Breakwater ATCApplication

Breakwater Alternative Treatment Center
Application for the Operation of a Medicinal Marijuana Alternative Treatment Center

In the Central Region of New Jersey
Breakwater Alternative Treatment Center, Corp. (BATC) is comprised of an accomplished

and seasoned team of highly skilled professionals, respected by their peers who are seeking
approval to operate a state-of-the-art Alternative Treatment Center. Although the Medicinal
Marijuana Industry is still a very young industry, we know that with one common vision and
purpose this diverse team of specialists will take BATC and the industry as a whole to, until now,
unexplored heights. BATC will set the benchmark for treatment centers not only in the State of
New Jersey but for other states and other companies in our nation.
Our relationship will not be one of mere licensing authority/applicant. Rather, we envision a true
partnership with the New Jersey Department of Health and Senior Services wherein each partner
can learn from the other and contribute equally to the success of the treatment center for the
benefit of its patients, its surrounding neighbors and the citizens of New Jersey at large.
Our Management Team includes:

An Attorney and business owner of a multi-million dollar institutional pharmaceutical
company employing over 80 employees.
An Attorney and former owner of a medical waste service business.
A Doctor of Horticulture, with a background in community medical research ethics, who
holds a PhD degree in agricultural sciences. He runs Good Tree Farm an award winning
Community Supported Agriculture (CSA) in the town of New Egypt.
Our Medical Advisory Board includes:

An Attorney and former mayor of Manalapan.
A Registered Pharmacist with expertise in the pharmacology of medical marijuana who
will expertly counsel ATC patients and their caregivers.
A Registered Nurse specializing in births.
This proven team of health experts is well equipped to effectively satisfy the needs of all patients
in the medical marijuana program as well as excel in our compliance obligations. They will
conduct regular clinical trials and closely monitor patient outcomes and share this critically
important with NJDHSS. We have developed a strong relationship with the Towns of Manalapan
and New Egypt and have their full support.
Mission Statement
Breakwater Alternative Treatment Center p.1 of 210

The mission of Breakwater Alternative Treatment Center (BATC) is to create a safe,
compassionate, comfortable and controlled environment where qualifying patients can receive
laboratory-tested medical cannabis at a reasonable price.
Objectives
¾ To promote a “hands on” approach to treatment and wellness.
¾ To protect and care for patients, employees and the earth by using environmentally
responsible "green" technologies and techniques.
¾ To be a leader in the medical cannabis industry as a sustainable, organic growing
company providing the highest quality, toxin-free and safest medicine.
¾ To offer assistance programs in order to ensure equal access to treatment and care for all
qualifying patients regardless of ability to pay.
¾ To collaborate with the State of New Jersey, community leaders, CMMNJ, medical
professionals, patients and their families to develop innovative and caring programs,
services and support plans to care for qualifying patients.
¾ To establish strategic alliances with other non-profit organizations to protect patient
rights to access and appropriate treatment, advocate for responsible public policy, and
facilitate fundraising efforts.
¾ To pursue grant opportunities from government agencies, foundations and corporations in
order to expand programs that provide qualifying patients with access to treatment and
care.
Breakwater Alternative Treatment Center will fully and completely comply with all of the
requirements and standards set forth herein. We will rely on the experience and expertise of all
of our patients, team members, board of directors, real estate professionals, public and
government relation professionals, consultants, attorneys and medical advisory board. We will
work closely with the New Jersey Department of Health and Senior Services (NJDHSS) to
ensure full initial compliance and to monitor and correct any issues that may arise in the future.
We believe our application fulfills the requirements of the Medical Marijuana Program Rules
and Regulations and lays a strong foundation for operation of an Alternative Treatment Center in
this central region of New Jersey.
PREPARED BY:
BREAKWATER ALTERNATIVE TREATMENT CENTER, CORP.

Criterion 1: Submission of Required Information Regarding Applicant & Facility
[MANDATORY REQUIREMENTS]
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.
Proposed Legal Name: Breakwater Alternative Treatment Center Corp.
¾ Certificate and Articles of Incorporation and By-Laws for corporations

See Appendix A-1 “Articles of Incorporation”
¾ Organizing documents for associations
See Appendix A-2 “By-Laws”
¾ Evidence of nonprofit status
See Appendix A-3 “Nonprofit Status”
¾ Certificate of good standing issued by the New Jersey Secretary of State
See Appendix A-4 “Certificate of Good Standing”
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.
¾ 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.
¾ 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
N.J.A.C. 8:64-1.2.
¾ If a precise address has not been determined, the applicant shall identify the general
location(s) where the facilities would be sited, and when.
BATC has been working diligently with real estate agents and land owners, leasing agents and
attorneys to secure properly zoned and municipally approved facilities in the Central Region of
New Jersey that meet the criteria outlined in the Rules and Regulations Related to the Medicinal
Marijuana Program issued by the New Jersey Department of Health and Senior Services.

Due to the efforts involved in securing and cultivating a medical marijuana crop and because the
functions of distributing and cultivating are so different, Breakwater has decided to split the
operation into two (2) distinct locations within the Central Region.
Cultivation Site – The cultivation site is a Fifty-Five (55) acre active organic farm (Good Tree
Farm) located at 82 Jacobstown Road, New Egypt, NJ 08533 situated within the Central Region.
See Appendix B-1 “Initial Commitment Letter- Cultivation Site” (Attached)
Site Control – The owner of the Cultivation site is an organic consultant to Breakwater
and has extended an option to lease portions of the site for the operation which shall be
formalized upon receipt of the operations license. Cultivation site selection is of
particular strategic importance as time is needed to bring the production part of the
operation on-line to ensure adequate supply. The Dispensary site location shall be
finalized while the cultivation site moves forward within two (2) months of award of
license.
Dispensary Site (ATC) – BATC intends to operate a convenient and accessible dispensary in
order to serve the qualified patient population of New Jersey and will establish its dispensary
location as expeditiously as possible (30 days) following approval. The dispensary will be
opened as soon as it is ready for occupancy and well before the first harvest of useable marijuana
is available. We intend on opening the dispensary or a temporary office at least five months
(prior to August) prior to dispensing medical marijuana in order to register patients and
caregivers as well as educate patients and the public.
Proposed location is in an existing office building. While the present applicable laws provide for
only two Alternative Treatment Center’s in Central New Jersey, BATC is confident that the
public can be best served by locating its Alternative Treatment Center in this area of the state.
Dispensary Address: 400 Madison Avenue

Manalapan, NJ 07726
Site Control –The Dispensary site location shall be finalized while the cultivation site
moves forward within two (2) months of award of license. See Appendix B-2 “Initial
Commitment Letter- Dispensary” & Appendix B-3 “Dispensary Real Estate Letter"
(Attached)
BATC has several other potential dispensary site options, which are all located within the
Central Region in Monmouth County (towns include Manalapan, Freehold, Wall Township and
Morganville). The final determination regarding the dispensary location will be made upon the
issuance of a permit and after consultations with the NJDHSS, if so advised. In the event that
two permits are awarded in Central Jersey and BATC is granted a permit, we are willing to
consult with the NJDHSS regarding the location of our dispensary in order to prevent the
clustering of dispensaries in two areas. We have also identified dispensary sites and are currently
engaging with officials from the Cities of Freehold, Neptune and New Brunswick. Having made
the business decision to choose to separate the dispensary from the cultivation site leaves BATC
in the unique position to be more flexible with their dispensary location. If NJDHSS does not
find another qualified candidate, BATC would be willing and able to handle both ATC licenses
or have the ability to open a second dispensary in Central Jersey using one cultivation site.

BATC recognizes the important responsibility of providing high quality medical cannabis to
qualifying patients in New Jersey through its licensed dispensary location. BATC has consulted
and will continue to work with the provider community, pain management specialists, the
Coalition for Medical Marijuana - New Jersey (CMMNJ), the New Jersey Pharmacists
Association (NJPHA), and health/wellness providers in order to design a facility and services
that meet the needs of New Jersey’s medical marijuana patient population. Upon approval of its
application, BATC will work to quickly establish its dispensary location in a convenient and
accessible location in the state as set forth above. BATC is open to additional guidance from the
New Jersey Department of Health and Senior Services regarding appropriate distribution
methods and advertising/promotion. For instance, with guidance from the Department of Health
and Senior Services, BATC would like to provide a transportation service (to and from) for those
patients who are immobile or otherwise unable to visit its dispensary location. In the event that
the demand increases for medical marijuana, we will continuously maintain our financial ability
and resources to meet any increase in demand. We have identified an optimal location for a
cultivation site and will secure a lease within three to five days after receiving an approved
permit.
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.
Breakwater Alternative Treatment Center (BATC) is working with the municipal zoning boards in
the proposed cultivation and dispensary communities to ensure compliance with all zoning
regulations, local codes and ordinances. Our New Jersey real estate attorneys are prepared to
submit timely applications for any additional building permits (if needed) that are in full
compliance with all zoning rules and regulations. Municipal (Zoning officials) and state officials
have assured that BATC’s proposed cultivation site will fall under agriculture zoning laws and
will not require zoning variances.
Cultivation Site - The site is zoned RA5 – Rural Agricultural as is the adjoining farm to the west
in Burlington County. Please See Appendix C - Zoning Map & Aerial Map.
The cultivatable portions of the site front Jacobstown Road to the north, an active farm to the
west (Burlington County), a Utility Line easement to the South where the eastern part of the site
is undeveloped woods.
Mayor Dancer has visited the Good Tree Farm organic operation and is supportive of the farm
and we are in communication regarding medical marijuana being added to the Farm’s list of
crops. Since the cultivation site conforms to current zoning laws and is in a rural part of town
and more than 3,000 feet from any school we do not anticipate any problems with the site. But
we are conscious of the perceived nature of the operation and will endeavor to address any
concerns the Township may have.
Dispensary Location (ATC)

The Breakwater strategic plan was such that only sites that met all zoning ordinances would be
considered. That would include distance to schools and not located in a drug-free zone. As most
Township ordinances do not specifically address the production of medical marijuana, detailed

follow-up meetings with elected officials, zoning officers and the police will be necessary to
garner their input into successfully rolling out the operation.
During a recent teleconference with the Mayor of Manalapan, Andrew Lucas, concerning
locating the dispensary in Manalapan, Mr. Lucas had no objection to the project and thanked us
for the heads up on the application. BATC has also spoken with one of the committeemen who
indicated that she was fully supportive of the idea. BATC next step is to meet with the zoning
officer of Manalapan for a review meeting in the next week. At this meeting we’ll determine if
the proposed use is conforming to zoning laws or if variances need to be obtained for such a use.
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.
Cultivation Site
Great care was taken throughout the site selection process to avoid school areas. The Cultivation
site is more than 3,000 feet from the closest school. See Appendix D-1 “Cultivation Map-
Proximity to School”
Dispensary (ATC)
BATC’s proposed dispensary location at 400 Madison Avenue, Manalapan is more than 4,800
feet from the Kiddie Academy Child Care Learning Center. BATC affirms that once the specific
Alternative Treatment Center facility location is determined it will not be located within 1000
feet of a preexisting public or private school or in a drug free zone. BATC will work with its
New Jersey-based attorneys, exclusive NJ dispensary real estate agent (Glen Jaffe), public affairs
consultants and office/medical building owners to ensure its facilities are not located within 1000
feet of the property line of a preexisting public or private school. Please see Appendix D-2
“Dispensary Map- Proximity to School”.
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.
Based on approximately a 20-mile radius around our dispensary location 400 Madison Avenue,
Manalapan located in the Central Region of New Jersey we have. We decided that most patients
will drive at least 30-45 minutes to our dispensary and within the 19-mile radius there are
513,870 patients (based on 2008 estimates) in 93 zip codes.
Below is a map showing the zip codes within a 19-mile radius from the dispensary and a list of
the zip codes to be served by BATC.

07701 Red Bank, NJ, 07702 Shrewsbury, NJ 07712 Asbury Park, NJ
07719 Belmar, NJ 07721 Cliffwood, NJ 07722 Colts Neck, NJ
07724 Eatontown, NJ 07726 Englishtown, NJ 07727 Farmingdale, NJ,
07728 Freehold, NJ 07730 Hazlet, NJ 07731 Howell, NJ
07733 Holmdel, NJ 07735 Keyport, NJ 07738 Lincroft, NJ
07746 Marlboro, NJ 07747 Matawan, NJ 07748 Middletown, NJ
07751 Morganville, NJ 07753 Neptune, NJ 07763 Tennent, NJ
08501 Allentown, NJ 08510 Millstone Township, NJ 08511 Cookstown, NJ
08512 Cranbury, NJ 08514 Cream Ridge, NJ 08515 Chesterfield, NJ
08520 Hightstown, NJ 08526 Imlaystown, NJ 08527 Jackson, NJ
08528 Kingston, NJ 08533 New Egypt, NJ 08535 Millstone Twnship, NJ
08536 Plainsboro, NJ 08540 Princeton, NJ 08542 Princeton, NJ
08550 West Windsor, NJ 08553 Rocky Hill, NJ 08555 Roosevelt, NJ
08561 Windsor, NJ 08562 Wrightstown, NJ 08610 Trenton, NJ
08619 Trenton, NJ 08620 Trenton, NJ 08629 Trenton, NJ
08648 Lawrence Twnship, NJ08650 Trenton, NJ 08690 Trenton, NJ
08691 Trenton, NJ 08701 Lakewood, NJ 08720 Allenwood, NJ
08724 Brick, NJ 08733 Lakehurst, NJ 08755 Toms River, NJ
08810 Dayton, NJ 08816 East Brunswick, NJ 08817 Edison, NJ
08823 Franklin Park, NJ 08824 Kendall Park, NJ 08828 Helmetta, NJ
08831 Monroe Township, NJ 08832 Keasbey, NJ 08837 Edison, NJ
08850 Milltown, NJ 08852 Monmouth Junction, NJ 08857 Old Bridge, NJ
08859 Parlin, NJ 08872 Sayreville, NJ 08873 Somerset, NJ
08879 South Amboy, NJ 08882 South River, NJ 08884 Spotswood, NJ
08899 Edison, NJ 08901 New Brunswick, NJ 08902 North Brunswick, NJ
08904 Highland Park, NJ 07710 Adelphia, NJ (point) 07765 Wickatunk, NJ (point)

07799 Eatontown, NJ (point) 08541 Princeton, NJ (point) 08543 Princeton, NJ (point)
08544 Princeton, NJ (point) 08818 Edison, NJ (point) 08855 Piscataway, NJ (point)
08862 Perth Amboy, NJ 08871 Sayreville, NJ (point) 08903 New Brunswick, NJ
08905 New Brunswick, NJ 08906 New Brunswick, NJ (point) 08922 New Brunswick, NJ
08933 New Brunswick, NJ 08988 New Brunswick, NJ 08989 New Brunswick, NJ
BATC intends to operate its dispensary in a location that is accessible by the maximum number
of patients and caregivers. The precise location will be selected after weighing current market
conditions and ease of accessibility by auto and public transportation alike. The location will be
carefully selected to serve the major population centers of New Jersey. The dispensary will be
handicapped accessible and be located in close proximity to public transportation routes to
ensure access for all qualifying patients. And for those patients who are immobile and cannot
visit our dispensary, BATC intends to work with the NJDHSS, on a case-by-case basis, to
determine if secure alternative dispensing methods for medical marijuana products are possible.
Our Alternative Treatment Center will be located in the City of Manalapan and will be easily
accessible by the citizens living in the two largest counties in the Central Region of New Jersey,
Middlesex (2009, 790,738) and Monmouth (2009, 644,105). New Jersey’s largest municipalities
based on population. Public transportation as well as major highways (I-95, Garden State
Parkway and I-195) and other major routes (Route 9, 18 and 33) will provide convenient access
to BATC's Alternative Treatment Center. The Alternative Treatment Center hopes to be located
close to a convenient NJ TRANSIT train and/or bus route. The location of major hospitals and
cancer treatment centers:
¾ Raritan Bay Medical Center-Old Bridge Division (13 miles)
¾ Centra State & Bayshore Community Hospital (18 miles)
¾ Robert Wood Johnson University & Meridian Health Middletown (16 miles)
¾ Riverview Medical Center (23 miles)
¾ Healthsouth Rehabilitation Hospital (25 miles)
As well as commercial commerce areas and other medical districts have and will continue to be
taken into consideration when determining a precise location. Consultations with local municipal
officials are also of paramount importance. Local opposition, if any, is another factor that will
influence the selection of the site for the Alternative Treatment Center. Our determination in this
regard will be made within a month after the awarding of our permit and after consulting with
the NJDHSS if it so desires. In order to properly service the maximum number of patients we are
considering providing our own transportation for those patients that are otherwise unable to
come to our dispensary on their own.
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.
Directors of Breakwater Alternative Treatment Center Corp.

**Please note the changes to our board of directors after incorporation of BATC.

1. Richard S. Lefkowitz – owning 50%
Board Member & Chief Executive Officer (CEO)
1500 Allaire Avenue, Ocean, NJ 07712
DOB – 7/15/1959
Richard Lefkowitz is an attorney and experienced entrepreneur. Mr. Lefkowitz received a law
degree from Rutgers University School of Law-Camden. Richard has operated his law practice
“Lefkowitz & Edelstein” for the past 20 years with offices throughout the United States. Mr.
Lefkowitz specializes in transactional and contract law and maintains a diverse client base.
Mr. Lefkowitz was also a founding member of Stonebridge Pharmacy Corp. an institutional
pharmacy providing prescription pharmaceuticals, including controlled substances, to thousands
of patients in nursing homes and long term care facilities throughout the Northeastern United
States. Under Mr. Lefkowitz’s guidance, this industrial pharmacy grew from a fledgling
business with a hand full of employees into a large supplier of prescription medication with
over 80 employees and $10 million in annual revenue. Always aware of the needs of others, Mr.
Lefkowitz was instrumental in installing a program for patients with financial difficulties
establishing a company policy of providing either free or discounted pharmaceuticals to certain
patients, who lacked the financial ability to pay.
Additionally, Mr. Lefkowitz continues to be active in numerous philanthropic endeavors.
Recently, he has served on the board of the Chemotherapy Foundation. In the past, he has
played an active role in charitable organizations such as “Heather on Earth”, the United Jewish
Appeal, the Make a Wish Foundation, the Ryan White Foundation.
With a broad base of hands-on business experience and a working knowledge of the law, Mr.
Lefkowitz contribution to BATC is invaluable.
2. H. Alexander Zaleski, ESQ. (Alex) – owning 50%

Board Member & Chief Operating Officer (COO)
26 Lakeview Drive, Marlboro, NJ 07746
DOB - 7/13/1947
Henry Alexander Zaleski (Alex) is a 1969 graduate of Fordham College, School of Business
Administration in New York City and Suffolk University School of Law in Boston,
Massachusetts. He was admitted to the Bar in 1975.
In 1972 he started a construction business specializing in build to suit single-family home
construction and renovation, including luxury homes. As an adjunct to this business he also
began acquiring vacant parcels to facilitate the home construction business. Eventually, his
business expanded into the Caribbean. In 2002 he was introduced to the Arxx insulated concrete
form construction technique and has employed this construction method to build reinforced
concrete structures. He has also constructed non-Arxx, concrete only structures. As the owner of
this business he has at all times personally directed all aspects of the business. At the same time
he began the construction business be began acquiring rental homes and has directed all aspects

of that business as well. Finally, he has owned and managed commercial rental property with
insurance companies and retail computer stores as tenants.
In 1987 he co-founded Gull Environmental Systems, a medical and hazardous waste
transportation company. The company was licensed by The State of New York (Department of
Environmental Conservation) and operated in Nassau and Suffolk counties. The company
serviced hospitals, doctors, dentists, dermatologists, podiatrists, veterinary clinics, chiropractors,
sports centers and nursing homes in a region with a population of 2.8 million people. At various
times, the waste was transported by locked cargo trucks to Pennsylvania, New York City and
Connecticut for disposal. When not in use the trucks remained locked in a secure parking
facility. In more than 20 years of operation, the company was never cited for any violations of
the strict rules and regulations imposed on medical and hazardous waste transporters.
These combined business experiences, spanning decades, makes Alex very well qualified to run
a medical marijuana Alternative Treatment Center and grow facility.
**See full experience running a Business in Criterion 2, Measure 3.
3. Dr. Hisham Moharram, PhD

Board Member & Chief Cultivator
82 Jacobstown Road, New Egypt, NJ
DOB – 12/8/1961
The founder and CEO of Good Tree Farm of New Egypt, LLC, is Dr. Hisham Moharram. Prior
to establishing the farm, Dr. Moharram was engaged in research in the area of Plant Natural
Products, and medicinal plants in particular. Dr. Moharram’s formal education is summarized in
the attached resume. The business concept of the farm has among its cornerstones the following
concepts; producing food locally, organically and sustainably (based on food security being a
critical component of national security), retailing at affordable prices (to widen accessibility of
fresh and wholesome food to broader segments of society, especially seniors on fixed incomes),
making fuller use of the value potential of plants by utilizing value-added processing (functional
foods), strengthening local economies (by hiring locally and spending and purchasing locally),
and facilitating employment opportunities for local residents willing to work hard and uphold
‘best production practices’ (to guarantee food safety for all our customers). We also facilitate
access to our farm fresh food for the poor and needy via our business focused ‘charitable
sponsorship’ program.
Please view Dr. Moharram’s Company website: www.goodtreefarm.com
Please see Appendix F for Full CV
4. Ross Basen
Board Member
113 Stratford Dr, Freehold, NJ
DOB – 4/27/1965
Ross Basen brings more than a dozen years of fundraising experience to IFDS and he is happy to
share his knowledge with the Non-Profit community. A graduate of the University of Pittsburgh

with a BA in Political Science, Ross worked in the financial services field prior to becoming a
fundraising professional. It was his commitment to helping others which led him to the Non-
Profit arena.
Ross has successfully raised funds for several universities - NJIT in Newark, NJ and Georgian
Court University in Lakewood, NJ - as well as for the Jewish Federation of Central NJ and the
American Red Cross.
As a sales person, Ross understands the value and importance of networking as well as
establishing and maintaining relationships. "Financial development is a relationship business -
you need to be willing to take the time to get to know your donors and make them feel
comfortable with your organization but most importantly, with you."
Ross is a Charter Member of the Freehold Area Kiwanis Club, as well as a member of its board
of trustees. He is also a member of the board for the Friends of Camp Sprout Lake, Verbank,
NY and the VP for Programming for the AFP NJ Southern Chapter.
A firm believer in continuing education, Ross has held the designation of Certified Fundraising
Professional (CFRE) since 2005 and will complete his studies for an MS in NonProfit
Management and Philanthropy from Bay Path College, Long Meadow, MA in May 2011.
Please view Mr. Basen’s Company website: www.raisemoredollars.com
5. Victor Coppola
Board Member & Environmental Planner / Land Use Consultant
2105 Princeton Court, Allenwood, NJ 08720
DOB – 3/27/1964
Mr. Coppola’s diverse environmental and strategic planning background offers a unique
perspective of existing and potential environmental and planning issues that affect land related
projects, corporate social responsibility & environmental. Mr. Coppola is the founder and
Managing Member of GreenWorks Environmental, LLC (GWE) a Land Use, Environmental
Science and Green Design / Build firm that offers complete eco-friendly / sustainability
consulting services to developers of commercial, industrial and residential projects; private
clients; governmental agencies; allied professionals; business owners and individuals targeted for
environmental violations.
Please view Mr. Coppola’s Company website: www.greenworksllc.com
6. Joseph Bender, Horticulturist (Joe)

Senior Cultivator
604 Granite Street #201-1 Frisco, CO 80443
DOB – 2/16/1985

Joe has received a Bachelor of Horticulture Science from the University of Florida, Gainesville
and an Associate of Arts (Horticulture Science) from Valencia Community College, Central
Florida. His coursework has included Entomology*, Plant Pathology*, Advanced Organic and
Sustainable Crop Production*, Horticultural Crop Production, Soils*, Plant Propagation*, World
Herbs and Vegetables, Micro propagation of Horticultural Crops*, Field Techniques in
Integrated Pest Management*, Horticultural Physiology I and II, Nutrition of Horticultural
Crops*, Genetics, Fruit Crop Production, and Safety in Agriculture* (Asterisk denotes the course
had a laboratory section).
Joe brings 8 years of extensive horticultural and consulting experience to BATC. He has toured
many greenhouse growing facilities, plant growth chamber labs, and outdoor horticultural sites
with the University of Florida and Valencia Community College. Joe has spent countless hours
of hands on laboratory experience at UF (refer to coursework list) and in the field.
7. Amy Klauber, ESQ.

Board Member & Legal Counsel
1500 Allaire Avenue Ocean, NJ 07712
DOB – 3/31/1965
Amy is a board member who will oversee all legal aspects of the Alternative Treatment Center to
make sure the company is in compliance with non-profit status and other related fiscal matters.
Amy is a Partner in her own general practice firm with offices in New York and New Jersey,
concentrating primarily on various aspects of civil law.
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:
¾ 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;
has been convicted of a felony under any Federal, state or local laws;
¾ 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;
has ever furnished false or fraudulent material in any application concerning drug
manufacturing or distribution;
¾ Whether the applicant is in compliance with any previously granted professional health
license or registration, if any; and
¾ Any other factors the Department might consider relevant.

Breakwater Alternative Treatment Center and all staff members, principals, officers and board
members have never been convicted under any Federal, state or local laws, relating to drug
samples, wholesale or retail distribution, or distribution of a controlled substance.
members have never been convicted of a felony under any Federal, state or local laws.
1. Richard S. Lefkowitz, Maureen Ivers, Victor Coppola have past experience in the legal
distribution of drugs or controlled substances through owning Stonebridge Pharmacy
Corp. an institutional pharmacy, Johnson & Johnson, the largest NJ based
pharmaceutical company Merck & Co, Inc.
members have never furnished false or fraudulent material in any application concerning drug
distribution.
Some staff members, principals, officers and board members are in compliance with a previously
granted professional health license or registration.
Measure 8: The applicant shall provide the identities of all its creditors, if any.
None
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.
Direct Management Oversight:
1. Richard Lefkowitz
Board Member & CEO
*See experience running a Business in Criterion 2, Measure 3.
2. H. Alexander Zaleski (Alex)

Board Member & COO
Alex will have direct management control over Breakwater Alternative Treatment Center.

Board Member & Chief Cultivator
Please see also Appendix F for Full CV

Indirect Management (Consulting) Oversight:
1. Bluemark Asset Management Corp.

Website: www.bluemarkassetmanagement.com
Originally formed in 1999 with the objective of developing a strategic “hands-on” financial
services company that significantly enhanced the value of selected media, life science, health,
medical and technology companies. BlueMark typically operated as a lead investor and provided
strategic services and financial services to a select number of these companies.
Today, the vision remains very much the same. With an expanded infrastructure, we have added
expertise, new strategic partners and enhanced investor services. The operational component of
the company continues to be strategic in nature – providing the essential services that add
substantial value to each company. We directly support our companies in the areas of operations,
structure, planning, finance and distribution.
BlueMark’s consulting team for BATC consists of Andrew Zaleski and Ashif Jiwa.
Andrew Zaleski received his Bachelors Degree in Finance at Stetson University, Deland,
Florida. He is a consultant to private investors, proposing and facilitating real estate and
businesses investment opportunities in healthcare and other industries. Over the years, Andrew
has consulted on many levels (operations, structure, planning, finance, marketing and
distribution) for companies including but not limited to Stonebridge Pharmaceutical, Gull
Environmental Systems, Altitude Organic Medicine (medical marijuana cultivation &
dispensary), Locman Watches, E. Lee Martin Inc. (Estate Jewelry wholesaler) and Charter
Logic.
Andrew has a strong interest and belief in the licensed and regulated medical marijuana industry
and is an integral part of the team pursuing BATC’s Alternative Treatment Center permit. He
possesses significant knowledge and research experience in the industry and has established an
ongoing dialogue and relationships with patients and potential patients, physicians and other care
providers, owners of dispensaries in other states, advocates and organizations in support of the
medical marijuana industry including, but not limited to: American Academy of Cannabinoid
Medicine (AACM), Full Spectrum Labs (FSL)- Robert Winnicki & Associates, Legislators and
policy-makers on the state and federal level, Leading Medical Marijuana cultivators in the
industry across the country, Authors/sponsors of medical marijuana draft legislation and various
directors, Law Enforcement Against Prohibition (LEAP), Coalition for Medical Marijuana - New
Jersey (CMMNJ) and various directors from Americans for Safe Access (ASA).
Andrew attended the 6th Annual Cannabis Convention hosted in Rhode Island and continues to
attend major industry conferences and conventions to keep abreast of key legislative reforms and
innovations in the industry. He has worked at Altitude Organic Medicine's cultivation site in
Denver, Colorado and has also consulted with operators of numerous other cultivation
companies and dispensaries. Andrew has spent countless hours auditing dispensaries in other
states to observe firsthand the diverse spectrum of business practices. His in-depth knowledge of
the medical marijuana industry combined with his business experience qualifies him to be an
effective consultant for BATC.
Ashif Jiwa possesses a very broad range of business experience and will act as a consultant to
Breakwater Alternative Treatment Center.

2. Rimol Greenhouses Systems
Website: www.rimolgreenhouses.com
BATC has been developed their greenhouse plans with the help of John Wells from Rimol
Greenhouses. Together with his expert knowledge in greenhouse design planning, horticulture
and having worked on sophisticated medical marijuana greenhouse designs, Mr. Wells has been a
great asset to BATC’s greenhouse design team to develop State-of-the-Art greenhouses.
3. Sheldon Gross Realty, Inc.

BATC secured the services of Glenn Jaffe of Sheldon Gross Realty, a New Jersey based Real
Estate Brokerage Company to assist in finding a dispensary location. Mr. Jaffe has identified over
five dispensary locations with approximately 2,000 square feet in prime office/medical buildings
and will work to secure the lease for the dispensary facility. After reviewing our business plan
with the medical office owners Glen has received great feedback. Some owners have even written
letters of approval to operate such a facility in their medical office buildings and others are very
interested in continuing discussions.
4. ADT
BATC has been developed both of their security plans with the help of ADT’s professionals.
They have worked closely with the local experts who specialties include has a vast knowledge in
retail pharmaceutical security and safety measures. The team has worked on projects such as
CVS, Walgreens, etc. retail pharmacies. When deciding on what division to work with
concerning the cultivation site BATC was directed to the Biochemical’s Division to develop a
security and safety measures for such a site. Working with experts responsible for high tech and
very secure industry security has produced the approach to the cultivation site that sets the bar.
5. Joan E. Zaleski (CFP)

BATC has secured the services of a certified financial planner to assist in analyzing our financial
status, identifying opportunities for greater efficiency, developing, coordinating and
implementing cost-effective strategies and monitoring our progress in meeting our business and
financial goals.
6. Steven Mueller
Mr. Mueller has established himself as a highly respected entrepreneur and expert in the Medical
Marijuana manufacturing and dispensary industry. His company, Altitude Organic Medicine,
owns and operates cultivation and dispensary facilities in Colorado. Steve is a consultant to
BATC in the areas of operations and employee training/management.
8. Certified Information Systems Security Professional (CISSP)

Due to restrictions related to his current employment, this individual is unable to participate as a
formal member of BHCC at this time.
This individual is currently employed by Fidelity Investments, one of the global leaders in the
financial services industry. He has been employed by Fidelity for 16 years, the last 12 of which

have been in various roles within information technology. From 2005 to the present he has been
supporting information security programs. In that capacity, he has been tasked with multiple
responsibilities that are core to the operation of a medical marijuana facility.
He has managed awareness and training on corporate policies on such topics as IT controls,
handling of customer information, use of company systems and devices, and corporate ethics.
He has also managing vendor relationships. This has included such work as reviewing contracts
in conjunction with Fidelity’s legal department to guarantee that these agreements provide them
with the ability to audit 3rd party facilities and technology infrastructure. The execution of these
3rd party reviews has provided him with experience that translates directly to the requirements of
running a compassion center. He must be familiar with physical and IT security controls for data
centers containing information on trillions of dollars in assets. This comprises such diverse
subjects as fence height, surveillance camera spacing, biometric access controls, climate control
systems, utilities management, network security, hiring practices, background checks, internal
policies, internal training programs, employee oversight programs, information technology
infrastructure and development processes, and too many more to list here.
In 2008, he became a Certified Information Systems Security Professional (CISSP), the gold
standard certification for information security professionals. The CISSP is formally approved by
the US Department of Defense for both their Information Assurance Technical and Managerial
(IAT, IAM) categories. It has also been adopted as a baseline for the US National Security
Agency's Information Systems Security Engineer Program (ISSEP).
7. Accountant
BATC has secured the services of a Certified Public Accountant to advise the company on fiscal
matters, maintain the financial books of the business and prepare tax returns and related
documents.
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.
Ownership Breakdown
There are no other interested parties except those set forth in this application. Richard S.
Lefkowitz, ESQ is the CEO owning 50% and H. Alexander Zaleski, ESQ is the COO owning
50% of Breakwater Alternative Treatment Center Corp. that presently does not own any land or
buildings.
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.
The cover sheet has been signed by Richard S. Lefkowitz, the Chief Executive Officer (CEO)
and has been provided on the first page of this application.

