February 14, 2011

By Hand Delivery

Poonam Alaigh, MD, MSHCPM, FACP

Commissioner
New Jersey Medicinal Marijuana Program
NJ Department of Health and Senior Services
PO Box 360
Trenton, NJ 08625-0360

RE: Application to Establish and Operate Medicinal Marijuana Alternative Treatment

Center in New Jersey’s Southern Region (RFA#3683_001)
Dear Commissioner Alaigh:
Attached please find the application of the Compassionate Care Foundation, Inc.
(“Compassionate Care”) to establish and operate a medicinal marijuana alternative treatment
center in the Southern Region in response to New Jersey Department of Health and Senior
Services Request for Applications RFA #3683_001. Compassionate Care, a New Jersey non-
profit created to cultivate and dispense pharmaceutical grade cannabis to meet medical needs,
was founded by a group of former health department regulators, community leaders, healthcare
professionals, researchers and non-profit directors who understand both the therapeutic value of
this product and public sensitivities. Compassionate Care is committed to providing New Jersey
patients with safe and affordable medicine.
Compassionate Care is applying for additional permits to operate a total of three Alternative
Treatment Centers – one each in the Northern, Central, and Southern Regions of the state. Our
team is highly capable, qualified, and capitalized to establish and operate these three facilities.
We will maintain the highest standards of quality control and accountability to prevent diversion.
We have developed research protocols to enable us to collect and share required data on patient
outcomes, utilization, and trends.
We have undertaken outreach to local government and law enforcement in each of the
communities where we propose to locate our facilities to confirm that they are receptive to our
endeavor, and selected sites at an acceptable distance from sensitive uses such as schools. We
have negotiated workable terms with landlords, disclosing our intent to cultivate and distribute
medicinal cannabis. As a result, we are very proud to attach letters of support from throughout
the state, including from local communities.
Please note that this application contains security-related and proprietary information which is
exempt from the Open Public Records Act (OPRA). We hereby request that you protect the
confidentiality of any portions of the application for which the information is exempt from
OPRA. Relatedly, please retain this cover letter with the application at all times so that this
request is honored without fail.
As President and Chief Executive Officer of Compassionate Care, I can and do attest to the
accuracy and veracity of all statements, figures, amounts and other information incorporated
within the materials submitted. Thank you very much for your efforts to enable patients to
obtain medicinal marijuana, and for your careful consideration of our application to assist in
those efforts.
Sincerely,

Compassionate Care Foundation, Inc.

William J. Thomas
President & CEO
 TABLE OF CONTENTS

TABLE
OF
CONTENTS


INTRODUCTION .............................................................................................................................................1

CRITERION 1 - INFORMATION REGARDING APPLICANT & FACILITY ......................................................3

CRITERION 2 - OPERATIONAL INFORMATION ..........................................................................................11
CRITERION 3 - COMMUNITY INPUT AND APPROVAL ...............................................................................20
CRITERION 4 - PATIENT CARE CENTER SPECIFIC CONSIDERATIONS ......................................................22
CRITERION 5 - CULTIVATION SPECIFIC CONSIDERATIONS .....................................................................35

APPENDIX A – CORPORATE DOCUMENTS ...............................................................................................A1

APPENDIX B – EVIDENCE OF SITE CONTROL ........................................................................................A19
APPENDIX C – EVIDENCE OF ZONING COMPLIANCE ...........................................................................A21
APPENDIX D – DISTANCE TO SENSITIVE SITES .....................................................................................A24
APPENDIX E – ZIP CODE MAP OF SERVICE AREAS ..............................................................................A26
APPENDIX F – QUALIFICATIONS AND POSITION DESCRIPTIONS .........................................................A28
APPENDIX G – OPERATIONS PLAN .........................................................................................................A51
APPENDIX H – SECURITY PLAN ..............................................................................................................A93
APPENDIX I – EMPLOYEE TRAINING MANUAL ...................................................................................A114
APPENDIX J – HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA) MANUAL............A116
APPENDIX K – HUMAN RESOURCES MANUAL ....................................................................................A121
APPENDIX L – CULTIVATION OVERVIEW ............................................................................................A135
APPENDIX M – HYDROPONIC DESIGN .................................................................................................A137
APPENDIX N – PRODUCT SAFETY PLAN ...............................................................................................A139
APPENDIX O – FIRE SAFETY PLAN .......................................................................................................A142
APPENDIX P – ENVIRONMENTAL PLAN................................................................................................A144
APPENDIX Q – FINANCIAL PRO-FORMA ..............................................................................................A146
APPENDIX R – LETTERS OF RECOMMENDATION ................................................................................A174
 INTRODUCTION

The Compassionate Care Foundation Inc. (“Compassionate Care”) very much appreciates the
opportunity to submit this application for a permit from the State of New Jersey in response to
DHSS RFA #3683_001 (“RFA”). We seek a permit to cultivate and dispense medicinal cannabis
in Bellmawr, New Jersey. We are simultaneously submitting additional permit applications to
operate Alternative Treatment Centers (“ATC”) in the state’s Central and Northern Regions.

Compassionate Care is a non-profit corporation organized under the State of New Jersey with the
mission of providing therapeutic pain relief to patients in need and conducting research into the
effectiveness of medicinal cannabis for the individuals and communities we serve. Founded in
2011, Compassionate Care is lead by a Board of Directors whose members are medical
professionals, former health department regulators, community leaders, and researchers. They
are committed to providing New Jersey patients with safe and affordable medicinal cannabis.

Using advanced horticultural technology, we offer many varieties of pharmaceutical grade

cannabis. Our unique approach allows us to trace the genetic strand of every plant, to protect our
medicinal products from disease, pest, and mold, and to ensure that our medicinal cannabis is
maximally effective for our patients. We realize that our corporate sustainability depends on a
reciprocal relationship with our host community and surrounding environment. We make
substantial contributions to our host communities through job creation and charitable giving.
Moreover, we operate environmentally responsible facilities, use cultivation methods with “zero
waste” polices and procedures, rely upon high security protocols to ensure the safety of our
workers and our neighbors, and conduct a sophisticated research and development program on
medical cannabis efficacy. Our commitment to the environment, workers, customers, and our
community are reflected throughout this document.

The organization of this application mirrors the structure of the RFA – a section for each
criterion, and within that, a subsection for each measure. Thus, Section 1 provides information
requested about the applicant (Compassionate Care) and the cultivation facility and patient care
center for which we are seeking this permit. Section 2 describes requested information about our
operating plans, policies, and funding. Section 3 describes our proposed methods for obtaining
the input and support of our host communities (from members of the public as well as local
government entities). Section 4 details more specifically the patient care, data collection,
security, and educational programs and procedures we will use in operating these facilities and
the interface between this cultivation center and our patient care center. Section 5 focuses on our
cultivation procedures. Section 6 contains eleven appendices (e.g., zoning compliance documents
and letters of support from local communities).

1
 INTRODUCTION

This proposal will specifically articulate our knowledge of and conformance with the State of
New Jersey’s medical cannabis program and addresses, item by item, the requirements under the
Request for Applications. In summary, this application demonstrates the reasons why
Compassionate Care is unsurpassed in the experience, capabilities, and qualifications needed to
operate an ATC. Based upon these attributes and the information contained in the remainder of
the document it is our hope that the reviewers will consider our organization for a permit to
operate an ATC for medical cannabis in the south section of State of New Jersey.

2
 CRITERION 1

CRITERION
1
‐
INFORMATION
REGARDING
APPLICANT
&
FACILITY

Measure
1:
The
applicant
shall
provide
the
proposed
legal
name
and
the
following
documents

applicable
 to
 the
 applicant’s
 legal
 status.
 Supporting
 documents
 should
 be
 included
 as

Appendix
A.

▪ Certificate
and
Articles
of
Incorporation
and
By‐Laws
for
corporations

▪ Organizing
documents
for
associations

▪ Evidence
of
nonprofit
status

▪ Certificate
of
good
standing
issued
by
the
New
Jersey
Secretary
of
State


The proposed legal name of our entity is Compassionate Care Foundation, Inc. We have
attached the following supporting documents:
• Certificate of Incorporation of Compassionate Care Foundation, dated February 4,
2011
• By-Laws for Compassionate Care Foundation, dated February 9, 2011
• Certificate of Good Standing for Compassionate Care Foundation, issued by the
New Jersey Secretary of State on February 7, 2011
• Business Registration Certificate1

Appendix A: Corporate Documents

Measure
2:
The
applicant
shall
provide
the
proposed
physical
address(es)
of
the
ATC,
if
a
precise

address
has
been
determined.
Supporting
documents
should
be
included
as
Appendix
B.

▪ For
 each
 proposed
 physical
 address,
 the
 applicant
 shall
 provide
 legally
 binding

evidence
 of
 site
 control
 (e.g.,
 deed,
 lease,
 option,
 etc.)
 sufficient
 to
 enable
 the

applicant
 to
 have
 use
 and
 possession
 of
 the
 subject
 property
 including,
 but
 not

limited
to,
length
of
term
of
use
and
possession.

▪ If
the
applicant
intends
to
cultivate
medicinal
marijuana
at
one
physical
address
and

dispense
 it
 at
 another,
 both
 facilities
 shall
 be
 located
 within
 the
 same
 region
 as

defined
 in
 Subchapter
 1
 of
 N.J.A.C.
 8:64,
 the
 Rules
 Related
 to
 the
 Medicinal

Marijuana
Program.

▪ If
a
precise
address
has
not
been
determined,
the
applicant
shall
identify
the
general

location(s)
where
the
facilities
would
be
sited,
and
when.


Compassionate Care plans to operate its cultivation and patient care center at separate
locations within the same region, as follows:


























































1
Evidence of Compassionate Care’s nonprofit status is included in its Bylaws and Certificate of
Incorporation. Compassionate Care is in the process of filing for its business registration
certification. This process will be complete by April 4, 2011.

3
 CRITERION 1

Measure
2
Response

cont’d


a) Cultivation Facility. The cultivation facility will be located at 330 Benigno

Boulevard, Bellmawr, NJ 08031. We have attached a Letter of Intent, dated
February 2, 2011, from Bradford Price to the Department’s Office of Legal and
Regulatory Compliance, showing a preliminary agreement for a 10-year lease for
Compassionate Care to use and possess the site as a cultivation facility.

b) Patient Care Center. While we have not selected the precise address of our patient
care center, it will be located in the same municipality and in the same region as
our cultivation facility, as defined in N.J.A.C. 8:64-1.2. If awarded a permit, we
will identify and secure the final site for the patient care center within thirty (30)
days from permit approval.

Appendix B: Evidence of Site Control

Measure
 3:
 The
 applicant
 shall
 provide
 evidence
 of
 compliance
 with
 the
 local
 zoning
 laws
 for

each
address
or
proposed
location
for
an
ATC.
If
the
current
zoning
is
not
appropriate
for
a

given
 address
 or
 location,
 identify
 any
 required
 zoning
 variance(s)
 and
 the
 applicant’s

actions
taken
to
date
to
obtain
such
approval(s)
and/or
variance(s).
Supporting
documents

should
be
included
as
Appendix
C.


Compassionate Care's cultivation facility will be located in the Heavy Industrial Zone
District of the Borough of Bellmawr. While the code does not specifically address our
proposed use of harvesting and packaging medical cannabis, we will make the appropriate
site plan /variance applications if required by the Township in order to secure a certificate of
occupancy. In addition, we will locate our patient care center in an area consistent with the
zoning requirements for the area. We currently do not anticipate any major zoning variance
request or approvals needed for the patient care center.

Appendix C: Evidence of Zoning Compliance

Measure
4:
The
applicant
shall
provide
evidence
that
all
of
the
physical
addresses
and
proposed

locations
provided
in
response
to
Measure
2
are
not
located
within
a
drug‐free
school
zone.

The
 applicant
 shall
 provide
 the
 distance
 to
 the
 closest
 school
 from
 the
 ATC.
 Supporting

documents
should
be
included
as
Appendix
D.


Community safety is a top priority for Compassionate Care. Our cultivation facility is not
located within a drug-free school zone. The closest distance to a school is 0.9 miles. We
also will select a patient care center location that is not located within a drug-free school
zone. We have provided a table showing distance to the closest school and other select
locations as defined in the regulations.

Appendix D: Distance to Sensitive Sites

4
 CRITERION 1

Measure
5:
The
applicant
shall
provide
a
legible
map
or
maps
of
the
ATC
service
areas
by
Zip

Code
to
be
served
by
the
ATC.
Supporting
documents
should
be
included
as
Appendix
E.


We have attached a legible map with zip codes of the areas that will be served by our patient
care center. In order to provide access for the largest number of those in need,
Compassionate Care will welcome and be prepared to serve all registered patients residing in
any of the counties in the region as defined in the New Jersey Compassionate Use Medical
Marijuana Act (the “Act”).

Appendix E: Zip Code Map of Service Areas

Measure
6:
The
applicant
shall
provide
the
role,
qualifications,
name,
address
and
date
of
birth

of
each
staff
member
and
the
role,
name,
percentage
interest,
address
and
date
of
birth
of

each
principal,
officer,
board
member
or
partner
of
the
ATC.
In
the
event
that
an
individual

has
not
yet
been
identified,
a
statement
of
required
qualifications
and
position
description

shall
be
included
as
Appendix
F.


The Compassionate Care team is composed of former health department regulators,

community leaders, healthcare professionals, researchers, and nonprofit directors committed
to providing qualifying patients, their caregivers, and their healthcare providers with current,
scientifically accurate care and information about medical cannabis. Led by the President
and Chief Executive Officer, William Thomas, the Board includes:

WILLIAM J. THOMAS
Mr. Thomas has spent the last 41 years developing methods for
delivering healthcare at affordable prices while maintaining the
highest levels of quality. He has demonstrated on many
occasions that he can build and maintain a large organization.
Since selling his consumer-focused health insurance company in
2007, he has been working with the application of social media
to improve the quality and cost of healthcare. In 2009, he started
working as the lead researcher for the Leapfrog Due Diligence
Cooperative. Membership includes the New Jersey Health Care
Quality Institute and many New Jersey companies and unions.
The focus of his research has been the comparative effectiveness of disease management
vendors, prescription benefit managers, and wellness companies. Mr. Thomas was asked to
serve on the board because of his experience with the delivery of health care services and his
ability to grow organizations from the ground up.

5
 CRITERION 1

Measure
6
Response

cont’d


DAVID KNOWLTON
Mr. Knowlton is the CEO of the New Jersey Healthcare Quality
Institute, a nonprofit health care think tank. The Board of the
Institute includes all of the major health care stakeholders in
New Jersey. Mr. Knowlton is the former Deputy Health
Commissioner of New Jersey and is currently the National
Chairman of the Leapfrog Group, a nonprofit health care
research organization. Leapfrog is an employer member-driven
nonprofit representing over 2,200 employers, including the New
Jersey Health Care Payers Coalition. Mr. Knowlton was asked
to serve on the Board because of his knowledge of the healthcare needs of New Jersey and
his experience with managing nonprofit organizations.

JAMES C. HERRMANN
Mr. Herrmann is the President of James C. Herrmann &
Associates, Ltd., (JCH), a full service insurance agency and
brokerage located in Rockville Centre, New York. Mr.
Herrmann began his insurance career in 1986, specializing in
healthcare professional liability and financial services. Today,
these two areas represent a significant portion of JCH’s
business. JCH insures numerous health care facilities,
physicians, and nonprofit agencies. JCH also maintains a large
presence in the construction and real estate industries,
representing contractors, developers, and real estate companies.
Mr. Herrmann was a Captain in The Rockville Centre Volunteer Fire Department, the past
President of the Friends of Mercy Medical Center, and a former board member of Mercy
Medical Center and Our Lady of Consolation Nursing Home. He is currently a member of
the Board of Trustees of the Long Island Power Authority, the State University of New York
College at Old Westbury Foundation, the United Cerebral Palsy Association of Nassau
County, and the Long Island 9/11 Memorial. Mr. Herrmann was asked to serve on the Board
because of his extensive experience with risk management and his knowledge of nonprofit
operations.

In addition, the following people have agreed to join our Board:

6
 CRITERION 1

Measure
6
Response

cont’d


ANN MARIE HILL

Mrs. Hill is the Executive Director of the New Jersey State
Commission on Cancer Research and the Internship Coordinator
for the Edward J Bloustein School of Planning & Public Policy,
Rutgers University, New Brunswick, NJ. At Rutgers, Mrs. Hill
currently coordinates over 200 students a year in senior public
health internships, and also teaches research diffusion and
senior workplace transition issues. In addition, she conducts
research activities on health care disparities, cancer
survivorship, clinical trial recruitment, community health and
outreach, and research dissemination. Mrs. Hill was asked to
serve on the Board because of her expertise in public health, cancer, and the diffusion of
research.

JEFFERY WARREN
Mr. Warren has more than 30 years of healthcare leadership
experience, including government, hospital administration,
philanthropy, consulting, and work in the pharmaceutical
industry. Mr. Warren is a principal with JR Market Strategies,
LLC, a healthcare consulting firm. Most recently, he served as
a senior advisor/consultant to the National Pharmaceutical
Council (NPC). Prior to NPC, Mr. Warren was responsible for
strategic marketing and media relations for Pfizer Health
Solutions. Earlier in his career, he was Executive Vice
President of Corporate Development for Cathedral Healthcare
System. During his tenure with Cathedral, Mr. Warren was a National Program Director for
the Robert Wood Johnson Foundation’s New Jersey Health Services Development Program.
Mr. Warren’s past experience includes tenure as Vice President of Corporate Development
with the Hackensack Medical Center. He also was named the first Executive Secretary to the
New Jersey Hospital Rate Setting Commission. Mr. Warren was asked to serve on the Board
because of his knowledge of the pharmaceutical industry and New Jersey healthcare issues,
and because of his service on nonprofit boards.

7
 CRITERION 1

Measure
6
Response

cont’d


JOANN LANGE
Ms. Lange has an extensive background in consumer
communications and marketing. She has worked on projects for
several pharmaceutical companies and an education company
serving healthcare providers. On one project she drove the
creation and the verification of a consumer database for use by
such clients as Pfizer and Astra-Zeneca. The database tracked
medical conditions for more than two million consumers.. Ms.
Lange is also on the Board of the Robotic Education
Foundation. Ms. Lange received an MBA from Harvard
University. Ms. Lange was asked to serve on the Board because
of her expertise in educating health care consumers and providers.

MARK DUMOFF
Mr. Dumoff is the President of Healing Spaces, Inc., a 501(c)3
nonprofit corporation he founded in 2005. The mission of
Healing Spaces is to “Bring Healing to the Home” by creating
“Dream Bedrooms” that enhance the spirit and quality of life
for children from underprivileged families in New Jersey who
are fighting cancer and other serious illnesses. Healing Spaces
partners with leading pediatric oncology hospitals in New
Jersey such as Tomorrow Children’s Institute at Hackensack
University Medical Center, Children's Hospital of New Jersey
at Newark Beth Israel Medical Center, and the Bristol-Myers Squibb Children's Hospital at
Robert Wood Johnson University Hospital. Mr. Dumoff also is CEO and President of
Relational Insights, Inc. (aka DocInsight), a health information technology strategy,
development, and services company. DocInsight is focused on patient experience
measurement and enhanced care coordination within a Patient Centered Medical Home and
Accountable Care Organization setting. Mr. Dumoff was asked to serve on the Board
because of his experience with managing a nonprofit and for his expertise in assessing and
surveying patient experience.

Our President and Chief Executive Officer, Mr. William Thomas is in place. We have
attached other key staff position descriptions and information requested regarding the role,
qualifications, name, address, and date of birth of each staff member, as well as the role
name, percentage of interest, address, and date of birth of each principal, officer, board
member, or partner of Compassionate Care.

Appendix F: Qualifications and Position Descriptions

8
 CRITERION 1

Measure
 7:
 Disqualifying
 Drug
 Offenses:
 In
 considering
 any
 application
 for
 an
 ATC
 permit,
 an

applicant
 must
 disclose
 and
 the
 Department
 shall
 consider,
 at
 a
 minimum,
 the
 following

factors
in
reviewing
the
qualifications
of
those
persons
applying:


▪ Whether
 the
 applicant
 or
 any
 staff
 member,
 principal,
 officer,
 board
 member
 or

partner
 has
 been
 convicted
 under
 any
 Federal,
 state
 or
 local
 laws,
 relating
 to
 drug

samples,
wholesale
or
retail
distribution,
or
distribution
of
a
controlled
substance

▪ Whether
 the
 applicant
 or
 any
 staff
 member,
 principal,
 officer,
 board
 member
 or

partner
has
been
convicted
of
a
felony
under
any
Federal,
state
or
local
laws

▪ The
 past
 experience
 in
 the
 manufacturing
 or
 distribution
 of
 drugs
 or
 controlled

substances
by
the
applicant
or
any
staff
member,
principal,
officer,
board
member
or

partner

▪ Whether
 the
 applicant
 or
 any
 staff
 member,
 principal,
 officer,
 board
 member
 or

partner
has
ever
furnished
false
or
fraudulent
material
in
any
application
concerning

drug
manufacturing
or
distribution

▪ Whether
 the
 applicant
 is
 in
 compliance
 with
 any
 previously
 granted
 professional

health
license
or
registration,
if
any

▪ Any
other
factors
the
Department
might
consider
relevant


Compassionate Care is committed to the highest ethical standards, patient safety, and
transparency in its operations and business practices. Based upon preliminary background
checks, our staff members, principals, officers, board members, and partners do not have any
potentially disqualifying drug or other criminal offenses. In addition, to the extent
applicable, all are, and will continue to be, in compliance with previously granted
professional health licenses and registrations. Finally, each principal, director, board
member, owner, and employee will be required to provide written consent to submit to a
criminal history record background check pursuant to N.J.S.A. 24:61-4. To ensure
transparency, the entire background check process will be conducted by an outside,
independent third-party agency. We will immediately notify the Department of Health (the
“Department”) if any principal, officer, board member, or employee has any disqualifying
drug offenses or other reportable events as defined by the Department.

Measure
8:
The
applicant
shall
provide
the
identities
of
all
its
creditors,
if
any.


Compassionate Care does not currently have any creditors. All start-up costs have been
incurred by one or more of Compassionate Care’s Board members. See financial statements
that set forth categories of future creditors.

Appendix Q: Financial Pro-Forma

9
 CRITERION 1

Measure
9:
The
applicant
shall
provide
a
list
of
all
persons
or
business
entities
having
direct
or

indirect
authority
over
the
management
or
policies
of
the
ATC.


Compassionate Care is managed by its officers/key staff and Board of Directors. No other
person or business entity has a direct or indirect authority over the management or policies of
Compassionate Care. The name of the President and Chief Executive Officer is William
Thomas. The current names of the Board members responsible for the management of
Compassionate Care are:

• William J. Thomas
• David Knowlton
• James C. Herrmann

See Board bios in Criterion 1, Measure 6 above.

Measure
 10:
 The
 applicant
 shall
 provide
 a
 list
 of
 all
 persons
 or
 business
 entities
 having
 an

indirect
interest
in
the
ATC.
An
indirect
interest
includes
an
interest
in
the
land
or
building

where
the
ATC
will
be
sited.


The landlord for Compassionate Care will be Albert E. Price, Inc., which does not have any
interest or ownership in Compassionate Care. If granted a permit, Compassionate Care
anticipates having several categories of third-party vendors to provide management, security,
scientific, and other professional functions. We have provisionally identified vendors for
specific services, including the following:
• Security: Henry Brothers Electronics and Universal Safety Response
• Product Safety Testing: CW Analytical
• Hydroponic Supplies/Cultivation Oversight: weGrow Enterprises, Inc.
• Accounting Firm: Lynn Elliott
• Transportation Security Services: Dunbar Armored

See financial statements that set forth categories of future creditors.

Appendix Q: Financial Pro-Forma

Measure
 11:
 The
 applicant
 shall
 include
 the
 required
 application
 cover
 sheet
 and
 attestation

statement
signed
by
its
chief
executive
officer
or
other
individual
authorized
to
make
legally

binding
commitments
on
its
behalf.


See cover letter and attestation statement at beginning of application.

10
 CRITERION 2

CRITERION
2
‐
OPERATIONAL
INFORMATION


Measure
 1:
 The
 applicant
 shall
 provide
 a
 draft
 operations
 manual
 and
 training
 plan
 which

demonstrates
 compliance
 with
 Subchapter
 9
 of
 N.J.A.C.
 8:64,
 the
 Rules
 Related
 to
 the

Medicinal
 Marijuana
 Program
 and
 which
 addresses
 ATC
 General
 Administration

Requirements
 for
 Organization
 and
 Recordkeeping.
 Supporting
 documents
 should
 be

included
as
Appendix
G.


To compliance with Subchapter 9 of N.J.A.C 8:64, we have addressed all of the specific
requirements in our Operations Plan. Because of the confidential and proprietary nature of
our Operations Plan and Training Manual, we have provided all additional documentation
that would ordinarily be included in our Operations Plan as separate appendices for sampling
purposes. Full copies are available for review in hardcopy, at the Department’s request.

The components of our Operations Plan include the following:

Appendix G: Operations Plan and Training Manual (For compliance with Subchapter 9)
Appendix H: Security Plan (Available for full view)
Appendix I: Employee Training Manual
Appendix J: The Health Insurance Portability and Accountability Act (HIPAA) Manual
Appendix K: Human Resources Manual
Appendix L: Cultivation Overview
Appendix M: Hydroponic Design
Appendix N: Product Safety Plan
Appendix O: Fire Safety Plan
Appendix P: Environmental Plan


Measure
 2:
 The
 applicant
 shall
 provide
 a
 description
 of
 how
 the
 ATC
 will
 operate
 on
 a
 long‐
term
 basis
 as
 a
 not‐for‐profit
 entity
 and
 a
 business
 plan
 that
 includes,
 at
 a
 minimum,
 the

following:




To operate on a long-term basis as a nonprofit entity, Compassionate Care intends to operate

a lean organization to provide patients with affordable medicine. The price of our medicine
will be equal to our cost. As our organization becomes more efficient over time and expands
its patient base, we intend to reduce our prices and invest more into areas that promote the
long-term wellbeing of our patients and the surrounding communities.

11
 CRITERION 2

Measure
2
Response

cont’d


Our primary focus areas will be:

1. Reducing the cost of our medicine and expanding our indigent care program
2. Investing in our research and development program
3. Developing and expanding our charitable and philanthropic programs
4. Providing additional worker education and training
5. Offering more free healthcare services to patients
6. Increasing product safety, hygiene and quality assurance standards

Measure
2‐I:
The
applicant
shall
provide
a
detailed
description
about
the
amount
and
source
of

the
equity
and
debt
commitment
for
the
proposed
ATC.

a) The
immediate
and
long‐term
financial
feasibility
of
the
proposed
financing
plan;

b) The
relative
availability
of
funds
for
capital
and
operating
needs;
and

c) The
applicant’s
financial
capability.


Compassionate Care has received a commitment of forty-five million dollars ($45,000,000)

from Metropolitan Financial Holdings to operate up to three ATCs. We have provided a
financial commitment letter and evidence that the funds are available through financial
statements. See Letter, dated February 7, 2011, from Goldie Dickey and Ben Penfield of
Metropolitan Financial Holdings to James Herrmann and the Compassionate Care
Foundation. The funds for this project have been set aside for our project, pending approval
of our permits.

