensary” locations. The following is the text of Alan’s message:

“Nepotism at Phoenix City Hall?

January 17 2011, without any notice, twelve people lined up at Phoenix City Hall to reserve their Dispensary Locations. Without any public notice the City of Phoenix rolled out their “Pre-Registration Program”,. According to the City officials, the program was intended to allow individuals to reserve a site for medical marijuana dispensary, cultivation or infusion facilities within the City of Phoenix. The problem, zoning officials had no authority to offer such pre-registration services. The Phoenix City Council adopted Ordinance G5573( the Marijuana zoning ordinance) on December 15, 2010. Nowhere contained therein was there a provision for such pre-registration services. The city violated its own public information rules.

Perhaps the more important question is who are these twelve people that showed up to register their marijuana facility locations, and how did they find out about this program? Hmmm!

But don’t worry, we are conducting an extensive investigation into this matter and will take appropriate action should we find evidence of wrongdoing.

We urge those of you who are considering locating your facility in Phoenix to immediately visit the Phoenix website and download this pre-registration form. (Phoenix.gov/planning). We would also suggest that you keep apprised of any such pre-registration services that might pop-up in other cities or towns. We will shortly be posting a link on our website to all Arizona City and Town websites. As always if you have any questions feel free to contact us.”

By On the Net|2015-04-06T18:49:22-07:00January 24th, 2011|Stories & Articles, Zoning|Comments Off

New Record: 2,750 Visitors During the Week Ending 1/23/11

January 23, 2011, was the end of the fifth week since I started this website. The number of visitors continues to grow each week. For the week ending at midnight on January 23, 2011, this site had 2,750 visitors. Thanks to all who visit. If you have any suggestions for topics for articles, please send me a message.

By Richard Keyt|2011-01-24T01:05:02-07:00January 24th, 2011|Miscellaneous|Comments Off

Is it Legal for a Promoter to Ask Me to Invest $25,000 in a Syndicate that Will Seek to Own an Arizona Medical Marijuana Dispensary

Question: An Arizona business has a website on which it is offering to put together a group of people to own minority interests in an entity that will seek to obtain a license to operate a medical marijuana dispensary in Arizona. In exchange for paying $25,000 I would become a part owner with several other investors in the entity that will seek the license. Is this legal?

Answer: Maybe, but be cautious. It appears that the people who are seeking the investors are soliciting investors to purchase a security. Federal and state securities law regulate the offer and sale of securities. The general rule is that no person or entity can offer to sell or actually sell a security unless the securities are registered with the United States Securities and Exchange Commission or offered and sold as a private offering under one of the SEC’s rules that provide for exceptions to the general rule.

In the famous United States Supreme Court case of Securities & Exchange Commission v. W. J. Howey Co. the Court ruled that the sale of real estate coupled with a mandatory leaseback of the land was a type of security called an “investment contract.” The Court said that”

“an investment contract for purposes of the Securities Act means a contract, transaction or scheme whereby a person invests his money in a common enterprise and is led to expect profits solely from the efforts of the promoter or a third party.”

If Sure Thing Investments, Inc., solicits me to join nine other investors who will each contribute $25,000 to World Wide Widgets, LLC, and my only involvement with the company is as a silent investor, I have purchased a security, i.e., the 10% membership interest in the LLC. Sure Thing Investments, Inc., and the people who put the deal together must comply with applicable federal and state securities laws or they will be liable to me and the other investors for any loss I suffer plus be subject to sanctions by the SEC and each state where an investor resides. Complying with securities law involves many things, including a requirement that the promoter deliver to investors before purchase a written prospectus or private placement memorandum that contains all material facts concerning the investment and that does not fail to disclose a material fact.

Given that the medical marijuana industry is brand new in Arizona and that its core busi9ness involves violating federal law, it is especially important that promoters and prospective issuers of securities involving an Arizona medical marijuana dispensary provide all prospective investors with a detailed disclosure document that lists all of the many risks arising from the unusual type of business.