Criterion 2: Submission of Required ATC Operational Information
[TOTAL WEIGHTED REQUIREMENT UP TO 80 POINTS]
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.
[WEIGHTED REQUIREMENT up to 40 points]
PLEASE NOTE: ALL OF “APPENDIX G” INCLUDED BELOW IN PAGES 65-143 MUST

BE READ. PLEASE REFER TO “APPENDIX G” FOR ALL ANSWERS TO CRITERION 2,
MEASURE 1. THE FOLLOWING IS PRESENTED AS A GUIDE AND IS NOT LIMITED TO
THE STATED SECTION FOR EACH. “APPENDIX G” HAS FULLY ANSWERED THE
BELOW MINIMUM REQUIREMENTS AND IN SOME CASES MULTIPLE SECTIONS
COMPLETE EACH ANSWER.
8:64-9.1 Alternative treatment centers policies, procedures and records.
(a) Each alternative treatment center shall develop, implement and maintain on the premises an
operations manual that addresses, at a minimum, the following:
1. Procedures for the oversight of the alternative treatment center;
Section 8
2. Procedures for safely growing and dispensing medicinal marijuana:
Section 9, 10, 11, 13, & 15
3. Procedures to ensure accurate recordkeeping, including inventory protocols to ensure that
quantities cultivated do not suggest redistribution;
Section 9, 10, 11, 13 & 14
4. Employee security policies;
Section 13.4
5. Safety and security procedures, including a disaster plan with procedures to be followed
in case of fire or other emergencies;
Section 13
6. Personal safety and crime prevention techniques;
Section 3.15, 3.18, 13 & 13.8 (in particular)
7. The alternative treatment center’s alcohol, smoke and drug-free workplace policies; and
Section 4.6, 12.7 & 12.8
8. A description of the ATC’s:
i. Hours of operation and after hour contact information;
Section 8.1
ii. Fee schedule and availability of sliding fee scales based on income;
Section 9.7

iii. Expectations of onsite personnel in maintaining confidentiality and privacy of the
operations and clients of the ATC;
Section 9.6
iv. Criteria for involuntary disenrollment from the ATC’s list of qualifying patients
pursuant to unacceptable behavior and appeal process; and
Section 9.8
v. Registered qualifying patient’s assumption of risk in complying with ATC
registration policies.
Section 9.8
(b) The permit holder shall ensure that the operating manual of the alternative treatment center is
available for inspection by the Department, upon request.
Section 1, Introduction
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:
[WEIGHTED REQUIREMENT up to up to 35 points]
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.
II. The applicant shall provide a copy of its proposed policy regarding charity care/servicing
indigent patients.
III. The applicant shall provide a copy of its proposed policy related to disposal of returned
or unusable marijuana.
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.
PLEASE SEE THE “BUSINESS PLAN” SECTION WITH OF THIS APPLICATION.
Measure 3: The applicant shall document its experience running a not-for-profit organization
or other business(es).
[WEIGHTED REQUIREMENT up to 5 Points]

The founder and CEO of Good Tree Farm of New Egypt, LLC, is Dr. Hisham Moharram. Prior
to establishing the farm, Dr. Moharram was engaged in research in the area of Plant Natural

Products, and medicinal plants in particular. Dr. Moharram’s formal education is summarized in
the attached resume. The business concept of the farm has among its cornerstones the following
concepts; producing food locally, organically and sustainably (based on food security being a
critical component of national security), retailing at affordable prices (to widen accessibility of
fresh and wholesome food to broader segments of society, especially seniors on fixed incomes),
making fuller use of the value potential of plants by utilizing value-added processing (functional
foods), strengthening local economies (by hiring locally and spending and purchasing locally),
and facilitating employment opportunities for local residents willing to work hard and uphold
‘best production practices’ (to guarantee food safety for all our customers). We also facilitate
access to our farm fresh food for the poor and needy via our business focused ‘charitable
sponsorship’ program.
Additional information can be found on our website, www.goodtreefarms.com
2. Richard S. Lefkowitz, ESQ

Richard Lefkowitz is an attorney and experienced entrepreneur. Mr. Lefkowitz received a law
degree from Rutgers University School of Law-Camden. Richard has operated his law practice
“Lefkowitz & Edelstein” for the past 20 years with offices throughout the United States. Mr.
Lefkowitz specializes in transactional and contract law and maintains a diverse client base.
Mr. Lefkowitz was also a founding member of Stonebridge Pharmacy Corp. an institutional
pharmacy providing prescription pharmaceuticals, including controlled substances, to thousands
of patients in nursing homes and long term care facilities throughout the Northeastern United
States. Under Mr. Lefkowitz’s guidance, this industrial pharmacy grew from a fledgling
business with a hand full of employees into a large supplier of prescription medication with
over 80 employees and $10 million in annual revenue. Always aware of the needs of others, Mr.
Lefkowitz was instrumental in installing a program for patients with financial difficulties
establishing a company policy providing either free and discounted pharmaceuticals to certain
patients, who lacked the financial ability to pay.
Additionally, Mr. Lefkowitz continues to be active in numerous philanthropic endeavors.
Recently, he has served on the board of the Chemotherapy Foundation. In the past, he has
played an active role in charitable organizations such as “Heather on Earth”, the United Jewish
Appeal, the Make a Wish Foundation, the Ryan White Foundation.
With a broad base of hands-on business experience and a working knowledge of the law, Mr.
Lefkowitz contribution to BATC is invaluable.
3. H. Alexander Zaleski, ESQ. (COO)

Specializing in Operations & Medical Transport/Delivery
H. Alexander Zaleski (Alex) is a 1969 graduate of Fordham College, School of Business

Administration in New York City and Suffolk University School of Law in Boston,
Massachusetts. He was admitted to the Bar in 1975.
In 1972 he started a construction business specializing in build to suit single-family home
construction and renovation, including luxury homes. As an adjunct to this business he also
began acquiring vacant parcels to facilitate the home construction business. Eventually, his

business expanded into the Caribbean. In 2002 he was introduced to the Arxx insulated concrete
form construction technique and has employed this construction method to build reinforced
concrete structures. He has also constructed non-Arxx, concrete only structures. As the owner of
this business he has at all times personally directed all aspects of the business. At the same time
he began the construction business be began acquiring rental homes and has directed all aspects
of that business as well. Finally, he has owned and managed commercial rental property with
insurance companies and retail computer stores as tenants.
In 1987 he co-founded Gull Environmental Systems, a medical and hazardous waste
transportation company. The company was licensed by The State of New York (Department of
Environmental Conservation) and operated in Nassau and Suffolk counties. The company
serviced hospitals, doctors, dentists, dermatologists, podiatrists, veterinary clinics, chiropractors,
sports centers and nursing homes in a region with a population of 2.8 million people. At various
times, the waste was transported by locked cargo trucks to Pennsylvania, New York City and
Connecticut for disposal. When not in use the trucks remained locked in a secure parking
facility. In more than 20 years of operation, the company was never cited for any violations of
the strict rules and regulations imposed on medical and hazardous waste transporters.
1. Experience transporting hazardous chemicals, medical waste and expired pharmaceutical
drugs has prepared BATC for the proper distribution of medical marijuana.
The transportation of hazardous chemicals and medical waste requires detailed
documentation and constant supervision. The company prepared transportation manifests for
the customer (generator) documenting the exact nature and amount of the materials received
for disposal. A copy was given to the generator at the time of the pickup. Gull Environmental
Systems (the transporter) retained a copy, as did the disposal facility. A final copy was
mailed back to the generator by the disposal facility to certify the proper receipt and disposal
of the material. This demonstrates familiarity with strict record keeping practices as well as
experience in developing detailed procedures for transporting controlled materials, which
BATC will implement in its business practices in operating a Alternative Treatment Center
and grow facility.
2. Management of medical and hazardous waste pickups and disposal.

Gull operated as an on-demand (customer call in) and regularly scheduled pickup and
disposal services company. This business model accommodated both customers with
sporadic needs and those that required routine service on a defined schedule. Adapting to
customer needs is an important aspect of operating a medical marijuana dispensary as well.
We will design the capacity of the grow facility to provide for patients that visit our
Alternative Treatment Centers on a regular basis as well as for those whose medical
marijuana needs are more sporadic. Over time we will be able to gauge the amount of
Medical Marijuana to have on hand to adequately provide for all BATC patients and no more
than that amount. We will strive to have the least amount of product at our dispensary
location as possible in order to maximize product control and minimize security issues.
3. Hiring capable employees

Gull’s hiring process focused on recruiting retired state troopers whenever possible to serve
as our transportation staff. There were two major factors behind this decision. First, state
troopers are very familiar with paperwork and the necessity of clarity and accuracy in record
keeping. Also, due to their familiarity with shift work we were able to provide service 24

hours a day as the need arose. Alex Zaleski’s employment by the Suffolk County District
Attorney (New York) and several New York State Supreme Court Justices also provided him
with an opportunity to work very closely with state troopers. Their professionalism and
trustworthiness make them excellent employees for businesses dealing with controlled or
regulated materials that require secure transport security and accountability. Breakwater
Alternative Treatment Center will recruit and hire its drivers and other employees from a
pool of retired New Jersey State Troopers. By hiring retired state troopers BATC will send a
clear message to other employees and the public at large that we take our security measures
and compliance with New Jersey state laws seriously. We will perform (utilizing an
independent outside agency) full and exhaustive background checks. All employees hired by
Breakwater Alternative Treatment Center must pass drug testing administered by an
independent third party provider. The third party provider hired by us will subject all workers
to employment and credit history scrutiny. Only individuals with a superior employment and
credit history record will be considered for employment. Hiring retired law enforcement
officers assures us that each employee has already undergone a thorough background check.
We value our employees and consider them to be long-term assets. We will compensate our
employees commensurate with their professionalism to insure that they remain loyal and
highly satisfied members of our team.
4. Computer systems and business software experience

Computers were utilized in all phases of the construction business, including building plan
design, property management business and the land acquisition business. Gull utilized
computers and business software systems in all aspects of its hazardous waste transportation
business. This included the preparation of manifests, annual reports to the state, billing,
inventory control, invoice payments, receipts, bank deposits and preparation of reports for
the accountant, among other documents. BATC has used this familiarity and experience to
assess and select the appropriate computing solutions and business management software for
its business operations regarding the Alternative Treatment Center and grow facility.
5. Security

Criterion 3: Community Input -Describe the ATC planning process and involvement of
community stakeholders in detail. Describe remaining steps if any to receive necessary
approval for site location or operations.
[TOTAL WEIGHTED REQUIREMENTS up to 30 Points]
Measure 1: Input from the city(s) or town(s) where the applicant’s ATC would be located.
The Breakwater strategic plan was such that only sites that met all zoning ordinances would be
considered. That would include distance to schools, agricultural operations, medical clinics and
such. As most Township ordinances do not specifically address the production of medical

marijuana, detailed follow-up meetings with elected officials, zoning officers and the police will
be necessary to garner their input into successfully rolling out the operation.
Cultivation Site – New Egypt has a deep-rooted rural farming culture that is supported by their
long-standing mayor & assemblyman (Ron Dancer). We have introduced the concept of organic
cultivation of medical marijuana to his personal assistant (Trudy) where a follow-up meeting is
pending. The owner of the cultivation site (Hisham Moharram) has an excellent rapport with the
Mayor and is confident that the project will be supported.
Dispensary (ATC) – During a recent teleconference with the Mayor of Manalapan, Andrew
Lucas, concerning locating the dispensary in Manalapan, Mr. Lucas had no objection to the
project and thanked us for the heads up on the application. BATC has also spoken with one of
the committeemen who indicated that she was fully supportive of the idea. We also have pending
teleconferences or a meeting scheduled with another committeeman who is the retired state
police officer to discuss our security measures for the project. BATC next step is to meet with
the zoning officer of Manalapan for a review meeting in the next week. At this meeting we’ll
determine if the proposed use is conforming to zoning laws or if variances need to be obtained
for such a use.
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.
Due to the nature of the medical marijuana product, we anticipate numerous meetings will be
held with the general public. A casual Town Hall format will be used where all residents within
200 feet of the selected site will be contacted as well as the general public and surrounding towns
via public notices. This Town Hall meeting schedule will commence after award of the
operator’s license and with the support and feedback of the township. BATC felt this type of
strategy enabled the Townships to be a part of the process and offer their input. These Town Hall
meetings (there will be several) will be educational in nature introducing the residents to the
concept of medical marijuana, the security measures that have been slated for the project and the
types of patients that will be treated (at a minimum). There will most likely be feedback from the
public, which will be documented and addressed accordingly to satisfy their concerns and make
for a well-received operation once the Dispensary opens.

Criterion 4: Dispensary specific considerations
[TOTAL WEIGHTED REQUIREMENT up to 90 points]
PLEASE NOTE: “APPENDIX G: OPERATIONS MANUAL” (INCLUDED BELOW IN

PAGES 65-143) HAS BEEN REFERED TO FOR CRITERION 4. PLEASE REFER TO
“APPENDIX G” FOR SPECIFIC SECTIONS WHICH HELP TO FULLY ANSWER ALL
MEASURES FOR CRITERION 4.
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].

PLEASE REFER TO SECTION 9, 10, 11, 13, & 14 OF “APPENDIX G: OPERATIONS
MANUAL” TO FULLY ANSWER MEASURE 1.
Record Keeping and Security

BATC will fully comply with healthcare patient record privacy standards by never releasing any
sensitive patient data (SPD) that could lead to the identification of an individual patient to an
entity unless it is required by law (i.e. State Department of Health audit), or has received prior
approval from the patient (family member, physician, etc.).
BATC believes one of the biggest deficiencies in the industry is a lack of relevant,
comprehensive information about the actual operation of a Medical Marijuana business. BATC
intends to address this deficiency by integrating all aspects of business operations under a single,
user-friendly computer management system. BATC has researched a number of companies in the
industry that have designed software systems exclusively for the medical marijuana industry and
found only one that has a reliable and technologically forward-thinking HIPAA compliant POS
(Point Of Sale) system that meets our high standards. BATC believes this system provides
requisite tools necessary to control security issues, employee records and the confidentiality
requirements of patient records the business demands.
BATC will provide a unified and biometrically secure HIPAA (Federal Health Insurance
Portability and Accountability Act of 1996) compliant registry of Medical Marijuana patients.
Patients will enroll at BATC’s Compassion Center after receiving their approved Medical
Marijuana Patient application from the New Jersey Department of Health. BATC will comply
with the confidentiality record keeping requirements for health care information under New
Jersey law. BATC will encourage its patients to voluntarily sign up to participate in New
Jersey’s Statewide Health Information Exchange Program.
BATC will follow international standards-based best practices in the securing of sensitive patient
data (SPD). The BATC network will utilize a layered defense to protect SPD. SPD is defined as
those data elements protected under HIPAA, PCI, and state and federal privacy laws.
Information systems containing SPD will be physically and logically segregated from POS
systems and BATC web site infrastructure. Internal and external firewalls and a DMZ will
protect the internal network from external attacks against the web site. Access to data will be
managed through the use of job roles. These job roles define specific access privileges for each
position within the BATC organization based upon the requirements of the job function. For
example, staff supporting POS activity will have access to billing data, patient purchase history,
and medicine inventory levels but will be unable to view aggregate sales figures or production
facilities data. Board of director members will have access to aggregated financial information
and management reports on the operation of the dispensary and production facilities but will not
be allowed to view individual patient lists or have visibility into SPD. Logical access to SPD on
the BATC managed systems will also be limited to those employees who require this information
to complete their job function. All access (both physical and systems) to SPD will be logged and
monitored on a regular schedule. Access control lists mapped to job role definitions combined
with real-time alerts will ensure immediate notification of management and security should there
be an unauthorized attempt to access SPD.
BATC will have a compliance/risk officer responsible for maintaining the job role definitions,
provisioning access based upon the job roles, providing oversight of monitoring reports, and
managing employee compliance with company policies.

The compliance/risk officer will also be responsible for creating and maintaining all BATC
policies on employee behavior, workplace environment, BATC ethics, patient interactions,
technology controls, Business Contingency Planning (BCP), and Disaster Recovery (DR)
procedures. Awareness and training will be developed for all internal employees to educate
them on their roles and responsibilities. These programs will cover such topics as electronic
communications and usage of BATC equipment, workplace environment behavior, information
protection, and patient interactions. The BATC focus on the patient will be a common thread
linking all training programs.
The BCP and DR procedures will play a key role in BATC operations as they will allow for the
continued service of the patient base should a major business challenge occur (natural disaster,
pandemic, power outage, etc.). BCP and DR procedures will be tested annually to guarantee that
BATC staff understand their roles. This also provides an opportunity to validate that the plan
steps are still appropriate.
The hardware supporting BATC operations will remain in a locked office with access limited to
BATC management whose job role requires this privilege. Video surveillance will be put in
place for the office entrance, with the recordings being handled in the same manner as those
described in the physical security component of this application.
A local area network will be established to connect the POS system to the web site. This will
allow patients and employees the ability to view custom information related to their BATC
interactions. These systems will contain BATC patient identifiers for authentication purposes
and general data on the patient’s prior interactions, but will not contain those elements
designated as sensitive patient data. Patients can consent to exposing more of their personal
information to BATC staff if they so desire by completing and signing a request form. This will
allow BATC to provide customized interactions and enhanced support to patients based upon
their personal preferences.
Patient Management
The objective of BATC’s patient management module is to provide fast and accurate patient
check-in and to track key indicators and paperwork required for legal operation.
Features of this module include:
a. Patient record to include a photo of the patient and/or scan of their driver's license.
b. Driver's/NJ medical marijuana patient license swipe to pull up patient record.
c. Support for bar-coded membership cards (scanning the bar code will bring up the patient
record).
d. Upload of scanned images of patient paperwork and ID (Identification card) and NJ
Medical Marijuana card attached to the patient record.
e. Purchase history will be tied to the patient record and accessible with one click.
f. Tracking of key information such as NJ Medical Marijuana card expiration date or
incomplete paperwork and visually warning staff of particular patient
concerns/issues/rewards as soon as patient record is pulled up.

g. Once checked in, the front desk can send the patient's record to the pharmacy technician’s
computer, eliminating any need for the pharmacy technician to re-verify the ID card.
h. In addition to the information already discussed BATC will also store in its database the
patient’s phone numbers, email and mailing address, physician name and phone number,
medical marijuana card number, birth date, designated caregiver status, diagnosis
information and symptoms, preferred contact method, permission to text, phone, or e-
mail, notes regarding effects and preferred cultivars, maximum amount allowed for
dispensing on a given day, and status fields to indicate if all paperwork is complete and in
the system.
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. [WEIGHTED REQUIREMENT up to 20 Points]
PLEASE REFER TO SECTION 15 OF “APPENDIX G: OPERATIONS MANUAL” TO

FULLY ANSWER MEASURE 2.
BATC will provide each registered qualifying patient and their registered primary caregivers
with a variety of source material regarding the various methods of ingestion (vaporizer, smoking,
eating, tincture, tea and marijuana compress) of medical marijuana accompanied by validated
research studies on the health effects of each. These materials may include a take home DVD,
printed information and brochures as well as direct training and consultation from BATC staff.
The DVD will also be available for viewing on site. BATC will compile a list of outside
individuals and entities that will provide similar instruction and will offer counseling on these
topics by psychologists if the patient requests it during our registration questioning. All opinions
regarding health side effects of ingesting medical marijuana will be presented so that the patient
can make an informed decision. A comprehensive listing of web sites covering these topics will
be made available to patients and caregivers alike.
Each patient will be presented with a BATC informational brochure, which will detail the
various ingestion options, safe smoking techniques and all potential side effects for the medical
cannabis products available at the Alternative Treatment Center. In addition to the brochure our
Alternative Treatment Center employees will provide all requested information in detail and
answer any other questions the patient or caregiver may have. We will also work with the
Department of Health and Senior Services to provide a list of Frequently Asked Questions
concerning the Medical Marijuana Program.
Each new registered qualifying patient who visits our Alternative Treatment Center will be
provided with the Department of Health and Senior Services’ "Frequently Asked Questions"
document, which explains the limitations on the right to use marijuana in the State of New
Jersey.
Computer stations will be available for patient and caregiver use to conduct their own online
research. BATC will provide a list of suggested websites and online videos to assist in their
initial research. Key search topics, such as, marijuana side effects, marijuana long term side

effects, marijuana overdose, marijuana effects, marijuana addiction, marijuana facts, marijuana
long term effects and marijuana physical side effects will be suggested as starting points for
obtaining additional information. These search topics will be updated on a regular basis and any
important new research results will be immediately provided to patients and caregivers.
Breakwater Alternative Treatment Center will take pride in the care provided to patients.
Educating on the safest methods of ingestion is a key component in making a patient comfortable
and providing the most effective means of obtaining the optimum results for pain management
and the treatment of other conditions. BATC will offer multiple methods and product options for
the ingestion of medical cannabis.
Please see the following pages “Using Your Medicine”

Bracketed numbers (ex. [1]) refers to “References” listed at the end of this section
Using Your Medicine (Educational Materials)
The federal government classifies cannabis as a schedule 1 drug; a classification that implies
that cannabis has no legitimate medical use. This classification should be changed because
cannabis is recommended by a multitude of physicians for the treatment of many medical
conditions. Furthermore THC (the primary active compound in cannabis) is FDA approved and
is called dronabinol [6]. Dronabinol is marketed using the trade name Marinol [6].
There are many methods of using cannabis for the treatment of medical conditions. The
following information is intended to inform medical cannabis patients about the various options
available to them.
Please note: The only form options that BATC offers currently are flower/bud form, lozenges
and topical formulations. We understand the present Laws of the Medical Marijuana Program
are restricted to three forms, the following is provided for educational purposes only.
Smoking Cannabis
Smoking is popular among patients for several reasons:
1. Rapid onset: Smoking delivers active compounds quickly into the bloodstream and to
receptor sites via the lungs [4].
2. Simplicity: Compared to other dosage methods, smoking cannabis is simple, requiring
very little preparation time. Before smoking cannabis, the patient must simply separate
the buds into individual flowers and remove any stems [2]. Doing so ensures an even
burn and less need for flame application (less unwanted fumes=better-tasting, more
healthful smoke). To make this easy, use a handheld herb grinder or a pair of scissors and
a shot glass [2].
3. Easy dosage determination: smoked cannabis is effective almost immediately, allowing
the user to titrate the dose one puff at a time. This allows the user to get just the right
dose by gradually increasing the dose until effective [7].
Methods of smoking
a. Joint: (a.k.a. “marijuana cigarette” or “reefer”) Convenience of joints is key, as joints burn
for multiple puffs worth of cannabis after only being lit once and are easily transportable [2].
Joints also taste pleasant to most patients, and they don’t require breakable, expensive, or
conspicuous equipment [2]. A huge plus is efficient delivery of cannabinoids [3]. This is
perhaps due to a joint’s lack of a filter or long piping before the mouth, to which sticky
cannabinoids adhere easily, reducing the amount of medicine that actually reaches the
patient’s body [3]. It is a skill to roll a good joint, however, novices uninterested in learning

how to do so should buy a joint-rolling machine or pre-rolled joints [2]. Before rolling a
joint, the patient should break the bud(s) into small, uniform pieces about the size of the
individual bud flowers or slightly smaller [2]. Stems should be removed from the flowers to
avoid foul, acrid smoke and possible holes poked in the rolling paper [2]. To roll a joint,
practice, practice, practice...or ask an expert at BATC for help. Some joint smokers prefer
unbleached rolling papers, hemp rolling papers, or clear, cellulose-based papers, which may
taste better and contain fewer impurities than traditional, bleached-white rolling papers.
**Patients should note that, while still remarkably safe, joints are one of the less-healthful
methods of dosage because they burn paper and glue along with cannabis, exposing users to
impurities not presented by some other alternative dosage methods [2]. Another downside is
waste: Some smoke is inevitably lost between inhalations, and there is usually leftover
cannabis in the “roach”, or the small, undesirable leftover part of a burned joint [2].
However, joints’ efficient delivery of cannabinoids—relative to other smoking methods—
may compensate for such waste [3].
b. Pipes: Pipes are an easy way to smoke cannabis, and can be broken down into two basic
categories: 1) Dry “Hand” pipes, and 2) Waterpipes [2].
c. Hand Pipes: These come in a (possibly overwhelming) variety of shapes, sizes, and materials,
but the basic mechanics are universal. To smoke a cannabis pipe:
1. Pack prepared buds into the bowl
2. Hold a flame directly over the medicine while simultaneously inhaling through the
mouthpiece [2].
3. Waterpipes: Mechanically, these are nearly identical to hand pipes, but use a chamber of
water to filter and cool the smoke before it is inhaled [2]. There are two main types:
bongs and bubblers, classified by either a large or a small filling chamber, respectively, in
which the smoke collects. The main proven advantage over dry pipes or joints is comfort;
smoke is cooled and free of hot ashes and particles [3]. *BEWARE: large “hits” of smoke
will cause light-headedness and an inclination to blacking out, and waterpipes make
accidentally taking a bigger-than-expected hit a possibility. Waterpipes are supposed by
many smokers to be a safer alternative to dry pipes or joints because the water filters tar
out of the smoke [2]. Unfortunately, as one test points out, water filtration removes THC
and other desirable active compounds more so than tar [3]. This means “in order to obtain
the same effective dose of THC, a smoker would end up taking in at least 30% more tars
from a waterpipe than from an unfiltered joint” [2]. However, water filtration may
remove water-soluble toxic gases such as carbon monoxide, which is linked to heart
disease, and aldehydes, which promote cancer [3], so more research is required to
determine whether waterpipes are beneficial or counterproductive [2].
**A problem with all pipe smoking is that you must suck on one side of the pipe, pulling air
and, along with the flame—lighter fluid fumes—over the cannabis, through the pipe, and into
your lungs to light the cannabis on fire. Grind your bud to minimize the need for a starting
flame. To avoid lighter fluid fumes, some patients light their pipe with an organic, beeswax-
covered hemp wick, or a magnifying glass under bright sunlight.
First time smoking? Use discretion, BATC's cannabis is highly potent! Don’t be alarmed though;
this is good news for the patient because it allows him or her to burn less plant material to get an
effective dose than with lower-potency cannabis [3,2]. This also means that, if the patient is new
to smoking, it may only take one substantial inhalation to get an effective dose. Start with a small
hit. Inhale deeply, exhale immediately (it is a myth that holding in the smoke will be more
effective), and WAIT for several minutes to feel the effects of the hit before taking the next so as
to minimize the dose [4].

In summary, if a patient wants the quickest relief possible (easy preparation, plus onset in
seconds [4]), and understands and accepts the possible risks inherent to smoking his or her
medicine, a pipe is the utensil of choice.
Our growing process and drying process are designed to prevent problems associated with fungi
that would affect the safety of our medicine. Buds will be inspected upon trimming and after
drying for the presence of mold, and samples from every batch will be sent to a laboratory for
testing.
Vaporization
Breakwater Alternative Treatment Center highly recommends this method to all patients. Good
vaporizers allow patients quick-onset relief and oral satisfaction similar to smoking without the
health risks associated with smoke [1]. They do this by delicately heating the cannabis to the
point that THC and other therapeutic substances change physical form, becoming gaseous [1].
The gas, or vapor, is then inhaled like smoke. The process leaves behind dry, slightly browned
buds that, rather than having gone up in smoke, simply lack richness in medicinal compounds
[2]. Studies show vaporizers significantly reduce carcinogens (cancer-causing agents), carbon
monoxide (linked to cardiovascular disease), and tar [1,2,3].
Lozenges
Lozenges are made in several ways. One way is to use edible gum such as Tragacanth or Acacia
to make a basic mucilage. Then we mix in a dried form of medicinal marijuana butter solution,
milk solution, oil solution or one of the three tincture solutions into the mucilage to make a paste
[2,4,8]. When the paste has cooled slightly, we cut the paste into various size lozenges depending
on dose. When it dries it is ready to be packaged and then stored in an airtight container. We will
offer sugar-free or unrefined brown sugar forms. [8] They are absorbed through the mucus
membranes of the mouth, and take effect in five to ten minutes [2,4].
Tinctures
Cannabis can be administered orally using cannabis tinctures [2]. Cannabis tinctures have a long
history of medical use in the United States [5]. As early as the 1850's American physicians
prescribed tincture of cannabis with successful results [5]. There are three types of cannabis
tinctures, made using alcohol and/or glycerine as solvents [4]. All three of these solutions may be
taken under the tongue with an eyedropper [2]. They are absorbed through the mucus membranes
of the mouth, and take effect in five to ten minutes [2,4]. Tincture dosage varies greatly
depending on the concentration of cannabis in the tincture [4]. Glycerine tinctures have the
advantages of tasting sweeter than alcohol tinctures, and being well suited for those who do not
consume alcohol [4]. Alcohol tinctures have the advantage of usually being more concentrated
than glycerine tinctures, thus less needs to be used for the desired effect [4]. Glycerine/alcohol
tinctures combine the advantages and disadvantages of glycerine tinctures and alcohol tinctures
[4]. Shake glycerine/alcohol tinctures to counteract separation [4].
Oral Administration
Not just brownies: In theory, cannabis food can be anything that contains substantial butter, oil,
milk, or alcohol, because cannabinoids are oil and fat-soluble and thus dissolve in these
ingredients [2].

Eating food enriched with cannabis offers patients several advantages:
1. No risk of damage to respiratory system.
2. Longer-lasting relief (up to 10 hrs.) [4]
3. Can be made with leaf, which costs less than high-grade bud [2]
Eating cannabis-laden foods also has distinct disadvantages for some patients:
1. Slower onset of effects (15min-3hrs) [2]
2. Proper dosage is difficult to gauge; many variables at play [4]
3. Cooking THC makes it slightly more psychoactive [2]
Dosage
Cannabis can be administered using tinctures, ingestion, smoking, vaporizing, and by other
methods. The effect of each method and the rate of onset when using each method varies.
Smoking and vaporization provide the fastest onset of effects of any method of administering
cannabis [4]. Effects can be felt almost instantly [4]. Tinctures are slightly slower to take effect
than inhalation methods; they start to take effect in five minutes or less [2]. Eating cannabis
infused foods or capsules is the slowest method of medicating with cannabis but it provides
longer lasting effects than other methods [2]. The effects of ingested cannabis may take from 30
minutes to longer than an hour to be noticeable, and may maintain peak intensity for one to two
hours before gradually diminishing over several hours [2]. The effects imparted by eating
cannabis are also pharmacologically different from those produced by other intake methods,
because THC is converted to 11-hydroxyl-THC in the liver when cannabis is eaten [2].
When using any cannabis preparation start with a small quantity, wait the proper amount of time
for the effects to take place, and then take more if necessary [5]. Dosage determination is most
easily accomplished using inhalation and tincture methods [2]. It is more difficult to determine
ingestion dosage than inhalation or tincture dosage, because the onset of effects is much less
rapid with ingestion [2]. The amount of food and type of food in the digestive tract also play
roles in determining effective ingestion dosage, further complicating the task [4]. Whatever the
method of intake, a lethal overdose of cannabis cannot be achieved [5]. Overdosing on cannabis
may produce unpleasant feelings such as drowsiness or anxiety, but users experiencing such
feelings should stay calm and wait for the effects of cannabis to diminish [4]. Users who fear the
possibility of unpleasant feelings from an overdose may wish to avoid cannabis edibles, as eating
cannabis is the most likely intake method to cause an overdose [2].
Potency
All of the varieties that BATC will offer are high, medium and low potent*. This is a BATC
policy for several reasons. One reason is high potency will save caretakers money by allowing
them to use less medicine. Another reason is highly potent varieties are healthier for those who
choose to smoke their medicine, because less plant material must be smoked to get the same dose
of active compounds [2]. We will also only offer highly potent varieties, as this will aid in
simplifying the caretaker's task of choosing the right varieties for their individual needs. One last
reason for this policy is that it will help caretakers determine the appropriate dosage of each
variety.
*Each variety we offer is of different potency and has unique medicinal effects.
Tolerance

Heavy cannabis use will, over time, result in lowered sensitivity to the drug [2]. However, most
patients lose side effects over time, not medicinal efficacy [2]. To avoid gaining tolerance to
cannabis, patients should try different varieties of cannabis and different intake methods [2].
Addiction
Cannabis isn't physically addictive, however psychological dependence may occur [2]. This
means cannabis use may become habitual in some users [2]. When discontinuing cannabis use,
long-term heavy users may experience mild withdrawal symptoms including anxiety, difficulty
sleeping, and irritability [2].
References
[1] Armentano, P. (2009). Emerging clinical applications for cannabis and cannabinoids: a
review of the recent scientific literature 2000- 2009. Washington, DC: NORML Foundation.
[2] Gieringer, D., Rosenthal E., & Carter G. T. (2008) Marijuana medical handbook. Oakland,
CA: Quick America.
[3] Gieringer, Dale (2000). Marijuana water pipe and vaporizer study. Newsletter of the
Multidisciplinary Association for Psychedelic Studies, 6(3) Retrieved 6/19/2010,
from http://www.maps.org/news-letters/v06n3/06359mj1.html
[4] Lauve J., & Luttrell, H. (2010, Feb./Mar.) What is the right amount for me? Cannabis Health
News Magazine, 1, 2.
[5] Mikuriya, T. H. (Ed.). (2007) Marijuana: medical papers 1839-1972 (Vol. 1). Nevada
City, CA: Symposium Publishing.
[6] Joy, J. E. (1999) Marijuana and Medicine: Assessing the Science Base.
Washington, D.C.: National Academy Press.
[7] Earleywine, M. (2002) Understanding Marijuana: A New Look at the Scientific
Evidence. NY: Oxford University Press.
[8] Hoffman, David. (2002) The Complete Illustrated Guide to Holistic Herbal: A Safe and
Practical Guide to Making and Using Herbal Remedies. Element Books.
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.
PLEASE REFER TO SECTION 3.15, 3.18, 8, 9, 10, 11, 12, 13, & 15 OF “APPENDIX G:
OPERATIONS MANUAL” TO FULLY ANSWER MEASURE 3. ALSO AT THE END
OF THE ANSWER TO MEASURE 3 IS A FLOOR PLAN AND SCHEDULE OF
SECURITY DEVICES USED.
Security & Safety Measures for Shipping, Receipt, and Storage

Shipping/Transportation of Medical Marijuana

Patient Transportation Service
Although state law has no explicit provision for transportation services, they might be justified
on the grounds that many patients lack transportation and cannot grow for themselves. Subject to
authorization and guidance from the New Jersey Department of Health and Senior Services,
BATC is prepared to personally provide transportation to our dispensary to patients on a case-by-
case basis, as determined by need.
Receiving
1. All growing equipment and supplies will be shipped to a separate secure discrete delivery
location in order to maintain a high level of security at the cultivation site. We will maintain a
separate off-site storage and office facility where all invoices and products (seed companies,
nutrient suppliers, pest control supplies, growth medium suppliers and all production
material) will be received for later transport to the growing facility.
2. Pickup and delivery of the materials listed above will only be performed by authorized
BATC employees.
Theft and Inventory Controls

Patient Management
i. Patient record to include a photo of the patient and/or scan of their driver's license.
j. Driver's/NJ medical marijuana patient license swipe to pull up patient record.
k. Support for bar-coded membership cards (scanning the bar code will bring up the patient
record).
l. Upload of scanned images of patient paperwork and ID (Identification card) and NJ
m. Purchase history will be tied to the patient record and accessible with one click.
n. Tracking of key information such as NJ Medical Marijuana card expiration date or
o. Once checked in, the front desk can send the patient's record to the pharmacy technician’s
p. In addition to the information already discussed BATC will also store in its database the
the system.

