"I'm not going to be using Justice Department resources to try to circumvent state laws on this issue." These comments were then echoed by the administration in March 2009 when Attorney General Eric Holder stated that only medical cannabis providers "who violate both federal and state law" would be targeted for prosecution. Additionally, an October 2009 memo from Deputy Attorney General David Ogden laid out further guidelines for federal enforcement that largely affirmed this hands-off approach. Despite these pronounced intentions of lessened enforcement from the Obama administration, however, an increasing number of raids were conducted during Obama's first two years in office, surpassing even the Bush administration in frequency. Federal enforcement efforts against medical cannabis were further escalated in early 2011, as a campaign of coercing state and local governments was initiated by the Justice Department. Letters were sent out by U.S. Attorneys to a number of state and city officials, threatening to criminally prosecute these individuals if the implementation of new medical cannabis laws moved forward. Some letters also threatened prosecution of state employees, or even the seizure of state administrative buildings (such as those used for the processing of medical cannabis licenses). In response to outcry and requests for clarification from numerous officials, a new memo was issued by Deputy Attorney General James M. Cole in June 2011. The Cole memo insisted that the 2009 Ogden memo was being adhered to, and that the Ogden memo's protections applied only to individual patients and not commercial operations. As the raids continued following release of the Cole memo, U.S. Attorneys sent out hundreds more letters over the next two years, threatening landlords with criminal prosecution and seizure of property for renting to medical cannabis providers. By June 2013, the total cost of the Obama administration crackdown on medical cannabis had climbed to $289 million, surpassing the previous 8 years of the Bush administration by $100 million. And the number of raids conducted during Obama's first 4 1/2 years had reached 270, in contrast to 260 during Bush's 8 years. Early in President Obama's second term, in August 2013, the Justice Department issued a new Cole memo setting forth the conditions under which federal law would be enforced. The memo was prompted in particular by the recent legalization of non-medical cannabis in Washington and Colorado, but also addressed enforcement in medical cannabis states. Regarding the medical use of cannabis, the memo