Karma Koala Podcast 255: Nathaniel Gurien, New Hampshire Deep Dive – Medical Now & How To Get To Adult Use | Cannabis Law Report | How to buy Skittles Moonrock online

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Nathanial has been in the cannabis industry for the past decade and you may recognize his name from his company Fincann who have helped businesses create relationships with financial institutions around the US.

He writes

As CEO of FINCANN®, I have steered the company to be a trailblazer in providing comprehensive banking and financial solutions within the high-risk sectors, including cannabis and cryptocurrency. Our services extend beyond basic banking, encompassing everything from commercial real estate and inventory financing to complex legal and tax advisory, ensuring our clients navigate the intricate financial landscape with ease. Our commitment to innovation is demonstrated through our proprietary CANNABIS BANKING FINANCIAL NETWORK®, connecting clients with a network of over 300 federally-insured financial institutions and 50+ financial service vendors.

Nathanial is now applying his skills learnt to move New Hampshire toward a fully regulated adult use environment.

We talk in detail about the development of the medical program in NH and how he and allies hope to move towards adult use.

He has also penned the following article on the topic

The Definitive Insider’s Guide to New Hampshire Cannabis Legalization

History 2013 – 2025

Chapter One

Limited Therapeutic Cannabis is Legalized

On July 23, 2013, now NH US Senator and then NH Governor Maggie Hassen signed legislation legalizing the state’s current Therapeutic Cannabis Program (TCP) after the majority Democratic NH House passed it 221-179 and the roughly evenly divided Senate passed it 18-6 with all Democratics voting in favor together with 7 Republicans joining them. The first of now seven medical cannabis dispensaries opened in 2016. It was a highly restricted program with qualifying patient conditions mostly limited to serious or terminal illness, significant obstacles to patient qualification, prohibitions on licensee advertising and outdoor cultivation, strict personnel and compliance guidance, and requiring each licensee to operate an insular, vertically integrated operation barring sale of cannabis or hemp products not produced in-house.

Relaxing Personal Restrictions

In July 2017, possession of three-quarters of an ounce of flower or the equivalent in manufactured products such as hashish and tinctures was decriminalized from a felony carrying jailtime and heavy fines to a violation carrying a maximum $100 fine. Possession and sale above this modest amount, except for registered medical cannabis patients (who may possess up to two ounces) remain a serious offense to this day.

In 2019, Republican Governor Sununu signed legislation providing annulment of misdemeanor marijuana convictions.

Adult-Use Legalization Gains Traction After Five Years

Despite the NH House approving adult-use commercial legalization numerous times between the commencement of legal medical sales in 2016 and 2021, the NH Senate rejected all these often substantially in anticipation of the Governor’s publicly stated intention of vetoing any such bills that might reach his desk. But then in 2022 this annual political kabuki theater took a promising turn.

In April, the University of NH published the results of a poll of NH residents showing 74% public support for recreational legalization across the state.

In June of that year, the NH Cannabis Party was founded to advocate for and endorse and support candidates for statewide office supporting common-sense cannabis legalization with myself as its first executive director. During this election year 2022, the NH Cannabis Party ultimately endorsed nearly 200 candidates with their active consent, each represented on the Party’s website with their photos, capsule write-ups about each candidate, and links to the candidates’ websites. Support was from across the political spectrum – about 40% Republicans, some Libertarians, and the rest Democrats including candidates for governor, senate, state rep, executive council and other state offices.

In a phone interview at the time with the local newspaper Conway Daily Sun, I said legalization wouldn’t just create jobs for growers, dispensaries and such, but that it could also spur innovation in pharmaceuticals and be a boon for New Hampshire’s tourism industry. The website also contained a lengthy list of businesses that stood to benefit from legalization and included legal, finance, general contractors, public relations and regulatory compliance. I added that common-sense reform would involve legalization for adults over 21 years old, and there would also still be prohibitions on driving while intoxicated.

During the campaign, senate candidate Dr. Bill Marsh stated: “My website clearly says I support legalization provided we pay attention to public health concerns. My opponent clearly stated at the Tamworth event that he opposes legalization, which he has done over the years. So, I believe it’s entirely logical the NH Cannabis Party would do this.”

State rep Anita Burroughs was also endorsed stating: “Nathaniel Gurien of Sandwich is the mover and shaker behind this movement. He would like to see cannabis move from the black market to the mainstream. As part of this, he is championing the legalization of cannabis in New Hampshire. I support this effort, and NH would be following in the path of 19 other states, plus D.C. Our neighbors Massachusetts and Maine have legalized marijuana. Cannabis has been demonized as a dangerous drug, a notion that has been widely debunked. It’s time to make it legal in NH and reap the entrepreneurial and tax benefits that it will bring to our state.”

Michael Costable was the lone Carroll County Republican to get an endorsement. He was running (and ultimately won) in House District 8. “The real reason we don’t have legal weed rests with the liquor commission and police union, said Costable. Look at what happens to alcohol sales post legalization (spoiler: they drop). And on that note, I will not support any bill that gives the Liquor Commission monopoly on weed as well.”

Democrat Peaco Todd of Tamworth, running in House District 3, was endorsed as well. “I’ve been a longtime supporter of medical marijuana and am firmly in favor of legalizing cannabis for recreational and other therapeutic uses as long as it’s carefully regulated”, said Todd, calling New Hampshire an island in a sea of legalization. “Failing to regulate it will not prevent its use. What we will be preventing, if legalized and regulated, is, among other things, marijuana that’s been contaminated with other substances, one of the most deadly being fentanyl. Legalized cannabis also has the potential to be a revenue producer for the state. Of course, marijuana, like alcohol, has the potential for abuse and regulations would need to address that issue. But overall, I think legalized cannabis is a win-win for N.H.”

Common Sense Cannabis Legalization Gains Further Momentum

In December 2022, following the 2022 midterm election, NH House Majority Leader Jason Osborne submitted legislation for smart, common-sense cannabis legalization with four of his Republican and three Democratic house colleagues (including House Minority Leader Matthew Wilhelm), as well as one Republican senator and two Democratic senators as original co-sponsors. Many other legislators from across the political spectrum subsequently signed on as cosponsors.

This legislation was crafted by a broad coalition of legalization advocacy groups who had been working on this issue for several years, including NH Cannabis Association, ACLU-NH, Americans for Prosperity, Marijuana Policy Project, NH Cannabis Party and Prime ATC (one of the four current medical cannabis licensees and which changed their company name a couple years ago to: ‘Granite Leaf Cannabis’).

