STATE OF MICHIGAN

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

MARIJUANA REGULATORY AGENCY

In the Matter of

The House of Mary Jane, LLC CMP No.: 21-000693

ERG No.: 000421
License No.: PC-000102
ENF No.: 21-00280
_______________________________/

FORMAL COMPLAINT

The Marijuana Regulatory Agency (“Complainant”) files this formal complaint

against The House of Mary Jane, LLC (“Respondent”) alleging upon information and
belief as follows:

1. The Marijuana Regulatory Agency (MRA) is authorized under the Medical

Marihuana Facilities Licensing Act (MMFLA), MCL 333.27101 et seq., and Executive
Reorganization Order No.2019-2, MCL 333.27001, to investigate alleged violations of the
MMFLA and the administrative rules promulgated thereunder, take disciplinary action to
prevent such violations, and impose fines and other sanctions against applicants and
licensees that violate the MMFLA or administrative rules.

2. Section 402(12) of the MMFLA provides that the expiration of a license does not
terminate the MRA’s authority to impose sanctions on the license.

3. Section 206(c) of the MMFLA provides that the administrative rules must ensure
the health, safety, and security of the public and integrity of the marihuana facility
operations.

4. Respondent’s conduct as described below is a risk to public health and safety

and/or the integrity of marihuana facility operations.

MARIJUANA REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/MRA
LARA is an equal opportunity employer/program
Formal Complaint
ENF No.: 21-00280 Page 1 of 7
MRA 5039
 FACTUAL ALLEGATIONS AND INTENDED ACTION OF THE MRA

5. Respondent holds an active state operating license under the MMFLA to operate
a medical marihuana provisioning center facility in the state of Michigan.

6. Respondent operated at 19154 James Couzens Fwy., Detroit, Michigan 48235, at

all times relevant to this complaint.

7. Following an investigation, the MRA determined that Respondent violated the

MMFLA and/or administrative rules promulgated thereunder as set forth below:

a. On May 19, 2021, the MRA conducted a compliance visit at Respondent’s

provisioning center facility.
b. The MRA observed multiple bags, backpacks, and duffle bags of marijuana
products that did not have the tracking identification numbers assigned by
the statewide monitoring system (METRC) attached.
c. Respondent was told none of the products that were without METRC tags
could be sold or destroyed until the investigation was completed and
guidance was given by the MRA. The MRA also requested Respondent
provide the 30 days of video surveillance coverage required by
administrative rule.
d. During the compliance visit, the MRA was able to view 30 days of
surveillance recordings on the provisioning center’s surveillance system.
e. Respondent is in violation of Mich Admin Codes, R 420.210(1) & R
420.210(2), which state except for designated consumption establishments
or temporary marihuana events licensed under the Michigan regulation and
taxation of marihuana act, a marihuana business must not have marihuana
products that are not identified and recorded in the statewide monitoring
system pursuant to these rules. A licensee shall not transfer or sell a
marihuana product that is not identified in the statewide monitoring system
MARIJUANA REGULATORY AGENCY
2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/MRA
LARA is an equal opportunity employer/program
Formal Complaint
ENF No.: 21-00280 Page 2 of 7
MRA 5039
 pursuant to these rules. And a marihuana business must not have any
marihuana product without a batch number or identification tag or label
pursuant to these rules. A licensee shall immediately tag, identify, or record
as part of a batch in the statewide monitoring system any marihuana
product as provided in these rules.
f. Respondent possessing untagged marijuana products at the facility is also
a violation of Mich Admin Code, R 420.505(2), which states a marihuana
sales location shall enter all transactions, current inventory, and other
information required by these rules in the statewide monitoring system in
compliance with the acts and these rules. The marihuana sales location
shall maintain appropriate records of all sales or transfers under the acts
and these rules and make them available to the agency upon request.
g. Finally, Respondent is in violation of Mich Admin Code, R 420.111(4)(b),
which states a provisioning center shall enter all transactions, current
inventory, and other information into the statewide monitoring system as
required in the medical marihuana facilities licensing act, these rules, and
the marihuana tracking act.
h. Respondent was not able to provide the 30 days of video surveillance as
requested by the MRA. Respondent is in violation of Mich Admin Codes, R
420.209(11) & R 420.209(12), which state a licensee shall keep surveillance
recordings for a minimum of 30 days, except in instances of investigation or
inspection by the agency in which case the licensee shall retain the
recordings until the time as the agency notifies the licensee that the
recordings may be destroyed. And surveillance recordings of the licensee
are subject to inspection by the agency and must be kept in a manner that
allows the agency to view and obtain copies of the recordings at the
marihuana business immediately upon request. The licensee shall also
send or otherwise provide copies of the recordings to the agency upon
request within the time specified by the agency.
i. The MRA requested the video management system log, after Respondent
could not provide the required footage and alleged a third-party vendor
MARIJUANA REGULATORY AGENCY
2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/MRA
LARA is an equal opportunity employer/program
Formal Complaint
ENF No.: 21-00280 Page 3 of 7
MRA 5039
 deleted the video back up. The log failed to identify the employee(s)
responsible for monitoring the video surveillance system and lacked the
identity of anyone removing or destroying recordings. Respondent is in
violation of Mich Admin Codes, R 420.209(14)(a-c), which state a licensee
shall maintain a log of the recordings, which includes all of the following: (a)
The identities of the employee or employees responsible for monitoring the
video surveillance system. (b) The identity of the employee who removed
the recording from the video surveillance system storage device and the
time and date removed. (c) The identity of the employee who destroyed any
recording.
j. On May 25, 2021, the MRA returned to the provisioning center facility and
inquired about the untagged marijuana products. Respondent had some
products remaining in a safe but destroyed the remaining marijuana
products with motor oil and had Waste Management remove the destroyed
products. Video surveillance recordings of the product destruction was
requested as required and not provided by Respondent.
k. Respondent is in violation of Mich Admin Code, R 420.209(6)(vii), which
states a licensee shall ensure the video surveillance system covers
anywhere marihuana or marihuana products are destroyed.
l. Respondent is also in violation of Mich Admin Codes, R 420.211(4) & R
420.211(8), which state a marihuana product rendered unusable and
unrecognizable and, therefore, considered waste, and marihuana plant
waste must be recorded in the statewide monitoring system. And a licensee
shall maintain accurate and comprehensive records regarding marihuana
product waste, and marihuana plant waste that accounts for, reconciles,
and evidences all waste activity related to the disposal. The agency may
publish guidance on marihuana product waste management.