Point of Sale System
The objective of the point of sale system is to provide timely and accurate information for
dispensary technicians to use to ensure appropriate dispensing and accuracy in inventory
tracking.
Features of this module will include:
a. Ability to print medicine labels and receipts at the time of sale, including our dispensary
information, disclaimer, medication details and patient information.
b. Create and apply discounts and specials with one click.
c. Each transaction is tied to inventory, giving BATC critical insight and precision tracking
of inventory.
d. Quickly add pharmacy technician notes to current or previous transactions to enable easy
tracking of patient symptoms and effectiveness of the medication.
e. Easy to navigate menu list of products with BATC's custom attributes displayed for easy
searching or sorting.
f. Ability to sell in grams, ounces and by piece.
g. Support for common POS hardware, including cash drawers, receipt and label printers,
bar code scanners, touch screen monitors, magnetic card swipes and biometric
capabilities (iris, finger and palm scanning).
Inventory Management
The key objective of the inventory module is to track our inventory precisely, down to the gram or
ounce and piece, and to allow for the unique inventory needs of dispensaries and the cultivation
process.
Features of this module will include:
a. Categories of inventory for bulk medical marijuana and associated products (i.e.
brownies) and hard goods (i.e. glassware).
b. Ability to easily set up specials, like 4-gram eighths that deduct medical marijuana from
inventory.
c. Simple conversion of inventory from bulk medical marijuana to a medical marijuana
product, such as cookies or marijuana cigarettes.
Tracking of both “weighed quantity” and “charged quantity”. If a weighed dose is a little
bit heavy, that amount is deducted from inventory and tracked so that inventory reports
remain accurate. Also, this information will be printed on the label so that patients know
exactly how much medicine they received and were charged for.
d. Tracking of both “weighed quantity” and “charged quantity”. If a weighed dose is a little
bit heavy, that amount is deducted from inventory and tracked so that inventory reports
remain accurate. Also, this information will be printed on the label so that patients know
exactly how much medicine they received and were charged for.
e. Ability to track MMJ product in grams and ounces - both for back-of-house tracking and
sales.

f. Ability to have custom attributes, like indica/sativa/blend. Ability to track a nearly
infinite number of variables and sort/search/display based on those variables.
g. Adding inventory items is quick and easy.
h. Generate bar codes and product labels on the fly for inventory items.
i. Easy inventory reports for a clear snapshot of products at any time.
j. Straightforward inventory adjustment screen and reports. This is restricted to a manager
level login for protection.
k. Patient tracking, including the ability to track purchases from patients by date, weight and
product, making compliance with New Jersey laws easy.
l. Tracking for fields such as name, description, cost, retail price, received date, expiration
date, image, attributes specific to the product (i.e. color, flavor, taste, smell and size for
hard goods for the MMJ), barcode, notes, and quality/condition.
Administration
The administrative functions of the web-based software program are designed to help the
dispensary manager understand and track every detail of the business operations.
Key administrative features and functions include:
a. Tracking - every entry and action has a virtual paper trail, detailing the time and date for
every transaction, as well as which staff member performed it.
b. User levels will provide you with the ability to limit access to different areas of the
system by individualizing each user's log in.
c. Our full array of reports covers sales, inventory, vendors, and patient transactions, among
others.
d. Sales tax reports are available with just a few clicks, making reporting quick, easy and
accurate.
e. Included data export to Excel for all reports.
f. Module to export our transactions to QuickBooks or similar.
g. Web-based solution - our data is stored remotely, encrypted and backed up nightly,
ensuring access from anywhere, anytime while, at the same time, complying with HIPAA
standards and requirements. This has the added benefit of keeping critical data safe from
fire, hardware theft, or mechanical and software failure.
Procedural Measures
Only authorized personnel will have access to the drying, trimming, storage (curing) area of the
cultivation facility and each area will have electronic access control points to alert the operating
manager when employees access specific areas of the facility.
Immediate Automatic Electronic Response
Response sets the performance standard for the development and exercising of emergency
response plans for security incidents at the facility. BATC will develop and exercise an
emergency plan to automatically respond to security incidents internally and with assistance of
local law enforcement and first responders.

BATC will maintain effective monitoring, communications, and warning systems to allow all of
our facilities to automatically notify internal personnel and local responders in a timely manner
about security incidents.
Personnel Background Check
The primary means of satisfying the personnel performance standards is through the
implementation of an appropriate background check program that BATC will implement.
a. Each employee or volunteer hired by BATC will go through a thorough background
check, intense screening and training program. BATC will model its employee hiring and
training procedures after those established by the retail pharmacy industry for its
pharmacy technicians and other employees who may come in contact with or have access
to controlled substances.
b. Any employee or contracted professional that works at or has knowledge of the location
and the security measures taken to protect the cultivation and dispensary site will be
required to sign a confidentiality agreement.
c. Only authorized personnel will be allowed to visit the cultivation site.
H. Alexander Zaleski has 40 years of experience with the design and construction of business
facilities and will handle the general contracting duties for the build-out of the site. He has
intimate knowledge of ICF (Insulated Concrete Form) construction techniques, which will be
used to construct the drying, curing and stockpiling building at the cultivation site. This
construction method uses a reinforced concrete (rebar installed horizontally and vertically) core
with insulating foam on each side. The R-value of these walls is approximately 50. However,
when a particular sub-contractor is necessary for the project, BATC will hire only bonded and
insured contractors with established business history and verifiable references. The actual
function of the grow site will not be disclosed to any sub-contractors. In the event of future
maintenance at the grow site, only sub-contractors who have undergone background checks will
be hired.
Employee Security:
All employees shall be provided with personal panic alarm buttons while working. Activation of
the personal panic button will automatically notify a private off-site central alarm company of a
current emergency. Closed circuit cameras together with remote controlled door locks will
control entry to the premises. All employees will be trained to manually activate the alarm
system in case of any emergency and to notify the appropriate public agency. BATC will keep
and maintain an accurate OSHA incident log to record any workplace accidents or injuries. All
employees will receive training in the areas of confidentiality, ethics, security and professional
conduct as part of their employment orientation process. The primary means of satisfying the
personnel surety performance standards is through the implementation of an appropriate and
complete background check program that BATC will implement.
a. Each employee or volunteer hired by BATC will go through a thorough background
check, intense screening and training program. BATC will model its employee hiring and
training procedures after those established by the retail pharmacy industry for its
pharmacy technicians and other employees who may come in contact with or have access
to controlled substances.

b. Any employee or contracted professional that works at or has knowledge of the location
and security measures utilized to protect the cultivation and dispensary site will sign a
confidentiality agreement.
c. Only authorized personnel will be allowed to visit the cultivation site.
Safety and Security:
Personal Safety and Crime Prevention:
Dispensary Security & Safety Measures

Dispensary Security Measures

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.
Transport Service Policy and Procedure

The transport driver will remain with the transport vehicle at all times when there is marijuana on
board.
A security guard will accompany all drivers.
All drivers must have a clean driving and criminal record.
Delivery Driver Checklist:
Track mileage using Breakwater Alternative Treatment Center’s mileage log
Medication must remain locked at all times in the truck safe
Driver must carry copies of Breakwater Alternative Treatment Center’s seller’s license
and business license in addition to delivery driver employee insurance information
Transport Driver will carry a portable Breakwater Alternative Treatment Center laptop on
which to record deliveries
Transport Driver will carry a portable Breakwater Alternative Treatment Center GPS
system for navigation purposes
Transport Drivers must obey all New Jersey state speed limits and traffic laws
Transport Drivers must not use any mind-altering substances while on deliveries, nor can
they begin deliveries if their sobriety is in question
Delivery Service Policy and Procedure

Breakwater shall transport only prepackaged usable marijuana from the cultivation site to the
dispensing site according to a delivery plan approved by the Department.
Procedures to follow:

All forms of medicinal marijuana will be placed in separate metal lockboxes for
transportation from the Storage room at the cultivation site
Flowers/buds are transported in tightly sealed mason jars (where the marijuana is
cured and stored in after the drying process) as described in packaging section of this
Lozenges are transported in their ready to sell packaging
Topical Formulations are transported in tightly sealed plastic containers
Breakwater will staff each transport vehicle with a delivery team consisting of at least two
registered ATC employees. At least one delivery team member (Security team member) will
remain with the vehicle at all times that the vehicle contains medicinal marijuana. Each delivery
team member will have access to a secure form of communication with the ATC, such as a
cellular telephone, at all times that the vehicle contains medicinal marijuana.
Each delivery team member will possess his or her ATC employee identification card at all times
and will produce it to Department staff or law enforcement officials upon demand. Each
transport vehicle will be equipped with a secure lockbox or locking cargo area, which will be
used for the sanitary and secure transport of medicinal marijuana. The driver/company will
maintain a current commercial automobile liability insurance policy on in the amount of one
million dollars per incident.
The vehicles used to transport medicinal marijuana will bear no markings that would either
identify or indicate that the vehicle is used to transport medicinal marijuana. Breakwater will
ensure that all transports are completed in a timely and efficient manner. The transport vehicle
will proceed from the cultivation site where the medicinal marijuana is loaded directly to the
treatment center where the medicinal marijuana is unloaded without intervening stops or delays.
Breakwater will report any vehicle accidents, diversions, losses, or other reportable events that
occur during transport to the permitting authority, forthwith.
Breakwater will maintain a record of each transport of medicinal marijuana in a transport
logbook which will record:
1. The date and time that the transport began and ended;
2. Track mileage using Breakwater Alternative Treatment Center’s mileage log
3. Medication must remain locked at all times in secure lockboxes.
4. The names of the ATC employees comprising the delivery team;
5. The weight of the medicinal marijuana transported;
6. The lot number of the medicinal marijuana, the name of the strain, whether it is high,
medium, or low potency; and
7. The signatures of the ATC employees comprising the delivery team.
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.
[WEIGHTED REQUIREMENT up to 10 points]
PLEASE REFER TO APPENDIX A-2 BY-LAWS SECTION TO FULLY ANSWER

MEASURE 5.
The members of Breakwater’s medical advisory board, none of whom will be employees,
officers or board members, will consist of at least three licensed health care professionals, at
least one of whom will be a physician, a patient registered with the ATC, and a business owner
from the region surrounding the treatment center location. As of now Breakwater’s Medical
Advisory Board consists of a pharmacist and a Registered Nurse (RN) from New Jersey:
The members of the medical advisory board will provide input to BATC on all aspects of its
business and will serve to keep the Treatment Center up-to-date on the latest research regarding
the benefits of medical marijuana in the treatment of debilitating medical conditions. The
medical advisory board will review and approve all free educational literature on medical
cannabis developed by BATC, and approve all reading materials provided, recommended, or
made available by BATC covering topics such as cannabinoids research, pain and stress
management and holistic approaches to health and wellness to assure that all information is
medically sound, fair and balanced. The medical advisory board will also help address specific
community issues that may arise, so as to assist Breakwater in developing and maintaining a
positive relationship with the community at large. Members of the Medical Advisory Board will
be required to meet on an “as needed” basis in preparation for the opening of the Breakwater
ATC and thereafter, will meet at least two times per calendar year.
The Medical Advisory Board shall endeavor to work closely with the New Jersey Department of
Health and Senior Services and other state designated medical authorities as point of contact to
provide oversight of current and evolving studies, reviews, analyses, and research into the
efficacy, procedures, knowledge base, and continuing education of medical practitioners and
resources within New Jersey for the benefit of the patients, medical personnel, and community
within the state.
As of now, Breakwater’s Medical Advisory Board consists of a pharmacist and a registered
nurse, licensed in the state of New Jersey. BATC desired to have a pharmacist, nurse and
physician on their medical advisory board and to draw from each of their unique backgrounds in
medicine and patient care. The pharmacist also possesses insight into federal and state
regulations that govern the distribution of controlled substances in a retail pharmacy environment
and the regulations that govern pharmaceutical industry. The pharmacist will play a key role in
the oversight of the patient education materials, and the nurse and pharmacist will help set the
standards for patient counseling and develop guidelines regarding the collection and monitoring
of patient response to treatment. With the patient’s permission this information could be sent to
the prescribing physician and/or become a source for a retrospective analysis of patient
outcomes. The physician selected to be on the Medical Advisory Board must currently treat
patients with conditions that qualify for medical marijuana under current law, such as an
oncologist, HIV/AIDS specialist, pain management specialist, or neurologist. Once the site for
BATC has been approved, a meeting will be set up to both educate the local businesses regarding
the mission of the ATC and to select a representative from the local business community to sit on
the Medical Advisory Board. BATC will encourage the development of a support group for the
registrants and their caregivers and will provide a place for the group to meet on BATC

premises. An active member of such a group would be an ideal individual to sit on the Medical
Advisory Board. The patient/support group member would be able to provide a collective
feedback from the patient community regarding their response to treatment and any issues they
might be encountering regarding acceptance of their treatment by their relative and friends.
1. Richard H. Klauber, ESQ.

1500 Allaire Avenue, Suite 101
Ocean, NJ 07712
DOB – 10/29/1958
Please see Appendix F for CV
2. Maureen Ivers
5 Estella Drive, Flemington, NJ 08822
DOB – 09/14/1955
3. Sue Lefkowitz, BSN, RN, C (Sue)

572 Clubhouse Drive
Middletown, NJ 07748
DOB – 2/12/1956
The members of the medical advisory board will meet at least twice a year with Breakwater’s
Medical Director to address specific community issues that may arise, medical marijuana
labeling concerns and Breakwater’s overall relationship with the community at large.
The advisory board will consist of a specialist in each condition qualifying for medical marijuana
under current law. Some members of the advisory board will possess expertise in the field of
New Jersey’s definition of “Debilitating Medical Condition”. Specific knowledge of medical
conditions such as seizure disorders, including epilepsy; intractable skeletal muscular spasticity;
glaucoma, severe or chronic pain, severe nausea or vomiting, cachexia or wasting syndrome will
be required. Additional areas of in depth knowledge will include a positive diagnosis for human
immunodeficiency virus, acquired immune deficiency syndrome, cancer, amyotrophic lateral
sclerosis, multiple sclerosis, terminal cancer, muscular dystrophy, inflammatory bowel disease,
Crohn’s disease and terminal illness, if the physician has determined a prognosis of less than 12
months of life.
As additional medical conditions or their treatment are approved by the Department, Breakwater
will add individuals to the board with the requisite expertise in the new field.
The function of the medical advisory board will serve to keep the Treatment Center up to date on
the latest research and trends in each discipline, as well as identify any local trends which may be
specific to New Jersey. Advisory board members will be uncompensated by Breakwater
Alternative Treatment Center. We are currently assembling a team of specialists in the medical
conditions listed above.
The Medical Advisory Board shall endeavor to work closely with the New Jersey Department of
Health and Senior Services and other state designated medical authorities as point of contact to
provide oversight of current and evolving studies, reviews, analyses, and research into the
efficacy, procedures, knowledge base, and continuing education of medical practitioners and

resources within New Jersey for the benefit of the patients, medical personnel, and community
within the state.
Measure 6: The applicant shall submit a plan to track and analyze data including but not
limited to patient outcome, utilization and trends. [WEIGHTED REQUIREMENT
up to 20 points]
PLEASE REFER TO SECTION 9, 14 & 15 OF “APPENDIX G: OPERATIONS

MANUAL” TO FULLY ANSWER MEASURE 6.
Breakwater pledges to always put the well-being of our patients and the public good foremost in
our objectives. We want patients to be able to use the highest quality medicine available to
alleviate the symptoms of their illness and will always strive for positive patient utilization
outcomes.
The medical marijuana program is similar to introducing a new pharmaceutical drug that is
undergoing clinical trials (Phase 1: Clinical Trials, Phase 2 Clinical Trials, etc). Breakwater’s
approach to the medical marijuana program is much like the early days of “pharmacy care”
which was much more of a hands-on approach to wellness and care.
Breakwater will provide our patients with access to a complete medical marijuana resource
center. All of our services are designed to ensure that a patient’s transition to the use of medical
marijuana from their existing medical treatment is based on knowledge and compassion. BATC
will provide their patients with free educational literature on medical cannabis developed by
BATC and have available at the center reading materials regarding topics such as cannabinoids
research, pain and stress management, and holistic approaches to health and wellness. Our
services will include in-depth consultations and solutions by compassionate caregivers and legal
support administered through Breakwater’s legal services program. Our goal is simple – Positive
Patient Outcomes. As active members of the medical marijuana community, the Breakwater
Alternative Treatment Center staff has the expertise to help people who have a qualifying
medical condition become a legal medical marijuana patient. Our offices are private, confidential
and secure. We are committed to providing only high quality patient services.
Detailed demographic data, diagnostic information, treatment history, and self-reported treatment
utilization will be obtained at baseline. Self-reported symptom severity information will be
collected at baseline and at 3-month intervals. Registrants will also be required to complete
standardized questionnaires that include assessment of quality of life, symptom severity,
depression, anxiety, stress, coping skills, optimism/pessimism, etc.; at baseline and at least once
a year. Breakwater ATC plans to fully document and analyze all relevant patient data gathered
during the initial registration and all follow-up consultations with the registrant. Due to the lack
of current clinical research, there is a need to document the efficacy and side effects as well as
any unintended benefits our registrants might experience while using medical marijuana. BATC
intends to develop an in-depth patient survey and analysis concerning the ingestion levels,
techniques and effects in relation to each particular patient condition in conjunction with a New
Jersey college or university. All this information will provide a basis for the retrospective
analysis of the efficacy of medical marijuana in the treatment of specific debilitating medical
conditions. In addition, BATC endeavors to partner with a major New Jersey University to
conduct long-term studies on all aspects of the use of medical marijuana. The database will also
track the amount, by type, of medical marijuana being sold by BATC in order to assure that an

adequate supply is available to BATC registrants. The registrants will be advised as to the
safeguards in place to assure information extracted from the database will be devoid of patient
identifiers. They will be informed as to the type of information which will be gathered from the
database and how that information will be utilized. The registrant will be required to sign a letter
that acknowledges the registrant’s acceptance of BATC’s use of their anonymous medical
information in this manner.
The patients will be encouraged to fill out additional surveys at the BATC dispensary, or on our
website and the responses will be made available to physicians and other BATC registrants.
All facets of our operation will be tracked (patients management, inventory management-
seedling to patient, sales management, etc) utilizing the latest software applications. This data
will be fully integrated into patient profiles. Therefore, if an unexpected adverse reaction is
reported, the database can be utilized to determine if it is a lot specific reaction.
Stringent controls that will be put in place by way of a Point of Sale/Inventory tracking system,
tools and forms for accounting and verification, and tasks and processes that will ensure
accountability at every stage, such as verifying product identification and weight measurements
in multiple departments (Cultivation, Inventory, Processing and Sales).
Patient Management
a. Patient record to include a photo of the patient and/or scan of their driver's license.
b. Driver's/NJ medical marijuana patient license swipe to pull up patient record.
c. Support for bar-coded membership cards (scanning the bar code will bring up the patient
record).
d. Upload of scanned images of patient paperwork and ID (Identification card) and NJ
e. Purchase history will be tied to the patient record and accessible with one click.
f. Tracking of key information such as NJ Medical Marijuana card expiration date or
g. Once checked in, the front desk can send the patient's record to the pharmacy technician’s
h. In addition to the information already discussed BATC will also store in its database the
the system.
Using our website or at the BATC dispensary, patients will be encouraged to fill out surveys. The
program will include the use of patient surveys to develop a comprehensive database of the
efficacy of medical cannabis. BATC intends to develop an in depth patient survey and analysis

concerning the ingestion levels, techniques and effects in relation to each particular patient
condition in conjunction with a New Jersey college or university.
BATC patients will be able to access product test results in four ways: 1) labels in display cases,
2) labels on products and 3) a book of complete test results 4) on BATC’s website. Product labels
will include the percentages for THC, CBD, and CBN. These percentages will be posted in
medicine display cases (less than 10 percent THC abiding by the NJ Medical Marijuana Rules &
Regulations), as well as affixed to the products themselves. A book containing complete
spectrometry reports for each product will be available at the service counter and on our website
for those patients who desire more detailed analytical results. Testing services will commence
with the initial launch period to develop and refine the logistics of sample collection and results
identification. After these issues are fully addressed, the testing service results will be made
widely available to individual patients and potentially to our academic partner for research
purposes. These services will include an independent certification component, so patients can be
assured that the medicine they are purchasing has been thoroughly tested and approved. BATC
has reached out to Rutgers University and is beginning the process to eventually and hopefully
work with their lab department and medical research department (working through federal
funding restrictions).
Criterion 5: Cultivation specific considerations

[TOTAL WEIGHTED REQUIREMENT up to 100 Points]

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.
NOTE: OFFICIAL USE ONLY – SECURITY-RELATED INFORMATION –
WITHHELD PURSUANT TO THE NEW JERSEY OPEN PUBLIC RECORDS ACT
(OPRA)
PLEASE REFER TO THE SEPERATE DOCUMENT LABELED “OFFICIAL USE

ONLY – SECURITY-RELATED INFORMATION – WITHHELD PURSUANT TO THE
NEW JERSEY OPEN PUBLIC RECORDS ACT (OPRA)” FOR A FULL ANSWER TO
CRITERION 5, MEASURE 1.
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.

Measure 3: The applicant shall demonstrate an ability to provide a steady supply of medicinal
marijuana to registered qualifying patients.
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.
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.
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.
IV. The applicant shall describe:
¾ Methods to ensure that seed production and/or hybridization is prevented during
cultivation of medicinal marijuana;
¾ Methods of testing for the presence of mold, bacteria or other contaminants;
¾ Procedures for routine scouting of insect and plant disease conditions;
¾ 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;
¾ Procedures for proper sanitation practices to minimize plant disease, and to promptly
dispose of diseased plant material in a secured disposal area;
¾ Methods for utilization of fans and cooling systems to maintain airflow patterns
sufficient to prevent or minimize plant disease and insect infestation;

¾ 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;
¾ Recordkeeping of any cultural measures used for plant pest or disease control,
including disposal of culled plants;
¾ The various strains of marijuana to be dispensed, and the form(s) in which it will be
dispensed;
¾ Record keeping for each package by lot, label and bar code;
¾ Area security;
¾ Packaging and labeling requirements; and
¾ Methods of processing in a safe and sanitary manner.
Steadily Supplying Medical Cannabis

In order to steadily supply cannabis to our patients we will make sure we have adequate room for
expansion of our production facilities including our stock plant greenhouses, rooting
greenhouses, production (blooming) greenhouses, drying facilities, and storage facilities. The
trimming machine we will use is capable of processing all of the cannabis we will produce, even
with significant expansion of our growing facilities. We will purchase a reverse osmosis water
system that will have a high enough flow rate to provide enough water for significant expansion
of our operations.
We are confident that our 120' x 60' greenhouse design will yield 112 pounds of cannabis at the
minimum. It is likely to yield closer to 150 pounds. Once in the production cycle it will take 9
weeks between the harvest of the last plants to ripen and the harvest of the first buds of the next
cycle. Judging by the amount of time our production cycle takes and how many customers we
are taking on, we will construct as many greenhouses as necessary to keep up with patient
demand.
Utilizing our custom greenhouse design features, carefully selecting cultivars, and using sound
cultural practices are all strategies that we will employ to ensure that diseases and pests don't
affect the availability of medicine for our patients. Our greenhouses are designed with pest
insect/mite prevention and disease prevention in mind. The greenhouses will use computerized
environmental controls to regulate the growing environment. We will keep the relative humidity
of the greenhouses in a range that is unfavorable for the development of fungal diseases. Our
horticulturalist decided on a plant spacing that would prevent diseases from occurring by
avoiding crowding of leaves and buds. Crowded plants are more prone to disease because
crowded buds and leaves build up moisture. Proper air circulation will be achieved using
circulation fans and a polytube jet-fan system. Proper air circulation will prevent moisture from
building up around transpiring leaves and buds and help keep the conditions unfavorable for
fungal disease development. Proper air circulation will also aid in plant growth by supplying
fresh air to the plant at all times. Our expert horticulturist carefully selected all of the cultivars
that we will use with the prevention of fungal diseases being a major consideration in his
selection process. The growth habit of a cultivar has a strong influence on the susceptibility of
that cultivar for developing fungal bud rot. Our horticulturalist only selected cultivars that are not
prone to developing problems with fungal bud rot. Stock plants of each variety will be selected
that have moderately sized buds. Avoiding cultivation of plants with overly large buds will be
one strategy used to avoid fungal bud rot pre or post harvest. BATC will use cultural practices

that will prevent fungal diseases and insect/mite infestations. Our fertilization/irrigation practices
will be done in a manner that will not favor diseases or insects and mites. We will use pruning
strategies that will prevent disease development. Careful greenhouse sanitation and pest
exclusion strategies will be used to prevent pest entry. Insect exclusion netting will be used on
our greenhouses. Reverse door fans will be used to prevent pests from entering through
doorways. Trays containing benzyl ammonium chloride solution will be located at greenhouse
entry- ways for workers to step in and sanitize their shoes. We will release predatory insects and
mites regularly to prevent pest infestations. Diligent scouting/monitoring for pests will ensure
that enough predators are being released to achieve complete pest control. We will use blue
sticky card traps to assist in monitoring for thrips, and yellow sticky card traps to assist in
monitoring for aphids and whiteflies.
Our growing systems are designed to consistently supply high quality medicine year-round. We
are prepared to expand our operation as much as necessary to ensure that we consistently have
enough medicine in stock.
Startup Timetable
Prior to the awarding of permits BATC will use the period following the final submission date to
make preparations to close on the cultivation site and select the dispensary site from several sites
that have already been determined to be potential locations. After approval by the state of New
Jersey on or before March 21st, 2011, BATC will immediately begin the process of setting up its
cultivation site and dispensary. The estimates below are based upon consultations with
municipalities, project consultants, and vendor estimates for the cultivation site (greenhouse
construction, fence plan, security, etc.) and build-out of the dispensary floor plan. All the below
dates are in 2011.
March 21st awarding of license
March 22nd (on or before)- Building Permits received for Cultivation Site
Our New Jersey based attorney & real estate agent have assured us that based upon the
work and research already completed (researching zoning and all local municipal
approvals) building permits for the proposed greenhouses will be issued approximately 2
weeks after the awarding of the license. Architectural design drawings and floor plans
have been completed for all the proposed structures. Between the submission date and the
awarding of permits, BATC will work expeditiously to secure both facility sites.
March 23rd: Orders Placed & Phase 1 Construction

Orders Placed:
Stock Plant, Rooting and Office Room Materials & Supplies- We have placed an
order directly from the manufacture (Rimol Greenhouses) that is pending our
awarding of the license. The greenhouse materials and supplies for the Stock
Plant, Rooting and Office Room will take one to two weeks to arrive to the
cultivation site. Please refer to Criterion 2, Measure 5 “Greenhouse-Top &
Greenhouse-Side”
Strain (Cultivar) Seeds will be ordered and will arrive within (1-2 weeks)

Blooming Greenhouse Materials & Supplies Once our license is granted the order
will begin being filled for a fully functional 120 x 60 ft greenhouse design.
Appendix E-1 “Greenhouse-Top” & E-2 “Greenhouse-Side”
Phase 1 Construction
Upon issuance of the building permits, BATC will immediately prep the land (cement
foundation) and begin constructing the stock plant (mother plant) greenhouse, rooting
greenhouse (referred to as the “propagation area”), and office greenhouse structure (to
follow along please refer to Appendix E-1 “Greenhouse-Top” & E-2 “Greenhouse-
Side”, which will contain:
1. Stock Plant Room- where all the stock plants will be housed.
2. Rooting Room- where cloning machines will root cuttings from stock plants.
3. Office Room- contains the computers, the environment controllers (the brain for
maintaining and controlling the greenhouse environment by manipulating greenhouse
roof vents, supplemental lighting, motorized blackout and shade systems,
intake/exhaust fans, heating/cooling system, and CO2 generators) and the staff area.
It is estimated it will take approximately 2 weeks to construct this greenhouse structure.
Full-scale production will commence once this structure is operational.
PLEASE NOTE- the stock plant and rooting room will both have reverse door fans to
isolate the environments from threatening insects and mites. Insect exclusion netting will
also be used to protect the stock plants from virus transmitting insects such as aphids and
thrips. We will also use trays of sanitizing solution at the doorways to sanitize our shoes
upon entering the greenhouses. It is very important that we start with disease free seeds
and then protect our plants from diseases. During their development, seeds are isolated
from plant tissues in a way that isolates them from most diseases including viruses. This
makes seeds the best source of disease free plants. Our stock plants will be highly
protected from diseases to maintain the reliability of our clones.
April 13-20th: Seedling Production

Seedling Production within the initially constructed Greenhouse Structure, the
Stock Plant Room (12 Weeks)
From this point, it will take approximately 16 weeks for the cultivation site to reach full
operation. This takes into account 12 weeks of growing the initial seed to finishing the
seedling plants, and 4 weeks for propagating enough plants to fill our blooming
greenhouse. Seeds will be bought from a licensed distributor of seeds from world-
renowned seed companies. The seed companies we will be purchasing seeds from are
Soma Seeds, THSeeds, DJ Short, Serious Seeds, and Sensi Seeds. These companies are
legitimate breeders who have been awarded multiple times for their cultivars. Only
cultivars that are known to be potent and of medical quality will be purchased. Cuttings
(clones) of all the seedling females will be harvested prior to the flowering stage.
When the seedling females have finished flowering, clones of the highest quality plants
will be selected as our stock plants. Our selection process will ensure that our stock plants
have all the traits we desire including disease resistance, potency, vigorous growth, and
good flavor/aroma. We will also obtain a well-balanced variety of stock plants with
medical effects ranging from sleep inducing to stimulating.

April 14-21st: Phase 2 Construction
Building for Blooming Greenhouses & Drying, Trimming, Curing (storage), Processing
and Baking structure will commence.
June 2nd – 16th: Blooming Greenhouses Completed

Fully functional Blooming Greenhouses will be completed.
July 6-13th: using both the Stock Plant Room & Rooting Room (4 weeks)
The selected mother plants will be cloned to produce the number of plants needed to
populate the Blooming Greenhouses.
July 27th-August 3rd

At this point, the Breakwater Cultivation site will be fully operational.
The first mature plants will be harvested nine weeks after this date and will be ready for
dispensing to patients shortly thereafter.
We estimate the first harvest will be available the week of October 5th, 2011 after curing.
**These estimates are based on the advice of our expert team comprised of an
experienced organic farmer (PhD), senior horticulturist, experienced contractor,
attorney, real estate agent, greenhouse builder/supplier as well as other team members.
Although we have potential employees that are currently caregivers in other states who can
provide us with excellent clones to jump-start our operation- we will avoid this and focus on
the quality of our product. We are also focusing on the efficiency of our greenhouses, which
will lower our variable costs and thus effectively lower the costs to our patients. We
acknowledge that we could purchase an existing greenhouse structure and possibly supply
medicine to patients more rapidly; however, we desire that our greenhouse facilities have
custom design features that will ensure our greenhouses are as energy efficient as possible
and provide an optimal growing environment. Our patients will be able to depend on the
quality of our medicine because we are committed to excellence and won't take short cuts.
Quality medicine combined with efficient production will translate into customer savings and
effective treatment of illnesses.
The Dispensary:
We project that it will take approximately six-seven months to reach the stage when the
dispensary location is capable of full operation after the awarding of the medical marijuana
license. Prior to full operation, and upon commencement of a lease, the dispensary site will
be utilized for patient registration and consultations. BATC intends to open the dispensary at
least 5 to 6 months prior to full operation.
Organic Growing Methods

Breakwater Alternative Treatment Center will consistently supply qualifying patients with high
quality, pesticide free, organically grown cannabis. BATC’s cultivation techniques are organic,
efficient, and have minimal impact on the environment and avoid the use of non-renewable
resources. Cultivation of medical quality cannabis must be done by a knowledgeable and
experienced individual dedicated to providing safe and very high quality medicine. Our

horticulturalist will oversee the cultivation of medical cannabis for Breakwater Alternative
Treatment Center. He possesses a wealth of knowledge and has formal training in the areas of
horticultural crop production, entomology, nematology, plant pathology, mycology, plant
nutrition, organic and sustainable vegetable production, plant propagation, micro propagation of
horticultural crops/tissue culture, integrated pest management, plant physiology, ethnobotany,
greenhouse management, and orchidology. He holds a degree in Horticultural Science from the
University of Florida and is active in the medical cannabis industry. He participates in industry
conventions and exchanges ideas and growing techniques with some of the most influential
individuals and organizations in the industry. His expertise will help BATC avoid issues often
faced by less experienced cultivation operations, such as mold, pest infestations and deficiencies
in the growing environment. His knowledge and experience will ensure that BATC produces
premium quality medical cannabis in the most cost-effective and environmentally friendly
manner. Breakwater Alternative Treatment Center will provide patients with medical cannabis of
the very highest quality in the industry.
Ensuring Quality Medical Marijuana:

Introduction
BATC will select stock plants carefully, germinating the seeds of world-renowned cultivars and
will then select the best female as the stock plant for that cultivar. The stock plant of each
cultivar will be clonally propagated in order to provide a steady supply of genetically identical
females of each cultivar. BATC will take great care to ensure that its selection of cultivars
encompasses the full spectrum of genetic variation and medical benefits available in cannabis.
Clonally propagating each cultivar will give patients confidence in the consistency of dose when
using a particular cultivar.
Methods to ensure that seed production and/or hybridization is prevented during the
cultivation of medicinal marijuana.
Cannabis (marijuana) is dioecious meaning that male and female flowers occur on separate
plants. Male flowers are distinct in appearance from female flowers. With the proper
knowledge of marijuana anatomy, it is possible to identify and remove male plants from a crop
soon after they reach reproductive maturity and begin to flower. Removing the males soon after
they show signs of flowering can ensure that none of their staminate flowers open. If no male
flowers are permitted to open and release pollen, the female plants will not be pollinated. In this
desirable scenario, the female plants will use their photosynthate for flower production instead of
seed production. This will allow the female plants to develop large seedless buds. Although it is
considered normal for male and female flowers to develop on separate Cannabis plants,
hermaphroditic plants are a commonality in the genus. Hermaphroditic plants can cause major
problems for growers, and are a common cause of unintended crop pollination. Some cultivars
(strains) of marijuana are more prone to hermaphroditism than others. Also, within cultivars of
marijuana individual plants can show differences in how inclined they are to exhibit
hermaphroditism.
Recently the marijuana seed industry has seen a rise in the popularity of so called "feminized"
seeds, and consequently growers have experienced greater incidence of unintended pollination.
Feminized seeds offer growers the capability to grow a seed free crop without having to cull
male plants. Unfortunately these "feminized" seeds are produced by pollinating females with
hermaphrodite pollen and do not always develop into true female plants, thus leading to
unintended pollination by hermaphroditic 'females'. To produce "feminized seeds," seed

producers force female plants with slight hermaphroditic tendencies to develop male flowers by
stressing the plants. The pollen produced from the male flowers is then used to pollinate female
plants. This process creates "feminized" seeds. These seeds produce plants that appear female
but have a stronger than usual tendency towards hermaphroditism. Growing a crop from
"feminized" seeds is much more likely to result in unintended pollination than growing from
conventional seed. Growing from conventional seed however, will not guarantee the absence of
hermaphroditic females in a crop. The presence of even a single hermaphrodite male flower
must be avoided in order to prevent crop pollination. This can only be achieved consistently by
using clonal propagation.
BHCC will avoid pollination of crops by growing clones from carefully selected clonal stock
plants (mother plants). We will select our stock plants from seedling females that have no
hermaphroditic tendencies, while also exhibiting all of our other desired phenotypic traits.
Clonal propagation of our stock plants will provide us with the necessary number of clones to
populate our greenhouses. Clones from well- selected stock plants will provide uniform and
consistently high quality, seedless marijuana. Stock plants will be quarantined in their own
specially protected greenhouse, as a measure to prevent them from being infected with diseases
that would compromise their ability to supply healthy cuttings (clones).
Selected Cultivars (Strains)

BATC will consistently provide:
1. Flying Dutchman's 'Original Haze'
This cultivar ('strain') is the true original haze. This cultivar was developed in the 1970's, but is
still considered an excellent plant for the stimulating characteristics of its medicinal effect. This
cultivar is considered to be a pure sativa with a classic laughter increasing effect. The flavor is
sweet and sour.
2. Nirvana Seeds Standard 'Early Bud'

This is a fast flowering hybrid containing indica and sativa genetics. It has an effect that is
euphoric and mellow. This cultivar has a slightly spicy, fresh flavor.
3. Sensi Seed's 'Hindu Kush'

This cultivar comes from the Hindu Kush mountain range in the Afghanistan/Pakistan region. It
is considered to be a pure indica cultivar with a classic relaxing and slightly sedative effect. The
flavor is sandalwood- like with hints of sweetness.
BHCC will order seeds of these three cultivars and grow them to maturity. Before the seedlings
begin flowering cuttings will be taken from each seedling to serve as potential stock plants. The
harvested cannabis from each seedling female will be evaluated for potency using laboratory
techniques. After determining the potency of each seedling female, the females containing less
than ten percent THC will be further evaluated for additional characteristics, and a stock plant for
each variety will be chosen. Cuttings from the chosen seedlings will become BHCC's stock
plants for further propagation.
**Please see the “Draft Operations Manual- Section 15.6” for strain details.
Greenhouses
BATC will use greenhouses to cultivate medical cannabis. Greenhouses use sunlight as the
primary source of energy for plant photosynthesis, and can provide the best possible growing

environment. Using the sun as a light source will also reduce our use of electricity and therefore
lessen our company's carbon footprint. By utilizing sophisticated environmental controls, our
greenhouses will stay in production year round.
Pest Control
BATC’s greenhouses will provide a favorable environment for releasing beneficial predatory
arthropods. Releasing predatory arthropods regularly in our greenhouses will naturally help
prevent pest problems, and help eliminate the need to spray insecticides and miticides. BATC
will also implement comprehensive policies and procedures for greenhouse sanitation, scouting
for pests, and using pest monitoring traps to ensure that there is no need to spray insecticides or
miticides.
Hydroponics
Our growing technologies will save water by re-circulating an organic nutrient solution in
hydroponic growing systems. Re-circulating hydroponic systems save water by avoiding
evaporative water loss. The organic nutrients (fertilizers) that we will be using are derived from
organic renewable resources such as bat guano and bird guano. Although the fertilizers we will
use are not OMRI (Organic Materials Review Institute) certified, they are 100% organic and are
produced in Canada specifically for cultivating medical cannabis. Our hydroponic systems will
also use a reusable growing media. Using a reusable growing media will result in a limited
impact on the environment, as opposed to using disposable growing media such as peat moss (a
non-renewable resource).
Disease Prevention
Our plants will be carefully protected from plant diseases caused by plant pathogens, including
but not limited to, Pythium spp. and Botrytis cinerea. This will be accomplished through four
main strategies: careful greenhouse design, good cultural practices including sanitation of the
growing environment, selection of disease resistant cultivars, and the manipulation of
environmental conditions in a way that is unfavorable for disease development. Automated
greenhouse controls will assist in manipulating the conditions of the growing environment. Post
harvest processing will utilize atmospheric controls and proper drying techniques, to ensure that
the medicine remains unspoiled by fungi.
Utilization of fans and cooling systems to maintain airflow patterns sufficient to prevent of
minimize plant disease and insect infestation.
A jet fan poly-tube system automated by an atmosphere controller will be used for fresh air
intake and air distribution in BHCC's greenhouses. The poly-tube will evenly distribute intake air
throughout the greenhouse, and will also aid in air circulation when not bringing in fresh outside
air. Circulation fans will be located throughout the greenhouse in order to assist the poly-tube
system and ensure proper airflow within the greenhouse. A highly accurate handheld
anemometer will be used to monitor the wind speed throughout the house and around plants, in
order to ensure that proper airflow is being achieved in a uniform fashion. Ensuring that there is
adequate air movement in the canopy of plants will keep humidity levels around buds low
enough to prevent gray mold from developing. Powerful exhaust fans will be located on the end
of the greenhouses. These exhaust fans will also be automated by an atmosphere controller. In
addition to the intake and exhaust systems, the greenhouse will utilize automated wall and roof
panels that open to allow for air exchange. The intake, exhaust, wall, and roof openings will all
be secured by insect netting to prevent the entry of pest insects. The greenhouses will also utilize
reverse door fans to keep pests out upon entering and exiting the greenhouses.