The bill included legalized possession for personal use and home cultivation, extending the 8.5% rooms and meals tax (New Hampshire otherwise has no sales or personal income tax) to include cannabis sales to support property tax relief, education, pension funds, substance abuse prevention, distressed farmers, veterans, impacted communities, municipalities with at least one licensed cannabis retailer and public safety agencies for hiring and training. Also included were low application and license fees, wiping out criminal records for past cannabis offenses, allowing transitioning current medical dispensaries to adult-use and to be able to accept out-of-state medical cards, and exclusive opportunity for all New Hampshire residents with no artificial cap on licenses.

Remarkably, the lead sponsor of this bill, House Majority Leader Jason Osborne, commented on the record that he “hated” his own bill on his belief that legal cannabis as an agricultural crop should be no more overseen by government supervision and regulation than “tomatoes.” However, as a practical legal matter, he understood that at least while cannabis remains illegal under federal law as a dangerous narcotic, some regulatory oversight on the state’s part was necessary in order to protect the program from federal interference Just as when the hemp variety of cannabis was more or less legalized federally in 2018 and much of the suffocating regulatory framework was lifted, many New Hampshire policymakers expressed concern that unnecessary regulation and restrictions would be lifted as soon as possible following eventual federal legalization to keep a level playing field for all New Hampshire residents and licensed operators.

At the time, Sen. Keith Murphy (R-Manchester) was steadfastly opposed to any cap on the number of licenses available to New Hampshire residents but also conceded that that goal might need to be phased in to assure an orderly rollout and avoid the market chaos experienced by other states that moved too quickly on this, largely due to the fact their legalization programs prohibited interstate commerce resulting in oversupply, market pricing below the cost of production, and diversion of excess goods to illegal markets.

Sen. Donovan Fenton (D-Keene) was “all in” for common-sense cannabis legalization and believed as did many of his colleagues that the upcoming session of the New Hampshire legislature represented the most favorable for passage of smart cannabis legalization in 2023.

Lessons Learned and Good Public Policy Applied

Amid growing excitement that 2023 would the year New Hampshire finally passed an inclusive and thoughtful adult-use program, the NH House Commerce and Consumer Affairs committee chaired by Rep. John Hunt held a public hearing on two pending cannabis legalization bills. The first, as previously described, HB639 was crafted by a broad coalition of legalization advocacy groups and industry stakeholders who had been working on this issue for several years with broad bi-partisan support, including sponsorship from both the House majority and minority leaders. The second, HB544 was sponsored by Democratic state reps Richard Eaton and Christine Siebert, et.al. which sought to create monopoly control over the entire New Hampshire cannabis economy by the state owned and operated NH Liquor Commission in a manner like its exclusive sales of liquor and higher alcohol content wine and spirits.

My testimony during this hearing in support of HB639 primarily urged that gun rights, interstate and international commerce, and incentivizing public/private partnerships be considered for inclusion in the “coalition” bill (HB639), and that by contrast

HB 544 would suffocate a vibrant cannabis economy, limit opportunity to a privileged few, and squander a generational opportunity for boosting the overall economy of New Hampshire.

Several opponents of cannabis legalization testified about increased threats to public safety in other currently cannabis legal states largely based upon one-sided surveys showing elevated DWI arrests supposedly involving cannabis. However, upon questioning from committee members, these opponents were unable to identify whether alcohol was also or primarily involved in these incidents, whether the cannabis was derived from the legal or illegal market, or whether cannabis intoxication was actually a factor since a sobriety test for cannabis intoxication is not yet commercially available.

Subsequently, I interviewed Rep. Hunt for an upcoming column in the local Conway Daily Sun newspaper who explained that he was supporting HB544 to establish New Hampshire as a “control state” for cannabis commerce with the Liquor Commission owning 20 retail dispensaries throughout the state operated by one or more selected third-party contractors, unlimited cultivation licenses, existing medical dispensaries prohibited from transitioning to add recreational sales, and no specific provision for cannabis-related taxes or revenue other than undefined “fees.”

I pointed out that a severely restricted number of retail outlets combined with unrestricted cultivation that could only be wholesaled to the Liquor Commission was a prescription for oversupply of product thus incentivizing the black market among other serious defects in the proposal.

Nonetheless, he was adamant that this bill was the only framework that might garner the approval of the New Hampshire Senate and Governor’s office in the face of their overall opposition to enact cannabis legalization at all.

Right after that I called Liquor Commissioner Joe Mollica’s office for an appointment to discuss this issue and cannabis policy in general, and not an hour later state rep Hunt called me back to retract nearly our entire interview stating that he had just been in contact with the Commission who expressed the view that they had no intention or ability of taking such an extensive role in the proposed cannabis economy as contemplated by HB544.

Rep. Hunt went on to say that he apparently misunderstood their intentions and interest and had inadvertently “gotten ahead of his skis” in supporting this initiative. He was therefore going back to supporting the original “coalition” bill (HB639) without significant further revision.

At the following week’s subcommittee and full committee meetings, there was agreement that annulment of previous cannabis convictions would not be included in the final bill, that the Liquor Commission would be the designated regulatory body to be renamed the NH Liquor & Cannabis Commission, and that the issue of independent product testing laboratories would be settled at the regulatory level via rule-making following passage of the legislation.

The consensus of the committee and from further conversation with Rep Hunt after the meeting, the simplest, competitive, optimal and future-proof revenue model to emerge was a retail tax of 5% (lowest in the nation) combined with a 10% tax on commercial cultivation or future imported product (when interstate or international commerce is authorized). This would substitute for extension of the current 8.5% rooms and meals tax to retail cannabis sales as originally included in HB639 as a concession to policymakers who generally oppose enacting any new statewide taxes.

The committee then favorably reported out their final version of the bill which then headed to a full floor vote by the House including these revisions:

Testing was proposed to be done by labs that are independent from companies that produce cannabis.

Provisions to allow home grow and annulment of prior cannabis convictions were removed as a compromise to improve the bill’s chances of enactment this year.

Creation of a new advisory board to the Commission was removed as an unnecessary layer of bureaucracy.

There would be no retail (sales) tax. Growers were to be taxed at 15 % of their monthly gross revenue and likely extended to importers when interstate and international commerce is authorized. 80% of tax revenue would support an education trust fund, 10 % would fund substance misuse treatment programs, 5% would go to localities that have at least one operational retailer and 5% (up to $1 million) would support public agencies like police and fire departments.

