1 N. Scottsdale Rd., Ste. 0 0 Jeffrey S. Kaufman, Esq. JEFFREY S. KAUFMAN, LTD. N. Scottsdale Road, Ste. 0 (0-000 Bar No. 00 Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA WHITE MOUNTAIN HEALTH CENTER, INC., an Arizona non-profit corporation, Plaintiff, v. COUNTY OF MARICOPA; WILLIAM MONTGOMERY, ESQ., Maricopa County Attorney, in his official capacity; ARIZONA DEPARTMENT OF HEALTH SERVICES, an agency of the State of Arizona; WILL HUMBLE, Director of the Arizona Department of Health Services, in his Official Capacity; and DOES I-X, Defendants. Case No.: COMPLAINT (Special Action and Regular Action for Mandamus, Declaratory Judgment, Injunctive Relief and Other Relief COMES NOW Plaintiff, by and through its attorney, undersigned, and for its Complaint against Defendants herein, alleges as follows: COMMON ALLEGATIONS THE PARTIES. Plaintiff White Mountain Health Center, Inc. is an Arizona non-profit corporation, licensed to transact business and transacting business in Maricopa County, Headings are provided in order to aid the reader. They are not intended to limit the scope of any paragraph or its contents.
2 N. Scottsdale Rd., Ste. 0 0 Arizona.. Plaintiff desires to own and to operate a non-profit medical marijuana dispensary and cultivation site, as defined in the Arizona Medical Marijuana Act, at North th Avenue, Suite B, Sun City, Arizona, which is located within the Sun City CHAA (as herein after defined or any other location in the Sun City CHAA that is in compliance with Maricopa County restrictions. The Sun City CHAA, CHAA #, is located entirely within unincorporated portions of Maricopa County, Arizona.. Defendant William Montgomery is the County Attorney of Maricopa County, Arizona. In that capacity Defendant Montgomery is responsible for advising the Maricopa County Board of Supervisors with regard to the adoption and enforcement of laws, among other things.. Defendant Will Humble is the Director of the Arizona Department of Health Services ( DHS, a political subdivision of the State of Arizona. Defendant Humble is responsible for the DHS employees who are implementing and overseeing the Arizona Medical Marijuana Act, A.R.S. -0, et seq. This includes, but is not limited to, the review, approval and denial of applications for medical marijuana Dispensary Registration Certificates and approvals to operate medical marijuana dispensaries and cultivation sites, after a Dispensary Registration Certificate is obtained.. Defendants DOES -X are fictitious names, used to denote other persons or entities whose acts and/or omissions caused or contributed to Plaintiff s injuries. Plaintiff hereby requests leave of this Court to amend its Complaint to reflect the true names and statuses of Defendants DOES -X, when the same have been ascertained.
3 N. Scottsdale Rd., Ste. 0 0 JURISDICTION AND VENUE. This action is brought as an ordinary action in the Superior Court and as a Special Action, pursuant to the Rules of Procedure for Special Actions including, but not limited to Rule thereof. The acts and events complained of herein occurred in Maricopa County, Arizona. ARIZONA MEDICAL MARIJUANA ACT. On or about November, 0, the citizens of the State of Arizona passed and adopted Proposition 0, a voter initiative, known as the Arizona Medical Marijuana Act (the AMMA, A.R.S. -0 through -. Governor Jan Brewer signed the AMMA into law on December, 0. The AMMA states, in pertinent part, that the People of State of Arizona find and declare that modern medical research has confirmed beneficial uses for marijuana in treating or alleviating pain, nausea and other symptoms associated with a variety of debilitating medical conditions, as found by the National Academy of Sciences Institute of Medicine. These benefits include relief from neuropathic pain caused by a variety of illnesses that often fail to respond to conventional treatments and relief from nausea, vomiting and other side effects of drugs used to treat various illnesses. Marijuana s medical utility has been recognized by a wide range of medical and public health organizations. Arizona voters have declared that the health and welfare of its citizens would be enhanced by the adoption of the AMMA. The purpose of the AMMA is stated, at least in part, to protect medical marijuana patients with debilitating conditions from arrest and prosecution, criminal and other penalties, if such patients engage in such use of the medical use of marijuana.
