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Washington State 5052 Retail Licensing Part 4

By CBE Press


A study was released recently as a portion of a lawsuit in the State of Washington this month. The suit alleges that the Washington State Liquor and Cannabis Board acted contrary to State law in its treatment of medical marijuana businesses that applied for but were not awarded licenses under 5052 in Seattle.

The study shows detail of what happened during the licensing process for licensing retail shops in the City of Seattle.  CBE Press is not a court of law, but the study appears to support what the law suit alleges. The Liquor and Cannabis Board (LCB) did not, in fact, give licenses to existing medical dispensaries in good standing. It also is hard to imagine that the LCB was not aware of regarding 5052 licensing in Seattle.

A bit of background

When the State of Washington legalized cannabis in 2012, existing medical marijuana dispensaries were not dealt with in the citizen’s initiative (502) that provided for the changes in law. A law passed by the Legislature that regulated and licensed medical dispensaries was partially vetoed by then Gov. Christine Gregoire, striking down the portion of the law that licensed dispensaries.

In 2015, a law was passed (5052) that ended the old medical cannabis system but mandated that licenses be given to the existing medical dispensaries that had followed the rules. The task to do this was given to the LCB. More history of how this unfolded is included in previous articles in this series.

The Seattle Study

The Seattle Study was attached to one of the lawsuits currently against the LCB that alleges that the licensing process did not move over meritorious medical dispensaries. The Study consists of a spreadsheet located below showing who received licenses in the City of Seattle and data about the license recipients, supporting data about the applicants used in the spreadsheet and the Seattle Study Takeaways. The spreadsheet also provides links that show photos of the application addresses which shed light on the lax approach taken by the LCB in carefully reviewing applications that have used the same address.

The Cover describes what the Study is, methodologies and where the data was obtained. The Seattle Study Conclusions contains, of course, the conclusions of the Study.

What the Study seems to demonstrate is that out of 21 licenses issued under 5052, only three (3) were existing dispensaries that met the criteria of the State.  The rest are a mix of cobbled together entities that clearly were not dispensers that met the criteria, and buildings that clearly were not dispensaries that pre-date even the date of application much less 2013 as 5052 set as the bar. It also finds “evidence” that the “system was being manipulated.”

Seattle was the city where identifying real dispensaries was the easiest in the State of Washington. The City of Seattle had already vetted its medical dispensaries. It had identified 48 that they allowed to stay open. The City closed the rest, but, of these 48, only three (3) were given licenses.

The Study relies heavily on information that is readily attainable by the general public. The question that the Study does not ask is “How did Seattle get this result?

  • Why did the Washington State Liquor and Cannabis Board simply use the list of dispensaries given to them by the City?
  • Was there a vetting process at all?
  • How did existing 502 retail shops get a second or third location when they were clearly not medical before they opened as a 502 store?

CB Press has only explored the situation regarding medical dispensaries in Seattle. We have yet to explore what happened statewide. As the lawsuits mount, stay tuned.

Seattle Study Takeaways

The main take away from this study is that the retail marijuana licenses given in Seattle under SB 5052 (The Cannabis Patient Protection Act) were not given to medical marijuana dispensaries as was envisioned under the law.  The law was created, in may ways, to license dispensaries that existed before 2013.

Seattle identified 48 dispensaries that pre-dated 2013 that were compliant.  Seattle was allocated 21 additional licenses under 5052.  This analysis shows that:

  • Only nine (9) of the locations that received licenses even existed to serve medical prior to the application process. 
  • Of the applicants that received licenses, only seven (7) existed before 2013.  Only 3 of the 21 5052 licensees in Seattle were dispensary organizations that pre-dated 2013. 
  • Seven (7) organizations that received licenses were founded after the application process was already underway.

The main takeaway from the information gathered is that the majority of the newly licensed Seattle licensees under  5052 were exceptions to the intent of the law.  There are some other findings though that are worth noting.

On February 9th of 2016, Seattle applicants (re: the compliant Medical dispensaries) were officially notified that the city had “already met its allotments of retail stores” and were given 30 days to “provide a new location address” outside of the City  On this date only 7 of the 21 licenses had been awarded.  Only one 5052 store was open.  The remaining licenses were given out over the next 31 days.  As of the date of the study, May 5, 2016, less than half of these stores were open.

There is evidence in this study (although no definitive smoking gun) that the licensing system was being manipulated.

  • Eight of the locations had multiple applicants on the same address.
  • One small building (Homegrown Northwest), with three different addresses, had 5 applications on it.  This small building is directly next door to the large marijuana retailer Cannabis City.  The owner of Cannabis City put 2 applications in citing this building as the address.
  • Two successful licensees (Esho Funi and Ephermal Toast) are next door to each other at the same address. These licensees are business partners in another marijuana retail business.
  • The Source and Washington OG are the exact same applicant with different trade names using the same building. Both applications were assigned to the same investigator.  The investigator awarded two licenses to this building.
  • Uncle Ike’s, which is an existing 502 retail store, clearly used a corporate vehicle which they “had no ties with” to buy a license at a new location even using the Uncle Ike’s trade name on the application.  95% of the business was transferred to him 10 days after the corporate vehicle received its license.
  • One of the Licensed addresses was actually closed by the City of Seattle for being a non-compliant marijuana business.