Application, registration and renewal fees would not be capped by the legislation but determined by the Commission nor would there be any statewide cap on the number of businesses that could be licensed.

Existing medical cannabis dispensaries would be permitted to apply for dual licenses to start serving adult consumers.

Also included would be employment protections for state or local government workers who use marijuana off work so professional and occupational licenses couldn’t be denied or withdrawn because a person uses cannabis.

The Definitive Insider’s Guide to

New Hampshire Cannabis Legalization

History 2013 – 2025

Chapter Two

Comprehensive Smart Legalization Passes the New Hampshire House

In April 2023 remarkably smart, common-sense cannabis legalization (HB639) as originally sponsored by House Majority Leader Jason Osborne and House Minority Leader Matt Wilhelm cleared the full New Hampshire House 234-127, was then amended by House Ways & Means Committee members Terry Spilsbury, Fred Doucette, and Susan Almy and cleared that committee by a vote of 16-4 followed subsequently by approval in a final House vote with a roughly 3-1 margin.

Lessons learned from the mistakes of other states had been substantially applied, and pioneering, first-in-the-nation provisions added.

For example, when New York passed adult-use legalization a couple years before, it permitted anyone to exchange cannabis so long as no money changed hands. So nearly 1000 unlicensed retail stores, mobile trucks, sidewalk tables and the like popped up like mushrooms selling art, t-shirts, memberships, etc, then ‘gifting’ an amount of cannabis equal to the retail value of the non-cannabis merchandise. The result was enormous growth of the underground black market, especially in NYC and general chaos on many levels. Our smart legislators closed that loophole.

New Hampshire would become the first-in-the-nation with no retail sales tax and the lowest cannabis tax rate in the US at a rate of 12.5% imposed at the finished product wholesale price to the retail dispensary as an ‘excise’ tax. Since the retail price is typically about 3X wholesale, the effective tax rate indirectly passed on to the consumer would be around 4%.

New Hampshire would also be the first state in the nation to legalize interstate commerce per Section 318-F15 Part IX: “The following act(s) shall not be illegal under New Hampshire law…Selling, offering for sale, transferring, transporting or delivering cannabis to establishments licensed to process or sell cannabis under the laws of other states if the person or business entity has obtained a current, valid (cannabis) license…”

The NH Liquor Commission (to be re-named the “NH Liquor and Cannabis Commission”) would be responsible for licensing, rules, regulation and enforcement and would be advanced $15M to stand up its separate cannabis regulatory administration. An additional $500K was allocated to develop and implement a public education and safety campaign prior to initiation of retail sales. Both of these were to be reimbursed from future cannabis excise tax revenues.

The Commission’s cost of regulating the cannabis industry was projected to be offset on an ongoing basis from the licensing and related fees it collects, so the proposed excise tax will be fully applied to the specific purposes and programs as described below. However, as the industry matures, the overall increase in business activity from both cannabis licensees and especially those businesses, professions and trades that provide it goods and services were projected to swell revenue from existing state business and payroll taxes and provide even more revenue for the state than the wholesale excise tax. For perspective, the Liquor Commission currently contributes about $200,000,000 annually to the state’s revenue. With the commercial legalization and regulation proposed in this legislation, combined new revenue from cannabis within a decade could easily add 50% – 100% or more to the current liquor-generated revenue.

Revenue generated from the cannabis excise tax was proposed to be allocated as follows: $100,000 annually to the department of safety drug monitoring initiative for data collection and reporting related to the health impacts of cannabis prohibition and regulation; then 50% to the education trust fund, 30% to the unfunded retirement system liability, 10% for substance abuse and recovery, 5% to public safety, including police, fire and rescue, and 5% to children’s behavioral health services.

Other smart provisions include protection of individual privacy, safety, labeling, testing, guaranteed retail availability of low-potency products, municipalities may opt out but cannot restrict delivery, contracts are legally enforceable despite Federal prohibition, protection of professional, occupational, driver’s licenses, parole, probation and pre-trial release programs, protection of access to state services, medical care, employment and contracting. Employers would be permitted to prohibit cannabis use and intoxication on the job, and of course cannabis DWI or use in a moving vehicle would remain prohibited.

Last but not least, existing medical cannabis dispensaries (ATCs) would be permitted to obtain “Dual-Use” licenses so long as they prioritize access for registered patients.

Good Public Policy vs Political Shenanigans

Now it’s early May 2023 and legalization proponents had lined up a majority of Senators to pass this legislation and send it to the governor for his approval. This was an example of good public policy supported by nearly three quarters of New Hampshire residents, according to a recent poll from the University of NH.

But Governor Sununu had other priorities than what was in the best interests of the residents of New Hampshire and set to work behind the scenes to twist this issue to his political advantage and that of his Party. He convened a meeting with three of the four Republican senators planning to support the measure and pressured them to change their vote with some combination of the usual threats of withholding committee chairmanships, preventing bills they favor from receiving a floor vote and/or withholding their access to Senate PAC and Republican Party re-election campaign funds.

At that time the Governor was strongly considering a run for the Republican presidential nomination, and he was concerned that having to take a stand for or against cannabis legalization would alienate him from either the law enforcement or libertarian Republican constituencies depending upon which position he took and whether he signed or vetoed a bill sent to him by the Legislature. So, it was best that it never reached his desk, and he took steps to assure that outcome.

Having succeeded in persuading these three senators to switch their votes, it was also important that the five-member Senate Judiciary Committee disapprove of the bill’s passage. So, it was arranged that one of the Republican senators on the committee favoring passage excuse himself from the committee on the day of the vote permitting Senate leadership to replace him with an anti-legalization stand-in assuring that the committee would vote against the legislation 3-2 ITL (Inexpedient to Legislate) rather than OTP (Ought to Pass).

Then the legalization bill was rejected by the full Senate the next day 14-10 rather than the 13-11 in favor that would have been the result without the governor’s and senate leadership’s intervention.

House leadership was furious with these shenanigans and threatened to attach their bill to already approved unrelated pending legislation up to and including the annual state budget but then in a breathtaking apparent 180º turnaround, the governor announced the following day that he would 100% support cannabis legalization in the next legislative session if it was “done right”, that is with a New Hampshire state monopoly on retail sales under the auspices of the State Liquor Commission.