4 N. Scottsdale Rd., Ste The AMMA provides for a limited number of highly regulated dispensary and cultivation sites. Stringent dispensary license regulations include, but are not limited to full vetting of the applicant, verification of substantial financial resources, possible reasonable zoning restrictions that limit the locale of the dispensaries, comprehensive background checks, audited inventory controls which regulate the origin, distribution, transfer and sale of the cannabis, and a $, application fee.. Pursuant to A.R.S. - (F, and/or the AMMA the Arizona of Department of Health Services was granted rulemaking authority with regard to the AMMA. The current rules (the Rules adopted by the Arizona Department of Health Services aid in the implementation of the AMMA and are contained within R-- through R--. The effective date of the current Rules is on or about April, 0.. DHS-adopted Rules, among other things, divide the State of Arizona into separate geographical areas, known as CHAAs, where only one medical marijuana dispensary may be located. One such geographical area is known as the Sun City CHAA (CHAA #.. Neither the AMMA nor the Rules place geographic restrictions upon the locations of medical marijuana dispensaries and cultivation facilities vis a vis churches, places of worship, parks, libraries, day care centers and other places, businesses and institutions.. The only geographical restriction that the AMMA and the Rules place upon the location of a medical marijuana dispensary and/or a medical marijuana cultivation facility is contained in A.R.S. -0 (B((ii, which states, in essence, that neither dispensaries
5 N. Scottsdale Rd., Ste. 0 0 nor cultivation sites may be located within 00 feet of a public or private school, existing before the date of the non-profit medical marijuana dispensary application.. Plaintiff alleges, upon information and belief and after investigation, that there are no such schools in the Sun City CHAA. Plaintiff does not seek to operate its business within 00 feet of the boundary of the Sun City CHAA and any other CHAA.. One of the relevant Rules, R--0, provides, in pertinent part, that an entity that desires to operate a medical marijuana dispensary or cultivation site must first file an application for a Dispensary Registration Certificate ( Certificate with DHS.. Among other things, pursuant to Rules, R--0, after a Certificate is issued, the holder of the Certificate must then submit an application to DHS for approval to operate a dispensary at a certain location, with or without a cultivation site, at least 0 days before the expiration of the Certificate.. The State of Arizona unsuccessfully sought to delay or to prevent implementation of certain portions of the AMMA, and/or the Rules including, but not limited to, those portions that apply to dispensaries and cultivation sites. The United States District Court for the District of Arizona ruled against the State of Arizona and refused to accept jurisdiction of said matter. The State of Arizona has now commenced to implement those portions of the AMMA that provide for dispensaries and cultivation sites.. Defendants DHS and Humble are currently processing applications for Dispensary Registration Certificates ( Certificates aka dispensary applications, pursuant to R--0 or otherwise.
6 N. Scottsdale Rd., Ste. 0 0 MARICOPA COUNTY S INVOLVEMENT. In order to obtain a Certificate and in order to operate a dispensary or cultivation site, A.R.S. -0 (B((d and Rules, Rule R--0, state that an applicant must submit to DHS documentation issued by the local jurisdiction where the dispensary s proposed location is located, in this case Maricopa County, stating that either there are no zoning restrictions for the dispensary s proposed location or that the dispensary s location and/or cultivation site is in compliance with any and all zoning restrictions.. For all relevant purposes, a cultivation site cannot be opened without first or simultaneously opening a dispensary. In order to obtain a license to operate a dispensary, an applicant must first obtain a Certificate. After a Certificate is obtained from DHS, the holder of the Certificate must comply with Rules, R--0 (A(. This rule states that the holder of the Certificate must submit to DHS a copy of documentation issued by the local jurisdiction authorizing occupancy of the building as a dispensary and, if applicable, as the dispensary s cultivation site 0. On or before May, 0, Plaintiff filed a timely application for a Certificate with DHS.. On or about June, 0, DHS issued a Notice of Deficiencies to Plaintiff, attached Exhibit B. Exhibit B was issued to Plaintiff because, in pertinent part, Plaintiff was unable to obtain documentation from Defendants Maricopa County and/or Montgomery, stating that either there are no zoning restrictions for the dispensary s proposed location or that the dispensary s location is in compliance with any and all zoning restrictions.
