compassion collective of camden county

8/6/2019 Compassion Collective of Camden County

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Application for anAlternative Treatment Center to Operatein the Southern New Jersey Region

byThe Compassion Collective of Camden County (C4)

a New Jersey Non-Profit Corporation

Contact Information:J. Peter Rosenfeld

I to the accuracy and veracity of all statements, figures, amounts and other information incorporatedwithin the materials submitted.1. Peter Rosenfeld, CEO of the Compassion Collective of Camden County

February 14,2011


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Criterion 1: Mandatory RequirementsMeasure 1: Legal NameCompassion Collective of Camden CountySupporting documents are in Appendix A.The ATC will be referred to as "C4" in this document.A registered alias of the C4 ATC, to be used in relation to production and research activities, is"Camden County Pharmaceutical".

Measure 2: Physical address( es) of the ATCWe are in the process of procuring a lease option on 7239 Browning Road, Pennsauken, NJ.This is a warehouse space on the edge of one of Pennsauken's business and warehouse districts near theAirport Circle but with very good access by the public. The building is divided into two areas,an officespace for dispensing, and a much large warehouse space for production. Ifwe are unable to gain controlof this site, there are numerous similar sites in this area of Pennsauken as well as the other largePennsauken business/warehouse district around the intersection of National and Industrial Highways.

Measure 3: Compliance With the Local Zoning LawsMeetings with the economic development department of Pennsauken, NJ, who determined in ourmeetings that all proposed locations were zoned correctly for both production and simple distribution.Ifwe are unable to secure our primary site, the other sites in this and the other warehouse/businessdistrict have the same zoning. The director of the economic development department, Mr. Terry Carr,can be contacted at (856)665-1000, ext. 153, to confirm this information.Measure 4: Drug-Free School ZonesThe Pennsauken Township officials have determined that the proposed location is not within a drugfree zone. The nearest school, by road, is approximately 0.8 miles from the proposed ATC site,BishopEustace Preparatory School, Pennsauken, NJ. Amap showing the nearest public/private schools isincluded in Appendix D. The format of the police department drug-free zone map is difficult toreproduce in hard copy, but a scan will be made if desired.Measure 5: Coverage Area of ATCA large section of southern New Jersey is within 30 miles of the proposed ATC site. See Illustration 2in Appendix E. All of the southern New Jersey region, excluding Cape May county, is within 45 milesof the ATC location. The majority of the population centers of the southern New Jersey region arewithin 15 miles of the ATC. The ATC will cover the counties of Atlantic, Burlington, Camden,Cumberland, Gloucester, and Salem. If a reduced area is preferred, that would not significantly impactour business plan as long as Burlington, Camden and Gloucester counties are allowed. If delivery iseventually allowed, the ATC could also perform weekly delivery to Cape May County.Maps of coverage area and zip codes are in Appendix E.

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Measure 6: Staff and BoardBoard positions are unpaid positions, although reasonable expenses incurred in the carrying outoftheir duties can be compensated on a case-by-case basis.Because this is a non-profit organization, no person involved in the enterprise has any capital orother"interest" in theATe. The ATC is being financed by 3-year business loans, at typical interest rates for amedium to high-risk unsecured business loan, provided by members of the board.The Chair is also the CEO, a salaried staff position. This is a temporary 3 year position until theATereaches a stable operating and financial situation. After that period the board will consider separatingthe two positions,The requirements of each position are described below, followed by the name and information of theperson selected and a brief resume of that person.Board Chair and CEO(staff)Qualifications: extensive experience in management, systems, security, technology and operations torun the ATC organizationJ. Peter Rosenfeld

Mr Rosenfeld has nearly 30 years experience as an aerospace computer scientist and research engineerand as a project lead managing large programs. He has significant experience in developing and usingsecurity systems and security procedures. He is accredited in cannabis therapeutics by the UCSFSchool of Medicine, is training in commercial cannabis operations and is an expert amateur gardenerwith a background in both soil and hydroponic techniques. Mr. Rosenfeld is also using his engineeringbackground to aid in the development of advanced vaporizers for cannabis administration

Board Financial OfficerQualifications: experience in non-profit operations and finances to oversee the financial operations fotheATCCarol Babb

Ms. Babb has been working in the field of non-profits for over 25 years. She has 10+ years experiencein management and has been a consultant to not-for-profit organizations, universities, medical centersand the state of New Jersey in the areas of cancer needs assessment, start-up operations, marketresearch, marketing and public relations, and fund raising. Most recently, Carol was a financialstatement auditor in a Big 4 public accounting firm. She holds an MBA from Rutgers and anMA inSociology from the University of Memphis.

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Board Medical OfficerQualifications - A New Jersey physician with experience in NJ non-profit hospitals and an interest incannabis therapeutics to oversee medical operations and supervise medical researchJose Diaz-Jimenez, MD377 q 7 ~r urn.~J. JIll. Dr. Diaz developed an occupational and health program at Cooper University Hospital in Camden, NJ.Dr. Diaz was Pennsauken's official Police Force Physician for about 8 years. He currently practicesfamily medicine in Sewell, NJ and has recently completed a program in cannabis therapeutics andoperations.

Board IT OfficerQualifications - extensive experience in computer networks, information technology and systemstooversee the ATC computer and network operations

Mr. Wall has 12 years of experience in integrated CRM and Sales Reporting solutions, enterpriseapplication hosting, customer support center services, and inventory/asset management, financialtracking and reporting software systems, health and life science software systems, and web sitedevelopment.

Board Ombudsman RepresentativeQualifications - extensive experiences in medical non-profits and representing the non-profit topatients, the state, financial, insurance and regulatory agencies to act as the ATe's ombudsman

Ms. Lawrence has 40 years experience working with the American Red Cross and other blood supplyand processing agencies. She has worked directly in operations as well as financial and insurancecomponents. She is currently the Principal Investigator, Investigations &Resolutions, Quality &Regulatory Affairs of the American Red Cross BioMedical Service Headquarters

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Board Pharmaceu tical Research Adviser - non-voting positionQualifications- extensive experience in pharmaceutical research and development to aid in thedevelopment of neW forms of non-smoking cannabis administration

Mr. Cohen is the founder and CEO of Summit Biosciences. Before Summit, Mr. Cohen foundedandmanaged a number of pharmaceutical firms, including Barr Laboratories, which currently hasover 3billion dollars in annual sales. Summit and his previous company, Intranasal Therapeutics, havedeveloped a number of systems for delivering medication intranasally, where medications canbeabsorbed directly into the blood stream as quickly as by smoking. If the state approves, Mr. Cohenwould work with the C4 ATC to develop delivery methods for cannabinoids, including a 50:50CBD/THC ratio cannabinoid extract similar to the British Sativex. The C4 would make theseapproaches available, with state permission, to other non-profit ATCs in New Jersey while Mr.Cohenwould try to develop a national market via Summit Biosciences.

StaffCEOlManager - half time, initiallyMr. Rosenfeld as described aboveMr. Rosenfeld will loan his time for the first several months of startupAssistant Manager - half time position, will loan time for first several months of startupRequirements - Aids in the production and distribution of the cannabis, as well as handling patientcontacts and records, assisting patients with their medical needs and aiding potential collectivemembers with the state registry and informing them of legal issues. Experience in horticulture andrecord keeping required.

Ann Babb

Ms. Babb has had many years experience in helping individuals navigate state and federal medicalentitlements and private medical insurance. She is an expert gardener with over 30 years of experienceand is a certified Rutgers "Master Gardener" and has training in green house systems, organics andintegrated pest management. Ms. Babb has significant experience in office management. Ms. Babb alsoholds an MFA.

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Support Staff - hourly positionsInitially two part time positions. The number of positions will group as the ATC growsRequirements: Aids in operation of the ATC and dispensing. Duties include hydroponics management,computer operations support, record keeping support and general labor. Some experience in computersystems preferred. College degree preferred. Must not have any drug or felony convictions, ormusthave an exemption from the state.

Chris Geigel

BS, ComputerSClence, experience web design and IT

Samuel Creveling

BS, Science, currently working as IT consultant

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Measure 7: Disqualifying Drug OffensesAll members of the board and staff have been queried as to whether they have any disqualifyingoffenses.All have stated that they have not:

1. Been convicted of any controlled substance violations2. Been convicted of any felonies3. Ever provided any false or fraudulent material in any application for drug manufacturing or

distribution.Ed Cohen, our Pharmaceutical Board Adviser, has decades of experience in the manufacturing of drugsand in the licensing and handling of controlled substances via his pharmaceutical firms. See his resumeunder his board position, above.No board member or staff has any experience in the manufacturing or distribution of illicit controlledsubstances.Dr. Diaz, our Medical Board Officer, is currently in compliance with his medical licensesThere are no other factors, currently known, that might be of interest or relevant to DHSS.

Measure 8: CreditorsThe proposed ATC is being financed by business loans offered by members of the Board. Itwill be athree year business loan with interest paid over this period consistent with typical unsecured businessloans.

~o.~o.,~of the loan held by various board members is:

Total -100 %

Measure 9: Persons or Business Entities Having Direct or Indirect Authority Over theManagement or Policies of the ATCManagement and Policies of the ATC are fully controlled by the C4 Board and the CEO

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Measure 10: Persons or Business Entities Having an Indirect Interest in the ATeNo persons or business entities have an indirect interest in the C4 ATe. Once our lease is secured, thelandlord will not have an indirect interest in the ATC beyond receiving monthly rent as defined in ourlease. Information on the commercial landlord will be provided to DHSS if this is required.