One must assume that he had this in mind all along. Was his purpose to promote a policy and program that was best for New Hampshire? Not even remotely. Since he was not intending to run for re-election to a fifth (two-year) term he wanted to assure that the issue of cannabis legalization did not hinder the electoral prospects of any of his likely Republican successors (Chuck Morse, Kelly Ayotte, and Jeb Bradley) all of whom were on record in opposition to legalization. Be reminded that the year before, the University of NH published the results of a poll showing that 74% of New Hampshire residents were in favor of cannabis legalization. So, by introducing in the following year a state monopoly bill in the Senate that was rejected by common-sense legislators in both the previous and current years, he was angling to remove the issue from the upcoming campaign by either having a poorly-conceived bill approved, or blaming the Democrats and its other proponents for their failure to pass legalization when they had the chance.

The day following sabotaging passage of this reasonable legalization bill in the Senate after the House passed it by a 3-1 margin, the plan was for the Governor to suddenly pretend to reverse himself by announcing his support for a legalization framework that was patently illegal, dangerous and unworkable. He then rammed a bill through the Legislature creating a heavily-biased “NH Cannabis Study Commission” without any industry or public stakeholders as members with a mandate to study and create state monopoly model legislation that he and leadership knew could never be implemented unless and at least until Federal cannabis prohibition ended. The scheme included having the Senate then pass this stillborn contrivance in its next session and send it to the pro-legalization House forcing them to make a devil’s choice to either pass the legislation to the extreme chagrin of pro-cannabis stakeholders or reject it so Ms. Ayotte and Mr. Morse could claim not to be the ones opposing legalization and thereby neutralize the issue for the election.

In the midst of all this, it must be noted that the State Liquor Commission under the leadership of Commissioner Joe Mollica and his executive team had acquitted themselves with their standout professionalism, energy and devotion to the state’s best interests. Although they knew little at first about the cannabis industry, over the preceding 18 months they’d become well-informed by learning from stakeholders, visiting licensed operators in other states, studying the relevant issues and nuances and thoughtfully incorporating it all into their proposals. They did good work preparing themselves to be well qualified to regulate the state’s eventual program.

Legal Constraints of the State Monopoly Model

They also understood enough to know that state employees cannot be required to engage in violations of Federal law so they devised a workaround franchise model in which the Liquor Commission itself would not actually sell cannabis but franchise independent operators to do so with the rationale that the state would then not be required to defend those operators from possible Federal enforcement penalties and consequences.

With the tension between federal and state law, the cannabis industry is complicated and chaotic in many often-unforeseen ways. For example, the Commission as franchisor would be required to file what is known as a Franchise Disclosure Document (FDD) with the Federal Trade Commission subjecting them to federal jurisdiction, penalties and investigations. A criminal enterprise cannot offer franchises of its business model. Contrived legal firewalls notwithstanding, the State Liquor Commission’s position would be precarious and could easily become subject to serious anticipated and unanticipated legal risks and entanglements.

Claiming to not be directly involved in the business of selling cannabis because one is merely a franchisor is as prima facie absurd as McDonald’s claiming it’s not in the business of selling hamburgers because it has franchisees.

In 2017, a federal district court in Massachusetts dismissed a RICO case (Crimson Galleria Partnership, et.al vs. Healthy Pharms Inc, Century Bank, et.al.) against the bank on grounds that merely providing customary financial services to a cannabis state licensee (albeit operating in violation of federal law) did not rise to the level of direction in and control of the enterprise to implicate RICO liability as a co-defendant. This reasoning allows states to regulate cannabis industry operators as a customary government function so long as they are not substantially involved in the operation and direction of the business itself.

However, the franchise model proposed by the Liquor Commission envisions quite the opposite as they would be enforcing strict standards in almost every aspect of franchisee operations, direction and practices. Enacting this scheme could easily invite multiple RICO-based private litigations as well as public prosecution.

The Definitive Insider’s Guide to

New Hampshire Cannabis Legalization

History 2013 – 2025

Chapter Three

Cannabis Commission Collapse

Sometime after the “franchise model” was proposed by the Marijuana Study Commission, the Governor realized that he could bend it further to his political advantage by refusing to agree to establishment of more than 15 statewide retail dispensaries. These could then be primarily if not entirely awarded to his well-connected and wealthy cronies who would in turn be grateful for their exclusive, lucrative monopoly control and generously express that gratitude during the Governor’s next political campaign.

The Governor insisted that the primary motivation in now supporting cannabis legalization was “harm reduction” but not financial profit and building a new industry in New Hampshire that would bring considerable prosperity to its residents and encourage our young people to stay here after graduation and grow their professional careers and families in New Hampshire. The hypocrisy is if harm reduction is one’s primary purpose, why then insist that the Program will be limited to just 15 statewide retail locations? Clearly that would incentivize 90% of cannabis consumers to continue to buy wherever they currently do, mostly from the black market. He further insisted that each retail licensee be permitted up to 5 locations which encourages corruption by awarding monopoly licenses to as few as three political allies and excluding everyone else.

I emailed a copy of my November 14, 2023 newspaper column entitled “Cannabis and Hamburgers”. highlighting many of the foregoing points, along with additional related material to all roughly 500 New Hampshire policymakers (House and Senate), Governor’s Executive Council, AGs office, senior leadership of the NH Liquor Commission and the Bedford police chief (who was also a member of the Marijuana (Kangaroo) Study Commission). About 75% of the recipients returned ‘read receipts’ showing they opened the email.

The email highlighted the key takeaway from the column: “Let this column serve as a public notice to those who participate in enacting this legislation that they are exposing themselves and our state to potentially crippling and multiple criminal and civil penalties up to and including RICO charges and the federal seizure of state property and pension funds.”

On Monday, November 29^th the 14 members present at the final meeting of the Study Commission which was charged by the Legislature to study and report out state-monopoly model legislation voted 7-2 to not report out or recommend any legislation. Subsequently one New Hampshire Senator confirmed to me off-the-record that my email influenced the ultimate vote.

Apparently after reading the email, none of the Commission members wanted their fingerprints on this reckless, ill-conceived hot mess and they ran for cover. Unfortunately for Republican leadership, their scheme to insulate likely gubernatorial candidates Kelly Ayotte and Chuck Morse from the political liability of their opposition to cannabis legalization may have just gone up in smoke.

