Organizations

04/17/19 Rick Doblin

Program
Century of Lies
Date
Guest
Rick Doblin
Organization
MAPS

This week on Century of Lies we speak with Arnold Diehl from Floridians For Freedom about their marijuana legalization initiative; with Bryan Krumm, NP, about medicinal cannabis and PTSD; and with Rick Doblin, PhD, executive director and founder of MAPS, about psychedelics, medical cannabis, and drug policy reform.

Audio file

TRANSCRIPT

CENTURY OF LIES

APRIL 10, 2019

DEAN BECKER: The failure of drug war is glaringly obvious to judges, cops, wardens, prosecutors, and millions more now calling for decriminalization, legalization, the end of prohibition. Let us investigate the Century Of Lies.

DOUG MCVAY: Hello, and welcome to Century of Lies. I'm your host Doug McVay, editor of DrugWarFacts.org.

Later in the show we're going to have a conversation with Rick Doblin, PhD, he's the founder and executive director of the Multidisciplinary Association for Psychedelic Studies, or MAPS.

But first, in the state of Florida there is an initiative petition circulating that would put a marijuana legalization measure up for a statewide vote. I spoke with one of the folks working on that measure, Arnold Diehl.

Could you tell me about Floridians for Freedom?

ARNOLD DIEHL: Floridians for Freedom's a ballot initiative, trying to get cannabis legalized and on the ballot the way it should be. Not like any other state has legalized it, because I believe if there's regulation, it's not legal. It's regulated. And that means somebody could break a regulation and go to jail.

What we believe is that this plant should be given back to you as a human right, and the only thing our initiative allows the government to regulate is the buying and selling of it. So if you grow extra tomatoes in your back yard, you can give them to your neighbor, as long as you don't charge anybody and kept them out of their taxes.

This plant is healthier and safer than most vegetables, and that's, so many people need it, this is the only way we're going to get affordable healthcare is let people just have this plant back, and man's greed has been stopping that.

We have until February 2020 to get seven hundred and some thousand signatures to get it on the ballot. We've been trying for several years, and we can keep on going. At least, I've got to say that I feel good that we're standing for what's right. Even if some of the other initiatives get backing and money from big business, there's still the shining light of what -- how it really should be.

This plant should be given back to the people first, and let business take care of itself later.

DOUG MCVAY: Talk to me more about this initiative. How did you get the idea, why did you decide to start it?

ARNOLD DIEHL: Well, it's kind of something that Florida Cannabis Action Network has gotten together. We really started it, like, five years ago, four or five years ago it was first initially thought of, and brought about.

And we've been trying to get the signatures but it's very difficult to do it grassroots, where it's just, you know, a core of twenty to fifty people in the state trying to, you know, get signatures and go to groups and organizations, and, it's difficult to get the signatures that way.

But like I said, there's some amendments out there that are trying to get on the ballot that maybe are a little bit more money behind them. They're using the fact that ours is the best one to bring the people in, so, maybe that will help us.

DOUG MCVAY: Well, hopefully so, I mean, I know it's -- I know at OMI, back in the Eighties, we had to pay petitioners, but we were paying by the signature, so a person could go out -- well, at the time it was twenty-five cents, fifty cents, maybe even a dollar, and, but that was the Eighties, right?

ARNOLD DIEHL: Right.

DOUG MCVAY: And we had, we did all that stuff to try and, but we also had a lot of volunteers, and, you know, and professional is -- professionals are good, but, it, I hate to say it --

ARNOLD DIEHL: That's all we have is volunteers. And, there's not as many of those. We need more.

DOUG MCVAY: Well, hopefully folks will -- hopefully folks in Florida listening to this will check out FloridiansForFreedom.com and see how they can get involved. Can people just go to your website and print out copies and do that?

ARNOLD DIEHL: They can. They can, yes, there's a PDF there they can download, print out copies, it's one page. It's very simple. A hundred and nineteen words is all it is.

DOUG MCVAY: So all a person would have to do is have an internet connection and a printer. And they could make democracy happen.

ARNOLD DIEHL: They do need to be a registered voter in Florida for it to work for Florida, but you could still print it, no matter what state you're in, and promote it in your state also. It's the way it should be.

