DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO Case No.

2014cv48 Division/Courtroom: 409 __________________________________________________________________________ Cannabis University, Plaintiff vs. Metropolitan Football Stadium District, PDB Sports, and Stadium Management Company, Defendants Attorneys for Defendants: DanielM. Reilly, # 11468, Caleb Durling, # 39253, REILLY POZNER LLP 1900 Sixteenth Street, Suite 1700 Denver, Colorado 80202 Phone Number: 303-893-6100 Fax Number: 303-893-6110 ______________________________________________________________________________ AMENDED COMPLAINT: CLAIMS FOR RELIEF WITH PLEAS FOR ENTRANCE TO THE COURT AND FOR DAMAGES and FINES ______________________________________________________________________________ ! COMES NOW the Plaintiff, Cannabis University, and submits to the Court an

amended Complaint, also served by process to the Defendants, in order to conform with this Courts Rules and the Defendants complaints in their Motion to Dismiss this case. The Plaintiff begs the Court, as is their power, to allow Michelle L. LaMay to represent her business and begs the Court to proceed with signing the Order for the MOTION FOR DECLARATORY JUDGEMENT IN A SPECIAL MATTER FED R.CIV R.9 and R.17(3), presented to the Court February 26, 2014.

JURISDICTION & VENUE

1. This Court has jurisdiction over this action pursuant to 28 U.S.C. 1331 and 1343(3)(4) for

federal constitutional claims; and supplemental jurisdiction under 28 U.S.C. 1367 for state law tort claims. This Court is authorized to grant the relief requested herein pursuant to 28 U.S.C. 2201(a). 2. The venue is proper in the 2nd Judicial District Court of Colorado pursuant to 28 U.S.C.1391. 3. Cannabis University resides in Denver, Colorado, and submits Exhibit A: Colorado business registration and Exhibit B: Colorado Secretary of State Certificate of Good Standing.

4. The two incidents at issue in this complaint occurred the mornings January 12, 2014 and January19, 2014 at Metropolitan Football Stadium District owned, and lessees PDB Sports and Stadium Management Company managed, Sports Authority Field, 1701 Bryant St, Denver, CO 80204, in and outside parking lot C, a public place as defined by Block v. Westminster Mall Company, 819 P.2d 55 (1991). In the instance of this complaint, the property is owned by the public, and leased to PDB Sports and Stadium Management Company. MFSD lease between them is Exhibit C.

5. Colorado law protects other businesses [in agriculture] in order to, for example eliminate unfair competition, C.R.S. 35-28-106(e) (2013). Violations to a marketing order result in claims for relief in District Courts: C.R.S. 35-28-116(6) (2013).

6. This Amended Complaint is filed within the time limit required to amend or answer or reply to the Defendants.
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1st Claim for Relief Common Law Torte of Business Disparagement

Plaintiff begs the Court to apply the common law torte of business disparagement to this dispute and determine the following: 1. that the Defendants knowingly and maliciously published false, disparaging statements to the Denver Police because of the use of the word cannabis in Cannabis Universitys logo/ advertising display, Exhibit B, on the ticket holders motor home Exhibit E. The Defendants request to forcibly evict the legal ticket holders vehicle from their property were false, and malicious accusations based on a stated prejudice against cannabis, Texas Beef Group v. Winfrey, 201 F.3d, 680 (5th Cir.2000); 2) that the Defendants statements to law enforcement of January 12 and January 19, 2014 were "of and concerning" Cannabis Universitys specific property, trademarked advertising display, Exhibit E, previously presented to this Court January 29, 2014, Texas Beef Group v. Winfrey, 201 F.3d, 680 (5th Cir.2000); 3. that the Defendants statements to law enforcement of January 12 and January 19, 2014 were made with knowledge of the falsity of the disparaging statement, and with spite, ill will, and evil motive, Texas Beef Group v. Winfrey, 201 F.3d, 680 (5th Cir.2000); and with actual malice, defined as with knowledge that it was false or with reckless disregard of whether it was false or not, in New York Times Co. v. Sullivan, 376 U.S. 254 (1964). The Plaintiff submits that the Denver 911 archives will reveal that the Defendants acted maliciously when they called law
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enforcement to enforce their criminal policy, should the Court find it necessary to subpoena them; 4. and that the evidence of the Defendants disparaging statements to law enforcement of January 12 and January 19, 2014, plays an ongoing substantial and direct part in inducing specific damage, Texas Beef Group v. Winfrey, 201 F.3d, 680 (5th Cir.2000), by wielding their power and wealth to suppress all communications containing the word cannabis from a public place. Communications constituting business disparagement are not directed at an individual's personal reputation; rather, they are injurious falsehoods that are aimed at the business's goods or services, Aetna Cas. & Sur. Co. v. Centennial Ins. Co., 838 F.2d 346, 351 (9th Cir.1988).

