Oct 12, 2026

Dr. Jeff Rawson, Ph.D.,

Chair Institute of Cannabis Science

Secretary of the Commonwealth William F. Galvin

Dear Sir, I am writing to report violations of G. L. c. 4, § 7(26) and abuses of my rights under the Constitution of the United States by the Records Access Officer of the Cannabis Control Commission and by the Supervisor of Records within your office. My complaint concerns Public Records Requests which I submitted on July 27th and 28th of this year to further my journalistic investigations. As I shall lay out further below, my request for records from CCC began normally, but ended with violations of my constitutional rights.

My interactions with the Records Access Officer of the Cannabis Control Commission

1. My first several communications with the RAO of CCC, Attorney Roche, were unremarkable. Those communications indicated to me that, in substance, many records would be responsive to my request and provided without charge, on the condition that I would narrow my requests to exclude searches of email, which RAO alleged to be laborious. I agreed to the narrowing of scope and an extension which deviated from G. L. c. 4, § 7(26).

a. On July 27th and 28th, 2026, I sent a total of four emails to RAO of the CCC. Each requested, over a limited timeframe and for one particular Independent Testing Lab in Massachusetts:

i. Notices of Deficiency, Orders to Show Cause, or Letters of Enforcement Intent; documents which CCC issues to ITLs in the course of investigation and enforcement activities.

ii. Plans of Correction; documents which ITLs submit to CCC in response to investigation and enforcement activities.

iii. Emails which were part of investigation and enforcement activities CCC partook upon ITLs.

b. On July 31, 2026, I received an email from CCC’s RAO, Attorney Roche, which responded to my four requests collectively. Attorney Roche noted all of my requests, and suggested that I withdraw “ the email part of your requests since you are already going to receive various responsive records for the requests. ” The Massachusetts Public Records Law, G. L. c. 4, § 7(26), allows for reasonable suggestions by RAOs of modifications to the scope of PRRs to manage expenses. Encouraged that I would receive many documents, I acceded to this narrowing of scope that was permitted by law.

c. On August 14th, 2026, I received the next communication from CCC’s RAO, stating, “ I am writing as a follow to your 4 public records requests (PRRs) with the Commission. We continue to process your requests but need additional time. Therefore, we are extending our response time by 5 business days. ” The Commonwealth’s Public Records Law, G. L. c. 4, § 7(26), states, “ … a records access officer may… petition the supervisor of records for an extension of the time for the agency or municipality to furnish copies of the requested record, or any portion of the requested record, that the agency or municipality has within its possession, custody or control and intends to furnish. ” The law quoted here provides for extensions of PRRs to be adjudicated by the Supervisor of Records, but does not provide for an RAO to declare an extension unilaterally, as Attorney Roche did with that email. Out of an abundance of goodwill, I acceded to the delay in spite of the deviation from statutory procedure which it represented.

The above record shows that my first communications with RAO of CCC were cordial, that RAO promised many respondent records, and that the communications were not remarkable except for a counter-procedural extension granted to the RAO by himself, which I accepted out of an abundance of goodwill.

2. On August 28th, I received a blanket denial of my PRRs from CCC’s RAO, who invoked my associates, motives, and potential actions I might take as justifications, but did not name specific documents or categories of documents, as required by G. L. c. 4, § 7(26). Specific features of the denial email from RAO of the CCC worth noting include:

a. The denial introduced my requests but failed to acknowledge the earlier assurances from CCC’s RAO that many records would be provided to me, nor did it acknowledge the late responses of CCC with respect to the timeframe laid out by statute. Massachusetts PRL states, “ If the agency or municipality does not intend to permit inspection or furnish a copy of a requested record … the agency or municipality shall inform the requestor in writing not later than 10 business days after the initial receipt of the request for public records. ” Coming a month after my initial requests, with no extensions granted by the Supervisor of Records, and after a previous suggestion by RAO that I narrow the PRR and receive many records, the RAO of CCC, instead, issued a blanket denial when they wrote, “ The records which you are requesting cannot be released at this time pursuant to exemption (f) of the Public Records Law. ” RAO violated G. L. c. 4, § 7(26) and the Secretary’s guidance with this denial.

b. The denial became accusatory and referenced an outdated affiliation between myself and a party to some lawsuit when it alleged that “ One of the ITLs with whom you have been affiliated has sued competitor ITLs and has alleged various forms of testing fraud. ” The accusations from RAO against me continued, “ in light of your current or prior affiliation with one of the parties in the pending litigation involving ITLs, the Commission questions whether the documents are being requested to advance a party’s litigation interests. ” I am affiliated with no ITLs. Furthermore, it would be inappropriate for any government employee to raise the actions of my associates in official communications with me, or to penalize me as a proxy for others. Finally, G. L. c. 4, § 7(26) does not provide for an RAO to determine whether documents are subjects of active litigation, instead stating, “ the Supervisor may deny an appeal for, among other reasons if, in the opinion of the Supervisor : 1. the public records in question are the subjects of disputes in active litigation, administrative hearings or mediation; ” (emphasis added).

