This document is a first amended complaint filed in California Superior Court by Medical Marijuana, Inc. and HempMeds PX, LLC against CannLabs, Inc., Rifle Mountain, LLC, and several individuals. It alleges causes of action for libel, trade libel, false light, negligence, and intentional interference with prospective business advantage based on statements made by the defendants regarding the plaintiffs and their CBD products. The complaint provides background on the parties and alleges the defendants conspired to tortiously injure the plaintiffs through defamatory statements made on the internet, causing damage to the plaintiffs' reputation and business interests.
Temuryan et al vs jensen, wead, Cosway 2ACArmen Temurian
Armen Temuryan sues Glen Jensen, Brent Jensen, Douglas Wead, Cosway, et al. for Breech of Contract, etc.
Read All About It Before You Join an MLM with these people Involved. The Truth does set you free. It IS Knowledge which will help you make correct decisions and eliminate Loss, Hurt and protect those you will be responsible for bringing into engagement after you are recruited into the next MLM business with these characters I am suing. INTEGRITY is always doing what is right even if you had to forfeit millions. Never Compromise. Never. Never fear you will incur loss if you are always Integral. It Always happens, What you will Deposit in the North, you will ALWAYS withdraw in the South. This is Integrity. Your name will always remain GOLD. More valuable then then most valuable commodity - money, is TRUST.
Armen Temuryan
Official Motion to add 200 new plaintiffs to the Armando Montelongo Lawsuit. This outlines how attempts to Arbitrate the case failed due to Montelongo refusing to follow the American Arbitration Association Rules, thus they declined to arbitrate the case and asked he remove their name from clauses in the contract. In addition, new plaintiff's have approached the case with similar details of fraud. See additional file with documentation supporting the case, or get a synopsis at http://www.jeannorton.com/armando-montelongo-rico-doubles/
Temuryan et al vs jensen, wead, Cosway 2ACArmen Temurian
Armen Temuryan sues Glen Jensen, Brent Jensen, Douglas Wead, Cosway, et al. for Breech of Contract, etc.
Read All About It Before You Join an MLM with these people Involved. The Truth does set you free. It IS Knowledge which will help you make correct decisions and eliminate Loss, Hurt and protect those you will be responsible for bringing into engagement after you are recruited into the next MLM business with these characters I am suing. INTEGRITY is always doing what is right even if you had to forfeit millions. Never Compromise. Never. Never fear you will incur loss if you are always Integral. It Always happens, What you will Deposit in the North, you will ALWAYS withdraw in the South. This is Integrity. Your name will always remain GOLD. More valuable then then most valuable commodity - money, is TRUST.
Armen Temuryan
Official Motion to add 200 new plaintiffs to the Armando Montelongo Lawsuit. This outlines how attempts to Arbitrate the case failed due to Montelongo refusing to follow the American Arbitration Association Rules, thus they declined to arbitrate the case and asked he remove their name from clauses in the contract. In addition, new plaintiff's have approached the case with similar details of fraud. See additional file with documentation supporting the case, or get a synopsis at http://www.jeannorton.com/armando-montelongo-rico-doubles/
Peter C. Sheridan, the Chair of Glaser Weil’s Construction Law Practice Group, heads a team of attorneys who focus on construction law, complex real estate, eminent domain and inverse condemnation cases. He represents owners, developers and architects in California, Nevada and internationally, and is a Charter Fellow of the Construction Lawyers Society of America (CLSA).
I don't know that I have an opinion about this yet but there are other documents that I will upload that will need to be looked at as well to come to a conclusion.
Vegas physician, America's Frontline Doctors sued after Reno man died from ta...This Is Reno
The estate of Jeremy Parker last week sued the anti-vaccination, right-wing group America's Frontline Doctors for alleged wrongful death. Dr. Medina Culver, an osteopathic physician and Instagram influencer based in Henderson, Nevada, is also named in the case. The lawsuit alleges negligence by the group and Culver for the death of Parker last year.
"Based on information provided by America's Frontline Doctors, Mr. Parker became convinced, along with several of his co-workers, that hydroxychloroquine was an effective treatment for COVID-19," the suit alleges. "On or about August 26, 2021, Mr. Parker had a telemedicine visit with Dr. Culver, at which time Dr. Culver prescribed Mr. Parker with hydroxychloroquine and/or ivermectin for COVID-19 treatment or 'preventative therapy.' Dr. Culver never performed a physical examination of Mr. Parker."
According to the suit, Parker developed cold-like symptoms in late January of 2022. His body was found Feb. 3, 2022. The Washoe County coroner listed Parker's cause of death as "sudden in the setting of therapeutic use of hydroxychloroquine."
Frank Yan and James "Nick" Salondaka are mortgage Fraud Con Men. Here is one lawsuit that shows the partners fraud. Frank Yan and Nick Salondaka are both being investigated for years of selling loans through FRAUD. My family is losing our home to these crooks.
Kyko Global Inc. Files Complaint against Madhavi Vuppalapati & Prithvi Info S...mh37o
This is the complaint copy by United States District Court of Washington filed by Kyko Global Inc against Madhavi Vuppalapati & Prithvi Info Solutions Ltd.
Complaint for breach of contract, constructive fraud, constructive trust and unfair business practices against Joshua Macciello, self-pronounced bidder for the Dodgers and alleged film producer. Anyone with knowledge of Mr. Macciello's whereabouts, or who "invested" or "lent" money to Mr. Macciello, please contact CharismaticScam@gmail.com
The Hells Angels Motorcycle Club's cyberpiracy and trademark infringement lawsuit against the seller of domain names that the HAMC charges infringe upon its intellectual property rights.
LEGAL SYSTEM ABUSE REPARATION BILLS
LONG-TERM WIDESPREAD FRAUD
JUDGES ABOVE THE LAW- NO RULE OF LAW-NO REMEDY AT LAW
WHISTLEBLOWER LAW FIRMS/LAW CLINICS/HUMAN RIGHT DEFENDERS
https://judicialcriminal.com/ (USA)
BOOK/AMAZON: JUDICIAL CRIMINALS The Greatest fraud upon American society America’s Legal System
https://www.amazon.com/dp/B07G4K3QFY?ref_=k4w_oembed_YSuOoH1t7Ab8kJ&tag=kpembed-20&linkCode=kpd (USA)
See Case No. 3:13-cv-1944 CAB BLM Judge Cathy Ann Bencivengo FIRST AMENDED COMPLAINT
1. VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1871 (42 U.S.C. §§ 1983, 1985, 1986);
2. RACKETEERING AND CORRUPT ORGANIZATIONS ACT OF 1970 (18 U.S.C. § 1962);
3. FALSE ADVERTISING (15 U.S.C. § 1125);
WHISTLEBLOWER LAW FIRMS/LAW CLINICS/HUMAN RIGHT DEFENDERS
LEGAL SYSTEM ABUSE REPARATION BILLS
LONG-TERM WIDESPREAD FRAUD
JUDGES ABOVE THE LAW- NO RULE OF LAW-NO REMEDY AT LAW
https://judicialcriminal.com/ (USA)
BOOK/AMAZON: JUDICIAL CRIMINALS The Greatest fraud upon American society America’s Legal System
https://www.amazon.com/dp/B07G4K3QFY?ref_=k4w_oembed_YSuOoH1t7Ab8kJ&tag=kpembed-20&linkCode=kpd (USA)
See Case No. 3:13-cv-1944 CAB BLM Judge Cathy Ann Bencivengo FIRST AMENDED COMPLAINT
1. VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1871 (42 U.S.C. §§ 1983, 1985, 1986);
2. RACKETEERING AND CORRUPT ORGANIZATIONS ACT OF 1970 (18 U.S.C. § 1962);
3. FALSE ADVERTISING (15 U.S.C. § 1125);
Peter C. Sheridan, the Chair of Glaser Weil’s Construction Law Practice Group, heads a team of attorneys who focus on construction law, complex real estate, eminent domain and inverse condemnation cases. He represents owners, developers and architects in California, Nevada and internationally, and is a Charter Fellow of the Construction Lawyers Society of America (CLSA).
I don't know that I have an opinion about this yet but there are other documents that I will upload that will need to be looked at as well to come to a conclusion.
Vegas physician, America's Frontline Doctors sued after Reno man died from ta...This Is Reno
The estate of Jeremy Parker last week sued the anti-vaccination, right-wing group America's Frontline Doctors for alleged wrongful death. Dr. Medina Culver, an osteopathic physician and Instagram influencer based in Henderson, Nevada, is also named in the case. The lawsuit alleges negligence by the group and Culver for the death of Parker last year.
"Based on information provided by America's Frontline Doctors, Mr. Parker became convinced, along with several of his co-workers, that hydroxychloroquine was an effective treatment for COVID-19," the suit alleges. "On or about August 26, 2021, Mr. Parker had a telemedicine visit with Dr. Culver, at which time Dr. Culver prescribed Mr. Parker with hydroxychloroquine and/or ivermectin for COVID-19 treatment or 'preventative therapy.' Dr. Culver never performed a physical examination of Mr. Parker."