CBE Press can only conclude that the upshot of what happened in the Seattle 5052 Retail licensing process had very little to do with the legislative intent of 5052 in moving medical cannabis into a licensed system.  The law demanded that the Washington State Liquor and Cannabis Board “develop a competitive, merit-based application process that includes, at a minimum, the opportunity for an applicant to demonstrate experience and qualifications in the marijuana industry.”

As other states examine the eventual transition of medical dispensaries to recreational licensees, they should take a close look at Washington’s experience and develop a system that rewards experienced compliant operators that have invested heavily in creating legitimate businesses that have serve their patients and the intent of 502 and 5052 well.

(Click For Link to Image)
Location AddressLocation
License #Entity CreatedEntity Legal Name
11/10/152/5/16FWeedom Collective12001 Aurora Ave NYes4129225/8/08Fweedom Incorporated
2/9/162/13/16Green Sky Seattle9804 Lake City Way NE #AYes4142982/22/11Green Sky Seattle LLC
1/07/152/16/16Have a Heart CC300 NW 85TH STNo4214094/20/11Have A Heart Compassion Care LLC
2/11/162/20/16SMA (Pot Stop)4465 Fremont AVE NYes42081912/12/13SMA LLC
2/9/163/8/16Seattle Trees Collective10532 Greenwood Ave NYes41351911/22/13Seattle Trees Collective LLC
3/1/163/11/16Green Works Cannabis11064 Lake City Wy NE #6AYes42079310/8/15Green Zap LLC
3/7/163/14/16Have a Heart CC Fremont316 N 36th St #BYes42170812/18/12J&R Patners
3/4/163/21/16Homegrown Northwest2724 3RD AVE SSee Notes4213508/19/15TIRZAH VICTORIA FORTNER
1/7/164/20/16Herban Legends55 Bell St #100No42030210/13/14Legend Makers LLC
2/29/164/20/16Queen Anne Cannabis Co.312 W Republican STYes4134799/24/13Green Anne LLC
2/2/16Not OpenEsho Funi LLC8401 Aurora Ave N #ANo42161812/21/15Esho Funi LLC
2/3/16Not OpenThe Source5300 17th Ave NW #ANo4202929/29/11Washington OG, LLC
2/4/16Not OpenWashington OG5300 17th Ave NW #BNo4203829/29/11Washington OG, LLC
2/6/16Not OpenUncle Ike's 501 15th Ave ENo42114110/26/15Lion's Heart Productions LLC
2/11/16Not OpenLTC5440 California Ave SWNo42066612/20/13LTC LLC
2/17/16Not OpenOrigins Cannabis1416 SW Roxbury St #BYes42141711/19/15Origins Sale, LLC
2/18/16Not OpenEphermal Toast8401 Aurora Ave N #FNo42161911/20/15Ephermal Toast LLC
2/18/16Not OpenIsland on 4th Ave-District 4203405 4th Ave SNo42133211/21/15Island on 4th Ave, LLC
2/24/16Not OpenThe Green Door Seattle708 Rainier Ave S No4133572/7/12Good Patient Network LLC
3/11/16Not OpenThe Center for Palliative Care (CPC)74 S Lucile St #102Yes42126111/10/15The Center for Palliative Care, SPC
3/11/16Not OpenThe Center for Palliative Care (CPC)8600 LAKE CITY WAY NENo41478711/11/15The Center for Palliative Care, SPC
Qualified for Priority 1 licensing under 5052Business Entity Pre-Dates 2013
After Seattle had been officially closed on Feb 9, 2016After Licencing had started

Spreadsheet Sources

The above spreadsheet was created on 5/5/16. It uses information from several public sources including The Washington State Liquor and Cannabis Board (LCB) and the City of Seattle (COS).

The spreadsheet shows the license recipients in the City of Seattle and gives information about the licensing, status and entity receiving licenses.  Other documents are included to show how the information included was obtained includes:

  • LCB Approval Date- This is the date that the LCB issued the entity a Retail Marijuana License according to a document obtained through the COS.
  • Open Date- This is the date that the entity opened for business.  “Not Open” indicates that the entity was not open for business as of 5/5/16. This is also from a document obtained through the COS.
  • Tradename- This is the name that the LCB calls the licensee in its lists.  It is not necessarily the legal name of the entity.  This information is available on the LCB website.
  • Location Address- This is the address where the licensees received their license. This information is available on the LCB website.
  • Location Pre-Existing (10-12-15) Medical- This indicates whether the location address was a medical marijuana dispensary prior to the start of licensing.  It is not in the scope of this study to determine if they were a medical dispensary before January 1, 2013 as is in SB 5052.  This simply shows if this location was a medical dispensary at the date of Google Image capture listed on the photos.  This information was sourced from Google map images.
  • License #- This is the number assigned the licensee when they applied.  This becomes the license number upon licensing.  This information is available on the LCB website.
  • Entity Created- This is the date that the licensee’s business was started.  See report from the Secretary of State for each entity.  This information was retrieved from the Secretary of State’s website.
  • Entity Legal Name- The legal name of the applicant entity.  This information was retrieved from the Secretary of State’s website.