c. The denial by RAO of CCC stated that “ the Commission questions whether the documents are being requested to advance a party’s litigation interests, ” but such a supposition was not appropriate or warranted in responding to my PRR. The Secretary of the Commonwealth’s guide to PRL states: “ The requestor is not required to provide any reason for making a request and, generally, the purpose of the request has no bearing on the public status of the record. All requestors must be treated the same with respect to the response to their requests. Given this, the requestor may not be required to identify himself or herself as a condition of obtaining access to the requested records. ” The unfounded suspicions of my motives advanced by the CCC were inconsistent with the guidance upon PRL the Secretary of the Commonwealth promulgates.

d. The RAO falsely alleged that a blanket of confidentiality extends over all documents from past investigations under exemption (f), for records concerned in ongoing investigations, as I outline further below: i. The Secretary of the Commonwealth’s guide to the PRL states, “ Exemption (f) does not, however, create a blanket exemption for all records that investigative officials create or maintain. A custodian of records generally must demonstrate a prejudice to investigative efforts in order to withhold requested records. Information relating to an ongoing investigation may be withheld if disclosure could alert suspects to the activities of investigative officials. ” Many investigations into the four concerned ITLs were closed by CCC over the timeframe of my requests, and the RAO failed to demonstrate how releases of documents which relate to those investigations would jeopardize current investigative efforts.

ii. CCC’s RAO failed to accompany their request for exemption with “ individual documents or an indexed manifest of said documents which will be subject to the exemption ,” despite the statutory requirement for such.

iii. The statute also provides, “ The priority of the agency shall always be toward segregation and redaction of sensitive details from public documents, rather than outright denials of entire requests .” After acknowledging that many records should be responsive to my requests, CCC’s RAO issued a blanket denial.

The misuses of exemption (f) in G. L. c. 4, § 7(26), the failure to index the exempt documents or categories of documents, and the failure to segregate or redact in a manner which would favor disclosure, violated PRL.

This denial by RAO of the CCC violated the laws of Massachusetts and my right to associate freely under the First Amendment of the Constitution of the United States.

Response of the CCC’s RAO to my appeal

3. On Friday, August 28th, 2026, I emailed the Supervisor of Records an appeal over my denial by the RAO of the CCC. My appeal argued the misapplication of exemption (f) to the PRL and CCC’s invocations of my motives and associates in their denial. I presented the full record of my communications with RAO of CCC, which, as I described above, violated G. L. c. 4, § 7(26) and my rights under the First Amendment of the Constitution of the United States. I noted that I had published an article at Talking Joints Memo which had appeared to embarrass CCC’s Office of General Counsel on August 26th, two days before the denial, and speculated my hypothesis of a connection between the timings. I further provided, as additional evidence, a previous, unresolved complaint of mine which addressed the compliance with Public Records Law by two previous RAOs at the CCC.

4. On Monday, August 31st, 2026, I received an email from Gabriel Zuniga in the office of the Supervisor of Records which acknowledged receipt of my complaint. I noted that the RAO of the CCC was copied on that email, and that the Supervisor of Records had acknowledged their statutory obligation to rule within ten business days.

5. On Sunday, September 13th, 2026, at 9:15 pm, the RAO of CCC emailed myself and the Supervisor of Records to notify us that CCC would respond to my appeal by the close of business on September 14th, 2026. A subsequent email from RAO of CCC on September 14th provided irrelevant justifications for the denial of my request:

a. The Sept. 14th email from RAO of the CCC began with personalization when it stated, “ Initially, we want to address Jeff Rawson’s silly suggestion that the Commission denied his requests ‘in retaliation for an article I published Wednesday, Aug 26th.’ First, I didn’t see the article until a day or 2 days after the denial was sent. I don’t know where it was “published” but even if I had, I’m pretty sure that it wouldn’t have swayed me. ” In fact, I have understood from other employees that articles published at  https://talkingjointsmemo.com which concern the Commission are routinely emailed to the entire staff. My LinkedIn account shows me that many unique visitors who accessed the internet from the CCC domain have visited my profile and posts each week for the past several years.

i. For example: I made a post on LinkedIn about an interview with Mike Crawford in which we had discussed the article in question. The post received 994 impressions, 4% of which (~40) were from machines accessing the internet via the CCC’s domain.