According to the suit, Parker developed cold-like symptoms in late January of 2022. His body was found Feb. 3, 2022. The Washoe County coroner listed Parker's cause of death as "sudden in the setting of therapeutic use of hydroxychloroquine."
Frank Yan and James "Nick" Salondaka are mortgage Fraud Con Men. Here is one lawsuit that shows the partners fraud. Frank Yan and Nick Salondaka are both being investigated for years of selling loans through FRAUD. My family is losing our home to these crooks.
Kyko Global Inc. Files Complaint against Madhavi Vuppalapati & Prithvi Info S...mh37o
This is the complaint copy by United States District Court of Washington filed by Kyko Global Inc against Madhavi Vuppalapati & Prithvi Info Solutions Ltd.
Complaint for breach of contract, constructive fraud, constructive trust and unfair business practices against Joshua Macciello, self-pronounced bidder for the Dodgers and alleged film producer. Anyone with knowledge of Mr. Macciello's whereabouts, or who "invested" or "lent" money to Mr. Macciello, please contact CharismaticScam@gmail.com
The Hells Angels Motorcycle Club's cyberpiracy and trademark infringement lawsuit against the seller of domain names that the HAMC charges infringe upon its intellectual property rights.
LEGAL SYSTEM ABUSE REPARATION BILLS
LONG-TERM WIDESPREAD FRAUD
JUDGES ABOVE THE LAW- NO RULE OF LAW-NO REMEDY AT LAW
WHISTLEBLOWER LAW FIRMS/LAW CLINICS/HUMAN RIGHT DEFENDERS
https://judicialcriminal.com/ (USA)
BOOK/AMAZON: JUDICIAL CRIMINALS The Greatest fraud upon American society America’s Legal System
https://www.amazon.com/dp/B07G4K3QFY?ref_=k4w_oembed_YSuOoH1t7Ab8kJ&tag=kpembed-20&linkCode=kpd (USA)
See Case No. 3:13-cv-1944 CAB BLM Judge Cathy Ann Bencivengo FIRST AMENDED COMPLAINT
1. VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1871 (42 U.S.C. §§ 1983, 1985, 1986);
2. RACKETEERING AND CORRUPT ORGANIZATIONS ACT OF 1970 (18 U.S.C. § 1962);
3. FALSE ADVERTISING (15 U.S.C. § 1125);
WHISTLEBLOWER LAW FIRMS/LAW CLINICS/HUMAN RIGHT DEFENDERS
LEGAL SYSTEM ABUSE REPARATION BILLS
LONG-TERM WIDESPREAD FRAUD
JUDGES ABOVE THE LAW- NO RULE OF LAW-NO REMEDY AT LAW
https://judicialcriminal.com/ (USA)
BOOK/AMAZON: JUDICIAL CRIMINALS The Greatest fraud upon American society America’s Legal System
https://www.amazon.com/dp/B07G4K3QFY?ref_=k4w_oembed_YSuOoH1t7Ab8kJ&tag=kpembed-20&linkCode=kpd (USA)
See Case No. 3:13-cv-1944 CAB BLM Judge Cathy Ann Bencivengo FIRST AMENDED COMPLAINT
1. VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1871 (42 U.S.C. §§ 1983, 1985, 1986);
2. RACKETEERING AND CORRUPT ORGANIZATIONS ACT OF 1970 (18 U.S.C. § 1962);
3. FALSE ADVERTISING (15 U.S.C. § 1125);
Sample California complaint for assault and batteryLegalDocsPro
This sample California complaint for assault and battery also includes a cause of action for intentional infliction of emotional distress. The sample could be modified to add other causes of action as well. This is a preview of the sample complaint sold by LegalDocsPro.
Let's discuss it here. I posted this in the
forum earlier today:
I'm definitely not that happy with the alerts
lately. I understand the reasons they are
being done: trim the paper portfolio, etc, but
let's have a little compassion for all the
underwater stock holders who have
patiently held for a couple months, & just
want now to be able to break even, let
alone make money.
Terra Tech Corp. Edible Garden Issue August 14, 2014Norman Gates
A greenhouse in Warren County is at the center of that debate. People living around the Edible Garden plant say it was fine when the company started growing organic vegetables. They're worried about what growing marijuana there will do to their community. The petition clearly states the position of some Brookfield Glen residents in White Township, Warren County. They oppose the legalization and production of marijuana in the Garden State. “This is a horror," said Rita Foti, organizer of the petition. "Somebody wants to turn the growth of marijuana into a healthy cash crop.” Fred and Rita Foti caught wind of the possible plan after seeing news reports that owners of Edible Garden Greenhouse on Route 519 want to start a marijuana farm if recreational use of the drug is legalized in Trenton.
Terra Tech Corp. Edible Garden Issue June 12, 2014Norman Gates
A greenhouse in Warren County is at the center of that debate. People living around the Edible Garden plant say it was fine when the company started growing organic vegetables. They're worried about what growing marijuana there will do to their community. The petition clearly states the position of some Brookfield Glen residents in White Township, Warren County. They oppose the legalization and production of marijuana in the Garden State. “This is a horror," said Rita Foti, organizer of the petition. "Somebody wants to turn the growth of marijuana into a healthy cash crop.” Fred and Rita Foti caught wind of the possible plan after seeing news reports that owners of Edible Garden Greenhouse on Route 519 want to start a marijuana farm if recreational use of the drug is legalized in Trenton.
Immune system dysregulation is well-recognized in autism and thought to be part of the etiology of this disorder. The endocannabinoid system is a key regulator of the immune system via the cannabinoid receptor type 2 (CB2R) which is highly expressed on macrophages and microglial cells. We have previously published significant differences in peripheral blood mononuclear cell CB2R gene expression in the autism population. The use of the Gc protein-derived Macrophage Activating Factor (GcMAF), an endogenous glycosylated vitamin D binding protein responsible for macrophage cell activation has demonstrated positive effects in the treatment of autistic children. In this current study, we investigated the in vitro effects of GcMAF treatment on the endocannabinoid system gene expression, as well as cellular activation in blood monocyte-derived macrophages (BMDMs) from autistic patients compared to age-matched healthy developing controls.
Conclusions
This study presents the first observations of GcMAF effects on the transcriptionomics of the endocannabinoid system and expression of CB2R protein. These data point to a potential nexus between endocannabinoids, vitamin D and its transporter proteins, and the immune dysregulations observed with autism.
The Drug Enforcement Administration is raising the production quota for marijuana that is ordered by the federal government.
The National Institute on Drug Abuse produces marijuana for the purpose of research. The DEA is giving the agency permission to produce up to 600 kilograms of marijuana this year.
"The aggregate production quota for marijuana should be increased in order to provide a continuous and uninterrupted supply of marijuana in support of DEA-registered researchers who are approved by the federal government to utilize marijuana in their research protocols," the agency wrote.
The United States Government established a Claims Process to make available up to $1.33 billion or more to farmers who alleged discrimination by the U.S. Department of Agriculture (USDA) based on being female, or based on being Hispanic, in making or servicing farm loans during certain periods between 1981 and 2000. If you qualified and submitted a timely claim, you could receive an award of up to $50,000 or up to $250,000 in cash, depending on the evidence that you submitted. USDA will also provide a total of up to $160 million in debt relief to successful Claimants who currently owe USDA money for eligible farm loans. Successful Claimants may also receive an additional amount, equal to 25% of the combined cash award plus the principal amount of debt relief, to help pay federal taxes that may be owed.
Attorney General Eric Holder is expected to answer questions about federal marijuana policy during a Tuesday hearing of the House Judiciary Committee regarding Oversight of the U.S. Department of Justice. Holder will be providing testimony regarding various Obama administration enforcement policies.
Rose S, Frye RE, Slattery J, Wynne R, Tippett M, et al. (2014) Oxidative Stress Induces Mitochondrial Dysfunction in a Subset of Autism Lymphoblastoid Cell Lines in a Well-Matched Case Control Cohort. PLoS ONE 9(1):e85436.doi:10.1371/journal.pone.0085436.
The invention involves transforming Cannabis with a transgene(s) or chemical(s) expressing biological, chemical, luminescent, and fluorescent markers from the UV, visible, near, mid, and far spectrums of light. This transformation allows for the detection of Medical Marijuana from other forms of marijuana. Cannabis is a genus of flowering plant that include three putative species Cannabis sativa, Cannabis indica, and Cannabis ruderalis. The invention relates to seeds, plants, plant cells, plant tissue, and harvested products from transformed Cannabis. The invention also relates to plants and varieties produced by the method of essential derivation from plants of transformed Cannabis and to plants of transformed Cannabis reproduced by vegetative methods, including but not limited to tissue culture of regenerated cells or tissue from transformed Cannabis.
