Charlotte’s Tangled Web: Strain Owner’s Ethics Questioned

    By Jacob Engels


    I am beginning to feel pity for Patty Nelson, the director of the office of compassionate use, who is tasked with creating the rule and awarding the lucrative contracts to 5 nurseries statewide to sell medical marijuana. Patty appears to be competent and engaged, and has a good reputation for getting things done. Unfortunately, the same cannot be said for the members of her negotiated rulemaking panel, who seemed to think it was ok to lie to her and cheat their way on to the panel to skew the rulemaking process in their favor.


    We previously reported how Bob Wallace of Chestnut Hill Nursery in Alachua appears to have misled the state about his supposed studies at the University of Florida, affiliation with the DEA, and medical credentials.


    The latest revelations of wrongdoing on that panel are equally serious. It appears that committee members Joel Stanley, the owner of the “Charlotte’s Web” strain, and Holly Moseley, the ‘patient representative’ on the panel, failed to disclose that they have business relationship to Patty Nelson, to their fellow members of the panel, and to the public watching the meeting. This is an incredibly serious breach of ethics and very possibly a criminal violation of the law.


    The Compassionate Care Act has been nicknamed the “Charlotte’s Web” bill – after a strain of marijuana that is owned by Joel Stanley of Colorado. Stanley himself was invited to serve on the negotiated rulemaking panel – to help create the criteria by which those applying to grow and sell the cannabis will be judged.


    Panel members were required to commit to negotiate honestly for the good of the process, and ultimately for the sick children that this treatment is intended to help. They pledged to discuss things in good faith and to disclose their personal and financial interests in advance. Even absent the ability to make final decisions, the members of this small committee influence the results by making suggestions.


    That is why their financial interests and relationships needed to be specifically disclosed in advance. They are not expected to be absolutely neutral – but being intentionally deceptive about their interests is strictly forbidden.


    Here is what I have put together:


    Holley Moseley also was appointed to serve on the panel. She presented herself to be representing “patient interests”, but what she failed to disclose were her own financial interests in the matter and those of her husband – as well as her close association to another panel member, Joel Stanley – and possible ties to a nursery that plans to apply for a license.


    In Moseley’s written application to the state to serve as the ‘patient advocate’, she stated that she had done research on cannabis oil and had visited Stanley’s greenhouses, but she failed to mention in her application that she was already in business with Stanley.


    See the article below with Stanley’s arm around Holley Moseley. The article announces that Stanley’s company has merged with Holley’s company – and how Holley’s husband Peyton has spun off a second for-profit company to capitalize on the windfall from Charlotte’s Web and their plans to affiliate with a nursery to accomplish this:


    From left to right: Paige Figi (Charlotte’s mother), Peyton Moseley, Holley Moseley, and Joel Stanley.


    During the introductions at the commencement of the panel, members were asked to disclose their interests. Holley once again indicated she was representing the interests of patients in the state of Florida, but once again failed to disclose her business relationship with Joel Stanley, that her husband had a business to sell Charlotte’s Web, and that they were likely already in negotiations with a nursery to sell their plants. Oops. Maybe she is just a little absent-minded?


    So Charlotte’s Web, the business, did not just have just one single voice on the panel with Mrs. Moseley, they also had a second voice by way of panelist Joel Stanley himself – effectively giving Charlotte’s Web, the business, TWO voices on this small but powerful panel (one of which was operating clandestinely).


    Their scheme is clear, because Holley discussed it directly in the article above. The Moseley’s plan is taken right out of Joel Stanley’s playbook in Colorado:


    “We‘ll be using the same model as they do in Colorado,” Holley said. “There’s a profit side and then there’s the nonprofit group side. The profit side will produce and dispense medicine, and the nonprofit group side which will help educate the community and help with costs.”


    The wife (Holley) runs the non-profit side, her husband runs the for-profit side. They buy their product from the Stanleys. And then sell it through a qualified nursery in the state. They conspired to get the bill originally passed through the legislature and then stacked the rule-making panel to favor the nursery that they will partner with. It was widely reported that the Moseley’s were very influential in getting the SB1030 bill passed in the first place. Was their motivation to help their sick daughter? Or was it to profit from legalizing the Charlotte’s Web strain, so that their exclusive license for that plant could reap them a private fortune? As the article above stated:


    “Peyton Moseley has sold his landscaping business to work in the day-to-day operations of a for-profit company, Ray of Hope 4 Florida, which will partner with one of five nurseries statewide to cultivate and process the marijuana.”


    My only question at this point is: will Charlotte’s Web cure MY nausea? I’m frankly sick to my stomach that this mother and father would use their sick daughter as a pretext to make money – and then try to conceal their business interests and the stack the committee designed to create a fair rulemaking process.


    On top of this, we have another serious question: can we guarantee that Holley and Stanley did not violate the Sunshine Law, which prohibits panel members from discussing panel matters in private? After all, they are in business together. Perhaps their texts, emails, and phone logs should be reviewed to ensure that the law was not violated from their possible private collusion to slant the decisions of the committee. Destruction of those texts and emails would be destruction of a public record, which is a misdemeanor, and would seriously undermine their credibility.


    As the referenced article stated, the Moseley’s planned to partner with a qualified nursery. Shouldn’t that relationship have been disclosed in advance, too? Were Holley and Stanley also looking out for that OTHER unnamed business partner? Shouldn’t we have the right to know if they were in negotiations, or had already signed a deal, with a qualified nursery when they were both appointed to the panel. What if the nursery they signed with also had representation on the panel? That would theoretically give a nursery applicant THREE voices on this powerful panel.


    Who were Moseley and Stanley really representing? Perhaps the nursery or nurseries that they hope will be empowered to sell their Charlotte’s Web strain? Or maybe it was Holley’s husband who quit his job to run a for-profit business selling the strain? How can we be sure that Moseley and Stanley did not illegally conspire together before the panel met (in violation of Florida’s oft discussed Sunshine Laws)? All of this should have been disclosed, and it must be researched now to clear the air of the appearance of impropriety.


    As if all this doesn’t stink enough, we can now enter the involvement of a powerful lobbyist who weighed in on behalf of Moseley, describing her as a client. The only problem is that the lobbyist isn’t registered to represent any entity that would have Moseley as an employee.


    Darrick McGhee, VP of Government Relations at Johnson & Blanton and an ordained pastor in Tallahassee, was Governor Scott’s Legislative Affairs director until leaving his post last year to join his firm. McGhee spoke on the phone and wrote a letter to Patricia Nelson recommending Holley Moseley to serve on the panel. In an email on 1/12/15, McGhee referred to Ms. Moseley as a client, however, he is not registered to represent her or any companies affiliated with medical marijuana in any way – a clear violation of lobbying procedures.


    What should be obvious to anyone who cares enough to think through this process is that the Moseley’s and Stanley are committed to lying, cheating and hiding their true intentions from the public, be it through their committee service or through their unregistered lobbyist.


    During the debate last year, there was extensive conversation about the type of characters that will come to Florida if marijuana is available. I am starting to think they were right.


    The lies of Charlotte’s Web keep getting more and more tangled. Between this new revelation and what we learned about Robert Wallace and Chestnut Hill Nursery, it looks like we’ve got some serious issues. If you know of any additional problems with the panel, please contact me at


    Jacob Engels, is the Founder of East Orlando Post & Seminole County Post. He is a seasoned political operative who has led numerous statewide political groups and has worked on several high-profile local, statewide, and national races. Jacob has been interviewed on national television & radio programs, with his work having been featured in the Orlando Sentinel, New York Times, Washington Post, Miami Herald and other publications nationwide. He can be reached at