 On August 29, 2013, the Department of Justice published a memorandum authored by Cole which described a new set of priorities for federal prosecutors operating in states which had legalized the medical or other adult use of marijuana.The "Cole memo" followed a 2009 memorandum from Deputy Attorney General David W. Ogden directing U.S.Attorneys in the Western United States to "not focus federal resources in your States on individuals whose actions are in clear and unambiguous compliance with existing state laws providing for the medical use of marijuana".