Appendix Q: Financial Pro-Forma

a)
THE
IMMEDIATE
AND
LONG‐TERM
FINANCIAL
FEASIBILITY
OF
THE
PROPOSED
FINANCING
PLAN


We have compiled comprehensive financial statements that show the immediate and long-
term financial feasibility of our proposed financing plan.

Because of the confidential and proprietary nature of our full business plan, complete copies
are available for review in hardcopy, at the Department’s request.

Appendix Q: Financial Pro-Forma

b)
THE
RELATIVE
AVAILABILITY
OF
FUNDS
FOR
CAPITAL
AND
OPERATING
NEEDS


Metropolitan Financial Solutions has blocked and held in support funds for our capital and
operating needs as evidenced in the financial commitment letter provided. See Criterion 2,
Measure 2-I.

Appendix Q: Financial Pro-Forma

12
 CRITERION 2

Measure
2‐I
Response

cont’d


c)
THE
APPLICANT’S
FINANCIAL
CAPABILITY


As indicated in our attached financial statements, Compassionate Care is financially capable

of carrying out our plans described within this proposal. Our leadership has owned and
operated many successful ventures over time and has the capacity to build and operate a
cultivation facility and patient care center if awarded a permit.

Measure
 2‐II:
 The
 applicant
 shall
 provide
 a
 copy
 of
 its
 proposed
 policy
 regarding
 charity

care/servicing
indigent
patients.


Compassionate Care has two basic charitable missions. The first is to provide high quality
medicine to patients in need. The second is to expand the understanding of the clinical effects
of medicinal cannabis and how it should be used in the treatment of different diseases and
conditions. This section briefly summarizes Compassionate Care’s basic approach to our
charitable missions, but it should be understood that our board and management will be
refining our charitable programs on an ongoing basis in response to our experience and
evolving patient and community needs.

As mentioned above, our first charitable mission is to provide the best quality medical
cannabis to patients who can benefit from this treatment. In our cultivation facility we will
use state-of-the-art horticultural equipment and methods as well as scrupulous hygienic
practices to ensure our product is safe and healthful. In our patient care center we are
dedicated to providing informed and caring patient education with exceptional customer
service. We aim to be recognized as the industry leader in our field and will leverage
systematic patient feedback and ongoing dialogue with the medical community to
continuously improve our products and services.

An important aspect of our patient care mission is our commitment to increase access to
medical cannabis for those who are medically underserved. Most immediately we recognize
that people with chronic or terminal illness often have limited financial means, frequently
made worse by the loss of ability to work and the expenditure of income on expensive
medical and custodial care. We will need to refine the details, but we intend to make
generous provisions for patients who need but cannot afford our product or the specialty
equipment to consume it. Access issues for medical cannabis are especially pronounced
because cannabis is currently a self-pay drug product. Neither public nor commercial insurers
provide any subsidies or reimbursement to patients electing to use this medicine. With our
board’s experience in the health care and insurance industries, we expect to bring forth
research that will persuade third-party payers to reimburse patients using medical cannabis
for conditions for which it has been shown to be clinically efficacious, safe, and cost-
effective in comparison to alternative therapies.

13
 CRITERION 2

Measure
2‐II
Response

cont’d


This leads us to Compassionate Care’s research mission. At the present time there is clear
and convincing evidence that cannabis is a safe and effective product for many patients, but
we do not yet have the level of knowledge that would allow physicians to confidently guide
patients on the maximum benefits associated with use of the product. Experts in the field of
pain management agree that cannabis is one of the least addictive of currently available
therapies and has fewer serious risks and toxicities than other drugs, but further research and
education on these issues is needed to rectify long-standing misperceptions about the relative
safety of cannabis. The National Institutes of Health has recently announced a new grant
program for research on the clinical effectiveness of cannabis, and Compassionate Care is
applying for one of these grants, conditioned on our success in obtaining a permit for one or
more patient care centers. Whether we obtain a grant or not, we will use a portion of the
funds from sales to conduct our own research on these matters. We will be eager to work
with the Department and other state agencies to document New Jersey patients’ experiences
with medical cannabis so this knowledge can be used to inform future regulatory policies and
practices.

You can see from reviewing the profiles of members of our Board and our independent
Medical Advisory Board (see below) that we are very serious about research. The key to
gathering the data we need on effectiveness is to obtain patient participation. We need
patients to report their experience with the drug. We need to know how the use of specific
strains and strengths of the drug affects symptoms such as pain and nausea. Since our
organization is new and therefore unknown to the patient population of New Jersey, we will
need the support of the longstanding patient advocacy organizations and charities. To this
end we have reached out to charities such as Gilda’s Club and other similar organizations.
We intend to provide funding to these organizations to advance the understanding of
medicinal cannabis. In return we have asked that they encourage their medical cannabis-
using clients to participate in our outcomes studies. Some of their clients who use medicinal
cannabis will already be known to us because they are also our clients. Therefore, there is no
breach of confidentiality. We anticipate the charities will give us general support, not
specific client interaction. We are not suggesting that they recommend using medical
cannabis. We only need their assistance in encouraging their clients to participate in the
research.

These patient support organizations will be natural places for us to distribute educational
information about medicinal cannabis. There are special organizations such as the Children’s
Cancer Network where distributing information about the use of this drug in patients under
the age of 18 will be critical. There are other organizations such as the New Jersey Health
Care Quality Institute, the New Jersey Nurses Association, the New Jersey Medical Society,
the New Jersey Hospital Association, and the New Jersey Healthcare Payers Association
where there are opportunities for education and support. We will offer our experts and Board
members the opportunity to meet with these organizations and their members to discuss the
use and effectiveness of this drug. Our Board members have worked with all of these
organizations in the past either as members, supporters, or board members.

14
 CRITERION 2

Measure
2‐II
Response

cont’d


We will also reach out with education to employers because they may have employees who
are using the drug and the employers should be aware of its effects on employee
performance. Employers may also elect to fund the prescriptions in their benefit plan if we
can show through comparative effectiveness research that medical cannabis is more cost
effective.

To facilitate our interaction with charities and other important organizations we have asked
current board members of charities to participate in a Charitable Research Support
Committee. This committee will be headed by Mr. Kenneth Merin, the former New Jersey
Insurance Commissioner and current President of the Charles Hayden Foundation.

Measure
 2‐III:
 The
 applicant
 shall
 provide
 a
 copy
 of
 its
 proposed
 policy
 related
 to
 disposal
 of

returned
or
unusable
marijuana.


Compassionate Care has developed a return policy based on our principles and our
understanding of the Medical Marijuana Program (the “MPP”). We anticipate that aspects of
the return policy may be revised as the Department further clarifies the rules of the Program.
Compassionate Care’s policy on unused or returned medication is guided by three orienting
objectives:
• Ensure product safety issues are promptly identified, analyzed, and corrected;
• Provide excellent value and service to our patients; and
• Minimize opportunities for diversion

Before a batch of medicinal cannabis is packaged, a sample will be tested in our laboratory
for pests, molds, and other contaminants, and we will also analyze the cannabinoid profile of
product (details are provided in Criterion 5, Measure 3). Any medicinal cannabis found to be
deficient, whether because of mold, excessive THC, or other issues, will be incinerated. In
addition, excess inventory will periodically be destroyed to prevent any unauthorized use or
distribution. An on-site incinerator in a secure room of the facility will be used for this
purpose.

15
 CRITERION 2

Measure
2‐III
Response

cont’d


If a patient or caregiver returns product claiming that it is defective, our staff will complete a
report on the complaint and take possession of the returned product. The returned product
will be weighed, and if the returned product is >50% of the volume purchased, the customer
will be eligible for a full refund of the purchase price. Also, the customer may apply the
value of the product returned to another medication purchase. As each patient may only
purchase two ounces of medication per month, patients returning >50% of a quantity of
medicine for quality reasons will be able to replace that allotment within their two-ounce-
per-month purchase limit. Patients making returns of less than half of the product purchased
will be eligible for a refund of the purchase price, but they will only be able to buy substitute
product if they have not reached their purchase limit for the month, inclusive of the product
returned. With this policy we hope to balance consumer protections with the Act’s objective
to limit personal consumption of medicinal cannabis to no more than two ounces of medicine
per month.

Any product returned for quality reasons will be sent to our laboratory for inspection and
analysis. If the product has evidence of pests, contaminants, or other problems, we will use
our inventory tracking system to identify all products produced from the same plant, whether
they are in our cultivation facility or patient care center, or have been sold to patients and
caregivers. Upon receipt of returned product from the patient care center the product
received will be weighed and its weight compared to recorded weight of the product when
returned. Management and security will investigate discrepancies and any reportable events
will be communicated to the Department. Once the source plant associated with a product
quality problem has been identified, any related product that remains in our possession will
be returned to the lab for inspection and the product will be destroyed. We will also issue a
consumer alert to patients who have received related product, and they will be encouraged to
return the potentially damaged product to their patient care center. Any returned product
received by our patient care center will be sent to our cultivation facility where it will be
incinerated after appropriate samples have been provided to the laboratory for analysis.
Throughout this process the volume of the product will be recorded in our inventory
management system, so there will be thorough documentation of the product’s disposition
and any diversion can be identified and managed as required by New Jersey law and the rules
of the Department.

Measure
2‐IV:
The
applicant
shall
complete
the
following
projected
income
statements
for
the

first
three
(3)
years
of
operation.
Round
all
amounts
to
the
nearest
dollar.


16
 CRITERION 2

COMPASSIONATE CARE FOUNDATION, INC.

PROJECTED INCOME STATEMENTS
REQUIRED FORMAT
,-!./%,&00% .(1234%,&00%
!"#$%&$%'("!%%%%
,-.1"0%'("!%%%%%%%% ,-.1"0%'("!%%%%%%%%%
)*++
)*+) )*+5
!"#"$%"

&'()*)+,-./,0)12,+,.3,-'3.45.
0'6)34'0'(.72,-)89)+6.:,;'+43 A................<=><?=>@@@ A..............=B>@C?>=@@ A..............BD>=C?>=@@

E4F'0.32::-)'3.35-(.45.
0'6)34'0'(.72,-)89)+6.:,;'+43 A......................?G=>@=@ A................<><=H>?B= A.................<>D=B>?@@
E4F'0.0'I'+2'.3520*'3J
K)('+;89L
.....&'()*)+'.M)3*52+43 A..............K=>B@C>?=@L A...............KB>D=C>?=@L

NENOP.!"#"$%" A................<=>DB@>@=@ A..............=?>=<=>=?= A..............CB>=CD>G=@

"QR"$S"SJ

&'()*)+,-./,0)12,+,.605T)+6 A..................=>?HD>@?B A..............<=>D=B>DB= A..............<U>C@C>BUB

&'()*)+,-./,0)12,+,.4'3;+6 A......................<@D>GG@ A...................D?C>U?U A....................CHH>U<B
&'()*)+,-./,0)12,+,.
:,*V,6)+6.,+(.-,W'-)+6 A........................?U>=@@ A.....................G=>@@@ A......................=B>@@@
....&'()*,-.!'3',0*F A..................<>=DB>@@= A................C>=H?><BU A..............<@>GDG>GB@
N'*F+5-569 A......................<<=>HC@ A...................D<B>HD< A....................BD@>DB@
X,--.X'+4'0 A........................B?>H<G A...................<BH>BBC A....................<HB>CUB
S'*20)49 A......................BUG>BCB A................?><CD><@G A.................?>D@H>@G?
S2::-)'3 A..........................H>@@@ A.....................<C>=@@ A......................?B>@@@
EY*'."Z:'+3' A........................B@><=@ A...................?@D>G@@ A....................DH@>C=@
%;-);'3 A......................BU<>GDU A................?>U@D>GCH A.................D>=HH>?<H
[+320,+*' A......................<D=>@@@ A...................D@@>@@@ A....................D@@>@@@
[+4'0'34 A......................H@@>@@@ A................<>?@@>@@@ A.................<>?@@>@@@
M':0'*),;5+\O/50;],;5+ A......................G@@>C@G A...................BUG>=@B A....................BUG>=@B
P',3'F5-(."Z:'+3'3 A......................CD@>@CH A...................U=D>@H? A....................UUD>@H?
^,(.M'W4
.....[+*5/'.N,Z'3 A..................=>C<<>DB= A..............?<><B@><UU A..............?B>?H<>CUU
NENOP."QR"$S"SJ A................<C>GBD>?GH A..............=?>D<D>DGB A..............CB>=<<>D?U
.....M)_'0'+*' A.................K<><@D><HHL A...................?@?><BU A......................=?><??

$2/W'0.58.R,;'+43 ............................C>?=@ ........................<@>@@@ ........................<<>?=@

$2/W'0.58.#)3)43 ..........................?B>=@@ .....................<@D>B=@ ......................<DD>B=@

17
 COMPASSIONATE CARE FOUNDATION, INC.
NEW JERSEY PAYROLL EXPENSE REPORT
REQUIRED FORMAT

!"#$%&$%'("! )*!+,%)&--%)*+."- +(./01%)&--%)*+."-

'("!%2344 '("!%2342 '("!%2345

!"#$%&&"'( .(%/(( !*-#%''((((((((( .(%/(( !*-#%''((((((((( .(%/(( !*-#%''(((((((((
)*+",%#- /+"(((( 01/#2&," /+"((((((((01/#2&," /+"(((((((( 01/#2&,"

*34565789:;<=(:63(%>?= @A (B((((((((((CD@EFGHIAA( @J B((((((@EFADEKJ@ICC @J B(((((((@EFDDEKFKILF

M57N=67:9O @@ (B((((((((((KDFECCCICG(
%N=9:;P67(Q:6:R=4=68 @ (B((((((((((((DDECGHIHH(
,9PS56R @H@ (B((((((@EDGFEFHHIGH(
/:?5T58O($UNNP98 D (B((((((((((@KFEFLHIFH(
$V5NN56R(:63(#=?=5<56R @G (B((((((((((KHDEFGHIHH(
$=?U958O KF (B((((((((((D@FEHFDIKH(
):TT()=68=9 G (B((((((((((((LFEG@GIHH(
':WP9:8P9O G (B((((((((((((DDECGHIHH(
#=7=:9?V A (B((((((((((((J@ECLHIHH(
!:O9PTT(+:X=7 (B((((((((((G@DEC@HIFF(
!:O9PTT(Y=6=Z87 (B((((((((((LGCELHKIGH(
0P9[=9\7()P4N(267I (B((((((((((AAAEGLKIJD(
@@ B(((((((((JDFECKGIFF
@ B(((((((((@HDEF@DIHH
@FA B((((((JEDLFEHFFIKL KK@
F B(((((((((KFJEGFJIJL
KH B(((((((((DKHEHDCIHH
AL B((((((@ECFCELGAILL
J B(((((((((@LCEHKJIFF
@@ B(((((((((KLCEFKFIKF
@H B(((((((((KKDECA@IKH
B((((((@E@JAEJLFIA@
B((((((@EDCAE@@@IAL
B(((((((((CKHEGLAIFA
@@ B(((((((((((JFLECGLI@K
@ B(((((((((((@@AEKHDIFJ
B(((((((DEGAGECC@IGD
F B(((((((((((KCKECJAIHF
K@ B(((((((((((FHGE@GJICJ
AL B(((((((KEHCLEJFKI@H
J B(((((((((((@FJELFLIFJ
K@ B(((((((((((LACEF@DIKJ
KH B(((((((((((LKFEALCILH
B(((((((@EG@GELFFIAL
B(((((((KE@CFECCDIGG
B(((((((@E@KFEF@FILC

+%+*'$ @FL B(((((((JEDA@ELJFIJ@ AHH B((((@JEFK@EK@CIKH AJC B(((((@CEGHKEGFDIGJ

CRITERION
2

18
 CRITERION 2


Measure
3:
The
applicant
shall
document
its
experience
running
a
not‐for‐profit
organization
or

other
business(es).


We are proud of our Board members’ experience working with and managing nonprofits.
The Board members have outlined their experience with nonprofits in their individual CVs.
Here is a partial list of nonprofits they have served:
• New Jersey Health Care Quality Institute
• New Jersey Health Care Payers Coalition
• The Epilepsy Foundation of New Jersey
• Newark AIDS Consortium
• The Leapfrog Group
• Gilda’s Club
• Self Insured Association of America
• National Robotics Education Association
• Healing Spaces
• The Long Island Power Authority
• State University of New York College at Old Westbury Foundation
• The Foundation of United Cerebral Palsy of Nassau County
• The Long Island 9/11 Memorial
• The American Association of Preferred Provider Organizations
• The Adler Aphasia Center
• The Health Enhancement Research Organization





19
 CRITERION 3

CRITERION
3
‐
COMMUNITY
INPUT
AND
APPROVAL



Compassionate Care has contacted municipal authorities and has a plan to solicit and incorporate
meaningful community input into the project. We seek to be a good, responsible neighbor to the
community, while providing much needed medical services to patients with debilitating medical
conditions.

Measure
1:
Input
from
the
city(s)
or
town(s)
where
the
applicant’s
ATC
would
be
located.


Compassionate Care has contacted the Town of Bellmawr to secure a meeting with
municipal officials, at which meeting we expect to review the program and proposed
cultivation and patient care center operations with the governing body or its representatives.
We are in the process of seeking a letter of recommendation.

Appendix R: Letters of Recommendation


Measure
 2:
 Input
 from
 the
 general
 public
 regarding
 the
 suitability
 of
 the
 applicant
 and
 the

general
 standards
 for
 location(s)
 such
 as,
 distance
 from
 a
 school,
 daycare
 center
 or
 other

child‐oriented
location;
distance
from
a
commercial
shopping
district,
pharmacy;
etc.


Compassionate Care is committed to strong public engagement and outreach to the

community. Our community input plan has three goals: (i) to establish a process by which
the community can express itself regarding the project; (ii) to inform the community about
medical cannabis issues; and (iii) to ensure that Compassionate Care's approach genuinely
reflects the community's needs. To reach our goals, we anticipate doing one or more of the
following, depending on input from municipal political leaders:
1. Identifying a broad cross-section of community-based organizations and
community leaders, including those representing indigent and traditionally
underserved and underrepresented residents, to learn how residents and
stakeholders can best receive useful information that enables them to participate
meaningfully.
2. Identifying and visiting civic, senior, and veteran organizations, health care
support groups, and community meetings to introduce our nonprofit organization,
our mission, and our vision for the patient care center. We believe this type of
outreach establishes our legitimacy with the community and our vested interest in
its welfare. We will listen receptively and respond to any concerns about the
project.
3. Holding a community meeting so Compassionate Care can introduce itself and
present the project to any parties with the same goals. Again, our purpose would
be to listen and find ways to be responsive.

20
 CRITERION 3

Measure
2
Response

cont’d


4. Completing our outreach efforts with a follow-up letter to community

stakeholders, letting them know that we heard their concerns and what procedures
we will follow in responding to such concerns.
5. In addition to the foregoing initiatives, Compassionate Care is committed to
engaging our patient and residential communities on an ongoing basis. The
Medical Advisory Board will always include at least two community members and
one patient (see response to Criterion 4, Measure 5). We will partner with local
community organizations to solicit volunteers for these positions.

Appendix D: Distance to Sensitive Sites

Appendix R: Letters of Recommendation









21
 CRITERION 4

CRITERION
4
‐
PATIENT
CARE
CENTER
SPECIFIC
CONSIDERATIONS



Measure
1:
The
applicant
shall
provide
a
plan
for
inventory,
record
keeping
and
security
which

shows
an
understanding
of
the
types
of
records
that
shall
be
considered
confidential
health

care
 information
 under
 New
 Jersey
 law
 and
 are
 intended
 to
 be
 deemed
 protected
 health

care
information
for
purposes
of
the
Federal
Health
Insurance
Portability
and
Accountability

Act
of
1996,
as
amended
[HIPAA].


Compassionate Care will use standard industrial supply chain tracking tools to keep proper
inventory levels of products available for our patients. Having an oversupply of inventory
could result in product degradation and increased security risks, but an undersupply might
deny patients access to their medicine. One of the capabilities of our supply chain tracking
system (described in Criterion 5, Measure 3) is to control our inventory and also anticipate
future production needs. Under our system, each plant in our cultivation facility is assigned a
unique, systematic serial number from the moment a cutting is taken. This serial number is
entered into our secure computer database so that we are always aware of the number and
strain of plants within our facility. We are also aware of the current status of the plant (e.g.,
whether it is in the vegetative or flowering growth stage). This information allows us to
forecast inventory levels for the future. If a patient inquires when a particular strain will be
available, we can determine how many plants of that strain are in production, what stage of
production they are in, and how long it will be before they are ready to harvest.

After harvesting, when the medical cannabis is securely transported to our patient care center
(see Criterion 5, Measure 1, Part 3), our supply chain tracking system is integrated with our
high-security delivery company and patient care center database. After a product from our
cultivation facility is placed in transit, the status of the package is updated to reflect pending
delivery confirmation, and then the status is updated when it is received by the patient care
center. Once we sell the product at the patient care center, information on the patient buying
it is associated with the serial number of the plant, so there is traceability from seedling to
sale.

Even in the absence of physical communication, our technology allows us to retrieve current
inventory levels from within our patient care center so the cultivation personnel are made
aware of any possible shortages or overages.

22
 CRITERION 4

Measure
1
Response

cont’d


Inventory Diversion Prevention

To prevent diversion by patients or caregivers, we will take the following measures:

• At the time of each purchase, verify an individual’s status as a qualified patient or
caregiver with a valid identification card;
• Have the individual agree not to distribute cannabis to non-patients;
• Have the individual agree not to use the cannabis for other than medical purposes;
• Maintain membership records on site or have them reasonably available;
• Track when members’ medical cannabis recommendation and/or identification
card expires;
• Enforce conditions of membership by excluding members whose identification
card or physician recommendation is invalid or has expired, or who are caught
diverting cannabis for non-medical use;
• Refuse to transfer medical cannabis to any person or entity, even if legally
qualified, if there is reason to believe such person or entity is using cannabis for
non-medical reasons or is likely to divert such medical cannabis to persons or
entities unauthorized to possess it under state law; and
• Monitor transactions and program controls to prevent a patient and/or caregiver
from purchasing more than the legal amount of cannabis that a patient may receive
in a month.

Having strict guidelines and policies in place to prevent diversion is important. Our supply
chain tracking system follows every plant from seedling to sale, so we can verify the
destination of every product Compassionate Care manufactures and sells. This system
allows us to:
• Prevent shrinkage within the cultivation facility, whereby plants are stolen, since
each plant has a barcode and if it is missing we will know that a serial number is
unaccounted for;
• Compare average yields of plants, whereby if plants in particular areas are
yielding less end product we can alert Security to a possible concern; and
• Require the shipping and receiving department to obtain delivery confirmations
for each product delivered, and log that information with our record keeping
system.

Furthermore, all patient care center sale transactions will be done through a point-of-sale
cashiering system, and excess inventory will be securely stored in vaults compliant with 21
CFR 1301.72.

23
 CRITERION 4

Measure
1
Response

cont’d


Since regular inventory and supply chain tracking is crucial to
preventing diversion to non-
medical recipients, inventory will be manually performed every day in the patient care center
by two background-checked employees to verify the accuracy of our computerized inventory
management system. Manual inventory will also be performed in our cultivation facility on
at least a monthly basis to ensure all products, byproducts, and discarded items in our
operations are accounted for. All information pertaining to production, transferring, sales,
and patients will be securely kept for a period of at least 7 years and be available for review
by the State of New Jersey as required by law.

Compassionate Care believes that by having strict guidelines aimed at preventing diversion,
and creating an inventory tracking system that allows us to follow each plant from seedling
to sale, we will be able to create a closed loop system where cannabis does not end up in the
possession of a non-medical user.

Recordkeeping and Security

Compassionate Care plans to create and preserve adequate and proper documentation of all
of its activities through designated recordkeeping systems to support operational needs, allow
for accountability, and comply with the State of New Jersey’s requirements. Our record
keeping and software system will be designed and managed by our Information Technology
(“IT”) Department. Our IT Director will make sure all data and information are highly
secure and backed up in real time, several times throughout the day. Data will not only be
backed up to private servers but also to an off-site, highly secure server location to prevent a
disaster from compromising Compassionate Care’s database and recordkeeping.

At a minimum, Compassionate Care will maintain a database that:

• Tracks all clients using their state medical cannabis identification card number;
• Anonymizes and secures patient and confidential records in an encrypted database
to comply with HIPAA, New Jersey identity laws, and other applicable laws;
• Tracks all products manufactured, sold, and the frequency of such sales;
• Maintains records for the total number of patients affiliated with Compassionate
Care, along with their location, local jurisdiction permit number, and all affiliated
business license numbers.

Compassionate Care will limit access to our network and web portal using not only network
passwords, but also by restricting IP addresses and MAC addresses to a specific computer.
The system will be designed to deny access to users not authorized to view certain
documentation and protect the privacy of confidential information. Certain confidential
documents will have file open passwords to add an additional layer of security. Whenever
possible the use of third party email, web, and data servers will be avoided. Compassionate
Care will provide training to internal and external users on these procedures. We have
developed an HIPAA manual and training program.

Appendix G: Operations Plan

24
 CRITERION 4

Measure
1
Response

cont’d


To meet the requirements set forth by the State of New Jersey and to meet the business needs
of Compassionate Care, an enterprise level application will be developed. The system will
have many users with corresponding access levels that fit into four basic groups.
• External Customers (many)
• Internal Customers (many)
• External Administrator (few)
• Internal Administrators (few)

Customers have very limited access and administrators will have more expansive access to
our systems. Outside vendors and patients are described as external customers with the
lowest access level assignment. Compassionate Care’s various departments and employees
are described as internal customers, with the second lowest access level. The State of New
Jersey, our third party lab testing service, and other regulatory bodies will be defined as
external Administrators. They will be given sufficient access to meet the requirements set out
in the Compassionate Use Medical Marijuana Act and associated rules. Internal
Administrators include the Board of Directors and department heads, and these will be given
the highest level of access. Passwords will be changed frequently and access levels
reassigned as necessary.

The system will manage a master database through modules defined for a specific reporting
purpose. One module may track the one-plant flow system that discloses the stage and
destination of all plants from clone or seed to final product. Unique tracking, testing,
barcodes, labeling, and packaging will greatly reduce the risk of diversion to other markets
and counterfeiting of the Compassionate Care brand. The one-plant flow module may be
used by other modules, such as a product availability forecast module.

Data entry from our internal customers will be routinely updated as any status changes occur.
Compassionate Care departmental directors will meet regularly to determine how system
modules should be updated or if new modules need to be created.

Compassionate Care will allow the State of New Jersey to have access to the cultivation
facility’s books, records, accounts, inventory management system, and any and all data
relevant to our permitted activities for the purpose of conducting an audit or examination.
With our record keeping and software design, Compassionate Care should be able to produce
records in sync with our various departments instantaneously or at least within 24 hours, in
the absence of unforeseen circumstances occurring. Compassionate Care shall be prepared
for quarterly financial record audits by the DHSS or other responsible state and local
authorities.

