MEDICAL MARIJUANA AND PUBLIC SAFETY Presented by Michael

MEDICAL MARIJUANA AND PUBLIC SAFETY Presented by: Michael D. Cirullo, Jr. , Esq. Brian J. Sherman, Esq. Goren, Cherof, Doody, and Ezrol P. A. 3099 E. Commercial Boulevard Suite 200 Fort Lauderdale, Florida 33308

IS THERE A PUBLIC SAFETY CONCERN? Law Enforcement express concern Florida is untested in resolving Medical Marijuana issues Studies from other states appear to show limited correlation between Medical Marijuana and increased crime

PUBLIC SAFETY Neighborhood Effects � Ingress/Egress � Pedestrians � Loitering � Vehicle Stacking � Lighting Distribution of Controlled Substances Cash Business Federal Concerns

NEIGHBORHOOD EFFECTS Ingress Egress

NEIGHBORHOOD EFFECTS Pedestrian Loitering Queuing

NEIGHBORHOOD EFFECTS Vehicle Stacking

DISTRIBUTION OF CONTROLLED SUBSTANCES Transportation of Controlled Substances Non-Residents Parking lot transactions Patients targets for theft and robbery � Cash � Controlled Substances Internal Theft Emergency Management

PUBLIC SAFETY ISSUES Storefront Management: � Limitation of Hours � Security Requirements � Lighting � Product Limitation

CASH BUSINESS Federal Regulations prohibit credit card transactions for marijuana Effectively transforming Medical Marijuana into a CASH ONLY business

CASH BUSINESS Cole Memo: August 29, 2013: � Provided guidance to the Department of Justice to focus its priorities. � Among the priorities affecting local government planning: Preventing the distribution of marijuana to minors Preventing revenue from sale of marijuana from going to criminal enterprises Preventing state authorized marijuana activity as a pretext for illegal activity Preventing violence and use of firearms in the cultivation and distribution of marijuana Preventing adverse public health consequences and crimes

CASH BUSINESS Colorado House Bill 1398 – Marijuana Financial Services Act � Creates a Co-op Banking System for Medical Marijuana � Passed in June 2014 � No application has been made to the Federal Reserve

FEDERAL CONCERNS Little guidance from Federal Regulations: � February 14, 2014 – Dept. of Treasury issues “expectations” for marijuana related transactions New Attorney General may adopt differing or contrary policies Individual Credit Card Companies may continue to refuse to accept “illegal” transactions based on company policy Advent and proliferation of cashless “ATM” transactions, Bit. Coin, RFID chips, and other payment transactions No screening or training requirements for non-medical employees � Prevention of internal theft

UNIQUE CHALLENGES Recognition of Out of State Medical Marijuana recipients � Fort Lauderdale Hollywood International Airport � Port Everglades Temporary Residence Patients Regulation of Use: Parks and Beaches

PUBLIC SAFETY THROUGH ENVIRONMENTAL DESIGN Strategies implemented to reduce crime at targeted businesses by: � Taking advantage existing conditions; � Maximizing the use of environmental conditions; � Enhancing environmental management techniques; � Modifying structures, uses, and design features to enhance security and visibility; and � Increase community awareness.

QUESTIONS?