The lie which alleged disinterest of CCC employees in my publications, using personal terms, at the start of this justification for RAO’s blanket denial of my request for public records, was evidence that an employee of the Commonwealth was using official means to retaliate against me personally.

b. The justification from RAO of the CCC went on to present an unwarranted investigation into myself, my alleged associates, and my organization in an effort to support their denial of my request:

i. RAO listed the labs named in my requests, writing, “ Jeff Lawson [sic] submitted four separate requests for public records relating to the following Independent Testing Labs (ITLs): MassBiolytics, Assured, Kaycha, and MCR Labs. ”

ii. RAO then noted that “ MCR Labs has sued these three other ILTs and all other ITLs as part of its lawsuit. ” The suit of MCR Labs does not name all other ITLs as defendants, but I believe it does name the three others which I also named.

iii. RAO continued with an accusation and an unwarranted investigation into my organization when it stated, “ Mr. Rawson denies any relationship with MCR Labs. Yet, when Jeff Rawson filed Articles of Organization for the Institute of Cannabis Science, LLC on 10/14/2022, he listed Michael Khan [sic] as Treasurer and a Director. Michael Khan [sic] is the Founder and CEO of MCR Labs. ” Indeed, Mr. Kahn was a founding member of my Institute of Cannabis Science, but has long since departed and drifted far from me. To my knowledge, the RAO of the CCC is not charged with investigating the organizations and associates of requestors of public records, and such an investigation must surely violate my rights against unreasonable searches under the Fourth Amendment of the Constitution of the United States.

iv. RAO unnecessarily named an additional party in a manner suggestive of bias when they wrote, “ His brother, Yasha Khan, [sic] is a Vice President of MCR Labs. ” There was no need to name Yasha Kahn, as RAO had already established my past association with a founder of MCR Labs. The naming of each of the brothers Kahn separately appears to reflect the bias of RAO rather than any substantive concern about my request.

v. Further evidence of bias by the RAO was the following accusation, “ The denial of a relationship with MCR Labs is false. His relationship with Michael Kahan [sic] goes back at least 4 years, even if Mr. Khan [sic] no longer serves as an officer or director of the Institute. ” These allegations by RAO of the CCC continue to reflect their prosecution of enemies they perceive rather than an effort to administer my request for records.

vi. RAO of the CCC became even more conspiratorial by writing, “ This pending litigation is a concern for the Commission. If successful, Yasha Khan [sic] at MCR Labs could gain access to confidential information on it’s [sic] competitors’ clients that could be shared by him with his brother, Michael. Then it could be shared with Mr. Rawson. ” I have expressed no interest in lists of the clients of ITLs, which I believe could not be reconstructed from the records I requested. Here, RAO has inexplicably conflated the records which I requested about closed investigations with records of ITL clients, constructing a preposterous daisy chain of connections.

vii. RAO of the CCC then invoked a determination they were not permitted to make by writing, “ Here is information on the above-referenced case. It is active and ongoing in the Suffolk Superior Court. Please see MCR Labs, LLC vs. Analytics Labs, LLC, Docket No. 2584CV00260. We ask that you deny this appeal at this time pursuant to 950 C.M.R. 32.08(2)(b) given the pending litigation. ” The Commonwealth’s PRL does not grant RAOs the power to determine that records are the subjects of pending litigation, and the agency is not, itself, a party to the named suit. RAO thus conducted an unwarranted investigation into myself and my purported associates to assert an interpretation they were not permitted to offer.

The unreasonable investigation by RAO of the CCC into my organization and their unsupported claims about my associates were irrelevant to any request for public records and violated my right to freely associate under the First Amendment, and my protection against unreasonable searches under the Fourth Amendment of the Constitution of the United States.

c. CCC’s RAO went on to volunteer an additional, inappropriate justification for denying my requests by writing, “ Furthermore, the Commission is denying access to the requested records pursuant to exemption (f), the investigatory exemption. ” As I laid out above, both the Secretary’s guidance on public records law and the text of G. L. c. 4, § 7(26) refute the existence of a blanket exemption to PRL for all documents which were part of any past investigation. Instead, the Commonwealth’s law states that such an exemption applies only to materials which “ would probably so prejudice the possibility of effective law enforcement that such disclosure would not be in the public interest; ” and requires the enumeration of said documents, along with segregations and redactions which would favor disclosure.