Measure 11: Cover SheetA cover sheet signed by the C4 ATC CEO, Mr. Rosenfeld, is at the beginning of this document. ThePDP version is not signed.

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Criterion 2 - ATC Operational InformationMeasure 1:Operational ManualA draft of the C4 Operational Manual is in Appendix GMeasure 2: C4ATe Long-term Basis Not-For-Profit Entity Business PlanOverviewThe C4 ATC plans to operate as a true non-profit. There will be no ownership or "interests" held in thenon-profit other than the holders of our business loans. In general, banks and other such agencieswillnot offer loans to non-profits due to lack of capitalization. Therefore, we secured loans fromindividualswhich will be described below.In developing our business plan we analyzed the expected number of patients over time basedon theexperience in other states and by mapping the current qualifying New Jersey conditions tothosestates.We found that the initial numbers are likely to be quite small compared to what has been seenin otherstates. See Appendix I at the end of this document for our analysis. The numbers might beevensmaller than estimated due to additional restrictions in the New Jersey law not found in otherstates,such as restrictions on patient-doctor relationships in recommendations, physician registrationrequirements, limits on cannabis strains and potency, as well as the ATe requirements that elevate theprice of the produced cannabis, pushing prices towards black market levels.Additionally, the qualifying condition restrictions indicate that the majority of patients will be ondisability or have only partial employment. This means that an ATC must attempt to keep theoverallprice of cannabis as low as possible because it cannot, while maintaining long-term financial viability,totally subsidize the cost of cannabis to low-income patients. The normal tactic of charging morefinancially secure patients higher prices to allow lower prices to indigent patients may not workdue tothe relatively low numbers of financially secure patients, at least not without charging priceswellabove black market levels to those patients. Of course, donations to the non-profit can be usedto helpoffset the price of medicine to indigent and lower-income patients, and we will have a non-profitexperton our board to work on securing donations, but they cannot be relied upon at this time.Because of our concern about keeping the price of the medicine as low as possible, we are takinga"right size" approach, meaning the facility will be no larger than necessary at any time.As shown below, our initial average cannabis price is expected to be around $150/ounce basedon ourestimated cost or production + cost of operation + a small charge to allow for future growth withoutsignificantly increasing the ATC's debt load. Our long-term goal is to drive this price to below$100/ounce as we grow to our final size. We can do this because the size of our fixed overheadcostsand debt load become less significant with size.Our analysis of patient numbers is an estimate. There is considerable uncertainty to this number.Forinstance, if the state registry does not have the capability to handle the total number of registries,thenumbers may grow slower. Also, due to a higher population density in the northern section ofNewJersey, it is likely the northern ATCs will have more patients than the central or southern Arcs. Variousprogram delays and or state challenges to the regulations are likely to occur and slow down thegrowth,

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and so on. Eventually, the state is likely to add new conditions that will stimulate the number ofpatients, and so on. So our approach is to be extremely flexible, starting small and tracking numbers,being able to increase production dramatically ifnecessary. Our initial available finances w i l l allow thisand we have oversized our expected building square footage and tools to allow this.But for the purpose of the presentation, we will use those estimates which are:Time Patient Numbers6 months12 months18 months24 months

200400650900

We do not expect significant growth after 24 months as it is likely that New Jersey will beginto licensefor-profits ATCs at that point.We expect that most patients will not use the maximum allowed cannabis per month of2 ouncesbutsignificantly less. Assuming a "uniform distribution" of patient needs, the average wi 11be aboutoneounce per patient. So the number of patients will equal the number of ounces needed to beproducedeach month.However, we have not taken into account potency restrictions, which may drive up the amountperpatient. From a business plan, this may not matter if we are allowed to grow more potent strainsandthen blend the flowers with the slightly lower potency flower trimmings (normally not usedorconverted into extracts for foods and tinctures but typically equal in weight to the flowers) to achievethe required THC level, as this will increase our yield per square foot at the production facility.We have also not taken into account the additional income. from lozenges and topical applications thatare allowed under the regulations, which also typically use these trimmings. To be conservative, we arebasing our financial plan, and price to patients, purely on flower production.Based on these numbers, we have sized our facility to be able to handle a production of just around1000 ounces of flowers a month. This is so the facility will not have to be relocated during thegrowthphase of the ATC. However, we are using a one-ye~r lease for flexibility. If it turns out we haveunderestimate our production needs, we can transition to a much larger facility. Our chosen location inPennsauken is ideal for this as there are a number of facilities with very similar layout to oursbut largersquare footages to choose from. All are located in an pleasant industrial and business park thatwillappeal to patients but are not located near to any schools, retail districts or residential homes.

I the amount and source of the equity and debt commitment for the proposedATea. The immediate and long-term financial feasibility of theproposed financing planOur basic plan, outlined below, is for a debt load not to exceed $180,000. This debt would peakduring

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the first year of operation and then gradually reduce. This is the amount we currently have setupasloans to the ATe.However, two of the individuals making the loans have considerable additional assets that theywillconsider loaning if needed. These loans would require advance notice of about two months toallowtheconversion of stocks and/or laddered bonds to cash.b. The relative availability of funds for capital and operatingneedsAll assets to be loaned to the ATe are currently held as cash and/or stocks and bonds in the individual'sinvestment accounts until needed by the ATe

............ In cash for an immediate initial ATe loan.in funds that he can make available within two weeks of request

~ available within several weeks of a requestIi...~vailable within several weeks of a request with two months notice to allow her to convertassets to cash6._ ..; 2.3 &convert Investment assets to cash &. I I I T h with several months notice to allowher to

So total funds available are approximately $280,000 staggered over a period of several monthsThis money would be made available as (up to) 3-year business loans to the ATe at interest ratesthatare typical for non-capitalized moderate-risk business loans for businesses with limited collateral.

c. The alJl-"........See above.financial statements to the state, if necessary, to document thethis time.

said they will makeavailablehas not been askedat

II Proposed policy regarding charity care/servicing indigent patientsInitially, the ATe plans to use a sliding scale for the price of marijuana which charges indigentpatientsY :z the price charged patients with income 4x the poverty line. Patients must provide income taxreturnsto document income to be eligible.Initially we do not believe we can offer indigent patients free or very low-cost cannabis andremainfinancially viable due to the expected large number of patients on disability or very low incomedue tothe types of conditions approved for medical marijuana. A large majority of patients with theseconditions are unable to work.We will review this policy as we start registering patients and get a better idea of actual incomesandability to pay. Our financial officer has an extensive background in non-profit fund raising andwill belooking to initiate fund raising for indigent patients as another approach, but this will likely takea

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while. Any funds made from our medical delivery devices will also be used to subsidize patients.III Proposed policy related to disposal of returned or unusable marijuana.Packaged marijuana returned to the ATe in the original, unopened package will be re-entered into theATC's record system and be made available for redistribution. Patients can receive a refund. Openedcontainers of marijuana that are still apparently undisturbed will be examined and/or tested andifdeemed still usable will be sterilized and used for process cannabis products such as lozenges andtopical agents allowed by the regulations. Patients will receive a partial refund.All other cannabis returned in unusable condition and unusable cannabis generated by theATCthat isunusable due to fungus, contamination, plus unusable cannabis from harvesting such as fanleaves,stems and roots, will be collected and destroyed by incineration. We are inquiring with thePennsaukenpolice as to the best and preferred method for incineration. We are considering using the methodthepolice use to destroy illicit drugs to destroy all the unusable waste, but the quantity of agriculturalwaste generated by the ATe may be too much for this approach. One approach would be toseparate the"high quality" waste - flowers and trimmings and other waste that might appeal to recreational users -from the waste flow and directly incinerate these materials via the police method and then to take themore low level waste - fan leave, stems, roots, etc., that have no appeal as recreational drugs- to acommercial incinerator for disposal. Transportation to the incinerator would be via a locked area in anATe vehicle with an escort by our uniform guard. We expect to hold waste at our facility andmove itfor disposal roughly monthly. "High level" waste would be held in a lock cabinet in our lockedofficein our production facility where we also hold processed cannabis awaiting distribution it'samount/weight would be tracked by our record keeping system until it was released for disposal. Low-level waste would be bagged in labeled bags and held in a waste area of our production facility.Itwould also be weighed and tracked, but by disposal bag.IV Projected Income Statements for the First Three (3) Years of Operation.The following is based on patient numbers and medical marijuana sold as described above. The(average) price of marijuana varies each year as it is set by expected costs of production andoperationwhich will gradually fall until the ATe reaches steady state. Our maximum debt load in thisanalysisnever exceeds approximately $150K. Sales tax, if required, is not shown in the revenue. Because ourfocus is primarily patient medicine and care, we have not yet developed a plan for other revenuesources but will likely offer vaporizers and other preferred medical delivery systems to patients, sold atcost, so these items will not impact revenue.Packaging assumes that most cannabis will be dispensed in 1 f 4 ounce units. If dispensed insmalleramounts, costs would go up.Testing includes the cost of testing the cannabis for mold, bacteria, etc., to be done by EMLabP&Kwithin New Jersey. There are currently no commercial labs within New Jersey that test for levels ofcannabinoids, so we will be performing these tests internally using strip tests on averaged lotsofcannabis. Eventually, as part of our medical research, we plan to purchase a gas chromatographyequipment and do professional level testing in-house, and to offer this service to other ATCs.Salaries include payroll taxes and benefits. We are forming a group medical plan to employees and willcover part of the cost for those employees who sign up. Salaries assume all employees takeadvantageof this program.