Medical Marijuana, Inc is extremely pleased with Q4 performance which has exceeded expectations in sales and awareness of the benefits of CBD-rich hemp oil products. Due to rapidly expanding growth, the Company is in the process of securing additional office space to relocate the corporate office and obtain a larger warehousing distribution center. It is anticipated that sales and customer service will remain at the existing facility.
Tata Group Dials Taiwan for Its Chipmaking Ambition in Gujarat’s DholeraAvirahi City Dholera
The Tata Group, a titan of Indian industry, is making waves with its advanced talks with Taiwanese chipmakers Powerchip Semiconductor Manufacturing Corporation (PSMC) and UMC Group. The goal? Establishing a cutting-edge semiconductor fabrication unit (fab) in Dholera, Gujarat. This isn’t just any project; it’s a potential game changer for India’s chipmaking aspirations and a boon for investors seeking promising residential projects in dholera sir.
Visit : https://www.avirahi.com/blog/tata-group-dials-taiwan-for-its-chipmaking-ambition-in-gujarats-dholera/
What is the TDS Return Filing Due Date for FY 2024-25.pdfseoforlegalpillers
It is crucial for the taxpayers to understand about the TDS Return Filing Due Date, so that they can fulfill your TDS obligations efficiently. Taxpayers can avoid penalties by sticking to the deadlines and by accurate filing of TDS. Timely filing of TDS will make sure about the availability of tax credits. You can also seek the professional guidance of experts like Legal Pillers for timely filing of the TDS Return.
"𝑩𝑬𝑮𝑼𝑵 𝑾𝑰𝑻𝑯 𝑻𝑱 𝑰𝑺 𝑯𝑨𝑳𝑭 𝑫𝑶𝑵𝑬"
𝐓𝐉 𝐂𝐨𝐦𝐬 (𝐓𝐉 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬) is a professional event agency that includes experts in the event-organizing market in Vietnam, Korea, and ASEAN countries. We provide unlimited types of events from Music concerts, Fan meetings, and Culture festivals to Corporate events, Internal company events, Golf tournaments, MICE events, and Exhibitions.
𝐓𝐉 𝐂𝐨𝐦𝐬 provides unlimited package services including such as Event organizing, Event planning, Event production, Manpower, PR marketing, Design 2D/3D, VIP protocols, Interpreter agency, etc.
Sports events - Golf competitions/billiards competitions/company sports events: dynamic and challenging
⭐ 𝐅𝐞𝐚𝐭𝐮𝐫𝐞𝐝 𝐩𝐫𝐨𝐣𝐞𝐜𝐭𝐬:
➢ 2024 BAEKHYUN [Lonsdaleite] IN HO CHI MINH
➢ SUPER JUNIOR-L.S.S. THE SHOW : Th3ee Guys in HO CHI MINH
➢FreenBecky 1st Fan Meeting in Vietnam
➢CHILDREN ART EXHIBITION 2024: BEYOND BARRIERS
➢ WOW K-Music Festival 2023
➢ Winner [CROSS] Tour in HCM
➢ Super Show 9 in HCM with Super Junior
➢ HCMC - Gyeongsangbuk-do Culture and Tourism Festival
➢ Korean Vietnam Partnership - Fair with LG
➢ Korean President visits Samsung Electronics R&D Center
➢ Vietnam Food Expo with Lotte Wellfood
"𝐄𝐯𝐞𝐫𝐲 𝐞𝐯𝐞𝐧𝐭 𝐢𝐬 𝐚 𝐬𝐭𝐨𝐫𝐲, 𝐚 𝐬𝐩𝐞𝐜𝐢𝐚𝐥 𝐣𝐨𝐮𝐫𝐧𝐞𝐲. 𝐖𝐞 𝐚𝐥𝐰𝐚𝐲𝐬 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐬𝐡𝐨𝐫𝐭𝐥𝐲 𝐲𝐨𝐮 𝐰𝐢𝐥𝐥 𝐛𝐞 𝐚 𝐩𝐚𝐫𝐭 𝐨𝐟 𝐨𝐮𝐫 𝐬𝐭𝐨𝐫𝐢𝐞𝐬."
Personal Brand Statement:
As an Army veteran dedicated to lifelong learning, I bring a disciplined, strategic mindset to my pursuits. I am constantly expanding my knowledge to innovate and lead effectively. My journey is driven by a commitment to excellence, and to make a meaningful impact in the world.
Unveiling the Secrets How Does Generative AI Work.pdfSam H
At its core, generative artificial intelligence relies on the concept of generative models, which serve as engines that churn out entirely new data resembling their training data. It is like a sculptor who has studied so many forms found in nature and then uses this knowledge to create sculptures from his imagination that have never been seen before anywhere else. If taken to cyberspace, gans work almost the same way.
Kseniya Leshchenko: Shared development support service model as the way to ma...Lviv Startup Club
Kseniya Leshchenko: Shared development support service model as the way to make small projects with small budgets profitable for the company (UA)
Kyiv PMDay 2024 Summer
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RMD24 | Retail media: hoe zet je dit in als je geen AH of Unilever bent? Heid...BBPMedia1
Grote partijen zijn al een tijdje onderweg met retail media. Ondertussen worden in dit domein ook de kansen zichtbaar voor andere spelers in de markt. Maar met die kansen ontstaan ook vragen: Zelf retail media worden of erop adverteren? In welke fase van de funnel past het en hoe integreer je het in een mediaplan? Wat is nu precies het verschil met marketplaces en Programmatic ads? In dit half uur beslechten we de dilemma's en krijg je antwoorden op wanneer het voor jou tijd is om de volgende stap te zetten.
Attending a job Interview for B1 and B2 Englsih learnersErika906060
It is a sample of an interview for a business english class for pre-intermediate and intermediate english students with emphasis on the speking ability.
The world of search engine optimization (SEO) is buzzing with discussions after Google confirmed that around 2,500 leaked internal documents related to its Search feature are indeed authentic. The revelation has sparked significant concerns within the SEO community. The leaked documents were initially reported by SEO experts Rand Fishkin and Mike King, igniting widespread analysis and discourse. For More Info:- https://news.arihantwebtech.com/search-disrupted-googles-leaked-documents-rock-the-seo-world/
LA HUG - Video Testimonials with Chynna Morgan - June 2024Lital Barkan
Have you ever heard that user-generated content or video testimonials can take your brand to the next level? We will explore how you can effectively use video testimonials to leverage and boost your sales, content strategy, and increase your CRM data.🤯
We will dig deeper into:
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2. How to leverage your testimonials to boost your sales 💲
3. How you can capture more CRM data to understand your audience better through video testimonials. 📊
LA HUG - Video Testimonials with Chynna Morgan - June 2024
Medical Marijuana Inc. Smear Campaign Lawsuit
1. ll115 Al lb A lit 1 _
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1
4
Phillip E. Koehnke, Esq. (163912)
Phillip E. Koehnke, APC
PO Box 235472
2 Encinitas, CA 92024
(858) 229-8116
3
Attorneys for Medical Marijuana, Inc.
And HempMeds PX, LLC 4.
JAN 16 2015
FChit at th. Suptior
Ecouip
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO — CENTRAL DIVISION
Medical Marijuana, Inc., an Oregon
Corporation; HempMeds PX, LLC, a
California Limited Liability Company;
Plaintiffs,
VS.
CannLabs, Inc., a Nevada
Corporation, Rifle Mountain, LLC, a
Colorado Limited Liability Company,
Stewart Environmental Consultants,
LLC, a Colorado Limited Liability
Company, Genifer Murray, an
individual, Jason Cranford, an
individual, ProjectCBD.com , a
California business entity, Aaron
Miguel Cantu, an individual, Martin
Lee, an individual, and DOES 1-20
inclusive,
Defendants.
CASE NO. JANI675,='10C3
37-2014-00036039-CU-DF-CTL
FIRST AMENDED COMPLAINT FOR:
1. Libel
2. Trade Libel
3. False Light
4. Negligence
5. Intentional Interference with
Prospective Business Advantage
Judge: Joel R. Wohlfeil
Dept: C-73
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PLAINTIFFS MEDICAL MARIJUANA, INC. AND HEMPMEDS PX, LLC ARE
INFORMED AND BELIEVE, AND BASED THEREON ALLEGE AS FOLLOWS:
Il-
///
///
FIRST AMENDED COMPLAINT
www.cannabidial.com
2. PARTIES
1. At all times herein mentioned, Plaintiff, MEDICAL MARIJUANA, INC. was, and
now is, an Oregon Corporation registered to do business in California, doing business in the
County of San Diego, State of California.
2. At all times herein mentioned, Plaintiff, HEMPMEDS PX, LLC was, and now is,
a California Limited Liability Company, doing business in the County of San Diego, State of
California. HEMPMEDS PX, LLC is a wholly owned subsidiary of MEDICAL MARIJUANA,
INC.
