Confidential                                                                                      July 17, 2024

Commissioner Desmon Duncan-Walker

City of Gainesville

200 E. University Ave.

Gainesville, FL 32601

Subject: Request for Investigation into Ballot Measure 3 and the Florida Cannabis Industry

Dear Commissioner Duncan-Walker,

I am writing to request your support regarding serious concerns of racial discrimination and financial misconduct within Trulieve, a dominant entity in Florida’s cannabis industry. Enclosed is a letter to Attorney General Moody, urging an investigation into these issues. In Florida more than 70% of the cannabis market is controlled by five large corporations (source)

Key Points:

Extension of Monopoly: Ballot Measure 3 would cement the dominance of a few large cannabis companies in both the medical and adult use markets in Florida.

Racial Discrimination: The largest backer of Ballot Measure 3, Trulieve, has been accused of racial discrimination in multiple lawsuits brought by black employees.

Criminal Activities: There have been concerns raised about undisclosed transactions and potential financial irregularities linked to Trulieve's leadership, which merit further investigation regarding their influence on the ballot measure.

Ballot Measure 3 will exacerbate existing inequalities by ensuring that control over Florida's cannabis industry remains concentrated in the hands of a few large entities, limiting economic opportunities for local communities and minority-owned businesses.

Request:

1. Endorsement: Please endorse the request to Attorney General Moody for an investigation.

2. Request Findings: Alternatively, make a formal request for the findings of any investigation.

Your support and inquiry will significantly enhance the credibility and urgency of this matter, ensuring that these concerns are thoroughly investigated.

Thank you for your attention to this important issue.

Sincerely,

Scott Ayers, Mbr

CEA, LLC

Attachments

Confidential Request for Investigation - Attorney General Moody (source)

Trulieve Request for Investigation (A70) - Criminal and Unethical Activity (source)

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Trulieve Board of Directors

Trulieve Senior Executives

Questions for Consideration

1. If a company with all Black leadership received adverse opinions from its auditors for two consecutive years (2022 and 2023), would regulators be unable or slow to intervene? Trulieve adverse opinion reference here

2. If this company had multiple OSHA violations but still failed to provide PPE to a young worker, documented her distress, refused reassignment or PPE, filmed her collapse and hospitalization, and then returned her to the same conditions leading to her death, would it receive only a minor fine or would the authorities take prompt effective action? Trulieve death reference here

3. If a company with all Black leadership violated regulations by growing marijuana in large outdoor plantations, would the government ignore it? Trulieve cultivation reference here

4. If this company faced repeated lawsuits from White individuals alleging racial hatred and discrimination, would the State of Florida remain inactive? Would the State continue to annually affirm and renew the company’s cannabis license? Trulieve racial discrimination lawsuits here

5. If a company with all Black leadership boasted about tweaking the license process that resulted in the exclusion of all White applicants, would authorities turn a blind eye to such blatant discrimination? Trulieve license tweaks reference here

6. If the company falsely claimed its CFO resigned voluntarily but later admitted in court that evidence of embezzlement (concealed from investors) was used to force the resignation, would securities regulators (SEC, FINRA) fail to act? Would they fail to investigate additional crimes concealed by these false statements? Trulieve fraud in accounting reference here

7. If the company submitted incomplete cannabis license applications, omitting lawsuits, concealing allegations of criminal activity including fraud, sales tax audits, and judgments, would the cannabis commissions be powerless to respond? Trulieve License application reference here

8. If a company with all Black leadership branded its marijuana products with names intended to appeal to children, such as Cinderella, Root Beer Float, and Girl Scout Cookie, and used imagery of children and skateboards in its cannabis ads, would the State of Florida fail to take action? Trulieve cannabis products, kids names and images here

A company under all Black leadership facing accusations of being a continuing criminal enterprise could find itself subject to the Florida Contraband Forfeiture Act, resulting in the seizure of its assets by state authorities.

Addressing Systemic Racism

Systemic racism often blends into the background, only occasionally becoming visible to those who care to see. When it becomes obvious to all, it is crucial to act: to identify the reluctance to enforce regulations, to pinpoint government facilitators of racism, and to shine a light of righteous outrage on the situation.

This is no easy task. The company in question has significant financial resources, enabling it to influence political and legal processes to maintain the status quo. Committed, long-term action is required. The choice is clear: do nothing and accept systemic racism, or speak out and prepare to fight against injustice.

Cartel acknowledged by Florida:

“DeSantis criticized the state’s existing regulatory framework as a “cartel essentially” that violated the free-market principles he ascribed to.” - News article (source)

74% of Marijuana Sales Controlled by Florida’s MSO Cartel

*mgs THC per OMMU June 2024 data (source)

These are not typical private enterprises, but rather government sanctioned monopolies. The State of Florida has effectively provided each of these companies a license to print money.

Florida’s MSO Cartel - Marijuana Sales

*mgs THC per OMMU June 2024 data (source)

Among the Cartel, Trulieve boasts the highest sales, despite being fined $350,000 and specifically called out in a recent investigation “Throughout 2021 and into 2022, Respondent [Trulieve] failed to Process Marijuana in a safe and sanitary manner” - section 94, pg 13 (source)

Florida’s MSO Cartel - Payments to ‘Smart and Safe’

Data source

Smart and Safe, a front organization masking Trulieve's involvement, spent $40 per signature, using millions from Trulieve to support Ballot Measure 3.

These large companies cooperate to benefit each other.

Trulieve, Florida’s Largest Marijuana Company has a poor BBB rating:

This company has become Florida's leading cannabis player despite a customer rating of 1 out of 5, which some observers attribute to what appears to be leniency in regulatory oversight and perceived political connections.

Trulieve has received multiple serious OSHA violations and fines. Trulieve faces multiple environmental whistleblower and racial discrimination lawsuits brought by employees. The spouse of Trulieve’s CEO is a felon convicted of bribery and extortion of public officials told agents:

"We didn't know how to grow marijuana." He told the undercover FBI agent, "all we knew is, is that five licensed marijuana in Florida, f***** real valuable. We didn’t have to know anything more than that." (source) [emphasis added]  Spouse of Trulieve CEO

One must question the legitimacy of a cannabis license process that awards a license to an entity associated with an FBI suspect, an individual with a learning disability. Notably, this individual is white and has close connections with members of the Florida State Legislature.

Florida Demographics

Demographic data source