Note: Federal law provides that no person or entity can be compensate or receive property of value for finding an investor who purchases a security unless the person or entity is licensed as a securities broker or licensed as a securities sales agent working for a licensed securities broker. For example, if Joe solicits investors on his website to invest $25,000 to become one of ten people who form an Arizona limited liability company that seeks to obtain a license to operate an Arizona medical marijuana dispensary and the LLC pays Joe $500 for each investor he brings to the deal, Joe must be a licensed securities broker or a licensed securities salesman working for a licensed securities broker.

Query: What if Joe finds the investors for the would be dispensary LLC, but the LLC does not pay Joe any money or property for finding investors. Instead, the LLC hires Joe for big bucks to assist the LLC in obtaining a dispensary license. Must Joe be a broker or a salesman working for a broker? I don’t know, but it is a good question to ask a securities law lawyer or the Securities Division of the Arizona Corporation Commission. You could argue that Joe must be licensed because the only reason the LLC paid Joe the money was because of Joe’s efforts that caused the investors to form the LLC for the purpose of hiring Joe. My advise to Joe is to consult with an experienced securities law lawyer and if necessary, get licensed.

Warning: Any person or business that solicits investors over the internet is by definition involved in a public offering that must be registered with the Securities and Exchange Commission. As an Arizona business lawyer I have had people come to me from time to time because they placed an ad in a newspaper soliciting investors and received a cease and desist letter from the Securities Division of the Arizona Corporation Commission. If you know of a website that is making a public offer to sell a security that has not been registered with the SEC or that is exempt from registration, contact the SEC. If you have any inquiries or complaints regarding salesmen, investment advisers or securities involving offers or sales of securities to an Arizona resident, call the Securities Division of the Arizona Corporation Commission at (602) 542-0662.

See “Arizona Corporation Commission Takes Action Against Sellers of Unregistered Real Estate Investments,” “But is it a security?” and “Federal Securities Laws Basics.

By Richard Keyt|2017-02-12T07:38:36-07:00January 22nd, 2011|Legal Issues, Questions People Ask|Comments Off

Chandler Working on Tough Medical-marijuana Zoning

Arizona Republic: “Chandler’s regulations for medical-marijuana dispensaries will likely be more restrictive than those in other Valley cities, forcing greater distances from schools, churches, day care centers and public parks and requiring additional permits for dispensaries that also grow marijuana. . . . Under the proposed Chandler law, dispensaries must be at least 5,280 feet from another medical-marijuana facility”

By On the Net|2012-08-18T09:29:07-07:00January 22nd, 2011|Zoning|Comments Off

Thanks for Coming – 569 Visitors Yesterday is a New Record

Yesterday, January 20, 2011, this website had a new record number of daily visitors – 569. I started my Arizona medical marijuana law website on December 23, 2010, because I want to help people learn about legal issues affecting Arizona’s new industry. The number of viewers has climbed steadily since day one. Each of the last four days set a new daily record number of visitors. This site has had 6,836 visitors in the first 29 days its been online.

My website at www.keytlaw.com has had over 6,000,000 visitors since January 1, 2006, because it contains tons of useful information about Arizona and federal law. I currently have two other law websites. They are IRA LLC Law and the KEYTLaw Law Blog. I just started a new website called U.S. Real Estate Law, but it is not live yet. The purpose of the new site is to inform non-U.S. citizens about legal issues that arise when they want to purchase investment real estate in the United States.

By Richard Keyt|2011-01-21T07:51:44-07:00January 21st, 2011|Miscellaneous|Comments Off

Chandler Medical-marijuana Zoning Recommended by Commission

Arizona Republic: “Chandler Planning and Zoning Commissioners unanimously recommended regulations for medical marijuana cultivation and dispensaries Wednesday night that require separate permits for selling and cultivating, allow 9 a.m. to 9 p.m. hours of operation and restrict locations.”

By On the Net|2012-08-18T09:29:22-07:00January 20th, 2011|Zoning|Comments Off

Alan Sobol & Andrew Meyer Speak at the Same NORML Event

I got an email message from The Consiglieri Group on January 16, 2011, that contained the following from Alan Sobol about his close encounter of the third kind with Andrew Meyer at a NORML meeting in Tucson where both men had been invited to speak. I’m sure Alan was hoping to start the debate with Andrew that Alan asked for recently, but alas, it didn’t happen. Here’s what Alan wrote:

As you may recall I challenged MPP Manager , Andrew Meyer to a debate last week. So far no response.