7 N. Scottsdale Rd., Ste Pursuant to A.R.S. -0.0, cities, towns and counties may enact reasonable zoning regulations that limit the use of land for registered non-profit medical marijuana dispensaries to specific areas.. Defendant Maricopa County, acting by and through its County Attorney, Board of Supervisors and others, has taken the position that neither Defendant Maricopa County nor Defendant Montgomery will issue, supply or state written reasons for failing to supply the sworn statement (and/or any other documentation or evidence certifying or refusing to certify that Plaintiff s proposed dispensary and/or cultivation site and/or any other non-profit medical marijuana dispensary and/or cultivation site in CHAA # is (or is not in compliance with Maricopa County zoning and/or all other building occupancy restrictions, if any, for the opening of a medical marijuana dispensary and or cultivation site.. On more than one occasion Defendant Montgomery has stated or written that he and Maricopa County will not comply with the AMMA or with DHS relevant Rules because marijuana is illegal under federal law. Upon information and belief, Mr. Montgomery has so advised the Maricopa County Board of Supervisors and the Maricopa County Planning and Development [zoning] Department. Consequently, no person with authority to act for Maricopa County will confirm or deny whether Plaintiff s proposed location, North th Avenue, Suite B, Sun City, Arizona, or any other location in the Sun City CHAA, is or is not in compliance with Maricopa County restrictions and/or whether said address location is allowed as a medical marijuana dispensary and/or cultivation site, as required by Rules, R--0 and/or R--0 (A(. See attached Exhibit A, a letter from Mr. Montgomery to the undersigned, dated June, 0.
8 N. Scottsdale Rd., Ste Defendants Maricopa County and Montgomery have willfully, wrongfully, arbitrarily, capriciously and/or without cause, failed and refused and still fail and refuse to accept and process requests for zoning, location and/or building compliance and/or to confirm whether Maricopa County has adopted any reasonable or unreasonable restrictions upon the location of medical marijuana dispensaries and/or cultivation sites in unincorporated portions of Maricopa County.. The refusal of Defendants Maricopa County, Montgomery and/or other Defendants to process and issue dispensary and/or cultivation site zoning and/or building location approval and/or compliance is wrong, arbitrary, capricious and/or an abuse of discretion, for a number of reasons including, but not limited to: a. The AMMA has not been declared to be pre-empted by federal law, nor has any federal court issued an Injunction or Order blocking implementation of the AMMA. b. No court has ruled that Maricopa County may refuse to accept and process requests for location compliance. c. No court has ruled that Maricopa County or any other county, city, town or entity may act to thwart any purpose of the AMMA or the Rules. d. Defendants DHS and Humble have already determined that one medical marijuana dispensary shall be located in each CHAA. e. The restrictions, if any, currently force and effect in unincorporated Maricopa County violate A.R.S because they are unreasonable. f. It is clearly unreasonable, unsafe and contrary to the terms and intentions of the AMMA and the Rules to require the permanent and other residents of the
9 N. Scottsdale Rd., Ste. 0 0 Sun City CHAA, all of whom are believed to be over the age of, to travel long distances, outside of the CHAA in which they reside, in order to obtain medical marijuana that the State of Arizona has authorized them to obtain and use, under appropriate circumstances.. Except to the extent that Judge Bolton s decisions, in State of Arizona v. U.S., No. CV-0-PHX-SRB (D. Ariz. 0, effect this dispute, no court has ruled upon the issues raised in this Complaint.. Eric Holder, the United States Attorney, and the local United States Attorney s Office have indicated that county and government employees in Arizona are not at risk of prosecution. They have refuted all such claims of risk of prosecution and/or penalty because Arizona is one of the states that have adopted medical marijuana legislation and are complying with state law. PLAINTIFF S STATUS AND DAMAGES. No other application for a Certificate to operate a dispensary in the Sun City CHAA will be accepted in the near future because the deadline for applying was May, Plaintiff submitted the only application for a medical marijuana dispensary Certificate in the Sun City CHAA. Up to applications were filed for one other CHAA. Thirteen applications were filed in at least four other CHAAs. The time for filing such applications has passed. Plaintiff would be awarded the Certificate, which is an authorization to commence construction of a dispensary and cultivation site and a license to open not-forprofit businesses, after inspection by DHS, if not for the sole reason that Defendants Maricopa County and Montgomery have failed to act upon Plaintiff s request for zoning and
10 N. Scottsdale Rd., Ste. 0 0 building location approval. MARICOPA COUNTY S PRIOR/CURRENT ZONING ORDINANCES. On or about December, 0, Maricopa County duly adopted changes to its Zoning Ordinance ( Ordinance, Article 0.., to provide for medical marijuana dispensaries and cultivation sites. The only restrictions upon the locations are that they may not be located within,00 feet of another dispensary; a church, a private elementary or secondary school, a public or private day care center, preschool, nursery, kindergarten or similar use; a public park or playground; or an adult oriented facility. Article 0.. further provided that medical marijuana dispensaries shall be located only within the C- or C- Commercial Zoning Districts.. Article 0.. is very similar to the restrictions placed upon medical marijuana dispensaries and cultivation sites throughout Phoenix and in incorporated areas in close proximity to Phoenix.. Plaintiff s proposed location complies with each and every one of the above described (former provisions of Article Article 0.. was subsequently repealed. Upon information, and belief, it was repealed upon the advice of Defendant Montgomery and/or his subordinates, with his permission.. Plaintiff is entitled to collect their reasonable attorney fees from Defendants pursuant to A.R.S. - and - and/or pursuant to the Rules of Procedure for Special Actions, Rule (g.