Methods to keep environment free from flowering male plants
As previously discussed our production greenhouses will only be populated by female clones
from carefully selected stock selected plants that have undergone evaluation for hermaphroditism
and show no hermaphroditic tendencies.
Procedures for proper sanitation practices to minimize plant disease, and to promptly
dispose of diseased plant material in a secured disposal area.
Any pathogen-infected or pest infested plant material that is discovered in the greenhouses will
be immediately disposed of. In order to properly dispose of infected plant material, BHCC will
use an on-site coal burning cinder block incinerator to burn it. Burning plant materials infested
with pests or pathogens is an effective way of destroying the pests and/or potential disease
inoculum. It will also ensure the secure disposal of any potentially psychoactive plant materials.
Records will be kept of all destroyed plants.
Recordkeeping of any cultural measures used for plant pest or disease control, including
disposal of culled plants
Sticky cards will be located in multiple locations throughout BHCC's greenhouses to assist in
monitoring for flying insect pests. The sticky cards will feature square grids for more efficient
counting of the insects on each card. Once each week a greenhouse manager will collect the
cards and record the number of insects per card. The information recorded each week will be
stored in a computer file. Using this recordkeeping technique will provide an early indication of
the possibility of a growing insect pest population. Managers will frequently release beneficial
arthropods into the greenhouses to control pests. Records of when releases are made and how
many arthropods are released will be kept on file.
Greenhouse management will scout for arthropod pests and for diseases daily to ensure that
infestations of pests or diseases are detected early if they do occur. Managers will keep a record
of their observations in a notebook.
Proper nutrient management including irrigation management is important for plant health and
performance. Plant problems that are caused by a lack or excess of nutrients and/or water are
considered to be abiotic diseases (disease not caused by pathogen infection). Abiotic plant
disease can often be a precursor to biotic plant disease due to suppression or interference with the
plants normal immune system responses. In order to prevent abiotic and biotic plant diseases
related to nutrients or water, greenhouse managers will utilize a carefully planned
fertilization/irrigation schedule. To ensure the proper performance of the fertilization/irrigation
schedule the plants nutrient status will be carefully monitored, and so will nutrient solution
concentrations in reservoirs. Plants sap will be sampled frequently for nitrate and potassium ion
concentrations to monitor for deficiencies or excesses within plant tissues, thus allowing for
changes in fertilization to made as necessary. The temperature of the greenhouse air will be
measured frequently using a highly accurate handheld thermo-hygrometer. The measured air
temperatures will also be compared against leaf temperature measurements measured by a highly
accurate handheld infrared thermometer. Calculating the difference between the air and leaf
temperature will provide greenhouse managers with information about the health of the plant
before problem symptoms become evident, and will provide a very good measure of the
irrigation schedule's success. Managers will record the measured air and leaf temperatures and
store the data for later use.

Regulating the conditions of the growing environment is also important to prevent plant diseases.
Plant diseases favor certain environmental conditions. For instance the fungus Botrytis cinerea
(the cause of grey mold) favors relative humidity above seventy percent. Managers will measure
relative humidity and dew point in the greenhouses using a thermo-hygrometer. The thermo-
hygrometer measurements will indicate to the greenhouse management when to make changes to
the settings of the automated environmental controls of the greenhouse, in order to prevent
disease development. For instance, if a greenhouse is expected to reach the calculated dewpoint
in the early morning hours the next day, the minimum temperature setting of the greenhouse
controls may be raised to prevent the dewpoint from being reached. As another example, if the
greenhouse is significantly above 70 percent relative humidity, the grower may change the
settings of the environmental controls to keep the humidity level down. Managers will record
thermo-hygrometer measurements and store the information in case further analysis becomes
necessary.
BHCC will keep record of any plants removed from the greenhouses due to suspicion of the
presence of pests or biotic disease. Each plant will be labeled with its own code number when
started, which will allow the life history of each plant to be followed through BHCC's records.
Although pest infested or pathogen infected plants will be incinerated on-site, record of doing so
will be kept in order to remove any suspicion that plants could have been taken off-site.
Laboratory Analysis
Breakwater Alternative Treatment Center will provide product security and purity to its patients
through detailed laboratory analysis of its medical cannabis products. This effort will be
developed in partnership with a New Jersey university or private company that owns and
operates a state-of-the-art laboratory testing facility. We are currently exploring the possibility of
a laboratory and medical research partnership with Rutgers University (working through federal
funding restrictions). All medicinal cannabis products produced by BATC will be laboratory
tested and patients will be provided with a scientific assessment of the safety and potency of their
medicine, prior to ingestion. Testing will be performed on flowers and leaves of all cannabis
cultivars prior to making lozenges or topical formulations. The testing techniques will include
gas chromatography/mass spectrometry, gas chromatography/flame ionization detection and
plate culture analysis. The testing program has two main components: safety screening and
potency quantification. Safety screening analyzes and detects contamination of pathogenic
molds, which can threaten the health of patients with or without compromised immune systems.
Potency quantification provides the percentages of three major cannabinoids: THC, CBD and
CBN. Later stages of the program will include the use of patient surveys to develop a
comprehensive database of the efficacy of medical cannabis. BATC intends to develop an in
depth patient survey and analysis concerning the ingestion levels, techniques and effects in
relation to each particular patient condition in conjunction with a New Jersey college or
university. BATC patients will be able to access product test results in three ways: 1) labels in
display cases, 2) labels on products and 3) a book of complete test results. Product labels will
include the percentages for THC, CBD, and CBN. These percentages will be posted in medicine
display cases, as well as affixed to the products themselves. A book containing complete
spectrometry reports for each product will be available at the service counter for those patients
who desire more detailed analytical results. Testing services will commence with the initial
launch period to develop and refine the logistics of sample collection and results identification.
After these issues are fully addressed, the testing service results will be made widely available to
individual patients and potentially to our academic partner for research purposes. These services
will include an independent certification component, so patients can be assured that the medicine

they are purchasing has been thoroughly tested and approved.
Summary
Breakwater Alternative Treatment Center is fully committed to providing patients with safe,
medically effective, and cost effective medicinal cannabis. Through industry leading cultivation
techniques and state-of- the-art quality control policies, procedures, and systems, our Chief
Cultivator/Horticulturalist will ensure that BATC produces the highest quality, organic and
disease free medicinal cannabis. PLEASE SEE ALSO - OPERATION MANUAL SECTIONS 9
& 15.

Appendix A-1
ARTICLES OF INCORPORATION

Appendix A-2
BY-LAWS

Breakwater Alternative Treatment Center Corp.
BY-LAWS
ARTICLE I
MEMBERS
1. Annual Meeting
A meeting of the member(s) shall be held annually for the election of directors and the
transaction of other business on such date in each year as may be determined by the Board of
Directors, but in no event later than 100 days after the anniversary of the date of incorporation of
the Corporation.
2. Special Meetings
Special meetings of the member(s) may be called by the Board of Directors, Chairman of the
Board or President and shall be called by the Board upon the written request of the holders of
record of a majority of the members of the Corporation entitled to vote at the meeting requested
to be called. Such request shall state the purpose or purposes of the proposed meeting. At such
special meetings the only business which may be transacted is that relating to the purpose or
purposes set forth in the notice thereof.
3. Place of Meetings
Meetings of the members shall be held at such place within or outside of the State of New Jersey
may be fixed by the Board of Directors. If no place is so fixed, such meetings shall be held at an
office of the Corporation.
4. Notice of Meetings
Notice of each meeting of the members shall be given in writing and shall state the place, date
and hour of the meeting and the purpose or purposes for which the meeting is called. Notice of a
special meeting shall indicate that it is being issued by or at the direction of the person or persons
calling or requesting the meeting. If, at any meeting, action is proposed to be taken which, if
taken, would entitle objecting members to receive payment for their interests, the notice shall
include a statement of that purpose and to that effect.
A copy of the notice of each meeting shall be given, personally or by first class mail, not less
than ten nor more than fifty days before the date of the meeting, to each member entitled to vote
at such meeting. If mailed, such notice shall be deemed to have been given when deposited in the
United States mail, with postage thereon prepaid, directed to the member at his address as it
appears on the record of the members, or, if he shall have filed with the Secretary of the
Corporation a written request that notices to him or her be mailed to some other address, then
directed to him at such other address.
When a meeting is adjourned to another time or place, it shall not be necessary to give any notice
of the adjourned meeting if the time and place to which the meeting is adjourned are announced
at the meeting at which the adjournment is taken. At the adjourned meeting any business may be
transacted that might have been transacted on the original date of the meeting. However, if after
the adjournment the Board of Directors fixes a new record date for the adjourned meeting, a
notice of the adjourned meeting shall be given to each member of record on the new record date
entitled to notice under this Section 4.
5. Waiver of Notice

Notice of a meeting need not be given to any member who submits a signed waiver of notice, in
person or by proxy, whether before or after the meeting. The attendance of any member at a
meeting, in person or by proxy, without protesting prior to the conclusion of the meeting the lack
of notice of such meeting, shall constitute a waiver of notice by him or her.
6. List of Members at Meetings

A list of the members as of the record date, certified by the Secretary or any Assistant Secretary
or by a transfer agent, shall be produced at any meeting of the members upon the request thereat
or prior thereto of any member. If the right to vote at any meeting is challenged, the inspectors of
election, or the person presiding thereat, shall require such list of the members to be produced as
evidence of the right of the persons challenged to vote at such meeting, and all persons who
appear from such list to be members entitled to vote thereat may vote at such meeting.
7. Qualification of Voters
Unless otherwise provided in the Certificate of Incorporation, every member of record shall be
entitled at every meeting of the members to one vote for every interest standing in its name on
the record of the members.
Treasury interests as of the record date and interests held as of the record date by another
domestic or foreign corporation of any kind, if a majority of the interests entitled to vote in the
election of directors of such other corporation is held as of the record date by the Corporation,
shall not be interests entitled to vote or to be counted in determining the total number of
outstanding interests.
Interests held by an administrator, executor, guardian, conservator, committee or other fiduciary,
other than a trustee, may be voted by such fiduciary, either in person or by proxy, without the
transfer of such interests into the name of such fiduciary. Interests held by a trustee may be voted
by him or her, either in person or by proxy, only after the interests have been transferred into his
name as trustee or into the name of his nominee.
Interests standing in the name of another domestic or foreign corporation of any type or kind
may be voted by such officer, agent or proxy as the bylaws of such corporation may provide, or,
in the absence of such provision, as the board of directors of such corporation may determine.
No member shall sell his vote, or issue a proxy to vote, to any person for any sum of money or
anything of value except as permitted by law.
8. Quorum of Members
The holders of a majority of the interests of the Corporation issued and outstanding and entitled
to vote at any meeting of the members shall constitute a quorum at such meeting for the
transaction of any business, provided that when a specified item of business is required to be
voted on by a class or series, voting as a class, the holders of a majority of the interests of such
class or series shall constitute a quorum for the transaction of such specified item of business.
When a quorum is once present to organize a meeting, it is not broken by the subsequent
withdrawal of any members.
The members who are present in person or by proxy and who are entitled to vote may, by a
majority of votes cast, adjourn the meeting despite the absence of a quorum.
9. Proxies
Every member entitled to vote at a meeting of the members, or to express consent or dissent
without a meeting, may authorize another person or persons to act for him by proxy.

Every proxy must be signed by the member or its attorney. No proxy shall be valid after the
expiration of eleven months from the date thereof unless otherwise provided in the proxy. Every
proxy shall be revocable at the pleasure of the member executing it, except as otherwise provided
by law.
The authority of the holder of a proxy to act shall not be revoked by the incompetence or death
of the member who executed the proxy, unless before the authority is exercised written notice of
adjudication of such incompetence or of such death is received by the Secretary or any Assistant
Secretary.
10. Vote or Consent of Members

Directors shall be elected by a plurality of the votes cast at a meeting of members by the holders
of interests entitled to vote in the election.
Whenever any corporate action, other than the election of directors, is to be taken by vote of the
members, it shall, except as otherwise required by law, be authorized by a majority of the votes
cast at a meeting of members by the holders of interests entitled to vote thereon.
Whenever members are required or permitted to take any action by vote, such action may be
taken without a meeting on written consent, setting forth the action so taken, signed by the
holders of all outstanding interests entitled to vote thereon. Written consent thus given by the
holders of all outstanding interests entitled to vote shall have the same effect as an unanimous
vote of members.
11. Fixing The Record Date

For the purpose of determining the members entitled to notice of or to vote at any meeting of
members or any adjournment thereof, or to express consent to or dissent from any proposal
without a meeting, or for the purpose of determining members entitled to receive payment of any
dividend or the allotment of any rights, or for the purpose of any other action, the Board of
Directors may fix, in advance, a date as the record date for any such determination of members.
Such date shall not be less than ten nor more than fifty days before the date of such meeting, nor
more than fifty days prior to any other action.
When a determination of members of record entitled to notice of or to vote at any meeting of
members has been made as provided in this Section, such determination shall apply to any
adjournment thereof, unless the Board of Directors fixes a new record date for the adjourned
meeting.
ARTICLE II
BOARD OF DIRECTORS
1. Power of Board and Qualification of Directors

The business of the Corporation shall be managed by the Board of Directors. Each director shall
be at least eighteen years of age.
2. Number of Directors
The number of directors constituting the entire Board of Directors shall be the number, not less
than three nor more than ten, fixed from time to time by a majority of the total number of
members which the Corporation would have, prior to any increase or decrease, if there were no

vacancies, provided, however, that no decrease shall shorten the term of an incumbent director,
and provided further the number of directors must not be less than three.
3. Election and Term of Directors

At each annual meeting of members, directors shall be elected to hold office until the next annual
meeting and until their successors have been elected and qualified or until their death,
resignation or removal in the manner hereinafter provided.
4. Quorum of Directors and Action by the Board

A majority of the entire Board of Directors shall constitute a quorum for the transaction of
business, and, except where otherwise provided herein, the vote of a majority of the directors
present at a meeting at the time of such vote, if a quorum is then present, shall be the act of the
Board.
Any action required or permitted to be taken by the Board of Directors or any committee thereof
may be taken without a meeting if all members of the Board or the committee consent in writing
to the adoption of a resolution authorizing the action. The resolution and the written consent
thereto by the members of the Board or committee shall be filed with the minutes of the
proceedings of the Board or committee.
5. Meetings of the Board

A bi-annual meeting of the Board of Directors shall be held in twice each calendar year with the
first meeting being held directly after the annual meeting of members. Regular meetings of the
Board shall be held at such times as may be fixed by the Board. Special meetings of the Board
may be held at any time upon the call of the President or any three directors.
Meetings of the Board of Directors shall be held at such places as may be fixed by the Board for
annual and regular meetings and in the notice of meeting for special meetings. If no place is so
fixed, meetings of the Board shall be held at the principal office of the Corporation. Any one or
more members of the Board of Directors may participate in meetings by means of a conference
telephone or similar communications equipment.
Notice must be given of annual or regular meetings of the Board of Directors. Notice of each
special meeting of the Board shall be given to each director either by mail not later than noon,
Eastern Standard Time, on the third day prior to the meeting or by telegram, written message or
orally not later than noon, Eastern Standard Time, on the day prior to the meeting. Notices are
deemed to have been properly given if given: by mail, when deposited in the United States mail;
by telegram at the time of filing; or by messenger at the time of delivery. Notices by mail,
telegram or messenger shall be sent to each director at the address designated by him for that
purpose, or, if none has been so designated, at his last known residence or business address.
Notice of a meeting of the Board of Directors need not be given to any director who submits a
signed waiver of notice whether before or after the meeting, or who attends the meeting without
protesting, prior thereto or at its commencement, the lack of notice to any director.
A notice, or waiver of notice, need not specify the purpose of any meeting of the Board of
Directors.
A majority of the directors present, whether or not a quorum is present, may adjourn any meeting
to another time and place. Notice of any adjournment of a meeting to another time or place shall
be given, in the manner described above, to the directors who were not present at the time of the
adjournment and, unless such time and place are announced at the meeting, to the other directors.
6. Resignations

Any director of the Corporation may resign at any time by giving written notice to the Board of
Directors or to the President or to the Secretary of the Corporation. Such resignation shall take
effect at the time specified therein; and unless otherwise specified therein the acceptance of such
resignation shall not be necessary to make it effective.
7. Removal of Directors
Any one or more of the directors may be removed for cause by action of the Board of Directors.
Any or all of the directors may be removed with or without cause by vote of the members.
ARTICLE III
OFFICERS
1. Election of Officers
The Board of Directors, as soon as may be practicable after the annual election of directors, shall
elect a President, a Secretary, and a Treasurer, and from time to time may elect or appoint such
other officers as it may determine. Any two or more offices may be held by the same person,
except that the same person may not hold the offices of President and Secretary unless the person
is the sole member of the Corporation and holding of said offices of President and Secretary by
such person is permitted under applicable law. The Board of Directors may also elect one or
more Vice Presidents, Assistant Secretaries and Assistant Treasurers.
2. Other Officers
The Board of Directors may appoint such other officers and agents as it shall deem necessary
who shall hold their offices for such terms and shall exercise such powers and perform such
duties as shall be determined from time to time by the Board.
3. Term of Office and Removal

Each officer shall hold office for the term for which he is elected or appointed, and until his
successor has been elected or appointed and qualified. Unless otherwise provided in the
resolution of the Board of Directors electing or appointing an officer, his term of office shall
extend to and expire at the meeting of the Board following the next annual meeting of members.
Any officer may be removed by the Board with or without cause, at any time. Removal of an
officer without cause shall be without prejudice to his contract rights, if any, and the election or
appointment of an officer shall not of itself create contract rights.
4. President
The President shall be the chief executive officer of the Corporation, shall have general and
active management of the business of the Corporation and shall see that all orders and
resolutions of the Board of Directors are carried into effect. The President shall also preside at all
meetings of the members and the Board of Directors.
5. Vice Presidents
The Vice Presidents, in the order designated by the Board of Directors, or in the absence of any
designation, then in the order of their election, during the absence or disability of or refusal to act
by the President, shall perform the duties and exercise the powers of the President and shall
perform such other duties as the Board of Directors shall prescribe.
6. Secretary and Assistant Secretaries

The Secretary shall attend all meetings of the Board of Directors and all meetings of the
members and record all the proceedings of the meetings of the Corporation and of the Board of
Directors in a book to be kept for that purpose, and shall perform like duties for the standing
committees when required. The Secretary shall give or cause to be given, notice of all meetings
of the members and special meetings of the Board of Directors, and shall perform such other
duties as may be prescribed by the Board of Directors or President, under whose supervision the
Secretary shall be. The Secretary shall have custody of the corporate seal of the Corporation and
the Secretary, or an Assistant Secretary, shall have authority to affix the same to any instrument
requiring it and when so affixed, it may be attested by the Secretary's signature or by the
signature of such Assistant Secretary. The Board of Directors may give general authority to any
other officer to affix the seal of the Corporation and to attest the affixing by his signature.
The Assistant Secretary, or if there be more than one, the Assistant Secretaries in the order
designated by the Board of Directors, or in the absence of such designation then in the order of
their election, in the absence of the Secretary or in the event of the Secretary's inability or refusal
to act, shall perform the duties and exercise the powers of the Secretary and shall perform such
other duties and have such other powers as the Board of Directors may from time to time
prescribe.
7. Treasurer and Assistant Treasurers

The Treasurer shall have the custody of the corporate funds and securities; shall keep full and
accurate accounts of receipts and disbursements in books belonging to the Corporation; and shall
deposit all moneys and other valuable effects in the name and to the credit of the Corporation in
such depositories as may be designated by the Board of Directors.
The Treasurer shall disburse the funds as may be ordered by the Board of Directors, taking
proper vouchers for such disbursements, and shall render to the President and the Board of
Directors, at its regular meetings, or when the Board of Directors so requires, an account of all
his transactions as Treasurer and of the financial condition of the Corporation.
If required by the Board of Directors, the Treasurer shall give the Corporation a bond in such
sum and with such surety or sureties as shall be satisfactory to the Board of Directors for the
faithful performance of the duties of the office of Treasurer, and for the restoration to the
Corporation, in the case of the Treasurer's death, resignation, retirement or removal from office,
of all books, papers, vouchers, money and other property of whatever kind in the possession or
under the control of the Treasurer belonging to the Corporation.
The Assistant Treasurer, or if there shall be more than one, the Assistant Treasurers in the order
designated by the Board of Directors, or in the absence of such designation, then in the order of
their election, in the absence of the Treasurer or in the event of the Treasurer's inability or refusal
to act, shall perform the duties and exercise the powers of the Treasurer and shall perform such
prescribe.
8. Books and Records
The Corporation shall keep: (a) correct and complete books and records of account; (b) minutes
of the proceedings of the members, Board of Directors and any committees of directors; and (c) a
current list of the directors and officers and their residence addresses. The Corporation shall also
keep at its office in the State of New Jersey or at the office of its transfer agent or registrar in the
State of New Jersey, if any, a record containing the names and addresses of all members, the
number and class of interests held by each and the dates when they respectively became the
owners of record thereof.

The Board of Directors may determine whether and to what extent and at what times and places
and under what conditions and regulations any accounts, books, records or other documents of
the Corporation shall be open to inspection, and no creditor, security holder or other person shall
have any right to inspect any accounts, books, records or other documents of the Corporation
except as conferred by statute or as so authorized by the Board.
9. Checks, Notes, etc.

All checks and drafts on, and withdrawals from the Corporation's accounts with banks or other
financial institutions, and all bills of exchange, notes and other instruments for the payment of
money, drawn, made, endorsed, or accepted by the Corporation, shall be signed on its behalf by
the incorporating member or persons thereunto authorized by, or pursuant to resolution of the
majority of the members.
ARTICLE IV
CERTIFICATES AND TRANSFERS OF INTERESTS
1. Forms of Interest Certificates

The interest of the Corporation shall be represented by certificates, in such forms as the Board of
Directors may prescribe, signed by the President or a Vice President and the Secretary or an
Assistant Secretary or the Treasurer or an Assistant Treasurer. The interests may be sealed with
the seal of the Corporation or a facsimile thereof. The signatures of the officers upon a certificate
may be facsimiles if the certificate is countersigned by a transfer agent or registered by a
registrar other than the Corporation or its employee. In case any officer who has signed or whose
facsimile signature has been placed upon a certificate shall have ceased to be such officer before
such certificate is issued, it may be issued by the Corporation with the same effect as if he were
such officer at the date of issue.
Each certificate representing interests issued by the Corporation shall set forth upon the face or
back of the certificate, or shall state that the Corporation will furnish to any member upon
request and without charge, a full statement of the designation, relative rights, preferences and
limitations of the interests of each class of interests, if more than one, authorized to be issued and
the designation, relative rights, preferences and limitations of each series of any class of
preferred interests authorized to be issued so far as the same have been fixed, and the authority of
the Board of Directors to designate and fix the relative rights, preferences and limitations of
other series.
Each certificate representing interests shall state upon the face thereof: (a) that the Corporation is
formed under the laws of the State of New Jersey; (b) the name of the person or persons to whom
issued; and (c) the number and class of interests, and the designation of the series, if any, which
such certificate represents.
As of the date of Formation, the sole shareholder of all certificates of interest in the Corporation
is H. Alexander Zaleski.
2. Transfers of Interests
No Interests of the Corporation shall be transferable on the record of members upon presentment
to the Corporation of a transfer agent of a certificate or certificates representing the interests
requested to be transferred, with proper endorsement on the certificate or on a separate
accompanying document, together with such evidence of the payment of transfer taxes and
compliance with other provisions of law as the Corporation or its transfer agent may require.

3. Lost, Stolen or Destroyed Interest Certificates
No certificate for interests of the Corporation shall be issued to anyone but the member(s). No
certificate for interests of the Corporation shall be issued in place of any certificate alleged to
have been lost, destroyed or wrongfully taken, except, if and to the extent required by the Board
of Directors upon: (a) production of evidence of loss, destruction or wrongful taking; (b) delivery
of a bond indemnifying the Corporation and its agents against any claim that may be made
against it or them on account of the alleged loss, destruction or wrongful taking of the replaced
certificate or the issuance of the new certificate; (c) payment of the expenses of the Corporation
and its agents incurred in connection with the issuance of the new certificate; and (d) compliance
with other such reasonable requirements as may be imposed.
4. Dissolution of the Corporation

In the Event that the Corporation is dissolved for any reason whatsoever, the Corporation shall
proceed with its dissolution pursuant to the laws of the State of New Jersey.
ARTICLE V
CORPORATE ORGANIZATION
1. Not for Profit Status
The Corporation shall be formed and operate as a Not for Profit entity pursuant to the laws of the
State of New Jersey.
2. Corporations Tax Exempt Purpose

The Corporation shall operate as a tax exempt not for profit entity within the State of New
Jersey. The purpose of the Corporation shall be for educational and scientific purposes that
qualify for Tax Exempt Not for Profit treatment under the relevant laws of the State of New
Jersey.
ARTICLE VI
Medical Advisory Board
1. Composition of the Medical Advisory Board
The Company’s “ Medical Advisory Board” shall consist of a five-member panel comprised of at
least three New Jersey Licensed Health Care professionals. Of the at least three health care
professionals, at least one of the professional shall be a licensed physician. One Medical
Advisory Board Member shall be a current patient registered to receive their medical treatment
within the State of New Jersey. At least one Medical advisory Board member shall be a local
business owner currently operating a business within the same specified medical service territory
as the Company. No current Company employee, officer or board member shall be permitted to
serve on the Medical Advisory Board.
2. Medical Advisory Board Meetings

The Company’s Medical Advisory Board shall meet no less than twice during any calendar year
and the second meeting shall take place within 8 months of the first annual meeting, but no
sooner than 4 months after the first annual meeting. The location of the meeting shall be agreed
to and determined by the individual members of the Company’s Medical Advisory Board.

3. Appointment of the Medical Advisory Board
The Members of the Medical Advisory Board shall be appointed by the Board of Directors
during the first annual meeting of the Board of Directors of the Company each calendar year.
Should a member of the Medical Advisory Board resign, become medically unable to fulfill their
position or perish at any time, the Board of Directors shall meet within 30 days of the notice of
said recognition, notice of illness or notice of death for the purpose of immediately replacing the
resigning member of the Medical Advisory Board.
4. Resignation of a member of the Medical Advisory Board

Any member of the Medical Advisory Board may resign by 30 days written notice to the
Company’s Board of Directors for any reason whatsoever.
5. Purpose of the Medical Advisory Board
The purpose of the Medical Advisory Board shall be to provide specific Medical advice to both
the officers and the board of Directors of the Company. Additionally, the Medical Advisory
Board shall regularly provide the Company’s officers and Board of Directors with any
information regarding any medical or technical advances made or discovered in the areas of
alternative treatment and specifically the usage of medicinal marijuana.
ARTICLE VII
OTHER MATTERS
1. Corporate Seal
The Board of Directors may adopt a corporate seal, alter such seal at pleasure, and authorize it to
be used by causing it or a facsimile to be affixed or impressed or reproduced in any other
manner.
2. Fiscal Year
The fiscal year of the Corporation shall be the twelve months ending December 31st, or such
other period as may be fixed by the Board of Directors.
3. Amendments
Bylaws of the Corporation may be adopted, amended or repealed by vote of the holders of the
members at the time entitled to vote in the election of any directors.

APPENDIX A-3
NON PROFIT STATUS
“FORM 1023- UNDER SECTION 501(c)(3) OF THE INTERNAL REVENUE CODE”

ARTICLE I
MEMBERS
1. Annual Meeting
A meeting of the member(s) shall be held annually for the election of directors and the
transaction of other business on such date in each year as may be determined by the Board of
Directors, but in no event later than 100 days after the anniversary of the date of incorporation of
the Corporation.
2. Special Meetings
Special meetings of the member(s) may be called by the Board of Directors, Chairman of the
Board or President and shall be called by the Board upon the written request of the holders of
record of a majority of the members of the Corporation entitled to vote at the meeting requested
to be called. Such request shall state the purpose or purposes of the proposed meeting. At such
special meetings the only business which may be transacted is that relating to the purpose or
purposes set forth in the notice thereof.
3. Place of Meetings
Meetings of the members shall be held at such place within or outside of the State of New Jersey
may be fixed by the Board of Directors. If no place is so fixed, such meetings shall be held at an
office of the Corporation.
4. Notice of Meetings
Notice of each meeting of the members shall be given in writing and shall state the place, date
and hour of the meeting and the purpose or purposes for which the meeting is called. Notice of a
special meeting shall indicate that it is being issued by or at the direction of the person or persons
calling or requesting the meeting. If, at any meeting, action is proposed to be taken which, if
taken, would entitle objecting members to receive payment for their interests, the notice shall
include a statement of that purpose and to that effect.
A copy of the notice of each meeting shall be given, personally or by first class mail, not less
than ten nor more than fifty days before the date of the meeting, to each member entitled to vote
at such meeting. If mailed, such notice shall be deemed to have been given when deposited in the
United States mail, with postage thereon prepaid, directed to the member at his address as it
appears on the record of the members, or, if he shall have filed with the Secretary of the
Corporation a written request that notices to him or her be mailed to some other address, then
directed to him at such other address.
When a meeting is adjourned to another time or place, it shall not be necessary to give any notice
of the adjourned meeting if the time and place to which the meeting is adjourned are announced
at the meeting at which the adjournment is taken. At the adjourned meeting any business may be
transacted that might have been transacted on the original date of the meeting. However, if after
the adjournment the Board of Directors fixes a new record date for the adjourned meeting, a
notice of the adjourned meeting shall be given to each member of record on the new record date
entitled to notice under this Section 4.
5. Waiver of Notice
Notice of a meeting need not be given to any member who submits a signed waiver of notice, in
person or by proxy, whether before or after the meeting. The attendance of any member at a

meeting, in person or by proxy, without protesting prior to the conclusion of the meeting the lack
of notice of such meeting, shall constitute a waiver of notice by him or her.
6. List of Members at Meetings

A list of the members as of the record date, certified by the Secretary or any Assistant Secretary
or by a transfer agent, shall be produced at any meeting of the members upon the request thereat
or prior thereto of any member. If the right to vote at any meeting is challenged, the inspectors of
election, or the person presiding thereat, shall require such list of the members to be produced as
evidence of the right of the persons challenged to vote at such meeting, and all persons who
appear from such list to be members entitled to vote thereat may vote at such meeting.
7. Qualification of Voters
Unless otherwise provided in the Certificate of Incorporation, every member of record shall be
entitled at every meeting of the members to one vote for every interest standing in its name on
the record of the members.
Treasury interests as of the record date and interests held as of the record date by another
domestic or foreign corporation of any kind, if a majority of the interests entitled to vote in the
election of directors of such other corporation is held as of the record date by the Corporation,
shall not be interests entitled to vote or to be counted in determining the total number of
outstanding interests.
Interests held by an administrator, executor, guardian, conservator, committee or other fiduciary,
other than a trustee, may be voted by such fiduciary, either in person or by proxy, without the
transfer of such interests into the name of such fiduciary. Interests held by a trustee may be voted
by him or her, either in person or by proxy, only after the interests have been transferred into his
name as trustee or into the name of his nominee.
Interests standing in the name of another domestic or foreign corporation of any type or kind
may be voted by such officer, agent or proxy as the bylaws of such corporation may provide, or,
in the absence of such provision, as the board of directors of such corporation may determine.
No member shall sell his vote, or issue a proxy to vote, to any person for any sum of money or
anything of value except as permitted by law.
8. Quorum of Members
The holders of a majority of the interests of the Corporation issued and outstanding and entitled
to vote at any meeting of the members shall constitute a quorum at such meeting for the
transaction of any business, provided that when a specified item of business is required to be
voted on by a class or series, voting as a class, the holders of a majority of the interests of such
class or series shall constitute a quorum for the transaction of such specified item of business.
When a quorum is once present to organize a meeting, it is not broken by the subsequent
withdrawal of any members.
The members who are present in person or by proxy and who are entitled to vote may, by a
majority of votes cast, adjourn the meeting despite the absence of a quorum.
9. Proxies
Every member entitled to vote at a meeting of the members, or to express consent or dissent
without a meeting, may authorize another person or persons to act for him by proxy.