DOUG MCVAY: That was my interview with Arnold Diehl, he is with Floridians for Freedom, they're circulating an initiative petition to put up a ballot measure to legalize marijuana in the state of Florida. Find more information about them at FloridiansForFreedom.com.

BRYAN KRUMM, CNP: I'm Bryan Krumm, I'm a psychiatric nurse practitioner in Albuquerque, New Mexico. I specialize in the treatment of PTSD using cannabis and different dietary supplements.

I've found in my clinical practice that cannabis is really the only thing that's effective in treating all the different symptom clusters we see with PTSD, but by adding different types of dietary supplements to support the endocannabinoid system, I see far better clinical outcomes from my patients than with cannabis alone.

DOUG MCVAY: Talk to me about the Supreme Court.

BRYAN KRUMM, CNP: Okeh. Well, I have to go back to the start of this whole recent fiasco. So 2009, I filed a rescheduling petition with the DEA, demanding that they take cannabis out of schedule one. Said it can't be in schedule one because it has accepted medical use, I think there was like 21 states at that point.

After two lawsuits, seven years later, I had to sue them twice to get them to act on it, but the DEA finally settled that case. And it was also, there was another rescheduling petition that had been filed a year after mine by the governors of Washington and Rhode Island.

So they settled these rescheduling petitions, and they said they were going -- keeping cannabis in schedule one, but because of the FDA's report, they were forced to change their policies. So they were no longer allowed to keep blocking medical cannabis research, and they had to allow more people to grow cannabis for research purposes.

Well, Jeff Sessions stepped in as our new attorney general and told the head of the DEA, Chuck Rosenberg at that time, he was the one who settled the previous rescheduling petition with me, he told Chuck Rosenberg to keep sitting on all the new applications, don't do anything with them, and keep blocking the research.

So I filed a new rescheduling petition, citing the new report that had come out by the National Academies of Science, where they said there's conclusive evidence that cannabis is effective for treating pain. They are a government organization, conclusive evidence, it's not just the states saying this. Maybe they'll take heed.

But, the -- Chuck Rosenberg resigned not too long after I filed that. He said he doesn't trust the new administration to follow the law, so he got out of the Department of Justice entirely under Jeff Sessions.

They appointed a new head of the DEA, Robert Patterson, and after my petition had sat up there for six months I sent him out a nasty letter saying, look, you can either deny the petition, you can approve it, or you can forward it for review, but you don't get to just sit on them forever.

So he denied it. I filed a lawsuit against him, I filed in the court of appeals. After a couple back and forth filings with this thing, he decided he was going to resign as head of the DEA. He said he doesn't know enough about marijuana to be head of the DEA.

Well, the court of appeals ended up, the case had been assigned to a three judge panel, and two of those judges were George Bush judges and one was a Donald Trump judge. So, not surprisingly, they denied it.

I filed for a rehearing en banc, that was denied. That would have put it in front of the entire panel of judges up at the court of appeals. So now I'm appealing it up to the Supreme Court.

It's kind of a long shot, but, my argument is that typically, a government agency like the DEA, they're entitled to a certain amount of deference in their decision making processes. So the courts will defer to them and say, okeh, we understand your rationale, it's a reasonable rationale, we're going to let you do what you want to do.

My argument is that because the DEA only allows testimony from the FDA to be considered, and they only allow the FDA to review to consider phase three clinical trials when they do their reviews, and they block these phase three clinical trials from being done, that they're tampering with witnesses. They're acting as a RICO organization, ongoing criminal enterprise, and that they're tampering with witness testimony to get their way in the courts.

So they're not entitled to that deference that otherwise should be given to a government organization. So, we'll see where it's all going to go. It's a long shot, the Supreme Court doesn't usually take many of the cases that are appealed to them, and cases from a pro se defendant like myself puts me even further at a setback, but, I've got to try to get the truth out there some way, so ....

DOUG MCVAY: You spoke here at Patients Out of Time, we're of course at the Patients Out of Time Thirteenth National Clinical Conference on Cannabis Therapeutics. What are the key takeaways from your talk that you hope people caught?

BRYAN KRUMM, CNP: The talk just now, that was a panel discussion, just kind of talking about some of the potential adverse effects of cannabis.

What I'm hoping more is that people who heard my talk yesterday are going to understand more about how cannabis works in treating PTSD. They'll understand more about the dysfunctions of the endocannabinoid signalling that cause PTSD, and maybe have less stigma associated.