Appendix H: Security Plan

Appendix J: The Health Insurance Portability and Accountability Act (HIPAA) Manual
Appendix K: Human Resources Manual

25
 CRITERION 4

Measure
 2:
 The
 applicant
 shall
 submit
 a
 description
 of
 its
 proposed
 program
 for
 providing

counseling
 and
 educational
 materials
 regarding
 methods
 of
 administration
 and
 research

studies
on
health
effects
of
medicinal
marijuana
to
registered
qualifying
patients
and
their

registered
 primary
 caregivers.
 
 The
 applicant
 shall
 submit
 a
 description
 of
 its
 historical

relationship
with
clinical
or
research
activities,
if
present.




Compassionate Care embraces a patient-centered care coordination model influenced by the

Agency for Healthcare Research and Quality’s (AHRQ) definition of a patient-centered
medical home. In this section we give a basic overview of our care model and then describe
how Compassionate Care will implement elements of this model in our clinical practice. A
patient-centered medical home has the following characteristics:
• Patient-centered care
• Comprehensive care
• Coordinated care
• Superb access to care
• A systems-based approach to quality and safety

Overview

Patient-Centered Care

A medical home practice provides patient-centered care based on relationships and oriented
toward the whole person. Partnering with patients and their families requires understanding
and respecting each patient’s unique needs, culture, values, and preferences. The medical
home practice actively supports patients in learning to manage and organize their own care at
the level the patient chooses. Recognizing that patients and families are core members of the
care team, medical home practices ensure that patients are fully informed partners in
establishing personalized care plans. Patient-centered care requires a Clinical Care
Coordinator (CCC) who is a skilled advanced practice nurse working in partnership with the
patient’s primary care and/or specialty doctor.

Comprehensive Care

A medical home practice provides comprehensive care, assisting patients in meeting their
physical and mental health care needs, including prevention and wellness, acute care, and
chronic care. It needs to address various phases of a patient’s lifespan, including end-of-life
care. Comprehensive care requires care providers to work together as a team. This team
might include physicians, advanced practice nurses, physician assistants, nurses, pharmacists,
nutritionists, mental health workers, social workers, educators, and care coordinators.

The CCC plays a crucial role in comprehensive care. He or she must work collaboratively
with an interdisciplinary team and have the broad-based knowledge and experience necessary
to handle most medical needs of the patient and to resolve conflicting recommendations for
care.

26
 CRITERION 4

Measure
2
Response

cont’d


Coordinated Care

A medical home practice assists patients in coordinating care across all elements of the
broader health care system, including specialty care, hospitals, home health care, and
community services and supports. Such coordination is particularly critical during transitions
between sites of care, such as when patients are being discharged from the hospital. Medical
home practices excel at building clear and open communication among patients and families,
the patient’s primary care medical home, and members of the broader care team.

Superb Access to Care

A medical home practice delivers accessible services with shorter waiting times for urgent
needs, enhanced in-person hours such as flexible appointment times or physician availability
seven days a week, around-the-clock telephone or electronic access to a member of the care
team, access for non-visit related patient needs, and alternative methods of communication
such as email and telephone. Medical home practice is responsive to patients’ preferences
regarding access and provides for patients with special communication needs.

A Systems-Based Approach to Quality and Safety

A medical home practice takes a systems approach to quality and safety. It employs
evidence-based medicine and orients its practice to population-specific health management.
Using clinical decision support tools to guide it, the systems approach shares decision
making with patients and families, engaging in performance measurement and responding to
patient experiences and satisfaction. Sharing robust quality and safety data and improvement
activities publicly is an important marker of a system-level commitment to quality.

Implementation

Before the Visit

• Physician and patient discuss the risks and benefits of cannabis for the patient’s
debilitating medical condition.
• If the physician and patient agree that cannabis may be an appropriate treatment
for the patient, the physician enters the patient in the Physician Registry for
Medicinal Marijuana.
• The patient registers with New Jersey MMP, designating a caregiver if so desired.
• Patient obtains authorized personal identification card.
• Patient and/or authorized caregiver visits Compassionate Care’s patient care
center and meets with a CCC.

27
 CRITERION 4

Measure
2
Response

cont’d


Sharing Information

One of the most important roles of the CCC is to provide information, including answering
patients’ questions about a disease or its symptoms, discussing the physician’s
recommendation and the patient’s decision to try medicinal cannabis, and explaining the
appropriate use and methods for taking medical cannabis. Information is central to patients’
ability to manage well, but information alone is not enough. The goal in sharing information
for self-management support is to ensure that patients not only understand the information
but are also prepared to act on it in daily life. Telling patients what they need to know is not a
guarantee that they will be able to use the information, and conveying all critical information
during a short visit may not have the desired outcome if patients are not able to understand
and use it. The CCC will ask patients to complete a health risk assessment (described
below). We then will interpret that information to confirm the patient’s understanding of
healthy patient behavior.

Setting Healthy Goals

Studies show that patients rely on professional advice in determining health goals.
Collaboratively setting health improvement goals with patients is an important step in
motivating healthy behaviors. Using agenda-setting tools, CCCs will introduce the
collaborative process of establishing healthy goals. It is important that patients’ priorities in
goal setting lead the decision about which goals are established. By achieving small
successes toward a goal that is important to them, patients will enhance their confidence and
sense of control in managing their illness, and this will pave the way to achieving goals in
other areas.

Goal Setting, Action Planning, and Problem Solving

Helping patients know what to do to stay healthy is important, but the goal of self-
management support is to help them adopt the behaviors that will keep them healthy over
time. Motivating and coaching healthy behaviors is one method of supporting self-
management that can be done very effectively by CCCs. Moreover, for patients with chronic
conditions requiring medical cannabis, while setting health goals with their doctor is an
important step, few achieve their goals without more specific planning. Additional behavior
change coaching is needed to develop patient confidence in reaching goals. Trained CCCs
can effectively work with patients to define their action plans. With practice, tasks required
to support patients and families—such as making a specific plan of action, anticipating
barriers, and connecting them with community resources—can be the responsibility of
members of the care team other than the physician, often with equivalent results.

28
 CRITERION 4

Measure
2
Response

cont’d


Patient Education and Skill Building

Patients and families need clear information to understand the signs and symptoms of the
disease(s) and treatments, and training to build the skills to monitor clinical indicators such
as wasting, nausea, and intraocular eye pressure. This clinical content distinguishes self-
management education from self-management support, which helps people make behavior
changes and sustain them over time. CCCs with appropriate training can provide self-
management education. Primary care teams may have difficulty finding time and appropriate
staff to provide patient education sessions in the course of an office visit. CCCs will provide
just the right information in response to patient needs or questions, increasing the patient’s
understanding and skills incrementally. For in-depth education, CCCs will refer patients to
community programs offered by public health entities or hospitals that are an underused
resource. Psychosocial and emotional stressors, as well as physical symptoms, should be
considered in these programs.

Patient Engagement in the Collaborative Care Process

• Patient arrives and registers at Compassionate Care and is greeted by reception

staff for his/her scheduled or unscheduled appointment. Patient provides NJ
Medical Marijuana identification card and secondary form of identification.
• Reception staff use “warm handoff” introductions and explain CCC team member
role to patient.
• The CCC welcomes patient, escorts him/her to consultation room, and guides the
patient through an intake questionnaire covering information we are required to
report to the Department, such as patient demographics, intractable medical
condition, and the current severity of the patient’s pain and other symptoms.
• The CCC then explains that Compassionate Care wishes to collect additional data
for research and quality improvement purposes and requests the patient consent to
participation in a voluntary new patient Health Risk Assessment (HRA; contents
discussed below).
• The CCC reviews the patient’s request for medical cannabis to evaluate its
appropriateness and make alternative treatment suggestions if deemed necessary.
If patient consents, CCC will immediately contact patient’s primary or specialty
care provider to suggest an alternative treatment plan if medical cannabis does not
appear to be clinically indicated.
• The CCC and patient review goals to improve patient health and help them make
action plans that build confidence in their ability to reach these goals.
• The CCC uses patient education materials to provide learning and support for the
patient.
• The CCC uses “ask-tell-ask” to provide just the right information at just the right
time and “close the loop” to ensure patient knows how to use the information.
• The CCC collects feedback to prepare a personal home care plan that includes
goals and action plans to ensure patient and family know what to do when they
leave the visit.

29
 CRITERION 4

Measure
2
Response

cont’d


After the Visit

Ongoing Follow-Up

Sustaining healthy behaviors requires courage and tenacity, most often involving small,
incremental changes that build over time into bigger successes. Even the best plans of action
require adjustment to work effectively. Certain strains of medical cannabis may produce side
effects or not produce the desired effect, requiring further support and explanation or
alterations to make the plan workable. For all of these reasons, making regular contact with
patients after each visit or change in treatment is central to sustaining positive change. By
utilizing patient experience assessment and reporting tools, we will engage the voice of all
patients throughout the continuum of care.

Patient Experience Measurement and Outcomes Evaluation

• Every three months, or as clinically indicated, a CCC will repeat symptom

severity assessments to monitor changes from baseline in patient’s pain and other
symptoms
• Compassionate Care has selected a state-of-the-art survey collection tool to obtain
additional patient experience feedback and patient reported outcomes that will
enable further quality measurement, continuous improvement, and comparative
effectiveness evaluations.
• The CCCs will organize follow-up support to help patient sustain healthy
behaviors between visits.
• The CCCs will extend care into the community by linking patient to community
programs.

Measure
3:
The
applicant
shall
provide
an
acceptable
safety
and
security
plan,
including
staffing

and
 site,
 and
 a
 detailed
 description
 of
 proposed
 security
 and
 safety
 measures
 which

demonstrate
compliance
with
the
Rules
Related
to
the
Medicinal
Marijuana
Program.




The patient care facility will be a fully secured building, equipped with perimeter fencing,
on-site employee and patient parking, sufficient area lighting, surveillance, electronic
keycard access, on-site and parking lot security personnel, and alarms. Employees will be
fully trained on security procedures and Compassionate Care will conduct periodic safety and
training drills. Our Security Plan provides details as to specific proposed security and safety
measures that demonstrate compliance with the Rules Related to the Medicinal Marijuana
Program.

Appendix H: Security Plan

30
 CRITERION 4

Measure
 4:
 If
 the
 applicant
 proposes
 to
 cultivate
 and
 dispense
 at
 two
 separate
 physical

locations,
the
applicant
shall
provide
an
acceptable
delivery
receipt
plan,
including
measures

to
 ensure
 sanitary
 medicinal
 standards,
 security
 and
 inventory
 control,
 for
 the
 receipt
 of

medicinal
 marijuana
 from
 the
 cultivation
 site
 by
 ATC
 staff
 at
 the
 dispensing
 site.
 
 The

delivery
receipt
plan
shall
demonstrate
compliance
with
the
Rules
Related
to
the
Medicinal

Marijuana
Program.




Delivery from cultivation facility to patient care center will be secure. The inventory control
plan is provided in the Security Plan.

Appendix H: Security Plan

Measure
5:
The
applicant
shall
submit
a
description
of
its
Medical
Advisory
Board,
including
by‐
laws,
 setting
 forth
 the
 names
 and
 expertise
 of
 its
 members
 and
 describing
 how
 it
 will

function
within
the
organizational
structure
of
the
ATC,
consistent
with
the
Rules
Related
to

the
Medicinal
Marijuana
Program.

For
purposes
of
this
requirement,
it
is
not
necessary
for

the
 applicant
 to
 provide
 the
 name
 of
 the
 Medical
 Advisory
 Board
 member
 who
 is
 a

registered
qualifying
patient.


The Medical Advisory Board will be made up of physicians, nurses, other licensed healthcare
providers, community members, and patients. We have recruited a number of prestigious
physicians and PhDs to serve on the Board. Many of our Board Advisors are affiliated with
one or more acute care general hospitals located in and around our patient care center area. If
we are granted a permit, we will ask the New Jersey State Nurses Association to nominate
nurses to the Board. As patients are enrolled and develop experience we will recruit patients
to the Board. Once we have finalized the locations for our patient care centers we will recruit
local community members to the Board as well. Our bylaws will require that the Medical
Advisory Board include at least two residents of the community and one active medical
cannabis patient.

The duties of the Board will include but not be limited to:
• Setting protocols for the patient care centers,
• Monitoring and modifying the patient care center treatment protocols as needed,
• Assisting in directing and monitoring research on the clinical effectiveness and
safety of cannabis, and
• Providing educational outreach to other providers on the use of the drug.

The members of the Board and their credentials are as follows:

1. T. Patrick Hill, Ph.D. is Senior Policy Fellow, Edward J. Bloustein School of
Planning and Public Policy, Rutgers; Clinical Research Ethics Consultant, The
Cancer Institute of New Jersey; and Clinical Ethics Consultant, The Neonatology
Division UMDNJ-Robert Wood Johnson Medical School. Dr. Hill was asked to
join the Board for his expertise in biomedical ethics.

31
 CRITERION 4

Measure
5
Response

cont’d


2. Ronald Librizzi, DO is Chief of Maternal-Fetal Medicine and Clinical Associate

Professor at Thomas Jefferson University School of Medicine and Chief of
Maternal-Fetal Medicine at Virtual Health System in New Jersey. Dr. Librizzi is
Chair of the Osteopathic Board of Obstetrics and Gynecology and a past President
of the American College of Obstetrics and Gynecology. He serves the state as a
commissioner on the New Jersey Mandated Health Care Advisory Commission.
Dr. Librizzi was asked to serve on the Board for his knowledge of issues
concerning pregnancy, women’s health issues, and health care in New Jersey.
3. Suzanne M Miller, PhD is Professor at Fox Chase Cancer Center where she is the
Director of the Psychosocial and Biobehavioral Medicine Program, Director of the
Behavioral Center of Excellence in Breast Cancer, Director of the Intervention
Development and Measurement Core of the Cancer Information Service Research
Consortium, and Director of the Behavioral Research Facility Dr. Miller has been
asked to join the Board for her expertise in cancer, the psychosocial dynamics of
patient care, and research.
4. Christopher Olivia is the President of West Penn Allegheny Health System and the
former President of Cooper University Health System in Camden. He is also a
Professor at the University of Pennsylvania’s Wharton School. Dr. Olivia has
been recognized as one of the nation’s 50 most powerful physician executives by
Modern Healthcare and Modern Physician magazines. Dr. Olivia has been asked
to join the Board because of his specific experience in serving the indigent
population of New Jersey. His specialty is ophthalmology.
5. Alfred F. Tallia, MD, MPH is Professor and Chair, Department of Family
Medicine and Community Health at the Robert Wood Johnson Medical School,
University of Medicine and Dentistry of New Jersey. Dr. Tallia was asked to join
the Board for his expertise in family medicine and in physician education.

Measure
6:
The
applicant
shall
submit
a
plan
to
track
and
analyze
data
including
but
not
limited

to
patient
outcome,
utilization
and
trends.


The success of Compassionate Care’s patient-centered “medical home” care model is

predicated on the ongoing collection and analysis of patient data (for description of the
medical home model see response to Criterion 4, Measure 2, Part 1). We have asked several
well respected medical researchers to be on our Board and on our Medical Advisory Board.
From these groups we will form a Research Committee to direct our research.

32
 CRITERION 4

Measure
6
Response

cont’d


In the initial phase of our operations, we will choose three strains of cannabis to cultivate
based upon our knowledge and our assumptions about the patient population that will be
seeking care. It is impossible to forecast which types of eligible patients will actually elect to
enter our program, and currently there is no adequate scientific literature documenting how
different strains affect different classes of patients. Most of what is known about medical
cannabis can be characterized as craft knowledge based on individual practitioners’
experience and not systematic studies. It is central to our mission that we will develop a
more scientific knowledge base, which we will use to refine our practice and better educate
our patients, their physicians, the wider medical community, regulators, and the public. To
generate the necessary data for this enhanced knowledge base, Compassionate Care will
follow the rigorous data collection protocols described below.

Data Collection Protocols

Level 1 – Data Collection: Routine Record Keeping (applies to all patients)

Upon enrollment, patients and caregivers will be issued a Registry Identification (“ID”) Card
with a unique Registry ID number (“RIN”). Compassionate Care will use the RIN to track
an individual’s visits and transactions at our patient care center. In order to comply with the
ATC reporting requirements, we will, at the time of registration, conduct baseline symptom
severity assessments and collect data on patient demographics, the patient’s debilitating
medical condition, and such other information as the Department may require.

All purchases made by a patient or the patient’s caregiver will be identified by using the
qualifying patient’s RIN. Whenever a patient or caregiver has a CCC encounter or initiates a
transaction in our patient care center, our personnel will review the patient’s transaction
history, including the date of prior purchases, the cannabis strains purchased, the forms of
cannabis purchased (dried leaves and flowers, lozenges, or topical formulations), the amount
of cannabis purchased, and the patient’s current purchase eligibility limit (a patient may
purchase no more than two ounces of usable marijuana in a 30-day period). Details of new
transactions will be documented at the time of sale, and the patient’s transaction history will
be immediately updated. Pain and other symptom severity measures will be repeated at a
minimum of every three months.

Using these routine records, we will develop a comprehensive basic knowledge of the
products patients are using for different conditions, the forms and amounts of cannabis they
are consuming, and the kinds of clinical outcomes they are experiencing. Based on these
analyses, our clinicians will have a better foundation for making recommendations to patients
as to how they should use the product depending on their underlying disease and symptoms.
These data will also help us to identify those strains which might be contra-indicated for
certain conditions or which present larger safety concerns.

33
 CRITERION 4

Measure
6
Response

cont’d


Level 2 – Ongoing Clinical Evaluation (applies to consenting patients)

At their first visit to the patient care center and periodically afterwards, all patients will be
asked to consent to participate in additional data collection beyond that required by the
MMP. With the patient’s consent, we will collect a brief medical history including current
and prior pharmaceutical treatments and a summary of his or her current (or “baseline”)
medical conditions. Thereafter we will collect patient experience data using our survey
technology and join this with the patient’s consumption history. By systematically gathering
patient self-reports on the risks, benefits, and overall efficacy of the product, as well as
assessments of our service and educational efforts, we will be able to do more in-depth
analysis of different strains’ comparative effectiveness and more intensive continuing quality
improvement of our products and services.

Level 3 – Special, In-depth Clinical Research Partnerships with Clinicians and Other
Researchers

In addition to collecting the data just described, we will also seek out partners to conduct
more detailed clinical investigations of medical cannabis. We anticipate conducting studies
where, with patient consent, we will collect complete medical history and prior treatment
data from the patient’s medical records, and we will also collect clinical assessments of the
effects of cannabis. This will give us access to patient outcome data beyond patient self-
reports and enable more rigorous analyses of the risks and benefits of cannabis for different
types of patients. Drawing on the networks of our Board of Directors and Medical Advisory
Board, we will recruit specialists to explore in depth the therapeutic effects of cannabis for
special populations, such as children or pregnant women, or for particular conditions, such as
Crohns disease or end-stage cancer.

34
 CRITERION 5



CRITERION
5
‐
CULTIVATION
SPECIFIC
CONSIDERATIONS


Measure
1:
The
applicant
shall
provide
an
acceptable
safety
and
security
plan,
including
staffing

and
 a
 detailed
 description
 of
 proposed
 security
 and
 safety
 measures
 which
 demonstrate

compliance
with
Rules
Related
to
the
Medicinal
Marijuana
Program.
Supporting
documents

should
be
included
as
Appendix
H.




I. The
description
shall
include
a
detailed
floor
plan
for
the
ATC
cultivation
site,
which

indicates
 location
 and
 design
 standards
 and
 performance
 specifications
 of
 security

devices
to
be
utilized.



II. The
 applicant
 shall
 provide
 a
 plan
 to
 involve
 and
 coordinate
 with
 local
 law

enforcement
 authorities
 on
 security
 and
 safety
 issues,
 and
 identify
 the
 law

enforcement
officials
contacted
during
the
development
of
this
plan.


III. If
 the
 applicant
 proposes
 to
 cultivate
 and
 dispense
 at
 two
 separate
 physical

locations,
the
applicant
shall
provide
an
acceptable
delivery
plan,
including
measures

to
 ensure
 sanitary
 medicinal
 standards,
 security
 and
 inventory
 control,
 for
 the

delivery
of
medicinal
marijuana
from
the
cultivation
site
to
the
dispensing
site.

The

delivery
plan
shall
demonstrate
compliance
with
the
Rules
Related
to
the
Medicinal

Marijuana
Program.




IV. All
 responses
 shall
 be
 utilized
 for
 internal
 Department
 review
 only
 and
 shall
 not
 be

available
for
public
comment
or
review.



Compassionate Care understands that our most important assets are our patients and
employees, and our overriding responsibility is to provide for their safety and security. We
have consulted with Dunbar, a leading nation-wide security company, and with other security
experts, to make sure our security plan considers all possible threats while utilizing today’s
most up-to-date technology to counteract them. We have developed a plan that meets or
exceeds current standards for policing and securing the type of facility we will be operating.
We have divided our security plan into two components: Cultivation Facility Security and
Operational Security. The key elements of cultivation facility security are:
• Physical inaccessibility of the site (fenced with limited ingress) and optimal
lighting;
• Around-the-clock protection and surveillance by armed security personnel;
• Comprehensive video surveillance, monitored both on site and remotely;
• Tight access control, both to the facility and to the various areas within it, through
keycard and password restriction;
• Electronic intrusion detection; alarms, both silent and audible; panic buttons; and
• Immediate, selective or total lockdown capability.

Key elements of operational security are:

35
 CRITERION 5


Measure
1
Response

cont’d


• Strict control of production and comprehensive tracking of all products in all

stages of production, including excess, returned, of substandard product destined
for destruction rather than sale;
• Armored car delivery to dispensary;
• Transactional security, including cashless operations at the cultivating facility;
• Comprehensive IT security;
• Strict access control for guests, media, and other visitors;
• Thorough vetting of employees and contractors, including extensive background
checks and probationary evaluation; and
• Comprehensive and ongoing training of all staff in both routine and extraordinary
security procedures, emergency response procedures, and disaster preparedness.

Appendix H: Security Plan

Measure
2:
The
applicant
shall
provide
a
description
of
the
enclosed,
locked
facility
that
would

be
 used
 in
 the
 cultivation
 of
 medicinal
 marijuana,
 including
 steps
 to
 ensure
 that
 the

medicinal
marijuana
production
shall
not
be
visible
from
the
street
or
other
public
areas.






If
the
enclosed
site
is
a
greenhouse,
identify
materials
used
in
construction
of
panels.
Glass,

fiberglass,
 metal,
 or
 polycarbonate
 panels
 shall
 be
 used
 in
 construction
 of
 the
 facility;

polyethylene
film
is
not
permissible.
Describe
window
and
vent
covers.




The masonry-constructed building is 127,564 square feet, on a lot of approximately 5 acres.

The building is constructed of steel and concrete block. The 12" thick exterior perimeter
walls provide a solid base for security. All windows will be fitted with steel grates for
security. The remainder of the building has no windows, and the exterior doors have no
external access—they exist for egress purposes only. These doors have mechanisms only for
exiting the facility, with no exterior handles or hinges. If an intruder tried to enter the
facility, he would not be able to use the doors as an entry point. Since the only windows will
be fitted with steel grates and there are no doors for exterior entry, potential intruders would
have great difficulty gaining unauthorized access. Limiting the access through these existing
design elements deters and reduces the likelihood of unwanted intrusion. The entire facility
is to be fenced off, and all parties entering the grounds will need to go through a security
gate. This also greatly reduces the likelihood of unauthorized access.

36
 CRITERION 5


Measure
3:
The
applicant
shall
demonstrate
an
ability
to
provide
a
steady
supply
of
medicinal

marijuana
to
registered
qualifying
patients.





Measure
3‐I:
The
applicant
shall
provide
a
start‐up
timetable
which
provides
an
estimated
time

from
 issuance
 of
 an
 authorization
 for
 operation
 to
 limited
 operations
 to
 full
 operation,
 as

well
as
the
basis
for
these
estimates.



The planned startup timeline for our cultivation facility is summarized in the following table
showing the dates of the most significant construction and horticultural milestones. Upon
award of an ATC permit, Compassionate Care is prepared to immediately begin construction
planning and we expect to have construction complete by July 29. The General Contractor
will complete the primary growing areas first, so that horticultural activities can begin while
construction in other areas is ongoing. We will start growing in the facility on May 27, we
expect first harvest on August 1, and product will be available for sale by August 15. The
dates shown here are subject to change based on factors such as unexpected shortages of
construction materials, permitting and zoning delays.

37
 CRITERION 5



Measure
3‐I
Response

cont’d


Month Day Construction Milestone Horticultural Milestone

Construction commences: mobilization of

construction crews, tools, machinery and
22
equipment; review and finalization of
March specifications and prints
Begin building preparation: obtain
construction permits; order and release of
28
specified construction materials and
equipment
Layout of wall panel system, electrical
4
work and mechanical work
Begin build out of flowering rooms
including wall and ceiling panels, electrical
April 11
work, mechanical work, sprinkler system,
and doors

Flowering room wall and ceiling panels

complete. Electrical and mechanical to
work in conjunction with same time
27 Begin growing
May schedule. Concrete floor finishing,
installation of bumper, pipe guards and
Frasier racks
Begin build out of non-flowering room
30 process areas, exterior doors, docks, and
dock levelers
Start mother plants.
1 Move production plant to
vegetative cycle
Move production plants to
June 15
flowering cycle
Begin build out of office (employee) areas
20
including lockers, bathrooms and cabinetry
29 Start alternating month cycle

15 Completion of build out in all areas

July
18 Final touch up
29 Completion of all construction work
1 Harvest first crop
15 First product available for sale
August

38
 CRITERION 5


Measure
 3‐II:
 The
 applicant
 shall
 describe
 its
 knowledge
 of
 (and
 experience
 with)
 organic

growing
 practices
 or
 agricultural
 growing
 practices
 to
 be
 used
 in
 their
 cultivation
 of

medicinal
marijuana.



The Organic Foods Production Act of 1990 prohibits the following production practices and
materials. Compassionate Care will make every effort to use products that are compliant
with the intent of these regulations.

Prohibited crop production practices and materials

• Seed, Seedlings, and Planting Practices. For a farm to be certified under this
chapter, producers on such farm shall not apply materials to, or engage in
practices on, seeds or seedlings that are contrary to, or inconsistent with, the
applicable organic certification program.
• Soil Amendments. For a farm to be certified under this chapter, producers on such
farm shall not:
o Use any fertilizers containing synthetic ingredients or any commercially
blended fertilizers containing materials prohibited under this chapter or
under the applicable State organic certification program; or
o Use as a source of nitrogen: phosphorous, lime, potash, or any materials
that are inconsistent with the applicable organic certification program.
• Crop Management. For a farm to be certified under this chapter, producers on
such farm shall not:
o Use natural poisons such as arsenic or lead salts that have long-term effects
and persist in the environment, as determined by the applicable governing
State official or the Secretary;
o Use plastic mulches, unless such mulches are removed at the end of each
growing or harvest season; or
o Use transplants that are treated with any synthetic or prohibited material.

Title 7, Part 205 of the National Organics Program prohibits the following substances,
methods, and ingredients in organic production and handling. Compassionate Care will make
every effort to use products that are compliant with the intent of these regulations.