Every proxy must be signed by the member or its attorney. No proxy shall be valid after the
expiration of eleven months from the date thereof unless otherwise provided in the proxy. Every
proxy shall be revocable at the pleasure of the member executing it, except as otherwise provided
by law.
The authority of the holder of a proxy to act shall not be revoked by the incompetence or death
of the member who executed the proxy, unless before the authority is exercised written notice of
adjudication of such incompetence or of such death is received by the Secretary or any Assistant
Secretary.
10. Vote or Consent of Members

Directors shall be elected by a plurality of the votes cast at a meeting of members by the holders
of interests entitled to vote in the election.
Whenever any corporate action, other than the election of directors, is to be taken by vote of the
members, it shall, except as otherwise required by law, be authorized by a majority of the votes
cast at a meeting of members by the holders of interests entitled to vote thereon.
Whenever members are required or permitted to take any action by vote, such action may be
taken without a meeting on written consent, setting forth the action so taken, signed by the
holders of all outstanding interests entitled to vote thereon. Written consent thus given by the
holders of all outstanding interests entitled to vote shall have the same effect as an unanimous
vote of members.
11. Fixing The Record Date

For the purpose of determining the members entitled to notice of or to vote at any meeting of
members or any adjournment thereof, or to express consent to or dissent from any proposal
without a meeting, or for the purpose of determining members entitled to receive payment of any
dividend or the allotment of any rights, or for the purpose of any other action, the Board of
Directors may fix, in advance, a date as the record date for any such determination of members.
Such date shall not be less than ten nor more than fifty days before the date of such meeting, nor
more than fifty days prior to any other action.
When a determination of members of record entitled to notice of or to vote at any meeting of
members has been made as provided in this Section, such determination shall apply to any
adjournment thereof, unless the Board of Directors fixes a new record date for the adjourned
meeting.
ARTICLE II
BOARD OF DIRECTORS
1. Power of Board and Qualification of Directors

The business of the Corporation shall be managed by the Board of Directors. Each director shall
be at least eighteen years of age.
2. Number of Directors
The number of directors constituting the entire Board of Directors shall be the number, not less
than three nor more than ten, fixed from time to time by a majority of the total number of
members which the Corporation would have, prior to any increase or decrease, if there were no
vacancies, provided, however, that no decrease shall shorten the term of an incumbent director,
and provided further the number of directors must not be less than three.
3. Election and Term of Directors

At each annual meeting of members, directors shall be elected to hold office until the next annual
meeting and until their successors have been elected and qualified or until their death,
resignation or removal in the manner hereinafter provided.
4. Quorum of Directors and Action by the Board

A majority of the entire Board of Directors shall constitute a quorum for the transaction of
business, and, except where otherwise provided herein, the vote of a majority of the directors
present at a meeting at the time of such vote, if a quorum is then present, shall be the act of the
Board.
Any action required or permitted to be taken by the Board of Directors or any committee thereof
may be taken without a meeting if all members of the Board or the committee consent in writing
to the adoption of a resolution authorizing the action. The resolution and the written consent
thereto by the members of the Board or committee shall be filed with the minutes of the
proceedings of the Board or committee.
5. Meetings of the Board

A bi-annual meeting of the Board of Directors shall be held in twice each calendar year with the
first meeting being held directly after the annual meeting of members. Regular meetings of the
Board shall be held at such times as may be fixed by the Board. Special meetings of the Board
may be held at any time upon the call of the President or any three directors.
Meetings of the Board of Directors shall be held at such places as may be fixed by the Board for
annual and regular meetings and in the notice of meeting for special meetings. If no place is so
fixed, meetings of the Board shall be held at the principal office of the Corporation. Any one or
more members of the Board of Directors may participate in meetings by means of a conference
telephone or similar communications equipment.
Notice must be given of annual or regular meetings of the Board of Directors. Notice of each
special meeting of the Board shall be given to each director either by mail not later than noon,
Eastern Standard Time, on the third day prior to the meeting or by telegram, written message or
orally not later than noon, Eastern Standard Time, on the day prior to the meeting. Notices are
deemed to have been properly given if given: by mail, when deposited in the United States mail;
by telegram at the time of filing; or by messenger at the time of delivery. Notices by mail,
telegram or messenger shall be sent to each director at the address designated by him for that
purpose, or, if none has been so designated, at his last known residence or business address.
Notice of a meeting of the Board of Directors need not be given to any director who submits a
signed waiver of notice whether before or after the meeting, or who attends the meeting without
protesting, prior thereto or at its commencement, the lack of notice to any director.
A notice, or waiver of notice, need not specify the purpose of any meeting of the Board of
Directors.
A majority of the directors present, whether or not a quorum is present, may adjourn any meeting
to another time and place. Notice of any adjournment of a meeting to another time or place shall
be given, in the manner described above, to the directors who were not present at the time of the
adjournment and, unless such time and place are announced at the meeting, to the other directors.
6. Resignations
Any director of the Corporation may resign at any time by giving written notice to the Board of
Directors or to the President or to the Secretary of the Corporation. Such resignation shall take

effect at the time specified therein; and unless otherwise specified therein the acceptance of such
resignation shall not be necessary to make it effective.
7. Removal of Directors
Any one or more of the directors may be removed for cause by action of the Board of Directors.
Any or all of the directors may be removed with or without cause by vote of the members.
ARTICLE III
OFFICERS
1. Election of Officers
The Board of Directors, as soon as may be practicable after the annual election of directors, shall
elect a President, a Secretary, and a Treasurer, and from time to time may elect or appoint such
other officers as it may determine. Any two or more offices may be held by the same person,
except that the same person may not hold the offices of President and Secretary unless the person
is the sole member of the Corporation and holding of said offices of President and Secretary by
such person is permitted under applicable law. The Board of Directors may also elect one or
more Vice Presidents, Assistant Secretaries and Assistant Treasurers.
2. Other Officers
The Board of Directors may appoint such other officers and agents as it shall deem necessary
who shall hold their offices for such terms and shall exercise such powers and perform such
duties as shall be determined from time to time by the Board.
3. Term of Office and Removal

Each officer shall hold office for the term for which he is elected or appointed, and until his
successor has been elected or appointed and qualified. Unless otherwise provided in the
resolution of the Board of Directors electing or appointing an officer, his term of office shall
extend to and expire at the meeting of the Board following the next annual meeting of members.
Any officer may be removed by the Board with or without cause, at any time. Removal of an
officer without cause shall be without prejudice to his contract rights, if any, and the election or
appointment of an officer shall not of itself create contract rights.
4. President
The President shall be the chief executive officer of the Corporation, shall have general and
active management of the business of the Corporation and shall see that all orders and
resolutions of the Board of Directors are carried into effect. The President shall also preside at all
meetings of the members and the Board of Directors.
5. Vice Presidents
The Vice Presidents, in the order designated by the Board of Directors, or in the absence of any
designation, then in the order of their election, during the absence or disability of or refusal to act
by the President, shall perform the duties and exercise the powers of the President and shall
perform such other duties as the Board of Directors shall prescribe.
6. Secretary and Assistant Secretaries

The Secretary shall attend all meetings of the Board of Directors and all meetings of the
members and record all the proceedings of the meetings of the Corporation and of the Board of
Directors in a book to be kept for that purpose, and shall perform like duties for the standing

committees when required. The Secretary shall give or cause to be given, notice of all meetings
of the members and special meetings of the Board of Directors, and shall perform such other
duties as may be prescribed by the Board of Directors or President, under whose supervision the
Secretary shall be. The Secretary shall have custody of the corporate seal of the Corporation and
the Secretary, or an Assistant Secretary, shall have authority to affix the same to any instrument
requiring it and when so affixed, it may be attested by the Secretary's signature or by the
signature of such Assistant Secretary. The Board of Directors may give general authority to any
other officer to affix the seal of the Corporation and to attest the affixing by his signature.
The Assistant Secretary, or if there be more than one, the Assistant Secretaries in the order
designated by the Board of Directors, or in the absence of such designation then in the order of
their election, in the absence of the Secretary or in the event of the Secretary's inability or refusal
to act, shall perform the duties and exercise the powers of the Secretary and shall perform such
prescribe.
7. Treasurer and Assistant Treasurers

The Treasurer shall have the custody of the corporate funds and securities; shall keep full and
accurate accounts of receipts and disbursements in books belonging to the Corporation; and shall
deposit all moneys and other valuable effects in the name and to the credit of the Corporation in
such depositories as may be designated by the Board of Directors.
The Treasurer shall disburse the funds as may be ordered by the Board of Directors, taking
proper vouchers for such disbursements, and shall render to the President and the Board of
Directors, at its regular meetings, or when the Board of Directors so requires, an account of all
his transactions as Treasurer and of the financial condition of the Corporation.
If required by the Board of Directors, the Treasurer shall give the Corporation a bond in such
sum and with such surety or sureties as shall be satisfactory to the Board of Directors for the
faithful performance of the duties of the office of Treasurer, and for the restoration to the
Corporation, in the case of the Treasurer's death, resignation, retirement or removal from office,
of all books, papers, vouchers, money and other property of whatever kind in the possession or
under the control of the Treasurer belonging to the Corporation.
The Assistant Treasurer, or if there shall be more than one, the Assistant Treasurers in the order
designated by the Board of Directors, or in the absence of such designation, then in the order of
their election, in the absence of the Treasurer or in the event of the Treasurer's inability or refusal
to act, shall perform the duties and exercise the powers of the Treasurer and shall perform such
prescribe.
8. Books and Records

The Corporation shall keep: (a) correct and complete books and records of account; (b) minutes
of the proceedings of the members, Board of Directors and any committees of directors; and (c) a
current list of the directors and officers and their residence addresses. The Corporation shall also
keep at its office in the State of New Jersey or at the office of its transfer agent or registrar in the
State of New Jersey, if any, a record containing the names and addresses of all members, the
number and class of interests held by each and the dates when they respectively became the
owners of record thereof.
The Board of Directors may determine whether and to what extent and at what times and places
and under what conditions and regulations any accounts, books, records or other documents of
the Corporation shall be open to inspection, and no creditor, security holder or other person shall

have any right to inspect any accounts, books, records or other documents of the Corporation
except as conferred by statute or as so authorized by the Board.
9. Checks, Notes, etc.

All checks and drafts on, and withdrawals from the Corporation's accounts with banks or other
financial institutions, and all bills of exchange, notes and other instruments for the payment of
money, drawn, made, endorsed, or accepted by the Corporation, shall be signed on its behalf by
the incorporating member or persons thereunto authorized by, or pursuant to resolution of the
majority of the members.
ARTICLE IV
CERTIFICATES AND TRANSFERS OF INTERESTS
1. Forms of Interest Certificates

The interest of the Corporation shall be represented by certificates, in such forms as the Board of
Directors may prescribe, signed by the President or a Vice President and the Secretary or an
Assistant Secretary or the Treasurer or an Assistant Treasurer. The interests may be sealed with
the seal of the Corporation or a facsimile thereof. The signatures of the officers upon a certificate
may be facsimiles if the certificate is countersigned by a transfer agent or registered by a
registrar other than the Corporation or its employee. In case any officer who has signed or whose
facsimile signature has been placed upon a certificate shall have ceased to be such officer before
such certificate is issued, it may be issued by the Corporation with the same effect as if he were
such officer at the date of issue.
Each certificate representing interests issued by the Corporation shall set forth upon the face or
back of the certificate, or shall state that the Corporation will furnish to any member upon
request and without charge, a full statement of the designation, relative rights, preferences and
limitations of the interests of each class of interests, if more than one, authorized to be issued and
the designation, relative rights, preferences and limitations of each series of any class of
preferred interests authorized to be issued so far as the same have been fixed, and the authority of
the Board of Directors to designate and fix the relative rights, preferences and limitations of
other series.
Each certificate representing interests shall state upon the face thereof: (a) that the Corporation is
formed under the laws of the State of New Jersey; (b) the name of the person or persons to whom
issued; and (c) the number and class of interests, and the designation of the series, if any, which
such certificate represents.
As of the date of Formation, the sole shareholder of all certificates of interest in the Corporation
is H. Alexander Zaleski.
2. Transfers of Interests
No Interests of the Corporation shall be transferable on the record of members upon presentment
to the Corporation of a transfer agent of a certificate or certificates representing the interests
requested to be transferred, with proper endorsement on the certificate or on a separate
accompanying document, together with such evidence of the payment of transfer taxes and
compliance with other provisions of law as the Corporation or its transfer agent may require.
3. Lost, Stolen or Destroyed Interest Certificates

No certificate for interests of the Corporation shall be issued to anyone but the member(s). No
certificate for interests of the Corporation shall be issued in place of any certificate alleged to

have been lost, destroyed or wrongfully taken, except, if and to the extent required by the Board
of Directors upon: (a) production of evidence of loss, destruction or wrongful taking; (b) delivery
of a bond indemnifying the Corporation and its agents against any claim that may be made
against it or them on account of the alleged loss, destruction or wrongful taking of the replaced
certificate or the issuance of the new certificate; (c) payment of the expenses of the Corporation
and its agents incurred in connection with the issuance of the new certificate; and (d) compliance
with other such reasonable requirements as may be imposed.
4. Dissolution of the Corporation

In the Event that the Corporation is dissolved for any reason whatsoever, the Corporation shall
proceed with its dissolution pursuant to the laws of the State of New Jersey.
ARTICLE V
CORPORATE ORGANIZATION
1. Not for Profit Status
The Corporation shall be formed and operate as a Not for Profit entity pursuant to the laws of the
State of New Jersey.
2. Corporations Tax Exempt Purpose

The Corporation shall operate as a tax exempt not for profit entity within the State of New
Jersey. The purpose of the Corporation shall be for educational and scientific purposes that
qualify for Tax Exempt Not for Profit treatment under the relevant laws of the State of New
Jersey.
ARTICLE VI
Medical Advisory Board
6. Composition of the Medical Advisory Board
The Company’s “ Medical Advisory Board” shall consist of a five-member panel comprised of at
least three New Jersey Licensed Health Care professionals. Of the at least three health care
professionals, at least one of the professional shall be a licensed physician. One Medical
Advisory Board Member shall be a current patient registered to receive their medical treatment
within the State of New Jersey. At least one Medical advisory Board member shall be a local
business owner currently operating a business within the same specified medical service territory
as the Company. No current Company employee, officer or board member shall be permitted to
serve on the Medical Advisory Board.
7. Medical Advisory Board Meetings

The Company’s Medical Advisory Board shall meet no less than twice during any calendar year
and the second meeting shall take place within 8 months of the first annual meeting, but no
sooner than 4 months after the first annual meeting. The location of the meeting shall be agreed
to and determined by the individual members of the Company’s Medical Advisory Board.
8. Appointment of the Medical Advisory Board

The Members of the Medical Advisory Board shall be appointed by the Board of Directors
during the first annual meeting of the Board of Directors of the Company each calendar year.
Should a member of the Medical Advisory Board resign, become medically unable to fulfill their
position or perish at any time, the Board of Directors shall meet within 30 days of the notice of
said recognition, notice of illness or notice of death for the purpose of immediately replacing the
resigning member of the Medical Advisory Board.
9. Resignation of a member of the Medical Advisory Board

Any member of the Medical Advisory Board may resign by 30 days written notice to the
Company’s Board of Directors for any reason whatsoever.
10. Purpose of the Medical Advisory Board
The purpose of the Medical Advisory Board shall be to provide specific Medical advice to both
the officers and the board of Directors of the Company. Additionally, the Medical Advisory
Board shall regularly provide the Company’s officers and Board of Directors with any
information regarding any medical or technical advances made or discovered in the areas of
alternative treatment and specifically the usage of medicinal marijuana.
ARTICLE VII
OTHER MATTERS
1. Corporate Seal
The Board of Directors may adopt a corporate seal, alter such seal at pleasure, and authorize it to
be used by causing it or a facsimile to be affixed or impressed or reproduced in any other
manner.
2. Fiscal Year
The fiscal year of the Corporation shall be the twelve months ending December 31st, or such
other period as may be fixed by the Board of Directors.
3. Amendments
Bylaws of the Corporation may be adopted, amended or repealed by vote of the holders of the
members at the time entitled to vote in the election of any directors.

Part IV: Narrative Description of Your Activities
Introduction
The Breakwater Alternative Treatment Center (“Breakwater”) concept was created to infuse
horticultural innovation and sympathetic treatment into the medicinal marijuana industry.
Breakwater is committed to combining mental and physical health in a format previously
inaccessible to terminal and other patients. Breakwater plans to bring this concept to fruition
through the use of “green” growing techniques to create an affordable medicinal marijuana
product in a concerned and compassionate setting bringing both physical and mental relief to
qualifying patients.
Breakwater Alternative Treatment Center will operate on a long-term basis as a strictly non-
profit corporation. It is clear that for at least the first two years operating expenses will exceed
revenues. Once that is no longer the case and the reverse becomes true, BATC will allocate
excess funds to a mix of the needs of the patients and caregivers, capital investment in energy
saving programs and contributions to other charitable and non-profit organizations in the state of
New Jersey. At no time will excess revenue inure to the benefit of any individual person or
member of Breakwater Alternative Treatment Center.
After evaluating the medical marijuana industry nationwide and taking into account the needs of
patients in New Jersey, Breakwater Alternative Treatment Center has determined estimates for

an Alternative Treatment Center located City of Manalapan located in Monmouth County and a
cultivation site in New Egypt located in Ocean County. We have chosen these cities due to our
long established relationships with community leaders and residents within the City of
Manalapan and the surrounding communities as well as New Egypt and the surrounding areas.
The Concept
New Jersey. For example, BATC will establish a fund and allocate a percentage of excess funds
to pay for patient licenses and medicine for those patients that cannot afford to pay themselves.
At no time will excess revenue inure to the benefit of any individual person or member of
The Company intends to produce the highest quality medicinal marijuana using the most
environmental and cost effective growing techniques. Employing a growing system using
organic pest controls, sunlight and recyclable water and resources, Breakwater intends to
produce the finest product at the lowest cost. This method will ultimately enable Breakwater to
pass its production savings on to its patients. Along with its medicinal marijuana production,
Breakwater intends to provide free Chiropractic services and a library of information on the use
of medicinal marijuana and holistic healing.
APPENDIX A-4
CERTIFICATE OF GOOD STANDING

(TO BE PROVIDED UNDER SEPARATE COVER)
APPENDIX B-1
INITIAL COMMITMENT LETTER- CULTIVATION SITE

APPENDIX B-2
INITIAL COMMITMENT LETTER- DISPENSARY

APPENDIX B-3
DISPENSARY REAL ESTATE LETTER

APPENDIX C
Zoning Map & Aerial Map

APPENDIX D-1
Cultivation Map- Proximity to School

APPENDIX D-2
Dispensary Map- Proximity to School

APPENDIX E
Zip Code Map

APPENDIX E
Zip Code Map

APPENDIX F
Resumes Curriculum Vitae

C u r r i c u l u m V i t a e ( C V )
VICTOR J. COPPOLA, CGP, CEM
ENVIRONMENTAL PLANNER / LAND USE CONSULTANT / SCIENTIST
2105 Princeton Ct, Box 136 • Allenwood, NJ 08720 @victorverde0927
P(732)223-2073 • F(732)359-6376 • C(732)685-5636 @greenworksLLC
Email: vjcoppola@greenworksllc.com • www.greenworksLLC.com
PERSONAL PROFILE:
Mr. Coppola’s diverse environmental and strategic planning background offers a unique
perspective of existing and potential environmental and planning issues that affect land
related projects, corporate social responsibility & environmental. Mr. Coppola is the
founder and Managing Member of GreenWorks Environmental, LLC (GWE) a Land
Use, Environmental Science and Green Design / Build firm that offers complete eco-
friendly / sustainability consulting services to developers of commercial, industrial and
residential projects; private clients; governmental agencies; allied professionals;
business owners and individuals targeted for environmental violations.
SUMMARY OF QUALIFICATIONS
• Corp Social Responsblty • Mitigation Oversight • NJ Pinelands Comm.
• Feasibility Assessments • Mold Investigations • Zoning Change
• Groundwater Analysis • Site Remediation Plans • Well Water Quality
• Coastal Bluffs & Dunes • Sustainable Site Assmnt • US Army Corps of Eng.
• Shoreline Preservation • Impact Assessments • Landfill Closure
• Class A, B, C Recycling • Ordinance Review • Notice of Violations / AO
• Regulatory Negotiations • Redevelopment Planning • UST Investigations
• Habitat Assessments • Woodlands Management • Farm Managmnt Plans
• Waterfront Development • Dredge Analysis & Plans • T&E Surveys
• Environmental Inventory • Fiscal Impact Analysis • Day Care Licensure
• ISRA Compliance • Residential & Park Sites • ADA / Barrier Free
• Dam Issues Guidance • NJDEP & EPA Permits • Real Estate Tax Appeals
• Resource Management Plans (RMP) • Remedial Action Work Plans (RAWP)
• Visual Impact Assessments (VIA) • Ecological Risk Assessments (ERA)
• Special Activity Waivers (SAW) • Historic Impact Assessments (HIA)
• NJDEP Wetlands Delineation (LOI) • Habitat Conservation & Mngmnt Plans
• Environmental Impact Statement (EIS) • Americans w/Disability Act (ADA)
• Coastal Area Facilities Rev. Act(CAFRA) • Enviro Compliance Monitoring (ECM)
• Forensic Site Investigations (FSI) • Dock, Bulkhead & boardwalk Permits
• Phase I & II – Enviro Site Assmnt. (ESA) • NJDEP Preliminary Assessments (PA)
• Wetland Ecology, Revegetation and Restoration • Letter of Authorization (LOA)
• Discharge Prevention Containment and Countermeasures (DPCC)
• Mediation & Settlement Agreements in Lieu of a Permit
• Site Investigations (SI) requiring extensive sampling (soils, air, water, etc)

PROFESSIONAL TRAINING, CERTIFICATIONS & CONTINUING EDUCATION
PP - NJ State Board of Professional Planners (State Planners Exam 2008 / Lic. Pndg)
AICP - American Institute of Certified Planners (AICP Qualified / Lic. Pending)
CEM - Certified Environmental Manager (Environmental Assessment Association)
CGP – Certified Green Professional (National Association of Home Builders / NAHB)
CLR – Certified LiveRoof Design, Installation & Maintenance (Live Roof, LLC)
CRP – Certified RainXchange Professional (AquaScape)
• Rainwater Recycling Systems – Aquascapes (2010)
• Green Roof Design, Installation and Maintenance – Living Roof Systems (2009)
• Green Building for Building Professionals – NAHB (2009)
• Business Management for Building Professionals – NAHB (2009)
• Energy Audit Workshop – Stockton College (2009)
• Environmental Funding Opportunities – Rutgers / NJDEP (2008)
• Underground Storage Tank Regulatory Training – Rutgers / NJDEP (2008)
• Carbon Inventory Training – Stockton College (2008)
• Wetlands Mitigation Planning – Water Budgeting – Rutgers / NJDEP (2008)
• Ecological Risk Assessment Practice & Protocols – Rutgers / NJDEP (2008)
• Site Remediation Basics-Workplans, Methods & Reports – Rutgers / NJDEP (2007)
• Coastal Program Rules and Regulations – NJDEP (2006)
• Digital Photography for Field Investigations – Rutgers (2005)
• Pond Design and Management – Rutgers / NJDEP (2004)
• Green Design Techniques for Residential & Commercial Projects – Rutgers (2004)
• GIS for Environmental Analysis and Mapping – Rutgers (2004)
• Vernal Pool Identification and Registration – Stockton College (2003)
• Mold Assessment, Mitigation and Remediation – Rutgers (2003)
• Advanced Wetlands Delineation – Rutgers / NJDEP (2003)
• Threatened & Endangered Species of N. & S. NJ – Rutgers / NJDEP (2003)
• St. John’s Island • Marine Research Project (1981)
• Captive Breeding of Atlantic Green Sea Turtles, Cayman Islands, BWI (1980)
• Herpetological Habitat, Nutritional and Breeding Requirements (1974 – Present)
• Herpetological Field Sampling Methods (1974 – Present)
• Professional Tutelage Under Nicholas V. Coppola PLS, PP, CLA (1964 – Present)
EDUCATION
• Wake Forest University (Winston-Salem, NC) 1989
Master of Business Administration (MBA) / strategic planning & negotiations.
Paper & Training:
“Business Valuation & Ownership Transition Strategies for Small Private Firms”

Outward Bound Leadership Training Program – Charlotte, NC
Private Tutor – Chemistry and Biology
• North Carolina State University (Raleigh, NC) 1986
Bachelor of Science (BS) in Biology / concentration: wildlife biology and microbiology
Teacher’s Aide – Biology & Microbiology
Private Tutor – Genetics and Microbiology
• Point Pleasant Boro High School (Point Pleasant, NJ) 1982
High School Diploma, college preparatory, concentration: life sciences
Papers & Research Project:
“Captive Breeding and Nutritional Requirements of the Common Map Turtle”
“A Collection of Botanical Species, Trees & Flowers – Monmouth / Ocean Co.,
NJ”
Boy Scouts of America / Eagle Project – Community Avian Habitat Enhancement
EXPERT REPORTING & TESTIMONY
• Court Matter Proficiency:
Michaels vs. Holly River Estates (2008-2011) – Enviro permitting matters
associated with redevelopment of residential property with numerous
environmental constraints.
High Point Insurance Co vs. Hughes & Sons Oil Co. / East Orange, NJ (2009-
2011) – Soil & Groundwater impacts from alleged supplier induced UST failure.
NJDEP vs. Jersey Gas / Lakewood, NJ (20010 – 2011) – Environmental impacts
assoc. w/ gas station underground storage tank (UST’s) and notice of violations.
Campbell’s Junction Shopping Center Vs. Middletown Twp.(2008-2011) –
Monmouth County Construction Board of Appeals, ADA / NJ Barrier Free Sub-
code mall rehabilitation accessibility issues. 2010 Township Withdraws Case.
Sim Family Farm vs. NJDEP – Environmental impacts associated with filing
wetlands, clearing wooded wetlands, illegal stream crossing on 130 ± acre farm.
Leeds vs. Lakewood Twp Tax Assessor – private lot representation as to
environmental impacts affecting land valuation.
NJDEP vs. Good Tree Farm – Organic Farm - Wetlands, Transition Areas, Flood
Plains, Top-of-Bank, & wetlands restoration. Case Ongoing
Court Appointed Environmental Specialist - for Ocean County Superior Court
under Judge Kline (2002 – 2007).
NJDEP Vs. Mota – Farmland Reclamation - Wetlands, Transition Areas, Flood
Plains, Top-of-Bank, Solid waste fill & wetlands restoration. Case Ongoing
Cellar Vs. Howell Twp – Property Tax Assessment Challenge / Taxes reduced
for non-usable wetlands / Farmland status preserved / farm tax credits applied.
Lurvey Vs. Davis – Residential Redevelopment - Wetlands & transition areas
impacting redevelopment opportunities. Special Activity Waiver settled dispute.
NJDEP Vs. Steve Becker, Becker Tree Service & Wayne Pomanowski – Wood
Pulp & Firewood Operation – AO / NOV / Wetlands and transition areas, Solid
Waste, Class B Recycling, stream impacts, unauthorized dams.
NJDEP Vs. Cardella Trucking – Recycling Center - Permit Revocation /
Administrative Order / Notice of Violations (NOV) / Class B Recycling Center,
Transfer Station & Rail Yard Transfer activities.

NJDEP Vs. Mazza Demolition – Recycling Center - Wetlands, Transition Areas,
Vernal Pool, Class A & B Recycling Center Permits, Transfer Station, Solid
Waste and Landfill issues.
Seagull Square Shopping Center – ADA accessibility issues regarding mall
rehabilitation. Case dismissed with prejudice.
Delran Shopping Center – ADA accessibility issues regarding Mall rehabilitation
and expansion. Case settled.
Bricktown Shopping Center – ADA accessibility issues regarding Mall
rehabilitation. Case withdrawn.
• Adjudicatory Hearings Involving:
Public Access to Waterfront – For private residential, commercial and marina
sites surrounding facilities requirements and existing public access.
Wetlands Restoration – Residential / commercial and farmlands where wetland
impacts were negotiated as to wetlands line, restoration and compensation.
Shoreline Stabilization – Residential development denied shoreline restoration
and stabilization device. Negotiated contribution for “Letter of Authorization”.
Shellfish Bed Impacts - CAFRA denial for dock impacts to shellfish beds. Case
reviewed, monetized and a significantly reduced settlement agreed upon.
CAFRA Coverage Requirements – Consecutive residential / industrial lots under
same / pecuniary ownership interests subject to reduced coverage requirements.
Negotiations w/NJDEP involving historic use and transference of coverages.
Waterfront Structures – Upland area expansion denial due to illegal waterfront
structures. Research yielded Historic USACOE approvals / permits.
Dunes & Coastal Bluffs – Redevelopment of residential facility located on primary
dune. Historic architectural plans verified foundation location from 1956 and
voluntary dune stabilization allowed project to be settled and move forward.
• Planning Board / Zoning Board / Tax Assessor / Council testimony regarding
environmental issues such as:
Wetlands & Habitat Assessments Pesticide Impacts
Environ. Impact Statement (EIS) Phase I & II Enviro Assessments
Fiscal Impacts / Tax Appeals Woodlands Management Plans
Residential Wind Turbines Restrictive Easements
• Local, County & State workshop negotiations involving:
Cluster Development Options
Re-Zoning Opportunities
Parks and Recreation Projects
Tree Preservation / Relocation
Public Improvements
Constrained Site Development
Development / RSIS Guidelines
Public Access to the Waterfront

● Professional Speaking Engagements:
East Coast Green (2010) – Lecture at the NJ Architects annual meeting on the
pros and cons of Green Roof Technologies here and abroad, Applications &
obstacles to consider when designing / installing living green roof systems.
County College Green Curriculum – Green Mindset & Living Green Roofs (2010)
– Adjunct Faculty Member for Ocean County College offering series of green
centric continuing education programs.
“Environmental Problem Solving - Howland Hook Marine Terminal Expansion”
(2010) – Adjunct Faculty Member for New Jersey Institute of Technology offering
Master Degree & PhD program candidates insight into the broad array of
environmental / sustainability issues assoc. w/waterfront development land use.
“Sustainable Lunch Series” (2010) – In process of coordinating monthly
educational sessions with the NYC Architecture firm of Cooper, Robertson &
Partners geared towards green / sustainable design, urban land use and
construction practices.
“Assorted Environmental Issues / Q&A” – Conduct Quarterly environmental
educational sessions for the West Long Branch Environmental Commission.
“Beyond the Typical Home Inspection” (2010) – Conduct monthly educational
sessions to International Assoc. of Home Inspectors (NACHI) regarding site
inspection issues that go beyond your typical home inspection.
“Site Constraints to Land Development” (2005 – 2008) – Conducted quarterly for
the BLSJ, The SBCJ and the AIA (Local Chapter) where the following land
development focus topics were held:
• “The Simple 6-lot Subdivision”
• “The Rarely Seen Aboveground Storage Tank (AST) Serpent”
• “Waterfront Dvlpmnt Adjoining Redevlpmnt Zone Under Active Remediation”
“Photography, Graphics & Imagery Associated w/Environmental Due Diligence” -
Conducted for local area New Jersey High School Career Days.
“The Songs of New Jersey’s Frogs & Toads” (2004-2010) – Conducted for local
area New Jersey High School Career Days.
RECENT PROJECTS / SERVICES PROVIDED
Wind Turbine • Wall, NJ – Residential Site

Environmental – Limited EIS associated with township’s 1st residential wind turbine.
Planning – Zoning Board consultation & testimony regarding variances needed.
Project Portfolio -
http://www.flickr.com/photos/greenworksllc/sets/72157625660523160/
Herschel Street Landfill • Galloway, NJ – Municipal Landfill
Environmental – Environmental investigations associated with formal landfill closure
activities. In addition, Pinelands has oversight and their own special requirements.
Planning – Initial indications reveal site contamination and public interest in project.
BREAKWATER ALTERNATIVE TREATMENT CENTER p. 108 of 210

PLB Properties • Brick, NJ – Commercial Rehabilitation
Environmental – Freshwater & Tidal wetlands, CAFRA, Special Activity Waivers,
Transition area averaging, habitat restoration
Project Portfolio -
Jesel Valvetrain • Lakewood, NJ – Industrial Facility
Environmental – ISRA Compliance, Groundwater mercury contamination, Site
Investigation Reporting, Preliminary Assessment submission.
Planning – Baseline Ecological Evaluation, submission / clean-up strategies.
Project Portfolio - http://www.flickr.com/photos/greenworksllc/sets/72157623484674315/
Mazza Demolition • Tinton Falls, NJ – Transfer & Recycling Center
Environmental – Wetlands restoration regarding AO and numerous NOV’s
Planning – Habitat impact mitigation regarding industrial subdivision.
Cardella Trucking • North bergen, NJ – Transfer & Recycling Center
Environmental – File review regarding AO and numerous NOV’s.
Planning – NJDEP Permit renewal negotiations and settlement options.
Willows @ the Shore • Lakewood, NJ - 133 Unit Active Adult Community
Environmental - Wetlands, Stream Encroachment, EIS, CAFRA & SGP
Planning – Environmental constraints mapping via GIS.
Jakes Branch County Park • Beachwood, NJ - 400 Acre County Park
Environmental – Coordination Wetlands Delineation, EIS, T&E Species Survey.
Site Remediation – Piezometer installation and monitoring coordination.
Hoffman’s Marina • Brielle, NJ - 20 Unit Waterfront Townhouses
Environmental – Waterfront Dev., CAFRA, EIS, Phase I/II, Shellfish Assessment.
Site Remediation – Soil & Groundwater Sampling associated w/UST removal.
Brielle Yacht Club • Brielle, NJ - 60 Unit Waterfront Townhouses
Environmental – Waterfront Development Permit, CAFRA, EIS, Phase I ESA,
Coastal GP for bulkhead replacement, Habitat Assessment for coastal shellfish.
Site Remediation – Soil & groundwater sampling associated with UST removal.
Victorian Pines • Bayville, NJ - 42 Unit Housing Project & Linear Development
Environmental –CAFRA, EIS, Habitat Assessment, toluene/benzene contamination.
Hickory Farms • Bayville, NJ - 350 Unit Housing Project
Environmental – CAFRA, EIS, Habitat Assessment, adjoining superfund site.
Planning – Environmental constraints mapping via GIS and GPS.
Johnson Park • Jackson, NJ – 65 Acre Park
Environmental – Phase I ESA, Habitat Assessment, Phase II ESA - Pesticides
Lanes Mill Commercial Center • Howell, NJ – 35 ± Acre Commercial Center
Environmental – Phase I & II ESA, Wetlands, Woodlands Management Plan, C-1
Planning – Environmental constraints mapping via GIS and GPS, change use.