Even people without PTSD, there's always a huge stigma with this, where people will say, gosh, so something bad happened, why don't you just deal with it and get over it and move on? And that's not the way it works with PTSD. We have very real physiological changes in PTSD in the way that the body processes stress responses.

And to tell somebody with PTSD to just get over it and deal with it, and move on, that's like telling somebody with diabetes, oh, don't take your insulin, just eat the ice cream and get over it, and deal with it. It's like, no, that's not how it works. You have very real physiological changes in diabetes insulin is what works best to treat that. With PTSD, the only thing that's effective in treating those very real neurobiological changes is with cannabis.

DOUG MCVAY: Obviously all of these presentations are time limited. Is there anything that you wanted to get into your talk that you didn't, just didn't have time to get to?

BRYAN KRUMM, CNP: Oh, there's always more I want to talk about, but, that's just the way it is.

DOUG MCVAY: Anything that's at the top of the list, especially in the context of some of the other presentations, is there anything at the top of the list?

BRYAN KRUMM, CNP: Well, some of what we talked about yesterday with my PTSD thing, I got to address today in the other part. We were talking a little bit about cannabis and its role, supposed role, in causing psychosis, which, the, actually as a result of that last rescheduling petition the DEA had to admit that it doesn't.

But, it's still a huge misconception that marijuana causes people to become psychotic, and if you look at the evidence, that's just not true. People with schizophrenia who use cannabis have higher levels of executive function than the ones who have never used cannabis before who have schizophrenia.

And in my clinical experience, I've seen over and over with patients who have schizophrenia and also have co-occurring PTSD symptoms, which, it happens a lot, I mean, if you have schizophrenia, you're going to end up being in situations that could potentially become traumatic and damaging, so we see a lot of PTSD and psychotic disorders overlap with each other.

And cannabis really is effective at helping to tone down the paranoia for most of these patients. It helps to tone down the noises, it helps to keep the visual hallucinations from coming up. And, it actually has an impact on those negative symptoms, where anti-psychotic medications may help some of the positive symptoms, the hallucinations, things like that, it doesn't help the negative symptoms, the emotional numbing, the withdrawal.

And cannabis actually helps people with that emotional numbing, it makes it easier for people to get out, get around other people, to socialize.

So in the long run, I like that we got to address that, because we got to address the fact that, yeah, in spite of all these so-called research -- reports out there that say cannabis causes psychosis, in clinical practice it just doesn't look like that's as big an issue as it's been made out to be.

DOUG MCVAY: Do you have any closing thoughts for the listeners, and where can people find out more about you, the work you're doing, and of course the Supreme Court suit?

BRYAN KRUMM, CNP: Well, my website's probably the best place, HarmonyPsych.org, that's HarmonyPsych.org.

If you go in the patient information section there, I've got links to really good resources about medical cannabis, the first link actually takes you to a paper that I had published in the Nurse Practitioner Journal that looks really closely at what PTSD, talks about what happens in the brain and outside of the brain, and discusses why cannabis is so much more effective at treating PTSD than pharmaceuticals. They actually made me the 2017 Nurse Practitioner Journal Author of the Year for this article.

Also, all of the legal documents for this case are up on my website. The one going up to the Supreme Court I'm not quite done with yet, so that will go up once I get it all filed, but, it's in a section called My Argument For Legalization of Medical Cannabis.

Another section you can take a look at on there is the Harmony Treatment Algorithm for Psychiatric Wellness. It's got a lot of things that you can do on your own to really help support the endocannabinoid system, so that ultimately we can get cannabis working better for people.

DOUG MCVAY: Bryan Krumm, thank you so much. Thank you for all you're doing.

BRYAN KRUMM, CNP: You're welcome. Thank you.

DOUG MCVAY: That was my interview with Bryan Krumm, he's a psychiatric nurse practitioner out of New Mexico. We met up at the Patients Out of Time national clinical conference, which just finished down in Tampa, Florida. Full disclosure: I do some website and social media work for Patients Out of Time.

You're listening to Century of Lies. I'm your host Doug McVay, editor of DrugWarFacts.org.

Now, let's hear that conversation with Rick Doblin, PhD, executive director and founder of the Multidisciplinary Association for Psychedelic Studies, or MAPS.

All right, stranger, what's your name and where are you from?