d. RAO reiterated the inaccurate interpretations of the Commonwealth’s PRL for several more sentences, including “ Even when an investigation is closed, the exemption allows investigative officials to withhold materials that could compromise investigative efforts if disclosed. ” As I described above, and as reiterated by the Secretary’s own guidance page, “Where exempt information is intertwined with non-exempt information, the non-exempt portions are subject to disclosure once the exempt portions are deleted.” Although the Commonwealth’s PRL favors disclosure by requiring listings of sensitive documents, their release after redaction to remove sensitive details, and their segregation from non-sensitive documents, the RAO of the CCC demonstrated no commitment to those principles.

e. The email of justification from RAO of the CCC concluded with their wish that two inadequate exemptions to public records law would suffice where one appropriate one was required, writing, “ In summary, we believe that there are substantial grounds here to justify denying this appeal. Thank you for your consideration of the Commission’s concerns. ” This instance of prosecuting two exemptions poorly is one instance of CCC counsel’s grab-bag approach to the law, and evidence of unstated motives behind their denial of my request.

6. The guide to Massachusetts PRL provided by the Secretary of the Commonwealth makes clear the inappropriateness of the RAO’s investigation into my organization, my purported intentions, and my associates: “ The requestor is not required to provide any reason for making a request and, generally, the purpose of the request has no bearing on the public status of the record. All requestors must be treated the same with respect to the response to their requests. Given this, the requestor may not be required to identify himself or herself as a condition of obtaining access to the requested records. ” By digging into my personal details and offering two malappropriate objections to my request, RAO revealed a personal bias against myself.

7. The CCC’s RAO pursued irrelevant exemptions to PRL by investigating my personal details despite my established journalism and public overwatch activities. In G. L. c. 4, § 7(26) “ … a records access officer may not require the requester to specify the purpose for a request, except to determine whether the records are requested for a commercial purpose … the sale or resale of any portion of the public record … and shall not include gathering or reporting news or gathering information to promote citizen oversight or further the understanding of the operation or activities of government or or academic, scientific, journalistic or public research or education.” As demonstrated above, I have published many articles of journalism and am the founder of a citizen oversight group called the Institute of Cannabis Science of which CCC has been copiously aware, so raising the exemption for commercial purposes was wholly inappropriate of CCC’s RAO.

8. These actions by the RAO of CCC violated my rights to freely speak and freely associate under the First Amendment, and my protection against unreasonable searches under the Fourth Amendment, of the Constitution of the United States.

My appeal to Supervisor of Records and the Justification by CCC

9. As I described above, I appealed the decision of CCC’s RAO to the Office of the Supervisor of Records in a letter dated August 28th, 2026.

10. The burden of proof for an exemption to Massachusetts public records law is held by the holder of the records, as exemplified in the following statement from the Secretary of the Commonwealth’s guide, “ Every record that is made or received by a government entity or employee is presumed to be a public record unless a specific statutory exemption permits or requires it to be withheld in whole or in part. ” Despite that burden and as I detailed above, the RAO of the CCC offered scant evidence about whether the documents, themselves, were exempt, but copious unwarranted investigation of myself and organization in violation of the Constitution of the United States. The Office of the Supervisor of Records is expected to monitor the actions of RAOs to prevent constitutional abuses, but failed to do so in my case.

11. I received a so-called “determination letter” from Supervisor of Records dated Sept 15th, 2026. Despite the aforementioned fact that the burden of proof rests with the RAO of the CCC, the Supervisor of Records responded to my appeal but failed to critically probe CCC’s objections to my requests, nor did it acknowledge the evident violations of my constitutional rights by CCC’s RAO. Finally, it failed to offer any decision at all, a violation of Massachusetts law and also a deprivation of my liberty in the absence of due process as provided under the Fifth Amendment of the Constitution of the United States.

a. The “determination letter” of Supervisor of Records began as an orderly response to my appeal, introducing my four emails of request and the facts of public records law, including a reiteration that “ It is the burden of the records custodian to demonstrate the application of an exemption in order to withhold a requested record. ”

b. The “determination letter” of Supervisor of Records continued by recounting the dates of RAO of the CCC’s emails to me: “ The Commission responded on July 31, 2026, August 14, 2026, and August 28, 2026. Unsatisfied with the Commission’s August 28th response, Dr. Rawson petitioned this office and this appeal, SPR26/3451, was opened as a result. While this appeal was pending, the Commission provided a further response on September 14, 2026. ” This summary is factually correct, but I note that it mentions only one communication from RAO of the CCC on August 14th.

c. My personal records include one additional communication from RAO of the CCC, dated August 14th, which was not included in my original communications to Supervisor of Records, and, as I established above, was not specifically examined in the “determination letter.” I shall not discuss this second email dated August 14th further here, as I await the results of a pending investigation by a third party expert for signatures of email fraud.