However, I did have the opportunity to bump into Mr. Meyers last Saturday at the Tucson Norml meeting. Meyer’s did not know that I was asked to speak. According to the Norml president Jon, in order to give balance to the meeting both Meyers and me were invited to speak. Mr. Meyer was obviously shaken to learn of the dual speaking event. During Meyer’s presentation he admitted that he was working with the Health Department through “third party agencies” to develop the rules. He repeately referred to the rule making progress as, “WE ARE” working on the rules”. But the most shocking revelation was Meyer’s admission that he now believed that my original idea of a “two step” application process was the appropriate way to administer the approval process.

Immediately after his presentation Meyer rudely and hurrily exited the building apparently so as not to be confronted with any attendee questions regarding my presentation.
Meyer and I had no direct communication except for the finger I received from his lady friend Ms. Tea as they ran from the building.

I believe that on January 31, 2011 when the AZDHS releases their revised proposed rules we will see a more reasonable application process. I further believe that as a direct result of the thousands of comments received from all of you, the AZDHS will be forced to moderate their rules. want to encourage all of you to continue with your business plans, whatever they may be. Don’t loose the opportunity to become involved in this new industry, simply because you do not have enough time to get it finished. Keep moving forward prudently.

Thanks for all your support, and keep fighting,

Allan Sobol
Marijuana Marketing strategies, LLC

By On the Net|2011-01-19T20:52:39-07:00January 19th, 2011|Stories & Articles|Comments Off

Why Every Arizona Medical Marijuana Dispensary Must Hire a Primary & an Alternate Medical Director

The rules of the Arizona Department of Health Services require that every Arizona medical marijuana dispensary have a medical director. See “What is a Medical Director & Why Does Every Arizona Medical Marijuana Dispensary Need One?” If an operating dispensary were to suddenly lose its medical director, the dispensary would be in jeopardy of losing its Dispensary Registration Certificate, i.e., its license to grow and sell medical marijuana.

A dispensary could lose its medical director if the doctor were to:

die
become incapacitated or incompetent
lose his or her license to practice medicine
refuse to provide services even though it might be a breach of contract
suffer health problems
or experience any of an infinite number of events that result in no further services.

I could be wrong, but I’m pretty sure that no dispensary owner would want to risk losing the Dispensary Registration Certificate because of the loss of its medical director. Because the risk of the medical director could stop providing services at any time and cause the dispensary to lose its license and because the financial consequences so great, every dispensary should enter into a written contract with at least one other doctor to be an alternate medical director who automatically becomes the primary medical director if for any reason the primary medical director ceases to be the medical director.

By Richard Keyt|2012-08-18T09:21:18-07:00January 19th, 2011|Legal Issues, Medical Directors|Comments Off

What is a Medical Director & Why Does Every Arizona Medical Marijuana Dispensary Need One?

Question: I am an Arizona physician who is considering offering my services to be the medical director of an Arizona medical marijuana dispensary. Does every dispensary need a medical director? What are the duties of the medical director under the Arizona Department of Health Services rules?

Answer: The Arizona Department of Health Services rules require that every Arizona medical marijuana dispensary hire a medical director. Proposition 203 did not contain a requirement for a medical director, but DHS decided in its wisdom that every dispensary should spend a lot of money to hire a medical director who must be doctor of medicine who holds a valid and existing license to practice medicine pursuant to A.R.S. Title 32, Chapter 13 or its successor or a doctor of osteopathic medicine who holds a valid and existing license to practice osteopathic medicine pursuant to A.R.S. Title 32, Chapter 17 or its successor and who has been designated by a dispensary to provide medical oversight at the dispensary. R 9-17-312.