The Plaintiff begs the Court to apply the common law torte of business disparagement to

this dispute and asserts that the facts and circumstances are pro se and such that they point to 1) the Plaintiff as the business concerning whom the disparaging statements were made; and that 2) every listener did not have to understand the disparaging statements to refer to the individual Plaintiff as long as there are some who reasonably do, from which the damage to cannabis and to the legal business, Cannabis University, and to all legal cannabis businesses, arises. Not only has the Plaintiff incurred the direct intellectual damage to its business interests, the value of which can not, nor need not be determined by this Court on the occasions in this dispute, but the malicious business policy of the Defendants effects all legal Colorado cannabis growers, manufacturers and sellers, COLO. REV. STAT. ANN. (Criminal) Sect. 35-31-101, at all future Denver Broncos home games.

2nd Claim for Relief

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Defendants Criminal Violation of COLO. REV. STAT. ANN. (Criminal) Sect. 35-31-101
! The Evidence presented to this Court and incorporated into this Amended Complaint is

pro se proof of the Defendants violation of COLO. REV. STAT. ANN. (Criminal) Sect. 35-31-101: It is unlawful for any person, rm, partnership, association, or corporation or any servant, agent, employee, or ofcer thereof to destroy or cause to be destroyed, or to permit to decay or to become unt for use or consumption, or to take, send, or cause to be transported out of this state so to be destroyed or permitted to decay, or knowingly to make any materially false statement, for the purpose of maintaining prices or establishing higher prices for the same, or for the purpose of limiting or diminishing the quantity thereof available for market, or for the purpose of procuring, or aiding in procuring, or establishing, or maintaining a monopoly in such articles or products, or for the purpose of in any manner restraining trade, any fruits, vegetables, grain, meats, or other articles or products ordinarily grown, raised, produced, or used in any manner or to any extent as food for human beings or for domestic animal. 1. Cannabis is raised and produced and used in many manners and as an ingredient in food for human beings and a regulated product in Colorado subject to the Statutes and Department of Revue Rules and Regulations:

Applicability
On July 1, 2010, a person who is operating an established, locally approved business for the purpose of cultivation, manufacture, or sale of medical marijuana or medical marijuana-infused products or a person who has applied to a local government to operate a locally approved business for the purpose of cultivation, manufacture, or sale of medical marijuana

or medical marijuana-infused products which is subsequently granted may continue to operate that business in accordance with any applicable state or local laws. "Established", as used in this paragraph (a), shall mean owning or leasing a space with a storefront and remitting sales taxes in a timely manner on retail sales of the business as required pursuant to section 39-26-105, C.R.S., as well as any applicable local sales tax, 12-43.3-103(1) (a); and regulating a product for human consumption: R 602 Retail Marijuana Products Manufacturing Facility: General Limitations or Prohibited Acts G. Adequate Care of Perishable Product. A Retail Marijuana Products Manufacturing Facility must provide adequate refrigeration for perishable Retail Marijuana Product that will be consumed and shall utilize adequate storage facilities and transport methods. R 604 Health and Safety Regulations: Retail Marijuana Products Manufacturing Facility A. Training 1. Prior to engaging in the manufacture of any Edible Retail Marijuana Product each Owner or Occupational Licensee must: a. Have a currently valid ServSafe Food Handler Certificate obtained through the successful completion of an online assessment or print exam; or b. Take a food safety course that includes basic food handling training and is comparable to, or is a course given by, the Colorado State University extension service or a state, county, or district public health agency, and must maintain a status of good standing in accordance with the course requirements, including attending any additional classes if necessary. Any