To be sold or labeled as “100 percent organic,” “organic,” or “made with organic (specified
ingredients or food group(s)),” the product must be produced and handled without the use of:

39
 CRITERION 5


Measure
3‐II
Response

cont’d


• Synthetic substances and ingredients, except as provided in §205.601 or §205.603;

• Nonsynthetic substances prohibited in §205.602 or §205.604;
• Nonagricultural substances used in or on processed products, except as otherwise
provided in §205.605;
• Nonorganic agricultural substances used in or on processed products, except as
otherwise provided in §205.606;
• Excluded methods, except for vaccines: provided that the vaccines are approved in
accordance with §205.600(a);
• Ionizing radiation, as described in Food and Drug Administration regulation, 21
CFR 179.26; and
• Sewage sludge.

Hydroponics vs. Organics

Compassionate Care will be using efficient hydroponic cultivation techniques to produce

high quality medical cannabis for New Jersey’s patients. Considerable debate surrounds the
value of organic versus hydroponic cultivation methods. When weighing the pros and cons
of the two cultivation methods it is important to recognize the reasons that organically grown
products are gaining popularity. Consumers want products that are not tainted by hazardous
chemicals or poisons and that do not harm our fragile ecosystems. Fundamental principles of
organic cultivation are:
• Avoiding chemical pesticides through the use of natural pest control measures,
• Caring for soil through composting and erosion control, and
• Moderation of nutrient application.

Compassionate Care’s efficient hydroponic cultivation processes are in alignment with these
principles.
• Compassionate Care will avoid chemical pesticides through a holistic approach to
pest management that emphasizes preventative measures;
• Compassionate Care will use soil-less hydroponics and will incinerate all unused
plant material under a limited-waste policy;
• Compassionate Care will adhere to strict nutrient schedules and will utilize highly
efficient nutrient dosing technologies to minimize, if not eliminate, nutrient waste.

40
 CRITERION 5


Measure
3‐II
Response

cont’d


Through efficient hydroponic processes and the use of pure hydroponic nutrients
Compassionate Care will be able to minimize use of substances that would not be allowed by
the Organic Foods Production Act of 1990, by the regulations in Title 7, Part 205 of the Code
of Federal Regulations, or by the National Organic Program. Through detailed product safety
and laboratory testing protocols (described in our Product Safety Plan) Compassionate Care
will ensure that all products are free of harmful yeasts, molds, bacteria, and chemical
residues. These measures will produce a product far superior to organic standards—one that
is cleaner, safer, and greener.

Appendix P: Environmental Plan

Appendix M: Hydroponic Design
Appendix N: Product Safety Plan

Measure
 3‐III:
 The
 applicant
 shall
 describe
 its
 quality
 control
 program
 and
 steps
 that
 will
 be

taken
 to
 ensure
 the
 quality
 of
 the
 medicinal
 marijuana,
 including
 purity,
 potency
 and

consistency
of
dose.



Quality control and product safety are vitally important components of the medical cannabis
industry because patients with compromised immune systems often utilize medical cannabis
to improve their condition. As such, the medicine must be safe and free of contaminants to
prevent further complications to patients with already weakened health. Too often medical
cannabis contains mold, bacteria, pesticides, or other harmful substances. This can be
attributed to the lack of lab testing and quality assurance when distributing cannabis.

To address this concern, Compassionate Care has teamed up with a leading national
laboratory specializing in cannabis science. We are committed to providing clean, safe, and
effective cannabis to patients in need. Compassionate Care will test at least 8 different times
along the plant production process before a medical cannabis patient ever receives one of our
products. The testing results and data will be clearly labeled on our packaging so every
patient knows that their medicine is safe for consumption.

Additionally, we will abide by strict product safety and testing standards that currently do not
exist in the emerging cannabis industry. There are no state or federal guidelines defining
acceptable levels of chemical or biological residues for cannabis. Moreover, there are no
state or federal guidelines regarding appropriate analytical methods for detecting these
residues in or on cannabis medicines. We see this lack of official industry requirements and
protocols as a unique opportunity to self-impose these standards, to not only represent our
industry well but to ensure patient safety and medical efficacy. Compassionate Care will,
with the help of the highly-qualified scientists at the laboratory, self-impose product safety
and testing protocols that will ensure all products produced by the proposed facility will be of
known potency and free of chemical and biological contaminants. These protocols will
produce a level of quality control far superior to existing industry standards.

41
 CRITERION 5


Measure
3‐III
Response

cont’d


The quality control process involves the examination of products and processes for certain
minimum levels of quality. The goal of the quality control team is to identify products, or the
processes used to develop products, that do not meet specified standards of quality. If a
problem is identified, the job of the quality control team may involve stopping production
temporarily and/or recalling finished products.

Compassionate Care has an effective and environmentally sensitive approach to mold,

disease, pests, and heavy metal management that emphasizes prevention, observation, and
intervention. Compassionate Care will employ this strategy to manage these problems in a
manner that meets Organic Foods Production Act standards, while minimizing the use of
pesticides to reduce potential hazards for human, wildlife, and ecosystem health.

Appendix N: Product Safety Plan

Measure
3‐IV:
The
applicant
shall
describe:


• Methods
 to
 ensure
 that
 seed
 production
 and/or
 hybridization
 is
 prevented
 during

cultivation
of
medicinal
marijuana


• Methods
of
testing
for
the
presence
of
mold,
bacteria
or
other
contaminants


• Procedures
for
routine
scouting
of
insect
and
plant
disease
conditions


• Methods
to
control
insect
pests
that
do
not
include
the
application
of
pesticides
during

cultivation
 of
 medicinal
 marijuana,
 in
 accordance
 with
 the
 Rules
 Related
 to
 the

Medicinal
Marijuana
Program

• Procedures
 for
 proper
 sanitation
 practices
 to
 minimize
 plant
 disease,
 and
 to
 promptly

dispose
of
diseased
plant
material
in
a
secured
disposal
area

• Methods
 for
 utilization
 of
 fans
 and
 cooling
 systems
 to
 maintain
 airflow
 patterns

sufficient
to
prevent
or
minimize
plant
disease
and
insect
infestation.

• Methods
 to
 keep
 environment
 free
 from
 flowering
 male
 plants
 to
 ensure
 that
 female

plants
are
not
pollinated
and
seed
production
and/or
hybridization
is
prevented

• Recordkeeping
of
any
cultural
measures
used
for
plant
pest
or
disease
control,
including

disposal
of
culled
plants


• The
 various
 strains
 of
 marijuana
 to
 be
 dispensed,
 and
 the
 form(s)
 in
 which
 it
 will
 be

dispensed

• Record
keeping
for
each
package
by
lot,
label
and
bar
code

• Area
security


• Packaging
and
labeling
requirements

• Methods
of
processing
in
a
safe
and
sanitary
manner


42
 CRITERION 5


METHODS
TO
ENSURE
THAT
SEED
PRODUCTION
AND/OR
HYBRIDIZATION
IS
PREVENTED
DURING
CULTIVATION
OF

MEDICINAL
MARIJUANA



Unwanted seed production and strain hybridization will be prevented by proper facility
design and maintenance. The proposed facility consists of sealed cultivation rooms that do
not allow exchange of micro-size particles such as pollen. A Class 10 clean room will be
present before entering the cultivation rooms of the facility to ensure that unwanted elements
do not enter the facility. Staff will be required to wear clean suits and pass through a
decontaminating air shower to eliminate or prevent pests and pollen from entering the
cultivation rooms via staff clothing. Temperature, air flow, and humidity will be controlled
by a state-of-the-art environmental control system that eliminates the exchange of outside air.
HEPA filters and activated carbon air scrubbers further reduce the possibility of pollen
entering the cultivation facility and pollinating flowering plants.

Pollination of female plants will be further mitigated through the use of feminized seeds
during the initial startup phases of the project. Feminized seeds are cannabis seeds that have
been bred multiple times to create seeds that predominately produce female plants.
Feminized seeds will ensure that few, if any, male plants exist within the cultivation facility.
Male plants generally can only develop if non-feminized seeds are used. Compassionate Care
will create parent plants from germinated feminized seeds and use cloning processes to
effectively produce a large amount of new plants that share the exact same genetic
characteristics as their parent.

Any male plants identified in the cultivation areas will be promptly removed and incinerated,
thereby minimizing, if not eliminating, the potential for pollination of flowering female
plants. Preservation of male plants is not necessary since breeding of different genetic strains
is not planned at the proposed facility.

Appendix N: Product Safety Plan

METHODS
OF
TESTING
FOR
THE
PRESENCE
OF
MOLD,
BACTERIA
OR
OTHER
CONTAMINANTS



Compassionate Care has engaged a leading national laboratory as a third-party laboratory-

testing firm to develop an integrated monitoring program that ensures, to the greatest extent
possible, that results are truly representative of real-world conditions with negligible artifacts
due to sample collection and processing. Our laboratory will define when and where samples
should be taken, what tests should be run, and how results should be interpreted. This is the
next step in cannabis science and beyond the scope of what is typically offered in the market
today.

Laboratory testing is a critical part of the quality assurance plan for the proposed facility.
Testing will be performed by our laboratory and will focus on three basic goals: 1) ensuring
product safety, 2) optimizing horticulture practices, and 3) research and development of new
products. Ensuring product safety will be the priority for laboratory testing. The protocols
for that process include:

43
 CRITERION 5


Measure
3‐IV
Response

cont’d


• Developing a sampling strategy

• Sample collection
• Environmental sampling
• Laboratory analysis
• Adjusting testing processes
• Adjusting safety standards

The effectiveness of the product safety protocols outlined here is dependent on the staff
members who carry them out on a regular basis. Compassionate Care will, therefore, hold
regular training programs to educate staff on the importance of these protocols. Staff will be
trained to identify molds, yeasts, bacteria, pests, and irregular growth patterns. Plants
identified by staff as having one or more of these issues will be flagged for further inspection
by laboratory personnel.

Appendix I: Employee Training Manual

Appendix N: Product Safety Plan

PROCEDURES
FOR
ROUTINE
SCOUTING
OF
INSECT
AND
PLANT
DISEASE
CONDITIONS



Close observation is critical to the safety of our products. While Compassionate Care’s
facility and procedures will be designed in a way to prevent pests and contaminants,
examination of our products and environments is essential to detect and quarantine problems
early on before they spread. Close observation will limit the need for extreme intervention
measures later.

Some of the most common pests, molds, and diseases, which Compassionate Care’s staff will
be trained to detect early on and to combat using appropriate intervention measures, are:
• Spider Mites
• Aphids
• White Flies
• Powdery Mildew
• Damping-off and Root Rot
• Bud Rot
• Mildew and Rust

More information on these pests, molds, and diseases, including pictures, is contained in our
Product Safety Plan.

Appendix N: Product Safety Plan

44
 CRITERION 5


Measure
3‐IV
Response

cont’d


METHODS
TO
CONTROL
INSECT
PESTS
THAT
DO
NOT
INCLUDE
THE
APPLICATION
OF
PESTICIDES
DURING
CULTIVATION

OF
MEDICINAL
MARIJUANA,
IN
ACCORDANCE
WITH
THE
RULES
RELATED
TO
THE
MEDICINAL
MARIJUANA
PROGRAM


Even though Compassionate Care’s facility and operations are designed to prevent harmful
organisms from entering the facility, we realize that at some point these problems will occur
and intervention will become necessary. Compassionate Care’s first priority in intervention is
to remediate as many compromised plants as possible. This is to be accomplished while still
upholding our product safety standards, and if there is ever a decision or tradeoff between
patient health and minimizing plant loss, Compassionate Care will always put patient safety
first.

In the event of any type of infestation, Compassionate Care will preferentially use organic-
based pesticides and fungicides to control an invading population or disease infestation.
While our first solution is always preventative, in the event that pests and diseases do occur,
our Product Safety Plan includes:
• General procedures for handling common pests, molds, and diseases;
• Policies for minimizing pesticides use; and
• Alternative intervention methods including CO2 overdose and Radionics.

General Procedures for Handling Common Pests, Molds, and Diseases

Our Product Safety Plan includes general procedures for handling the most common pests,
molds, and diseases discussed previously. The general approach to all intervention methods
is to use the least toxic (i.e., most organic) approaches first. More aggressive measures will
be taken only after initial approaches have proven unsuccessful. Consideration of the
cultivation cycle will also be given when deciding on a mitigation approach so that
potentially harmful residues have time to degrade to acceptable levels before products are
distributed. Finally, Compassionate Care will seek alternative measures to using pesticides,
fungicides, and insecticides to remediate pests and contaminants and will continuously
develop safer and more effective mitigation measures.

Policies for Minimizing Pesticides

Compassionate Care is committed to minimizing the usage of pesticides. If pesticides are

used, plants absorb them during the cultivation process. In turn, they enter the human body
after a patient consumes the final product. Repeated exposure to unknown chemical poisons
is known to build toxic levels in a consumer’s system. There have been instances where
usage of harmful pesticides in cannabis plants have caused serious health problems or even
death. Because patients often consume cannabis every day for many years, there is a
substantial threat of health complications through repeated exposure to toxic pesticides.
Compassionate Care is well aware of the potential health hazards created through
administration of pesticides, and is committed to minimizing these health risks.

45
 CRITERION 5


Measure
3‐IV
Response

cont’d


Under Compassionate Care’s comprehensive product safety strategy highlighted in this

Section, intervention measures that include pesticide application will be implemented only
after all preventative measures have proven unsuccessful and application of pesticides is
deemed absolutely necessary. Under such conditions, botanically-based (i.e., organically-
derived) products will be preferentially used. These formulations are far less toxic and pose
less risk to humans, wildlife, and the environment than their synthetic counterparts. Attention
will be given to the environmental persistence of any pesticide used and the growth stage of
the plants on which they will be used so that residual levels in finished products will be
below levels of concern for human and wildlife health.

Alternative Remediation Methods

Compassionate Care will continue to explore innovative and alternative ways of remediation.
As the first course of action is always preventative, alternative methods will be explored to
avoid the use of chemicals. Two of these alternative methods include Controlled CO2
overdose and Radionics.

PROCEDURES
FOR
PROPER
SANITATION
PRACTICES
TO
MINIMIZE
PLANT
DISEASE,
AND
TO
PROMPTLY
DISPOSE
OF

DISEASED
PLANT
MATERIAL
IN
A
SECURED
DISPOSAL
AREA


Compassionate Care seeks to create clean room standards that parallel the protocols used in a
scientific laboratory. All departments within the Compassionate Care facility will have
individual clean room standards that are tailored to department-specific vulnerabilities and
day-to-day responsibilities, and there will be one central clean room that ensures no outside
hazards are brought into our facility. The clean room is a highly controlled area that limits
the level of environmental pollutants such as dust, airborne microbes, aerosol particles, and
chemical vapors. Our on-site laboratory will routinely monitor the clean room as well as
other areas of the facility to make sure the number of particles per cubic meter remains at
levels that are safe and acceptable by our clean room standards.

While access to our facility will be limited, individuals that do need to enter will be briefed to
understand that we manufacture products used as medicine, and that everyone must follow
our clean room protocols accordingly. After passing security clearances required for entry,
staff will enter and exit a central clean room through airlocked doors. There is a mandatory
requirement for any individual entering our facility to wear:
• Company clean suits;
• Hairnets and beard nets (if necessary);
• New disposable gloves;
• Company clean shoes or non-slip shoe coverings; and
• Facemasks, which may be required in certain circumstances.

46
 CRITERION 5


Measure
3‐IV
Response

cont’d


Additionally, all personal items must be stored in secure lockers. Clean room air showers are
available on site. In addition to initial security clearances, individuals will undergo another
clearance level just to ensure everyone is complying with Compassionate Care’s clean room
protocols before entering any manufacturing areas.

Cleaning is an integral part of maintaining an environment that is free of chemical and

biological contaminants. Proper cleaning will be performed before build-out is initiated, after
build-out is complete, and regularly throughout the production cycle. Chlorine-based
cleansers are appropriate for use on all open surfaces (e.g., benches, countertops, hydroponic
trays) used for cultivation or food preparation. Specific areas of the facility may require more
aggressive treatments such as fumigation by propylene oxide or a similar fumigant to combat
existing microbiological contamination or pests.

The cultivation facility must be easy to clean and maintain. This is facilitated by
• Appropriate, durable finishes for each functional space;
• Careful detailing of such features as cultivation room entrances, casework, and
finish transitions to avoid dirt-catching and hard-to-clean crevices and joints;
• Adequate and appropriately located maintenance spaces;
• Special materials, finishes, and details for spaces that are to be kept sterile;
• Incorporation of antimicrobial surfaces.

Additionally, Compassionate Care will encourage a culture of clean hygiene and sanitary
practices through training, seminars, signage, and other means, while implementing
procedures such as:
• Allowing drinking, eating, and gum-chewing only allowed in designated break
room areas;
• Requiring full clean room attire to be worn in the facility;
• Requiring employees to cover themselves when coughing, sneezing, blowing their
noses, etc.;
• Allowing minimal personal items to be brought to the facility and requiring
everything to be stored in designated locker room areas.

METHODS
FOR
UTILIZATION
OF
FANS
AND
COOLING
SYSTEMS
TO
MAINTAIN
AIRFLOW
PATTERNS
SUFFICIENT
TO

PREVENT
OR
MINIMIZE
PLANT
DISEASE
AND
INSECT
INFESTATION.


The utilization of fans and cooling systems can be effective measures of preventing and
controlling plant disease and infestation through ambient air movement, temperature and
humidity control.

47
 CRITERION 5


Measure
3‐IV
Response

cont’d


Ambient air movement

For every 4x8 area on the pallet racking system there will be 20 growing plants. An
oscillating fan will be installed for each area to help facilitate air movement above and below
the plant canopy and reduce the risk of any mold growing within the tray. This also helps the
plant to become strong and hardier. The constant air circulation will take any remaining
stagnant water on the bottom of the tray bed and expedite evaporation. The repetitive
movement of the oscillating fans helps keep the air flowing throughout the grow area and
reduce the risk of mold and mildew from forming as well as discourage pests from hanging
on leaves. The air movement from the same oscillating fan will also be pushing hot air that
accumulates from the light on top of the canopy, removing any hotspots and issues that may
develop from that heat.

Temperature

The ideal temperature for growing cannabis is between 72 degrees and 78 degrees. The
environmental control system will use high BTU's. BTU stands for British Thermal Unit, the
unit of measurement that is designated for cooling. The air conditioner vents in this system
will be strategically placed throughout the cultivation rooms in order to evenly distribute the
cool air and prevent any hot areas from developing leading to plant stress. Each cultivation
room will have a separate air conditioner to avoid contamination of pests or pollen migrating
from one room to another. The system also has a series of high powered exhaust fans that
will extract heat from the room, filter through activated carbon charcoal, and remove it. This
will regulate temperatures, maintain them in the ideal conditions and prevent the actual
ambient air temperature in the room from getting too hot.

Humidity Control

The cultivation rooms must have a relative humidity level which needs to stay 50% or below
in order to prevent mold or mildew from forming on the plant's stalk, leaves, or flowers. The
system will regulate these humidity levels by using either special dehumidifiers for high
concentrations of humidity, or using the exhaust fans on an as needed basis to prevent the
humidity from rising and any mildew or mold from forming.

Appendix M: Hydroponic Design

Appendix N: Product Safety Plan

METHODS
TO
KEEP
ENVIRONMENT
FREE
FROM
FLOWERING
MALE
PLANTS
TO
ENSURE
THAT
FEMALE
PLANTS
ARE
NOT

POLLINATED
AND
SEED
PRODUCTION
AND/OR
HYBRIDIZATION
IS
PREVENTED


Measures to prevent pollination of female plants are detailed in Criterion 5, Measure 3-IV.

48
 CRITERION 5


Measure
3‐IV
Response

cont’d


RECORDKEEPING
OF
ANY
CULTURAL
MEASURES
USED
FOR
PLANT
PEST
OR
DISEASE
CONTROL,
INCLUDING
DISPOSAL
OF

CULLED
PLANTS



Product safety related results (e.g., lab results, pesticide application logs, remediations,
recalls, etc.) will be reported quarterly to the State of New Jersey or designee. Reports will
be jointly prepared by Compassionate Care and its laboratory and will include raw data,
statistical representations, and narratives. Product safety results will be reported as required
to the State of New Jersey.

Our laboratory will maintain a custom-tailored laboratory information management system to

manage samples, from collection to reporting. All samples are given a unique serial that will
link to the unique plant serial number used by Compassionate Care’s supply chain tracking
system. This linkage will allow quality controls, such as product recalls, to be implemented.

The various data and information generated by our laboratory will be stored remotely on a
secure server that will be backed up regularly. Access to data and information will be
restricted to lab personnel and Compassionate Care. Access to the raw data will be restricted
to principals of our laboratory and Compassionate Care. Staff level employees will have
limited access. Compassionate Care personnel will be provided with a login and password
that enables them to view data and reports. In addition, Compassionate Care’s information
management system will have secure access to the raw data so that customized reports can be
prepared as needed from Compassionate Care’s system.

Compassionate Care will keep detailed records of all intervention measures utilized. Records
will indicate where and when treatments occurred along with the name and quantity of the
products used. Additionally, this information will be reported to our laboratory to aid in lab
analysis. By knowing which pesticides to analyze for, our laboratory can focus on
developing and maintaining analytical methods that can verify the presence of the given
chemicals at concentrations below levels of concern.

While Compassionate Care recognizes the sensitive nature of our information and has
designed a system to keep data secure and confidential, we also recognize the needs of
patients and dispensaries to know about the products they are consuming. For all products
that are distributed from our facility, the product safety test results will be clearly labeled on
all of our packaging. A final Compassionate Care seal will be placed on all of our products
so customers know the product has not been tampered with or altered.

THE
VARIOUS
STRAINS
OF
MARIJUANA
TO
BE
DISPENSED,
AND
THE
FORM(S)
IN
WHICH
IT
WILL
BE
DISPENSED


At least 85 cannabinoids have been identified in the cannabis plant. Tetrahydrocannabinol

(THC), cannabidiol (CBD) and cannabinol (CBN) are the most prevalent natural
cannabinoids; each has its own medicinal properties (table below). The relative amounts of
these cannabinoids, in particularly the CBD:THC ratio, ultimately determine the medicinal
and psychoactive properties of individual cannabis strains.

49
 CRITERION 5


Measure
3‐IV
Response

cont’d


Compassionate Care will select specific cannabis strains based on their unique ratios of CBD,
THC, and CBN. These strains will be cultivated by Compassionate Care and dispensed to
qualified patients as flowers, lozenges, and topicals. Each of these products will be clearly
labeled with the relative amounts of the three major cannabinoids. Educational material will
be provided to patients, caregivers, and doctors so that they may make an informed decision
when choosing medicines most appropriate for their conditions.

Major cannabinoids and their associated medicinal properties

Major Cannabinoid Properties Chemical Structure
The main psychoactive compound.
Δ9-Tetrahydrocannabinol Has mild to moderate analgesic
(THC) effects, can stimulate appetite and
reduce nausea.
A non-psychoactive compound
proven effective in treating
inflammation, pain, anxiety,
Cannabidiol (CBD) depression, and spasms without
euphoria or lethargy often associated
with cannabis. Has an antagonistic
effect on psychoactivity of THC.
A product of THC degradation
during storage and with exposure to
Cannabinol (CBN) light and air. Is an indicator of the
age of the cannabis. Has little, if any,
psychoactive effect.

Compassionate Care is dedicated to providing a diversity of medicinal strains. We recognize

that different cannabis strains can have different therapeutic properties. Indica and Sativa are
the two main varieties of the cannabis plant used as medicine. There are many strains that are
crosses of those two varieties. Within each of those varieties and crosses there are a large
number of individual strains, each with a potentially different cannabinoid profile and effect.
Research has shown Indica strains to be a relaxant, and effective for anxiety, pain, nausea,
appetite stimulation, sleep, muscle spasms, and other symptoms. The Sativa strains produce
an uplifting and energetic response more effective for disorders of low mood.

50
 CRITERION 5


Measure
3‐IV
Response

cont’d


Our treatment will focus on nine conditions:

• Seizure disorders (including epilepsy)
• Intractable muscular spasticity
• Glaucoma
• Severe pain
• Nausea and vomiting
• Cachexia (wasting syndrome)
• Amyotrophic lateral schlerosis (MS)
• Multiple schlerosis (ALS)
• Intestinal bowel disease (IBD), including Crohn's disease

Products will primarily be dispensed as dried flowers, but we will also offer cannabis
lozenges or topical formations produced with standards that meet good manufacturing
practices.

RECORD
KEEPING
FOR
EACH
PACKAGE
BY
LOT,
LABEL
AND
BAR
CODE


Our goal at Compassionate Care’s cultivation facility is to design and develop a

manufacturing process that produces, controls, audits, traces, and secures each plant
individually. We call this “one-plant flow.” A single plant is estimated to yield 1.5 to 2.0
ounces of finished cured cannabis.

Each plant at Compassionate Care will be uniquely identified with a sequential serial number
that is also associated with a lot number. Based upon the strain and plant, eight to twelve
uniquely serialized plants will be associated with a single lot number. In this scenario a single
lot should be able to produce at least 1 pound, or 16 ounces, of medical cannabis (8 plants x
2.0 ounces OR 12 plants x 1.5 ounces ~ 16 ounces). Each plant is bar-coded with a 9-digit
(alpha-numeric) license plate that travels with the plant all the way from seed to final sale to
patient.

All of a plant’s information is entered into a software system that tracks each plant using
these serial numbers. When a new serial number is created our software treats it as a new
product in our cultivation facility. Our software can give us a snapshot of not only how
many plants are presently being cultivated, but of historic cultivation records and future
production expectations as well.













51
 CRITERION 5


Measure
3‐IV
Response

cont’d


AREA
SECURITY



The cultivation facility is a fully secured building, equipped with perimeter fencing, on-site
employee parking, sufficient area lighting, secure building materials, surveillance, electronic
keycard access, on-site security personnel, and alarms. Employees are fully trained on
security procedures, and Compassionate Care will conduct periodic safety and training drills.
Our Security Plan provides details on operational and facility security procedures.

Appendix H: Security Plan

PACKAGING
AND
LABELING
REQUIREMENTS


There are 3 main steps involved in the cultivation packaging process: weighing, packaging,
and labeling.

Weighing

The only product by Compassionate Care that is weighed is medical cannabis, which is
weighed in increments of 1 gram by using a digital scale that is routinely tested for accuracy.

Compassionate Care uses the following weighing standards:

52
 CRITERION 5


Measure
3‐IV
Response

cont’d


• There are ~28.349 grams in an ounce.

• There are ~14.1745 grams in a half-ounce.
• There are ~3.54375 grams in an eighth-of-an-ounce.
• There are ~1.7719 grams in a sixteenth-of-an-ounce.

Packaging

All of our packaging materials will resemble medical grade packaging such as vials so
patients understand this is a medicine. Compassionate Care wants to provide patients with
various financial and medical needs access to their medicine, so we plan on offering
medicine in as small as sixteenth-of-an-ounce increments. We will evaluate this number after
we are operational. If patients advance concerns about the small increments and prefer being
able to buy different quantities, Compassionate Care will adjust its strategy accordingly. We
realize patients may not know their medical requirements initially, so our strategy is to start
small and adjust accordingly. Only packaging larger amounts will arbitrarily require them to
purchase more cannabis than they need. We will never sell in quantities larger than quarter-
ounce. Our clinical trials and consultations with patients are designed to evaluate a patient’s
true medical needs, so we can recommend not only the appropriate dosage, but the method of
absorption as well.