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We will be constantly increasing our employee numbers as the ATC grows. The Full-time equivalentemployee count is given for the number of employees at the end of each period.The security guard listed below is a.niformed guard hired through a professional serviceused~nd is not an employee of the ATC. The guard will not be permitted into anya~;~~ann;bis is stored, displayed or grown.Bad debt is not shown as we will not be loaning money or directly selling marijuana at credit.

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I Ramp Up Year2011 First Full Fiscal Year IecondFullFiscallI (April-December) 2012 I Year (steadystate) II - ~ ~ _ _ _ ~ _ . ~ ~_ ~ ~ _ _ _ _ _ _ _ ; _ _ ~_ __ _ _ j _ 2 ~ _jI REVEN~:~ces sold ~~~---~31-9-------I-16575 -t-0675 _ = - -I - Average Price per ounce $150.00 I ~$.71_.21_3_,02050.00 $$98950.0,0075.00 I!M;dical MarijuanaS~i~s- $197,850.00 t-:--I Other Revenue Sources T~B-D--------I TBD TBDI TOTAL REVENUE $197,850.00 ~:~~~$723,250.00 __~50,075.00~_-=I If-------~-----+------ ~---~~-+---------- f---~~~ I

$430,540.00~jl$36,000.00

$294,971.00$16,500.00onsumables related to growing $10,500.00

$89,503.00EXPENSES:f---------------~~-~~~-~~~-f_------Payroll with Fringe and Tax

Medical Marijuana Testing $4,000.00 $15,000.00 $18,000.00 !Medical Marijuana Packaging 1$65,750.00 $106,750.00 I~~ndLabelingi Technology Services $9,000.00 f$12,OOO.00 $12,000.00-I Security Guard $1O,OOO-._O-O_-_-_-_.~-+__120,000.00~_ -------+-$-20-,-00-0.~00= 1

c-r_~-~c-fiu-:e-it~-x-~-:-:s-i:-:r~-i~n=g==-~-~~~--~-~~~-~~-__+~--~:~-:-~~--_:~_~ J I _ i _ i _ ~ : _ ~ _ ~ ~ _ : _ ~ ~ _ _ _' : : ~ : ~ ~ ~ ~ ~ - - -Utilities $40,500.0__ -I-$_6~1,500.00 $ 120,000.00_ ~Insurance $9,000.00 $12,000.00 $12,000.00 [~an p;i~~~i~a_l_a~_d_n_te_r_es_t_ r_$-6-,0-0-0.-0~0~~~-~_----l-1-$8-7,000.00---- $-8-7,-00-0.0~0~_- i~qUipment (depreciate_d)_ --i ~5___,5_0_0_.0_0_~_~__1$46,500.00 $0.00iLease $33,000.00 I $44,000.00 _~_~ $44,000.00~uildin-g.~~.Modifi-cations $15,000.00 1$0.00 $0.00_

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Ir-T-m;~-~-~-~b-~-x-S-PE-N~S-E-S-:---+;-:-:-8,-19--3_._0-0 1--1~_:9_~_,2_2_1_.O_0-_-+_;9_Bl_~~_,2_0__0_:_~_~_jI Difference: -$110,343.00 $26,029.00 $36,785.00 JINumber of Patients (~nd of 300 -----+7-7-5 _ 1900 .--- II-~-e~~--:-~r-o-f-V~-is-its-(-t-o-ta-I-p-e-r~-+-1-31-9-(-a-ss-u-~-e-son-e-~-is-it--+-65-7-5---- 1067_5_- _ 'I.period_) _ _ _ _ l _ ! ::_pe_r_m_n!_~ __~ ~_~~ _

$13,190.00

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Full-Time Equivalent Employees,------~-----~,--------------,-------------~--------~_----~--------------- __I i Salary of Category Ramp UpYear First Full Fiscal Second FullFiscalI ] with Fringe 2011 Year 2012 Year 2013~ benefits-----+-'IPceartSeOgnOnrye~1- - f I --- -- I~FT-O-Ef-~p-ay-r-Ol-l--i-#-OfPayroll # of I Payroll

with fringe I FTE I with fringe FTE with fringe I .and taxes

d $101,9JJI01,90000L 1$101,00000$33,850.00 0.5 $33,850,00 0.5 _. I $33,850~

__l__ _ _ _ j _ _ 6 ' _ s l $254,800,007.5 '$294,000.00:I CEOlManagerI Asst. Manager,Hourlyr - - - - - - - - -L_

at endof

I perio$90,000.00 1$60,000.00 0.5$35,000.00 1.5

iNote - the number of "hourly" employees will be increasing during each period. The FTE listed is forthis category at the end of each fiscal year. The payroll with fringe benefits and employer-responsiblepayroll taxes is for a payroll as if they had worked at this level for an entire year. Also, theManagerand Assistant Manager will be loaning their time during the first few months of operation tokeep thedebt load down. The numbers shown is their payroll, with fringe benefits and employer with-holdingtaxes as if they had worked at their FTE for an entire year.The numbers used in the earlier Projected Income table are for the actual payrolls during eachfiscalperiod, and take into account employee ramp-ups during each period. A spreadsheet showing monthlypayroll, expenses and income is available upon request.These charts do not take into account any cost-of-living increase during this period. Currently, it is notplanned to supply cost-of-living increases or raises during this period.We had planned to add a higher labor category with more training and responsibility ( suchasopeningand closing the facility) but have not completed the spread sheets at this time. This sub-category wouldnot significantly impact the financial analysis.

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Measure 3: Experience running a not-for-profit organization or other businessMr. Edwin Cohen, our board Pharmaceutical Research Advisory, has decades of experience asCEO ofvarious pharmaceutical company and also with university pharmaceutical research programs. Ms.Carol Babb, our Financial Officer, has years of experience as a non-profit manager in variousmedicaland other non-profits. Mr Rosenfeld, the CEO, has decades of experience as a program leadof largeaerospace programs. Ms. Lawrence, our Ombudsman, has years of experience in dealing withmedicalnon-profit regulations via the American Red Cross.

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Criterion 3: Community InputMeasure 1: Input from the city(s) or town(s) where the applicant's ATewould be located.Two communities responded positively to our request to develop an ATC in their community:Gloucester Township and Pennsauken.Pennsauken was selected as the better location due to their very large business/industry districtswith alarge supply of rental buildings that provide ideal isolation from drug-free school zones andresidentialareas. The following describes our process with Pennsauken.

1. A series of emailswere initiated with the Director, Mr. Terry Carr, and assistant director,Mr.Larry Cardwell, of the Pennsauken Economic Development Department regarding thesuitability of Pennsauken for an Alternative Treatment Center and whether there wouldbe anyobjection to such a business.

2. A proposal describing how the ATC would operate and that we would locate in oneof twobusiness/industrial zones was was sent to them. They felt, in general, that it could beagood fitand the zoned business/industrial areas in Pennsauken were a good choice. The policeand othergroups in the city administration came back with no negative responses.

3. The C4 ATC board members were then invited to a meeting with the Economic DevelopmentDepartment were we gave a formal presentation and had a question and answer period.Issuessuch as whether production and dispensing were both OK in the township were discussed aswell as whether the zoning would allow dispensing from the same location as the productioncenter. The Economic Development Department then suggested which real estate owners"Wouldmost likely have the needed sites to lease.

4. After our meeting the Economic Development Department submitted our request andpresentation to the Township committee who reviewed and approved our proposal. Wehavesince been in contact with the township regarding zoning and other issues.The email concerning the decision is reproduced below:

project decisionT Add toFrom: erry ContactsTo: Carr _.us>Mr. Rosenfeld,This is to confirm our conversation this afternoon. Yourproposal was presented to and discussed b y ourAdministration.You have receivedthe go ahead to proceed with the approval process through the State and theTownship tolocate the business in Pennsauken.We have alsoordered the map you requested and will notify you when received.

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Thank you.Terrence Carr & Larry Cardwell

Measure 2: Input from the general public regarding the suitability of theapplicant and the general standards for location(s) such as, distance froma school, daycare center or other child-oriented location; distance from acommercial shopping district, pharmacy; etc.The township committee which reviewed and approved our location proposal are representatives of themembers of the community. The committee includes members who have served on the Pennsaukenschool board, are teachers in the township, been a volunteer fireman in the township, a memberof thePennsauken Youth Athletic Activities (PYAA), and township business men. They thus representa goodcross section of the community. The mayor is also the Director of Public Safety and thus representedthat viewpoint.Additionally, the proposed sites are not near any retail, residential or schools, day cares, etc.,so it isunlikely community members associated with these situations would object. The proposed siteissomewhat isolated from the rest of the community as it is surrounded by major highways andtheCooper River,The location is well-suited for an ATe. The nearest school in the community 0.8 mile away,BishopEustace Preparatory. The nearest day care that we can locate is El Shaddai Christian Day Care0.8 milesaway. There appears to be no child-oriented centers nearer to the site. There are various stripmalls onthe nearby Route 130 and State Highway 38. The nearest retail store, on State Highway 38 , is aDunkin' Donuts perhaps 1000 feet away in a straight line but about 0.8 miles away by car due to thecomplicated highway interchanges in the area. And the nearest pharmacy is Browning RoadApothecary, about 1000 feet away in a straight line but 0.8 miles away by road. A CVS is neartheApothecary.