Supporting Documentation

  • Excel Spreadsheet- These are filtered views of the “Marijuana Applicant” spreadsheet from the “Frequently Requested Lists”.  These typically show multiple applications on a property.  In the case of Herban Legends, it shows the properties that were applied on under the name Herban Legends.  The address that ultimately was licensed for Herban Legends was not one that was applied on.  Some of the business information that follows is of others that applied on the same address or have some tie to the Licensee.  Homegrown Northwest is a small building with three addresses.  All three addresses are shown as all of them had applications.
  • Business Licensing Service Information-  This shows the information about the Licensee from the BLS.  In some cases, other applicants on the same address or businesses related to the entity are shown.
  • Washington Secretary of State Corporate Registration Detail-  This is the definitive corporate document that accurately lists the WA Filing Date, the date that the entity was incorporated.  This is not available for Homegrown Northwest as that entity is a sole-proprietor.
  • Department of Revenue Business Records Database Detail-  This shows the applicants history with the DOR.  It does not show if an entity has remitted any Sales Tax.  It does show when the earliest that it could have done this.
  • Other Documents-  There are some other documents that are included mostly to show proximity to other licensees and ownership and applicants that are side by side.
This Post Has 4 Comments
  1. Do a search for Black Key Holdings. That is the company used by Ramsey Hamide and Main Street Marijuana to obtain a priority 1 license—and be fully licensed before anyone even know what was going on. That store is now open on 162nd in Vancouver. I obtained the full Public Records Request related to Black Key Holdings, including all documents submitted by the applicants. The documents clearly show that the only “proof” Black Key Holdings had was a pay stub from Greenside Medical. It is my understanding that Greenside Medical and a few others were running a scam where they sold paystubs to use as proof in a priority 1 application. The fact is, Ramsey Hamide never owned, operated, or was even part of a collective garden. Ever. I have attached a link to a copy of the file for your convenience. I suggest doing full Public Records Requests for any license that is suspicious to see exactly what documentation they used. I think you will find a number that suspiciously have Greenside Medical pay stubs. btw….the Attorney General’s office has been made aware of this fraudulent scheme as well. Here’s the link:

    Good Luck,

    George Flannery

    1. 5052 also requires u be current and in good standings with the IRS. Several people lic. Never paid there sales tax, as required, they made arrangements with the Wa IRS to pay, there back taxes, that apparently over road the people paying taxes sence day 1 and before 2013.

  2. CBE Press, Thanks for your efforts.

    This is just the Tip of the Iceberg. What about the folks that made application for priority 2 & 3. No wonder the LCB has begun refunds.

    The LCB is a Crooked outfit & should have done background checks on all Retail Med Applicants/organizations before licensing as all applicants expected them (LCB) to thoroughly do the necessary background checks. The public (Honest Applicants), try to do the right/honest thing and yet the crooks get rewarded.

    Just my thoughts.

  3. Thank-you both for this article and for the series.

    It is informative, largely accurate, and shows diligence in how it was researched before being published.

    I’d cut entities that ended up being located at a different address than they originally applied for a bit of slack. So long as they were not under a ban or moratorium locally, organizations were OK to change location so long as they remained within the “jurisdiction” that they originally applied for (e.g., the City of Seattle).

    However, the “Shake and Bake” or “Frankenstein” applications that were allowed by the LCB (and enabled by a relatively recent change to the definition of “applicant”) managed to bump many of the “true medical dispensaries” that were serving patient off of the list.

    This situation sucks, but it REALLY sucks for the patients that are less than 10 days away from being forced to either shop in one of these retail outlets, stop their use of Cannabis (once their stashes of meds runs out), or become re-criminalized thanks to puppet-master Vicki, her favorite puppet,Senator Ann Rivers and many of our other State lawmakers that prefer money and power to common decency and morality.

    I’ll be writing a few posts over the next two weeks intended to give these patients a better-informed view of how to navigate the regulated waters (where they might want to shop to avoid the types of capitalistic psychopaths who have been so active in killing our legitimate medical providers—- and where they might not want to shop, which lab results to avoid when evaluating meds, who is likely to be gouging them, and how to interpret the gol-darn mandatory labels that the State requires … hint: they are largely bullshit and not worth the paper they are printed on).

    For those interested, these posts will be available at
    CBE may be posting some of them (they have my permission to do so).


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