Our packaging system is designed to:

• Protect the product and prevent tampering;
• Ensure standards for hygiene;
• Provide legal disclosures to discourage diversion;
• Promote the Compassionate Care brand; and finally
• To be environmentally friendly.

Labeling

After a product is packaged, the final step before distribution to our patient care center is
labeling. Labeling will be applied to every product after it is packaged. The label of a
package will identify:
• The amount of product and form;
• The genetic lineage of the product (including medicinal variety);
• Weight (for medical cannabis);
• Date the product was packaged and expiration date (if applicable);
• Laboratory testing results;
• Legal disclosures;
• Medical disclosures (if applicable);
• THC levels and cannabinoid profiles; and
• Compassionate Care’s logo and contact information.

53
 CRITERION 5


Measure
3‐IV
Response

cont’d


Finally, the serial number of the plant will be placed on the package, for traceability, along
with Compassionate Care’s product seal. After the product is sent to the patient care center,
additional information such as patient and State identification number will be added as
required.

METHODS
OF
PROCESSING
IN
A
SAFE
AND
SANITARY
MANNER


Packaging areas must be easy to clean and maintain. This is facilitated by

• Appropriate, durable finishes for each functional space;
• Careful detailing of such features as room entrances, casework, and finish
transitions to avoid dirt-catching and hard-to-clean crevices and joints;
• Special materials, finishes, and details for spaces that are to be kept sterile.
• Incorporation of antimicrobial surfaces.

There is a mandatory requirement for any individual entering packaging areas to wear:

54
 CRITERION 5


Measure
3‐IV
Response

cont’d


• Company clean suits;

• Hairnets and beard nets (if necessary);
• New disposable gloves;
• Company clean-shoes or non-slip shoe coverings; and, in certain circumstances,
• Facemasks may be required.

All packaging areas will be maintained using good manufacturing practices and will be tested
and graded by our laboratory for compliance. Surfaces in the packaging areas (e.g.,
countertops, stove tops, sinks) will be swabbed and analyzed by the on-site lab to ensure
facility cleanliness. Samples of packaged products will be taken at random and analyzed to
ensure packaged products remain clear of mold, yeast, and bacteria.

55
 APPENDIX TOC

Appendices

APPENDIX A –CORPORATE DOCUMENTS .............................................................................................. A1

APPENDIX B – EVIDENCE OF SITE CONTROL....................................................................................... A19
APPENDIX C – EVIDENCE OF ZONING COMPLIANCE ........................................................................... A21
APPENDIX D – DISTANCE TO SENSITIVE S ITES.................................................................................... A23
APPENDIX E – ZIP CODE MAP OF SERVICE AREAS.............................................................................. A25
APPENDIX F – QUALIFICATIONS AND POSITION DESCRIPTIONS........................................................... A27
APPENDIX G – OPERATIONS PLAN ..................................................................................................... A50
APPENDIX H – SECURITY PLAN .......................................................................................................... A92
APPENDIX I – EMPLOYEE TRAINING MANUAL.................................................................................. A114
APPENDIX J – HIPAA MANUAL ....................................................................................................... A116
APPENDIX K – HR MANUAL ............................................................................................................ A121
APPENDIX L – CULTIVATION OVERVIEW.......................................................................................... A135
APPENDIX M – HYDROPONIC DESIGN .............................................................................................. A137
APPENDIX N – PRODUCT SAFETY PLAN ............................................................................................ A139
APPENDIX O – FIRE SAFETY PLAN ................................................................................................... A142
APPENDIX P – ENVIRONMENTAL PLAN ............................................................................................ A144
APPENDIX Q – FINANCIAL PRO-FORMA ........................................................................................... A146
APPENDIX R – LETTERS OF RECOMMENDATION ............................................................................... A174
 APPENDIX A

Appendix

A
Corporate Documents

A1
 APPENDIX A
BYLAWS

OF

COMPASSIONATE CARE FOUNDATION, INC.

(a New Jersey nonprofit corporation)

ARTICLE I.

_______________________

PURPOSE AND NONPROFIT STATUS

Section 1.01 PURPOSE. Compassionate Care Foundation, Inc. (the

“Corporation”) is organized to operate an Alternative Treatment Center under the New Jersey
Compassionate Use Medical Marijuana Act so that medical research can be conducted on the
comparative effectiveness of medical marijuana on certain medical conditions.

Section 1.02 NONPROFIT STATUS. The Corporation is incorporated

under the New Jersey Nonprofit Corporation Act. The Corporation does not contemplate
pecuniary gain or profit, incidental or otherwise, to its trustees, its officers or other private
persons, and no part of the net earnings of the Corporation shall inure to the benefit of, or be
distributed to, any such person, except that the Corporation shall be authorized and empowered
to pay reasonable compensation for services rendered and make payments and distributions in
furtherance of the purposes set forth in Section 1.01 above.

ARTICLE II.

_______________________

OFFICES AND FISCAL YEAR

Section 2.01 REGISTERED AGENT AND OFFICE. The initial

registered office of the Corporation shall be located at 830 Bear Tavern Road, West Trenton,
New Jersey 08628. The initial registered agent at such address shall be Corporation Service
Company.

Section 2.02 OTHER OFFICES. The Corporation may also have offices
at such other places, within or without New Jersey, as the board of trustees may from time to
time appoint or the business of the Corporation may require.

Section 2.03 FISCAL YEAR. The fiscal year of the Corporation shall
end on the last day of December.

A2
 APPENDIX A

ARTICLE III.

_______________________

NOTICE - WAIVERS - MEETINGS GENERALLY

Section 3.01 MANNER OF GIVING NOTICE.

(a) General Rule. Whenever notice is required to be given to any person

under the provisions of New Jersey law, the Corporation’s Certificate of Incorporation (the
“Certificate”) or these Bylaws, it may be given to such person, either personally or by sending a
copy thereof by first class mail, postage prepaid, by telephone, by facsimile with transmittal
confirmation, by electronic mail with transmittal confirmation or by telegram, charges prepaid,
to his or her address (including his or her electronic mail address) or telephone or facsimile
number appearing on the books of the Corporation or, in the case of trustees, supplied by him or
her to the Corporation for the purpose of notice. If the notice is sent by mail or by telegraph, it
shall be deemed to have been given to the person entitled thereto when deposited in the United
States mail or with a telegraph office for transmission to such person. A notice of meeting shall
specify the place, day and time of the meeting and any other information required by any other
provision of New Jersey law, the Certificate or these Bylaws.

(b) Adjourned Meetings. When a meeting is adjourned, it shall not be

necessary to give any notice of the adjourned meeting or of the business to be transacted at an
adjourned meeting, other than by announcement at the meeting at which such adjournment is
taken.

Section 3.02 NOTICE OF MEETINGS OF BOARD OF TRUSTEES.

(a) Notice.

(i) Notice of a regular meeting of the board of trustees need not be

given, except by the adoption of a resolution by the board of trustees establishing the places,
dates, and times of regular meetings.

(ii) Notice of a special meeting of the board of trustees shall be given

to each director by telephone or in writing at least twenty-four (24) hours before the time at
which the meeting is to be held.

(b) Content. Every required notice of a meeting shall state the place, date and
time of the meeting. Unless otherwise provided by New Jersey law, neither the business to be
transacted at, nor the purpose of, any special meeting of the board need be specified in a notice
of such meeting.

A3
 APPENDIX A
Section 3.03 WAIVER OF NOTICE.

(a) Written Waiver. Whenever any written notice is required to be given

under the provisions of New Jersey law, the Certificate or these Bylaws, a waiver thereof in
writing, signed by the person or persons entitled to such notice, whether before or after the time
stated therein, shall be deemed equivalent to the giving of such notice. Neither the business to be
transacted at, nor the purpose of, a meeting need be specified in the waiver of notice of such
meeting.

(b) Waiver by Attendance. Attendance of a person at any meeting shall

constitute a waiver of notice of such meeting, except where a person attends a meeting for the
express purpose of objecting, at the beginning of the meeting, to the transaction of any business
because the meeting was not lawfully called or convened.

Section 3.04 MODIFICATION OF PROPOSAL CONTAINED IN

NOTICE. Whenever the language of a proposed resolution is included in a written notice of a
meeting, the meeting considering the resolution may, without further notice, adopt it with such
clarifying or other amendments as do not enlarge its original purpose.

Section 3.05 EXCEPTION TO REQUIREMENT OF NOTICE.

Whenever any notice or communication is required to be given to any person under the
provisions of New Jersey law, the Certificate or these Bylaws, or by the terms of any agreement
or other instrument or as a condition precedent to taking any corporate action, and
communication with such person is then unlawful, the giving of such notice or communication
to such person shall not be required.

Section 3.06 USE OF CONFERENCE TELEPHONE AND SIMILAR

EQUIPMENT. One or more persons may participate in a meeting of the board of trustees, or
any committee thereof, by means of conference telephone or similar communications equipment
by means of which all persons participating in the meeting can hear each other. Participation in
a meeting pursuant to this section shall constitute presence in person at such meeting.

ARTICLE IV.

_______________________

MEMBERSHIP

Section 4.01 MEMBERSHIP. The Corporation shall have no members.

The affairs of the Corporation shall be managed by its board of trustees. Any provision of New
Jersey law requiring notice to, the presence of, or the vote, consent or other action by, members
of a corporation in connection with any matter shall be satisfied by notice to, the presence of, or
the vote, consent or other action by, the board of trustees of the Corporation.

A4
 APPENDIX A
ARTICLE V.

_______________________

BOARD OF TRUSTEES

Section 5.01 POWERS; STANDARD OF CARE.

(a) General Rule. Unless otherwise provided by New Jersey law, all powers
vested by law in the Corporation shall be exercised by or under the authority of, and the business
and affairs of the Corporation shall be managed under the direction of the board of trustees.

(b) Standard of Care; Justifiable Reliance. A trustee shall stand in a fiduciary

relation to the Corporation and shall perform his or her duties as a trustee, including duties as a
member of any committee of the board upon which the trustee may serve, in good faith, in a
manner the trustee reasonably believes to be in the best interests of the Corporation and with
such care, including reasonable inquiry, skill and diligence, as a person of ordinary prudence
would use under similar circumstances. In performing his or her duties, a trustee shall be entitled
to rely in good faith on information, opinions, reports or statements, including financial
statements and other financial data, in each case prepared or presented by any of the following:

(i) One or more officers or employees of the Corporation whom the

trustee reasonably believes to be reliable and competent in the matters presented.

(ii) Counsel, public accountants or other persons as to matters which

the trustee reasonably believes to be within the professional or expert competence of such
person.

(iii) A committee of the board of trustees upon which the trustee does
not serve, duly designated in accordance with law, as to matters within its designated authority,
which committee the Trustee reasonably believes to merit confidence.

A trustee shall not be considered to be acting in good faith if the trustee has knowledge
concerning the matter in question that would cause his or her reliance to be unwarranted.

(c) Consideration of Factors. In discharging the duties of their respective

positions, the board of trustees, committees of the board of trustees and individual trustees may,
in considering the best interests of the Corporation, consider the effects of any action upon
communities in which offices or other establishments of the Corporation are located, and all
other pertinent factors. The consideration of those factors shall not constitute a violation of
subsection (b) above.

(d) Presumption. Absent breach of fiduciary duty, lack of good faith or self-
dealing, any action taken as a trustee or any failure to take any action shall be presumed to be in
the best interests of the Corporation.

A5
 APPENDIX A
(e) Notation of Dissent. A trustee who is present at a meeting of the board of
trustees, or of a committee of the board of trustees, at which action on any corporate matter is
taken, shall be presumed to have assented to the action taken unless his or her dissent is entered
in the minutes of the meeting or unless the trustee files a written dissent to the action with the
secretary of the meeting before the adjournment thereof or transmits the dissent in writing to the
secretary of the Corporation immediately after the adjournment of the meeting. The right to
dissent shall not apply to a trustee who voted in favor of the action. Nothing in this section shall
bar a trustee from asserting that minutes of the meeting incorrectly omitted his or her dissent if,
promptly upon receipt of a copy of such minutes, the trustee notifies the secretary in writing of
the asserted omission or inaccuracy.

Section 5.02 QUALIFICATION AND SELECTION OF TRUSTEES.

(a) Qualifications. Each trustee of the Corporation shall be a natural person

21 years of age or older.

(b) Election of Trustees. Except as otherwise provided in the Certificate or

these Bylaws, the trustees of the Corporation shall be elected every two years by majority vote of
the trustees present at a duly qualified meeting of the board of trustees of the Corporation where
a quorum is present. In elections for trustees, voting need not be by ballot, except upon demand
made by a person entitled to vote at the election and before the voting begins. The candidates
receiving the highest number of votes cast shall be elected.

(c) Initial Trustees. The initial trustees of the Corporation shall be those
persons named as trustees by the Incorporator.

Section 5.03 NUMBER AND TERM OF OFFICE.

(a) Number. The board of trustees shall consist of not less than three (3) nor
more than ten (10) trustees.

(b) Term of Office. Except as otherwise provided in Section 5.04 hereof, the
term of office shall be two years and the term of office shall begin at the annual meeting of the
board of trustees. Each trustee shall hold office until the expiration of the term for which he or
she was selected or until a successor shall be selected and shall qualify or until his or her earlier
death, resignation or removal. A decrease in the number of trustees shall not have the effect of
shortening the term of any incumbent trustee. There shall be no limitation on the terms of office
for members of the board of trustees.

(c) Resignation. Any trustee may resign at any time upon written notice to
the Corporation. The resignation shall be effective upon receipt thereof by the Corporation or at
such subsequent time as shall be specified in the notice of resignation.

Section 5.04 VACANCIES. If a vacancy occurs in the office of a trustee

for any reason, including an increase in the number of trustees, the board of trustees of the
Corporation shall select a successor by majority vote of the trustees present at a duly called

A6
 APPENDIX A
meeting of the board of trustees where a quorum is present, and such trustee shall hold office for
the unexpired term for which the vacancy occurred, if applicable.

Section 5.05 REMOVAL OF TRUSTEES. A trustee may be removed

from office, with or without cause, at any time by vote of two-thirds (2/3) or more of the trustees
then in office.

Section 5.06 PLACE OF MEETINGS. Meetings of the board of trustees

may be held at such place, within or without New Jersey, as the board of trustees may from time
to time designate, or as may be designated in the notice of the meeting.

Section 5.07 ORGANIZATION OF MEETINGS. At every meeting of

the board of trustees, the chairman of the board, if there be one, or in the case of a vacancy in the
office or absence of the chairman of the board, one of the following officers present, in the order
stated, shall act as chairman of the meeting: the vice chairman of the board, if there be one; the
president; the treasurer; or a person chosen by a majority of the trustees present. The secretary,
or, in the absence of the secretary, any person appointed by the chairman of the meeting, shall act
as secretary of the meeting.

Section 5.08 REGULAR MEETINGS. Regular meetings of the board of

trustees shall be held at such places, dates and times as shall be designated from time to time by
resolution of the board of trustees.

Section 5.09 SPECIAL MEETINGS. Special meetings of the board of

trustees shall be held whenever called by the chairman or two (2) or more trustees of the
Corporation.

Section 5.10 QUORUM OF AND ACTION BY TRUSTEES.

(a) General Rule. A majority of the trustees in office shall be necessary to

constitute a quorum for the transaction of business and, except as otherwise expressly provided
in these Bylaws, the acts of a majority of the trustees present at a meeting at which a quorum is
present shall be the acts of the board of trustees.

(b) Voting Rights. Each trustee shall be entitled to one vote.

(c) Action by Written Consent. Any action which may be taken at a meeting
of the trustees may be taken without a meeting if a consent or consents in writing setting forth
the action so taken shall be signed by all of the trustees then in office and shall be filed with the
secretary of the Corporation.

Section 5.11 EXECUTIVE AND OTHER COMMITTEES.

(a) Establishment and Powers. The board of trustees may, by resolution

adopted by a majority of the trustees then in office, establish one (1) or more committees to
consist of one (1) or more trustees of the Corporation and such other individuals as the board of
trustees may appoint.

A7
 APPENDIX A
(b) Any committee, to the extent provided in the resolution of the board of
trustees, shall have and may exercise all of the powers and authority of the board of trustees,
except that no such committee shall have any power or authority as to the following:

(i) The filling of vacancies in the board of trustees.

(ii) The adopting, amendment or repeal of these Bylaws.

(iii) The amendment or repeal of any resolution of the board.

(iv) Action on matters committed by a resolution of the board of

trustees to another committee of the board.

(c) Committee Quorum. Unless otherwise expressly provided in the

resolution of the board of trustees establishing any committee, a majority of the members of such
committee shall be necessary to constitute a quorum for the transaction of business, and the acts
of a majority of the committee members present at a meeting at which a quorum is present shall
be the acts of such committee.

(d) Alternate Committee Members. The board of trustees may designate one
or more individuals as alternate members of any committee who may replace any absent or
disqualified member at any meeting of the committee. In the absence or disqualification of a
member of a committee, the member or members thereof present at any meeting and not
disqualified from voting, whether or not constituting a quorum, may unanimously appoint
another individual to act at the meeting in the place of the absent or disqualified member.

(e) Term. Each committee of the board of trustees shall serve at the pleasure
of the board of trustees.

Section 5.12 COMPENSATION. The board of trustees and committee

members shall receive no compensation for their services as trustees and committee members.
Trustees and committee members may, however, receive reimbursement for approved expenses.

ARTICLE VI.

___________________________

OFFICERS

Section 6.01 OFFICERS GENERALLY.

(a) Number, Qualifications and Designation. The officers of the Corporation

shall be a president, a vice president, a secretary, a treasurer, and such other officers as may be
designated in accordance with the provisions of this Section 6.01 and Sections 6.02 and 6.03.
The president, vice president, secretary and treasurer shall each be natural persons of full age.
The board of trustees may elect, from among the members of the board, a chairman of the board
A8
 APPENDIX A
and a vice chairman of the board, each of whom may also be an officer of the Corporation. Any
number of offices may be held by the same person.

(b) Resignation. Any officer may resign at any time upon written notice to
the Corporation. The resignation shall be effective upon receipt thereof by the Corporation or at
such subsequent time as may be specified in the notice of resignation.

(c) Bonding. The Corporation may secure the fidelity of any or all of its
officers by bond or otherwise. Alternatively, the Corporation may obtain fiduciary insurance on
behalf of its officers.

(d) Standard of Care. An officer shall perform his or her duties as an officer
in good faith, in a manner he or she reasonably believes to be in the best interests of the
Corporation and with such care, including reasonable inquiry, skill and diligence, as a person of
ordinary prudence would use under similar circumstances.

(e) Compensation. The officers of the Corporation shall receive no

compensation for the services they provide as officers. Officers may, however, receive
reimbursement for approved expenses.

Section 6.02 ELECTION AND TERM OF OFFICE. The officers of the

Corporation, except those elected by delegated authority pursuant to Section 6.03, shall be
elected every two years by majority vote of the trustees present at a duly called meeting of the
board of trustees where a quorum is present, and each officer shall hold office for a term of two
(2) years and until a successor shall be selected and shall qualify, or until his or her earlier death,
resignation or removal. There shall be no limitations on the number of terms of office for the
officers of the Corporation.

Section 6.03 SUBORDINATE OFFICERS, COMMITTEES AND

AGENTS. The board of trustees may from time to time elect such other officers and appoint
such committees or other agents as the business of the Corporation may require, including one
or more assistant secretaries and one or more assistant treasurers, each of whom shall hold
office for such period, have such authority, and perform such duties as are provided in these
Bylaws or as the board of trustees may from time to time determine. The board of trustees may
delegate to any officer or committee the power to elect subordinate officers and to retain or
appoint other agents or committees thereof, and to prescribe the authority and duties of such
subordinate officers, committees, or other agents.

Section 6.04 NO CONTRACT RIGHTS. Election or appointment of an

officer or agent shall not of itself create any contract rights in the officer or agent.

Section 6.05 REMOVAL OF OFFICERS AND AGENTS. Any officer

or agent of the Corporation may be removed at any time by a majority vote of the trustees
present at a duly called meeting of the board of trustees where a quorum is present, with or
without cause, but such removal shall be without prejudice to the contract rights, if any, of any
person so removed.

A9
 APPENDIX A
Section 6.06 VACANCIES. A vacancy in any office because of death,
resignation, removal, disqualification, or any other cause, shall be filled by majority vote of the
directors present at a duly called meeting of the board of trustees or by the officer or committee to
which the power to fill such office has been delegated pursuant to Section 6.03, as the case may
be, and if the office is one for which these Bylaws prescribe a term, shall be filled for the
unexpired portion of the term.

Section 6.07 AUTHORITY. All officers of the Corporation, as between

themselves and the Corporation, shall respectively have such authority and perform such duties in
the management of the property and affairs of the Corporation as are provided in these Bylaws or
may be provided by or pursuant to resolutions or orders of the board of trustees.

Section 6.08 CHAIRMAN AND VICE CHAIRMAN OF THE BOARD. The

Chairman shall preside at all meetings of the board of trustees. The Chairman shall appoint
all committees and their chairpersons in accordance with the Bylaws. The Chairman shall
have such other duties and responsibilities as shall be delegated to him or her by these
Bylaws and by the board of trustees from time to time. If no individual is currently serving
as Chairman, the Vice Chairman shall preside at all meetings of the board of trustees until a
Chairman has been elected. If there is a Chairman but he or she is unable to attend a board
of trustees meeting, the Vice Chairman shall preside at the meeting.

Section 6.09. THE PRESIDENT. The president shall be the chief

executive officer of the Corporation and shall have general supervision over the business and
operations of the Corporation, subject, however, to the control of the board of trustees. The
president shall sign, execute, and acknowledge, in the name of the Corporation, tax documents,
deeds, mortgages, contracts or other instruments authorized by the board of trustees, except in
cases where the signing and execution thereof shall be expressly delegated by the board of
trustees, or by these Bylaws, to some other officer or agent of the Corporation; and, in general,
shall perform all duties incident to the office of chief executive officer, and such other duties as
from time to time may be assigned by the board of trustees.

Section 6.10 THE VICE PRESIDENT. The vice president shall perform
all duties and have all authority given to the president of the Corporation, at any time when the
president is unable to act, and shall have the same authority to sign, execute and acknowledge, in
the name of the Corporation, tax documents, deeds, mortgages, contracts or other instruments as
is granted to the president by Section 6.09. The vice president shall have such other duties and
authority as from time to time may be assigned by the board of trustees.

Section 6.11 THE SECRETARY. The secretary shall attend all

meetings of the board of trustees (or committees of the board) and shall record all votes of the
trustees (or committees persons) and the minutes of the meetings of the board of trustees (or
committees) in a book or books to be kept for that purpose; shall see that notices are given and
records and reports properly kept and filed by the Corporation as required by law; shall be the
custodian of the seal of the Corporation and see that it is affixed to all documents which are to be
executed on behalf of the Corporation under its seal; and, in general, shall perform all duties
A10
 APPENDIX A
incident to the office of secretary, and such other duties as may from time to time be assigned by
the board of trustees or the president. In addition, the secretary shall annually present a report to
the board of trustees not later than March 31 of each year summarizing all resolutions of the
board of trustees during the preceding fiscal year and certifying the accuracy of the records of the
Corporation for such year.

Section 6.12. THE TREASURER. The treasurer or an assistant treasurer

shall have or provide for the custody of the funds or other property of the Corporation; shall
collect and receive or provide for the collection and receipt of moneys earned by or in any
manner due to or received by the Corporation; shall deposit all funds in his or her custody as
treasurer in such banks or other places of deposit as the board of trustees may from time to time
designate; shall, whenever so required by the board of trustees, render an account showing all
transactions as treasurer and the financial condition of the Corporation; and, in general, shall
discharge such other duties as may from time to time be assigned by the board of trustees or the
president.

ARTICLE VII.

__________________________

LIMITATION OF TRUSTEES’ AND OFFICERS’

LIABILITIES AND INDEMNIFICATION

Section 7.01 LIMITATION OF LIABILITY. To the fullest extent

permitted by New Jersey law, a trustee or officer of the Corporation shall not be personally liable
to the Corporation, or others for monetary damages for any action taken or any failure to take
any action, unless the trustee or officer has breached or failed to perform the duties of his office
and such breach or failure constitutes self-dealing, willful misconduct or recklessness. The
provisions of this Section 7.01 shall not apply with respect to the responsibility or liability of a
trustee or officer under any criminal statute or the liability of a trustee or officer for the payment
of taxes pursuant to local, state or federal law.

Section 7.02 INDEMNIFICATION.

(a) Indemnification. The Corporation shall indemnify any person who was or
is a party or is threatened to be made a party to any threatened, pending or completed action, suit
or proceeding, whether civil, criminal, administrative or investigative, by reason of the fact that
such person is or was a trustee, officer, employee or agent of the Corporation, or is or was
serving, at the request of the Corporation, as trustee, officer, employee or agent of another
corporation, partnership, joint venture, trust or other enterprise, against expenses (including
attorneys’ fees), amounts paid in settlement, judgments, and fines actually and reasonably
incurred by such person in connection with such action, suit or proceeding, provided, however
that no indemnification shall be made in any case where the act or failure to act giving rise to the
claim for indemnification is determined by a court to have constituted willful misconduct or
recklessness.

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(b) Advance of Expenses. Expenses (including attorneys’ fees) incurred in
defending a civil or criminal action, suit, or proceeding shall be paid by the Corporation in
advance of the final disposition of such action, suit, or proceeding, upon receipt of an
undertaking by or on behalf of the trustee, officer, employee, or agent to repay such amount if it
shall be ultimately determined that he or she is not entitled to be indemnified by the Corporation
as authorized in this Article VII.

(c) Indemnification Not Exclusive. The indemnification and advancement of

expenses provided by this Article VII shall not be deemed exclusive of any other right to which
persons seeking indemnification and advancement of expenses may be entitled under any
agreement, vote of the board of trustees, or otherwise, both as to actions in such persons’ official
capacity and as to their actions in another capacity while holding office, and shall continue as to
a person who has ceased to be a trustee, officer, employee, or agent and shall inure to the benefit
of the heirs, executors, and administrators of any such person.

(d) Insurance, Contracts, Security. The Corporation may purchase and

maintain insurance on behalf of any person, may enter into contracts of indemnification with any
person, and may create a fund of any nature which may, but need not be, under the control of a
trustee for the benefit of any person, and may otherwise secure, in any manner, its obligations
with respect to indemnification and advancement of expenses, whether arising under this Article
VII or otherwise, whether or not the Corporation would have the power to indemnify such person
against such liability under the provisions of this Article VII.

Section 7.03 EFFECT OF AMENDMENT. Any repeal or modification

of this Article VII shall require a vote of two-thirds (2/3) or more of the trustees then in office.
Any such repeal or modification shall be prospective only, and shall not adversely affect any
limitation on the personal liability of a trustee or officer of the Corporation or any right of any
person to indemnification from the Corporation with respect to any action or failure to take any
action occurring prior to the time of such repeal or modification.

ARTICLE VIII.

__________________________

MISCELLANEOUS

Section 8.01 SEAL. The corporate seal shall have inscribed thereon the
name of the Corporation, the year of its organization, and the words “Corporate Seal, New
Jersey.”