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Criterion 4: Dispensary specific considerationsMeasure 1: Inventory, record keeping and security in terms of the Federal Health InsurancePortability and Accountability Act of 1996, as amended [HIPAA].A computer file will be kept on each patient that contains his state medical marijuana registrationinformation, his physician certification, the physicians instructions for dispensing cannabis tothepatient, the date, amount and type of cannabis dispensed to the patient, as well as lot number and otherinformation identifying the individual medical containers dispensed, any instructional materialhandedto the patient, issues raised by the patient in counseling, and any feedback from the patient regardingefficacy and side effects.This information will be stored in a password protected database with a system able to acceptpasswords up to 30 characters long. Each employee who is to enter or read data from the databasewillhave a separate password. The passwords will change on a regular basis with one person, thesystemadministrator, in charge of assigning initial user names and passwords and resetting passwords.A locked screen saver will appear on each database computer ifno activity occurs for a specifiedtime.A program will run on the database network that maintains an audit trail of users, noting whenthey logon/off and what patient data that they modify. This activity log is maintained per workstation and canbe viewed on the Work with Databases screen by clicking on the "View" item on the top andthen on"View activity log files". The activity log contains the activity for one day. Each day starts a new logfile on the workstation.When cannabis is dispensed to a patient, the container will be bar-code scanned twice, oncefor thepatient database to show which container was dispensed to that patient and again to remove thecontainer from the cannabis inventory system. These two databases are on different computer systemsto prevent leakage of patient information into the less secure cannabis production and trackingdatabase, while still allowing a traceback to the patient if a need occurs.The ATe awaits instruction from NJ DHSS as to the proper way to transmit required information to theDHSS to protect patient privacy .. If done electronically, an encrypted method is recommended.An area separated from the patient waiting area will be used to counsel patients, discuss theirconditionand the strains of cannabis, the best way to use cannabis for their condition, and so on.HIPAA privacy protection and procedures will be part of all employee training.

Measure 2: Program for providing counseling and educational materials regardingmethods of administration and research studies on health effects ofmedicinal marijuana for registered qualifying patients and their registeredprimary caregivers. Also the historical historical relationship with clinical or researchactivities of the ATe.

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The ATC will develop a web site that contains information on how to become a medical marijuanapatient, approved medical conditions, the latest peer-reviewed studies on medical marijuana includingtreatment benefits and side-effects as well as short- and long-term effects of use.Patients can download this information for discussion with their physician.Information will be available describing different modes of intake, how to safely titrate for eachmode,adverse effects due to improper titration, what to do when adverse effects occurs, and when tocontact adoctor. The risk of mold spores and smoking whole marijuana by people with weakened immunesystems will be reviewed. Best methods of administration for people with COPD and asthma willbereviewed, as well as counter-indications for various conditions.This is an outline of the information and is not a complete list.Hard copies of this material will be available at the ATC for patients who do not have computer access.When medicine is dispensed, a pharmaceutical literature packet will be attached to the bag thecannabiscontainer is placed into, similar to the literature pharmacies attach to dispensed medication. Itwillhavethe patients name, doctor's instructions, amount dispensed, how much is left in the current setofdoctor's dispensing instructions, a brief overview of use, conditions it is used for, titration andsideeffects/adverse effects.When a registered patient comes to the ATC to discuss and select medication, trained employees willtake the patient to an area separate from the waiting room, for medical privacy, and discuss thestrainsof cannabis the ATC carries, the different modes of administration, titration, side-effects, adverseeffects, etc., and answer patient questions. They will state that certain modes or administration are notsafe for, say, people with active AIDS and weakened immune systems, and recommend alternativemethods. All the information will be based on peer-reviewed scientific literature. A training manual forcounseling employees is being developed from the same material as will be available to patients,butwith more detailed scientific information.Research History - Mr. Edwin Cohen has decades of experience in pharmaceutical research. Hiscurrent company's web site has more information:http://www.summitbiosciences.com/management.htmlMr. Cohen will be advising the C4 ATC as we carry out our research in developing methods ofcannabis administration and studying the effects of high CBD-to-THC ratios, if this research ispermitted by the state. He also hopes to build relations with local universities and hospitals viathe C4ATC to further his ongoing research, development and testing of intranasal cannabinoid deliverysystems.

Measure 3: Safety and security plan, including staffing and site, and a detaileddescription of proposed security and safety measures which demonstrate compliancewith the Rules Related to the Medicinal Marijuana Program.

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Measure 4: Separate LocationsThe C4 ATC does not, at this time, plan to operate its dispensing and cultivation at separate locations. Ifthis would change, the C4 ATC would resubmit a plan as well as appropriate fees to the state.

Measure 5: Description of its Medical Advisory Board and By-LawsThe members of the Medical Advisory Board are:

1. Medical: Jefferey Pollack, MDDr. Pollack is a practicing internist in Mays Landing, NJ. He has a long involvement in thedevelopment of the New Jersey medical marijuana law and is knowledgeable in the medicalresearcd on medical marijuana.

2. Medical: Cathy Corson-Diaz, MDDr. Corson is a practicing family medicine physician and also an expert in aesthetic medicine.She practices in Sewell, NJ

3. Medical: Maria Cram, M.A.CCC-SLPMs. Cram is a certified medical therapist who practices in the Long Branch, NJ region. She isinterested in seeing that patient needs are met and in being the local community liaison.

4. Patient: Jennifer LandeMs. Lande is a patient with muscular dystrophy and other qualifying conditions who hastestified several times to the New Jersey legislature on medical marijuana. She lives inMarlton, NJ, an area in the proposed C4 coverage area. If Ms. Lande is unable to be aregistered patient with the C4 ATe, the C4 ATC will make recommendations for other patientsto the Medical Advisory Board.

S. Business: Mr. Bill ScaliaMr. Scalia is the owner of a gym and physical rehabilitation center in Haddonfield New Jersey.

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C4 MEDICAL ADVISORY BOARD BYLAWSI. Propose of OrganizationThe purpose ofthe board is to observe and advise the C4ATC regarding the production and distr ibution ofcannabisoeligible patients under New Jersey statutory law Chapter 307, the "New Jersey Compassionate Use Medical Marijuana Act"and as regulated by the New Jersey Departntnt of Health and Senior Services. They should observe and adviseo improvepatient care and community interactionII. Board of Directors

1. The Medical Advisory Board shall serve without pay and consist of five members, all New Jersey residents.2. Three members shall have backgrounds in medicine, with at least one member being a practiCing physiciann New

Jersey. One member shall bea patient who is registered with the C4ATC and one member a businessmanin thesouthern New Jersey region,,3. Board members shall serve one two year term, butcan be asked to serve multiple terms.4. Vacancies shall be filled bythe Board, with the recommendation of the Executive Director.

III. Officers1. One member shall be selected by the other board member as the chair who is responsible for headingmeetings and

calling for votes2. Another member shall be selected as the board secretary who is responsible for recording the minutesofmeetings.

IV.Meetings1. Meetings shall be held four times a year to correspond with the C4 ATC quarterly filing dates on thefirstSaturday of

the month associated with that quarter. Attendance can be by teleconfence.2. Special meetings may be held at any time when called for by the Chair or a majority of Board members.3. Agendas shal l be provided at least 3 days in advance.

V. Voting1. (a) A majority of board members constitutes a quorum. (b) In absence of a quorum, no formal action shallbe taken

except to adjourn the meeting to a subsequent date.2. Passage of a motion requires a yes vote by at least two thirds of those present.

VI. Conflict of Interest1. Any member of the board who has a financial, personal, or official interest in, or conflict (or appearance ofa conflict)

with any matter pending before the Board, of such nature that it prevents or may prevent that memberfromactingon the matter in an impartial manner, wil l offer to the Board to voluntarily excuse him/herself and willvacatehis seatand refrain from discussion and voting on said item.

VII. Fiscal Policies1. The MedicalAdvisory Board will not receive payment for its participation in meetings, although theymaybe

remunerated for expenses related to travel and other incidentals. This remuneration will be supplied bytheC4 ATewith the approval of the ATCCEO.

2. The MedicalAdvisory Boardwill not acquire assets or funds beyond a petty cash fund for incidentals suchas officesupplies.

VIII. Interaction with the C4ATC

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1.The Medical Advisory Boardwill attend a presentation by the C4ATC quarterly onthe same dateastheC4 ATehas it's quarterly board meeting. The date will be the 1" Saturday in each fiscal quarter unless otherwisespecified.- in this presentation, the Medical Advisory Board can ask questions, ask to see financial records, tourfacilityareas(within the boundaries of state law), etc. However, the meeting cannot exceed three hours for practicalreasons.2. The Medical Advisory Board will prepare a presentation for the C4ATC Board- The presentation will include concerns about operational, procedural and other concerns, as well asrecommendations for corrections

IX.Amendments1. These by-laws may be amended by a two-third vote of the entire Medical Advisory Board. A copy oftheproposed

amendment(s) must be provided to each Board member at least one week prior to said meeting. Thiscopycan besent electronically to the registered email address of each board member.

Measure 6: Plan to track and analyze data related to patient outcome, utilization,trends and other issues

Records will be kept that track and estimate the utilization of the various strains/strengths ofmarijuanaflowers used and the amount of lozenges and other allowed forms dispensed. A sliding average linearfit to the consumption levels will be made and extrapolated four months pass the current dateto predicthow much and which types of cannabis should be started for four months later. Four months is theapproximate time from starting to finishing of the cannabis.

The information for the utilization will come directly from the cannabis tracking database.

