June 24, 2019
To: 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)
Dear Mr. Barr,
Anguished our community reaches out to you. Last week my son was sentenced to an unjust and draconian 33 years in prison for under (1) kilo of fake weed strain called ADB-FUBINACA.
In our research we've learned that the Attorney General delegates the authority to place substances on temporary scheduling to the Drug Enforcement Administration (DEA).
In April 10, 2017, The DEA placed ADB-FUBINACA on it's temporary scheduling list. Rule document: Federal Registry Number 2017-07118.
In November 2018, The World Health Organization (WHO) along with the DEA during their 5 day "Expert Committee on Drug Dependence, Forty-First Meeting, Geneva, 12-16 November 2018", Published "Critical Review Report: ADB-FUBINACA".
See Report herein attached.
Facts and Conclusion:
1) ADB-FUBINACA (CAS: 1445583-53-6) is a synthetic cannabinoid that was first documented in international patent WO 2009/1069880-A2 issued to Ingrid Buchler and colleagues at Pfizer on September 3, 2009.
2) ADB-FUBINACA is NOT readily converted into other controlled substances.
3) Toxicology: Preclinical evaluation of acute or chronic toxicological effects of ADB-FUBINACA has NOT been conducted.
4) Dependence potential: The dependence potential of ADB-FUBINACA has NOT been evaluated or assessed in humans or in animals. Has NOT been evaluated for its dependence potential on humans.
5) Abuse potential: The abuse potential of ADB-FUBINACA has NOT been evaluated or assessed in humans or in animals. It has NOT been tested in drug discrimination or self-administration.
6) Reports on pharmacological effects of ADB-FUBINACA in humans after chronic use have NOT been done.
7) ADB-FUBINACA is NOT subject to international controls under the 1971 United Nations Convention on Psychotropic Substances or the 1961 Single Convention on Narcotic Drug.
8) Unit States: On April 10, 2017, the U.S. Drug Enforcement Agency issued an order for temporary placement of ADB- FUBINACA under Scheduling 1 Control.
9) ADB-FUBINACA has NOT been the cause of a single death in the United States.
How is it possible that a substance can be placed on Temporary Scheduling and/or considered a Scheduled 1 Controlled Substance if there has not been any studies or evidence as outlined above? The DEA is running amok with it's delegated powers and arbitrarily placing everything on temporary schedules. This is causing oppressive abuses on Americans.
Sir Every cleaning product on store shelves is more dangerous then this phantom substance ADB-FUBINACA. And how could my son receive a 33 year sentence for a substance that's empirically innocuous and that it is believed to mimic the effects of marijuana?
Sir Our community and family ask that ADB-FUBINACA be removed from it's Temporary Scheduling. As it is resulting in oppressive and arbitrary sentences, a humanitarian crisis's against Americans.
Fernando R. Rodriguez
13301 SW 96 Avenue
Miami, FL. 33176