Section 8.02 CHECKS. All checks, notes, bills of exchange or other

orders in writing shall be signed by such person or persons as the board of trustees, or any person
authorized by resolution of the board of trustees, may from time to time designate.

Section 8.03 CONTRACTS.

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(a) General Rule. Except as otherwise provided by New Jersey law, the board
of trustees may authorize any officer or agent to enter into any contract or to execute or deliver
any instrument on behalf of the Corporation, and such authority may be general or confined to
specific instances.

(b) Statutory Form of Execution of Instruments. Any note, mortgage,

evidence of indebtedness, contract or other instrument in writing, or any assignment or
endorsement thereof, executed or entered into between the Corporation and any other person,
when signed by one or more officers or agents having actual or apparent authority to sign it, or
by the chairman or vice chairman and secretary or treasurer of the Corporation, shall be held to
have been properly executed for and in behalf of the Corporation. Such fact shall be without
prejudice to the rights of the Corporation against any person who shall have executed the
instrument in excess of his actual authority.

(c) Seal. Except as otherwise required by New Jersey law, the affixation of
the corporate seal shall not be necessary to the valid execution, assignment or endorsement by
the Corporation of any instrument in writing.

Section 8.04 INTERESTED TRUSTEES OR OFFICERS; QUORUM.

(a) General Rule. A contract or transaction between the Corporation and one
or more of its trustees or officers or between the Corporation and another corporation,
partnership, association, or other organization in which one or more of its trustees or officers are
trustees, directors, or officers, or have a financial interest, shall not be void or voidable solely for
that reason, or solely because the trustee or officer is present at or participates in the meeting of
the board of trustees which authorizes the contract or transaction if the contract or transaction is
fair as to the Corporation as of the time it is authorized, approved or ratified by the board of
trustees of the Corporation, and:

(i) The material facts as to the relationship or interest and as to the

contract or transaction are disclosed or are known to the board of trustees, and the board in good
faith authorizes the contract or transaction by the affirmative votes of a majority of the
disinterested trustees even though the disinterested trustees are less than a quorum; or

(ii) The material facts as to the relationship or interest and as to the

contract or transaction are disclosed or are known to the trustees, and the contract or transaction
is specifically approved in good faith by vote of the trustees.

(b) Quorum. Interested trustees may be counted in determining the presence

of a quorum at a meeting of the board which authorizes a contract or transaction specified in
subsection (a) above.

Section 8.05 DEPOSITS. All funds of the Corporation shall be

deposited from time to time to the credit of the Corporation in such banks, trust companies or
other depositories as the board of trustees may approve or designate, and all such funds shall be
withdrawn only upon checks signed by such one or more officers or employees as the board of
trustees shall from time to time determine.
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Section 8.06 CORPORATE RECORDS. The Corporation shall keep
appropriate, complete and accurate books or records of account in accordance with generally
accepted accounting principles consistently applied (except that the financial records of the
Corporation may be kept on the cash receipts and disbursements method if permitted by law and
deemed appropriate by the board), minutes of the proceedings of the trustees, and a copy of these
Bylaws, including all amendments thereto to date, certified by the secretary of the Corporation.
All such records shall be kept at the registered office of the Corporation in New Jersey or at its
principal place of business. Any books, minutes or other records may be in written form or any
other form capable of being converted into written form within a reasonable time.

Section 8.07 ANNUAL REPORT.

(a) Contents. The board of trustees shall prepare annually a report, verified
by the president and treasurer or by a majority of the trustees, showing in appropriate detail the
following:

(i) The assets and liabilities, including the trust funds, of the
Corporation as of the end of the fiscal year immediately preceding the date of the report.

(ii) The principal changes in assets and liabilities, including trust

funds, during the year immediately preceding the date of the report.

(iii) The revenue or receipts of the Corporation, both unrestricted and

restricted to particular purposes, for the year immediately preceding the date of the report,
including separate data with respect to each trust fund held by or for the Corporation.

(iv) The expenses or disbursements of the Corporation, for both general

and restricted purposes, during the year immediately preceding the date of the report, including
separate data with respect to each trust fund held by or for the Corporation.

(b) Place of Filing. The annual report of the board of trustees shall be filed
with the minutes of the meetings of the board of trustees.

Section 8.08 AMENDMENT OF BYLAWS. Except for matters that are

reserved by applicable law only to be altered, amended or repealed by the board of trustees
pursuant to such law, these Bylaws may be amended or repealed by vote of two-thirds (2/3) or
more of the trustees then in office. Any change in these Bylaws shall take effect when adopted,
unless otherwise provided in the resolution effecting the change.

ARTICLE IX.

_______________________

DISSOLUTION AND LIQUIDATION

Section 9.01 DISSOLUTION AND LIQUIDATION. Upon the

dissolution of the Corporation, the Corporation’s board of trustees, after paying or making
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provisions for the payment of all of the liabilities and obligations of the Corporation, shall
distribute all assets of the Corporation to such organization or organizations as the Corporation’s
board of trustees shall determine. No portion of the assets shall inure to the benefit of any trustee
or officer of the Corporation, any other private person, or any enterprise organized for profit.

END OF BYLAWS

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Appendix

B
Evidence of Site Control

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Appendix

C
Evidence of Zoning Compliance

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Appendix

D
Distance to Sensitive Sites

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 APPENDIX E

Appendix

E
Zip Code Map of Service Areas

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 APPENDIX F

Appendix

F
Qualifications and Position Descriptions

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JOB DESCRIPTION RELATED INFORMATION: EXEMPT FROM OPRA PURSUANT TO N.J.S.A 47:1A-1.1
- LIMITED SAMPLING PROVIDED – HARD COPY AVAILABLE UPON R

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Appendix

G
Operations Plan

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 APPENDIX G

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 APPENDIX G

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 APPENDIX G

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 APPENDIX G

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 APPENDIX G

CFO COO

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3a-iii) If applicable, a projection of the number of qualified patients to be served
by the ATC;

It is difficult to determine the number of qualified patients to be served by our ATC due to
the relatively recent passage of New Jersey’s medical marijuana program and a lack of data
in this industry. Additionally, the regulations are subject to change prior to issuance of ATC
permits, creating uncertainty surrounding patient registration. If we are awarded a permit,
Compassionate Care will conduct a comprehensive market study to determine a reasonable
estimate of the number of patients we can anticipate will purchase medical cannabis from us.
This study will consider population, medical marijuana program requirements, income levels,
health statistics, target demographics, location, and proximity to prospective patient base. In
other states, the number of medical marijuana program participants has varied drastically.

For purposes of our projections, Compassionate Care anticipates having 5,000 patients when
operational. This takes into consideration that there will be active patient enrollment during
the construction of our ATC, so when we are operational there will be patients ready for our
grand opening. We are confident that once other ATCs are operational, our quality
medication, helpful service offerings, and affordable pricing will attract a higher proportion
of medical cannabis patients in our region than the other permitted ATC.

We have chosen a facility that has significant scalable capacity to prevent any disruption in
the event demand exceeds our estimated supply levels. In the event that we have produced
more cannabis than necessary, Compassionate Care will follow the correct procedures for
destroying and reporting excess cannabis, and reducing our supply accordingly.

3a-iv) Projections by the ATC for a two-year period of the ratio of registered
qualifying patients-to-demand for usable marijuana and procedures by which the
ATC shall periodically review these ratios for consistency with actual patient
demand ratios;

In formulating our projections we took into consideration the amount of time required
between permits being issued and our first harvest being cured and packaged for sale. We
assume during this timeframe there will be 5,000 patients registered and prepared to purchase
from our patient care center on our projected first day of sales, between August and
September 2011, as shown in our timetable in Criterion 5, Measure 3 and Financial Pro-
Forma. Thereafter, we anticipate every quarter having 1,250 more patients register with our
patient care center, allowing us to reach 10,000 patients by the last quarter of 2012. We
anticipate reaching a certain threshold where patient registration rates will decline, probably
after reaching 10,000 patients, but still allow for slow and steady growth to 11,250 two years
after our opening around September 2013.

Our cultivation facility is more than capable of handling such production. Although most of
our facility will be built out allowing for higher production levels, production will be phased
in beginning with 500 4” x 4” trays, each containing ten plants, estimated to produce two
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ounces per plant over eight weeks. Factoring in drying, curing, packaging and transport
times, the first production will be available for sale ten weeks after our first planting. Each
tray will harvest six times a year, allowing for twenty ounces of product a cycle, and one-
hundred twenty ounces of product a year.

The Financial Pro-Forma provides production tables and income statements to demonstrate
how our cultivated cannabis will be able to provide for anticipated demand levels over a two-
year period. The Chief Operations Officers and Director of our patient care facility will
routinely monitor supply levels to give our cultivation facility enough lead time to make
adjustments in our supply process. Due to the ten week lead time for products to be ready,
factoring in eight weeks for plant growth and two weeks for harvest and drying, our directors
and officers will work strategically to anticipate demand levels two and a half months in
advance to prevent shortages or surplus in medicine.

Appendix Q: Financial Pro-Forma

3a-v) Procedures by which the ATC shall ensure the availability of medicinal
marijuana in accordance with projected and actual demand ratios;

Compassionate Care’s sophisticated supply chain tracking system provides us with useful
information to forecast supply levels. At any given time we can take a snapshot of our
current inventory levels, our historical production levels, and our anticipated production
levels in the future. Reverse engineering the process, if we are running low on a particular
medicinal strain, our dispensary is able to contact our cultivation center and find out exactly
what stage of the plant production process plants of that particular strain are in. Based on the
stage and the time required before harvest, we can give an accurate forecast as to when
additional supply will be available to patients. This will prevent shortages from happening.

To ensure that patients have sufficient access to their medicine, we will routinely monitor our
supply levels and analyze demand levels. Some of the factors we will consider are:
 Medical marijuana program participation
 Growth rate of our patient base
 Number of registered doctors participating
 Previous sales
 Population analysis
As opposed to waiting for a shortage to arise, we will proactively monitor supply to ensure
adequate inventory levels are always sustained. This will also help prevent over-saturation of
the market, creating an excess supply of medicine that can go bad and presents added
security risks.

In order to make sure our production capabilities are sufficient for growth over time, we
chose a facility that is scalable so there would be no disruptions in supply. Due to limited
information available pertaining to the New Jersey patient registration process and this being

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a new program, there is no way to ascertain accurate information to formulate projections, as
discussed in the last section. However, our cultivation facility has the capability of servicing
up to 20,000 patients at two ounces per month, so we will be able to sustain increases in
patient registration levels for a long time.

Some of the information we have taken into account when estimating demand levels is
provided below:
 Land area = 8721 square miles
 Population = 8.078 million (2009)
 Population density = 1184 people/square mile
 Over 65 population = 1,137,731 (13.1%)
 Over 75 population = 402,000
 Over 85 population = 163,000
 70,000 deaths/year (NJ Hospice and Palliative Care organization claims
approximately 35,000 patients, or half those that died, received hospice care in
2008)
 19,566 ambulatory care facilities
 165 hospitals (1 per ~49k people)
 1787 nursing or residential homes
 27,383 doctors (1 per 316 people)
 50 hospice and palliative organizations
 1712 pharmacies (source: manta.com; equivalent to 1 per 4708 people)

3a-vi) The name, medical license number, résumé and contact address of the
medical director of the ATC, if applicable;

We have not yet chosen a medical director. Compassionate Care has discussed the
opportunity with a few well-qualified prospective medical directors, and if we are successful
in obtaining an ATC we intend to decide shortly thereafter.

3a-vii) The name, résumé and address of the chief administrative officer of the
ATC; and

Name: William J. Thomas

Address: 15 Roszel Road, Suite 107
Princeton, NJ 08540
Phone: 267.614.3341

Appendix F: Qualifications and Descriptions

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3a-viii) The standards and procedures by which the ATC determines the price it
charges for usable marijuana and a record of the prices charged.

Compassionate Care seeks to offer patients the most affordable medicine possible, while not
economizing on standards for product testing, research and development, adequate security
and safety procedures, or other quality concerns.

The price of our medicine will be equal to our cost. As our organization becomes more
efficient over time and expands its patient base, we intend to reduce our prices and invest
more into areas that promote the long-term well-being of our patients and the surrounding
communities.

Our primary focus areas will be:

 Reducing the cost of our medicine and expanding our indigent care program
 Investing in our research and development program
 Developing and expanding our charitable and philanthropic programs

Our secondary focus areas will be:

 Providing additional worker education and training

 Offering more free healthcare services to patients
 Increasing product safety, hygiene, and quality assurance standards

Compassionate Care intends to find an equilibrium that balances affordable medicine and
enrichment services so our patients, workers, and community members are better served now
and in the future.

All sales will be recorded into the point of sale system used at our dispensary. These sales
will be compared to inventory levels and production levels.

Appendix Q: Financial Pro-Forma

3b: ATCs shall maintain business records including, manual or computerized

records of assets and liabilities, monetary transactions, various journals, ledgers
and supporting documents, including agreements, checks, invoices and vouchers
that the ATC keeps as its books of accounts.

All documents and business records relating to assets and liabilities, monetary transactions,
various journals, ledgers, and supporting documents, including agreements, checks, invoices,
and vouchers will be retained. Compassionate Care shall keep these files in a secured area
placed in a locked filing cabinet. Financial records will be treated with the similar levels of
confidentiality as medical records and other sensitive information and maintained by our
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CFO. Compassionate Care shall make these records available as required.

Appendix K: HR Manual

3c: Business records include sales records that indicate the name of the
qualifying patient or primary caregiver to whom marijuana is distributed, the
quantity, strength and form and the cost of the product.

All documents and records relating to sales records that indicate the name of the qualifying
patient or primary caregiver to whom marijuana is distributed, the quantity, strength and
form, and the cost of the product will be retained by our point of sale system. Each patient’s
purchases will be tracked to ensure they are not purchasing more than allowed by law. Much
of this information will be contained within our package labeling. All of these records will be
backed up electronically and maintained in a secure database. Compassionate Care shall
make these records available as required by law.

Appendix K: HR Manual

3d: The bylaws of the ATC and its affiliates or sub-contractors shall contain
provisions relative to the disposition of revenues and receipts as may be
necessary and appropriate to establish and maintain its nonprofit status, as
applicable.

The following certification is provided in our bylaws:

NONPROFIT STATUS. The Corporation is incorporated under the New Jersey Nonprofit
Corporation Act. The Corporation does not contemplate pecuniary gain or profit, incidental
or otherwise, to its trustees, its officers or other private persons, and no part of the net
earnings of the Corporation shall inure to the benefit of, or be distributed to, any such person,
except that the Corporation shall be authorized and empowered to pay reasonable
compensation for services rendered and make payments and distributions in furtherance of
the purposes set forth in Section 1.01 above.

Section added: No portion of the assets shall inure to the benefit of any trustee or officer of
the Corporation, any other private person, or any enterprise organized for profit.

Exhibit A: Corporate Documents

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Chapter 4: Personnel records

Compassionate Care will maintain a personnel record for each employee, principal officer,
director, board member, agent or volunteer that includes, at a minimum, the following:
 An application for employment or to volunteer;
 A copy of his or her current ATC identification card and a copy of his or her
driver’s license or other State-issued photo identification card;
 Documentation of the certification of each principal officer, director, and board
member stating that he or she submits to the jurisdiction of the courts of the State
of New Jersey and agrees to comply with all the requirements of the laws of the
State of New Jersey pertaining to the Medicinal Marijuana Program;
 Documentation of background checks;
 Procedures by which the ATC shall ensure the availability of medicinal marijuana
in accordance with projected and actual demand;
 The job description or employment contract that include duties, authority,
responsibilities, qualifications, and supervision;
 Documentation of all required training, including training regarding privacy and
confidentiality requirements, and the signed statement of the individual indicating
the date, time, and place he or she received said training and the topics discussed,
including the name and title of presenters;
 Documentation of periodic performance evaluations;
 A record of any disciplinary action taken; and
 Documentation of the results of drug tests authorized pursuant to this policy.

Some of these policies are contained within our Qualifications and Position Descriptions,
Employee Training Manual, and Human Resources Manual.

Exhibit F: Qualifications and Position Descriptions

Exhibit I: Employee Training Manual
Exhibit K: HR Manual

Compassionate Care shall maintain personnel records for at least 12 months after termination
of the individual’s affiliation with the alternative treatment center, for the purposes of this
rule.

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Chapter 5: Employee training

5-a) Each alternative treatment center shall either:

I. DEVELOP, IMPLEMENT AND MAINTAIN ON THE PREMISES AN ONSITE TRAINING CURRICULUM;
II. ENTER INTO CONTRACTUAL RELATIONSHIPS WITH OUTSIDE RESOURCES CAPABLE OF MEETING
EMPLOYEE, AGENT AND VOLUNTEER TRAINING NEEDS;

Compassionate Care will offer on-site training as well as contract with outside resources for
very specialized training areas. We have engaged the University of Cannabis, a California-
based company, to provide medical cannabis education. The majority of training, however, is
provided on site by Compassionate Care.

5-b) Each employee, agent or volunteer, at the time of his or her initial
appointment, shall receive, as a minimum, training in the following:
I. PROFESSIONAL CONDUCT, ETHICS AND STATE AND FEDERAL LAWS REGARDING PATIENT
CONFIDENTIALITY;
II. INFORMATIONAL DEVELOPMENTS IN THE FIELD OF MEDICAL USE OF MARIJUANA;
III. THE PROPER USE OF SECURITY MEASURES AND CONTROLS THAT HAVE BEEN ADOPTED; AND
IV. SPECIFIC PROCEDURAL INSTRUCTIONS FOR RESPONDING TO AN EMERGENCY, INCLUDING A ROBBERY
OR WORKPLACE VIOLENCE.

Employee training manuals and workshops will augment our training efforts, and
Compassionate Care will incentivize our workforce to further their learning to excel both
intellectually and professionally by paying for training and further education. We believe
well-trained workers lead to the overall success of a company, so we will conduct frequent
workshops, seminars, retreats, meetings, and events designed to encourage learning and
provide learning aids that reinforce our training efforts. Training topics include:

 Legal Training - Legal training will cover all New Jersey State and Federal laws
relating to cannabis. Employees will be trained to understand patient rights, health
information privacy laws to protect the privacy of patients (HIPAA), sexual
harassment, laws surrounding operations of an ATC, and effective interaction with
law enforcement.

 Medical Training - Since many of our patients have serious medical conditions,
special training will be given to responding to medical emergencies. Each
employee will be trained on disability sensitivity, blood borne pathogens, ADA
compliance, and effective communication with medical patients. Compassionate
Care has selected a strong Medical Board to oversee and improve its medical
training protocols. Our employees will be well versed in the various medicinal
cannabis strains available and the different medical healing properties of each.
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 Customer Service and Sales Training - Staff will be well trained in patient care,
customer service and sales. Each employee will be well versed in health science,
best forms of ingestion, medical cannabis varieties, cannabanoid profiles, and
understanding patient needs. Our sales training will emphasize being
knowledgeable on our products and effectively communicating with patients.
There will be no emphasis on selling larger amounts of medical cannabis, and in
fact Compassionate Care seeks to encourage patients to purchase smaller amounts,
and adjust over time if necessary. High priority will be placed on providing a
positive atmosphere, where workers and employees will enjoy providing good
customer service.

 Privacy and Confidentiality Requirement Trainings - This training will include

professional conduct, ethics, and State and Federal laws regarding patient
confidentiality. Details of this training are included in our HIPAA manual.

Appendix J: HIPAA Manual

 Product Safety Training - As a means of ensuring that our products meet

minimum health standards, we intend to train employees on pertinent aspects of
product safety so health threats can be detected early on. The training will focus
on employees responsible for Compassionate Care’s production process. This
training will be designed specifically to enable employees to recognize superficial
indicators of health and safety risks so that our on-site Product Safety Department
can be notified for a thorough investigation.

Appendix N: Product Safety Plan

 Security Training and Security Drills - Given the nature of our business, security
is a significant aspect of our day-to-day operations. As such, employees will not
only be trained on site on the proper procedures in case of an emergency. All new
employees will also be required to attend off-site safety/security trainings that
must be completed during the early stages of employment. As part of our
commitment to a safe working environment, new employees will also receive
basic training on personal safety/security. This includes parking lot safety and
training for employees walking to work or utilizing public transportation. Lastly,
Compassionate Care will work with the local police to develop appropriate
ongoing training for all employees. All employees will be trained on the security
devices accessible to them, such as alarms, emergency phones, and keycard
access. Only the appropriate security personnel will be trained on all aspects of
security devices, such as surveillance cameras, retrieval of security footage,
monitoring, and controlling keycard access levels.

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Appendix H: Security Plan

 Environmental Training - In an effort to meet and exceed our environmental

standards all employees will be trained on the basics of green business practices.
Each employee will be trained to meet our sustainable goals and objectives
surrounding sustainable site development, water saving, energy efficiency,
material selection, indoor environmental quality, and innovation and design.
Employees will learn about Compassionate Care's environmental design strategy
and be trained to incorporate day-to-day environmentally friendly practices.

 Fire Safety and Training Drills - Given that fire safety is important in our line of
work, Compassionate Care will provide continuous training on fire prevention to
all employees, especially those in our cultivation facility. Employees will be
trained generally on fire hazards, with an emphasis on department specific
hazards. For example cultivation areas will have different and arguably greater
risks than the finance department. As such, employees in cultivation areas will
receive fire prevention training specific to wiring, amperage, and voltage.
Department and job classification specific training like this will be provided for
certain employees while general fire safety, hazard training, and drills will be
required for all employees. The general training will encompass detecting
potential fire hazards and appropriate steps to take in the event of an actual fire.

 Hazardous Materials Training - It is expected that every person working in the

cultivation and manufacturing facility at Compassionate Care will be
knowledgeable in acting responsibly in emergencies and handling hazardous
materials. In most cases the observer of an emergency is faced with the decision to
leave the scene and summon help or to stay and provide help. It is imperative that
the employees receive proper training so they know the correct protocols in
handling these types of situations. At minimum, employees should know basic
hazard and risk assessment, how to select and use protective equipment,
understand basic hazardous materials terms, know how to perform basic control
and containment operations, and know basic decontamination procedures.

 Delivery Truck Training - Compassionate Care will contract with Dunbar for
secure deliveries from our cultivation facility to our patient care center. For the
pick-up and delivery of supplies used for our operation, Compassionate Care plans
on implementing internal delivery truck training guidelines to ensure the safety of
our workers.

 Employee Safety Training - A top priority for Compassionate Care is protecting

our employees’ safety. On a daily basis, employees are exposed to potential
hazards that may require immediate attention. The potential hazards are different
in our cultivation facility than in our patient care facility. In our cultivation

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facility, potential hazards can include machinery malfunction, electrical fires,
natural disasters, small flooding, and intrusions. In our patient care facility, more
training will be focused on security procedures involving human interference than
on malfunctions since employees will be interacting with the public.

 Emergency Preparedness – Employees will be trained to identify and properly

respond to the most common types of emergencies, including fire and explosions,
hazardous materials release, suspicious packages, earthquakes, utility outage,
gunfire, death or serious injury, workplace violence, and hostage situations.

To fulfill the Cannabis education component, such as horticulture and propagation,

Compassionate Care has engaged the University of Cannabis, a California-based company, to
provide specialized education pertaining to medical cannabis curriculum.

Compassionate Care plans to compensate their employees during this training process, and
also pay for tuition or class fees when the training is not done internally, such as through the
University of Cannabis.

Each employee will give signed statements indicating the date, time, and place he or she
received training and the topics discussed, including the name and title of presenters. All of
this information will be stored in personnel records kept in secure areas and locked file
cabinets. Compassionate Care will conduct periodic performance evaluations to evaluate the
effectiveness of our training and to measure the development of our employees.
Compassionate Care will implement an ongoing education and training program so
employees and managers are continually challenged to learn new skills and expertise.
Complete training material is contained within our Employee Training Manual.

Exhibit I: Employee Training Manual

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Chapter 6: Alcohol, smoke and drug-free policies

6-a) The ATC shall establish, implement and adhere to a written alcohol, drug-free
and smoke-free workplace policy.

Compassionate Care intends to help provide a safe and drug-free work environment for our
clients and our employees. With this goal in mind and because of the serious drug abuse
problem in today's workplace, we are establishing the following policy for existing and
future employees of Compassionate Care.

The Company explicitly prohibits:

 The use, possession, solicitation for, or sale of narcotics or other illegal drugs,
alcohol, or prescription medication without a prescription on our premises or
while performing an assignment.
 Being impaired or under the influence of legal or illegal drugs or alcohol away
from Compassionate Care's premises, if such impairment or influence adversely
affects the employee's work performance, the safety of the employee or of others,
or puts at risk Compassionate Care’s reputation.
 Possession, use, solicitation for, or sale of legal or illegal drugs or alcohol away
from Compassionate Care's premises, if such activity or involvement adversely
affects the employee's work performance, the safety of the employee or of others,
or puts at risk our reputation.
 The presence of any detectable amount of prohibited substances in the employee's
system while at work, while on the premises of Compassionate Care, or while on
company business. "Prohibited substances" include illegal drugs, alcohol, or
prescription drugs not taken in accordance with a prescription given to the
employee.

The Company will conduct drug and/or alcohol testing under any of the following
circumstances:
 RANDOM TESTING: Employees may be selected at random for drug and/or
alcohol testing at any interval determined by Compassionate Care and as
allowable by law.
 FOR-CAUSE TESTING: Compassionate Care may ask an employee to submit to
a drug and/or alcohol test at any time as allowable by law if we feel that the
employee may be under the influence of drugs or alcohol, including, but not
limited to, the following circumstances: evidence of drugs or alcohol on or about
the employee's person or in the employee's vicinity, unusual conduct on the
employee's part that suggests impairment or influence of drugs or alcohol,
negative performance patterns, or excessive and unexplained absenteeism or
tardiness.
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 POST-ACCIDENT TESTING: Any employee involved in an on-the-job accident
or injury under circumstances that suggest possible use or influence of drugs or
alcohol in the accident or injury event may be asked to submit to a drug and/or
alcohol test. "Involved in an on-the-job accident or injury" means not only the one
who was or could have been injured, but also any employee who potentially
contributed to the accident or injury event in any way.

If an employee is tested for drugs or alcohol outside of the employment context and the
results indicate a violation of this policy, or if an employee refuses a request to submit to
testing under this policy, the employee may be subject to appropriate disciplinary action, up
to and possibly including discharge from employment. In such a case, the employee will be
given an opportunity to explain the circumstances prior to any final employment action
becoming effective.

Exhibit J: HR Manual

6-b) The permit holder shall ensure that the policy is available to the
Department upon request.

Compassionate Care will ensure that our alcohol, drug, and smoke free policy is available for
the Department upon request, and provided in our Human Resources Manual.