Project Portfolio -
Armstrong Estates • Jackson, NJ – 30 Lot Subdivision
Environmental – Phase I & II ESA, Habitat Assessment and Wetlands / LOI permits.
Metedeconk Estates • Jackson, NJ – 1,200 Unit Adult Community
Environmental – Wetlands, T&E Species Survey for Swamp Pink (Helonias bullata).
AH Sayreville • Sayreville, NJ – 150 Room 10 Story Waterfront Hotel
Environmental – Phase I & II ESA, Wetlands Delineation, LOI Application/permits.
Manahassett Creek Park • City of Longbranch, NJ – City’s Largest Parks Project
Environmental –Wetlands Delineation, CAFRA, Phase II ESA, Enviro Oversight.
Lakewood Cogeneration Power Plant (Phase II) • Lakewood, NJ
Environmental –Wetlands Delineation, CAFRA, Phase I & II ESA, Enviro Oversight.
THREATENED & ENDANGERED SPECIES SURVEY EXPERIENCE
Private Residential Lot – Brick, NJ (2008) – Submerged Aquatic Vegetation (SAV)

survey for pier dock project at the confluence of the Metedeconk River and the Barnegat
Bay. Evaluated submerged marine habitat for eelgrass (Zostera marina) and Widgeon
Grass (Ruppia Maritima).
Private Residential Lot – Manchester, NJ (2003 – 2006) - Timber Rattlesnake
(Crotalis horridus - Endangered) and Northern Pine Snake (Pituophis m. melanoleucus -
Threatened); Randomized and Transect Visual Surveys.
7-Lot Residential Subdivision – Manchester, NJ (2003 – 2006) - Timber Rattlesnake
(Crotalis horridus - Endangered). Randomized and Transect Visual Surveys.
Retreat at Manchester (500 ± Lot Active Adult Community) • Manchester, NJ
(2001) - Timber Rattlesnake (Crotalis horridus - Endangered), Northern Pine Snake
(Pituophis m. melanoleucus - Threatened) and Corn Snake (Elaphe g. Guttata -
Endangered); Randomized and Transect Visual Surveys coupled with Trapping.
Jakes Branch County Park • Beachwood, NJ (1998 & 2005) - Pine Barrens Tree
Frog (Hyla andersonii), Northern Pine Snake (Pituophis m. melanoleucus - Threatened)
and Corn Snake (Elaphe g. Guttata - Endangered). Randomized and Transect Visual
Surveys coupled with extensive local property owner interviews and literature review.
Leisure Village retirement communities • Lakewood, NJ (1979 - 1980) - Several
herpetological species were encountered during and after construction (Northen Black
Racer - Coluber constrictor constrictor, Northern Pine Snake - Pituophis m. melanoleucus,
Eastern Hog Nosed Snake - Heterodon platirhinos, Eastern Gartner Snake - Thamnophis
sirtalis sirtalis, and several turtle species. . The habitat assessments, T&E surveys and
species relocation performed predates currently utilized protocols and were not required at
the time of this project. Early morning and late afternoon opportunistic and transect visual

inspections of construction areas were performed where individual specimens found were
captured by hand and relocated.
Airport Road Extension • Lakewood, NJ (1978) - As part of the design and construction
of Airport Road, several species of snakes were found to be using the road for sunning
during and after construction which resulted in numerous snake vehicular fatalities. Early
morning and late afternoon roadside visual inspections were performed where individual
specimens found sunning on the new road were captured by hand and relocated. The area
of the project site contained suitable habitat and wetland environs as well as significant food
sources and known associated species for the species documented. After several months,
snake vehicular fatalities diminished. The following snake species were captured and
relocated: Northen Black Racer Snake - Coluber c. constrictor, Corn Snake - Elaphe g.
Guttata, Northern Pine Snake - Pituophis m. melanoleucus, Eastern Gartner Snake -
Thamnophis sirtalis sirtalis,
PROFESSIONAL WORK HISTORY
GreenWorks Environmental, LLC • Allenwood, NJ (2007 – Present) - Managing

Member / Environmental Planner / Consultant. Perform / coordinate environmental &
planning for land development, site remediation & sustainability projects.
D. W. Smith Associates, LLC • Farmingdale, NJ (2001 – 2007) – Principal / Director
of Environmental Services. engineering, surveying, planning, landscape architecture
and environmental / site remediation firm.
Royal Mail • London, UK (1999 – 2001) - Regional Sales Manager / International
Services. Western US international markets relations management.
Environmental / Business Consultant • San Francisco, CA (1996 – 2000) – Owner.
Environmental and business startup / development consultation.
Jordan Pace & Co., Inc • Fort Collins, CO (1991 – 1996) – General Manager. Import /
specialty home décor / retail & wholesale operations.
Merck & Company • Rahway, NJ (1989 – 1991) – Sales. efficacy and pharmacology of
Merck cardiovascular, anti-hypertensive, NSAID and ophthalmic drugs.
North Carolina Department of Agriculture • Raleigh, NC (NCSU, 1984 – 1986) – Lab
Assistant / Apiculture Research Assistant. Apiary management and lab research
surrounding honey bee infestation with Tracheal Mites.
North Carolina State University Marine Research • Raleigh, NC (1983 – 1984) – Lab
assistant / Phytoplankton Research. Maintained phyto and zooplankton specimens for
use in naval grant research.
North Carolina State University Microbiology Research • Raleigh, NC (1982 –
1983) – Lab assistant / Gel Electrophoresis Prep. / Specimen Culture Maintenance.
Boulevard Veterinary Hospital • Raleigh, NC (1982 – 1986) – Lab Technician. Lab
duties, administration of medications & injections, animal screenings, surgical assistant.
D.W. Smith Associates, PA • Lakewood, NJ (1978 – 1982) – Print Boy / Survey Field
Technician / Environmental Specialist. Summertime: print room, survey field technician
and environmental specialist.

Veterinary / Laboratory Experience (1977 – 1982) – Throughout High School, worked
for the Toms River Veterinary Hospital, Pleasant Plains Veterinary Hospital, Jersey
Shore Veterinary Emergency Service and the Point Pleasant Veterinary Hospital in
numerous capacities which revolved around veterinary assistant and lab technician
duties of domesticated, wild and exotic animal species.
BOARD MEMBER / COMMITTEES / ACTIVE REGISTRATION

• Boy Scouts of America / Jersey Shore Council - Executive Board.
• Board Member of the National Eagle Scout Association (NESA)
• Builders League of South Jersey (Action & Green Building Committee-Chair)
• National Association of Home Builders
• NJ Builders Association (NJBA) (Pinelands & Environmental Committee)
• American Planning Association (APA) and the New Jersey Chapter of the APA
• Pinelands Preservation Alliance
• NJDEP, Div of Fish, Game & Wildlife Conservation Corps
• United States Green Building Council (USGBC)
PERSONAL
Born in Newark, Essex County, NJ; Married with a son and daughter; and an Eagle
Scout. Other interests include: Boy Scout Volunteer, Camping, Hiking, Whitewater
Kayaking, Fly Fishing, Snow Sports, Bee Keeping, Gardening, Photography and a
Greener Lifestyle.
REFERENCES
Furnished upon request.

Amy Klauber, ESQ.
Secretary & Board Member
1500 Allaire Avenue, Suite 101, Ocean, NJ 07712
DOB – 3/31/1965
Experience Amy B. Klauber, Esq., / Klauber & Klauber, LLP 1998 - Present
Legal and Self-Employed General Practitioner
Related: Partner in a general practice firm with offices in New York and New
Jersey, concentrating primarily on various aspects of family law matters,
civil litigation and contract negotiations and transactions, including
personal injury, medical malpractice, breach of contract, construction
claims, commercial claims and real estate.
Office of the Public Defender – Parental Representation Unit, April

2008-Present
Pool Attorney for the Office of the Public Defender protecting parental
rights in cases regarding removal of children in DYFS litigation.
Senior Associate, 1991 - 1996; 1997 - 1998

PULVERS, PULVERS, THOMPSON & KUTNER, P.C.
New York, New York
Manage caseload in excess of 150 plaintiff personal injury/medical
malpractice and defense medical malpractice cases, handle all aspects of
file from client intake through verdict, significant client contact, negotiate
settlements, research, write and argue motions/appeals, conduct
depositions.
Associate, 1996 - 1997

AARONSON, RAPPAPORT, FEINSTEIN & DEUTSCH, LLP
New York, New York
Analyze, create and implement defense strategy in medical malpractice
cases from inception through all stages of litigation. Report findings to
managing partners and to insurance carriers.
Deans Fellow, 1988 - 1990

WASHINGTON COLLEGE OF LAW/AMERICAN UNIVERSITY
Washington, DC
Taught legal research and writing to first year law students, created and
graded assignments, including memorandum of law, wrote legal briefs and
memoranda as models for the class, conducted individual counseling
sessions with students.
Law Clerk, 1988 - 1989

SOLLER, SINGER & HORN
Washington, DC/New York, New York

Researched issues regarding general import/export law, contract law,
negligence, corporate, real estate and administrative law. Drafted protests
to administrative agencies regarding proposed and existing regulations and
their ramifications on specific or general class of clients.
Other: Advisory Board Member, 2010-Present

LEGAL AID SOCIETY OF MONMOUTH COUNTY, INC.
Volunteer. Review applications for aid by indigent residents of Monmouth
County and vote on acceptance of the matters. Participate in meetings with
Board members concerning furthering the objectives of the organization.
Member, Board of Directors, 2010 – Present

KIWANIS OF MANALAPAN
Volunteer. Plan and implement events and fund raising activities to further
the goals and objectives of the organization.
Advisory Board Member, 1992 - 1998

CAUSE EFFECTIVE
New York, New York
Volunteer. Plan and implement special events and individual donor
campaigns for purposes of raising funds and friends for nonprofit
management consulting organization, participate in meetings with Board
members concerning furthering the objectives of the organization,
participate in workshop concerning effectively planning special events.
Education: Washington College of Law/American University
Washington, DC
Juris Doctor 1990
University of Massachusetts
Amherst, MA
Bachelors of Business Administration, 1987
Major: Finance Minor: Economics
Admissions: Admitted New York Bar 1991

Admitted New Jersey Bar 1990

Richard Klauber, ESQ
Medical Advisory Board Member
1500 Allaire Avenue, Suite 101, Ocean, NJ 07712
Professional Klauber & Klauber, LLP, 2004 - Present

Experience: Partner
Responsible for managing all cases from inception through conclusion in
areas of civil litigation, construction litigation, tort litigation, breach of
contract, contract negotiation, general business/commercial law, family
law and real estate.
Manalapan Township, 2007-2009
Mayor, 2009; Committeeman 2007-2008
Elected to a three-year term for town council. 2 year member of the
Planning Board, Police Commissioner, finance/budget committee,
environmental commission and public works liaison. Lead Committeeman
for union contract negotiations.
Certified Municipal Attorney, pending
Completion of municipal attorney diplomat program and related
examinations offered by New Jersey Institute of Continuing Legal
Education in conjunction with the New Jersey Institute of Local
Government Attorneys (NJILGA) which covers all aspects of municipal
law. Topics include Open Public Meetings Act, OPRA, labor law, COAH,
land use, planning and zoning, ordinance and resolution requirements,
budgeting etc.
Certified Civil Mediator, 2007 – Present
Act as a mediator for alternative dispute resolution of civil related matters.
Middlesex County College, 2005-2008
Adjunct Professor
Develop curriculum and teach construction law course with emphasis on
contract s, lien laws, public bids, bonds and consumer fraud.
Cohen, Kuhn & Associates 1997 - 2003
Senior Litigation Associate
Responsible for legal analysis, litigation and reporting in connection with
the defense of significant high exposure case load in the areas of general
negligence, products liability, construction, dental malpractice, motor
vehicle and coverage issues from inception through trial and appeal as
well as preparing calendar assignments for staff.
Menagh, Trainor, Mundo & Falcone, 1996 - 1997
Senior Litigation Associate
Responsible for significant caseload management in the areas of
construction litigation, labor law, workers compensation, real estate and
insurance coverage issues from inception through trial and appeal. Lead
council for NYC Taxi Union in NYC Traffic Courts.
Jacobowitz, Garfinkel & Lesman, Esqs. 1990 - 1996

Litigation Associate
In-house defense counsel for major international insurance carrier
specializing in labor and construction law. Responsible for direction of
substantial caseload from inception through trial with heavy emphasis
upon discovery matters, depositions, motions and court appearances.
Edelman, Schoenfeld & Weinberg, 1988 - 1990
Involved with all aspects of litigation practice in the areas of commercial
transactions, products liability, medical malpractice and personal injury.
Steven M. Coren, P.C., 1987 - 1988
Involved with all aspects of commercial litigation and labor law.
Responsible for legal research and writing, drafting pleadings, motions
and appeals.
Education: State University of New York at Buffalo

Faculty of Law and Jurisprudence
Buffalo, New York
Juris Doctor: June, 1987
Estimated Class Rank: Top 25%
Honors: Research & Writing, Civil Procedure, International Dispute
Settlement, International Business Transactions, Labor law
State University of New York at Oswego
Oswego, New York
Bachelors of Science, December, 1980
Major: Business Administration, concentrating in accounting
Honors: Deans List, President & Treasurer Zeta Chi Zeta Fraternity
Continuing Legal Education
1988 - Present
Attendance at seminars run by various legal entities, including NITA, New
York State Trial Lawyers and New Jersey Institute of Continuing
Education involving review of major decisions in tort, labor and
construction law, land use, COAH, Municipal Law and trial training
technique.
Admissions: New York State Bar, March, 1988

United States District Court, Southern District New York, 1988
United States District Court, Eastern District New York, 1988
New Jersey State Bar, 2000
District Court, New Jersey, 2000

Maureen M. Ivers RPh
Medical Advisory Board Member
5 Estella Drive, Flemington, NJ 08822
DOB – 09/14/1955
NJ Registered Pharmacist w/a background in both retail pharmacy & pharmaceutical industry.
Professional Experience
Ikaria, Clinton, NJ 8/2010-Present
Drug Safety Specialist, Pharmacovigilance
• Understand FDA Code of Federal Regulations (CFR) and International Conference on
Harmonisation (ICH) safety guidelines pertaining to serious adverse event (SAE) and
medical device reporting (MDR).
• Assess both individual clinical and spontaneous adverse event reports for seriousness,
labeling status, and relatedness
• Follow-up on reports of adverse events received in conjunction with medical device
complaints and assess for seriousness, labeling, and relatedness.
• Review all adverse event report documents and prepare a narrative of the event.
• Capture details of the adverse event and device complaint (when applicable) in the
Adverse Event Reporting System (AERS) utilizing MedDRA to code the adverse events
and patient medical history.
• Perform case follow-up according to standard operating procedures (SOP) to obtain
clarifying or supplemental information.
• Prepare Investigational New Drug (IND), New Drug Application (NDA), and Medical
MDR safety reports for review by the Drug Safety Physician.
• Submit IND, NDA and MDR safety reports to the Food and Drug Administration (FDA)
according to regulation timelines and submit copies of these reports to business partners
and notifying bodies according to company standard operating procedures (SOP).
ImClone Systems, Branchburg, NJ 7/2008- 8/2010
Sr. Drug Safety Specialist
• Trained and mentored new Drug Safety Specialists
• Managed case workload to assure on-time regulatory reporting.
• Provided initial review of safety reports prepared by Drug Safety Specialists
• Performed database searches and prepared standard and adhoc reports for risk
management purposes.
• Assessed individual case safety reports for seriousness, labeling status, and relatedness.
• Reviewed adverse event report documents and prepared a narrative of the event
• Reviewed safety data captured in the company drug safety database (ARISg) to assure
accuracy and proper MedDRA coding.
• Prepared 7-Day and 15-Day IND safety reports
• Perform case follow-up according to SOP to obtain clarifying or supplemental
information.

Johnson and Johnson Family of Companies 1999 to 2008
Centocor Ortho Biotech Services, LLC, Bridgewater, NJ 3/2004 to 7/2008
Johnson & Johnson Consumer Products, Skillman, NJ 1/1999 to 3/2004
Medical Information and Customer Communications Specialist
• Responded promptly and professionally to requests for information on marketed
products.
• Captured details of spontaneous adverse events (AE’s), product quality complaints
(PQC’s), and consumer and healthcare professional inquiries in the Customer
Relationship Management (CRM) reporting system utilizing appropriate coding for
future reporting purposes.
• Prepared Adverse Event (AE) and Product Quality Complaint (PQC) reports on marketed
products for review by internal regulatory and product quality departments for FDA
reporting obligations.
• Interacted with business partners to resolve customer inquires or complaints.
• Developed work processes and guidance documents and assisted in the updating of SOPs
Sanofi Aventis (formerly Hoechst Marion Roussel) 1997 to 1998

Pharmaceutical Sales Representative
MARKETED ALLEGRA, ALTACE AND AMARYL TO HEALTHCARE PROFESSIONALS
INITIALLY AS A CONTRACTOR AND LATER AS A DIRECT EMPLOYEE.
• Made district-meeting presentations to help increase product knowledge of sales force.
• Coordinated efforts with team members to maximize sales opportunities within the
territory.
• Presented features and benefits of promoted products to Healthcare Professionals (HCPs).
• Utilized pharmaceutical knowledge to make solid comparisons against competing
products.
• Demonstrated effective probing skills to engage the HCP in discussions about products.
• Prepared progress and expense reports.
• Managed a yearly budget
RETAIL PHARMACIST EXPERIENCE
Village Prescription Pharmacy, Neshanic, NJ 1993 to 1998
Shop Rite Pharmacy, Hillsborough, NJ 1986 to 1996
Baron Drugs, Cranford, NJ 1978 to 1986
• Acted as preceptor to pharmacy students during their retail pharmacy internship rotations.
• Dispensed medications according to physician orders, after reviewing patient medication
history/disease states for possible interactions or contraindications.
• Consulted with physicians regarding drug interactions and drug safety issues.
• Consulted with insurance carriers to obtain proper authorizations.
• Provided patient consultation on both prescription and OTC medications.
• Responsible for inventory control and regulatory audits.
EDUCATION
BS in Pharmacy, Rutgers College of Pharmacy, Piscataway, New Jersey
PROFESSIONAL LICENSE
New Jersey Board of Pharmacy 1978 to Present

Sue Lefkowitz, BSN, RN, C
572 Clubhouse Drive • Middletown, NJ 07748
(732) 533-5608 • SLF430@aol.com
Nursing license # 26NR05620400
WORK EXPERIENCE:
Independent Legal Consulting
Review and analyze medical records for attorneys in connection with medical
malpractice claims. Provide reports containing summary of facts and findings.
Spring 08-10 Outcomes, Inc. HEDIS Project Field Reviewer
Scanned and uploaded relevant documents from medical records for insurance
company review
1989-Present Riverview Medical Center, Red Bank
Labor and Delivery- ‘Clinical Scholar” 2002-present
Responsible for total nursing care of patients from admission until transfer to post
partum unit.
Responsibilities Include:
Fetal monitor assessment and interventions
Labor assessment
Use and management of pitocin and prostaglandins
Assessment & care of patients with preterm labor, preeclampsia, and other
complications of pregnancy/labor & delivery
Assisting in natural and assisted vaginal births
Scrubbing and circulating for Cesearian deliveries
Post anesthesia care
Starting and maintaining IV sites, phlebotomy
Frequent “charge nurse” on unit
1978-1987 N.Y.U. Medical Center, New York, NY
Obstetrics Team Leader
Rotated through Labor & Delivery, Postpartum, and Nursery; responsible for
patient care in each of these areas
EDUCATION AND CERTIFICATIONS:
1978 Trenton State College, B.S., Nursing
2009 NALS (Neonatal Advanced Life Support) certification
2009 ACLS (Advanced Cardiac Life Support) certification
2008 Electronic Fetal Monitor Certified by the National Certification Corporation for the
Obstetric, Gynocologic, and Neonatal Nursing Specialties (NCC)
2010 BCLS (Basic Cardiac Life Support) certification
2006 AWHONN (Association of Women’s Health, Obstetric, and Neonatal Nursing Nurses)
National Convention (4 days)
2000 Fetal Monitor Certified by AWHONN
1993 Certification in Inpatient Obstetrical Nursing by NCC
MEMBERSHIPS:
1996-Present Delivery Room Committee (Riverview Medical Center)
Develops policies and procedures for the OB unit

Ashif Jiwa
444 Madison Avenue, Suite 1805
New York, NY 10022
Website: www.bluemarkassetmanagement.com
Email: ashif@bluemarkassetmanagement.com
AREAS OF KNOWLEDGE:
Marketing
Developed and maintained promotional portfolio for publicly traded companies,
investor/public and media relations
Developed marketing plan formats and feasibility studies
Comprised statistical analysis report, conducted contract negotiation with joint
venture partners and manufacturers
Designed product packaging, promo print and reading material
Acquired and maintained accounts for trade publications and news media
Business Consultant
Assisted clients in new business ventures on a consulting basis
Prepared detailed business plan and proposals
Structured corporate entities business
Advised clients on sources of venture capital, private equity capital, money
management, collections, market analysis, promotion and personal consulting.
Directed clients in the procedures of obtaining government grants and loans
Provided direction in avenues of fund raising campaigns and special events
Assisted in developing editorial services and communication programs for clients
Consulted with clients (private companies desiring to go public on a nationally
recognized stock exchange in Canada, U.S. or European markets)
Recommended appropriate vehicles IPO’s vend-ins and reverse take over’s
Provided vehicle selected by clients (US shell, Canadian Shell & SPAC)
Provided brokerage house for sponsorship
Selected brokers, broker dealers for distribution of equity
Assisted in financing pre/post IPO secondary financing and treasury financing
Liaison to after market activities i.e.:
1. Investor relations
2. Additional services requested by client
Management/Administration
Planned corporate development of sales oriented product distribution organization
Composed financial projection, short and long range financial planning
Developed costing and revenue programs, budgets and financial statements
Organized and implemented staffing procedures for inside and field sales teams
Interviewing, supervising, training and staff evaluations
PROFESSIONAL EXPERIENCE:
2010-Present Charter Logic Companies, Inc.

Private Air Charter & Cargo Brokerage Company
To date Procured $1M USD in funding.
2007- Present Visiomed International Inc. (Medicalinov)
Medical Device Company
Currently being financed.
2007 Netspace, Florida Corp
Board Member & Investor
Web Design Company
2004-2006 Established association with Z-Max Capital Vancouver, BC
Hendrix Corp, U.S. & China Entity Water purification Company
Procured $10M in financing. Took company public on NASDAQ, BB
High End Ventures, U.S. – Canadian entity (Electrolinks Corp)
Communications Company
Procured $1M in financing Took company public on NASDAQ,BB
2002-2004 Diomed Holdings (MA)

Medical Device Company
Took Company public on Amex stock exchange
Procured $10M USD in financing
Bluemark Asset Management investment $200K USD
Media Fusion LLC (TX)
Communications Company
Introduced company to Quebec government environment & Hydro
Quebec for deployment of technology both in CA & U.S.
Bluemark Asset Management investment $100K USD
Procured $25m in financing
Established Bluemark Asset Management LLC (Florida Corp)
2003 Stanford International Bank (TX, Antigua)
Introduced bank to Canadian environment. Bank opened office in
Quebec in 2005
2001-Present Bluemark Asset Management Inc. Quebec, CA
Founder
2001-2002 BSI 2000 Texas
Consulting Procurement of Funding
1997-1998 Not Even the Trees (1998)- Motion Picture New York, NY
Executive Producer
Seagal/Nasso Productions
Personal investment $250K USD
1999-2001 Panascope Capital Vancouver BC
Partner, Investment Banking Services

1992-1999 Nadira Enterprises Inc. Vancouver, BC
Founder
Merchant Banking Services
1992-1995 OPM Management Corp. Vancouver, BC
Partner
Investment Banking Services
1990-1992 Safe-T-Strip Industries Vancouver, BC
Founder
Established 35 retail franchise stores
1987-1989 International Bulk Food Center Vancouver, BC
Founder
EDUCATION
Undergraduate degree: University of San Diego
Graduate Studies: MBA Wharton School of business
Fluent in English and French

Rimol Greenhouses
Company History
In 1994, Bob Rimol, founder of Rimol Greenhouse Systems, decided to leave New Jersey to
relocate to New Hampshire and, Rimol Greenhouse Systems began as a manufacturer’s
representative specializing in structures and systems. However, Bob soon realized the need to
build a better “mouse trap” and set out to customize greenhouse technology to suit the needs of
his customers. Bob contacted a fellow University of Vermont graduate who had settled in
Williston, Vermont. Combining their talents in engineering and horticulture with a mutual
entrepreneurial spirit, the first Rimol Greenhouse was designed.
Today, Rimol Greenhouse Systems has expanded their product line to include a number of free-
standing greenhouses, a gutter connect greenhouse called the Matterhorn, shade structures,
benches and an entire line of products to compliment the greenhouse structures. All greenhouses
have been developed to be economical, yet rugged enough to handle the harshest snow and wind
loads that New England and other regions of the country endure. Rimol Greenhouse Systems
now has products all over the United States.
John Wells joined the Rimol Greenhouse Systems team in 2005 to cover sales and service of the
New England region. John brings with him a wealth of knowledge and experience from his
diverse background in the Greenhouse and horticulture industry.
After attending Louisiana Tech University, John went to work for a large grower in Virginia. It
was there that John learned to appreciate the luxury of automation, and gained an understanding
of the sensitive needs of a growing environment.
Up for an adventure and a change of scenery, John moved to the West Coast, working for a
grower in California who specialized in vegetative propagation. Eventually, the lure of family
connections drew John and his wife to New Hampshire to settle and raise their family.
Upon his return to New England, John worked for a grower in a fast paced, marketing-oriented
company. It was this experience that led John in the direction of sales, and to his current position
at Rimol Greenhouse Systems.
“This industry is a great one, as there are so many levels to apply yourself. You can choose to be
well connected to the earth and farm or be on the cutting edge of biotechnology or somewhere in
between. Being is sales allows me to meet so many people all over the region. I see hard work,
talent and ability come together into success. This is an exciting time in our industry. Things are
changing quickly, sometimes more quickly than we like, and improvements are happening just as
fast.”

Joan E. Zaleski, CFP®
Advisor
427 Main Road, Westhampton Beach, NY 11978
DOB: 7/10/1946
Joan E. Zaleski, CFP® has worked in the financial services industry since 1986 as a planner
focusing on taxes, retirement, asset protection and executive benefits, including stock
management strategies to minimize concentration and taxes. She works with high net worth
families, executives, professionals and business owners and their advisors to develop and
implement planning strategies to minimize estate and income taxes while maintaining control
through the use of trusts, gifting, income shifting, valuation discounts and freeze techniques.
Utilizing a comprehensive process of goal defining, data gathering, evaluation and holistic
analysis to identify inconsistencies that may exist in a client’s current planning she is able to
offer simple and flexible solutions to complex problems to help clients more efficiently achieve
their goals and bring balance to their lives. She works with clients and a team of experts to test
the short and long term implications of various planning strategies and facilitates the
coordination and implementation of the plan with clients and their other advisors.
Several years ago recognizing a void she began conducting workshops for not for profits to
educate members of the special needs community on the need for a long term plan that
coordinates their personal intent and objectives, unique family dynamics, other documents,
financial resources and public policy with the needs of their loved one(s) with developmental
disabilities. She works with families to help them define their long term goals, identify obstacles
and provide trusted tools to assure a successful plan that will preserve both personal financial
resources and public benefits. She introduces them to other specialists trained in all aspects of
working with the special needs community, makes available resources to guide them through the
financial, legal and entitlement issues of transitioning, assists in creating a life plan, which
includes employment training, if feasible, and helps them to prepare for the housing crisis they
are facing by educating them on the innovative solutions being developed.
Experience: Center for Wealth Preservation 2005 – Present

MML Investor Services, Inc.
Sagemark Consulting/ Lincoln Financial Advisors 2002 – 2005
Joan E. Zaleski, CFP® 1990 – 2002

Park Avenue Securities, LLC previously Guardian Investor Services
Corp
Maran, DeBaun, Cruise and Simonson 1988 - 1990

Lincoln Financial Services Corp
Lincoln Financial Advisors 1986 - 1988
Elite Linen and Laundry Services, Inc. 1974 – 1986

Philip Band
Executive Assistant to President
Liaison in business, financial, tax and legal matters with executive’s
advisors and represented him at real estate closings and in other business
matters.
Connecticut General Life Insurance Company 1968 – 1969

1970 – 1971
Education: College of New Rochelle

New Rochelle, NY
Bachelor of Arts 1968
Concentration: French
College for Financial Planning 1994 - 1996

Certified Financial Planner Board of Standards 1997
Denver, Colorado
Certified Financial Planner Designee
Additional: American College 2008 – Present

Bryn Mawr, PA
Special Care Planner Program and working towards new Chartered
Special Needs Consultant designation
Financial Planning Association

Volunteer in the 9/11 Financial Planning Relief Services Program
Securities Licenses: Series 6, 7, 22 and 63

New York, New Jersey, Connecticut, California, Massachusetts and
Florida

Appendix G
Breakwater Alternative Treatment Center

Draft Operations Manual

TABLE OF CONTENTS
SECTION 1 - INTRODUCTION
1.1 Changes In Policy
1.2 Employment Applications
1.3 Employment Relationship
SECTION 2 - DEFINITIONS OF EMPLOYEE STATUS

“Employees” Defined
SECTION 3 - EMPLOYMENT POLICIES

3.1 Non-Discrimination
3.2 Non-Disclosure/Confidentiality
3.3 New Employee Orientation
3.4 Probationary Period For New Employees
3.5 Office Hours
3.6 Lunch Periods
3.7 Break Periods
3.8 Personnel Files
3.9 Personnel Data Changes
3.10 Inclement Weather/Emergency Closings
3.11 Performance Review And Planning Sessions
3.12 Outside Employment
3.13 Corrective Action
3.14 Employment Termination
3.15 Safety
3.16 Health Related Issues
3.17 Employee Requiring Medical Attention
3.18 Building Security
3.19 Insurance On Personal Effects
3.20 Supplies; Expenditures; Obligating The Company
3.21 Expense Reimbursement
3.22 Parking
3.23 Visitors In The Workplace
3.24 Immigration Law Compliance
SECTION 4 - STANDARDS OF CONDUCT

4.1 Attendance/Punctuality
4.2 Absence Without Notice
4.3 Harassment, Including Sexual Harassment
4.4 Telephone Use
4.5 Public Image
4.6 Substance Abuse Policy
4.7 Tobacco Products
4.8 Internet Use

SECTION 5 - WAGE AND SALARY POLICIES
5.1 Wage Or Salary Increases
5.2 Timekeeping
5.3 Overtime
5.4 Paydays
SECTION 6 - BENEFITS AND SERVICES

6.1 Insurance
6.2 Cobra Benefits
6.3 Social Security/Medicare
6.4 Simple IRA
6.5 Vacation
6.6 Record Keeping
6.7 Holidays
6.8 Jury Duty/Military Leave
6.9 Educational Assistance
6.10 Training And Professional Development
SECTION 7 - EMPLOYEE COMMUNICATIONS

7.1 Staff Meetings
7.2 Bulletin Boards
7.3 Suggestion Box
7.4 Procedure For Handling Complaints
SECTION 8 – ALTERNATIVE CENTER OVERSIGHT

8.1 Introduction
8.2 Daily & Weekly Duties
8.3 Open Door Policy
SECTION 9 – SALES DEPARTMENT OPERATIONS

9.1 Operations Manual Overview
9.2 The Role Of The Sales Department
9.3 Product knowledge
9.4 Sales Floor Layout
9.5 Cleanliness & Organization
9.6 Record Keeping And Patient Confidentiality
9.7 Dispensing Medical Marijuana
9.8 Patient Admittance, Disenrollment and Assumption of Risk
9.9 Sales Opening Checklist
9.10 Sales Closing Checklist
SECTION 10 – MEMBER SERVICES DEPARTMENT OPERATIONS

10.2 The Role Of The Member Services Department
10.3 Upholding The Mission & Vision Statements
10.4 Member Services Department Structure

10.5 Member Services Department Scheduling
10.6 Aesthetics, Cleanliness, & Organization
10.7 Member Services Opening Checklist
10.8 Member Services Closing Checklist
SECTION 11 – PROCESSING DEPARTMENT OPERATIONS

11.2 The Role Of The Processing Department
11.3 Typical Day In Processing
11.4 Misc. Processing Room Policies
11.5 Individual Processing “Styles”
11.6 Processing Opening Checklist
11.7 Manager Only Duties
11.8 Processing Closing Checklist
11.9 Manager Only Duties
SECTION 12 – HUMAN RESOURCES & EMPLOYEE SECURITY POLICIES

12.1 Each Employee's Responsibility
12.2 Door Protocol
12.3 Workplace Violence
12.4 Workplace Searches
12.5 No Weapons In The Workplace
12.6 In An Emergency
12.7 Tobacco Smoking In The Workplace
12.8 Substance Abuse
12.9 Job Descriptions
12.10 Employment Contracts
SECTION 13 – SAFETY DEPARTMENT

13.2 Role Of The Safety Department
13.3 Our Approach To Safety & Security
13.4 Employee Security
13.5 Daily Log
13.6 Opening Procedure Breakdown
13.7 Closing Procedure
13.8 Personal Safety And Crime Prevention
13.9 Emergency Preparedness Plan
13.10 Bomb Threat Procedures
13.11 External Disaster Procedures
13.12 Fire Procedures
13.13 Earthquake Procedures
13.14 Tornado Warning Procedures
SECTION 14 – INVENTORY CONTROL DEPARTMENT

14.1 Operation Manual Overview

14.2 The Role Of The Inventory Department
14.3 Inventory Department Administration
14.4 General Inventory Dept. Policies
14.5 Inventory Associate Daily Duties
14.6 Cash Management/Till Drops
14.7 Credit Card Machine Issues
14.8 Monthly Inventory Count
14.9 Inventory Opening Checklist
14.10 Inventory Closing Checklist
SECTION 15 – EDUCATIONAL DEPARTMENT

15.1 Educational Policy
15.2 Frequently Asked Questions
15.3 Tracking Useful Data
15.4 Example Of Educational Materials
15.5 Education On Packaging & Labeling
15.6 Education On Strains
SECTION 16– CRITICAL INCIDENT REPORTING

16.1 Identify And Record The Incident
16.2 Prepare For The Review
16.3 Running The Review
16.4 Keeping A Record
SECTION 17- SAMPLE EMPLOYMENT CONTRACTS

SECTION 1
INTRODUCTION
This Manual is designed to acquaint you with Breakwater Alternative Treatment Center and
provide you with information about working conditions, benefits, and policies affecting your
employment. The information contained in this Manual applies to all employees of Breakwater
Alternative Treatment Center. Following the policies described in this Manual is considered a
condition of continued employment. However, nothing in this Manual alters an employee’s
status. The contents of this Manual shall not constitute nor be construed as a promise of
employment or as a contract between the Company and any of its employees. The Manual is a
summary of our policies, which are presented here only as a matter of information. You are
responsible for reading, understanding, and complying with the provisions of this Manual. Our
objective is to provide you with a work environment that is constructive to both personal and
professional growth.
This operations manual shall remain available for inspection by the Department of Health
and Senior Services and any other authorized government agency upon request.
1.1 CHANGES IN POLICY

