The Honorable William Barr
Attorney General of the United States
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001
Re: ADB-FUBINACA (arbitrary scheduling) assigned ID number 4287762.
Dear Mr. Barr
Our community letter to your office on June 24th, 2019 was forwarded to the Drug Enforcement administration (DEA). Whose response did not address the Public's concerns addressed in corresponded case number 4287762 to our Attorney General William Barr.
Our concerns to your office are directly related to the DEA's abuse of the delegated powers afforded by the United States Attorney General. Without over-sight.
As it relates to ADB-FUBINACA specifically the World Health Organization (WHO) did an extensive analysis and everything the Commission on Narcotic Drugs is alleging was totally debunked by the WHO Critical Review Report (See attached Critical Review Report). Which proves that the effect, abuse potential and potency has NOT been, to date, tested or determined. The Commission is clearly generalizing the effects, abuse potential and potency by analysis done and resulted on other strains of Synthetic Marijuana to make a determination on the effects, abuse potential and potency for ADB-FUBINACA, in order, to place ADB-FUBINACA on permanent control. This amounts to arbitrary enforcement and a substance being placed illegally as controlled substance without the required analysis being done.
Thus, being the facts as they are, we ask HOW can a substance be placed or the Commission vote to Control ADB-Fubinaca under the 1971 United Nations Convention on Psychotropic substances? Without the proper analysis being done and/or determined?
This matter is of great concern and of Public Interest,
Fernando R. Rodriguez
13301 SW 96 Avenue
Miami, FL. 33176