They would now be faced with the unattractive choice to either approve a common-sense, private enterprise-based legalization model as soon as the Legislature re-convened in early Spring 2024, hopefully defusing the issue for the next election cycle, or face their nightmare election scenario of the strong headwinds of New Hampshire voters overwhelming approval of full commercial legalization with Democratic gubernatorial candidates in favor of legalization and Republican gubernatorial candidates against.

The Governor and his leadership team’s primary miscalculation was in not understanding the unique challenges of the cannabis industry that has no modern equivalent. As a result of the tension between states’ legalization and prevailing federal prohibition, there are innumerable loose ends and foreseeable as well as unforeseeable consequences that arise constantly to bedevil even the savviest industry pioneers and insiders, specific examples of which I provided in the aforementioned email. Even as thoughtful and experienced as I and many of my colleagues are in this field, we are still often blindsided by unforeseen obstacles and restrictions that subvert otherwise well-considered plans. Our political leaders are utterly ill-equipped to enact cannabis industry policies that tread into such uncharted territory beyond the narrow legal path charted by other states that have implemented sustainable cannabis programs. The Study Commission also never called the New Hampshire Cannabis Association to testify or any of its available experts in regulation, business & finance (as the Commission bill required) so it’s hardly surprising there was no consensus built. This is further evidence there was never any intention to do so from its inception.

Frankly, a hybrid state monopoly commercial cannabis model with both state-owned and private enterprises operating side-by-side may be a pioneering and smart option and should perhaps be ultimately given some consideration but only following the end of federal prohibition. Requiring state employees to violate current federal law is reckless and thoughtless and effectively a non-starter, a truth which obviously was known from the outset by the Republican leaders who originally hatched this scheme.

New Hampshire House Makes Political Sausage

The full New Hampshire House voted on February 22, 2024 on a heavily compromised cannabis legalization bill intended to satisfy as closely as legally viable the Governor’s stated conditions for approval. It passed the House by a wide margin.

The legislation incorporated many of the restrictive, counterproductive conditions that both the Governor and some Senators had insisted upon, but it had also been frameworked to permit substantial flexibility over the next few years for reasonable improvement in formulating rules and regulations in line with market conditions. If passed by the Senate, it could be considered a modest first step towards common-sense cannabis commercial legalization.

The original plan from the Governor was for the State to exclusively sell cannabis in stores owned and operated by the NH Liquor Commission under a division titled NH Cannabis Commission. Both Liquor and Marijuana Study Commissions quickly realized that requiring state employees to violate Federal law by selling cannabis would subject both the Commission and the State to a wide range of potential legal and criminal risks that would render the program legally unviable and dead-on-arrival. Therefore, it proposed franchising third-party operators to run their stores for them, presuming that such would sufficiently distance themselves and the State from liability. Based upon many practical examples over the last decade of similar cannabis industry workaround schemes, such as the instance of numerous often clever attempts to circumvent MasterCard and Visa’s prohibition on the use of the products and systems for cannabis sales, this one had likewise no chance of even being implemented let alone being sustainable and additionally carried with it risks of endless private and public litigation, RICO lawsuits and criminal prosecutions.

As previously mentioned, I published a column in the Conway Daily Sun local newspaper in November 2023 entitled “Cannabis & Hamburgers” which pointed this out, then emailed all our legislators and other stakeholders both the article and additional materials warning against approving this proposal. This led to the Cannabis Study Commission promoted by the Governor to adjourn on November 29th without producing any result, partly due to the uncertainty generated by the alarms I raised.

Both I and my colleagues continued to repeat this alarm in committee testimony, documents and white papers submitted and meetings with policymakers such that finally it began to sink in that the franchise model, and any level of state control that mimicked a franchise model was legally unviable. The House Commerce committee now hit a brick wall and a devil’s choice – either pass the pending common-sense private enterprise bill co-sponsored by my local state rep Anita Burroughs certain in the knowledge that it would be again rejected by the Senate, or revise the bill along the lines of the discredited franchise model that would pass and be both worthless and dangerous but permit everyone to make the election claim that they approved cannabis legalization consistent with the opinion of 74% of NH residents, when in fact they had done nothing of the sort.

To break this impasse, I proposed we simply rename retail operators from “franchisees” to “licensed agents” or the equivalent, and reduce the day-to-day operational control envisioned by the franchise model sufficiently below its legal definition so as to avoid the attendant legal liabilities, while retaining as much of the state control as would pass legal muster. This simple solution was embraced by nearly all stakeholders and permitted the current revised version to go forward in the House Commerce committee by a vote of 17-3.

The bottom line was that proponents of the private enterprise model had acceded to every condition required by the Governor and conservative Senators that was legally viable.

It included immediately legalizing adults 21 years or older to possess, consume, use, display, obtain, purchase, process, produce, transport, or transfer to another adult without renumeration up to four ounces of cannabis flower or trim, ten grams of concentrate, including pre-filled vape cartridges and no more than 2000 mg of other cannabis concentrates.

Additionally, although this bill did not legalize home cultivation, purchase and possession of cannabis seeds will be legal.

Possession or transfer to minors as well as use while operating a motor vehicle and DWIs remained illegal and subject to substantial penalties. Public consumption was also prohibited, but the House Finance Committee accepted the ACLU’s suggestion that jail time should not be a penalty even for repeat offenders of the prohibition against public consumption.

After a New Hampshire Senate or House committee conducts hearings, meetings and modifies and reviews legislation, they vote to recommend to the full House or Senate that the bill either “Ought to Pass” (OTP) or is “Inexpedient to Legislate” (ITL). Neither the House nor Senate is obliged to follow this recommendation but in practice they generally do.

The House Commerce Committee rejected the discredited franchise model overwhelmingly OTP in favor of the more realistic and legally viable alternative model of ‘licensed agency’ retail stores.

Then the full House voted to approve the bill and send it to the House Finance Committee to finalize issues like taxes, fees, and allocation of funds to specific purposes and agencies, such as education, the state pension fund, drug and alcohol recovery, reduction of property taxes, etc. The Finance Committee then voted 6-3 ITL to again reject the franchise model.

However, advocates were now faced with the prospect of the House sending a non-franchise model bill to the Senate where public statements from several senators flatly stated it would be DOA. Faced with this impasse, the prime House sponsor of the agency store bill, Rep Erica Layon (R-Derry) burned the midnight oil and devised an inspired, last-minute amendment acceptable to the Senate.

Now if the Senate re-inserted the franchise model when it came to them for consideration, but if it could not be legally or practically implemented within two years of the bill’s passage, the newly established NH Cannabis Commission would automatically default to the original “licensed agency store” model so legalization would still be on track.