The patient dispensing database will also be processed to generate overall trends in cannabis utilization:a histogram of amounts of cannabis dispensed per visit and per month to patients, a histogram of types,correlation between type and amount, as well as analysis to give the mean and standard deviation ofthese amounts.

Patients will be asked to fill out a form each month about how the cannabis has worked for theircondition, adverse effects and other information. This will be voluntary. Patient doctor's w i l l also beprovided with similar forms that they can fill out with patient permission and within the H I P A Aguidelines.

Quarterly reports of this information will be produced, for presenting to the Medical OversightBoardand made available to the state.

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._ ..... ., .. _ This will beconducted when we take po of the facility and any problems rectified. We will also be addedadditional AC systems to the cultivation area and will ensure they do not give visual or visual access.

Measure 3: Providing a steady supply of medicinal marijuana to registered qualifyingpatients.I. Start-up timetable

I.Week 0 - issuance of authorization2.Week 0-3 - equipment and root stock purchased2.Week 4 - electrical, secutiy and other modifications complete,3.Week 5 - Cultivation Begin4.Week 15 - Modest amounts of auto-flowering cannabis available5. Week 19 - Initial crop of phtotperiod cannabis available plus auto-flowering6. Week 23 - 2nd crop of photoperiod cannabis7. Week 27 - 3rd crop, etc.

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Cash funds for the initial period of operation are available in a checking count for use by theATC.Initial staff is available for setup and cultivation. We also will have crop loss and other insuranceaspart of our business insurance and liability packet from Statewide Insurance Services, Inc - MMDSpecialty Unit to ensure we can quickly get back to cultivation if a disaster does occur.We believe it will take two weeks to secure the lease on our building. We have a carpenter whois oncall and can begin work as soon as the building is available. The security company will havea walk-through as soon as we are approved and put together their plan to implement as soon as the building isavailable. Same for the plumber and electrician. The building already has adequate electric service andis almost ready to go "as is". We will simply be installing another set of circuits and outlets fora betterlayout of the cultivation facility and some simple modes for better security and operation. Noneof thework expected is significant or complex and is estimated that each area: carpentry, security, plumbingand electricity will take only a few days each.a. Carpentry - this is the most demanding area, requiring the building of a partition wall andframeworks for light supports. Estimated time to completion < 2 weeks. Carpenter is on call tobeginimmediately upon lease

c. Plumbing - addition of a processing sink and tank room intake and drain. Estimated time to completeis two days.d. Electricity - additional circuit for backup power system and about 10 20 amp outlets. Estimated timeto perform work is 1 week.Other needed work, such as additional venting systems, AC enhancement and backup power, will beadded after the system is up and operating.Equipment and stock will be acquired during this first month of building acquisition and mods. Wewill be using a hydroponic method that can be quickly set up and tuned. It is also partially automated toreduce labor start-up problems. We will start cultivation immediately. If no patients are registered atthat time, we will estimate the expected number of patients who will need dispensing over time. Seeour business plan and Appendix I for these estimates.Cannabis is normally a photoperiod plant that begins flowering based on daylight. The strains we willgrow long-term are all photoperiod plants that we will propagate from cloning. The time fromclone todry, processed cannabis is approximately 14 weeks for most of these strains. But to get cannabis topatients as quickly as possible we will also be starting "auto-flowering" varieties that can be ready foruse within 9-10 weeks. They will be making use of unused "flowering" equipment as our photoperiodcannabis is proceeding from vegetative to flowering stages.The yield of these auto-flowering strains is generally low and they cannot be cloned. We will needpermission from the state to grow these additional strains ( due to the three strain limit). These strainswill only be grown twice to allow quick distribution to patients and thereafter not used.We will be growing in a continuous yield arrangement, with one crop in vegetative growth while twocrops are in different stages of flowering. One crop will be harvested every month, allowing acontinuous yield once the process is started and has reached the first harvest.The actual amount grown will be determined by the number of patients already registered or our initialestimates. But after week 15 we can easily double production every 14 weeks to meet patient demand,

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up to the maximum capacity of the facility and our ability to hire and train staff. Our cash-flowanalysisindicate we have enough ready funding to rapidly grow in this manner up to the facilities maximumcapacity.II. Knowledge of (and experience with) organic growing practices or agricultural growing practices tobe used in their cultivation of medicinal marijuanaOur Assistant Manager is trained in organic growing practices and is a Rutger's "Master Gardner"trained in greenhouse integrated pest management practices. Our CEO, Mr. Rosenfeld, isaknowledgeable hydroponics and lighting engineer who has designed several types of hydroponicsystem. Both are experienced gardeners of mid-size crops other than cannabis. Mr. Rosenfeld hastaken training in cannabis cultivation. Dr. Diaz has taken training in commercial cannabis growing. Weplan to consult various groups as needed, including the Camden County Rutgers Extension Agents.

III. Quality control program and steps that will be taken to ensure the quality of the medicinalmarijuana, including purity, potency and consistency of dose.Agricultural practices will be taken, to ensure that mold and other organisms do not develop in thecannabis. This is primarily down by maintaining adequate ventilation and controlling humidity.We willalso be maintaining the grow areas at a slight positive pressure and used filtered air intakes tominimizeincursions of spores and insects. Street shoes, which can track in spores and bacteria, will notbe wornin the cultivation area. Plastic gloves will be worn when processing the cannabis.We will be testing each crop of cannabis for unacceptable mold and bacteria levels and alsomeasuringTHC and CBD levels. Once our clones are established, the potency levels of the cannabis willbe veryconsistent from crop-to-crop.

IV Detailed DescriptionsDMethods to ensure that seed production and/or hybridization is prevented during cultivation ofmedicinal marijuanaWe will be using "feminized" seeds that produce only female plants. We will be developing cloneproducers ( "mother plants") from selected phenotypes of the initial seed grown plant. The"mother"will, of course, be female. All clones taken from the "mother" will also be female. No maleplants willever be in the facility unless, at some much later date, we begin a breeding program. Such aprogram, ifapproved by the state, would take place in a separately vented and closed area. But we haveno plansfor such a program at this time.

Even though we will be growing only female plants, a female cannabis plants can convert intoahermaphrodite, that is, have both female and male flowers on the same plant. This tendency is higher insome strains of cannabis which we plan to avoid. Environmental stresses can also trigger thisconditionin prone strains, especially light period changes during flowering and temperature extremes. We plan tocarefully control the environmental conditions to prevent this.

We will be doing weekly inspections of flowering female plants to check for male flowers. This shouldcatch any male flowers before they have a chance to release pollen. If the plant has just a fewmale

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flowers, we will remove them. If the female plant has a significant number of male flowers, the plantwill be removed and bagged and taken to our disposal area.

[J Methods of testing for the presence of mold, bacteria or othercontaminants

We will be using a commercial testing service branch located in New Jersey, EMLab P&K totest forcontaminants, mold and bacteria. Each crop lot - which is a particular strain harvested at thesame time- will have minute specimens gathered from each processed flower and trimmings. These will becombined and sent to the testing services for analysis. If significant levels of mold and.or bacteria aredetected or contaminants are found, we will recall that batch. Normally, the batch will be testedbeforewe release it to patients, but the first few crops may be released before testing is completed to allowdistribution to patients as soon as possible. If the state objects to this approach, we will holdthecannabis until it has been tested, but this will add 3-4 weeks to the initial release process thatwasoutlined above.[J Procedures for routine scouting of insect and plant diseaseconditionsWe will hand yellow insert traps (sticky paper traps) from each lamp over the growing cannabis. Manyspecies of white flies and other insects are attracted to the color and thus get trapped. This can actuallycontrol mild infestations. The traps will be examined weekly for signs of insects.The plants themselves will be examined at least weekly with a magnifying glass for signs of mites,thrips, powdery mildew and other common greenhouse problems so that the problem can be rectifiedbefore it becomes too extensive to control.[J Methods to control insect pests that do not include the application of pesticides during cultivation ofmedicinal marijuana, in accordance with the Rules Related to the Medicinal Marijuana ProgramOur primary method of insect and other pest control is environmental.The center will be sterilized before cultivation begins and a rigorous cleaning schedule thenmaintained. Mild plant and food-safe fungicides will be used in cleaning floors and walls. All looseplant material will be removed from the cultivation areas.The growing plants will also be trimmed to remove non-essential leaves. Any dead leaves will beremoved. This opens the plants to ventilation and helps prevents infestations.Internal fans blow on the plants. This helps strengthen the plants but also adds to the air flow, helpingto prevent various infestations.Air brought into the center will be filtered to prevent insects and larger spores from entering the center.Street shoes, which often track spores and other problems into greenhouses, will be removed at theentrance and sandals kept just for the cultivation area will be worn. A lab coat and hat will normally beworn to reduce spores from blowing off of clothes, although this will not be enforced. Air pressure willbe maintained at a slight positive value to prevent insects and spores from entering with workers. Themain door is also a double entryway door that will tend to prevent entry of insects.

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The humidity and temperatures will be maintained at levels that are conducive to healthy plants,willwill reduce the impact of mild infestations.A hydroponic method was chosen that minimize the amount of water that is evaporated intotheenvironment or liquid water that is exposed to the environment, allowing easier humidity control andreducing an infestation pathway.Peroxide and other approved agents will be added periodically to the liquid hydroponic supplythatprevents root rots and other mold infestations. The hydroponic liquid will also be cooled tohelpprevent these problems. The hydroponic tanks will be changed roughly weekly and inspected to detectany problems. If a problem is detected, in addition to replacing the fluid, the tank will be scrubbed witha plant and food safe cleaning agent and the plants flushed, before new hydroponic solution added.If an infestation becomes out of control, the infested plants will have to be removed from thecultivation area, bagged, and brought to our storage area to await incineration. In a worst-case scenario,the entire grow area would have to be shut down and sterilized before plant production wouldbeginagain.