11 N. Scottsdale Rd., Ste. 0 0 FIRST CLAIM FOR RELIEF (Declaratory Judgment. Plaintiff hereby realleges paragraphs through of its Common Allegations, as though the same were fully set forth herein.. Plaintiff is entitled to a judgment declaring that there are no local or Maricopa County zoning restrictions for a proposed dispensary in the Sun City CHAA # and/or, in the alternative, that any and all locations in the Sun City CHAA # are in compliance with the Maricopa County Zoning Ordinance and regulations relating to a where a dispensary may be located, except for those locations that are within 00 feet of a public or private school, existing before the date of the non-profit medical marijuana application and/or, in the alternative, that Maricopa County has not enacted any reasonable zoning restrictions with regard to medical marijuana and/or, in the alternative, that the only reasonable restrictions that Maricopa County has enacted or could enact, with regard to medical marijuana dispensaries and cultivation sites in the Sun City CHAA, are those restrictions that are or were previously set forth in Article 0.. of the Maricopa County Zoning Ordinance and/or, in the alternative, that Plaintiff has otherwise complied with all requirements for obtaining a Dispensary Registration Certificate in the Sun City CHAA and has complied with all Maricopa County requirements for opening a medical marijuana dispensary and cultivation in the Sun City CHAA #, subject only to proper construction of improvements at Plaintiff s site. SECOND CLAIM FOR RELIEF (Injunctive Relief
12 N. Scottsdale Rd., Ste Plaintiff hereby realleges paragraphs through of its Common Allegations and First Claim for Relief, as though the same were fully set forth herein.. Plaintiff reasonably believes that, if Defendants Arizona Department of Health Services and Humble are not enjoined pendente lite and permanently from withdrawing and/or rejecting Plaintiff s application for a Dispensary Registration Certificate, Plaintiff will have no adequate remedy at law because the damages that they will suffer will be unreasonably difficult, if not impossible, to prove for reasons including, but not limited to the fact that Plaintiff s business is a new business; because, if their application is deemed to be withdrawn or is denied, they will not have an opportunity to re-apply in the near future and, when they do re-apply, there is likely to be multiple applicants for the single Dispensary Registration Certificate in the Sun City CHAA, as opposed to the present situation where Plaintiff is the sole applicant. THIRD CLAIM FOR RELIEF (Mandamus 0. Plaintiff hereby realleges paragraphs through of its Common Allegations, First Claim for Relief and Second Claim for Relief, as though the same were fully set forth herein.. Plaintiff seeks and is entitled to the issuance of a Writ of Mandamus, requiring Defendants Maricopa County and/or Montgomery to provide Plaintiff and the Arizona Department of Health Services with a sworn statement and/or other materials required by the AMMA, the Rules including, but not limited to Rules, R--0 through 0, declaring that Maricopa County has not adopted any restrictions upon the location of medical
13 N. Scottsdale Rd., Ste. 0 0 marijuana dispensaries and/or cultivation sites in the Sun City CHAA and/or, in the alternative, that Plaintiff s proposed location at North th Avenue, Suite B, Sun City, Arizona and/or any other location selected by Plaintiff within the Sun City CHAA that complies with the provisions of the current version or former version of Article 0.. of the Maricopa County Zoning Ordinance is in compliance with the restrictions adopted by Maricopa County and that occupancy of the building(s where Plaintiff intends to open a dispensary and/or cultivation site in CHAA # comply with all of the above identified requirements. WHEREFORE, Plaintiff demands relief from all Defendants, individually, jointly and severally, as follows:. For the issuance of a declaratory judgment ruling that there are no local or Maricopa County zoning restrictions for a proposed dispensary and/or cultivation site in the Sun City CHAA # and/or, in the alternative, that any and all