RICK DOBLIN, PHD: Well, I'm Rick Doblin, and I'm from Boston. But I'm also from Sarasota, I lived here 17 years, and before that I was in Chicago, and who Rick Doblin is? I'm learning myself, still changing.

DOUG MCVAY: He's a psychedelic guy, can you tell? Rick Doblin, PhD, graduate of the Kennedy School of Government, let's see, where did you get your, was it psychology?

RICK DOBLIN, PHD: My masters -- no, no, public policy.

DOUG MCVAY: Public policy.

RICK DOBLIN, PHD: Well, see, so my undergraduate degree was at New College in Sarasota, and that was the one political battle I lost at New College. My major was actually transpersonal psychology and psychedelic research.

DOUG MCVAY: Stan Groff?

RICK DOBLIN, PHD: Yes.

DOUG MCVAY: Cool.

RICK DOBLIN, PHD: But, when they -- when I graduated, New College is all about making up your own majors, and I really did do that as my major, but they refused to let me do that because they didn't want anybody there coming to learn about psychedelics.

So I technically had to do all the psychology requirements, so I've got an undergraduate degree in psychology and then a masters and PhD from the Kennedy School in public policy.

DOUG MCVAY: I knew you had a psych degree in there somewhere.

RICK DOBLIN, PHD: Yeah. Yeah, yeah. And then, let me just say also, when I got my masters from the Kennedy School, from '88 to '90, those were the same two years that I was working with Stan Grof in holotropic breath work, and that's where I got certified in the first group of holotropic breath work practitioners, so I felt like I had this dual track, one was public policy, and one was -- one was the internal work, one was the external work.

DOUG MCVAY: Why did you first become interested in working on cannabis and cannabis issues?

RICK DOBLIN, PHD: Well, the first time I started working on it was, I needed a project for my masters thesis for what's called the policy analysis exercise. And it was a time when research was blocked with psychedelics, and also blocked with cannabis.

And I had done an undergraduate thesis as a follow up study to the Good Friday experiment that Tim Leary and Walter Pahnke had done at Harvard on whether psilocybin could be triggering mystical experiences.

So when I was looking for a project for my masters, I wanted to do something that -- beyond, well, I don't want to say marijuana's beyond psychedelics, but I wanted to do something with cannabis.

DOUG MCVAY: Other than.

RICK DOBLIN, PHD: Yeah, I wanted to contribute to this discussion about marijuana, and so because it wasn't possible to actually do marijuana research, I figured what I could do is survey oncologists about their attitudes of Marinol versus smoked marijuana for nausea control for cancer chemotherapy.

So, it turned out that that survey, of the Association -- American Association of Clinical Oncologists got so much PR, more than most any other policy analysis exercise in the history of the Kennedy School, because it came at a time where at least it was new information, but it wasn't actually administering cannabis.

And I also felt that there was a lot of change starting to happen with cannabis, I thought this could maybe contribute to getting it more available to patients.

DOUG MCVAY: So, you gave a talk here, at this thing, and, to the folks, and what are the things you hope people take away, aside from a satisfied feeling and a lot of food?

RICK DOBLIN, PHD: So, the first thing is that we need to end the NIDA monopoly. You know, and that the more that people can help out with that, the more that they can contact their Senators, their Representatives, particularly if they happen to be Republican, to get them to try to pressure this administration to end this monopoly sooner than the end of this year.

So that's the most important take away. The other take aways are, I wanted people to know that the FDA is open to making cannabis into a medicine. In plant form and other ways, that we need to really think about it as a viable strategy, and the other thing I -- people want to know is that we're making enormous progress with psychedelics, and turning them into FDA approved medicines.

The one thing I didn't say, but I think is also what a lot of people know, and I didn't say it partly because I don't have this powerpoint chart that I often use, but that medicalization leads to legalization.

And we see that in this chart, you've probably seen this chart of the Gallup Poll, of the attitudes of American voters towards marijuana legalization, starting from like 1968 to 2017, do you know that chart?

DOUG MCVAY: Yeah.

RICK DOBLIN, PHD: All right. And then there's like, basically, it goes up through the '70s, and then the parents movement, and then Nancy Reagan, the backlash, and then it's basically stable for about 20 years, and then it starts growing again when we start having medical marijuana states.