The Arizona Department of Health Services rules (R 9-17-312) for Arizona medical marijuana dispensaries require that every dispensary contract with a medical director who shall provide oversight for the development and dissemination of educational materials for qualifying patients and designated caregivers. Here is the text of R9-17-312:

A. A dispensary shall appoint an individual who is a physician to function as a medical director.

B. During hours of operation, a medical director or an individual who is a physician and is designated by the medical director to serve as medical director in the medical director’s absence is:

1. On-site, or

2. Able to be contacted by any means possible, such as by telephone or pager.

C. A medical director shall:

1. Develop and provide training to the dispensary’s dispensary agents at least once every 12 months from the initial date of the dispensary’s registration certificate on the following subjects:

a. Guidelines for providing information to qualifying patients related to risks, benefits, and sides effects associated with medical marijuana;

b. Guidelines for providing support to qualifying patients related to the qualifying patient’s self-assessment of the qualifying patient’s symptoms including a rating scale for pain, cachexia or wasting syndrome, nausea, seizures, muscle spasms, and agitation;

c. Recognizing signs and symptoms for substance abuse; and

d. Guidelines for refusing to provide medical marijuana to an individual who appears to be impaired or abusing medical marijuana; and

2. Assist in the development and implementation of review and improvement processes for patient education and support provided by the dispensary.

D. A medical director shall provide oversight for the development and dissemination of:

1. Educational materials for qualifying patients and designated caregivers that include:

a. Alternative medical options for the qualifying patient’s debilitating medical condition;

b. Information about possible side effects of and contraindications for medical marijuana including possible impairment with use and operation of a motor vehicle or heavy machinery, when caring for children, or of job performance;

c. Guidelines for notifying the physician who provided the written certification for medical marijuana if side effects or contraindications occur;

d. A description of the potential for differing strengths of medical marijuana strains and products;

e. Information about potential drug-drug interactions, including interactions with alcohol, prescription drugs, non-prescription drugs, and supplements;

f. Techniques for the use of medical marijuana and marijuana paraphernalia;

g. Information about different methods, forms, and routes of medical marijuana administration;

h. Signs and symptoms of substance abuse, including tolerance, dependency, and withdrawal; and

i. A listing of substance abuse programs and referral information;

2. A system for a qualifying patient or the qualifying patient’s designated caregiver to document the qualifying patient’s pain, cachexia or wasting syndrome, nausea, seizures, muscle spasms, or agitation that includes:

a. A log book, maintained by the qualifying patient and or the qualifying patient’s designated caregiver, to track the use and effects of specific medical marijuana strains and products;

b. A rating scale for pain, cachexia or wasting syndrome, nausea, seizures, muscles spasms, and agitation;

c. Guidelines for the qualifying patient’s self-assessment or, if applicable,assessment of the qualifying patient by the qualifying patient’s designated caregiver; and

d. Guidelines for reporting usage and symptoms to the physician providing the written certification for medical marijuana and any other treating physicians; and

3. Policies and procedures for refusing to provide medical marijuana to an individual who appears to be impaired or abusing medical marijuana.

E. A medical director shall not establish a physician-patient relationship with or provide a written certification for medical marijuana for a qualifying patient.

By Richard Keyt|2011-02-12T08:51:04-07:00January 19th, 2011|DHS Rules, Legal Issues, Medical Directors, Questions People Ask|Comments Off

Beware of the Single Owner Arizona Medical Marijuana Dispensary

Question: Should I be the sole owner of my Arizona medical marijuana dispensary?

Answer: Probably not. Although the Arizona Department of Health Services rules allow an Arizona medical marijuana dispensary to be owned by a single person (a sole proprietor) or a company that has only one owner, I strongly recommend that no dispensary owner be the sole owner of the business. The reason every dispensary should have at least two owners is to prevent the lose of the valuable dispensary license if the sole owner were to die or to become ineligible to be an owner, officer or director of the business.

Two examples will illustrate the terrible consequences of having a sole owner dispensary business.

Example 1: Homer Simpson is the sole owner of an Arizona LLC called Bart’s Greenies, LLC. Homer invested $500,000 to get a dispensary license and open his dispensary in Scottsdale in the food court of the Fashion Square Mall and to set up his 20,000 square foot cultivation farm in Pine Top. Homer unexpectedly dies from joy and pride while attending Bart’s graduation ceremony at the Penn State University Hershey School of Medicine where Bart received his M.D. degree. Because the LLC no longer has an owner approved by the Arizona Department of Health Services to be an owner, the LLC’s dispensary license automatically evaporates and so does all of its value. There is no LLC with a dispensary license to be inherited by Homer’s family.