This Manual supersedes all previous employee manuals and memos that may have been issued
from time to time on subjects covered in this Manual. However, since our business and our
organization are subject to change, we reserve the right to interpret, change, suspend, cancel, or
dispute with or without notice all or any part of our policies, procedures, and benefits at any
time. We will notify all employees of these changes. Changes will be effective on the dates
determined by the Company, and after those dates all superseded policies will be null. No
individual supervisor or manager has the authority to change policies at any time. If you are
uncertain about any policy or procedure, speak with your direct supervisor.
1.2 EMPLOYMENT APPLICATIONS

We rely upon the accuracy of information contained in the employment application and the
accuracy of other data presented throughout the hiring process and employment. Any
misrepresentations, falsifications, or material omissions in any of this information or data may
result in exclusion of the individual from further consideration for employment or, if the person
has been hired, termination of employment.
1.3 EMPLOYMENT RELATIONSHIP

You enter into employment voluntarily, and you are free to resign at any time for any reason or
no reason. Similarly, Breakwater Alternative Treatment Center is free to conclude its relationship
with any employee at any time for any reason or no reason. Following the probationary period,
employees are required to follow the Employment Termination Policy (See Section 3.13).
SECTION 2
DEFINITIONS OF EMPLOYEES STATUS
“EMPLOYEES” DEFINED
An “employee” of Breakwater Alternative Treatment Center is a person who regularly works for

Breakwater Alternative Treatment Center on a wage or salary basis. “Employees” may include
exempt, non-exempt, regular full-time, regular part-time, voluntary and temporary persons, and
others employed with the Company who are subject to the control and direction of Breakwater
Alternative Treatment Center in the performance of their duties.
EXEMPT
Employees whose positions meet specific criteria established by the Fair Labor Standards Act
(FLSA) and who are exempt from overtime pay requirements.
NON-EXEMPT
Employees whose positions do not meet FLSA criteria and who are paid one and one-half their
regular rate of pay for hours worked in excess of 40 hours per week.
REGULAR FULL-TIME
Employees who have completed the 90-day probationary period and who are regularly scheduled
to work 35 or more hours per week. Generally, they are eligible for the Company’s benefit
package, subject to the terms, conditions, and limitations of each benefit program.
REGULAR PART-TIME
Employees who have completed the 90 day probationary period and who are regularly scheduled
to work less than 35 hours per week. Regular part-time employees are eligible for some benefits
sponsored by the Company, subject to the terms, conditions, and limitations of each benefit
program.
TEMPORARY (FULL-TIME or PART-TIME)

Those whose performance is being evaluated to determine whether further employment in a
specific position or with the Company is appropriate or individuals who are hired as interim
replacements to assist in the completion of a specific project or for vacation relief. Employment
beyond any initially stated period does not in any way imply a change in employment status.
Temporary employees retain that status until they are notified of a change. They are not eligible
for any of the Company’s benefit programs.
PROBATIONARY PERIOD FOR NEW EMPLOYEES

A new employee whose performance is being evaluated to determine whether further
employment in a specific position or with Breakwater Alternative Treatment Center is
appropriate. When an employee completes the probationary period, the employee will be notified
of his/her new status with Breakwater Alternative Treatment Center.
SECTION 3
EMPLOYMENT POLICIES
3.1 NON-DISCRIMINATION
In order to provide equal employment and advancement opportunities to all individuals,
employment decisions at Breakwater Alternative Treatment Center will be based on merit,
qualifications, and abilities. Breakwater Alternative Treatment Center does not discriminate in
employment opportunities or practices because of race, color, religion, sex, national origin, age

or disability. Breakwater Alternative Treatment Center will make reasonable accommodations
for qualified individuals with known disabilities unless doing so would result in an undue
hardship. This policy governs all aspects of employment, including selection, job assignment,
compensation, discipline, termination, and access to benefits and training. Employees with
questions or concerns about discrimination in the workplace are encouraged to bring these issues
to the attention of their supervisor. Employees can raise concerns and make reports without fear
of reprisal. Anyone found to be engaging in unlawful discrimination would be subject to
disciplinary action, including termination of employment.
3.2 NON-DISCLOSURE/CONFIDENTIALITY
The protection of confidential business information and trade secrets is vital to the interests and
success of Breakwater Alternative Treatment Center. Such confidential information includes, but
is not limited to, the following examples: Compensation data, Financial information, Marketing
strategies, Pending projects and proposals, Proprietary growing and production processes,
Personnel/Payroll records, and Conversations between any persons associated with the company.
All employees are required to sign a non-disclosure agreement as a condition of employment.
Employees who improperly use or disclose trade secrets or confidential business information will
be subject to disciplinary action, including termination of employment and legal action, even if
they do not actually benefit from the disclosed information.
3.3 NEW EMPLOYEE ORIENTATION

Orientation is a formal welcoming process that is designed to make the new employee feel
comfortable, informed about the company, and prepared for their position. New employee
orientation is conducted by a Human Resources representative, and includes an overview of the
company history, an explanation of the company core values, vision, and mission; and company
goals and objectives. In addition, the new employee will be given an overview of benefits, tax,
and legal issues, and complete any necessary paperwork. Employees are presented with all
personal key codes, keys, biometrics setup and procedures needed to navigate within the
workplace. The new employee’s supervisor then introduces the new hire to staff throughout the
company, reviews their job description and scope of position, explains the company’s evaluation
procedures, and helps the new employee get started on specific functions.
3.4 PROBATIONARY PERIOD FOR NEW EMPLOYEES

The probationary period for regular full-time and regular part-time employees lasts up to 90 days
from date of hire. During this time, employees have the opportunity to evaluate our Company as
a place to work and management has its first opportunity to evaluate the employee. During this
introductory period, both the employee and the Company have the right to terminate employment
without advance notice. Upon satisfactory completion of the probationary period, a 90-day
review will be given and benefits will begin as appropriate. All employees, regardless of
classification or length of service, are expected to meet and maintain Company standards for job
performance and behavior (See Section 4, Standards of Conduct).
3.5 OFFICE HOURS

Breakwater Alternative Treatment Center office is open for business from 9 a.m. to 7 p.m.
Monday through Saturday, except for Holidays (See Section 6.7, Holidays). The standard
workweek is 40 hours of work (see Section 5.3, Overtime). In the computation of various

employee benefits, the employee workweek is considered to begin on Sunday (starting at 12:01
a.m.) through Saturday (ending at 12:00 a.m.), unless a supervisor makes prior other arrangement
with the employee.
3.6 LUNCH PERIODS

Employees are allowed a one-hour lunch break. Lunch breaks generally are taken between the
hours of 11 a.m. and 2:00 p.m. on a staggered schedule so that your absence does not create a
problem for co-workers or clients.
3.7 BREAK PERIODS

Breakwater Alternative Treatment Center does not provide for employees to break during
production activities except for the above outlined lunch period. If employees have unexpected
personal business to take care of, they must notify their direct supervisor to discuss time away
from work and make provisions as necessary. Personal business should be conducted on the
employee’s own time. Employees who do not adhere to the break policy will be subject to
disciplinary action, including termination.
3.8 PERSONNEL FILES

Employee personnel files include the following: job application, job description, résumé, records
of participation in training events, salary history, records of disciplinary action and documents
related to employee performance reviews, coaching, and mentoring. Personnel files are the
property of Breakwater Alternative Treatment Center, and access to the information is restricted.
Management personnel of Breakwater Alternative Treatment Center who have a legitimate
reason to review the file are allowed to do so. Employees who wish to review their own file
should contact their supervisor or Human Resources Representative. With reasonable advance
notice, the employee may review his/her personnel file in Company’s office and in the presence
of their supervisor or Human Resources Representative.
3.9 PERSONNEL DATA CHANGES

It is the responsibility of each employee to promptly notify their supervisor or Breakwater
Alternative Treatment Center Human Resources Department of any changes in personnel data
such as Mailing address, Telephone numbers, Name and number of dependents, and Individuals
to be contacted in the event of an emergency. An employee’s personnel data should be accurate
and current at all times.
3.10 INCLEMENT WEATHER/EMERGENCY CLOSINGS

At times, emergencies such as severe weather, fires, or power failures can disrupt company
operations. The decision to close the office will be made by the Executive Staff. When the
decision is made to close the office, employees will receive official notification from their
supervisors. Time off from scheduled work due to emergency closings will be unpaid for all non-
exempt employees. However, if employees would like to be paid, they are permitted to use
vacation time if it is available to them.
3.11 EMPLOYEE PERFORMANCE REVIEW AND PLANNING SESSIONS

Supervisors will conduct performance reviews and planning sessions with all regular full-time
and regular part-time employees after six months of service. Supervisors may conduct informal

performance reviews and planning sessions more often if they choose. Performance reviews and
planning sessions are designed for the supervisor and the employee to discuss his/her current job
tasks, encourage and recognize attributes, and discuss positive, purposeful approaches for
meeting work-related goals. Together, employee and supervisor discuss ways in which the
employee can accomplish goals or learn new skills. The planning sessions are designed for the
employee and his/her supervisor to make and agree on new goals, skills, and areas for
improvement. Breakwater Alternative Treatment Center directly links wage and salary increases
with performance. Your performance review and planning sessions will have a direct effect on
any changes in your compensation. For this reason among others, it is important to prepare for
these reviews carefully, and participate in them fully. New employees will be reviewed at the
end of their probationary periods (see Section 3.3, Probationary Period for New Employees).
After the initial review, the employee will be reviewed according to the regular semi-annual
schedule.
3.12 OUTSIDE EMPLOYMENT

Employees may hold outside jobs in non-related businesses or professions as long as the
employee meets the performance standards of their job description with Breakwater Alternative
Treatment Center. Unless an alternative work schedule has been approved by Breakwater
Alternative Treatment Center, employees will be subject to the company’s scheduling demands,
regardless of any existing outside work assignments. Breakwater Alternative Treatment Center’s
office space, equipment, and materials are not to be used for outside employment.
3.13 CORRECTIVE ACTION

Breakwater Alternative Treatment Center holds each of its employees to certain work rules and
standards of conduct (see Section 4). When an employee deviates from these rules and standards,
Breakwater Alternative Treatment Center expects the employee’s supervisor to take corrective
action. Corrective action at Breakwater Alternative Treatment Center is progressive. That is, the
action taken in response to a rule infraction or violation of standards typically follows a pattern
increasing in seriousness until the infraction or violation is corrected. The usual sequence of
corrective actions includes an oral warning, a written warning, probation, and finally termination
of employment. In deciding which initial corrective action would be appropriate, a supervisor
will consider the seriousness of the infraction, the circumstances surrounding the matter, and the
employee’s previous record. Though committed to a progressive approach to corrective action,
Breakwater Alternative Treatment Center considers certain rule infractions and violations of
standards as grounds for immediate termination of employment. These include but are not
limited to: theft in any form, insubordinate behavior, vandalism or destruction of company
property, being on company property during non-business hours, the use of company equipment
and/or company vehicles without prior authorization by Executive Staff, untruthfulness about
personal work history, skills, or training, divulging Company business practices, and
misrepresentations of Breakwater Alternative Treatment Center to a patient, a prospective
patient, the general public, or an employee.
3.14 EMPLOYMENT TERMINATION

Termination of employment is an inevitable part of personnel activity within any organization,
and many of the reasons for termination are routine. Below are a few examples of some of the
most common circumstances under which employment is terminated:

Resignation – voluntary employment termination initiated by an employee.
Termination–involuntary employment termination initiated by Breakwater Alternative
Treatment Center.
Layoff–involuntary employment termination initiated by Breakwater Alternative
Treatment Center for non-disciplinary reasons.
When a non-exempt employee intends to terminate his/her employment with Breakwater
Alternative Treatment Center is based on mutual consent, both the employee and Breakwater
Alternative Treatment Center have the right to terminate employment at will, with or without
cause during the Introductory/Probationary Period for New Employees (See Section 3.3,
Introductory/Probationary Period for New Employees). Any employee who terminates
employment with Breakwater Alternative Treatment Center shall return all files, records, keys,
and any other materials that are property of Breakwater Alternative Treatment Center. No final
settlement of an employee’s pay will be made until all items are returned in appropriate
condition. The cost of replacing non-returned items will be deducted from the employee’s final
paycheck. Furthermore, any outstanding financial obligations owed to Breakwater Alternative
Treatment Center will also be deducted from the employee’s final check. Employee’s benefits
will be affected by employment termination in the following manner. All accrued vested benefits
that are due and payable at termination will be paid. Some benefits may be continued at the
employee’s expense (See Section 5, Benefits) if the employee elects to do so. The employee will
be notified of the benefits that may be continued and of the terms, conditions, and limitations.
3.15 SAFETY
Breakwater Alternative Treatment Center provides information to employees about workplace
safety and health issues through regular internal communication such as:
Training sessions
Team meetings
Bulletin board postings
Memorandums
Other written communications
Each employee is expected to obey safety rules and exercise caution and common sense in all
work activities. Employees must immediately report any unsafe conditions to their supervisor.
Employees who violate safety standards, cause hazardous or dangerous situations, or fail to
report, or where appropriate, remedy such situations, may be subject to disciplinary action
including termination of employment. In the case of an accident that results in injury, regardless
of how insignificant the injury may appear, employees should notify their supervisor (See
Section 3.16, Employee Requiring Medical Attention).
3.16 HEALTH-RELATED ISSUES

Employees who become aware of any health-related issue, including pregnancy, should notify
their supervisor and Human Resources Representative of health status. This policy has been
instituted strictly to protect the employee. A written “permission to work” from the employee’s
doctor is required at the time or shortly after notice has been given. The doctor’s note should
specify whether the employee is able to perform regular duties as outlined in his/her job
description. A leave of absence may be granted on a case-by-case basis. If the need arises for a
leave of absence, employees should notify their supervisor and Human Resources
Representative.

3.17 EMPLOYEE REQUIRING MEDICAL ATTENTION
In the event an employee requires medical attention, whether injured or becoming ill while at
work, the employee’s personal physician must be notified immediately. If it is necessary for the
employee to be seen by the doctor or go to the hospital, a family member will be called to
transport the employee to the appropriate facility. If an emergency arises requiring Emergency
Medical Services to evaluate the injury/illness of an employee on-site, the employee will be
responsible for any transportation charges. Furthermore, Breakwater Alternative Treatment
Center’s employees will not be responsible for transportation of another employee due to
liabilities that may occur. A physician’s “return to work” notice may be required.
3.18 BUILDING SECURITY

All employees who are issued keys to the office are responsible for their safekeeping. These
employees will sign a Building Key Disbursement form upon receiving the key. The last
employee, or a designated employee, who leaves the office at the end of the business day
assumes the responsibility to ensure that all doors and security access points (i.e. safe) are
securely locked, the alarm system is armed, thermostats are set on appropriate evening and/or
weekend setting, and all appliances and lights are turned off with exception of the lights
normally left on for security or operational purposes. Employees are not allowed on Company
property after hours without prior authorization from the Executive Staff.
3.19 INSURANCE ON PERSONAL EFFECTS

All employees should be sure that their own personal insurance policies cover the loss of
anything occasionally left at the office. Breakwater Alternative Treatment Center assumes no
risk for any loss or damage to personal property.
3.20 SUPPLIES; EXPENDITURES; OBLIGATING THE COMPANY

Only authorized persons may purchase supplies in the name of Breakwater Alternative
Treatment Center. No employee whose regular duties do not include purchasing shall incur any
expense on behalf of Breakwater Alternative Treatment Center or bind Breakwater Alternative
Treatment Center by any promise or representation without written approval.
3.21 EXPENSE REIMBURSEMENT

Expenses incurred by an employee must have prior approval by a supervisor. Reimbursements
under $25.00 will be included in the employee’s next regular paycheck. An example of such an
expense would include mileage. If the amount is more than $25.00, the reimbursement request
will be processed like an invoice. All completed reimbursement request forms should be turned
in to Accounts Payable/Payroll Department.
3.22 PARKING
Employees must park their cars in areas indicated and provided by the Company.
3.23 VISITORS IN THE WORKPLACE

To provide for the safety and security of employees, visitors, and the facilities at Breakwater
Alternative Treatment Center, only authorized visitors are allowed in the workplace. Restricting
unauthorized visitors helps ensure security, decreases insurance liability, protects confidential
information, safeguards employee welfare, and avoids potential distractions and disturbances.

All visitors must enter through the main reception area, sign-in, and sign-out at the front desk
and receive a ‘Visitor’ badge to wear while on premises. Authorized visitors will be escorted to
their destination and must be accompanied by an employee at all times.
3.24 IMMIGRATION LAW COMPLIANCE

Breakwater Alternative Treatment Center employs only United States citizens and those non-
U.S. citizens authorized to work in the United States in compliance with the Immigration Reform
and Control Act of 1986. Each new employee, as a condition of employment, must complete the
Employment Eligibility Verification Form I-9 and present documentation establishing identity
and employment eligibility. Former employees who are rehired must also complete the form if
they have not completed an I-9 with Breakwater Alternative Treatment Center within the past
three years or if their previous I-9 is no longer retained or valid.
SECTION 4
STANDARDS OF CONDUCT
The work rules and standards of conduct for Breakwater Alternative Treatment Center are
important, and the Company regards them seriously. All employees are urged to become familiar
with these rules and standards. In addition, employees are expected to follow the rules and
standards faithfully in doing their own jobs and conducting the Company’s business. Please note
that any employee who deviates from these rules and standards will be subject to corrective
action, up to and including termination of employment (see Section 3.12, Corrective Action).
While not intended to list all the forms of behavior that are considered unacceptable in the
workplace, the following are examples of rule infractions or misconduct that may result in
disciplinary action, including termination of employment. Theft or inappropriate removal or
possession of property; Falsification of timekeeping records (See Section 5.2, Timekeeping);
Working under the influence of alcohol or illegal drugs (See Section 4.6, Substance Abuse);
Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace (See
Section 4.6, Substance Abuse); Fighting or threatening violence in the workplace; Boisterous or
disruptive activity in the workplace; Negligence or improper conduct leading to damage of
company-owned or patient-owned property; Insubordination or other disrespectful conduct;
Violation of safety or health rules; Smoking in the workplace; Sexual or other unlawful or
unwelcome harassment (See Section 4.3, Harassment, Including Sexual Harassment); Excessive
absenteeism or any absence without notice (See also, Section 4.1 Attendance/Punctuality and
4.2, Absence without Notice); Unauthorized use of telephones, or other company-owned
equipment (See Section 4.4, Telephone Use); Using company equipment for purposes other than
business (i.e. playing games on computers or personal Internet usage); Unauthorized disclosure
of business “secrets” or confidential information; Violation of personnel policies; and
Unsatisfactory performance or conduct.
4.1 ATTENDANCE/PUNCTUALITY
The Company expects that every employee will be regular and punctual in attendance. This
means being in the office, ready to work, at their starting time each day. Absenteeism and
tardiness places a burden on other employees and on the Company. If you are unable to report
for work for any reason, notify your supervisor before regular starting time. You are responsible
for speaking directly with your supervisor about your absence. It is not acceptable to leave a

message on a supervisor’s voice mail, except in extreme emergencies. In the case of leaving a
voice-mail message, a follow-up call must be made later that day. Should undue tardiness
become apparent, disciplinary action may be required. If there comes a time when you see that
you will need to work some hours other than those that make up your usual work week, notify
your supervisor at least seven working days in advance. Each request for special work hours will
be considered separately, in light of the employee’s needs and the needs of the Company. Such
requests may or may not be granted.
4.2 ABSENCE WITHOUT NOTICE

When you are unable to work owing to illness or an accident, please notify your supervisor. This
will allow the Company to arrange for temporary coverage of your duties, and helps other
employees to continue work in your absence. If you do not report for work and the Company is
not notified of your status, it will be assumed after two consecutive days of absence that you
have resigned, and you will be removed from the payroll. If you become ill while at work or
must leave the office for some other reason before the end of the workday, be sure to inform
your supervisor of the situation and check out with the manager.
4.3 HARASSMENT, INCLUDING SEXUAL HARASSMENT

Breakwater Alternative Treatment Center is committed to providing a work environment that is
free of discrimination and unlawful harassment. Actions, words, jokes, or comments based on an
individual’s sex, race, ethnicity, age, religion, or any other legally protected characteristic will
not be tolerated. If you believe you have been the victim of harassment, or know of another
employee who has, report it immediately. Employees can raise concerns and make reports
without fear of reprisal. Any supervisor who becomes aware of possible harassment should
promptly advise their supervisor or the Human Resources Representative who will handle the
matter in a timely and confidential manner.
4.4 TELEPHONE USE

Breakwater Alternative Treatment Center telephones are intended for the use of serving our
patients and in conducting the Company’s business. Personal usage during business hours is
discouraged except for extreme emergencies. All personal telephone calls should be kept brief to
avoid congestion on the telephone line. To respect the rights of all employees and avoid
miscommunication in the office, employees must inform family members and friends to limit
personal telephone calls during working hours. If an employee is found to be deviating from this
policy, he/she will be subject to disciplinary action (See Section 3.12, Corrective Action).
4.5 PUBLIC IMAGE

A professional appearance is important anytime that you come in contact with patients or
potential patients. Employees should be well groomed and dressed appropriately for our business
and for their position in particular. The following items are considered inappropriate working
attire for Breakwater Alternative Treatment Center: Open-toed sandals, Spaghetti-strapped shirts,
Tank tops or revealing shirts, Short mini skirts, Sheer clothing, T-shirts with inappropriate or
offensive gestures or advertising. When meeting with a client, the dress code is more business-
oriented, including attire such as: Slacks and dress shirt or blouse and Dress or skirt and blouse.
If management occasionally designates "casual days," appropriate guidelines will be provided to
you. Consult your supervisor if you have any questions about appropriate business attire.

4.6 SUBSTANCE ABUSE
The Company is committed to providing a safe and productive workplace for its employees. In
keeping with this commitment, the following rules regarding alcohol and drugs of abuse have
been established for all staff members, regardless of rank or position, including both regular and
temporary employees. The rules apply during working hours to all employees of the Company
while they are on Company premises or elsewhere on Company business.
So that there is no question about what these rules signify, please note the following definitions:
Company property: All Company owned or leased property used by employees.
Controlled substance of abuse: Any substance listed in Schedules I-V of Section 202 of the
Controlled Substance Act, as amended.
Drug: Any chemical substance that produces physical, mental, emotional, or behavioral change
in the user.
Drug paraphernalia: Equipment, a product, or material that is used or intended for use in
concealing an illegal drug, or otherwise introducing into the human body an illegal drug or
controlled substance.
Illegal drug:
a. Any drug or derivative thereof whose use, possession, sale, transfer, attempted sale or
transfer, manufacture, or storage is illegal or regulated under any federal, state, or local
law or regulation.
b. Any drug, including – but not limited to – a prescription drug, used for any reason other
than that prescribed by a physician.
c. Inhalants used illegally.
Under the influence: A state of not having the normal use of mental or physical faculties
resulting from the voluntary introduction into the body of an alcoholic beverage, drug, or
substance of abuse.
Employee Alcohol and Drug Policy

The foundation of our business practices is the establishment of a "zero tolerance policy" with
regard to alcohol and drug use in the work place. Any employee found to have violated this
policy, will be immediately terminated.
The manufacture, distribution, possession, sale, or purchase of controlled substances of abuse on
Company property is prohibited. Being under the influence of illegal drugs, alcohol, or
substances of abuse on Company property is prohibited. Working while under the influence of
prescription drugs that impair performance is prohibited.
The causes for termination shall include but not be limited to the following activities:
The use, possession, solicitation or sale of narcotics, other illegal drugs or prescription
medication without an authorized prescription on Alternative Center premises or while
performing job duties.
Conviction of a crime directly related to the possession, sale or distribution of narcotics,
other illegal drugs or unauthorized prescription drugs.
The presence of any detectable amount of prohibited substances in the employee's system
while at work, while on the premises of the Center, or representing the Center's in any
business related capacity. "Prohibited substances" include illegal drugs, alcohol, or
prescription drugs not taken in accordance with a authorized medical prescription given
to the employee.

The Center will conduct drug and/or alcohol tests in accordance with any or all of the following
procedures:
RANDOM TESTING: Employees may be selected for drug and/or alcohol testing at any
time during their employment with the Center.
FOR-CAUSE TESTING: The Center may ask an employee to submit to a drug and/or
alcohol test at any time it feels 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.
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 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.
Consistent with the rules listed above, any of the following actions constitutes a violation of the
Company’s policy on drugs and may subject an employee to disciplinary action, up to and
including immediate termination. Using, selling, purchasing, transferring, manufacturing, or
storing an illegal drug or drug paraphernalia, or attempting to or assisting another to do so, while
in the course of employment. Working or reporting to work, conducting Company business or
being on Company property while under the influence of an illegal drug or alcohol, or in an
impaired condition.
4.7 TOBACCO PRODUCTS

The use of tobacco products is not permitted anywhere on the Company’s premises.
4.8 INTERNET USE

Breakwater Alternative Treatment Center employees are allowed use of the Internet and e-mail
when necessary to serve our patients and conduct the Company’s business. Employees may use
the Internet when appropriate to access information needed to conduct business of the Company.
Employees may use e-mail when appropriate for Company business correspondence. Use of the
Internet must not disrupt operation of the company computer network. Use of the Internet must
not interfere with an employee's productivity. Employees are responsible for using the Internet in
a manner that is ethical and lawful. Internet messages are public and not private. Breakwater
Alternative Treatment Center reserves the right to access and monitor all files and messages on
its systems.

SECTION 5
WAGE AND SALARY POLICIES
5.1 WAGE OR SALARY INCREASES
Each employee’s hourly wage or annual salary will be reviewed at least once each year. The
employee’s review date will usually be conducted on or about the anniversary date of
employment or the date of the previous compensation review. Such reviews may be conducted
more frequently for a newly created position, or based on a recent promotion. Increases will be
determined on the basis of performance, adherence to company policies and procedures, and
ability to meet or exceed duties per job description and achieve performance goals (See Section
3.10, Performance Review/Planning Sessions). Although the Company’s salary ranges and
hourly wage schedules will be adjusted on an ongoing basis, Breakwater Alternative Treatment
Center does not grant “cost of living” increases. Performance is the key to wage increases in the
Company.
5.2 TIMEKEEPING
Accurately recording time worked is the responsibility of every non-exempt employee. Time
worked is the time actually spent on a job(s) performing assigned duties. Each client job is
assigned a job number as posted in the Employee Message Center. Employees are responsible
for accurately documenting their time spent on individual jobs. Breakwater Alternative
Treatment Center does not pay for extended breaks or time spent on personal matters. The time
clock is a legal instrument. Altering, falsifying, tampering with time records, or recording time
on another team member’s time record will result in disciplinary action, including termination of
employment. Authorized personnel will review time records each week. Any changes to an
employee’s time record must be approved by his/her supervisor. Questions regarding the
timekeeping system or time cards should be directed to the manager or president.
Time Cards – Non-exempt employees will be issued a time card on their first day of
employment. The employee will be given thorough instructions on usage and instructions on
what to do should a problem occur. Employees will be financially responsible for replacing the
card if it is lost or stolen.
5.3 OVERTIME
Breakwater Alternative Treatment Center is open for business 60 hours per week. Overtime
compensation is paid to non-exempt employees in accordance with federal and state wage and
hour restrictions. Overtime is payable for all hours worked over 40 per week at a rate of one and
one-half times the non-exempt employee's regular hourly rate. Time off on personal time,
holidays, or any leave of absence will not be considered hours worked when calculating
overtime. In addition, vacation time does not constitute hours worked. All overtime work
performed by an hourly employee must receive the supervisor’s prior authorization. Overtime
worked without prior authorization from the supervisor may result in disciplinary action. The
supervisor’s signature on a timesheet authorizes pay for overtime hours worked.
5.4 PAYDAYS
All employees are paid every two weeks. In the event that a regularly scheduled payday falls on
a weekend or holiday, employees will receive pay on the next day of operation. If a regular
payday falls during an employee’s vacation, the employee’s paycheck will be available upon
his/her return from vacation. Paychecks will not, under any circumstances, be given to any

person other than the employee without written authorization. Paychecks may also be mailed to
the employee’s address or deposited directly into an employee's bank account upon request.
SECTION 6
BENEFITS AND SERVICES
Breakwater Alternative Treatment Center offers a benefits program for its regular full-time and
regular part-time employees. However, the existence of these programs does not signify that an
employee will necessarily be employed for the required time necessary to qualify for the benefits
included in and administered through these programs.
6.1 GROUP INSURANCE

Breakwater Alternative Treatment Center offers the following health and life insurance programs
for REGULAR FULL-TIME employees (as determined by the carrier of the policies).
HEALTH INSURANCE
Coverage begins 90 days after employment commences.
The company pays 50% of the premium.
The employee pays 50 % of the premium.
The employee premium is paid through payroll deduction.
6.2 COBRA BENEFITS

The Federal Consolidated Budget Reconciliation Act (COBRA) gives employees and their
qualified beneficiaries the opportunity to continue health insurance coverage under the
Breakwater Alternative Treatment Center’s health plan when a “qualifying event” would
normally result in the loss of eligibility. Some common qualifying events are resignation,
termination of employment, or death of an employee; a reduction in an employee’s hours or
leave of absence, divorce or legal separation and a dependent child no longer meeting eligibility
requirements. Under COBRA, the employee or beneficiary pays the full cost of coverage at
Breakwater Alternative Treatment Center’s group rates plus an administration fee. Breakwater
Alternative Treatment Center provides each eligible employee with a written notice describing
rights granted under COBRA when the employee becomes eligible for coverage under
Breakwater Alternative Treatment Center’s health insurance plan. The notice contains important
information about the employee's rights and obligations.
6.3 SOCIAL SECURITY/MEDICARE

Breakwater Alternative Treatment Center withholds income tax from all employees' earnings and
participates in FICA (Social Security) and Medicare withholding and matching programs as
required by law.
6.4 VACATION
Paid vacation is available to regular full-time and regular part-time employees following their
first-year anniversary with Breakwater Alternative Treatment Center and is provided based on
the following calculation: During the first 2 (two) years of employment, vacation time will be
earned at the rate of .0192 hours per hour worked. Earned vacation can be taken after 1 (one)
year continuous employment. During the 3rd (third) through 5th (fifth) years of employment,
paid vacation time will be earned at the rate of .0384 hours per hour worked. During the 6th
(sixth) and following years of employment, vacation time will be earned at the rate of .0586
hours per hour worked. The vacation policy applies to all regular full-time employees. Paid

vacation time of regular employees will be earned on a fractional basis. Fractional vacation
weeks will correspond to the average number of hours worked during the preceding year.
Example: Employee “A” works 25 hours per week for 52 continuous weeks, 25 x 52 = 1,300
hours, Earned vacation equals 1,300 hours worked x .0192 = 25 hours. Earned vacation leave
cannot be taken before it is accrued and approved. Vacation may be taken in half-day increments
of time. Upon termination, unused earned vacation will be paid in a lump sum in the employee’s
final paycheck. Only one week paid vacation may be carried over from one calendar year to the
next. However, no more than one week of vacation may be taken at one time, except under
extraordinary circumstances. Requests for more than one week of vacation should be in writing
at least ninety days prior to the beginning of the requested vacation period.
6.5 RECORD KEEPING

The Human Resources Department maintains vacation days accrued and used. Each employee is
responsible for verifying his/her pay stub to make sure the correct amount of hours appear.
6.6 HOLIDAYS
Breakwater Alternative Treatment Center observes the following paid holidays per year for
all employees: New Year’s Day, Memorial Day, Independence Day, Labor Day, Thanksgiving
Day, and Christmas Day.
6.7 JURY DUTY/MILITARY LEAVE

Employees will be granted time off to serve on a jury or military leave without pay. However, all
regular employees both full-time or part-time will be kept on the active payroll until their civic
duties have been completed. A copy of the jury duty summons and all other associated
paperwork are required for the personnel file.
SECTION 7
EMPLOYEE COMMUNICATIONS
7.1 STAFF MEETINGS
Quarterly staff meetings will be held on the first Monday of each quarter. These informative
meetings allow employees to be informed on recent company activities, changes in the
workplace and employee recognition.
7.2 BULLETIN BOARDS

Bulletin boards placed in designated areas provide employees access to important posted
information and announcements. The employee is responsible for reading necessary information
posted on the bulletin boards.
7.3 SUGGESTION BOX

Breakwater Alternative Treatment Center encourages employees who have suggestions that they
do not want to offer orally or in person to write them down and leave them in the suggestion box.
If this is done anonymously, every care will be taken to preserve the employee’s privacy.
7.4 PROCEDURE FOR HANDLING COMPLAINTS
Under normal working conditions, employees who have a job-related problem, question or
complaint should first discuss it with their immediate supervisor. At this level, employees

usually reach the simplest, quickest, and most satisfactory solution. If the employee and
supervisor do not solve the problem, Breakwater Alternative Treatment Center encourages
employees to contact the Manager.
SECTION 8
ALTERNATIVE CENTER OVERSIGHT
8.1 INTRODUCTION
The Alternative Center (Center) shall have an on-site manager during all hours of operation. It is
anticipated that the Alternative Center will be open from 10 am to 7 pm, seven days a week.
After hour contact information will be provided to local and state police and fire officials and to
the Department of Health and Senior Services. The manager shall conduct an inventory of
medical cannabis products, and all processed marijuana, at the beginning of each day, prior to the
dispensing of any medical cannabis and again at the end of the day. All inventory data will be
entered into an electronic barcode tracking inventory control system. By using an inventory
control management software system, our barcode record system will update our inventory based
on each delivery and transaction made throughout the operating day. Breakwater Alternative
Treatment Center will use a bridge between the inventory control and POS system to the security
video and monitoring system. This means that all activity recorded is overlaid onto the recorded
video. This process is aimed at addressing any discrepancy discovered that is not consistent with
the inventory and recorded sales.
8.2 DAILY & WEEKLY DUTIES

On a daily basis, the manager shall verify that the security alarm system is operational and that
each employee is in possession of their company issued personal alarm panic button. The
manager shall personally verify the eligibility of each patient to receive medical cannabis and
shall confirm said eligibility with the Department of Health and Senior Services. The manager
will prepare weekly reports indicating the number of patients seen, the type and quantity of
medical cannabis dispensed and the gross revenue generated. All Alternative Center and the
cultivation site reports will be submitted electronically to the President on a weekly basis.
Breakwater Alternative Treatment Center will conduct random site visits at each Alternative
Center to ensure compliance with the stated policies.
8.3 OPEN DOOR POLICY

The Breakwater Alternative Treatment Center and the cultivation site will have an open door
policy regarding inspections. Breakwater Alternative Treatment Center welcomes any input from
state officials that may result from these inspections.
SECTION 9
SALES DEPARTMENT
9.1 OPERATIONS MANUAL OVERVIEW
This section delineates the policies and procedures for the Sales Department of this dispensary.
All employees working in the Sales Department must follow these policies and procedures.
9.2 THE ROLE OF THE SALES DEPARTMENT