So I think people under -- want them to understand that medicalization leads to legalization, as a strategy.

DOUG MCVAY: I want to talk to you about the psychedelic bit for a minute, because I want to know what you think about, and you have watched the evolution of drug policy since the Reagan era.

RICK DOBLIN, PHD: Yeah, yeah. Since before, since Nixon.

DOUG MCVAY: Well, oh, that's right, you're -- never mind.

RICK DOBLIN, PHD: I'm a little bit older than you, yes.

DOUG MCVAY: Technically a few years older than me, even though you look younger. And I'm still quite jealous. But, well, yeah, you've been watching.

RICK DOBLIN, PHD: You should do more psychedelics.

DOUG MCVAY: My doctor told me it's okeh. That's a good idea.

RICK DOBLIN, PHD: Yeah.

DOUG MCVAY: Okeh, you've watched this evolution, you've watched the evolution of drug policy -- not just of drug policy but also the reform movement.

RICK DOBLIN, PHD: Yeah.

DOUG MCVAY: And it went from well, marijuana's cool but we only want to say decrim, all the way to legalize all this stuff, and, how do you think -- how has the marijuana movement influenced the psychedelic movement, and vice versa?

RICK DOBLIN, PHD: Well, I think the marijuana movement has really proved this concept, that medicalization leads to legalization, that medicalization's the way to change people's attitudes, because there is so much misinformation, so much government propaganda, how do you reach people?

And the key, that we've learned from medical marijuana, is that it's through people knowing medical marijuana patients, seeing dispensaries not covered with machine guns and violence, seeing the alternatives.

Rob Kampia one time said something very interesting to me, which was that he thought the -- if you compare marijuana, medical marijuana states versus marijuana decrim, what leads more towards changing people's attitudes toward legalization is medical marijuana, not marijuana decrim, although decrim is about changing law, for that, because people can see examples.

So, I think one of the things we've learned from the marijuana is that -- the movement also is that you need to be super careful not to overestimate your success. So I'm going back to the '70s, where people thought, oh, it's going to be legal in a few years, and you get way overconfident, and you get then taken by surprise.

And so I think we need to really reach out. So now, we're trying to think about the main group that we've not reached out to, it's fundamentalist Christians. In terms of, we've got the Republicans because we're so much with the veterans, for MDMA, for PTSD, but how do we reach fundamentalist Christians, and try to help them not be resistant to this?

There's no answer to that, we haven't figured it out, but that's I think one thing you've learned from marijuana is, you get overconfident, you get taken by surprise.

I think the other thing that we've learned is that state by state and patients makes a lot of sense.

DOUG MCVAY: I hate greed.

RICK DOBLIN, PHD: Yeah, yeah.

DOUG MCVAY: And I'm not really fond of the money making corporate model that seems to be coming in, and so the -- I don't know how any of the corporate money people talking about investments reacted to your notion of a mutual benefit corporation and I don't give a flying, the question is, could you unpack that idea for folks?

RICK DOBLIN, PHD: Well, if you look at capitalism, it's about profit and unlimited growth, and, you know, and forget about the externalities. So not every company is like that, at all, but in general, we're destroying the planet, and it's, I think people are shortsighted on their narrow interests and not paying attention to the other.

So the benefit corp is a modification of capitalism, where you maximize public benefit, meaning you take care of the -- you account for the externalities. You don't ignore them. I think that's what we need. That's the problem with capitalism is you offload the externalities on other people and you just make your profit, and you don't care.

And so I think that the idea of the benefit corp is the antidote to capitalism. But it is capitalism, it's a form, it's the evolution of capitalism. Maybe that's a better way to say it, it's the evolution of capitalism, not the antidote to capitalism.

DOUG MCVAY: Interesting.

RICK DOBLIN, PHD: Yeah, and there's thousands of these companies now, these benefit corporations, and more all the time, and I think it makes a lot of sense. Particularly in healthcare, or drugs, anything that's got a risky product, you want people to be thinking about public benefit as the topmost metric, more than what profits they make.

If the tobacco industry, or the sugar industry, or all these were public benefit corporations, we'd have a whole different world now.

DOUG MCVAY: The investment you turned down.

RICK DOBLIN, PHD: Yeah, yeah.

DOUG MCVAY: How big?