d. The “determination letter” from the Supervisor of Records did not examine communications from RAO of the CCC dated August 14th, 2026, in detail, but did examine communications from RAO of the CCC to me dated August 28th and September 14th. Supervisor of Records noted that “ In its August 28, 2026 response, the Commission cited Exemption (f) of the Public Records Law to withhold responsive records… ” and that in its September 14th response CCC added an additional justification, including that “ This pending litigation is a concern for the Commission. If successful, [an identified individual] at MCR Labs could gain access to confidential information on its competitors’ clients that could be shared by him with his brother. ” The “determination letter” of the Supervisor of Records did not note the inappropriateness of the investigation into my organization and speculations about my associates promulgated by CCC’s RAO, nor their apparent violation of my constitutional rights, and it credulously permitted CCC’s inappropriate assertion that the documents responsive to my request are subjects of ongoing litigation, despite the fact that CCC is not a party to the litigation in question and despite the absence of such a broad exemption in the public records law of MA.

e. The “determination letter” from Supervisor of Records abstained from addressing my submitted documentation of CCC’s past obstructions of my PRRs, including evidence which I submitted which showed preferential treatment for different requestors going back to 2022, shifting explanations for withholding information that extend from 2023 through to the present day, incompetent handling and analysis of aggregated data from compliance testing by CCC staff, and my past entreaties that CCC cooperate with myself and the database provider METRC on the analysis and interpretation of said data in shared pursuit of the common good.

f. Supervisor of Records’ “determination letter” went on to iterate my own objections to the initial ruling by RAO of the CCC: “ The alleged affiliation does not exist, yet it was used to suggest, in substance, that the materials would be especially dangerous in my hands and so exemption (f) should be applied. Such a selective application is a transparent violation of public records law, and far from the first I have experienced from this agency… I believe CCC is violating the law by making any reference to how I might use the records, let alone by denying my request on that basis. ” Supervisor of Records did not refute or even address the assertions of my writing, quoted above.

g. The “determination letter” from Supervisor of Records referred to the section of Massachusetts G. L. that states, “ the Supervisor may deny an appeal for, among other reasons if, in the opinion of the Supervisor: 1. the public records in question are the subjects of disputes in active litigation, administrative hearings or mediation. ” but failed to acknowledge that no RAO has the authority to make such a determination, but rather it is required of the Supervisor themselves.

h. The “determination letter” from Supervisor of Records countenanced the violation by RAO of the CCC of my protections under the Fourth Amendment of the Constitution of the United States against unreasonable searches by acknowledging that the Supervisor retraced RAO’s investigative steps when it stated, “ This office has reviewed the docket of the trial court and verified that civil litigation concerning the records at issue in these requests is active and ongoing in Suffolk Superior Court. ” The CCC is not a party to the litigation in question, so I understand no exemption that should be appropriate on that basis, and the Supervisor of Records ought not to investigate the affiliations of the founder of a citizens overwatch group in search of excuses to deny a lawful request for public records that are to be used in journalism.

i. The “determination letter” from Supervisor of Records abruptly concluded, “ In light of the pending litigation, I decline to opine on this matter at this time. See 950 C.M.R. 32.08(2)(b). I additionally decline to opine on the applicability of Exemption (f) of the Public Records Law to the responsive records. ” By declining to rule, Supervisor of
Records left my appeal unresolved, but effectively ratified the unlawful determinations which RAO of the CCC was not permitted to make under M. G. L.

In so doing, Supervisor of Records countenanced the denial of my liberties without due process in violation of the Fifth Amendment of the Constitution of the United States, and also duplicated steps of the unreasonable search which ought to have been prohibited under the Fourth Amendment of the Constitution, all in retaliation against a member of the press, in violation of the First Amendment of the Constitution of the United States.

Summary and instruction to preserve records

12. RAO of the CCC and the Supervisor of Records in the Office of the Secretary of the Commonwealth cooperated to violate my rights under the First Amendment, Fourth Amendment, and Fifth Amendment of the Constitution of the United States as they violated provisions of the PRL of the Commonwealth.

13. As I and the Institute of Cannabis Science are formulating further actions against the Cannabis Control Commission and the Office of the Secretary of the Commonwealth, I instruct you to preserve all records of interactions between CCC and Supervisor of Records, and of each with myself, including emails, text messages, messages on WhatsApp, Telegram, or other applications, and records of telephone calls. In addition, I instruct CCC to refrain from any post-facto modifications to the records of email communications.

Signed this 12th day of October, 2026, in the town of Millis in the Commonwealth of Massachusetts:

Dr. Jeff Rawson, Ph.D.