Example 2: Same facts as in Example 1 except Homer does not die. Instead, Homer divorces Marge and defaults on his child support payments for Maggie. Because Homer is no longer eligible to be an owner, officer or director of an Arizona medical marijuana dispensary the LLC’s dispensary license automatically evaporates and so does all of its value.

Solution: I recommend that every Arizona medical marijuana dispensary organization have at least two owners so that if one of the owners were to die or cease to be eligible to own an interest in the business, the other owner could continue as the sole owner of the business so that the business does not automatically lose its dispensary license. Although a husband and wife who jointly own a dispensary are technically do not have a sole owner business, they should consider having another nominal owner in case the husband and wife were killed in a common accident.

Caution 1: The December 17, 2010, first draft of the proposed rules contains 18 requirements that must be satisfied for a person to become an owner, officer or director of an Arizona medical marijuana dispensary business. If any owner, officer or director ever becomes ineligible to be an owner, officer or director, the business will automatically lose its license to operate the dispensary. This risk of automatic termination is one very big reason why all entities that want to obtain a dispensary license need to purchase my Bylaws that contain provisions intended to protect against the loss of the license if an owner, officer or director ceases to be eligible to be an owner, officer or director. For more about why all dispensaries need properly drafted Bylaws see “Bylaws for Arizona Medical Marijuana Dispensaries.”

Caution 2: Whenever a business has multiple unrelated owners, the owners must enter into a buy-sell agreement that contains their exit strategy. Medical marijuana dispensaries especially need a good buy-sell agreement that covers the automatic buy-out of any owner who ceases to be eligible to be an owner.

By Richard Keyt|2012-05-13T16:24:48-07:00January 18th, 2011|Legal Issues, Questions People Ask|Comments Off

Medical Marijuana Backers Air Views at Tempe Council Session

Arizona Republic: “”A crowd of medical marijuana supporters attended a Tempe City Council meeting to demand that council members respect the ‘will of the voters’ who passed Proposition 203 in November. . . . Many of the medical marijuana advocates took issue with the proposed Tempe ordinance requiring dispensaries be located only in industrial areas and operate only in the daytime.”

By On the Net|2012-08-18T10:16:53-07:00January 18th, 2011|Stories & Articles, Zoning|Comments Off

Arizona Medical Marijuana and Driving Under the Influence (DUI)

In Arizona, there are two ways that you can be charged with a marijuana related DUI:

1. Under the influence of marijuana and impaired to the slightest degree (A.R.S. 28-1381(A)(1))

First, you can be charged with DUI if you are under the influence of marijuana and your driving is found to be “impaired to the slightest degree.” It does not matter if you have a legal prescription for the marijuana. Arizona residents who will now benefit from the new Arizona Medical Marijuana law should be aware that their medical status will not grant them an automatic get-out-of-jail-card when it comes to DUI laws. If the State can prove the marijuana caused impaired driving, you can be charged and convicted of a DUI.

If the prosecutor is charging you with a Section 28-1381(A)(1) charge, he must prove that you were under the influence of marijuana, and your driving was impaired to the slightest degree. To prove you were under the influence of marijuana, the prosecutor will move to submit into evidence a blood or urine test showing the presence of marijuana in your system. A good marijuana DUI defense attorney will examine the evidence to determine how the urine or blood samples were collected and stored, and whether any compelling arguments can be made to suppress the evidence as inadmissible.

A good marijuana DUI defense attorney may also argue that the blood or urine tests do not show you were under the influence of marijuana, despite a test showing the presence of metabolites. Test results do not always distinguish between the psychoactive component of marijuana (“THC”) or its metabolite (“carboxy THC”), which is inactive and does not cause impairment, even though it can stay in your system for weeks. The presence of non-active metabolites do not indicate either impairment or when marijuana was last used or how often it was used.

Even the new Arizona Medical Marijuana law recognizes that someone may have marijuana metabolites that are inactive and do not cause the psychoactive responses caused by THC in marijuana. The new Arizona Medical Marijuana law states that “a registered qualifying patient shall not be considered to be under the influence of marijuana solely because of the presence of metabolites or components of marijuana that appear in insufficient concentration to cause impairment.” The new law recognizes that there are going to be instances of someone lawfully using medical marijuana and still showing metabolites in their system when driving even though they’re not affected by it.