3. As used herein, "Plaintiffs" collectively refers to MEDICAL MARIJUANA, INC.
and HEMPMEDS PX, LLC.
4. Plaintiffs are informed and believe, and based thereon allege, that Defendant,
GENIFER MURRAY (hereinafter referred to as "Murray") is, and at all times herein mentioned
was, an individual with continuous and substantial contacts with the State of California,
including, but not limited to, solicitation of business, formulation, publication, and distribution of
statements and posts via the Internet throughout the State of California, as well as in all other
states of the United States, and throughout the world.
5. Plaintiffs are informed and believe, and based there on allege, that Defendant
Murray is, and at all times herein mentioned was, the Chief Executive Officer and President of
CannLabs, Inc., a Nevada corporation with its principle place of business located in Denver,
Colorado, and is publicly traded on the stock market under the ticker "CANL..
6. Plaintiffs are informed and believe, and based thereon allege, that Defendant,
JASON CRANFORD (hereinafter referred to as "Cranford") is, and at all times herein
mentioned was, an individual with continuous and substantial contacts with the State of
California, including, but not limited to, conducting business while serving as a Board Member
for KannaLife Sciences, Inc., formulating, publishing, and distributing statements via the
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FIRST AMENDED COMPLAINT
www.cannabidial.com
3. Internet throughout the State of California, as well as in all other states of the United States,
and throughout the world.
7. Plaintiffs are informed and believe, and based thereon alleged, that Defendant
Cranford is, and at all times herein mentioned was, the owner of Rifle Mountain, LLC, a
Colorado corporation with its principle place of business located in Boulder, Colorado.
8. Plaintiffs are informed and believe, and based thereon allege, that Defendant,
CANNLABS, INC. (hereinafter referred to as "CannLabs") is, and at all times herein
mentioned was, a Nevada business entity with its principle place of business in Colorado, and
a business entity with continuous and substantial contacts with the State of California,
including, but not limited to, trading on the stock exchange, solicitation of business,
formulation, publication, and distribution of statements by its officers via the intemet
throughout the State of California, as well as in all other states of the United States, and
throughout the world.
9. Plaintiffs are informed and believe, and based thereon allege, that Defendant, •
Rifle Mountain, LLC, (hereinafter referred to as "Rifle Mountain, LLC") is, and at all times
herein mentioned was, a Colorado business entity with its principle place of business in
Colorado, and a business entity with continuous and substantial contacts with the State of
California, including, but not limited to, solicitation of business, formulation, publication, and
distribution of statements by its officers via the intemet throughout the State of California, as
well as in all other states of the United States, and throughout the world.
10. Plaintiffs are informed and believe, and based thereon allege, that Defendant,
Stewart Environmental Consultants, LLC, (hereinafter referred to as "Stewart") is, and at all
times herein mentioned was, a Colorado business entity with its principle place of business in
Colorado, and a business entity with continuous and substantial contacts with the State of
California, including, but not limited to, solicitation of business, formulation, publication, and
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4. distribution of statements by its officers and/or employees via the intemet throughout the State
of California, as well as in all other states of the United States, and throughout the world.
11. Plaintiffs are informed and believe, based thereon allege, that Defendant
ProjectCBD.com (hereinafter referred to as "Project CBD") is, and at all times herein mentions
was a California business with its principle place of business in California, and a business
entity with continuous and substantial contacts with the State of California, including, but not
limited to, solicitation of business, formulation, publication, and distribution of statements by its
officers and/or employees via the intemet throughout the State of California, as well as in all
other states of the United States, and throughout the world.
12. Plaintiffs are informed and believe, and based thereon alleged, that Defendant
Aaron Miguel Cantu ("Cantu") is, and at all times herein mentioned was a writer for Project
CBD.
13. Plaintiffs are informed and believe, and based thereon alleged, that Defendant
Martin Lee ("Lee") is, and at all times herein mentioned was, the owner and director of
Project CBD.
14. Plaintiffs are ignorant of the true names and capacities of Defendants sued
herein as Does 1 through 20, inclusive, and therefore sue these Defendants by such fictitious
names. Plaintiffs will amend the complaint to allege their true names and capacities when
ascertained. Plaintiffs are informed and believe, and based thereon allege that each of the
fictitiously named Defendants, including all or some of the DOE Defendants, is responsible in
some manner for the occurrences herein alleged, and that Plaintiffs' damages as herein
alleged were proximately caused by their conduct.
15. Plaintiffs are informed and believe, and based thereon allege that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, were acting as agents, independent
contractors, and/or employees of each other, and in doing the things hereinafter alleged, were
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5. acting within the course and scope of such agency, and with the permission and consent of
such other Defendants. CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD,
Cantu, Lee and DOES 1 through 20, and/or each of them, jointly or separately, acted as
alleged herein for financial gain and to damage Plaintiffs.
16. Plaintiffs are informed and believe, and based thereon allege CannLabs, Rifle
Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, were responsible in some manner for the
formulation, publication, and distribution of false statements concerning Plaintiffs and Plaintiffs'
products.
17. Plaintiffs are informed and believe, and based thereon allege, that at all times
mentioned herein, and in doing the acts hereinafter set forth CannLabs, Rifle Mountain, LLC,
Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20, and/or each of them,
were primary participants in intentional and malicious conduct calculated to and actually
causing injury to Plaintiffs in this State, in the remainder of the United States and throughout
the world.
18. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, acted with actual malice. Plaintiffs are
informed and believe, and based thereon allege, that CannLabs, Rifle Mountain, LLC, Murray,
Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20, inclusive, and/or each of
them, jointly or separately, either had actual knowledge that the statements concerning
Plaintiffs and Plaintiffs' product, Real Scientific Hemp Oil (RSHO), included false statements,
were degrading to Plaintiffs, or in the alternative, acted in reckless disregard of the truth.
19. Plaintiffs are informed and believe, and based thereon allege, that the
dissemination of the statements were extensive, and that the defamatory, false, and invasive
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statements contained therein, have been seen and read by thousands upon thousands of
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persons in California and elsewhere within the United States and internationally.
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20. Plaintiffs are informed and believe, and based thereon allege that CannLabs,
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Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
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inclusive, and/or each of them, jointly or separately, had actual knowledge that the publication
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and dissemination of statements about Plaintiffs would have injurious impact upon Plaintiffs
worldwide, but particularly in California where Plaintiffs are domiciled.
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21. Plaintiffs are informed and believe, and based thereon allege, that commencing
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sometime in or about April, 2014, CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project
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CBD, Cantu, Lee, and/or DOES 1 through 20, inclusive, and/or each of them, jointly or
separately, knowingly, maliciously and willfully, conspired and agreed among themselves to
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tortiously and/or unlawfully injure Plaintiffs by committing the acts herein alleged in
furtherance of such conspiracy and agreement.
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22. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
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Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
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inclusive, and/or each of them, jointly or separately, knowingly and willfully conspired to post
statements on the intemet about Plaintiffs for, among other things, financial gain, with the
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knowledge that in doing so it would damage the reputation and well-being of Plaintiffs.
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23. Plaintiffs are informed and believe, and based thereon allege, that the
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aforementioned conspiracy was operated to perform the tortious course of conduct and the
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illegal acts described hereinafter, which were done in furtherance of the objectives of the
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conspiracy, all to Plaintiffs' damages as alleged herein.
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24. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
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Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
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inclusive, and/or each of them, jointly or separately, furthered such conspiracy by ratifying and
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adopting the acts of each of the other members of the conspiracy. As a result of said
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FIRST AMENDED COMPLAINT
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conspiracy, Plaintiffs have suffered the damages set forth herein which were actually and
proximately caused jointly and severally by each and every Defendant.
25. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, knew of some, or all of the wrongful acts
described hereinafter, yet CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD,
Cantu, Lee, and/or DOES 1 through 20, and each of them, nevertheless knowingly assisted in
the performance of those wrongful acts, or otherwise participated in furtherance of the
conspiracy to Plaintiffs' damages as alleged herein.
FACTS COMMON TO ALL CLAIMS
26. Plaintiffs re-allege and incorporate by reference the allegations contained in
Paragraphs 1 — 25 above as though fully set forth herein.
27. Plaintiff MEDICAL MARIJUANA, INC. is a business specializing in investing in
industrial hemp businesses. In particular, Plaintiff MEDICAL MARIJUANA holds interests in a
variety of companies, including HEMPMEDS PX, LLC, a wholly owned subsidiary specializing
in the production, sale, and distribution of cannabidiol (CBD)-containing hennp oil, which is
known by the trade name "Real Scientific Hemp Oil" or "RSHO." Plaintiff MEDICAL
MARIJUANA also holds interests in KannaLife Sciences, Inc. (hereinafter referred to as
"KannaLife"), a business with its principle place of business in New York.