Exhibit J: HR Manual

6-c) The policy shall address the following:

I. THE POLICY’S INAPPLICABILITY IF AN EMPLOYEE, WHO IS ALSO A QUALIFYING PATIENT, FAILS THE
DRUG TEST SOLELY BECAUSE OF THE PRESENCE OF MARIJUANA IN A CONFIRMED POSITIVE TEST
RESULT;
II. THE ATC’S POLICY PROVIDING FOR PROBABLE CAUSE SUBSTANCE ABUSE TESTING CONSISTENT WITH
APPLICABLE STATE AND FEDERAL LAW; AND
III. OPPORTUNITIES FOR ASSISTANCE OF AN EMPLOYEE WITH A SUBSTANCE ABUSE PROBLEM.
IV. SPECIFIC PROCEDURAL INSTRUCTIONS FOR RESPONDING TO AN EMERGENCY, INCLUDING A ROBBERY
OR WORKPLACE VIOLENCE.

These policies are provided in our Human Resources Manual. Compassionate Care shall not
apply our alcohol, drug and smoke free policy to qualifying medical cannabis patients. All of
our procedures will be consistent with applicable state and federal laws. We will always seek
to provide opportunities for assistance to employees with substance abuse problems. Policies
on responding to emergencies, including robberies and workplace violence, are also provided
in our Human Resources Manual.

Exhibit J: HR Manual

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6-d) The ATC shall maintain a contract with an approved New Jersey employee
assistance program.

Compassionate Care intends to work and contract with an approved New Jersey employee
assistance program. We recognize that employee assistance programs can help employees
with issues affecting job-related performance and well-being, which is a cause
Compassionate Care fosters within its own operations and training programs. Some of the
employee assistance programs we have identified and intend to work with include:
 Associates for Life Enrichment
 CARE EAP
 Center for Psychotherapy and Addictions Treatment
 Intervention Strategies International, Inc.
 Lifeworks Employee Assistance Program
 Lynne Pastor
 Responseworks, Inc.

We also recognize that working with an employee assistance program can help complement
our efforts in assisting employees deal with problems such as personal relationships,
emotional conflicts, health care resources, parenting, transitions, decision making skills,
addictive behaviors, financial prioritizing, and work stress.

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Chapter 7: Security

7a) Each alternative treatment center shall provide effective controls and
procedures to guard against theft and diversion of marijuana including, when
appropriate, systems to protect against electronic records tampering.

Compassionate Care has consulted with several high-level security experts to develop a
comprehensive plan that protects our products, patients, employees, facilities, administration,
and neighbors. We intend to implement effective controls and procedures to guard against the
theft and diversion of marijuana. They are discussed in our Security Plan.

Some of the operational security measures include:

 Third party security participation and monitoring
 Recognizing potential security threats early on
 Contingency planning
 Transactional security (i.e., limited cash procedures, inventory, securing data and
network servers)
 Delivery security (in conjunction with our service provider, Dunbar)
 Employee security training
 Employee background checks
 Strict guest, media, and visitor procedures
 Active neighborhood involvement
 Emergency response planning

Some of the facility security controls include:

 Utilizing secure buildings and locations
 Providing on-site, secure parking
 Having 24/7 coverage
 Security systems (i.e., alarms, third party monitoring, overhead PA and panic
buttons, lockdown capabilities, video surveillance and recording, lighting)
 Access control for ingress and egress
 Perimeter security (i.e., fencing, uniformed armed security personnel)
 Product security

Exhibit H: Security Plan

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7b) At minimum, each alternative treatment center shall:

7b-i) Install, maintain in good working order and operate a safety and security
alarm system at its authorized physical address(es) that will provide suitable
protection 24 hours a day, seven days a week against theft and diversion and that
provides, at a minimum:

 Immediate automatic or electronic notification to alert State or local police

agencies to an unauthorized breach of security at the alternative treatment
center; and
 A backup system that activates immediately and automatically upon a loss
of electrical support and that immediately issues either automatically or
electronic notification to State or local police agencies of the loss of
electrical support;

Compassionate Care intends to install and maintain safety and security alarm systems at our
cultivation and patient care centers. These systems will provide around the clock coverage,
seven days a week to protect against theft and diversion. In the event that our safety and
security systems are activated, notification will be sent to the directors of Compassionate
Care, our third party monitoring service, and State or local police agencies to alert them of
the security breach. These systems will be routinely maintenanced to limit false alarms, and
there will be battery and emergency generator backups to prevent any downtime of our
security systems.

7b-ii) Implement appropriate security and safety Sections to deter and prevent
the unauthorized entrance into areas containing marijuana and the theft of
marijuana;

Compassionate Care plans to implement security and safety measures to deter and prevent
the theft of cannabis or any the unauthorized access to areas containing cannabis. All
cannabis will be stored in highly secure areas with no public access. Our measures to
safeguard against unauthorized access include: perimeter fencing, security screening,
uniformed armed security personnel, electronic keycard access, and lockdown capabilities.
The primary preventative measure for unauthorized entrance will be through our keycard
access system.

Our keycard access system is a web-based IP access control system that enables real-time
control of each key card and entry point. We are able to define what the various security
zones are, and which individual key cards will grant access to the various areas. This
information can be quickly changed, so if an employee is terminated, for instance, his or her
keycard can be immediately disabled. In high security areas containing cannabis, keypad

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entry will be required in addition to an electronic card, preventing unauthorized individuals
who have come into possession of a keycard from gaining access. In the event of an
unauthorized keycard attempt, security personnel will be alerted to monitor the event to
determine whether it constitutes an attempted breach of security. Our intercoms and phones
will be able to communicate with a keycard holder in the event of a legitimate problem. The
passwords for managing electronic access will be constantly changed and managed by our IT
Department. More information is contained in our Security Plan.

Exhibit H: Security Plan

7b-iii) Implement security Sections that protect the premises, registered

qualifying patients, registered primary caregivers and principal officers, directors,
board members and employees of the alternative treatment center.

A comprehensive plan to protect our premises, registered qualifying patients, registered

primary caregivers, and principal officers, directors, board members, and employees is
provided within our Security Plan.

Exhibit H: Security Plan

7b-iv) Establish a protocol for testing and maintenance of the security alarm
system;

After our security system installation, Compassionate Care will conduct monthly and annual
tests to ensure all systems are fully operational. We will request a service contract from our
manufacturers that includes regularly testing our system, sensors, electrical connections, and
batteries monthly. Our maintenance and security personnel will also be trained on how to
maintain these systems. In addition to human monitoring, our systems include warning alerts
to notify us of any occurring or imminent problems.

Ongoing maintenance includes:

 Testing door/window sensors
 Testing motion detectors and diagnosing problems (conducted by two people, one
person to walk in front of a motion sensor and the other to verify motion is
detected)
 Testing smoke detectors (smoke detectors will be hard wired with battery backups
and have test buttons on each detector)
 Testing and replacing smoke detector backup batteries (batteries will routinely be
replaced)
 Testing the phone connection (false alarm tests with third party monitoring
company and law enforcement)
 Testing wireless sensors and replacing their batteries

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Compassionate Care will have an industrial-scale power generator in the event of a larger
power problem so our systems do not rely on their battery backups.

7b-v) Conduct maintenance inspections and tests of the security alarm system at
the ATC’s authorized location at intervals not to exceed 30 days from the previous
inspection and test and promptly implement all necessary repairs to ensure the
proper operation of the alarm system;

Compassionate Care will conduct maintenance inspections and tests of the security alarm
system at our cultivation facility and at our care center at intervals of not more than 30 days,
and we will promptly implement all necessary repairs to ensure the proper operation of the
alarm system. All inspections, inspection results, and maintenance records will be securely
kept for review as required.

7b-vi) In the event of a failure of the security alarm system due to a loss of
electrical support or mechanical malfunction that is expected to last longer than
eight hours:

 Notify the Department pursuant to N.J.A.C. 8:64-9.8; and

 Provide alternative security measures approved by the Department or close
the authorized physical addresses impacted by the failure or malfunction
until the security alarm system is restored to full operation;

With our routine inspections, prompt repairs, system self-monitoring mechanisms, battery
backups, and backup power generators, we do not anticipate our security alarm system being
down for more than eight hours due to loss of electrical support or mechanical malfunction.
If such an event occurs, we will immediately notify the Department pursuant to N.J.A.C.
8:64-9.8. Our emergency response planning will also include plans to close all access to our
cultivation and patient care centers until our security alarm system is restored to full
operation.

7b-vii) Keep access from outside the premises to a minimum and ensure that
access is well controlled;

Access to our cultivation and patient care centers is strictly controlled. In our cultivation
facility, no patients, guests, visitors, media, or members of the public are allowed to enter
without special clearances. In addition, they must always be accompanied by security
personnel. The cultivation site has high security perimeter fencing, video surveillance,
security lighting, and a guard post to prevent unauthorized access. Our patient care center
will also have a secure perimeter with appropriate security clearance required for entry.
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Detailed information is provided in our Security Plan.

Exhibit H: Security Plan

7b-viii) Keep the outside areas of the premises and its perimeter well lighted.

 Exterior lighting must be sufficient to deter nuisance and criminal activity

and facilitate surveillance and must not disturb surrounding businesses or
neighbors;

Security lighting will be used as a preventative and corrective measure against intrusions or
other criminal activity. Security lights are one of the most practical and effective ways to
prevent crime. Criminals look for areas with little to no lighting.

Our research has shown that downward directed and shielded security lighting of medium
intensity provides for the best outdoor vision. In addition to the position of the security lights,
controlling glare is an important consideration. This is essential for our security staff and
third party monitoring to be able to see an intruder. Our staff and surveillance technology
must be able to provide authorities with accurate descriptions and visual evidence in the
event of a security breach.

Specific security lighting we have considered for our cultivation and patient care facilities:
 L-Shaped steel poles with vertically secured 18 and 20ft. high exterior adjustable
dual mounted 400 HPS lamps
 Exterior 150 HPS wall sconces above all entrances and exits
 Motion sensitive exterior perimeter lighting
 Interior motion-sensitive ceiling and wall mounted luminaries

Exhibit H: Security Plan

7b-ix) Provide law enforcement and neighbors within 100 feet of the ATC with the
name and phone number of a staff person to notify during and after operating
hours to whom they can report problems with the establishment;

Name: William J. Thomas

Phone: 267.614.3341

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7b-x) Equip interior and exterior premises with electronic monitoring, video
cameras and panic buttons.

 A video surveillance system shall be installed and operated to clearly

monitor all critical control activities of the ATC and shall be in working order
and operating at all times. The ATC shall provide two monitors for remote
viewing via telephone lines in State offices. This system shall be approved
by the MMP prior to permit issuance.
 The original tapes or digital pictures produced by this system shall be
stored in a safe place with a 30-day archive;

In our Security Plan, we have provided a layout of our cultivation facility that features a
security overlay. The floorplan shows interior and exterior camera locations and other
security devices, as well as the area for around-the-clock video monitoring and DVR
locations. Our third party monitoring company will have video surveillance access for
additional protection, and Compassionate Care will provide the State of New Jersey with
remote access and at least two video monitors for viewing our facility via telephone lines.
We will obtain all necessary approvals by the MMP and follow the same procedures for our
patient care center. All video footage will be stored in our on-site 1,000 GB DVR, which is
capable of storing at least thirty days of video footage and will be expanded as needed to
comply. All recordings will be backed up to the internet daily to prevent loss of surveillance
footage in the event of an emergency.

Compassionate Care’s facilities will also incorporate an intrusion detection system that
includes a hold-up, panic, and critical condition signal monitoring service to give employees
an opportunity to react to a security breach. Panic buttons will be located in specific locations
throughout the cultivation facility to allow for easy employee accessibility. To prevent
misuse, we will train employees on when a situation warrants activating the alarm. The panic
buttons as well as the entire security system will be tested monthly to ensure that it is
working in the event of a real emergency. More information is provided in our Security Plan.

Exhibit H: Security Plan

7b-xi) Limit entry into areas where marijuana is held to authorized personnel;

Areas where marijuana is held are strictly secured, as described in earlier sections and in our
Security Plan. Only authorized employees will be given access to these areas. Keycard
access and PIN numbers are always required for entry. Maximum-security measures will be
taken in these areas, and they will be closely monitored by security and management.

In our cultivation facility, areas considered high-risk include:

 Loading space

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 Armored truck parking
 Loading dock
 Shipping/receiving
 Packaging and curing
 Harvest area
 Trimming room
 Security monitoring rooms

These areas are shown in our security floorplan. In patient care centers, all areas where
marijuana is held will undergo similar security measures.

Exhibit H: Security Plan

7b-xii) Consistently and systematically prevent loitering, that is, the presence of
persons who are not on-duty personnel of the ATC and who are not ATC
registrants engaging in authorized ATC-dispensary activity; and

Compassionate Care does not allow loitering around our facilities. For our patients visiting
our patient care center, we will provide our no loitering policy during their orientations and
in the patient handbook. Not complying with this policy could lead to involuntary
disenrollment or other disciplinary measures. For non-patient loitering or any loitering
around our cultivation facility, our security personnel will be trained on how to regulate it.
Any suspicious activity will be reported to law enforcement.

7b-xiii) Provide onsite parking.

Secured on-site parking will be provided. All entrants are required to pass though a perimeter
fence that is monitored by video surveillance. Access to parking areas in our cultivation
facility requires security clearance from our guard post. Access to parking areas in our
patient care centers is permitted during normal business hours with security personnel nearby
at all times. Parking areas are monitored 24/7, with ample lighting, to ensure individuals get
to and from their cars safely.

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Chapter 8: Reportable Events

Upon becoming aware of a reportable loss, discrepancies in inventory, diversion, or theft,
whether or not the medicinal cannabis, funds, or other lost or stolen property is subsequently
recovered, and whether or not the responsible parties are identified and action taken against
them, we shall:
 Immediately notify appropriate law enforcement authorities by telephone.
 Notify the permitting authority immediately, and in no case later than three hours
after discovery of the event.

We shall notify the permitting authority within 24 hours by telephone at (609) 826-4935,
followed by written notification within 10 business days, of any of the following:
 An alarm activation or other event that requires response by public safety
personnel;
 A breach of security;
 The failure of the security alarm system due to a loss of electrical support or
mechanical malfunction that is expected to last longer than eight hours; and
 Corrective measures taken, if any.

We shall further maintain documentation in an auditable form for a period of at least two
years after the reporting of an occurrence that is reportable pursuant to this section.

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Chapter 9: Inventory
Compassionate Care intends to keep adequate inventory levels of products available for our
patients. Having an oversupply of inventory leads to product degradation and security risks,
but having an undersupply of inventory leads to insufficient access to medicine. In order to
sustain sufficient inventory levels, our cultivation facility and patient care center facility will
communicate regularly and efficiently. When a particular strain is running low, we can
advise our cultivation facility to increase production. When we have an excess of a particular
strain we can decrease production accordingly, or offer pricing incentives to expedite sales.

One of the capabilities of our supply chain tracking system (described in Criterion 5,
Measure 3) is to control our inventory and anticipate future production needs. Under our
supply chain tracking system each plant in our cultivation facility is assigned a unique,
progressive serial number from the moment a cutting is taken. This serial number is entered
into our secure computer database so we are always aware of the number of plants within our
facility and their strain. We are also aware of the current status of the plant (e.g., whether it is
in the vegetative stage of growth or the flowering stage of growth). This information allows
us to forecast inventory levels for the future, so if a patient ever inquires when a particular
strain will be available, we can quickly determine how many of those plants are in
production, what stage of production they are in, and how long until the plants are ready to
harvest.

After harvesting, when the medical cannabis is securely transported to our patient care
center, our supply chain tracking system is integrated with the secured database of our
delivery company and patient care center. After a product from our cultivation facility is
placed in transit, the status of the package is updated pending delivery confirmation, and then
the status is updated when it is received by the patient care center. Once the product is sold at
the patient care center, information as to the patient it was sold to will be associated with the
serial number of our plant, so there is traceability from seedling to sale. Even in the absence
of physical communication,, our secure technology allows us to retrieve current inventory
levels in our patient care center so the cultivation personnel are made aware of any possible
shortages or overages.

Inventory will be manually performed every day in the patient care center to verify the
accuracy of our computerized inventory management system and prevent diversion. Manual
inventory will also be performed in our cultivation facility on at least a weekly basis to
ensure all products, byproducts, and discarded items in our operations are accounted for.
Information will be kept for a period of at least 7 years, or as otherwise required by the State
of New Jersey.

Regular inventory and supply chain tracking allows us to prevent diversion or distribution to
non-medical recipients. We will take the following measures to prevent diversion:
 At the time of each purchase, verify an individual’s status as a qualified patient or
caregiver with a valid identification card;

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 Have the individual agree not to distribute cannabis to non-patients;
 Have the individual agree not to use the cannabis for other than medical purposes;
 Maintain membership records on site or have them reasonably available;
 Track when members’ medical cannabis recommendation and/or identification
cards expire;
 Enforce conditions of membership by excluding members whose identification
card has expired, or who are caught diverting cannabis for non-medical use;
 Track each patient’s purchases to make sure he or she is not purchasing more than
legally allowed;
 Refuse to transfer medical cannabis to any person, even if legally qualified, if
there is reason to believe such person or entity is using cannabis for non-medical
reasons or is likely to divert such medical cannabis to persons or entities
unauthorized to possess it under state law.

To prevent diversion in our cultivation facility, our supply chain tracking system follows
every plant from seedling to sale, so we can verify the destination of every product
Compassionate Care produces and sells. This system allows us to:
 Prevent shrinkage within the facility, whereby plants are stolen, since each plant
has a barcode and if it is missing we will know that a serial number is
unaccounted for;
 Compare average yields of plants, whereby if plants in particular areas are
yielding less end product we can alert security to a possible concern; and
 Require the accounting department to obtain delivery confirmations for every
product delivered, and log that information with our record keeping system.

Furthermore, all patient care center sale transactions are done through a point of sale
cashiering system; two background checked employees manually verify inventory counts
daily, and we use storage safes for any excess inventory.

Compassionate Care believes that having strict guidelines aimed at preventing diversion, and
creating an inventory tracking system that allows us to follow each plant from seedling to
sale, we will be able to create a closed loop system where cannabis does not end up in the
possession of a non-medical user. All of the information pertaining to production,
transferring, sales, and patients will be securely kept and available for review by the State of
New Jersey as required by law.

Minimal inventory procedures

Compassionate Care will develop a comprehensive inventory system that keeps track of all
medicinal cannabis, including cannabis available for cultivation and usable cannabis
available for dispensing, from seedlings to mature cannabis plants and unusable cannabis, at
our authorized location, beginning on the date we first engage in the production or dispensing
of medicinal cannabis. We anticipate beginning with no medicinal cannabis on hand, and we
will record this fact as the initial inventory. Cannabis is deemed to be “on hand” if it is in our

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possession or control.

Our inventory shall include damaged, defective, expired, or adulterated cannabis awaiting
disposal, including the name, the quantity, and the reasons for which we are holding the
cannabis. Compassionate Care will comply with the State of New Jersey’s Health and Senior
Services Medicinal Marijuana Program for minimal inventory requirements, which includes:
 Establishing inventory controls and procedures for the conduct of inventory
reviews and comprehensive inventories of cultivating, stored, usable, and
unusable cannabis;
 Conducting a monthly inventory of cultivating, stored, usable, and unusable
cannabis;
 Conducting a comprehensive annual inventory not more than one year from the
date of the previous comprehensive inventory;
 Promptly transcribing inventories by use of an oral recording device;
 If cannabis is disposed of, maintaining a written record of the date, the quantity
disposed of, the manner of disposal, and the persons present during the disposal,
with their signatures;
 Keeping all records for a minimum of two years; and
 For all inventory records, at a minimum, including the date of the inventory, a
summary of the inventory findings, and the name, signature, and title of the
individuals who conducted the inventory.

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Chapter 10: Destruction of marijuana

Compassionate Care has developed a return policy based on our principles and our
understanding of the Medical Marijuana Program (the ―MPP‖). We anticipate that aspects of
the return policy may be revised as the Department further clarifies the rules of the Program.
Compassionate Care’s policy on unused or returned medication is guided by three orienting
objectives:
 Ensure product safety issues are promptly identified, analyzed, and corrected;
 Provide excellent value and service to our patients; and
 Minimize opportunities for diversion.

Before a batch of medicinal cannabis is packaged, a sample will be tested in our laboratory
for pests, molds, and other contaminants, and we will also analyze the cannabinoid profile of
the product (details are provided in Criterion 5, Measure 3). Any medicinal cannabis found
to be deficient, whether because of mold, excessive THC, or other issues, will be incinerated.
In addition, excess inventory will periodically be destroyed to prevent any unauthorized use
or distribution. An on-site incinerator in a secure room of the facility will be used for this
purpose and operated by highly trained personnel.

If a patient or caregiver returns product claiming that it is defective, our staff will complete a
report on the complaint and take possession of the returned product. The returned product
will be weighed, and if the returned product is >50% of the volume purchased, the customer
will be eligible for a full refund of the purchase price. Also, the customer may apply the
value of the product returned to another medication purchase. As each patient may only
purchase two ounces of medication per month, patients returning >50% of a quantity of
medicine for quality reasons will be able to replace that allotment within their two-ounce-
per-month purchase limit. Patients making returns of less than half of the product purchased
will be eligible for a refund of the purchase price, but they will only be able to buy substitute
product if they have not reached their purchase limit for the month, inclusive of the product
returned. With this policy we hope to balance consumer protections with the Act’s objective
to limit personal consumption of medicinal cannabis to no more than two ounces of medicine
per month and prevent diversion.

Any product returned for quality reasons will be sent to our laboratory for inspection and
analysis. If the product has evidence of pests, contaminants, or other problems, we will use
our inventory tracking system to identify all products produced from the same plant, whether
they are in our cultivation facility or patient care center, or have been sold to patients and
caregivers. Upon receipt of returned product from the patient care center the product
received will be weighed and its weight compared to recorded weight of the product when
returned. Management and security will investigate discrepancies and any reportable events
will be communicated to the Department. Once the source plant associated with a product
quality problem has been identified, any related product that remains in our possession will
be returned to the lab for inspection and the product will be destroyed. We will also issue a
consumer alert to patients who have received related product, and they will be encouraged to

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return the potentially damaged product to their patient care center. Any returned product
received by our patient care center will be sent to our cultivation facility where it will be
incinerated after appropriate samples have been provided to the laboratory for analysis.
Throughout this process the volume of the product will be recorded in our inventory
management system, so there will be thorough documentation of the product’s disposition
and any diversion can be identified and managed as required by New Jersey law and the rules
of the Department.

Permit Expiration

If our permit to operate ur ATC expires without being renewed or is revoked, Compassionate
Care will comply with the State of New Jersey’s Health and Senior Services Medicinal
Marijuana Program for destruction of cannabis and recordkeeping, including:
 Destroying or disposing of all unused cannabis or surplus inventory in our
possession by providing it to the New Jersey State Police for destruction;
 Creating and maintaining a written record of the disposal of cannabis that is
identified for disposal, weighing and inventorying it prior to destruction; and
 Discontinuing production of cannabis.

Within 10 business days after destroying the cannabis, we shall notify the Department, in
writing, of the amount of cannabis destroyed.

Cannabis No Longer Required

We shall disclose to a qualifying patient or a primary caregiver who is in possession of

unused, unadulterated cannabis that is no longer needed for the qualifying patient’s medical
use the he or she shall dispose of the cannabis by:
 Returning it to an alternative treatment center; or
 Transporting it or arranging for pickup by State or local police.

The person or entity submitting cannabis for disposal pursuant to this section shall present a
valid registry identification card and a within ten business days after destroying the cannabis,
we shall notify the Department, in writing, of the amount of cannabis destroyed.

Qualifying patients or primary caregivers in possession of unused, unadulterated cannabis

that is no longer needed for the qualifying patient’s medical use shall dispose of the cannabis
by:
 Returning it to our patient care center where they purchased the cannabis; or
 Transporting it or arranging for pickup by State or local police.
The person or entity submitting cannabis for disposal pursuant to this section shall present a
valid registry identification card and a New Jersey driver’s license or other State-issued
photographic identification to us or the police, as applicable.

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Appendix

H
Security Plan

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Security Plan
Compassionate Care understands the most important assets we have are not our products,
but our people. That’s why Compassionate Care has approached our security plan with
the seriousness of not only protecting our equipment, inventory, and products, but, more
importantly, the lives and well-being of our community and team members. We are
keenly aware of the added security challenges that our business faces, and we have taken
extensive measures to have policies, procedures, and systems in place to provide
comprehensive protection.

We have consulted with Barragan Corp International (BCI), a world-wide safety/security

company, to make sure our security plan considers all possible threats while utilizing
today’s most up-to-date technology to counteract them. BCI is owned and operated by
former Department of Defense Security/Safety Specialist, David F. Barragan, a 24-year
Marine and former Director of Safety and Security for all Marine Corps Installations west
of the Mississippi, additionally Mr. Barragan was Detachment Commander of American
Embassies in Lima Peru, Athens Greece, and Dhahran Saudi Arabia. While BCI has
designed many comprehensive security solutions, Mr. Barragan has personally
experienced them, with firsthand knowledge of the various tactics that can be used to
overcome traditional security measures. BCI understands the various security concerns
that we may anticipate.

We have divided our security plan into two components: Cultivation Facility Security and
Operational Security. Both categories are designed to minimize our security exposure
and prevent breaches. However, in the event that preventative measures fail, our
operational solutions are designed to quickly detect, monitor, contain, counter, and report
situations that do occur.

FACILITY SECURITY

This section pertains to our cultivation facility, as our patient care facility has not been
chosen yet. Our cultivation facility is designed to include physical safeguards that protect
against security breaches and trigger an immediate response. After choosing consultants
with appropriate experience levels to manage this project, the next security decision we
made was during our site selection. For each possible site we took physical security into
consideration. We wanted to find a space with as many intrinsic security features as
possible, based on such things as location, layout, existing security systems, neighboring
uses, and building finishes. Each site was analyzed for barriers, control points, points of
entry, roofing, lighting, hardware, building finishes, and other security considerations. It
was important to find a facility located in a secure area, fabricated with durable material
that would reduce our exposure to security risks, and not visible from the street or public
areas.

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Specific selection criteria included: set back from any high traffic intersections; secure
avenues of ingress and egress; located in an industrial park; not located near any schools,
freeways, residential housing, or places of worship; and not accessible via foot traffic.
At the facility we have chosen, the existing building is constructed of masonry. The 12‖
thick concrete exterior perimeter walls provide a solid base for security. There are no
exterior windows anywhere on the building, and the exit doors have no external access—
they exist for egress purposes only. These doors have mechanisms only for exiting the
cultivation facility, with no exterior handles or hinges. If an intruder tried to enter the
cultivation facility, he would not be able to use the doors as an entry point. Since there
are no windows and no doors with exterior entry, potential intruders would have great
difficulty gaining unauthorized access. Limiting access through these existing design
elements deters and reduces the likelihood of unwanted intrusion.

Law Enforcement Assessment

Compassionate Care has submitted its security plan for review by several highly-
experienced security consultants, including leaders in the Metropolitan Transportation
Authority Police Department and the Detectives’ Endowment Association, Inc and TRC
Corporation. These consultants have concluded that Compassionate Care’s plan meets or
exceeds current standards for policing and securing of this type of facility (see Appendix
J). We have reached out to local law enforcement officials as well, and as we move
forward we will develop plans to coordinate our security measures with their policies and
procedures.

