STATE OF MICHIGAN

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS1

CANNABIS REGULATORY AGENCY

In the Matter of

Kassab Investments LLC dba Packwoods Distribution ENF No: 22-00404

License No.: PR-000161
_______________________________/

FORMAL COMPLAINT

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

against Kassab Investments LLC dba Packwoods Distribution (“Respondent”) alleging
upon information and belief as follows:

1. The Cannabis Regulatory Agency (CRA) 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 CRA’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.

1 Executive Reorganization Order 2019-2 created the Marijuana Regulatory Agency (MRA) as a Type I agency within the Department of
Licensing and Regulatory Affairs (LARA). MCL 333.27001(1)(a)(d). On April 13, 2022, the MRA became the Cannabis Regulatory Agency
(CRA). The CRA exercises its statutory powers, duties, and functions independent of LARA’s direction. MCL 16.103.

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Formal Complaint
ENF No.: 22-00404 Page 1 of 6
CRA 5039
 FACTUAL ALLEGATIONS AND INTENDED ACTION OF THE CRA

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

6. Respondent operated at 2001 E.10 Mile Rd., Warren, Michigan 48091, at all times
relevant to this complaint.

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

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

a. On April 5, 2022, the CRA was conducting a 30-day post license inspection
at a medical marihuana provisioning center and observed Respondent with
a vendor booth set up at the facility.
b. The CRA observed Respondent distributing non-medicated ‘koko nuggz’
chocolate edibles to customers and employees of the medical marihuana
provisioning center facility, who then consumed the products onsite. The
sale, consumption or serving of food is not allowed onsite at a marihuana
business, an investigation was opened as a result.
c. On April 13, 2022, the CRA discovered one of Respondent’s employees
working the vendor booth was not entered in the statewide monitoring
system (Metrc), that individual began their employment with Respondent
approximately one month earlier.
d. On April 19, 2022, Respondent entered the employee into Metrc, beyond
the 7 business days required by administrative rule.
e. On May 12, 2022, the CRA contacted a representative of Respondent
regarding the partnership between Respondent and the medical marihuana
provisioning center where they had the vendor booth present.

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Formal Complaint
ENF No.: 22-00404 Page 2 of 6
CRA 5039
 f. Respondent stated no licensing agreement had been worked out at that
time. A ‘handshake agreement’ was made to develop the brand and see if
it would ‘work out’ after a test period.
g. Respondent also stated when a long-term deal was in writing, it would be
submitted to the CRA for approval.
h. Respondent failing to have an employee in Metrc is a violation of Mich
Admin Code, R 420.602(2)(b), which states a licensee shall comply with all
of the following: (b) Enter in the statewide monitoring system an employee’s
information and level of statewide monitoring system access within 7
business days of hiring for the system to assign an employee Identification
number. The licensee shall update in the statewide monitoring system
employee information and changes in status or access within 7 business
days.
i. Respondent failing to obtain approval from the CRA prior to the licensing
agreement being in practice is a violation of Mich Admin Codes, R
420.112a(1) & 420.112a(2), which state a licensee may contract with
another party to use the other party’s intellectual property or for the other
party to provide management or other services necessary for the operation
of the licensee pursuant to a licensing or management agreement approved
by the agency. And a licensee shall submit a complete, unredacted, signed
copy of the licensing, management, or other agreement to the agency for
review and approval prior to performance under the agreement.

THEREFORE, based on the above, the CRA 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.

Under MCL 333.27407(4) and Mich Admin Code, R 420.704(2), any party aggrieved
by an action of the CRA 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
CANNABIS REGULATORY AGENCY
2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Formal Complaint
ENF No.: 22-00404 Page 3 of 6
CRA 5039
be submitted to the CRA 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 CRA 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

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

In Person: Department of Licensing & Regulatory Affairs

Cannabis 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 Cannabis Regulatory

Agency at (517) 284-8599 or [email protected].

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Formal Complaint
ENF No.: 22-00404 Page 4 of 6
CRA 5039
 Alyssa A. Digitally signed by
Alyssa A. Grissom
6/22/2022 Date: 2022.06.22
Dated: _______________ By: Grissom
_______________________________
22:28:26 -04'00'

Alyssa A. Grissom
Legal Section Manager
Enforcement Division
Cannabis Regulatory Agency

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Formal Complaint
ENF No.: 22-00404 Page 5 of 6
CRA 5039
 In the Matter of

Kassab Investments LLC dba Packwoods Distribution ENF No: 22-00404

License No.: PR-000161
_______________________________/

PROOF OF SERVICE
06/24/2022
I hereby certify that on ________________________________, I mailed a copy of the
06/22/2022
Formal Complaint dated ____________________________ in the above captioned case

by certified mail (return receipt requested) to:

Kassab Investments LLC dba Packwoods Distribution

22199 Shane Drive
Macomb, Michigan 48042

Digitally signed by: Abby Rae Brooks

Abby Rae DN: CN = Abby Rae Brooks email =

[email protected] C = US O =

Brooks
Marijuana Regulatory Agency OU = Legal
Section
Date: 2022.06.24 08:44:03 -04'00'

Abby Rae Brooks

Departmental Technician
Cannabis Regulatory Agency
Department of Licensing & Regulatory
Affairs

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER  P.O. BOX 30205  LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Formal Complaint
ENF No.: 22-00404 Page 6 of 6
CRA 5039