28. Plaintiffs are informed and believe, and based thereon allege, that on or about
March 31, 2014, Defendant Cranford resigned from KannaLife's Board of Directors, allegedly
stemming from a business dispute. Cranford stated this information in an email to other board
members of KannaLife and brought up RSHO in his statements.
29. Plaintiffs are informed and believe, and based thereon allege, that Cranford
owns a business, "Rifle Mountain, LLC", (hereinafter referred to as "Rifle Mountain, LLC"), a
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FIRST AMENDED COMPLAINT
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8. Colorado medical marijuana dispensary, since December 30, 2011. This business continues
to operate under Cranford's ownership.
30. Plaintiffs are informed and believe, and based thereon allege, that while
conducting business through Rifle Mountain, LLC, Cranford also served on the Board of
Directors at KannaLife, Inc. After leaving the Board at KannaLife, Inc., Cranford and Rifle
Mountain, LLC started selling high CBD products which were competitive with other CBD-
containing products (including RSHO) being sold by HempMeds and Medical Marijuana, Inc.
Accordingly, Cranford had motive to discredit RSHO, HempMeds, and Medical Marijuana, for
his personal financial gains.
31. Plaintiffs are informed and believe, and based thereon allege, that on or about
April 26, 2014, Cranford created a "public announcement" by posting on Cranford's public
Facebook profile that he would have Plaintiffs' product, RSHO, tested at Colorado State
University veterinary lab (hereinafter referred to as "CSU"), a diagnostic lab for animals and
animals' food, that Cranford acknowledged, “does not specialize in Cannabis." Cranford
stated that CSU's report would be neutral and accurate. Cranford also posted a picture of
CSU's Veterinary Hospital in the same post. This post reached over one hundred twenty (120)
readers nationwide. [See Exhibit A].
32. Plaintiffs are informed and believe, and based thereon allege, that Cranford also
stated in his posting that a child by the name of Jaqie Angel had become sick due to a bad
reaction to Plaintiffs' product. [See Exhibit B].
33. Plaintiffs are informed and believe, and based thereon allege, that Cantu, Lee
and Project CBD used Cranford as a source to state that Jaqie Angel became sick due to a
bad reaction to the Plaintiffs product. [See Exhibit C and M].
34. Plaintiffs are informed and believe, and based thereon allege, that ultimately,
CSU did not perform the test on Cranford's sample.
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9. 1
35. Plaintiffs are informed and believe, and based thereon allege, that on or about
2 May 8, 2014, Cranford then took the purported RSHO sample to Stewart Environmental
3 Consultants, LLC, an environmental testing lab specializing in soil testing. Stewart accepted
4 the sample and performed tests for volatile organic compounds (VOC) and heavy metal
5 concentrations on the purported RSHO sample provided by Cranford.
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36. Plaintiffs are informed and believe, and based thereon allege, that while waiting
7 for the Stewart results, Cranford continued to post on Facebook that results were coming
8 soon, and that CSU had to outsource some of the tests. [See Exhibit C].
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37. Plaintiffs are informed and believe, and based thereon allege, that on or about
10 May 23, 2014, Stewart caused a preliminary report on the purported RSHO sample submitted
11 by Cranford to be released to Cranford. The preliminary report did not reflect the final
12 reporting values on many analytical parameters, including heavy metals such as lead,
13 molybdenum, nickel, selenium, and silver, among other metals. [See Exhibit D].
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38. Plaintiffs are informed and believe, and based thereon allege, that on or about
15 May 23, 2014, Cranford released copies of "preliminary" test results from Stewart. These
16 preliminary test results were not accurate and did not reflect the true contaminant levels in the
17 purported RSHO sample, and Plaintiffs are informed and believe and hereby allege that
18 Cranford was aware that the preliminary test results were inaccurate. Cranford stated in
19 another Facebook post that the results were posted on Jaqie Angel's Facebook page. [See
Exhibit E].
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39. Plaintiffs are informed and believe, and based thereon allege, that Murray was
and is the Chief Executive Officer and President of CannLabs and had motives to discredit
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24 as a cannabis testing facility and to appear as if doing the public a service by discrediting
RSHO, HempMeds, and Medical Marijuana.
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FIRST AMENDED COMPLAINT
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10. 40. Plaintiffs are informed and believe, and based thereon allege, that on or about
May 8, 2014, Murray posted false statements about Plaintiffs and its RSHO on the Internet,
which was then reposted, used and referred to by numerous different social media platforms,
including the Investor Hub chat rooms. The false statements by Murray (hereinafter referred
as "Murray's Post") stated as follows: "Hello Everyone: something has come to my attention .
and I feel I need to share it. The RSHO Real Scientific Hemp Oil was taken to the CSU lab so
they could do extensive tests on it. The preliminary results: The lab I sent RSHO to called me
this morning to warn me about consuming it. They are not finished but already found heavy
metals, fluorides, chlorides and bromine. They said it is dangerous to consume and warned
me not to let anyone take it. They said it is not even hemp oil. Please do not consume this
product until we have more information." [See Exhibit F].
41. Plaintiffs are informed and believe, and based thereon allege, that Murray's
statements were false because on or about Maya, 2014, CSU did not and had not tested any
purported RSHO sample.
42. Plaintiffs are informed and believe, and based thereon allege, that on or about
May 19, 2014, a Facebook Profile by the name Shannon Moore re-posted a quote of Murray's
Post on a thread conversation on his Facebook account. However, Murray's post was edited
by Cranford as follows: The words "[t]he lab" were replaced by the words "[t]he other lab,"
and "[p]lease do not consume this product until there is more information" was replaced with
"[p]lease do not consume this until there is better understanding." [See Exhibit G].
43. Plaintiffs are informed and believe, and based thereon allege, that as a result of
Murray's Post having been re-posted by Shannon Moore, the false statement regarding
Plaintiffs' RSHO was broadcasted to additional readers, which included Shannon Moore's
followers on Facebook.
44. Plaintiffs are informed and believe, and based thereon allege, that thereafter,
Cranford posted an email for people to contact if they had suffered negative reactions after
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11. 1 taking Plaintiffs' RSHO product. The email address as posted in Cranford's timeline was:
2 rshocomplaintsaomail.com . [See Exhibit B].
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45. Plaintiffs are informed and believe, and based thereon allege, that as a result of
4 Murray and Cranford's announcements, people throughout the world have read and followed
5 the story and re-posted it on their Facebook timelines, further publishing the false statements
concerning Plaintiffs.
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46. Plaintiffs are informed and believe, and based thereon allege, that on or about
8 May 26, 2014, Julian McCulloch, a Facebook profile who followed Cranford's story, posted the
9 photos of preliminary test results from Stewart Environmental Consultants, LLC that Cranford
had previously posted. [See Exhibit H].
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47. Plaintiffs are informed and believe, and based thereon allege, that on or about
12 May 30, 2014, Stewart published the complete and final test results on the purported RSHO
13 sample submitted by Cranford. The final results showed significant different reporting values,
14 especially for heavy metals such as lead, molybdenum, nickel, selenium, and silver, among
other metals [See Exhibit l].
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48. Plaintiffs are informed and believe, and based thereon allege, that on or about
June 1, 2014, despite the knowledge of the final test results from Stewart, Cranford stated that
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18 he "... [j]ust read a message from a Mom saying her child died from heavy metal poisoning
after use of [Plaintiffs] product. I will post the link." Cranford then posted a link to a statement
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written by "Sarah Hadigan," a profile on Facebook. The link posted by Cranford stated, "Sarah
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21 Hadigan" referred to Plaintiffs' product, RSHO, by stating, among other things, "My daughter
is dead because of this product....[m]y daughter had more metals in her liver, kidney, and
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muscle tissues than fort knox has gold." [See Exhibit J].
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49. Plaintiffs are informed and believe, and based thereon allege, that on or about
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June 5, 2014, Stewart, by and through Michael Glavanovich, its lab manager, stated in an
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email communication that the preliminary test results published by Cranford were not
11
FIRST AMENDED COMPLAINT
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accurate, were possibly contaminated as the sample had been through three (3) different
hands without proper chain of custody record before arriving at Stewart, did not account for
contaminations introduced during the measurement process, did not reflect the final testing
results, and should not have been published. [See Exhibit K].
50. Plaintiffs are informed and believe, and based thereon allege, that on or about
October 14, 2014, Cantu, By and through Lee and Project CBD published an article titled
"Hemp Oil Hustlers- A Project CBD Special Report on Medical Marijuana Inc., HempMeds &
Kannaway," (hereinafter referred to as "Hemp Oil Hustlers"). This article claimed to have
evidence that RSHO was contaminated with heavy metals and solvents without verifying the
accuracy of the results from Stewart Environmental. Project CBD also alleged that multiple
people became ill after using RSHO due to heavy metals and other toxins based on
Cranford's opinion. Lee wrote a forward for Cantu's article, asserting opinions and rumors as
fact without proof or citation, and published Cantu's article on his Project CBD website. [See
Exhibit M].