locations in the Sun City CHAA # are in compliance with the Maricopa County Zoning Ordinance and regulations relating to a where a dispensary may be located, except for those locations that are within 00 feet of a public or private school, existing before the date of the non-profit medical marijuana application and/or, in the alternative, that Maricopa County has not enacted any reasonable zoning restrictions with regard to medical marijuana and/or, in the alternative, that the only reasonable restrictions that Maricopa County has enacted or could enact, with regard to medical marijuana dispensaries and cultivation sites in the Sun City CHAA, are those restrictions that are or were previously set forth in Article 0.. of the Maricopa County Zoning Ordinance and/or, in the alternative, that Plaintiff has otherwise complied
14 N. Scottsdale Rd., Ste. 0 0 with all requirements for obtaining a Dispensary Registration Certificate in the Sun City CHAA and has complied with all Maricopa County requirements for opening a medical marijuana dispensary and cultivation in the Sun City CHAA #, subject only to proper construction of improvements at Plaintiff s site;. If requested in a separate pleading, for the issuance of a Temporary Restraining Order, Preliminary Injunction and/or Permanent Injunction, enjoining Defendants and their agents from deeming Plaintiff s application for a Dispensary Registration Certificate and/or Plaintiff s application to actually operate a medicinal marijuana dispensary and/or cultivation site to be withdrawn, being deficient or denying said application, until the conclusion of this case upon its merits;. If requested in a separate pleading, for the issuance of a Writ of Mandamus, requiring Defendants Maricopa County and/or Montgomery to provide Plaintiff and the Arizona Department of Health Services with a sworn statement and/or other materials required by the Arizona Department of Health Services, et al., declaring that Maricopa County has not adopted any restrictions upon the location of medical marijuana dispensaries and/or cultivation sites in the Sun City CHAA and/or, in the alternative, that Plaintiff s proposed location at North th Avenue, Suite B, Sun City, Arizona and/or any other location selected by Plaintiff within the Sun City CHAA that complies with the provisions of the current version or former version of Article 0.. of the Maricopa County Zoning Ordinance is in compliance with the restrictions adopted by Maricopa County and has complied with all Maricopa County requirements for opening a medical marijuana dispensary and cultivation in the Sun City CHAA #, subject only to proper construction of
15 N. Scottsdale Rd., Ste. 0 0 improvements at Plaintiff s site.. For the issuance of an Order to Show Cause directing the Defendants to appear before this court and show cause, if any they have, why the relief requested should not be granted.. For damages, in an amount in excess of the minimum jurisdictional requirements of this Court, the exact amount of which will be determined and proved at the time of trial;. For Plaintiff s reasonable attorney fees, in an amount to be determined by the court before or after the time of trial;. For Plaintiff s accrued court costs;. For interest on all sums due and owing to Plaintiff, at the highest rate authorized by law, from the date of judgment, until paid in full; and. For such other and further relief as is just and proper. Dated this day of June, 0. JEFFREY S. KAUFMAN, LTD. By: Jeffrey S. Kaufman, Esq. N. Scottsdale Road, Ste. 0 Attorney for Plaintiff
16 N. Scottsdale Rd., Ste. 0 0 STATE OF ARIZONA ss. County of Maricopa VERIFICATION Jeffrey S. Kaufman, Esq., being first duly sworn upon his oath, deposes and states:. That he is the attorney for Plaintiff in the above entitled action;. That he has read the foregoing Complaint and knows the contents thereof, and that the matters and things contained therein are true and correct to the best of his knowledge, information and belief. Jeffrey S. Kaufman, Esq. SUBSCRIBED AND SWORN to before me this day of June, 0, by Jeffrey S. Kaufman, Esq. My Commission Expires: Notary Public
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