This amendment was then voted 8-1 OTP by the Finance I sub-committee, 19-6 OTP by the full Finance Committee, passed 239-136 by the full House on the following Thursday and headed over to the Senate.

Cannabis legalization proponents were cautiously optimistic that this bill now met all the Governor’s demands so New Hampshire could turn the corner and finally join the rest of New England in implementing a safe and prosperous legal cannabis market. Comment from key players at the time:

“Quite frankly I think it is time to vote on this bill and let the other body deal with it.”

–Rep. Erica Layon, prime sponsor of the House cannabis legalization bill

“The legislation passed today doesn’t get us there, but the Governor looks forward to working with the Senate to see if we can get it done.” —Gov. Chris Sununu’s office urging the Senate to work on the cannabis bill instead of declaring it “Dead on Arrival.”

The Definitive Insider’s Guide to

New Hampshire Cannabis Legalization

History 2013 – 2025

Chapter Four

New Hampshire Senate Meatgrinder

Once in the Senate, the masks all finally came off and Governor Sununu’s questionable devices and schemes surrounding the issue of cannabis legalization were now revealed for all to see.

After his Senate toadies tanked a fair and equitable legalization bill in 2023, the Governor famously announced the next day that although he was personally opposed, he believed it was inevitable and would be amenable to allowing it so long as it was “done right”. Turns out “done right” means an exclusive cannabis monopoly for a handful of his favored cronies and fat cat buddies and nothing for the rest of New Hampshire residents, including New Hampshire’s trailblazing four therapeutic cannabis licensees operating the seven heavily restricted and over-regulated medical dispensaries.

Almost immediately the hogs were lining up at the trough. One well-known Maine-based recreational dispensary teamed up with the NH Liquor Commission’s biggest landlord in an attempt to position themselves to snag up to three of the precious fifteen licenses to be awarded under the legislation passed by the Senate Judiciary Committee and headed to a vote by the full Senate.

As mentioned, the House bent over backwards in passing a bill trying to incorporate all the Governor’s nitpicking conditions into a still workable legalization framework, including a mechanism for attempting to implement his preferred but discredited and legally unviable ‘franchise store model’. This mechanism allowed the franchises to be downgraded to agency licenses in the event the franchise model collapsed under its own weight before being implemented, so at least New Hampshire still had a legalization framework to go forward with.

But this was not good enough for him and his Senate lickspittles. The provisions of what the Senate Judiciary committee passed feature something for everyone to dislike including jail time for 2^nd and subsequent acts of public consumption; current medical cannabis dispensaries were to have no better chance at any recreational cannabis retail licenses than anyone else, so as likely as not will be ultimately forced to go out of business while a new tax of 15% will be imposed upon them to be passed along to their patients. only fifteen retail licenses were to be awarded but an individual can own up to three, so potentially five fat cats could own and control the whole industry; home growing of any kind remained illegal; last but not least, the Cannabis Advisory Board which was empowered to advise the Liquor Commission to make rules and regulate and support the industry’s safety and prosperity, unlike in the House version, would be cut in half, no longer have representation from anyone outside the Governor’s circle of cronies and anti-legalization advocates and be empowered to instruct and make binding rules rather than simply advise.

Passing this monopoly takeover model would be a slap in the face to the residents of New Hampshire who support a decentralized industry and economic opportunity.

Legalization isn’t about the lack of supply or saving some time on one’s drive to a dispensary. It is about economic opportunity for the people, sorely needed in an age where inflation is pushing the cost of everything sky high, and incomes are static. The average home price in the state has increased to over $520,000 in four short years and the average two family income needed to afford a home shot up from mid-$80,000 to over $116,000.

Not surprisingly both pro-cannabis and anti-cannabis stakeholders were now united in the Senate and House to kill this inequitable and offensive bill.

Nevertheless, the Governor’s Republican toadies joined with most Democrats in the Senate to ignore and discard the approved but already highly compromised House bill to pass this replacement hot mess and send it back to the House daring them to reject it, which to their principled credit they did.

WWII military slang defines a ‘blivet’ as ten pounds of manure in a five-pound bag. This is a kind description of the cannabis legalization bill approved by the New Hampshire Senate and overwhelmingly rejected by the New Hampshire House which essentially proposed to create a state monopoly on retail adult-use cannabis sales for fat cats and cronies, excluding meaningful participation by both the people of New Hampshire and the existing medical cannabis Alternative Treatment Centers (ATCs). The two chambers agreed to try to find a compromise solution by convening a Committee of Conference to iron out their differences before the end of the 2024 legislative session.

Last Chance for Compromise

For the past couple months leading up to this point, I had transitioned my counter messaging both in print and directly with state legislators from “the franchise model is illegal, unviable and risky” to “it’s a cartel bill intended to benefit Republican fat cats and cronies”. In fact, I even published a column entitled “Cannabis Cronies and Fatcats”. At the same time, the leading Democratic candidate for governor had begun including this perspective in her regular campaign messaging.

In between Senate passage of their ‘cartel’ bill and the scheduled Committee of Conference meeting, the Governor expressed concern to one of his colleagues in the Senate that the ‘cartel’ messaging was gaining traction, and it might be best to adopt a more accommodating posture during the upcoming conference, and if possible find a compromise that didn’t impact his core concerns, and thus avoid the issue negatively impacting Republican prospects in the upcoming election.

Referring to the version passed by the Senate, Governor Sununu said: “They put some other stuff in there that I wasn’t necessarily looking for, but they’re not deal breakers.”

The “other stuff” he was referring to included: jailtime for 2^nd and subsequent convictions for public consumption including in-vehicle passenger consumption of edibles, a January 2026 effective date for legalization of private possession and consumption, no licensing preference for New Hampshire ATCs, 15% tax on medical cannabis sold by adult-use franchisees, and membership in the Cannabis Control Commission limited to regulators, law enforcement and legalization opponents.

The Senate redlines were limited to those expressly demanded by the Governor to earn his approval and signature, and included core provisions such as no more than 15 NH Liquor Commission-run franchised dispensaries, a ban on lobbying by franchisees, a cannabis control commission with the liquor commissioner as chair to promulgate rules and regulations, Liquor Commission control, licensing and enforcement of all aspects of the New Hampshire cannabis industry, a prohibition on home grow, a 15% fee on franchisee retail cannabis sales, prohibition on alcohol-infused cannabis products, restrictions on locations near schools, municipal opt-in required to locate a cannabis business in any city or town, limits on advertising, child-proof packaging, strict product labeling and warnings, product testing, one store limit per city or town except the larger cities of Nashua and Manchester, and prohibition of advertising or packaging that appeals to minors.