RICK DOBLIN, PHD: Well, people were offering fifty million dollars. But it changes everything if you start doing that. I mean, if we can't raise it through donations, and we're stuck, and there's people -- see, the --

DOUG MCVAY: And you've raised -- and you've raised through donations how much?

RICK DOBLIN, PHD: Well, in the history of MAPS we've raised over seventy million dollars. Shocking. In donations, and there's no private gain. Not me, not anybody.

So I think the good argument about for-profit is that -- in general you could say nonprofits are for innovation, and for profits are for scaling. So, we're still at the innovation phase, and I want to maximize therapeutic outcome rather than maximize, you know, how low we can get the costs so that it will --

But on the other hand, there are eight to ten million people in America with PTSD. So, there's a moral argument to going as fast as you can. I just think, at this point, we are going as fast as we can, and I think it would change the flavor of things if we started taking investments.

But I'm not against the for profit drug development. So let me just make that clear. I support the for profit development of psilocybin, I support the nonprofit development of psilcybin, I just personally, with MAPS, want to continue with the nonprofit, but as I was talking during -- a few minutes ago, what if we want to make cannabis into a medicine, and the donors would rather pay for marijuana legalization? How -- where are we going to get the money?

What if the Michigan thing doesn't work out? Then I think you could make a good argument, but I would take an investment inside a benefit corp more so than inside a for profit.

Yeah, so MAPS one day could have -- okeh, let's go back to ibogaine.

DOUG MCVAY: Please, yes, talk to me about ibogaine.

RICK DOBLIN, PHD: Okeh, so, the very next step for ibogaine right now is roughly two, two and a half million dollars, which is a phase one two safety study in opiate addicts, to address the challenges that happen. People die from ibogaine, impacting the heart.

So, we need to show FDA that -- what is that risk, what people does it happen to, can you predict it, and if it happens, how do you block it and save people?

And Jeffrey Kamlet says people can be saved, that he's never had anybody die. So, the next step is two, two and a half million dollars in this phase one two dose response safety study. The Mission Within Group is saying they want to do a study like this but they want to do it for PTSD.

So it's different to do a safety study for each different patient population. So they're talking about, they've got somebody at Stanford, that they're interested in -- they think that they might have these millions of dollars, they're talking about trying to do this safety study, which would be good. I hope they do it.

But we need it, because each patient population has different safety risks. So we need to really do that, I think, with opiate addiction. I think we've got a real good approach towards PTSD, I think ibogaine can be helpful for PTSD, so can psilocybin, so can the classic psychedelics.

In the future, I think people with PTSD would get MDMA first, and then they might end up getting psilocybin or ibogaine or something else, for the more spiritual aspects, the MDMA for more working through trauma from their lives.

So we're talking about psychedelic medicine, but we have to go through the FDA one drug at a time. But eventually people will have a whole range of drugs in different sequences.

So, we're trying now to develop a protocol. We got a grant for ten thousand dollars, a new grant for ten thousand dollars, in order to develop this protocol and budget it out for a phase one two dose response safety study in opiate addicts.

And also we're funding a small study, thirty-five thousand dollars in Afghanistan, with ibogaine, for opiate addiction. It's with ISEERS, which is a group in Spain.

DOUG MCVAY: Yeah, yeah yeah.

RICK DOBLIN, PHD: And they're also going to do an ibogaine project in Barcelona, which is to take people off of methadone using low dose ibogaine, and then I think they're still working on the protocol, but what I've been suggesting to them, and they may do this, it's with Clare Wilkins, that, you know, you use low dose to taper people off their drugs, and then you use a high dose to try to prevent relapse, to do the psychological factors that -- so it's a different thing to detox versus help people not feel the need to become addicts again.

DOUG MCVAY: That was my conversation with Rick Doblin, PhD, the founder and executive director of MAPS, the Multidisciplinary Association for Psychedelic Studies. You can find MAPS out there on the web at MAPS.org.

And that's it for this week. I want to thank you for joining us. You have been listening to Century of Lies. We're a production of the Drug Truth Network for the Pacifica Foundation Radio Network, on the web at DrugTruth.net. I’m your host Doug McVay, editor of DrugWarFacts.org.

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For the Drug Truth Network, this is Doug McVay asking you to examine our policy of drug prohibition: the century of lies. Drug Truth Network programs archived at the James A. Baker III Institute for Public Policy.