Ms. Ann Babb, our Assistant Manager and gardening expert, is developing an integrated pestmanagement manual tailored towards hydroponic cannabis production. All methods are organicanduse food-safe GRAS methods that can be used for edible plants right up to harvest. Our methodswillbe graduated, with such methods as sulfur applied as a fungicide before new clones are broughtinto thegrowth areas. Then the next step would be agents such as Safer Soap, essentially a food gradeoilproduct, that is used to wash otfmildews and suffocate burrowing insects. Finally, various approvedessential oils such as garlic, clove and cinnamon would be used to kill infestations. These wouldnot beapplied within two weeks of harvest as they would impact the taste of the product.

This is not a complete list of materials that would be used, but give a flavor of the approach. Thesemethods have been used successfully at many organic greenhouses.

D Procedures for proper sanitation practices to minimize plantdisease, and to promptly dispose of diseased plant material in asecured disposal area

The above section described both our insect and disease prevention approach, including moisturecontrol, sanitation and other issues.Diseased and dead plant material will be bagged and moved to our storage area to await incineration.

D Methods for utilization of fans and cooling systems to maintainairflow patterns sufficient to prevent or minimize plant diseaseand insect infestation.

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As mentioned earlier, our air intakes will be filtered to help prevent insects entering through theintakes. Air pressure will be maintained at a slight positive pressure to also prevent insects andsporesfrom entering. During periods we do not need to actively heat or cool the grow area, we will set theventilation to a fairly high air exchange rate recommended for green houses of one complete airexchange a minute. Our ventilation system will be sized to achieve this. This will also helptomaintainthe temperature inside the facility to the ambient external temperature.We will be adding additional air conditioning to our grow area so that we can maintain thetemperaturebelow 85 to 90 degrees F on hot days. The lighting systems are all enclosed with in-line fansventingto the exterior to help reduce the heat load. During cooler periods, the heat from the lamps willbepermitted to dump into the grow area to help maintain temperate. A thermostat will control thelampheat dump.

Plants will be spaced far enough apart that there is clearance between plants to help allow ventilation.Dead leaves and excessive fan leaves will be removed to allow light and ventilation into theplants.Oscillating fans will be used near the plants to help strengthen the plants by the changing air flow andto provide positive air flow through the plants, helping to reduce disease.During periods we are actively heating or cooling, dehumidifiers will be used to help maintainthehumidity. Some air exchange will always occur to maintain C02 levels even in very cold orhotexternal air conditions. But the internal fans will provide most of the air flow in these conditions.

D Methods to keep environment free from flowering male plants toensure that female plants are not pollinated and seedproduction and/or hybridization is prevented

As mentioned earlier, we will be growing only female plants, initially using "feminized" seedsthatalmost always produce female plants, and them establishing female "mother" plants that wewill Use asthe source ot female clones. In spite of this, female plants can become hermaphrodites, producing maleflowers in addition to female flowers. Environmental stresses often induce this condition. Wewill beminimizing these stressors. We will also establish "mother" plants from phenotypes that showaresistance to this phenomenon.

Routine inspection for this condition will be performed. About once a week should be frequentenoughto prevent the male flowers from maturing and releasing pollen. It is a somewhat tedious taskas amagnifier is often needed to see the early males. Plants with a few male flowers will have thef lowersremoved. Plants with many male flowers will be bagged and destroy. Records of which phenotypes arebecoming hermaphrodites will be made and "mothers" producing these plants removed andreplace bymore stable "mothers" to reduce the incidence of this happening.

D Record keeping of any cultural measures used for plant pest ordisease control, including disposal of culled plants

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Plant history is recorded from cloning to harvesting or disposal. Each hydroponic pot is labeledandtracked through the entire grow cycle. A number of plants are in one line, feeding off of onehydroponictank. Information about the hydroponics used, extra additives used for disease prevention/resolution,etc., is recorded in the grow database. Any treatments used are recorded by line and pot. Thisnot onlyhelps backtrack dispensed cannabis batches but adds us in increasing quality and efficiency.

Culled plants are weighed and bagged. The bag may contain many culled plants. The bag isweightedand labeled with a number and check that its weight matches the sum of individual plants. Thetime thebag is taken out of the facility for disposal is recorded.

D The various strains of marijuana to be dispensed, and theformes) in which it will be dispensed

At this time we are informed we may grow only three strains. These strains will be chosen tohavevarious CBD-to- THC ratios, and the strains changed over time with DHSS permission. In particular wewill want to eventually grow a very high CBD strain for research, but this plant is too low yielding touse as one of our initial strains.Also, we plan to grow an autoflowering strain for the initial grow to get cannabis to patients assoon aspossible. Then we will switch to our long-term cloned strains.The initial auto-floweing strains to be grown, are planned to be:White Dwarf, Big Bang2 and LowRyder2Two crops of these will be grown while our longer growth photoperiod plants are readied fordispensing. Once we grow these two crops of autoflowerers, we do not intend to grow themagain.

Our long-term plant strains are currently planed to be:Big Bang 2The ChurchBig Bud

These have varying values ofTHC and CBD.Note - these plants can also produce THC levels higher than the state limited 10% level. Weplan toblend flowers with the trimmed leaves from near the flower to bring the THC level down, ifnecessary.If this approach is rejected, we will determine if we can get strains with lower THe levels inorder tobe in compliance.

We will be dispensing the cannabis as:

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l) blended flowers - the blending will help ensure we do not exceed the maximum allowedTHC2) lozenges - made from cannabis extract3) tincture - if allowed, a sublingual tincture is a superior form of administration, allowingmore

rapid onset than ingestion, and can also be added by the patient to food or drinks. Theregulations do not appear to allow this form, so we will inquire about this method ifwereceivean award.

4) Topical

We also, plan, if approved by DHSS and other state agencies, to perform research into newdeliverymethods, including an intranasal delivery device developed by Summit Biosciences. Intranasalallowsa rapid onset similar to smnoking and is a portable medical delivery system. We also plan, ifallowed,to develop a 50:50 CBD-to- THC cannabinoid ratio whole cannabis extract for use in this deliverymethod, vaporization and sublingual tincture. Such high CBD levels have therapeutic effectsbeyondthose ofTHC and the CBD modulates the effect ofTRC to reduce the psychoactive effects. Aproprietary strain of cannabis would be grown to supply this research.

D Record keeping for each package by lot, label and bar codeA commercial inventory tracking system will be used. We will purchase hardware and softwarefromWASP Barcode Technologies for this. Our grow records will generate a code indicating theplant lotthat a dispensed medicine is from. This code, with lot information, strain information, THe andCBDlevels will be entered into the barcoding system which will also attach date, amount and soonto thedata for the individual barcode generated for the package. The package is then tracked by thebarcodesystem until the medicine is dispensed or destroyed. The barcode will also be scanned intopatientrecords when dispensed so that those records can be searched for a particular package if theneed arises.The patient system is separated from the inventory tracking system for security reasons, but thisapproach allows easy retrieval of patient records if, for instance, a recall occurs.D Area security

Area security has been described in considerable detail in earlier sections.

D Packaging and labeling requirementsOur understanding that the state is to supply packaging. Ifnot, small, clear plastic containers with whitetwist on lids will be used, sized to hold about Y4ounce, the default dispensed amount. A sealwill beapplied to the container after the cannabis is measured, put into the container and the lid applied.

Lozenges and topicals will also be dispensed in standardized amounts in these containers.

The label will contain a bar code that ties the package into our inventory system. Itwill alsohaveprinted on the barcode label the strain, strength, date packaged, and amount.

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When dispensed, a second label will be affixed to the container showing the date dispensed, patient'sname, amount dispensed, amount left in the current physician instructions, physician's name,andbothpatient and physician's registry numbers.

The container will be put in a bag and instructional literature stapled to the bag.

o Methods of processing in a safe and sanitary mannerWorkers will wear lab coats and plastic gloves while handling the cannabis during processing.When the cannabis is harvested, each plant will have the flowers trimmed off using a mechanicalsystem. The flowers and flower trimmings will be weighed and put in a drying bin with otherflowersand trimmings from the same batch. The rest of the plant will be weighed, bagged and takento thedisposal area to await disposal transport. Information about the weight of the flowers and trimmingswill be entered into the tracking database, as well as the discarded plant residual. The flowerandtrimmings will be dried, the dried weight recorded and then the flowers cured. Once cured, sampleswill be taken for sending to the lab for testing for mold, bacterial and contaminants, and theflowers andtrimmings tested for CBD and THC levels.

The flowers will be blended with trimmings to bring the THC level down to the state required levels.

A tincture or extract of some of the cannabis will be made for use in making lozenges and, ifa llowed,sublingual tinctures. Some of the trimming will be processed into topical formulations. Thedetails ofthese tincture and extraction processes are proprietary and perhaps too long for this application but willbe supplied upon request. All materials used will be food grade and standard commercial kitchenandpharmaceutical lab equipment used.

