An American Injustice
8101 SW 72ND AV. Suite 101W.
Miami, FL 33143
September 5, 2019
To: Neil D. Doherty, Deputy Assistant Administrator
U.S. DEPARTMENT OF JUSTICE
DRUG ENFORCEMENT ADMINISTRATION (Diversion Control Division)
8701 Morrissette Drive. Springfield, VA 22152
Re: ADB-FUBINACA (arbitrary scheduling) assigned ID number 4287762.
Dear Mr. Doherty,
Our community letter to your office on June 24th, 2019 was forwarded to the Deputy Assistant Administrator. Whose response did not address the Public's concerns addressed in corresponded case number 4287762 to our Attorney General William Barr.
Our concerns to the Attorney General 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. Your response wrongly claimed that the data your division relied on was detained from in vitro and in vivo scientific studies. Yet the attached report is absolutely clear that no such studies have been done on ADB-FUBINACA. 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 determined. See attachment.
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.