Driving must be impaired to the slightest degree.

In addition to the state having to prove that you were under the influence of marijuana, the prosecutor also has to prove your driving was impaired. You don’t have to crash your vehicle for the prosecutor to prove your driving was impaired. Arizona law only requires the prosecutor to show driving is impaired “to the slightest degree.” The prosecutor will try to prove driving was impaired by introducing evidence of driving errors (even if they are minor), your physical appearance after you were stopped on the road, and performance on any Field Sobriety Tests. Note: decline the FSTs if asked to do so by an officer. These “coordination tests” are extremely difficult to pass and some officers will use them to find fault with whatever you do. It is naive to think if you show you can pass the coordination tests, the officer will let you go. Remember, you are not required by law to submit to FSTs. However, you ARE required by implied consent law to submit to a blood, breath, or urine test if requested by a police officer. If you do not submit to blood, breath, or urine, the police will get a warrant within minutes to take the sample and you will lose your driver’s license for a year. But always decline the FSTs as they hurt more than help.

2. Operating a motor vehicle with any trace of marijuana in your system (A.R.S. 28-1381(A)(3))

The second way you can be charged with DUI is by merely operating a motor vehicle with any marijuana or marijuana metabolite (“THC”) in your system. If the prosecutor is charging you with a Section 28-1381(A)(3) charge, he is not required to prove your driving was impaired, only that it was in your system. This “zero tolerance” law creates an interesting question for medical marijuana users who legally use marijuana, and then drive a car days later when the inactive metabolites may be present. If they are stopped and tested for DUI, how do these medical marijuana patients know the metabolites are present if they do not cause psychoactive symptoms/reactions? A good marijuana DUI defense lawyer may make a constitutional argument that you couldn’t have known inactive metabolites were present in your system and therefore you shouldn’t be criminally liable when you are not under the influence of marijuana. If you have been arrested for marijuana or any drug DUI, you should discuss these charges with an experienced DUI marijuana lawyer.

Penalties and Sentences for DUI marijuana misdemeanors in Arizona:

In Arizona, a first time DUI offense involving marijuana is a misdemeanor punishable by a minimum one day to a maximum six month jail sentence, fines and fees ranging from $1,470 or more, a mandatory substance abuse program, and you must put an ignition interlock device on your car. Additionally, if the conviction involves marijuana alone, your driver’s license will be revoked for one year. Ironically, if you are driving under the influence of marijuana AND alcohol, your license might only be suspended for 90 days because your plea bargain might involve pleading to the alcohol component of the DUI and not the marijuana. However, it’s only logical that alcohol and marijuana mixed together will make your driving more impaired so just don’t do it.

If this is a second misdemeanor DUI involving marijuana or another drug, the minimum jail sentence is 30 days, the fine is increased to a minimum of $3,430 and at least 30 hours of community service will be ordered in addition to an 18 month license revocation and ignition interlock device requirement.

If if the DUI is a third offense within 7 years, or your driver’s license was already suspended or revoked, or there was a child in the vehicle at the time, the DUI is charged as a felony and you could be facing a longer jail and/or prison sentence.

If you are charged with a violation of Arizona law involving marijuana and need experienced legal representation, call me, Karen Boehmer at 602-796-0882.

By Karen Boehmer|2017-02-11T17:26:53-07:00January 17th, 2011|Marijuana Crimes|Comments Off

Bylaws for Arizona Medical Marijuana Dispensaries

All Arizona Medical Marijuana Dispensaries Must Have Bylaws

Arizona law requires that all Arizona corporations (for profit and nonprofit) adopt Bylaws. Since Proposition 203 became law on December 15, 2010, all organizations (not just corporations) that seek a license to own and operate a dispensary in Arizona must adopt Bylaws. Arizona Revised Statutes Section 36-2806.A states:

“The Bylaws of a registered nonprofit medical marijuana dispensary shall contain such provisions relative to the disposition of revenues and receipts to establish and maintain its nonprofit character.”