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Appendix A- Supporting Documents of Legal Status and BylawsC4BYLAWSI. The name ofthe non-profit organization shall be the Compassion Coalition of Camden CountyII. Propose of Organization

The purpose of the organization is the production and distribution of cannabis to eligible patients underNew Jersey statutory law Chapter 307, the "New Jersey Compassionate Use Medical Marij uana Act"andasregulated by the New Jersey Department of Healthand Senior Services. The primary goal is to offercannabis topatients as as Iowa cost as possible.

III. Board of Directors5. The Board of Directors shall serve without pay andconsist of five members.6. Four members will initially have backgrounds in: medicine, engineering, IT and finance/business. Thefifthmember,

with a background in phanmaceuticals, will be a non-voting member who advices the organization.7. Board members shall serve one two year term, but can be asked to serve multiple terms.8. Vacancies shall be filled by the Board, with the recommendation of the Executive Director.9. New members of the board can be added via the board voting process.

IV.Officers3. The off icers of the board shall consist of a Chair, Treasurer and Secretary who are nominated by theBoard4. Elected off icers will serve a term of one year, except the Chair, who serves three years and will initiallyalsoserve as

the Executive Director of the non-profit.5. (a)The Chair shall preside at all Board meetings, appoint committee members, and perform other dutiesas

associated with the office. (b)The Vice-Chair shall assume the duties of the Chair in case of the Chair'sabsence.(c)The Secretary shall be responsible forthe minutes ofthe Board, keep all approved minutes in a minutebook, andsend out copies of minutes to all. (d) The Treasurer shall keep record of the organization's budget andpreparefinancial reports as needed.

V. Committees1. The Board may appoint standing and ad hoc committees as needed.

VI. Meetings4. Meetings shall be held four t imes a year to correspond with the organization quarterly f il ing dates onthefirst

Saturday of the month associated with that quarter. Attendance can be by teleconfence.5. Special meetings may be held at any time when called for by the Chair or a majority of Board members.6. Agendas shall be provided at least 3 days in advance.

VII. Voting3. (a)A majority of board members constitutes a quorum. (b) In absence of a quorum, no formal action shallbe taken

except to adjourn the meeting to a subsequent date.4. Passage of a motion requires a yes vote by at least two thirds of those present.

VIII. Conflict of Interest2. Any member of the board who has a financial, personal, or off icial interest in, or conflict (or appearance ofa conflict)

with any matter pending before the Board, of such nature that it prevents or may prevent that memberfromactingon the matter in an impartial manner, will offer to the Board to voluntarily excuse him/herself and willvacatehis seatand refrain from discussion and voting on said item.

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IX. Fiscal Policies3. The fiscal year of the board shall be January 1 to December 31.4. The board shall ensure that the organization operates as a true non-profit, with patients charged onlyanamount

derived directly from the costs of production and operation along with a small amount to be used forfutureexpansions of the organization. Financial projection can be used to make the estimates used to chargepatients withat least yearly corrections to the projections to ensure accuracy.

5. In the event of the dissolut ion ofthe organization, ifany assets remain after payment of debt to creditors,he excessmonetary assets shall be returned, on a pro rated basis (which can be roughly estimated) to the patientswho havemade use of the organization. Existing equipment, ifof significant value, can either be donated to othernon-profits inNew Jersey with similar missions, or sold and the proceeds returned to patients inthe manner describedabove.

X. Interaction with Medical Advisory Board1.The ATe Board will prepare a presentation for theMedical Advisory Board that will meet on the samedate as theregular ATe board quarterly meetings- the presentation will include financial status, patient numbers and condition summaries, quantity ofmedicationsdelivered, overview of medical research, and important legal and medical issues that may have arisen- the presentation will also address any concerns that were presented to the board by the Medical AdvisoryBoard atthe previous board meeting.2. The ATe Board must address concerns presented to it by the Medical Advisory Board

- it may reject suggested actions from the MedicalAdvisory Board but must base rejections onsubstantiverationals such as economic viability or patient impacts.

XI. Amendments2. These by-laws may be amended by a two-third vote of the entire Board. A copy of the proposed amendment(s)

must be provided to each Board member at least oneweek prior to said meeting. This copy can besentelectronically to the registered email address of each board member.

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NEW JERSEY DEPARTMENT OF THE TREASURYDIVISION OF REVENUE

CERTIFICATE OF INC, (NON PROFIT)COMPASSION COLLECTIVE OF CAMDEN COUNTY A NJ NONPROFIT CORPORATION

0 4 0 0 3 9 3 2 1 0

The above-named DOMESTICNON-PROFIT CORPORATIONwas duly fi~ed inaccordance with New Jersey state law on 01/23/2011 and was assignedidentification number 0400393210. Following are the artic~es thatconsti tute its original certificate.1. Name:

COMPASSION COLLECTIVE OF CAMDEN COUNTY A NJ NONPROFIT CORPORATION2. Reqi.stered Agent:

PETER ROSENFELD3. Registered Office:

301 W FRANKLIN AVECOLLINGSWOOD, NJ 08107 1922

4. Business Purpose:The non-profit research and development of pharmaceuticals andtheir delivery to patients under N.J.S.A. 24:61-1

5. Method of electing Trustees as set forth herein:AS SET FORTH IN THE BYLAWS

6. Asset Distribution:AS SET FORTH IN THE BYLAWS

7. First Board of Trustees:

CAROL BABB

8. Incorporators:

9. Main Business Address:301 W FRANKLIN AVE.COLLINGSWOOD, NJ 08107 1922

Signatures:PETER ROSENFELD

Page J of2


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Certificate of non-profit incorporation, page 2

NEW JERSEY DEPARTMENT OF THE TREASURYDIVISION OF REVENUE

CERTIFICATE OF INC, (NON PROFIT)COMPASSION COLLECTIVE OF CAMDEN COUNTY A NJ NONPROFIT CORPORATION

0400393210

IN TESTIMONY WHEREOF, I havehereunto set my hand and affixed myOfficial Seal at Trenton, this23rd day ofJanuary, 2011

Andrew r Siaamon-EnstoffS tat e Trea su rerCertification# 119311455

Verify this certificate athttps://wwwl.state.nj.usrrYTR_StandingCert/JSPNerify_Certjsp

Page 2 of2


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' '' '' : . .. . ": "" " '~ :- -~ '" ~ ', ' ~ ' .~' ~, '~ ' ,~ t" _ . . .. .. .. . ~ . .. . "" "" '" "' ~,- ;" ,; -- ~. " , ~, _Yn _' ~~ ' ;" :, "" .' ~" ,' '' '' '' '' ', ' ~ ': "'1 " . ,. '" ""~,:-",:f:""""'I"',~;,,.',~.'."'~""-\-! .........,~,I ",".Jersey Division of Taxat ion POBox 252 ,I renton, N.J. 08646-0252 (609) 292-9292.Authority (CA-1) must be c:1isplayed atyourplace of business. . "

Tills auth-orization_-Is-good ONLY_for the named personat the I~This authoriza tion is nul l and void if any cnenue of ownership or'

TaxEffectiveDate 05-01-,11Document-Locatcr No.: 10000577139

DateIssued: 02-01-.11

This -Certificate IS NOT'8ssigrlable o~,t,~nsferable. It rnu'st be cons-pjc~ousl_yd'isplayed at ,above"address_

CERT-104-08, D205846L

(Se~ Reverse Side)

301 WFRANKLIN AVE.COLLINGS'" " 10M922EFFECTIVE02/01/11


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APPENDIX B - Not UsedAPPENDIC C - Not Used

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Appendix D - Nearest Schools

Illustration 1. ' Schools in Vicinity of Proposed ATC. The ATC is the purple maker and the schools arethe red dots and markers. No school is within 2000 feet


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Appendix E - Coverage Area of C4ATe

Illustration 2: Area Within 30 Miles of Pennsauken C4 ATC

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_ Q . $ . f , " ( ; l . ! " 9 :? ' .Q . J l P '~ .Q9 . :1 , ( l .~ t lo. J . .Q JL?P .J . P . . ~ . 1 . Q . : i Q & 1 J . : 2 _ _Q_$ .1:~1 !JJ!.~.;t.~QJ::'tn .l .9.ftl;~~ . ? l. : !J W l ~ . '1 : 1 . 9 .a : , (! " Q D . f 1. J .I Q Q J ; 'i ; 2 J. 1 ._ f J Jr u _ ~ Il~;~.~S!Q~ 'L? 'J f 19 .~ } ;HJ I WJ : : t :l J . . 9 Ji ; j4 . 1 ! } . 9. J .~ J ~ mp . 5. 9 . , Q { P . . 9 : I l _Q: : f .H l lm.1.Q.;.l'.9 .{\1.QJ. fHHn~.~_lP..Q.l.ZAtl ant ic Cou ntYt N]- u ni qu e ~Sin gl e Ent ity Z IP Cod es~ H } ' : H t 5 . _N: :I te zv e-v ZI P Code has a s ing e ACTUAL C ty Name ass aqned by the US c cstet Serv ce (USPS).See the spec if ic Z IP Cede for ec cep tebe A ter na te Ctv Names and :spel ir t9 ver iet c ns .