51. Plaintiffs are informed and believe, and based thereon allege, that the Hemp Oil
Hustlers article from October 14, 2014, has been republished on at least seventy- eight other
websites. [See Exhibit U.
52. Despite knowledge that the preliminary results were inaccurate, CannLabs, Rifle
Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately continued to publish these results.
53. Plaintiffs are informed and believe, and based thereon allege, that CannLabs is
in the cannabis and hemp industry and competes against Plaintiffs. CannLabs, by and through
Murray, published untrue statements of fact concerning RSHO, HempMeds, and Medical
Marijuana to create positive publicity for CannLabs as a cannabis testing facility and to appear
as if doing the public a service by discrediting RSHO, HempMeds, and Medical Marijuana.
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FIRST AMENDED COMPLAINT
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13. 1
54. Plaintiffs are informed and believe, and based thereon allege, that Rifle
2 Mountain, LLC is in the cannabis and hemp industry and competes against Plaintiffs. Rifle
3 Mountain, LLC, by and through Cranford, published untrue statements of fact concerning
4 RSHO, HempMeds, and Medical Marijuana, which and who are competing product and
5 businesses of CannLabs' business, for its financial gains.
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55. Plaintiffs are informed and believe, and based thereon allege, that in the month
7 of March, 2014, Medical Marijuana's stock price, trade by the ticker "MJNA" was at
$0.34/share.
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56. Plaintiffs are informed and believe, and based thereon allege, that ever since
10 CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1
11 through 20, inclusive, and/or each of them, jointly or separately, made these announcements;
12 Plaintiff MEDICAL MARIJUANA INC.'S stock price has plummeted and has not been able to
recover.
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57. Plaintiffs are informed and believe, and based thereon allege, that as a direct
15 and proximate result of the Defendant's actions, Plaintiffs have been damaged and continue to
16 suffer damages in excess of one hundred million dollars ($100,000,000).
FIRST CAUSE OF ACTION
17
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(For Libel as to Defendants CannLabs, Rifle Mountain, LLC, Murray, Cranford,
Project CBD, Cantu, and Lee)
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58. Plaintiffs re-allege and incorporate by reference the allegations contained in
Paragraphs 1 — 57 above as though fully set forth herein.
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59. Plaintiffs are informed and believe, and based thereon allege, that between May
23 1, 2014 and June 1, 2014, CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD,
24 Cantu, Lee, and/or DOES 1 through 20, inclusive, and/or each of them, jointly or separately,
published negative statements of fact about Plaintiffs on Facebook, which contained untrue
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and false statements regarding Plaintiffs' product, RSHO.
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FIRST AMENDED COMPLAINT
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14. 60. The statements of fact about Plaintiffs are and were false, untrue, and
defamatory. The statements published by CannLabs, Rifle Mountain, LLC, Murray, Cranford,
Project CBD, Cantu, Lee and/or DOES 1 through 20, inclusive, and/or each of them, jointly or
separately, were libelous on its face and the statements wrongfully accused Plaintiffs, and
were intended to wrongfully accuse Plaintiffs, of actions and statements that were false,
defamatory, and damaging.
61. The statements published by CannLabs, Rifle Mountain, LLC, Murray, Cranford,
Project CBD, Cantu, Lee and/or DOES 1 through 20, inclusive, and/or each of them, jointly or
separately clearly expose Plaintiffs to hatred, contempt, ridicule and obloquy because they
falsely accuse and depict Plaintiffs, among other things, as companies which supply a product
(RSHO) that contains high heavy metal concentrations and bleach, and as companies that
misrepresent the nature of their product.
62. CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee,
and/or DOES 1 through 20, inclusive, and/or each of them, jointly or separately, knew that
statements published by Murray and Cranford as it applied to Plaintiffs to be false, and were
intended by CannLabs, Rifle Mountain, LLC, Murray, Cranford, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, to convey a false or defamatory
statements about Plaintiffs.
63. CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee,
and/or DOES 1 through 20, inclusive, and/or each of them, jointly or separately, wrote,
published, and circulated, and/or caused to be written, published and circulated, the libelous
statements concerning Plaintiffs either with knowledge of the falsity of the statements or with
reckless disregard for the truth.
64. The statements appearing in the posts written by CannLabs, Rifle Mountain,
LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20, were so
understood by those who read the statements to have the defamatory meaning ascribed to by
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15. Defendants. CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee,
and/or DOES 1 through 20, inclusive, and/or each of them, jointly or separately, intended the
statements to be read by consumers nationally, internationally, and specifically within the
State of California where Plaintiffs were and are domiciled.
65. At the time the statements were being publicly distributed and circulated
throughout the United States and the world, CannLabs, Rifle Mountain, LLC, Murray,
Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20, inclusive, and/or each of
them, jointly or separately, were in possession of evidence which would raise serious doubt
about the truth of their statements.
66. At the time the statements were publicly distributed and circulated throughout
the United States and the world, CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project
CBD, Cantu, Lee, and/or DOES 1 through 20, inclusive, and/or each of them, jointly or
separately, failed to sufficiently investigate the truth of their statements. Thus, Defendants,
and each of them, lacked any substantial reason to believe in the truth of the allegations
contained within the posts. The untruthful statements were therefore made with actual malice,
with the knowledge that each such statement was false and the statements were published
with reckless disregard of their truthfulness.
67. The statements were written and published with reckless disregard for the truth
of the matter, and Defendants knew at the time the statements were formulated that they were
false and injurious to Plaintiffs with respect to their reputation, character, and business.
68. As a legal result of the statements made by CannLabs, Rifle Mountain, LLC,
Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20, inclusive, and/or each
of them, jointly or separately, Plaintiffs have suffered loss of reputation, shame and
mortification, all to their general damage in a sum to be proven at trial.
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16. 69. The defamatory statements were not privileged in any manner. The statements
were intended by Defendants, and each of them, to directly injure Plaintiffs with respect to its
reputation, character, and business.
70. As a legal result of the defamatory statements, Plaintiffs have suffered loss of
reputation and general damage, the exact amount of which to be proven at trial.
71. As a legal result of the intentional and malicious conduct of CannLabs, Rifle
Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, Plaintiffs have suffered with respect to its
property, business, trade, profession and occupation, all to its special damage in a sum to be
determined at time of trial.
72. By engaging in the misconduct alleged above, CannLabs, Rifle Mountain, LLC,
Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20, inclusive, and/or each
of them, jointly or separately, intended to cause Plaintiffs injury or engaged in that misconduct
with the willful and conscious disregard for the rights of Plaintiffs.
73. CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee,
and/or DOES 1 through 20, inclusive, and/or each of them, jointly or separately, were aware of
the probable dangerous consequences of their misconduct and willfully and deliberately failed
to avoid those consequences, including subjecting Plaintiffs to cruel and unjust hardship, in
conscious disregard of Plaintiffs' rights. Thus, the award of exemplary and punitive damages
is justified.
SECOND CAUSE OF ACTION
(For Trade Libel as to Defendants CannLabs, Rifle Mountain, LLC, Murray,
Cranford Project CBD, Cantu and Lee)
74. Plaintiffs re-allege and incorporate by reference the allegations contained in
Paragraphs 1 — 73 above as though fully set forth herein.
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17. 75. Plaintiffs are informed and believe, and based thereon allege, that Plaintiffs'
product, RSHO, previously enjoyed a good reputation in the community.
76. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, intentionally, wrongfully, without
justification, and without privilege made statements that Plaintiffs' product (RSHO) was
dangerous to consume, contained heavy metals, fluorides, chlorides, bromine, and bleach at
high concentration, that it was not even hemp oil, that it caused the death of a child [known as
"Jaqi Angel" on Facebook].
77. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, published these statements on Facebook,
an international social network media with billions of participants and readers. Defendant
Murray's Facebook page had a total of four thousand nine hundred eleven (4911) followers
and friends. Defendant Cranford's Facebook posts also received hundreds of shares and
likes.
78. Plaintiffs are informed and believe, and based thereon allege, that followers of
CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1
through 20, and/or each of their Facebook statements reposted and broadcasted CannLabs's,
Rifle Mountain, LLC's, Murray's, Cranford's, Project CBD, Cantu, Lee, and/or DOES 1 through
20, and/or each of their statements on other various social media outlets, including Investor
Hub. Investor Hub is a popular social media platform wherein investors and interested
business persons discuss the business potential of various products and businesses.
79. Plaintiffs are informed and believe, and based thereon allege, that Murray's
Post and/or DOES 1 through 20's statements were quoted and publicized in a paper by
Project CBD, an online information website calling for the legalization of medical marijuana,
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18. and Aaron Miguel Cantu, an employee of Project CBD. The "Hemp Oil Hustlers" article has
been reprinted and updated as of November 4, 2014.