I then had a long telephone call with the Senator who had met with the Governor, who was also one of the Senate’s representatives to the conference committee and was able to determine the Senate’s exact negotiating position both in general and on specific provisions, and with his permission, briefed House leadership, including members of the House negotiating team.

Senate negotiators were prepared to bring “an open mind” to the conference committee regarding all this “other stuff” so long as none of the Governor’s redlines were not crossed. And yet knowing all this, the House negotiators on Tuesday meekly asked only to allow passengers holding cannabis patient cards to consume edibles while riding in a vehicle, that current NH medical cannabis operators receive token preference over other states’ operators, and that cannabis decriminalization be increased from three-quarters to one ounce during the 18 months until legalization were to take effect, as well as crossing one of the Governor’s redlines pointlessly asking to reduce the retail tax from 15% to 12.5%.

Afterwards, the senators could barely contain their astonishment at how little the House side was asking for. The House’s pathetic performance can be summed up by these comments from Wednesday session: “Help us out here, Jeb, help us out. Come on.” —Rep. John Hunt (R-Rindge) to Senate President. Jeb Bradley (R-Wolfeboro) who quipped “I’m not here to get people to vote for it.”

Then on Wednesday, while the Senate negotiators reminded the House that the 15% tax amount was a redline and non-negotiable, the House side proposed to add one or two token cannabis industry experts to the Control Commission’s 13-member monopoly bloc rather than the 10 included in the original House bill, while taking away the ATC’s right to convert from non-profit to for-profit companies regardless of whether they received an adult-use franchise, a right which was already uncontroversially enshrined in the Senate bill.

One of the House negotiators stated that they were in touch with the ATCs and they were fine with what the House negotiators were doing, which is flatly contradicted by their chief spokesperson’s on-the-record statement: “I wouldn’t say we are “happy” with any of this”.

All the House negotiators had to do was ask for the “other stuff” and it would have been largely or entirely accepted on the Senate side. Without basis, they rationalized that afterwards they could fix these glaring defects the following year. How exactly were they planning to unwind and claw back a year later the $8,000,000 allocated to the NH Liquor Commission to establish the state-controlled program? What guarantee had they that the next year’s Senate or Governor would concur? They inexplicitly squandered their true window of opportunity to create something that could actually be ‘fixed’ and improved later consigning the people of New Hampshire and the ATCs to scrounge for crumbs. Good public policy demanded that the full House vote the following week to consign this ‘blivet’ of a bill to the dustbin of history.

Instead nearly all the pro-legalization folks (state reps, senators, advocates and lobbyists) were ready to settle for a ‘few coppers’ in their tin cup, and a sprinkling of crumbs (aka: ‘caved’) when it came time to stand up for opportunity, prosperity and safety for the people of New Hampshire and oppose the complete takeover of a whole new industry by a dozen or so fat cats and cronies and their enablers.

Fortunately, many members of the House relied on my guidance in messaging and policy on this issue and were awaiting my decision whether or not to support it. One of the Republican senators supporting the bill spent a half hour a couple days before the House vote in June urging me to make a statement in its favor. In fact, he and I texted each other on the subject well past midnight the night before the vote. Representatives from national cannabis advocacy groups likewise were vigorously lobbying me into the early evening.

I refused to support the bill and as a result it narrowly failed in the House, consigning it to the aforementioned dustbin.

What’s Next for 2025 and Beyond

Prior to the November 2024 election, State Rep Jared Sullivan (D-Grafton) sponsored two cannabis legalization bills for the upcoming 2025 legislative session, one simply legalizing personal possession and private consumption with penalties for public consumption if Kelly Ayotte (R) became our next governor, and the other legalizing and regulating commercial commerce via licensed private-sector operators if Joyce Craig (D) won. Since Ayotte won, who vehemently opposes legalization, the commercial commerce bill is DOA, but since the NH Senate went from 14-10 Republican to (a veto-proof) 16-8 Republican majority and is even more hostile to cannabis legalization than the current Senate, in Rep Sullivan’s words the likelihood of passing even simple personal consumption next year has gone from possible to “slim to none”.

Conventional wisdom was that since Kamala Harris (D-CA) and her VP nominee Tim Waltz (D-MN) both come from states with liberal commercial cannabis legalization and had come out strongly in favor of ending federal prohibition, the odds favored this happening even before the next election in 2026. Since they lost, prospects for legalization on a federal level seemed to dim. President Donald Trump has sent mixed messages on the issue with consensus opinion that he is relatively indifferent to the issue and although probably wouldn’t be inclined to sign any executive orders liberalizing prohibition, he would likely sign a legalization bill sent to him after approval by Congress. But with the Republicans holding majorities in both houses of Congress, there is less than an even chance such a bill would reach his desk during the upcoming congressional session.

Even opponents acknowledge that the momentum of cannabis legalization is now inevitable and is slowly but steadily growing into a mainstream industry despite the roadblocks and setbacks that have bedeviled the industry since its inception over a decade ago. Although currently stymied by local and federal restrictions, there is substantial expectation that while some avenues are closed for now, alternative opportunities present themselves.

First, there is the wild card of RFK Jr’s appointment as Health & Human Services secretary with jurisdiction over both the FDA and CDC. As a presidential candidate, RFK Jr stated his commitment to cannabis legalization “on day one” of his presidency. There’s a good chance he’ll get behind pushing for common sense federal legalization and so it could happen as early as before the end of 2025, although more likely in 2027. Such a development could effectively pressure New Hampshire to jump on the bandwagon, perhaps as early as 2027.

At the encouragement of the current Biden administration, the Drug Enforcement Agency (DEA) was well along a formal process to ‘re-schedule’ cannabis from Schedule 1 to Schedule 3 on its controlled substance list. That would move cannabis from being included along with heroin and methamphetamine as prohibited and dangerous drugs with no medical use to the same category as Tylenol with codeine, and able to be prescribed by physicians and dispensed by pharmacies. If that happens, within a few years, we could see 100+ NH pharmacies dispensing medical cannabis against physician prescriptions. However, re-scheduling now seems at an impasse, and it may require presidential intervention to move it along.