Secured Employee Parking

Secured parking will be provided for Compassionate Care’s employees. All employees
will be required to enter though the main campus security gate. This gate will be
monitored and on-site security personnel will grant authorized access. Compassionate
Care will encourage the use of carpooling and public transportation, and individuals
arriving at the site through these methods will be dropped off in front of the secured
campus and granted pedestrian access by security. Before entering the cultivation
facility, a final security clearance is required. Authorized individuals will need keycard
access to enter the various areas. To ensure employees get to and from their cars safely,
parking areas will be provided with ample lighting and monitored 24/7 by our security
personnel and surveillance system.

Around the Clock Coverage

Plants grow 24 hours a day, 7 days a week. Therefore, Compassionate Care plans to have
staff and security on site 24/7. Sufficient security staff will always be available to
monitor the cultivation facility, parking lots, and campus, including at least 3 security
guards overseeing the surveillance systems and servers in the security department. Our
security systems will operate around the clock to prevent and detect threats and alert our
staff to any possible breaches. These systems will be checked regularly to ensure proper
functionality. Our internal security guard force will monitor all of these systems and our
cultivation facility and our corporate headquarters, so even in the event that our security
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personnel are unable to detect a problem, there is an additional layer of observation and
protection.

Security Systems

Compassionate Care plans to have in place a comprehensive security system that includes
alarms, third party monitoring, overhead PA and panic buttons, lockdown capabilities,
video surveillance/recording and security lighting. Intrusion detection mechanisms,
including alarms and video surveillance, will be located strategically throughout the site.
Specifically, entries and exits will be secured, and cameras will be located on the exterior
and interior of the building to capture suspicious behavior.

Alarms

Compassionate Care has reviewed various alarm systems available in the market today
and has chosen Henry Bros. Electronics VISTA 128BPE security alarm system to
monitor access to the cultivation facility, specifically all entry and exit points. Alarms
serve to deter unauthorized access once an intruder has breached at least one of our
security layers. The hope is that once an audible alarm is triggered an intruder will flee.
With our silent alarm system the objective is to catch an intruder in the act or prevent the
aggravation of a dangerous person while simultaneously alerting the authorities and our
security team.

Silent alarm panic buttons will be placed throughout the cultivation facility. They will be
used to alert our corporate headquarters to take appropriate action. Our on-site security
will have access to our video surveillance and can identify the level of threat and
emergency. Generally, silent alarms are advisable in situations where an intruder is
unaware of detection and triggering a siren alarm would put our staff in danger. Given
the level of security barriers, it is unlikely an intruder will overcome them and cause a
situation where a silent alarm is necessary. Silent alarm and panic buttons will likely be
more appropriate if someone granted access becomes unruly and threatens staff.

The system will provide intrusion detection, such as laser beam penetration and
unauthorized keycard access that notifies our on-site security and corporate headquarters
of the specific area of the problem. This system covers multiple points of entry in case
there is more than one intruder. Generally, alarm distress signals will be siren alar ms that
are loud, can scare off or disorient intruders, and alert all staff to a security breach.

In the event that someone has already gotten into the building, our door contacts will
accurately detect exiting and cause appropriate alarms to go off when doors are forced
open. This system alerts security staff and appropriate Compassionate Care personnel.
To prevent the of New Jersey Police Department’s resources, Compassionate Care staff
will contact the New Jersey Police Department only if the threat is deemed legitimate.

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Ongoing maintenance and testing

After our security system installation Compassionate Care will conduct monthly and
annual tests to ensure all systems are fully operational. We will request a service contract
from our manufacturers that includes regularly testing our system, sensors, electrical
connections and batteries monthly. Our maintenance and security personnel will also be
trained on how to maintain these systems. In addition to human monitoring, our systems
include warning alerts to notify us of any occurring or upcoming problems.

Some of the areas that tests will be done include:

 Testing Door/Window Sensors
 Testing Motion Detectors & Diagnosing Problems (conducted by two people, one
person to walk in front of a motion sensor and the other to verify motion is detected)
 Testing Smoke Detectors & Battery Replacement (smoke detectors will be hard wired
with battery backups and have test buttons on each detector)
 Testing and Replacing the Backup Battery (batteries will routinely be replaced)
 Testing the Phone Connection (false alarm tests with 3 rd party monitoring company
and law enforcement)
 Testing Wireless Sensors & Replacing Batteries

Compassionate Care will have an industrial-scale power generator in the event of a larger
power problem so our systems do not rely on their battery backups.

With our routine inspections, prompt repairs, system self-monitoring mechanisms, battery
backups and backup power generators, we do not anticipate our security alarm system
being down for more than eight (8) hours due to loss of electrical support or mechanical
malfunction. If such an instance happens, we will immediately notify the Department
pursuant to N.J.A.C. 8:64-9.8. Our emergency response planning will also include plans
to close all access to our cultivation and patient care centers until our security alarm
system is restored to full operation.

Compassionate Care will conduct maintenance inspections and tests of the security alarm
system at our cultivation and dispensary care center in intervals not to exceed 30 days
from the previous inspection and test and promptly implement all necessary repairs to
ensure the proper operation of the alarm system. All inspections, inspection results and
maintenance records will be securely kept for review as required.

Third Party Monitoring

Compassionate Care has decided to utilize monitoring from the corporate headquarters to
help deter, detect, and document security events at the cultivation facility. Trained
professionals from the security staff located at our corporate headquarters will be able to
access our security surveillance system at all times and will report and document any
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suspicious activity. Our internal security department will establish guidelines for what
entails suspicious activity.

There will be triggers around the cultivation facility to alert our monitoring team of a
possible intrusion or unauthorized access. Triggers can be:
 Motion-sensor surveillance cameras
 Motion-sensor laser beams
 Unauthorized electronic access
 Security and fire alarms
 Silent alarms

If a security alarm is activated or someone unauthorized tries to access a restricted area

with a key card, an alert will automatically be sent to our corporate headquarters. The
corporate staff will be able to see what is happening remotely via our surveillance system
and determine if the incident represents a security breach. Typically an alarm or
unauthorized key card attempt represents a higher concern than motion-sensor
surveillance or laser detection.

For motion-sensor surveillance or laser detection, triggers must be configured around

access needs by staff. We will work together with our security consultants and subject
matter experts to designate areas that are considered off-limits for staff during certain
hours (typically after normal business hours, 5PM-8AM). Any movement in these areas
during those times will trigger an alert to our monitoring team. For example, if there were
an after-hour access request in the shipping and receiving department (see site plan in
Appendix H), where our finished products are stored, an alert would be sent to our
monitoring team notifying them of a possible security breach. The monitoring staff
would be able to see what was happening inside the cultivation facility and determine if
the incident represented a security breach.

Overhead PA and Panic Buttons

Compassionate Care’s cultivation facility will incorporate an intrusion detection system

that includes a hold-up, panic, and critical condition signal monitoring service to give
employees of Compassionate Care the opportunity to react to a security breach. Panic
buttons will be located throughout the cultivation facility to allow for easy employee
accessibility. We will train employees on when or not a situation warrants activating the
alarm. The panic buttons as well as the entire security system will be tested monthly to
ensure that they are working in the event of a real emergency.

In the event of a security breach, an overhead PA system will alert employees to the
emergency and direct them on the appropriate way to respond. Security personnel will be
responsible for operating and providing instructions over the PA system. The PA system
will be primarily accessed through the Security Department, but anyone on the premises

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can access the PA through any telephone within the cultivation facility. As an additional
safeguard, the on-site security supervisor will at all times have a mobile panic remote in
the case an employee cannot reach the panic button in a timely manner.

The PA system is connected to speakers throughout the cultivation facility so all staff can
be made aware of a critical happening. Part of the training protocol for all Compassionate
Care staff will include emergency drill training, so staff is adequately prepared to
respond.

Strategically placed red emergency phones will also be located in every department of the
cultivation facility. Located on the wall next to these phones will be phone numbers of
emergency service providers. While these phones traditionally are used for fire safety,
they can also be used for security purposes.

Lock Down Capabilities

Our Electronic Access Control system gives us the ability to centrally lock down our
entire cultivation facility. Each access point is controlled from a central membrane, and
in the event of an emergency, our security department can lock down any sector, from a
single door (partial lock down) to the entire cultivation facility (complete lock down).
This allows us to respond to different levels of threats and keep a problem contained. The
system can also be used to keep doors unlocked, allowing free access in the event of an
evacuation. Since each door can have unique access specifications, our system allows us
to lock down the cultivation facility to everyone with the exception of a certain access
class, such as our security personnel, or those with a special keycard, which could be
given to law enforcement.

In creating a lockdown plan, adequate staff training is imperative. Appropriate training

will include all staff. Security personnel will be routinely trained on what situations may
require a lock down and how to operate the system. Staff will be trained on what to do in
the event of a cultivation facility lockdown.

Compassionate Care will also make sure in the event of an emergency lockdown there is
adequate communication. A lockdown will automatically alert our corporate staff that
there is a critical situation at our facility. The lockdown will register on our overhead PA
system, notifying all personnel what’s happening. Additional communication measures
include sending text messages and emails to the cell phones and mobile communications
devices of directors and management.

By controlling entryways and exits, as well as movement within the cultivation facility,
authorized security personnel will be better able to contain and handle threats. Regular
training for staff will incorporate the most effective lockdown procedures. To manage
emergencies effectively, we will use communication methods that can distribute
emergency instructions quickly and widely during an event.

Video Surveillance / Recording

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Video surveillance is the cornerstone of our security system. Our surveillance systems are
a strong deterrent and will help Compassionate Care monitor the entire facility and its
surroundings. A variety of specialty cameras, such as infrared, motion-sensor, PTZ, fixed
zoom, low-light, megapixel, IP, and night vision cameras will be used in our video
surveillance. All cameras will have the tilt/pan/zoom capabilities and will have secure
off-site internet access. Compassionate Care encourages the State of New Jersey to
participate in surveillance access to its cultivation facility, similar to the practices in
Colorado for compassionate caregiver monitoring. We view this as an additional
monitoring measure to keep our employees and products safe.

Our security consultants have determined that a total of 39 vandal resistant, low power
consumption exterior and interior cameras need to be installed (see Picture X). These 39
cameras will be dynamic and have the ability to respond to motion and communicate
suspicious activity to our corporate monitoring personnel. Our indoor cameras include
discreet 2.0 megapixel cameras. Our exterior cameras offer high resolution and weather
resistant features that ensure a clear picture with every use. In addition to our corporate
monitoring, by the time we are in full operation, our internal Security Department will
always have at least 3 staff members present to oversee the security systems and
monitors, and they have the ability to call up 6 additional guards within 15 minutes. To
adequately secure the cultivation facility 24hrs a day, 365 days a year, the video
component of our security plan includes:
 Exterior Monitoring – We believe 4 surveillance cameras are sufficient for monitoring
and recording events on the surrounding lot, and 4 surveillance cameras for
monitoring the exterior of the cultivation facility. Accordingly, four 5-50mm AL VF
Outdoor Dome Cameras will be used. These cameras are all-weather high definition
cameras with day and night capabilities. With these megapixel cameras,
Compassionate Care will have clear, crisp images that let us see the important details
we need for identification. This includes face and license plate recognition, while still
capturing a full field of view for exterior monitoring.
 Interior Monitoring – We believe 14 cameras for the interior of the cultivation facility
are sufficient to provide complete coverage. High definition cameras placed in
specific high security areas will have forensic capability. We have chosen Speco
Color Series Indoor cameras for our interior needs. These cameras will be operable
24/7, have the ability to respond to motion, and will alert appropriate security
personnel of suspicious activity. The cameras will have infrared/night vision
capabilities and be heat sensitive, which allows them to respond to human
movements. The camera locations are depicted on the security floor plan included in
Appendix H.
 Night Monitoring – Compassionate Care’s cultivation facility will be monitored 24
hours a day. Security personnel will be on site during the evening/night hours and will
monitor the facility through the camera systems as well as through scheduled
cultivation facility and site walks. All exits and entrances will be monitored though
our intrusion detection system 24 hours a day. In addition to being dynamic, these

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cameras will have infrared capability and be heat sensitive, ensuring that personnel
can identify unusual activity and be alerted only when necessary.
 Body Cameras – Compassionate Care plans to use body cameras with certain types of
staff, such as exterior security personnel and those working in the shipping and
receiving department, where all of our finished products are kept. By placing body
cameras on individuals that provide products to our unmarked van delivery service,
we can monitor any product that leaves the cultivation facility. This will ensure
employee protection and non-diversion. In case of a security breach during delivery,
the high definition body cameras will record the event and provide forensic evidence.
As with cameras located at the physical site, the data from the body cameras will be
backed up and stored as necessary.

Lighting

Security lighting will be used as a preventative and corrective measure against intrusions
or other criminal activity at the cultivation facility. Security lights are one of the most
practical and effective ways to prevent crime. Statistics have shown that a well-lit
property reduces crime because lighting acts as a deterrent. Criminals most likely look
for areas with little to no lighting. With our security consultants, we have performed a
comprehensive site evaluation to ensure that more than sufficient lighting exists,
especially in areas otherwise overlooked and with dark surroundings.

Our research has shown that downward directed and shielded security lighting of medium
intensity provides the best outdoor vision. In addition to the position of the security
lights, controlling glare is a major consideration. This is essential for security. Our staff
and third party monitoring must be able to see an intruder, and our surveillance must be
able to capture clear images.

The specific security lighting proposed for our cultivation facility includes:
 L-shaped steel poles with vertically secured 18 and 20ft. high exterior adjustable dual
mounted 400 HPS lamps
 Exterior 150 HPS wall sconces above all entrances and exits
 Motion sensitive exterior perimeter lighting
 Interior motion sensitive ceiling and wall mounted luminares

Lighting is integral to our crime prevention strategy through environmental design.

Without risking a reduction in safety features, wherever practical Compassionate Care
seeks to use energy efficient bulbs to maintain our goal of being a carbon-neutral, LEED
Certified cultivation facility.

Access Control / Ingress and Egress

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The electronic access control management system we have chosen is the Honeywell
NetAXS Access Control system. NetAXS is a web-based IP access control system that
enables real-time control of each key card and entry point. We are able to define what
the various security zones are, and which individual key cards grant access to the various
areas. This clearance can be quickly changed using NetAXS. If an employee is
terminated, for instance, the employee’s key card can be immediately disabled.
Likewise, if an employee receives a promotion and needs additional access, NetAXS can
make those changes quickly.

Compassionate Care will have 3 levels of security access in our cultivation facility. The
lowest level of security will be Level 1 and include:
 The Conference Room
 Break Room
 Men’s and Women’s Showers, Bathroom, and Lockers
 Janitorial Room

Level 2 (Moderate Risk) Access will include:

 Mechanical Room
 Lab
 Extractions Room
 Administration Building
 Nursery (Cloning)
 Vegetative Room/Area

Level 3 (High Risk) Access will include:

 Loading Space
 Armored Truck Parking
 Loading Dock
 Shipping/Receiving
 Packaging and Curing
 Harvest Area
 Trimming Room
 Security Monitoring Rooms

At every access point is a card reader that requires a keycard to grant access, and a
surveillance camera that monitors the door. In extremely high security zones (i.e. Level
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3), key pads will be installed and a PIN required to gain entry. This protects against a
situation where an authorized employee loses his/her access card, and it is recovered by
an unauthorized individual before the card has been reported lost to the Director of
Security. Additional security for Level 3 areas include dual person access and dual entry
access. In the event of an unauthorized keycard attempt, security personnel will be alerted
to monitor the event to determine whether it is an attempted breach of security. Our
intercoms and phone can be utilized to communicate with a keycard holder in the event of
a legitimate problem.

Compassionate Care will be able to instantly review access activity by user and by
individual doors. We can see where each individual has traveled or look at a particular
entry point to see which individuals have accessed that area. This information helps us
narrow our focus in the event of a problem.

We will also have the ability to add customized notifications in the event of an
emergency. These customized notifications include email or cell phone alerts that can
notify appropriate staff of specific emergency alerts and access breaches. Linked with
security cameras, instant playback of events, including video and logs of door access,
will be available in the event of an emergency and can also be accessed remotely through
hand held devices.

Compassionate Care anticipates having many different layers of security access. Each
security zone has different security measures to protect that area, and the electronic
access control system regulates which individuals can access these areas. Some keycard
restrictions reflect operational rather than security concerns. For instance, individuals
that enter areas with male plants will not be allowed to enter areas with female plants to
prevent pollination, even though they have the same access. Generally, horticultural staff
will only be given access to the specific departments where they have direct
responsibilities in order to prevent contamination. In most circumstances, they will not
even be able to enter adjacent departments, so if contamination does occur, it is isolated
to the specific area worked by that staff person.

The passwords for managing Electronic Access Control will be constantly changed
through the IT Department. This will ensure only authorized security personnel can
regulate access levels.

Perimeter Security

Our surrounding campus security involves several layers of protection. The first layer is
our gate that surrounds the entire perimeter of the property. The second layer is the
uniformed security personnel that will be supplied by BCI Strategic Risk management.
The last level of perimeter security is our monitoring system that comprises video
surveillance, alarms, and optimal lighting.

Fence/Gate (Intrusion Detection)

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Compassionate Care is located within a secure campus. The entire site will be enclosed
within an 8’ high fence. There is only one entrance into the site. During Phase 1 of our
construction this gate will be reinforced by industrial strength steel. Heavy grade bollards
will be set every 4’ around the perimeter for additional security. The entrance consists of
a security gate that is monitored 24/7 by high definition day/night cameras and intrusion
detection systems. This 12’ high fence will provide an initial barrier to potential
intruders. Our independent security consultants confirm that deterrents such as these
ultimately prevent intruders from entering the site because it decreases the likelihood of
successful access and increases their chances of getting caught.

In the event that an intruder does try to access the site, our security cameras will be able
to capture clear images of the individual. Whether the attempt is successful or not, these
images will be sent to the New Jersey Police Department for further investigation.

Uniformed Armed Security Personnel

Uniformed armed security personnel will be on site monitoring the cultivation facility
24/7. Compassionate Care has consulted with BCI Strategic Risk Management, an
international protective services firm, for its 24/7 security guard needs. All security
personnel will be thoroughly screened, trained, and strictly supervised by BCI to ensure
they are acclimated to our cultivation facility’s unique needs. BCI will work in
conjunction with Compassionate Care’s Security Department. The Director of Security
will screen and conduct trainings to ensure that uniformed personnel can effectively carry
out our security objectives.

In collaboration with our consultants, we have determined that a total of 3 on-site security
guards will be required to monitor and protect the cultivation facility at all times. The
break-down of these 3 security guards is as follows:
 1 guard will patrol the perimeter (with at least 1 stationed by the Shipping and
Receiving Department during operation).
 1 guard will monitor images from surveillance cameras inside the cultivation facility,
monitor the cultivation facility entrance and login anyone attempting to enter the site,
and monitor the campus gate and cultivation facility gate.
 1 will supervise all security staff and freely travel the cultivation facility and campus
as needed

At the end of every shift, security personnel will be required to document any happenings
every 60 minutes and report any unusual activity occurring during their shift. These notes
will automatically be maintained in a database and electronically managed for future
retrieval.

Loitering

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Compassionate Care does not allow loitering around our facilities. For our patients
visiting our patient care center, during their orientations and in their patient handbook we
will provide our no loitering policy. Not complying with this policy could potentially
lead to involuntarily disenrollment or other disciplinary measures. For non-patient
loitering or any loitering around our cultivation facility, our security personnel will be
trained to consistently and systematically regulate this. Any suspicious activity will be
reported to law enforcement.

Product Security

Product security is ensured at every step of the process. By limiting access to the
cultivation facility and monitoring activities inside the facility, the mechanisms discussed
above will protect products from theft and tampering 24 hours a day, 7 days a week.
Added protection will be provided through our supply chain tracking software which will
record, track and monitor our products from seed until sale (see Criterion 4, Measure 1).
All products are required to go through a quality assurance assessment throughout
different stages of the growth and production cycle. Any tampering not immediately
noticed via surveillance camera will be caught during product safety testing.

In the event that a finished product is packaged after the last unmarked van delivery has
left for the day, it will be stored overnight in our safe. In consultation with our insurance
provider, JCH Insurance has suggested the use of the AMSEC AmVault CF5524. This
safe has the proven ability to withstand temperatures up to 1850 F and unwarranted entry
using sledgehammers, power saws, carbide disc cutters, and drills. The safe is equipped
with a three-way active bolt mechanism engaging the bolts horizontally and vertically
into the body of the safe. All finished products will be stored in the safe overnight and
then shipped out the next morning. All other products that are unfinished, immovable, or
in the development stage will be protected overnight by the system of surveillance
cameras, alarms, and armed security just described.

OPERATIONAL SECURITY

Our operational security measures are policies and procedures that are an important
component of reducing the threat to our facility, employees, contractors, products,
patients, administration and data.

Securing Data, Network & Servers

In today’s technological era, data and information have become as susceptible as goods
and products. While our IT Department is responsible for protecting our data against
intruders, basic measures that will be taken to protect our information include:
 Virus protection
 Spam-filtering software
 Firewalls
 Software and OS Updates
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 Passwords
 Physical security of data storage centers
 No portable laptop computers
 Secure Wireless networks
 Restricted Web browsing
 Data Backups

Backing Up Security Data

Having a system in place to back up and protect security data is just as important as
capturing security information. Often times a theft or security breach is not detected at
the time of the incident, and it’s important for Compassionate Care to be able to retrieve
historical information to see what took place. Therefore, our data backup plan is
designed to protect vital information.

The surveillance camera system will have a digital video recorder (DVR) with a
minimum of 1,000GB of storage. While the DVR will allow us to retrieve several weeks
of historic information, all of the recordings will be backed up online onto a much larger
database. That way, in the event our DVR is damaged, stolen or malfunctioning, all of
the recordings will still be retrievable online via a highly secure network access. Online
back-up is automatically done multiple times throughout the day, so there is never an
incident where vital data was not backed up.

We will have secured access to real time alarm history, service ticket information,
suspicious activity reporting, and open/close activity from our security system through
the web. All of this surveillance and security information is backed up, whereas in the
event of an emergency, natural disaster, or criminal breach, all of our security
information is safe in a remote location

Neighborhood Involvement

Compassionate Care is committed to participating in a fruitful partnership between the

local police department and the community to encourage safety and prevent crime in the
area surrounding the proposed cultivation site. As a means to gain a greater
understanding of the most problematic issues and general neighborhood concerns,
Compassionate Care’s will coordinate regularly neighborhood meetings.

Emergency Response

Compassionate Care recognizes the importance of maintaining an integrated Emergency

Response Plan to maintain the safety and well-being of its employees and visitors. In the
event of a potential security breach, Compassionate Care will maintain the following
emergency response protocol in order to conserve valuable municipal resources.
 On site security personnel will determine if security breach is an actual threat
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 Our 3rd party monitoring center will automatically be notified electronically if the
breach has been initially detected through the security system and determine the
extent of the threat
 If security breach is determined to be an actual threat, local and state authorities will
be notified as required as required.

Reporting Problems

Law enforcement and neighbors within 100 feet of our facility will be provided with the
name and phone number of a staff person to notify during and after operating hours to
whom they can report problems with the establishment. At this time, we have chosen:

Name: William J. Thomas

Phone: 267.614.3341

State or local police agencies will be notified of unauthorized breach of security. These
systems will be routinely maintained to limit false alarms and have battery and
emergency generator backups to prevent any downtime of our security systems.

In the event of a failure of the security alarm system due to a loss of electrical support or
mechanical malfunction that is expected to last longer than eight hours we will also
notify the Department as required.

Background Checks

Compassionate Care’s human resources department will ensure appropriate background

checks and references are conducted for all potential contractors, vendors, employees,
principals, directors and board members. We will provide all potential employees with
copies of any public records obtained in the background process. This could include
documents that pertain to an arrest (if it results in a conviction), indictment, conviction,
civil judicial action, tax lien, or outstanding judgment. More information, including
copies of our background check and reference verifications forms, is contained within our
Human Resources manual.

Appendix K: Human Resources Manual

Security Training & Security Drills

Security is a significant aspect of our day-to-day operations. As such, employees will be

required to complete personal safety, crime prevention, emergency planning, and security
systems and procedures training. Compassionate Care will work with the local police to
develop appropriate ongoing training for all employees,, and employees will be given
reference material consistent with our trainings to fully understand Compassionate Care’s
policies. All employees will be trained on the security devices accessible to them, such as
alarms, emergency phones and keycard access. Only the appropriate security personnel
will be trained on all aspects of security devices such as surveillance cameras, retrieval of
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security footage, monitoring, and controlling keycard access levels. Information on our
training programs is contained within our Employee Training Manual.

Appendix I: Employee Training Manual

Limited Cash Operation

We do not allow any financial transactions to take place at our cultivation facility, and
will institute procedures to limit the amount of cash stored on premises at our patient care
center. Low thresholds will be set for management to remove cash from registers and
place in a safe until pickup. All cash registers, display cases and any areas where
cannabis is stored will be fully secured and monitored by video surveillance.

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Appendix

I
Employee Training Manual

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Appendix

J
HIPAA Manual

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Appendix

K
HR Manual

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Appendix

L
Cultivation Overview

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 APPENDIX M

Appendix

M
Hydroponic Design

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 APPENDIX N

Appendix

N
Product Safety Plan

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Appendix

O
Fire Safety Plan

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Appendix

P
Environmental Plan

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Appendix

Q
Financial Pro-Forma

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 APPENDIX R

Appendix

R
Letters of Recommendation

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 APPENDIX R

February 11, 2011

Compassionate Care Foundation

c/o Valerie J. Kimson, Esq.
Mason, Griffin, Pierson, PC
101 Poor Farm Road
Princeton, NJ 08540

Dear colleagues:

Thank you for selecting CW Analytical Laboratories to provide analytical services for your project. CW
Analytical has scientifically defensible protocols and detailed quality assurance plans that meet or exceed
the Proposed Rules of New Jersey’s Medicinal Marijuana Program. In fact, CW Analytical is actively
engaged with government officials across the country to more clearly define product safety and testing
standards for medical Cannabis. Our team has the ability to analyze a wide range of medical Cannabis
products with the academic and professional expertise required to interpret and defend our results. These
attributes make CW Analytical the ideal candidate for providing third party product assurance for your
permitted medical Cannabis facilities.

This letter is to confirm that, per our conversations, CW Analytical Laboratories will provide the following
analytical services on a regular basis for your facility if you are awarded an operating permit:

 Accurate quantification of delta-9-tetrahydrocannabinol, cannabidiol, and cannabinol in all

suitable materials;
 Verification of the absence of harmful chemical pesticides in all suitable materials;
 Verification of the absence of harmful molds, yeasts, and bacteria in all suitable materials; and
 Environmental swabbing of production, trimming, packaging, and food processing areas to
confirm presence/absence of molds, yeasts, and bacteria.

In addition, our personnel are available to provide on-site consultation for all quality assurance related
issues. This includes establishment of an Integrated Pest Management strategy that will limit the use of
harmful chemical pesticides. We can also help verify the overall cleanliness of production, trimming,
packaging, and food processing areas of the facility.

Finally, our lab will maintain secure, digital records off all services performed for your facility. You will
have 24/7 access to these data files from anywhere. This will streamline the time needed to prepare reports
for government regulators.

Thank you again for the opportunity. We look forward to working with you.

Sincerely,

Dr John J Oram, PhD

Principal Scientist, Co-Founder

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