80. Plaintiffs are informed and believe, and based thereon allege, that Murray's
Post and/or DOES 1 through 20's statements were quoted and publicized worldwide in an
article, "Intrigas, dinheiro e cannabidiol," published online by Super Interessante, a major
online newspaper in Brazil.
81. These statements were made about and concerning Plaintiffs' product, RSHO,
and were understood by readers to refer to Plaintiffs' product, because these statements
specifically mention Plaintiffs' product, RSHO, which is a product owned and/or sold by
Plaintiffs. By reading the statements made explicitly about Plaintiffs' RSHO, a reader would
understand that the statement's referred to Plaintiffs' product.
82. These statements are false. Plaintiffs' product is not dangerous to consume;
Plaintiffs' product does not contain heavy metal, fluorides, chlorides, bromine, and/or bleach
at such concentrations; Plaintiffs' product is hemp oil derived from industrial hemp plants.
83. These statements disparaged Plaintiffs' product in that they specifically told
readers not to consume Plaintiffs' product; falsely indicating that Plaintiffs' product contained
heavy metals, fluorides, chlorides, and bromine; that Plaintiffs' product was not even hemp
oil; that Plaintiffs' product was dangerous to consume; and that Plaintiffs' product contained
bleach.
84. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, made these statements with knowledge of
their falsity or with reckless disregard for their truth or falsity.
85. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, made these statements with negligent
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19. disregard for their truth or falsity, in that CannLabs, Rifle Mountain, LLC, Murray, Cranford,
and/or DOES 1 through 20, inclusive, and/or each of them, jointly or separately, sent Plaintiffs'
food product to a soil testing lab, then brandished preliminary results before acquiring more
information.
4
86. Plaintiffs are informed and believe, and based thereon allege, that Defendant
Murray is a scientist with a Bachelor of Science Degree in Microbiology from Colorado State
University, and is the Chief Executive Office of a cannabis testing company. A reasonable
person with Defendant Murray's educational and professional background would understand
that preliminary results are inconclusive. Yet, Defendant Murray specifically told her Facebook
audience "...[n]ot to consume Plaintiffs' product until they had more information."
87. The statements proximately caused damage to Plaintiffs in that they have
deterred customers from purchasing Plaintiffs' above-described product. They have also
deterred customers from conducting business with Plaintiffs. As a direct and proximate result
of these statements, Plaintiffs have suffered pecuniary loss in a sum to be proven at trial.
88. The statements were motivated by Defendants' malice and oppression in that
Defendants submitted an unsealed and unverified sample of Plaintiffs' food product (RSHO) to
a soil testing lab, published the preliminary results, and published false statements of facts
concerning Plaintiffs' product, and warned consumers not to consume Plaintiffs' product
before any results were even published. Therefore, Plaintiffs are entitled under Civil Code
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section 3294, subd. (a) to punitive damages in an amount sufficient to punish Defendant and
deter similar conduct in the future.
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20. THIRD CAUSE OF ACTION
(For False Light as to Defendants CannLabs, Rifle Mountain, LLC, Murray,
Cranford Project CBD, Cantu, Lee)
89. Plaintiffs re-allege and incorporate by reference the allegations contained in
Paragraphs 1 — 88 above as though fully set forth herein.
90. Plaintiffs are informed and believe, and based thereon allege, that on or about
May 19, 2014, CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee
and/or DOES 1 through 20, inclusive, and/or each of them, jointly or separately, without
Plaintiffs' consent, put Plaintiffs in a false light by writing, publishing, and circulating negative
statements about Plaintiffs on Facebook, which contained untrue statements of fact regarding
Plaintiffs and Plaintiffs' product, RSHO.
91. Plaintiffs are informed and believe, and based thereon allege, that the
disclosure by Defendants, and each of them, jointly or separately, created publicity in the form
of a public disclosure to a large number of people, as Defendants' posts are and were read
by thousands of people in the state of California, throughout the United States and throughout
the world.
92. The publicity created by Defendants, and each of them, jointly or separately,
placed Plaintiffs in a false light in the public eye, in that the posts were fabricated by
Defendants, and each of them, and publicly conveyed, and was intended to convey, a
calculatedly false and inaccurate impression of Plaintiffs as companies which supplied
products with toxic contaminations, which misrepresented the nature of the product, and of
Plaintiffs' food product, RSHO, as a product containing bleach and high concentrations of
heavy metals and other organic compounds.
93. The publicity created by the posts was highly objectionable to Plaintiffs, and
would be to any company of ordinary sensibilities. The posts made Plaintiffs the object of
scorn and ridicule by many residents of the State of California, citizens of the United States,
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and in general, people throughout the world, and were intended to and did directly injure the
Plaintiffs with respect to their reputation, character and business
94. The formulation and publication of the posts by CannLabs, Rifle Mountain, LLC,
Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20, inclusive, and/or each
of them, jointly or separately, were each done with actual malice in that each was done with all
or some of Defendants' knowledge of the posts' falsity, or in reckless disregard of the truth. At
all relevant times, all or some of the Defendants were aware, or should have been aware, of
facts contrary to the Defendants' malicious allegations.
95. Plaintiffs are informed and believe, and based thereon allege, that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, were also negligent in publishing the
posts; as with ordinary and reasonable care, Defendants would have realized, or could have
discovered, that the statements made in various Facebook posts by Defendants were
obviously false and grossly libelous, offensive, and damaging to Plaintiffs.
96. As a legal result of the statements, Plaintiffs have suffered loss of reputation,
character and business, all to their general damages in a sum to be determined at trial.
97. As a further legal result of the above-mentioned disclosure, Plaintiffs have
suffered injury to its business all to their special damage in an amount to be proven at trial.
98. In making the disclosure described above, CannLabs, Rifle Mountain, LLC,
Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20, inclusive, and/or each
of them, jointly or separately, are guilty of oppression, fraud, or malice in that Defendants
made the disclosure with a willful disregard of Plaintiffs' rights. Defendants' acts in formulating
and publishing the posts were done with the knowledge by Defendants that such acts would
cause Plaintiffs to suffer injury. Defendants' acts were therefore willful, wanton, intentional,
and actually malicious and oppressive, thereby justifying the award of exemplary and punitive
damages according to proof at trial.
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www.cannabidial.com
22. 99. As a legal result of the posts and the false statements, Plaintiffs have suffered
loss of reputation, character, and business, all to their general damage in a sum to be proven
at trial.
100. The defamatory statements contained in the posts were not privileged in any
manner. The statements were intended by Defendants, and each of them, to directly injure
Plaintiffs with respect to their reputation, character, and business.
101. As a legal result of the articles, Plaintiffs have suffered general damage, the
exact amount of which to be proven at trial.
102. As a legal result of the intentional and malicious conduct of CannLabs, Rifle
Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, Plaintiffs have suffered with respect to
their property, business, trade, profession and occupation, all to their special damage in a sum
to be determined at the time of trial.
103. By engaging in the misconduct alleged above, CannLabs, Rifle Mountain, LLC,
Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20, inclusive, and/or each
of them, jointly or separately, intended to cause Plaintiffs injury or engaged in that misconduct
with the willful and conscious disregard for the rights of Plaintiffs. Defendants CannLabs, Rifle
Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, were aware of the probable dangerous
consequences of their misconduct and willfully and deliberately failed to avoid those
consequences, including subjecting Plaintiffs to cruel and unjust hardship, in conscious
disregard of Plaintiffs' rights. Thus, the award of exemplary and punitive damages is justified.
///
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23. FOURTH CAUSE OF ACTION
(For Negligence as to all Defendants)
104. Plaintiffs re-allege and incorporate by reference the allegations contained in
Paragraphs 1 — 97 above as though fully set forth herein.
105. Plaintiffs are informed and believe, and based thereon allege, that defendants
CannLabs, Rifle Mountain, LLC, Stewart, Murray, Cranford, Project CBD, Cantu, Lee and/or
DOES 1 through 20, inclusive, and/or each of them, jointly or separately, were negligent in
publishing the statements. With ordinary and reasonable care, Defendants would have
realized, or could have discovered, that the statements were obviously false, grossly libelous,
offensive, and damaging to Plaintiffs.
106. Plaintiffs are informed and believe, and based thereon allege, that Stewart,
and/or DOES 1 through 20, inclusive, and/or each of them, jointly or separately, were
negligent in publishing the preliminary testing results of the purported RSHO sample
submitted by Cranford. With ordinary and reasonable care, Defendant Stewart would have
realized, or could have discovered, that the preliminary results were obviously false, grossly
libelous, offensive, and damaging to Plaintiffs.
107. As a legal result of the negligent conduct of CannLabs, Rifle Mountain, LLC,
Stewart, Murray, Cranford, Project CBD, Cantu, Lee and/or DOES 1 through 20, inclusive,
and/or each of them, jointly or separately, Plaintiffs have suffered with respect to its property,
business, trade, profession and occupation, all to their damage in a sum to be determined at
time of trial.