Last but not least, since the very earliest a commercial legalization bill could now become law in New Hampshire is in two years, and it would take at least another three years for agency rule-making, licensing and opening the first adult-use dispensaries, the currently operating but fledgling NH medical industry will enjoy at least five years of effective market exclusivity to try to grow and strengthen their operations.

Over the last couple years, the medical conditions that qualify for a NH cannabis patient card have greatly expanded to include chronic pain, general anxiety as well as anything else a licensed DEA prescriber (physicians, nurse practitioners, dentists, podiatrists, optometrists, neuropathologists and physician assistants from neighboring states) certifies will do the patient’s condition more benefit than harm. Currently there are about 16,000 registered cannabis patients in NH with a population of 1.4 million. With this expansion of qualifying conditions and adequate messaging, reaching a goal of 100,000 patients within the next couple of years becomes realistic and would dramatically improve this sector’s long-term viability.

Four bills are working their way through the legislature in 2025. One bill (HB301) sponsored by state rep Suzanne Vail (D-Nashua) will permit outdoor cultivation in greenhouses which will dramatically lower their production costs to be more competitive with legalized border states. Although Governor Sununu vetoed a similar bill this year for technical reasons, Ms. Vail is cautiously optimistic it can pass in 2025. Another bill (HB54) sponsored by state rep Wendy Thomas (D-Merrimack) would permit the medical dispensaries (ATCs) to convert to ‘for-profit’ status, allowing them greater access to capital and increased revenue. A third bill (HB51) also sponsored by Wendy Thomas would permit medical dispensaries to re-sell non-intoxicating, hemp-derived cannabinoids (e.g., CBD, CBG and CBN) in addition to that which they produce in-house, bringing their pricing more in line with unlicensed smoke shops, convenience stores and gas stations. The fourth bill (HB190) sponsored by state rep Heath Howard (D-Stafford) would increase purchasing and possession limits for registered patients from two ounces to four ounces. This would allow patients who have difficulty traveling to make fewer trips to dispensaries.

Currently, cannabis patients are required to visit a dispensary to obtain their medicine but upon the dispensary operators’ request, their regulating agency, New Hampshire Health and Human Services (NH HHS) can update the rules to permit patient delivery, dramatically increasing access and convenience.

So overall, prospects for progress on legalization are not as grim as they might have initially seemed, with substantial and multiple opportunities on the medical side.

Chapter Five

Cannabis and Guns

ATF Form 4473 — the Firearm Transaction Record — is a seven-page document that must be filled out whenever someone buys a firearm from a licensed firearm dealer. It asks questions including whether the buyer is addicted to drugs and is the actual buyer of the firearm.

Question 21f states: Are you an unlawful user of, or addicted to, marijuana or any depressant, stimulant, narcotic drug, or any other controlled substance? WARNING: The use or possession of marijuana remains unlawful under Federal law regardless of whether it has been legalized or decriminalized for medicinal or recreational purposes in the state where you reside.

Holding a valid state-issued cannabis patient registration card is considered prima facia evidence of such federally illegal use.

Lying on the form is a felony punishable by up to 10 years in prison. For being a user of unlawful drugs in possession of a firearm, the punishment is up to five years.

This obliges law-abiding citizens to choose either to retain their constitutionally protected second amendment rights OR use cannabis, even for legal medical purposes in their state of residence. Perhaps even worse, it tempts otherwise law-abiding citizens to commit a felony each time they exercise their constitutionally protected second amendment rights.

One path to resolving this apparently unconstitutional restriction is to await until and if federal cannabis prohibition is ended.

Another may be judicial relief from federal courts. Already several courts e.g., the 5^th Circuit Court of Appeals in New Orleans covering Louisiana, Mississippi and Texas and the 10^th Circuit in Denver covering Oklahoma, Kansas, New Mexico, Colorado, Wyoming and Utah have determined this provision to be unconstitutional, but their jurisdiction is regionally limited, and their decisions are subject to government appeal all the way to the Supreme Court. As a practical matter, federal prohibition may be over before the appeal process is concluded.

However, there is a third more immediate solution no-one has yet considered that could resolve this issue for New Hampshire medical cannabis cardholders. Since there’s slim to no chance that recreational cannabis sales will be legal in New Hampshire for at least the next five years, this would have an outsized impact here in our state.

There is an amendment attached to the federal budget renewed annually every year since 2014 called Rohrabacher–Farr that prohibits the US Department of Justice (and by extension any of its bureaus and agencies) from interfering with state medical cannabis programs, to wit: “None of the funds made available in this Act to the Department of Justice may be used, with respect to the States of AL, AK, AR, CA, CO, CT, DE, DC, FL, HI, IL, IA, KY, ME, MD, MA, MI, MN, MS, MO, MT, NV, NH, NJ, NM, OR, RI, SC, TN, UT VT, WA and WI, to prevent such States from implementing their own State laws that authorize the use, distribution, possession, or cultivation of medical marijuana.”

Concord could pass a revision to our current medical cannabis statute RSA 126-X with language along the lines of: “Registered New Hampshire cannabis patients who use, distribute, possess or cultivate medical marijuana under New Hampshire’s therapeutic cannabis program (TCP) may purchase, possess and transfer firearms in accordance with New Hampshire law”.

The effect would be that the US DOJ, their bureaus Alcohol, Tobacco, Firearms & Explosives (ATF) and Drug Enforcement Agency (DEA) would be barred from interfering with any of the provisions of our state’s medical cannabis program, now including registered medical cannabis patients exercising their second amendment rights. Of course, just as with state medical cannabis programs, doing so would still violate federal law, but the DOJ, ATF and DEA would be powerless to enforce their probably unconstitutional restrictions.

Following the completion of ongoing rigorous due diligence and careful legal research this summer, legislation to achieve this goal could be introduced in Concord in the Fall and will likely attract substantial support and sponsorship from across the political spectrum.

Nathanial Gurien

I know what it’s like to be a rebel industry pioneering entrepreneur. It’s been a central part of my character for the last 50 years. I’ve operated many small to medium size innovative & disruptive companies. I’ve had decades of experience with sales, vertical integration, marketing, HR, negotiation, advertising, campaigning, e-commerce, warehousing, international & domestic trade as well as with attorneys, accountants, bankers, designers, politicians, financiers, investors, government officials, lenders, activists, merchants, builders, etc.

I find simple innovative solutions to complicated and seemingly intractable challenges. I set goals and achieve via meticulous strategic and tactical planning and execution

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