Ah~!C(Hl~t!:9.u.ti._j!y,f.i_g~f.!!J_!}glliHtlill.Co!9.yllo,"J_U P . I . 9 . t b ' Y .r .~r . t . tm_.{;.tt~_ f ; " ; g g . J : ! . P . . r . ! ; l UTnwfI_>;;hipEIII'Joodt : .~. t~J. l ;M.a.o.9.rH_i ) . n~ . t r . lQnt9 .n_ t . , ~ n - d _ i ~ . I l U I _ i . \,k.~.!9_Q~.~g.inlLInwoodl.cU3(UlortMi1fg;~J.~_'-lt'{.!~ .f J_Y/i_1._ i:!n~ .i.ngMilw


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cumberland countyr NJ- POBoxZIP Codes!!.!D.J.2_ 08:115 DJ1J.1.tl Qff1lQ!illJ21!!!022 ~ -oB]!}:' m3.16.1.cumberland Countyz NJ- Standard ZIPCodesm l ~ .l .Qq t t JQ1 - _ P ' _Q_ ;, I _ ll m .l ~ . ( l1 ) ;U . J . . Q~ n ~ -. 1, . Q J ! .: 3 .l Z q ~ tI Q . l . . Q JU : H . Q . a. J .: l~ iQA~ : : lQ . _Q J1 J1. ~ . ! J . u . J J H . ~ mi !_ : } Jd_Note: Every ZIP Code has a $ nglc: ACTUAL C ty Nalne assiqne d b .< the IJS Pas ta I Service (USPS).See the spe :. fic ZIP Code for acceptable AlterRate Ct y Names en d speH inQ ver ia t on s.

e X . L d g . ~ _ t ; _ - Q _ nhgg.q.r){jJl~OeerlleldS.1Lg_~t.QglnlQ.!1tO-ividinn Cr,,~ekp . Q _ r _ r . : . b ~~ J ~ rE~'!'lj;g.!!f'Qrte_scue~,tlg.bl!:J':YiHg1 . J . ~ t " . S J ; U : H : _ gM~t)rio:!1{)W"M . i n Y . i J !_ ~Newportport Efizatwth_ P . " Q : LU iQ . r f . i . ~ _f!,QlJignhny.nShilqhYj_m~!g_ml

Illustration 5: Cumberland County Zip Codes in Pink Area, Table a/Zip Codes at Top

Gloucester County, NJ - PO Sox ZIP Codes,q! lQ_~.~,QJH,l.J .9.9.!HP.1.Gloucester County, N.J - stenderd ZIP CodesQJU11.1 Q~!U.: ' f. PJ I . ! . t1 J ! !H19_~_7 .Q~{J_~1!9~g~ . I r U 1 Q . : ! .1 QpO-52 .9. i!!&l_Q:l; lfHil Q.$Jl\'iJ ..9JJJl.~ Q I 1 9 . Z J . Q~QJH. l9 .m,nL l - . .Q .6 .9J l. ' ; 'iQJ1P.1H! g_~JJ.9.jJ. P.1W2J . ..')_ll!.!B.g.6.Q~"Q.~.q?Z9.tl9.~QQ.'.nu.l i l ln o.l!.:t~.6.9.?H~ Q.U~.11mu . .9.Note: every ZIP Code has a single ACTUAL C ty Name essiqaed by the US Pona! Ser v ce (USPS ).See the specific ZIP Code for acceptable Alternate City H

aridg~PQd;O"f.kJilu-! .r .9 ::ChW t:ont .W.1U)n : . . o . k : J h r ) ! ' . ! . I . ! gGibh~1()wn~G r e n l 9 : o : : : : _ hHar;i5Ql1villef!t~l~.Y!-M.~.lJJJ..!~Mkklli'.t{lfl~YnlM . ! ,. I J H@ __~~)JiJ!.iatjoual Parkruwf~g!,ldP._~.V. ! ! li.~QI .Qpitnl~_nB i 5 :n Y H > O l j.s.~f.~U5w_.t : ; .d.~_~_b..9I9.Thurotllr


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salem counrv, NJ - POSox ZIP codesilllillU n a c a a=aezz illllll'Salem county, NJ- standerd ZIP Codesllif.illil Q QQ _ 2 _ lHl...Ql.Q~JU5lQ.!imi~ QJHI.211!lli.l.!lJ:)~3l.8 ~ ~Note: Every ZIP Code rasea s ingle ACTUAL Cty Nanle i ;I ;c5' i! ;J fled by the.USPostal se-vtce (USps).See the speci fic ZI P Cede f er acceptable A ternate C ty Names and s pe lin g var iet.cn s

8 . 1 . ! Q : w . . ~ . yDeepwater~H.~n f ;9 . - f J ~~BddgeMonroeyi!ltr . - !Q. nH.~ .p>c"!dricktowl'lp~~tln&Grov~~Dn~_Y..m.g.QM!UtfU1fulk.mW.2Q9.~.tgXf.!l

Map of Salem County, NJ ZIP CodesWith Actui 'l (De llml t) C ity Nl2mes

. . . . . . . . . . . . . .. . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .. . . . . . . . . ;~.; .

Illustration 7: Salem County Zip Codes in Pink Area, Tableof Zip Codes at Top

Burlington County, NJ - standard ZIP codesill!f.ill1 Ofl{nO 080'1.5OmJl6 ot'lfilQ nao aa Oa03fi OH037 08041Oan46 (l'R041lOnOSl OJH153!laQ..!HOMS5 08057 08060 08U65 Ol}06fluru!nillBJllllllllllllllJ!JlJll!=ID!:ilU~=llllilllllill!=~tll!5.lailllll!ll!l!JUl)~lll!lill=Nete: E ....erv ZP Co de has - ' !I ;n gte ACTUAL C ty Name aH; { ned ~ the l iS p este! Serv ce ( USPS).See the spec if ic Z IP Code fer a ccep ta bl e A. ter na te. C t y Nemes end spe li n; ~ venat ons .

~_a. . i r .m j_f. l .gtHH~1t?9.f.~.~n1.9..y.l!lBrown ... .Mil ls ~6urlinqlnu~h.~."!a.WQr!J]_:he.,terll~1Id~c . . 9 Q . t ! . : ~ . t g . w . l J .norgncl?;FortOixJj.~.in.~.1i.P.Q.rtJ.{J.b~t9..wllJtJ!iljstQ~ltlmtl!rt~mMai l le - ShildeMarltonMgg i 9L t !. M . 9 . Q m s : t p . . w . .n~f! tQ.\, I_( I .U.,~J, ! r .g.t. t < J . ~w . .Gr.~:tn~New Usbonpi:!lmyraE.~ . ~n . ! - ? r~~m_

Illustration 8: Burlington County Zip Codes inPinkArea, Table of Zip Codes at Top

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Appendix F - Not Used

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Appendix G - Operational Manual - DRAFT OUTLINEI.Procedures for the oversight of the alternative treatment centerThe management of the ATC will periodically review all records looking for discrepancies intheamount of processed cannabis and the expected amount. Wet and dried weights of the cannabisafterharvest will be gathered to develop a statistical estimate of the amount of cannabis being produced.Significant deviations from this amount will be investigated. Investigation will involve reviewof videorecords and database records. The database will tightly track processed cannabis until he cannabis isdispensed to a patient.Packaged cannabis will be stored in a locked safe within a locked office in theproduction facility when it is not needed for dispensing. All cannabis will be returned to thesafe atnight. Only management or the designated facility supervisor can open the safe.2.Procedures for safely growing and dispensing medicinal marijuanaA set of procedures are being developed to ensure that the cannabis produced is free of contaminantsand remains free from fungus and insects. See application related to this issue.Once packaged the cannabis will remain sealed until it is dispensed or destroyed.Testing will be performed to ensure the cannabis is safe and what the THC levels are.The packaging will be labeled with THC and CBD levels as well as other information suchass train,batch and date processed and this information will also be entered into the computer data base,ensuring the information matches the actual packaged cannabis and allowing back-tracing to the totalgrow information if problems do occur.2b. Entering Grow AreasEmployees not trained and clear to work in the grow areas are not allowed in these areas except inemergencies. Employees who are being trained for grow work must read the entire cultivationoperations manual which goes into detailed proceduresAll employees need to be aware of some basics in entering the grow area in case of emergencies orescorting a law enforcement officer, approved state official or other oversight person intothese areas:a) Street shoes are never to be worn into the grow areas. Shoes can easily track in mold sporesandother pathogens into these "clean" areas. Switch to the sandals kept outside the entryway. Sparesandals are kept for vistors.b) Remove coats ans other outerwear before entering the grow area. These can carry pathogens. Mostpeople should wear one of the lab coats kept in the entryway to further reduce risk.c )The grow areas are kept at a slight positive pressure to reduce incursions of inserts and spores into thearea. Door must be pulled shut or they will stay open.

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d)Some of the lights are on in the vegetation area 24 hours a day. Do not tum off the overhead lights.e)The lights in the flowering area are on a 12 hour cycle. Overhead lights must not be turned onduringa dark cycle. Any strong light could ruin the current crop. The current cycles are listed on thewhiteboard by the entry door. If you must enter the flower area during a dark period, due to emergency,usethe special flashlights kept by the door.d) You must wash your hands before touching plants or harvested plant materials.

3. Procedures to ensure accurate record keeping, including inventoryprotocols to ensure that quantities cultivated do not suggest redistributionBecause cannabis Is an agricultural product, yield per plant will vary. Itwill difficult to determineifsmall amounts of flowering cannabis is being diverted before it is packaged. As mentioned in"I.",statistical methods will be developed to estimate yield by strain and genotypes within a strain,and toestimate expected dry weight from the recorded harvested wet weight. Significant deviations fromthese statistics, if not accounted for in the "grow log" kept on each plant, will trigger an investigation todetermine if diversion actually occurred. If a diversion is determined, it will be reported to thestate andif necessary, the police.Once the