Bylaws is the name given to the policies and procedures that govern the internal operation of a business organization. The Merriam-Webster dictionary defines bylaws as “a rule adopted by an organization chiefly for the government of its members and the regulation of its affairs.”

Before Proposition 203 became the law of Arizona Bylaws were used almost exclusively by corporations. As an Arizona business attorney, I have formed over 3,200 Arizona limited liability companies since I started counting in 2002. Not one of the LLCs I formed prior to Proposition 203 have Bylaws because the Arizona laws that govern Arizona LLCs do not require Arizona LLCs to adopt Bylaws. Arizona statutory law requires that all Arizona corporations adopt Bylaws. Arizona Revised Statutes Section 10-206 (for profit corps) and Section 10-3206.A (nonprofit corps) both contain the following corporate requirement:

“The board of directors of a corporation shall adopt initial bylaws for the corporation.”

If you are part of an organization (regardless of the type of entity) that will seek to obtain a license to own and operate an Arizona medical marijuana dispensary, you must make sure that your organization has Bylaws that contain the specific language required by Arizona medical marijuana law and the Arizona Department of Health Services. If your organization does not have the required Bylaws, it’s application for a dispensary license will be rejected.

See my article called “Bylaws – We Don’t Need No Stinking Bylaws or Do We?”

By Richard Keyt|2017-02-12T07:10:46-07:00January 17th, 2011|Legal Issues|Comments Off

Text of the Public Comments to the 1st Draft of the Rules

On December 17, 2010, the Arizona Department of Health Services posted a draft of the medical marijuana rules for public comment. Read the following comments received by ADHS via its online survey from December 17, 2010, through January 7, 2011:

The Department also received the additional comments below:

Group A | Group B | Group C

By On the Net|2011-01-18T19:12:41-07:00January 15th, 2011|DHS Rules|Comments Off

Chandler Planners Mull Marijuana Restrictions

Arizona Republic: “Proposals for [medical marijuana dispensary] restrictions in Chandler, including those below, go before the city’s Planning and Zoning Commission on Wednesday for an advisory vote before it goes to the City Council in February. The 7 p.m. commission meeting is in City Council Chambers, 88 E. Chicago St.”

By On the Net|2012-08-18T09:29:36-07:00January 15th, 2011|Zoning|Comments Off

Gilbert Sets Rules for Medical Marijuana Locations, Hours

Arizona Republic: “As area entrepreneurs prepare to capitalize on a voter-approved initiative legalizing medical marijuana, the Gilbert Town Council approved regulations on where, when and how the pot-based businesses can operate. Dispensaries and cultivation sites will only be allowed within industrial zoning districts in northwest Gilbert near Morrison Ranch and near Gilbert Road and the Santan Freeway.”

By On the Net|2012-08-18T09:34:53-07:00January 15th, 2011|Stories & Articles, Zoning|Comments Off

Glendale Unveils Medical-marijuana Proposals

Arizona Republic: “Residents armed with questions attended a community meeting Thursday to hear Glendale’s proposed zoning restrictions on marijuana-related facilities. City planners propose to allow dispensaries in general-office, general-commercial and heavy-commercial zones and the cultivation in light- and heavy-industrial zones.”

By On the Net|2012-08-18T09:37:41-07:00January 11th, 2011|Stories & Articles, Zoning|Comments Off

Alan Sobol Challenges Andrew Meyer to a Verbal Duel

I got an email message from The Consiglieri Group on January 10, 2011, in which Alan Sobol is asking Andrew Meyers of the Arizona Medical Marijuana Association to debate him. Here’s the text of the challenge:

“The Challenge: Allan Sobol Vs. MPP Local Manager Andrew Meyer. OPEN CHALLENGE TO ANDREW MEYER. 2 hour Debate/discussion on the contested issues concerning the implementation of the new Arizona Medical Marijuana Act. Paid conference hall meeting with all proceeds going to AZDHS to offset the cost of applications for low income qualifying patients. Lets See if Mr, Meyers will respond.”

I’d like to attend, but I’m guessing Mr. Meyer will not accept the challenge.

By Richard Keyt|2011-01-15T09:15:00-07:00January 10th, 2011|Stories & Articles|Comments Off

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