course taken pursuant to this rule must last at least two hours and cover the following subjects: i. Causes of foodborne illness, highly susceptible populations and worker illness; ii. Personal hygiene and food handling practices; iii. Approved sources of food; iv. Potentially hazardous foods and food temperatures; v. Sanitization and chemical use; and vi. Emergency procedures (fire, flood, sewer backup). 2. A Retail Marijuana Products Manufacturing Facility must obtain documentation evidencing that each Owner and each Occupational Licensee has successfully completed the examination or course required by this rule and is in good standing. A copy of the documentation must be kept on file at any Licensed Premises where that Owner or Occupational Licensee is engaged in the manufacturing of an Edible Retail Marijuana Product. B. General Standards 1. A Retail Marijuana Products Manufacturing Facility may be subject to inspection by the local fire department, building inspector, or code enforcement officer to confirm that no health or safety concerns are present. The inspection could result in additional specific standards to meet local jurisdiction restrictions related to Retail Marijuana. An annual fire safety inspection may result in the required installation of fire suppression devices, or other means necessary for adequate fire safety. 2. A Retail Marijuana Products Manufacturing Facility that manufacturers edible Retail Marijuana Product shall comply with all kitchen-related health and safety
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standards of the relevant local jurisdiction and, to the extent applicable, with all Colorado Department of Public Health and Environment health and safety regulations applicable to retail food establishments, as set forth in 6 CCR 1010-2. C. General Sanitary Requirements. The Licensee shall take all reasonable measures and precautions to ensure the following: 1. That any person who, by medical examination or supervisory observation, is shown to have, or appears to have, an illness, open lesion, including boils, sores, or infected wounds, or any other abnormal source of microbial contamination for whom there is a reasonable possibility of contact with preparation surfaces for Retail Marijuana or Retail Marijuana Product shall be excluded from any operations which may be expected to result in such contamination until the condition is corrected; 2. That hand-washing facilities shall be adequate and convenient and be furnished with running water at a suitable temperature. Hand-washing facilities shall be located in the Licensed Premises and/or in Retail Marijuana Product preparation areas and where good sanitary practices require employees to wash and/or sanitize their hands, and provide effective hand-cleaning and sanitizing preparations and sanitary towel service or suitable drying devices; 3. That all persons working in direct contact with preparation of Retail Marijuana or Retail Marijuana Product shall conform to hygienic practices while on duty... 1 CCR 212-2(R 602)(R 604) RETAIL MARIJUANA CODE.

Summary of Claims for Relief #1 & #2

!
The Defendants did knowingly and maliciously use the word cannabis in the Cannabis

University logo/advertising display, Exhibit B, previously presented to this Court, on the ticket holders motor home, Exhibit E, previously presented to this Court, to forcibly and maliciously evict the legal ticket holder and owner of the motor home from their property by calling the Denver Police, not once, but twice, and on each occasion, making to law enforcement false and malicious accusations based on a stated prejudice against a Colorado food product,
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cannabis, for the purpose of restraining the Plaintiffs trade, which is sole the objective of Cannabis Universitys permanent advertising display on the ticket holders motor home, which breaks no law and evidence presented to this Court shows many other vehicles in Parking Lot C on July 12, 2014 that bear an advertising display/logo with impunity, Exhibit H. ! The Plaintiff begs the Court not allow the Defendants to continue enforcement of a

malicious business practice that targets and creates a special class, cannabis, and to consider the above Claims for Relief and the supporting case law and criminal law; all the exhibits previously presented to this Court, Exhibits A through K as pro se proof of malicious disparagement of the Plaintiff; and the criminal violation of COLO. REV. STAT. ANN. (Criminal) Sect. 35-31-101 by the Defendants and incorporate all the above into this amended Complaint. PLEAS FOR ENTRANCE TO THE COURT AND SPECIAL DAMAGES and FINES ! 1. The Plaintiff begs the Court, as is their power, to allow Michelle L. LaMay to represent

her business and begs the Court to proceed with the Order for the MOTION FOR DECLARATORY JUDGEMENT IN A SPECIAL MATTER FED R.CIV R.9 and R.17(3), presented to the Court February 26, 2014. 2. From Exhibit K, Governor Hickenloopers Amendment 64 and Proposition AA Implementation Budget Request of February 18, 2014, page 8 and 9, the cannabis industry revenue from the sale of cannabis in 2014-15 can be projected to be $957,658,586.00.

3. The Plaintiff seeks presumptive special damages, and all costs incurred by the Plaintiff for bringing this Complaint and Amended Complaint and punitive damages as the Court would

determine which this Court has the power to award and fine, in the amount of .001% of one years projected revenue from the sale of medical and retail cannabis in the amount of $957,658.00. Dated this 5th day of March, 2014.

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