FIFTH CAUSE OF ACTION — INTENTIONAL INTERFERENCE WITH
PROSPECTIVE BUSINESS ADVANTAGE
108. Plaintiffs re-allege and incorporate by reference the allegations contained in
Paragraphs 1 — 107 above as though fully set forth herein.
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24. 109. Plaintiffs are informed and believe, and based thereon allege that Plaintiffs have
an existing prospective relationship with multiple companies regarding the use of its products.
110. Plaintiffs are informed and believe, and based thereon allege that Plaintiffs have
a probability of future benefit from their existing prospective relationship with multiple
individuals and companies.
111. Plaintiffs are informed and believe, and based thereon allege that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
inclusive, and/or each of them, jointly or separately, have intentionally interfered with Plaintiffs'
existing prospective relationship with multiple individuals and companies.
112. Plaintiffs are informed and believe, and based thereon allege that CannLabs,
Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1 through 20,
and/or each of their false and misleading publications to the public was wrongful and made
with Defendants' knowledge and intent.
113. Plaintiffs are informed and believe, and based thereon allege that as a result of
CannLabs, Rifle Mountain, LLC, Murray, Cranford, Project CBD, Cantu, Lee, and/or DOES 1
through 20, and each of their conduct, Plaintiffs have been injured and have suffered
damages in an amount to be proven at trial.
DEMAND FOR JURY TRIAL
Please take notice Plaintiffs hereby demand a trial by jury in this action.
PRAYER
WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as
follows:
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1. For general damages according to proof but in excess of One Hundred Million
Dollars ($100,000,000).
2. For special damages in an amount to be determined at trial and for interest thereon
at the legal interest rate;
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25. 3. For punitive and exemplary damages in an amount to be determined at trial;
4. For costs of suit herein incurred; and
5. For such other and further relief as the court may deem just and proper.
/s/ PhiIli E. Koeh ke, APC 1/14/2014
Phillip E. oehnke, APC Date
Attorney for Plaintiffs
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www.cannabidial.com
38. Genifer Murray
;
Hello Everyone: something has come to
attention and I feel I need to share it The
RSHO Real Scientific Hemp Oil was taken to
the CSU lab so they could do extensive
tests on it. The preliminary results:
The lab I sent FISHO to called me this
morning to warn me about consuming It.
They are not finished but already found
heavy metals, fluorides, chlorides and
bromine. They said it is dangerous to
consume and warned me not to let anyone
take it. They said it is not even hemp oil.
Please do not consume this product until we
have more information.
Corhnic Share
_ .
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6/412014 10296655 1015421M3960035 8134689757638591011_nwg (960x843)
INQUIRING MINDS WANT TO KNOW.'.. WHAT'S THE TRUTH ABOUT RSHO?
1.a berstory Report
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Above, lab results from a container of RSHO, or
what is also known as Real Scientific Hemp Oil.
With this many chemicals in the product, it has
to be scientific, right?
Above, lab results from a testing facility showing the
level of MC in this batch of RSHO is illegal as defined
by the DFA How can this be promoted as legal when
it clearly is not legal, qualifying as a Schedule I drug?
https://fbaln-spholos-h-a.alcarnsihd.nettnphdos-ak-xpf1M34.0-12/10295655 10154217823960035 8134689757638591011 n.loaTciFe086963d7f44b2c92f396931... 1/1
www.cannabidial.com
48. Stewart Environmental Consultants, LLC
Engineering for Life
Laboratory Quality Control Report
Anions
EPA 300.0
Date of Analysis 10511312014
Blank
Analyte Tested Value (ppm) RC Acceptance Limit (ppm)
Bromide ND < 0.5
Chloride ND <0.5
Fluoride ND <0.1
Nitrate as N ND <0.1
Nitrite as N ND
Phosphate as P
ommin
ND <0.5
Independent Reference Material .. Quality Control Sample
Analyte Spike Amount (ppm) Observed And (ppm) Recovery Acceptance Limn
Bromide 1.00 1,02 102% 80% b 120%
Chloride 2.00 2.00 100% 80% to 120%
Fluoride 1.00 1.00 100% 80% to 120%
Nitrate as N 2.00 1.82 91% 80% to 120%
Nitrite AS N 1.00 0,70 70% 80% b 120%
Phosphate as P 3.00 3.01 100% 80% to 120%
Sulfate 4.00 3.92 98% 80% te 120% •
Blank Spike
A:Wyly Ref, Value (ppm) Recovery Acceptance Limit
Ekomide 1.00 1.03 103% 80% to 120%
Chloride 1.00 0.96 96% 80% to 120%
Fluoride 1.00 0.94 94% 80% to 120%
Nitrate as N 1.00 0,97 07% 80% lo 120%
Nitrite es N 140 0.79 79% 80% to 120%
Phosphate as P 1.00 0.98 98% 80% to 120%
Sulfate 1.00 0.99 99% 80% to 120%
<0.5
Blank Spike Duplicate
Anelyte Tested Vs use (ppm)
I Bromkie 1.03 1.07 4%
. __ _
<20%
Chloride 0.06 0.98 2% <20%
Fluodde 0.04 0.95 1% <20%
Nittate as N 0.97 0.99 2% <20%
Nitrite es N 0.79 0.82 4% <20%
Phosphate as P 0.98 1.04 6%
Sulfate 0.99 1.03 4% <20%
Deviation l Acceptance Limit
ND - Not detected.
www.cannabidial.com
56. message
From: Michael Glavanovich<michael.glavanovich(iv,gmail.com>
Date: Thu, Jun 5, 2014 at 1:01 PM
Subject: Re: FW: Cranford
INFAIIIIMOraltafffifallaNNININWINawar
MIL
The samples were received in our lab from Jason Cranford.
Apparently the samples went through three different hands
before we received them. Not that this is in an of itself bad, just
not ideal. We were asked to test for volatile organic compounds,
metals, and pesticides. There was insufficient volume to test for
pesticides, so we were able to eliminate that test. The volume of
sample, about 1-2mL was small for the remaining two analyses,
but we went ahead with it. The analysis for volatile organic
compounds is straight forward. The analysis for metals is
complicated in that the sample must first be oxidized with
potassium permanganate and sulfuric acid, a process called "wet
ashing". Subsequently the oxidized sample is treated with nitric
and hydrochloric acid to solubilize any metals that may be
present. In the oxidizing of the oils, a significant background of
interference is created that must be accounted for. Without this
correction the sample will look like it is testing positive for some
metals. Occasionally a client will call and ask for the report
ahead of our normal processing schedule, and this happed to be
the case. Sadly data went out before the metals background
correction was made. A day or two later, it was noticed that this
happen, the corrections were made and the corrected report was
sent to the client.
While this occurence is rare, it is not unheard of. All the follow-
up procedures were made: phone call, email, and a new report.
To go forward, I recommend additional testing for metals. In an
ideal world, about 3-4 mL of oil is preferred. This way we have
sufficient amount to run a duplicate analysis. I have attached a
chain of custody should you wish to test fresh oil with our
laboratory.
Kind regards,
Michael Glavanovich
Lab Manager
Stewart Environmental Consultants, LLC
www.cannabidial.com
58. vg4 Sample Receipt Checklist
STEWART ENVIRONMENTAL CONSULTANTS, LLC.
3803. Automation Way, Suite 200, Fort Crams CO 80525
cirenrirs,Con trtoria4 initials: >ill Date: tight( Time: I 31.5 C MsT/mur
To be filled out by laboratory courier, If applicable:
. .
Were samples rebievad bya taboratTY.99uricrrY. .
2 .Were.sarppIesphiceprin a refrigerated state upon fetrieyalt _
Courier Millais: Date: Time'
To be filled out by laboratory samplo receiving:
3 Sh0.9118 95.e.kier./.41019r
4 Chain of Custo4yfC09) Eresent?
5 Sample bottles Intact? •
samples onblue-ioe
7 P.rnEles .. •
8 Samples received within 4 hours of samplim?
1
9 Record temperature of sample babies within cooler with Infra-red thermometer.
{C; tntainer#141‘4rd I
10
11 COO complete, ierztale, signed end dated?
12 bPili.9:?.9°P1PICrte end VIA? ......... .
13 CDC the mementwith sample bottle labels? •
14 _Pmr container tiled Tor anatma restiaated?
15 Sample! requIring.prasentaffoqRreeerveti.aorrerge _
16 Sufficient sample volume for analyses requested? •
17 Samples within holdiNtimes for analyses requested? •
18 8911.0.PsfPritOna!!!1.1008.0199.grefteeall°,109acKl..1
(VOC, TVPH, BTIDC, Ethanol, Radon) If no, size of bubble: < green pea,
• If no, document on Chain of Custody.
(Pavved..9.Pd clanYS? *
_> green pea
Notes.:
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