THEREFORE, based on the above, the MRA gives notice of its intent to impose fines
and/or other sanctions against Respondent’s license, which may include the suspension,
revocation, restriction, and/or refusal to renew Respondent’s license.
MARIJUANA REGULATORY AGENCY
2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/MRA
LARA is an equal opportunity employer/program
Formal Complaint
ENF No.: 21-00280 Page 4 of 7
MRA 5039
 Under MCL 333.27407(4) and Mich Admin Code, R 420.704(2), any party aggrieved
by an action of the MRA suspending, revoking, restricting, or refusing to renew a license,
or imposing a fine, shall be given a hearing upon request. A request for a hearing must
be submitted to the MRA in writing within 21 days after service of this complaint. Notice
served by certified mail is considered complete on the business day following the date of
the mailing.
Respondent also has the right to request a compliance conference under Mich Admin
Code, R 420.704(1) A compliance conference is an informal meeting at which
Respondent has the opportunity to discuss the allegations in this complaint and
demonstrate compliance under the MMFLA and/or the administrative rules. A compliance
conference request must be submitted to the MRA in writing.
Hearing and compliance conference requests must be submitted in writing by one of
the following methods:

By Mail: Department of Licensing & Regulatory Affairs

Marijuana Regulatory Agency
P.O. Box 30205
Lansing, Michigan 48909

In Person: Department of Licensing & Regulatory Affairs

Marijuana Regulatory Agency
2407 North Grand River
Lansing, Michigan 48906

By Email: [email protected]

If Respondent fails to timely respond to this formal complaint, a contested case

hearing will be scheduled to resolve this matter.
Questions about this complaint should be directed to the Marijuana Regulatory
Agency at (517) 284-8599 or [email protected].

MARIJUANA REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/MRA
LARA is an equal opportunity employer/program
Formal Complaint
ENF No.: 21-00280 Page 5 of 7
MRA 5039
 Digitally signed by Claire
Claire Patterson
12/22/2021 Patterson Date: 2021.12.22 09:49:45
Dated: _______________ By: _______________________________
-05'00'

Claire Patterson, Manager

Scientific and Legal Section Manager
Enforcement Division
Marijuana Regulatory Agency

MARIJUANA REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/MRA
LARA is an equal opportunity employer/program
Formal Complaint
ENF No.: 21-00280 Page 6 of 7
MRA 5039
In the Matter of

The House of Mary Jane, LLC CMP No.: 21-000693

ERG No.: 000421
License No.: PC-000102
ENF No.: 21-00280
_______________________________/

PROOF OF SERVICE
12/22/2021
I hereby certify that on ________________________________, I mailed a copy of the
12/22/2021
Formal Complaint dated ____________________________ in the above captioned case

by certified mail (return receipt requested) to:

The House of Mary Jane, LLC

19154 James Couzens
Detroit, Michigan 48235

With a copy to:

Markwei Boye
5306 Kingsfield Dr.
West Bloomfield, Michigan 48322-2036

Digitally signed by: Abby Rae Brooks

Abby Rae DN: CN = Abby Rae Brooks email =

[email protected] C = US O =

Brooks
Marijuana Regulatory Agency OU = Scientific
and Legal Section
Date: 2021.12.22 10:03:53 -05'00'

Abby Rae Brooks

Departmental Technician
Marijuana Regulatory Agency
Department of Licensing & Regulatory
Affairs

MARIJUANA REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/MRA
LARA is an equal opportunity employer/program
Formal Complaint
ENF No.: 21-00280 Page 7 of 7
MRA 5039