The role of the Sales Department is to provide outstanding patient service by providing
medicine, product knowledge, and absolute accuracy in the sales process. Every patient should
walk out of the dispensary saying, “That was GREAT. I can’t wait to go back again.” It is each
Sales Associate’s responsibility to deliver a calm, unhurried, fully informative experience to
every patient, utilizing the “4 Steps of a Sale” every time. Since the dispensary is open from
10am until 7pm every day, Sales Associate shifts tend to be long and staff members are on their
feet for most of the day. However, the opportunity to engage with and serve patients can be a
deeply rewarding experience.
9.3 PRODUCT KNOWLEDGE

An integral part of providing exceptional patient care is having extensive knowledge of the
medicine and products available at the dispensary. There is a base of product knowledge that all
Sales staff members must possess before completion of their initial training.
Sales Associates must continue expanding their knowledge of the Cannabis product and the
industry as a whole. After the first 8 shifts (2 weeks) at the dispensary, in addition to basic
product knowledge, associates should also know the most popular products requested by
patients, the more common strains found at the dispensary, and the differences in each of the
concentrates. Beyond that, Sales Associates also will need to attend a mandatory once-a-month
Product Information Class, as well as completing Product Knowledge Reviews every 90 days.
9.4 SALES FLOOR LAYOUT

The Sales Floor is comprised of individual POS workstations. Each Sales Associate is assigned
to only one station at a time. Workstation assignments vary from shift-to-shift, but generally
remain the same within a shift.
Each workstation is comprised of a POS screen and cash register, as well as a small freezer for
edibles and a set of shelves for non-refrigerated edibles and supply storage. All workstations are
numbered. In addition to the individual POS stations, there are glass Display Cases.
Depending on the number of Display Cases, some workstations may share a display case
between them. Each display case displays only one (1) sample of every product available, with
few exceptions. Generally speaking, the display contents are not sold to patients, but again, there
are exceptions made on a case-by-case basis. Discuss details with a member of Sales
Management. All display cases are numbered.
9.5 CLEANLINESS & ORGANIZATION

Each Sales Floor workstation should be kept clean, organized, and stocked, with each Sales
Associate expeditiously maintaining each station between patients or before calling another
patient over for assistance. When a transaction is complete, any displayed inventory sold to the
patient must be replaced or put on request to the Inventory Manager before assisting the next
patient.
9.6 RECORD KEEPING AND PATIENT CONFIDENTIALITY
Prior to dispensing any medical cannabis, the patient's use history will be reviewed to insure that
only the amount of medical cannabis permitted by law is actually dispensed. The computer
software will "flag" the patient's record if the amount of marijuana purchased is in excess of the
recommended dosage.
All medical cannabis dispensed and all other products sold will have barcodes to insure accurate
record keeping. The employee dispensing medical cannabis will start the purchase transaction

process by scanning the product's barcode. The scan will produce a product image on the
employee's computer screen, simultaneously the transaction will be video digitally recorded as
well as key stroked. If the product needs to be weighed it will be placed on the scale and the POS
software makes a record. The printed record will then be placed in the patient's profile, the date
and time recorded and the quantity dispensed. The total amount dispensed will then deducted
from the patient's allowable medical cannabis quantity. All paper purchase and sales records will
be filed and retained for a period of twenty-four months.
Breakwater Alternative Treatment Center will fully comply with healthcare patient record
privacy standards by never releasing any personal data that could lead to the identification of an
individual patient. Breakwater Alternative Treatment Center believes one of the biggest
deficiencies in the industry is a lack of relevant, comprehensive information about the actual
operation of a Medical Marijuana business. Breakwater Alternative Treatment Center intends to
address this deficiency by integrating all aspects of business operations under a single, user-
friendly computer management system. Breakwater Alternative Treatment Center has researched
a number of companies in the industry that have designed software systems exclusively for the
medical marijuana industry and found only one that has a reliable and technologically forward-
thinking HIPAA compliant POS (Point Of Sale) system that meets our high standards.
Breakwater Alternative Treatment Center believes this system provides requisite tools necessary
to control security issues, employee records and the confidentiality requirements of patient
records the business demands.
Breakwater Alternative Treatment Center will provide a unified and biometrically secure HIPAA
(Federal Health Insurance Portability and Accountability Act of 1996) compliant registry of
Medical Marijuana patients. Patients will enroll at the Breakwater Alternative Treatment Center
after receiving their doctor's initial recommendation or after renewing their recommendation.
Breakwater Alternative Treatment Center will comply with the confidentiality record keeping
requirements for health care information under New Jersey law including the Health Information
Exchange Act. Breakwater Alternative Treatment Center will encourage its patients to
voluntarily sign up to participate in New Jersey’s Statewide Health Information Exchange
program.
Breakwater Alternative Treatment Center will follow international standards-based best practices
in the securing of sensitive patient data (SPD). The Breakwater Alternative Treatment Center
will utilize a layered defense to protect SPD. SPD is defined as those data elements protected
under HIPAA, PCI, and state and federal privacy laws. Information systems containing SPD will
be physically and logically segregated from POS systems and the Breakwater Alternative
Treatment Center web site infrastructure. Internal and external firewalls and a DMZ will protect
the internal network from external attacks against the web site.
The hardware housing SPD will remain in a locked office with access limited to Breakwater
Alternative Treatment Center management. Video surveillance will be put in place for the office
entrance, with the recordings being handled in the same manner as those described in the
physical security component of this application. Logical access to SPD will also be limited to
those Breakwater Alternative Treatment Center employees who require this information to
complete their job function. All access to SPD will be logged and monitored on a regular
schedule.

A local area network will be established to connect the POS system to the web site. This will
allow patients and employees the ability to view custom information related to their Breakwater
Alternative Treatment Center interactions. These systems will contain Breakwater Alternative
Treatment Center patient identifiers for authentication purposes and general data on the patient’s
prior interactions, but will not contain those elements designated as sensitive patient data.
Patients can consent to exposing more of their personal information to Breakwater Alternative
Treatment Center staff if they so desire by completing and signing a request form. This will
allow Breakwater Alternative Treatment Center to provide customized interactions and enhanced
support to patients based upon their personal preferences.
9.7 DISPENSING MEDICAL MARIJUANA

All registered qualifying patients or their registered primary caregiver must present their valid
state issued patient registry identification cards and be confirmed by our system as eligible
recipients, prior to the dispensing of any medical cannabis. The patient will be required to
electronically sign for the medical cannabis dispensed.
As a licensed dispensary it is our responsibility to take the utmost care when it comes to safely
dispensing medical cannabis to our patients. Breakwater Alternative Treatment Center will take
an organic and pesticide free approach to growing medical cannabis. To further ensure quality
and provide full transparency, all Breakwater Alternative Treatment Center's medical cannabis
will be laboratory tested and the test results will be made publicly available at dispensary
locations and on our website. To ensure safety, the manager will perform daily check-ups prior
to operating hours. The check-up will consist of the following activities:
Check all dispensable products for consistency of labels based on strain, potency, and
quantity for usable cannabis.
Confirm that proper ingredient labels and allergic warning labels are present on each
individual medical cannabis product.
Ensure that all medical cannabis shall be dispensed in clear sealed containers with labels
specifying the product, its full analysis and amount.
Confirm that each container has been assigned a barcode that will enable it to be scanned
in order to process sales and inventory information.
Showing Samples of Medicine to Patients

All samples should be selected from the re-sealable packages contained in the inventory
cabinets. The sample in the display case should only be purchased if it is the last
remaining quantity of that strain.
Sales Associates may have only 3 items/packages out on the sales counter at any given
time.
This applies to every product inventoried at the dispensary.
When the patient selects the type of product desired, place 3 packages of that product on
the counter from which the patient can choose. If the patient does not approve of any of
the three selections, put those packages away and offer the patient another 2-3 packages
from which they may make their selection. Continue presenting product as needed until
the patient chooses a package, or as many times as seems reasonable.

As a caregiver, Breakwater Alternative Treatment Center and its employees have the
responsibility to monitor the health of our patients. Patients will be encouraged to consult often
with their doctor regarding the amount of marijuana consumed and to report any adverse side
effects. The consumption of medical cannabis by a registered patient will be prohibited within or
on the property of a dispensary site.
Purchasing Limits
This dispensary has established Purchasing limits to prevent the resale of medicine and diversion
into the illegal market. All staff must abide by these limits at all times. No more than 2 ounces
per thirty- day period will be dispensed to any patient.
Even if these limits are not exceeded, if any staff member EVER suspects a patient may intend to
resell their medicine, they should halt the transaction and refer the patient to the Member
Services manager on duty.
There are stringent controls that will be put in place by way of a Point of Sale/Inventory tracking
system, tools and forms for accounting and verification, and tasks and processes that will ensure
accountability at every stage, such as verifying product identification and weight measurements
in multiple departments (Cultivation, Inventory, Processing and Sales).
We will enforce the purchasing limits set forth by New Jersey state law as a policy of the
Alternative Center (currently no more than 2 ounces of usable marijuana per qualifying patient or
caregiver during a 30-day period). These purchasing limits will be communicated to patients in
our Patient Handbook and verbally during the new patient orientation session. Additionally,
employees will be trained on what the limits are and how to communicate and enforce those
limits with patients at the time of sale. The Center will track the purchases of each patient within
the member database and POS system. Sales associates will be able to determine if patients have
reached the state’s limit for a 30-day period.
Frequent inventory taking of the usable medical marijuana on hand and the number of plants
under cultivation will be measured and compared to the number of patients being serviced to
ensure that only the required amount of medical marijuana is being produced.
Breakwater Treatment Center Discounts

Breakwater is committed to providing medicinal marijuana at low or no cost to patients for
whom paying full price would constitute an actual and substantial economic hardship. This
policy will be very liberally applied but will require patients and caregivers to document their
lack of financial resources.
Breakwater expects to set the following Discounts for its patients and caregivers:
1. Terminal Patients That Have One Year or Less To Live
Free services include assistance with doctor’s recommendations, transportation to
doctor’s office, referral and medical counseling and free medicine. Medicinal cannabis
shall be provided free to such patients (within the legal dispensing guidelines and terms
of recommendation).
2. Cancer and AIDS Treatment Center Access Program for Patients and Caregivers
A 50% discount per month ($120-$130 per ounce).

3. State, Federal, and Military Disability Patients and Caregivers
A 50% discount per month ($120-$130 per ounce).
4. Provide Medicine, on an Individual Income Verified Basis, Free-of-Charge or on Sliding

Scale to:
Non-ambulatory patients with serious illnesses and seriously ill patients who cannot
afford medicinal cannabis. Breakwater will match a patient’s contribution amount so that
they can purchase their needed medicinal cannabis. No patient or caregiver in need will
be turned away and we will give free medicine at the time of their visit (within the legal
dispensing guidelines and terms of recommendation) until they are able to purchase it in
the future.
Pre-Sales
We cannot do pre-sales, meaning that patients are not permitted to pre-pay for items that are not
in stock. If a patient requests a pre-sale, tell them that as Company policy delineates, we cannot
do pre-sales because we cannot anticipate when or if a product will be in stock. If the patient
wants more information, notify the Manager-On-Duty.
9.8 PATIENT ADMITTANCE, DISENROLLMENT AND ASSUMPTION OF RISK

Upon arrival, patients must show Safety their ID and documentation and then check in at
Reception before entering the Sales Floor. Patients will wait in line in the line cue until the next
Sales Associate is ready to assist them. Patients exit the dispensary at the same door they entered.
STEP 1: GREETING
As a patient approaches your station at the counter, smile, make eye contact, and with great
warmth and friendliness, greet them by saying something like, “Hi! Welcome to The Breakwater
Alternative Treatment Center. How are you doing today?” When the patient responds, LISTEN.
Be engaged. Sales Associates have one opportunity to make a first impression and this is it! Each
staff member’s personal demeanor, smile, tone and level of each voice, the personal touches
added to any patient interaction; all make a huge difference in the experience a patient has when
they approach the counter.
STEP 2: SELECTION
In the “Selection” stage, associates should determine what the patient WANTS (type of
medicine), NEEDS (quantity), and can AFFORD (price). Use “primer phrases” to begin the
selection process. For example:
− “Have you been here before?”
− “Do you know what you’re looking for today?”
− “Are you looking for anything in particular today?”
STEP 3: PURCHASE
Once all items have been selected, do a final run-through with the patient, checking every item
by name and size to assure it's what the patient wanted to purchase.
STEP 4: PAYMENT

Verbally verify the total amount due. When verbally verifying the total, out of respect for patient
privacy, use a voice level that doesn’t broadcast the information to others.
The orientation of each patient accepted by Breakwater Alternative Treatment Center will
include a training session regarding our right to involuntarily disenroll any patient our list of
qualifying patients for engaging in unacceptable behavior. Unacceptable behavior shall include
appearing at the Alternative Center under the influence of alcohol of drugs, failure to comply
with a directive issued by a member of the staff or engaging in any other conduct not permitted
on the premises. We may also disenroll a patient for "disruptive behavior." Disruptive behavior
is defined as behavior that substantially impairs our ability to arrange or provide care for you or
another qualifying patient member. Patients will be further advised that other Alternative
Treatment Centers may decline your enrollment if you have been disenrolled for disruptive
behavior.
In all cases of disenrollment, Breakwater Alternative Treatment Center will be required to

provide proper notice to you in writing and give you the opportunity to appeal the decision prior
to disenrollment. The initial decision regarding disenrollment shall be made by the manager of
the Alternative Center and any appeal shall be heard by the board of directors.
Each patient must agree to each and all of the following in connection with the registration
policies of Breakwater Alternative Treatment Center and receiving Medical Marijuana.
1. I am an adult, at least 18 years-of-age, and am voluntarily purchasing medical marijuana

and I assume all risks of illness, injury, death, damage and/or loss to myself or my
property that might result.
2. I warrant that I have received a valid form of medical marijuana documentation and
matching identification from the State of New Jersey.
3. On behalf of myself and my personal representatives, heirs, executors, administrators,
agents and assigns, I hereby release and discharge in advance Breakwater Alternative
Treatment Center (and its owners, members, employees, instructors, agents,
representatives, successors and assigns) from any and all liability, even if that liability
arises out of negligence and/or carelessness on the part of the persons or entity mentioned
above.
4. My assumption of risk, waiver and release of liability encompasses, but is not limited to:
death, bodily injury, illness, damage, theft and/or loss of personal property while on the
premises which occurs as a result of my purchasing and/or consumption of medical
marijuana and my time spent at Breakwater Alternative Treatment Center.
I have carefully read this Assumption of Risk, Waiver and Release of Liability, Including
Negligence. I hereby agree to assume all of those risks and to release and hold harmless all of the
persons or entity mentioned above who through negligence or carelessness would otherwise be
liable to me or to my heirs or assigns for damages.
9.9 SALES OPENING CHECKLIST

¾ Upon arrival
Do not clock in yet. Store your non-essential personal items as appropriate. No backpacks
or other bags are allowed on the sales floor or break room floor.

Are you the first sales employee to arrive? Notify the IM so they have inventory shelving
ready.
Check the posted schedule for any changes. If you haven’t already, approve your
schedule by initialing in the space requested. If there’s a problem with the schedule,
discuss it with the MOD.
Notify/remind the manager on duty of any important issues, such as break restrictions,
appointments, or personal needs for the day’s shift.
¾ Clock in. Once you’ve stored your personal belongings and are ready to start working, you
may clock in.
¾ Station Assignment. Ask the manager on duty for your station assignment.
¾ Open Inventory Cabinet Doors. Open the doors to your station’s inventory cabinet (wide;
back against the cabinet) so that it is ready to receive inventory once the racks are rolled out
to the sales floor.
¾ Rack #1: Display Shelves. A large metro shelving unit on wheels holds all display case racks
for each station’s display case. The rack should be on the sales floor when you arrive; if not,
inform Inventory or the MOD and it will be brought out. The display racks are labeled with
the station # to which they belong.
Remove your station’s display racks one by one, placing them into your station’s display
case.
When the metro shelving has been emptied, roll it back to the Inventory Department for
storage.
¾ Rack #2: Edibles. A cart containing each station’s edibles will be wheeled out to the sales
floor.
¾ Rack #3: Workstation Inventory Cabinet. Lastly, the inventory cabinet racks are wheeled out.
They are large metro shelving units. Each workstation has its own rack. Your station number
will be called out when your rack is approaching. The racks are wheeled in order, starting
with Workstation 1.
¾ Rack #4: Tills. Once all inventory is on the sales floor, the tills will be rolled out on a small
cart.
¾ Sign On to POS Workstation. If there are connectivity issues resolve, with management now.
¾ Stock Workstation. Make sure that your workstation is fully stocked and that supplies are
neat and orderly. If you notice we are low on the back stock of any items, let the MOD know.
¾ Cleanliness & Organization of Workstation. Ensure cleanliness and exceptional visual
presentation of your display case, workstation shelving, and inventory cabinet.
¾ Inventory Review. Each day Inventory adds new items into the system. Carefully check your
cabinet bins for new items. Familiarize yourself with each new item by looking at it, smelling
it, memorizing the name and price, and asking management about product characteristics as
needed. It is your responsibility to do this EVERY DAY so that you can share your
knowledge with patients.
¾ Break Assignments & Pre-Opening Meeting. Once your workstation is ready for patients,
notify the manager on duty. The MOD will give you your break assignments for the day.
¾ When the entire sales floor is ready for patients, the MOD will call all associates into the
Employee Lounge for a brief Morning Meeting to discuss new policies/procedures, review
old ones, talk about new products, etc.
9.10 SALES CLOSING CHECKLIST

¾ Dispensary Closing Confirmation.
¾ Do not begin any closing duties before the manager on duty gives the OK to Safety, and the
Safety team has provided the “clear” call.
¾ Break Down Display Cases.
¾ The edibles cart and display rack cart will be moved from the back to the sales floor.
¾ Break Down Inventory Cabinets.
¾ Once all display cases are empty and inventory has been transferred to the Display Rack, the
Inventory Cabinet Racks will come out one by one, starting with the last numbered rack and
continuing in sequence to Rack 1. As each rack is brought out or in to the sales floor, they
must be verbally and loudly called out to ensure safety. Listen for your station’s Inventory
Cabinet Rack to be brought out to the sales floor.
¾ Complete and Submit Paperwork.
¾ Cleanliness & Organization.
¾ Once all racks have been removed from the sales floor, do a final check of your workstation,
your inventory cabinet from top shelf down to bottom, underneath the cabinet, underneath
the POS station, and the general vicinity.
¾ Clock Out.
¾ Clock out then gather your personal belongings.
SECTION 10
MEMBER SERVICES DEPARTMENT
This section delineates the policies and procedures for the Member Services Department at this
dispensary. All employees working in the Member Services Department must follow these
policies and procedures.
10.2 ROLE OF THE MEMBER SERVICES DEPARTMENT

The overarching purpose of the Member Services department is to act as an ambassador for
patients and the dispensary, to educate and inform patients about the dispensary and to ensure the
dispensary is in strict compliance with all city, state, and federal regulations with regard to
patient registration and dispensary access.
10.3 UPHOLDING THE MISSION & VISION STATEMENTS

The Member Services Department has a tremendous impact on fulfilling this dispensary’s
Mission Statement, particularly:
Provide safe, dignified and affordable access to medical cannabis for approved patients in
the State of New Jersey.
And the Vision Statement, which states:
The Breakwater Alternative Treatment Center envisions being a community-oriented,
nonprofit organization that provides New Jersey patients in need with safe access to high
quality medicine, wellness services and educational resources.
We foresee the Breakwater Alternative Treatment Center serving as a model facility that
operates in full compliance with the law, maintains the highest standards of professional
operation and truly serves the needs of patients in our state.

10.4 MEMBER SERVICES DEPARTMENT STRUCTURE
The Member Services Department is comprised of two main “stations:”
1. Reception
2. New Patient Orientation
Reception
A Member Services Associate working in Reception is primarily responsible for the following:
Greet & check in patients as they enter the building, providing excellent patient care, full
compliance, and database accuracy. (This is the most routine task of the Receptionist).
Answer the phones, receive and transfer calls to staff, and adhere to company policies
regarding what can and cannot be shared over the phone.
Maintain the aesthetics of the reception area, ensuring a clean, organized, and well-
stocked environment. Also ensure the overall aesthetic meets our standard of excellence
(flowers, etc.)
New Patient Orientation

A Member Services Associate working in New Patient Orientation is primarily responsible for
the following:
Orient new patients to the dispensary and Company by ensuring an exceptional first
impression and educating new patients on company policies, procedures, and the
dispensary facilities.
Register New Patients.
Enter new patients into the patient database with absolute accuracy.
Ensure Legal Compliance.
Verify medical status of patients and maintain all compliance-related documentation.
10.5 MEMBER SERVICES DEPARTMENT SCHEDULING

There are two Member Services Department stations that must always be covered during
operating hours. They are MOD and Reception. So that breaks may be taken, a third Member
Services Associate is also scheduled for every shift. Depending on the demands of the
department, more Member Services Associates may be scheduled to work during a shift. All
personnel covering these positions and shifts must be a qualified member of the Member
Services Department.
10.6 AESTHETICS, CLEANLINESS, & ORGANIZATION

Member Services Associates are responsible for ensuring the reception desk, lobby, Member
Services office, and retail lobby always reflect our standards for excellence with regard to
cleanliness, organization, and overall aesthetics.
10.7 MEMBER SERVICES OPENING CHECKLIST

¾ Upon arrival
Do not clock in yet. Store your non-essential personal items as appropriate. No
backpacks or other bags are allowed on the Member Services office floor, behind the
Reception desk, or on the break room floor.

discuss it with the MOD.
Notify/remind the Member Services Manager-on-Duty of any important issues, such
as break restrictions, appointments, or personal needs for today’s shift.
¾ Clock in
Once you’ve stored your personal belongings and are ready to start working, you may
clock in.
¾ Morning Meeting.
The entire Member Services staff meets in the employee break room at 9:30 every morning.
During the meeting, post assignments and break schedule will be designated by the Member
Services Manager On Duty. Also covered in this meeting are new policies and procedures,
special assignments for the day, and a review of existing policies a needed.
¾ Reception & Member Services.

Turn on the Reception and Member Services office computers and monitors.
Verify that the database is working properly on all computers.
Verify pending patients in the New Patient Verification folder.
¾ Sign On to Computer Workstation.
Sign on to your computer workstation if applicable.
10.8 MEMBER SERVICES CLOSING CHECKLIST

¾ Dispensary Closing Confirmation.
Do not begin any closing duties before the Manager-On-Duty gives the OK to Safety, and the
Safety team has provided the “clear” call.
¾ Member Services Office.
Remove all Patient Registration Forms from the Inbox. Count and total the number of
new patients for the day. Review for completion.
File the Registration Forms in the Patient Registration Binder in the Member Services
office.
Close all programs and turn off the computer monitor.
Close the window blinds in the Member Services office.
Straighten the Member Services office (discard water bottles, straighten/organize
loose items, etc.).
¾ Reception
File the Healing Services Sign-up Sheets from today.
Enter Healing Services appointment no-shows into the spreadsheet.
Shut down both Reception computers.
Straighten the Reception Desk.
Close the window blinds in the Reception lobby.
Restock the Literature Display Rack.
¾ Clock Out.
Clock out and then gather your personal belongings.

SECTION 11
PROCESSING DEPARTMENT
This section delineates the policies and procedures for the Processing Department of this
dispensary. All employees working in the Processing Department must follow these policies and
procedures.
11.2 THE ROLE OF THE PROCESSING DEPARTMENT AND SAFE DISPENSING

Every morning, hours before the dispensary opens, the Inventory Department determines which
medicines and products should be available at the Sales Counter (and how much of each). Once
that decision is made, Inventory provides to the Processing Department bulk units of each of
those medicines and products. It is the job of the Processing Department to take each bulk unit
and divide it into individually packaged units for sale. This is what we refer to as “Processing”
the medicine.
The processing of bulk bud and bulk concentrates is the most complicated processing task.
Broadly speaking, it includes weighing the medicine into smaller, sellable units, inspecting the
medicine to ensure quality, and placing the weighed and inspected medicine into individual
labeled packages.
Our employee-training curriculum will provide critical procedures and instruction to employees
to ensure all systems are in place to dispense medical cannabis safely. These systems also ensure
that every employee understands how to implement these systems accurately. In addition, there
are sanitation, product quality, and quantity accuracy checkpoints to ensure that errors or
problems are caught and remedied long before patients receive their medicine.
Our Processing Department utilizes a Product Quality Assurance Program that provides weight
charts and other tools to ensure accuracy as well as photographs of what to look for when
determining if the medicine being processed meets our high quality standards. Close range
photographs depicting mildew, mold, wet medicine and other problems are utilized for
prevention purposes. Additionally, strict sanitation standards are built into each processing stage,
including the use of hair nets, sanitized uniforms, frequent and proper hand washing, gloves for
handling medicine, and sanitation of containers and scale platforms.
One of the most important tools we will implement is our Laboratory Analysis Program. This
testing program has two main components: safety screening and potency quantification. Safety
screening analyzes and detects contamination of pathogenic molds that can threaten the health of
patients with compromised immune systems. Potency quantification provides the percentages of
three major cannabinoids: THC, CBD and CBN. Later stages of the program will include the use
of anonymous patient surveys to develop a comprehensive database of the efficacy of medical
cannabis.
Patients are able to access the testing results in three ways: labels in display cases, labels on
products, and a book of complete test results. Labels include percentages for THC, CBD and
CBN, and are posted in medicine display cases, as well as affixed to the products themselves. A
book containing complete spectrometry reports for each product is available at the service
counter for those patients who desire more detailed analytical results.

11.3 TYPICAL DAY IN PROCESSING
A typical day in the Processing Department begins at 8:30am when a member of management
prepares for the shift. That includes:
Turning on the computer.
Logging in to the POS and electronic communication modes.
Calibrating the triple-beam scale.
Protecting Patients through Quality Assurance
Processing is the last point of careful inspection before medicine gets to patients.
Processing Associates ensure that medicine is free from mold, bug feces, hair, too much
moisture, excessive butane fumes, etc. The company’s commitment to the quality assurance
process is critical to patient safety.
Extraordinary Medical Care, Honesty, and Friendliness

Processing department staff members express their commitment to extraordinary medical
care, honesty, and friendliness through the following:
Ensuring actual medicine weights are consistent with the advertised weights on the
packaging, and that the actual contents of each package are what the packages say they
are.
Ensuring safe, quality medicine through careful inspection and adherence to sanitation
guidelines.
Taking care in the visual presentation of our medicine, which is an outward expression of
our respect for our patients and the medicine we provide them.
11.4 MISC. PROCESSING ROOM POLICIES

Your scale must be properly calibrated and leveled at all times.
Always clean and sterilize your utensils and surfaces that come in contact with the
medicine.
Always wear a hairnet and latex gloves when coming in contact with the medicine.
Never have more than 1/4 lb of bulk bud in the processing pan at any given time. This
helps prevent the loss of water weight due to evaporation.
Never place medicine directly on the scale platform. This ensures weigh accuracy and
longevity of the scale.
11.5 INDIVIDUAL PROCESSING “STYLES”

Every Processing Associate in the Processing Department has the exact same overall objective:
Consistently place the precise weight of quality medicine in the correct, properly labeled
packaging, and do this in the least amount of time possible.
Although the objective is the same, the method for achieving this objective may be quite
different from one employee to the next. Each Processing Associate discovers his or her
own unique “processing style” during the first few weeks and months of working in the
department.
11.6 PROCESSING OPENING CHECKLIST

¾ Upon arrival
Do not clock in yet. Store your non-essential personal items. No backpacks or other bags
are allowed on the processing or break room floor.

discuss it with your supervisor.
Notify/remind your supervisor of any important issues, such as break restrictions,
appointments, or personal needs for today’s shift.
¾ Clock in
Once you’ve stored your personal belongings and are ready to start working, you may
clock in.
Prepare Work Station. Ensure you have all of the supplies you will need and that your
workstation is clean and organized.
Gram Bag Labels. Begin labeling gram bags while your supervisor is preparing the day’s
projects.
Get Project Assignment(s). Check in with your supervisor about your projects for the
day.
Receive Project & Bar Codes. Your supervisor will give you your project along with the
appropriate bar codes.
Begin the labeling for your project.
Calibrate your scale before beginning the project.
Put on your hair net and latex gloves before handling medicine.
Begin the project, turn it into your supervisor when completed, and rotate to your next
assigned project.
11.7 MANAGER ONLY DUTIES

Check in with Inventory Manager about POS Inventory Item List to determine inventory
levels and project priorities for the day.
Calibrate triple beam scale.
Daily log of cart contents.
Figure out the unit ratio per project; enter that information into the computer and print bar
codes.
Assign projects with input from the Processing Associates based on their interest and
skill level.
Split projects as needed (if they are too large to process); data entry of breakdowns.
11.8 PROCESSING CLOSING CHECKLIST

Clean & Sanitize Workstation.
Stock, organize, and put away supplies as needed.
Sanitize utensils, trays, baskets, and scale and put them away.
“Air can” the crevices so that they can be vacuumed by the cleaning crew in the morning.
Sanitize all workstation surfaces.
Disconnect Scale.
Turn Off Workstation Light.
Delegated Tasks. Check in with your supervisor about any tasks they need completed,
such as restocking, trash compacting, shredding, etc.
Clock Out. Clock out and then gather your personal belongings.
11.9 MANAGER ONLY DUTIES

Oversee the cleaning and sanitizing of the Processing Room.
Delegate to Associates storage room restocking as needed.
Verify the Daily Log against projects completed.
Ensure nothing is left in the Project Bin; if yes, send back to Inventory.
Check in with Inventory to resolve discrepancies and enter adjustments in the computer
system.
SECTION 12
HUMAN RESOURCES &
EMPLOYEE SECURITY POLICIES
12.1 EACH EMPLOYEE'S RESPONSIBILITY
Safety can only be achieved through teamwork. Each employee must practice safety awareness
by thinking defensively, anticipating unsafe situations and reporting unsafe conditions
immediately.
Please observe the following precautions:
1. Notify your manager of any emergency situation. If you are injured or become sick at
work, no matter how slightly, you must inform your manager immediately.
2. The use of alcoholic beverages or illegal substances during working hours will not be
tolerated. The possession of alcoholic beverages or illegal substances on Company
property is forbidden.
3. Use, adjust and repair machines and equipment only if you are trained and qualified.
4. Know the proper lifting procedures. Get help when lifting or pushing heavy objects.
5. Understand your job fully and follow instructions. If you are not sure of the safe
procedure, don't guess; just ask your manager.
6. Know the locations, contents and use of first aid and fire-fighting equipment.
7. Wear personal protective equipment in accordance with the job you are performing.
Comply with OSHA standards and/or applicable state job safety and health standards as written
in our safety procedures manual.
A violation of a safety precaution is in itself an unsafe act. A violation may lead to disciplinary
action, up to and including discharge.
12.2 DOOR PROTOCOL
12.3 WORKPLACE VIOLENCE

Violence by an employee or anyone else against an employee, manager or member of
management will not be tolerated. The purpose of this policy is to minimize the potential risk of
personal injuries to employees at work and to reduce the possibility of damage to company
property in the event someone, for whatever reason, may be unhappy with a company decision or
action by an employee or member of management.

If you receive or overhear any threatening communications from an employee or outside third
party, report it to your manager at once. Do not engage in either physical or verbal confrontation
with a potentially violent individual. If you encounter an individual who is threatening
immediate harm to an employee or visitor to our premises, contact an emergency agency (such as
911) immediately.
All reports of work-related threats will be kept confidential to the extent possible, investigated
and documented. Employees are expected to report and participate in an investigation of any
suspected or actual cases of workplace violence and will not be subjected to disciplinary
consequences for such reports or cooperation.
Violations of this policy, including your failure to report or fully cooperate in The Company's
investigation, may result in disciplinary action, up to and including discharge.
12.4 WORKPLACE SEARCHES

To protect the property and to ensure the safety of all employees, patients and the organization,
The Company reserves the right to conduct personal searches consistent with state law, and to
inspect any packages, parcels, purses, handbags, brief cases, lunch boxes or any other
possessions or articles carried to and from Company property. In addition, The Company
reserves the right to search any employee's office, desk, files, equipment or any other area or
article on our premises. In this regard, it should be noted that all offices, desks, files, equipment,
etc. are the property of The Company, and are issued for the use of employees only during their
employment. Inspection may be conducted at any time at the discretion of The Company.
Persons entering the premises who refuse to cooperate in an inspection conducted pursuant to
this policy may not be permitted to enter the premises. Employees working on or entering or
leaving the premises who refuse to cooperate in an inspection, as well as employees who after
the inspection are believed to be in possession of stolen property or illegal substances, will be
subject to disciplinary action, up to and including discharge, if upon investigation they are found
to be in violation of The Company's security procedures or any other company rules and
regulations.
12.5 NO WEAPONS IN THE WORKPLACE

Possession, use or sale of weapons, firearms or explosives on work premises, while operating
company machinery, equipment or vehicles for work-related purposes or while engaged in
company business off premises is forbidden except where expressly authorized by The Company
and permitted by state and local laws. This policy applies to all employees, including but not
limited to, those who have a valid permit to carry a firearm.
Employees who are aware of violations or threats of violations of this policy are required to
report such violations or threats of violations to your manager immediately.
Violations of this policy will result in disciplinary action, up to and including discharge.
12.6 IN AN EMERGENCY



Chief Product Producer
Will be responsible for all marijuana lozenge and products. The Chief Product Producer must
follow the recipes and fully disclose all ingredients used. In conjunction with a cultivation
assistant, the baker is responsible for all packaging of products and ensuring proper labels are
attached.
Product Producer Assistant

Will take direction from their managers (Chief Product Producer & Chief Cultivator) as well as
follow directions from senior management. Job duties include following the recipes during
processing, fully disclose all ingredients used and packaging of all medical cannabis.
Security Guard
Medical Marijuana Transport Team

(Security Guard / Driver & Transport Handler)
It is Breakwater Alternative Treatment Center's intention to employ retired law enforcement
officers for the role of transporters. Law enforcement personnel are very experienced in keeping
detailed records and at data entry. Additionally, they are trained in personal safety issues and the
importance of safety in the workplace.
The team consists of two like qualified individuals (with a clear understanding of roles):
Security Guard / Driver: Will be responsible for the transportation (driving) of medical
cannabis from the cultivation site to the dispensary site(s). This position requires the
individual to always remain with the vehicle when assets are being transported unless
accompanying the Transporter for a pickup or delivery.
Transport Handler: Will be responsible for handling the assets (medical marijuana) of

medical cannabis from the cultivation site to the dispensary site(s). This position requires
the individual to manage and keep track of all records (including hard copies).
Manager of Alternative Center

Will be responsible for the supervision of all Alternative Center employees to assure that they
are properly performing their duties. The manager will also be responsible for preparing weekly
inventory and sales reports. In addition, the manager will be the primary person responsible for
the reporting of a fire, intrusion or other emergency.
Alternative Center Employees

Will be required to communicate clearly and show compassion for all patients entering the
facility. A bi-lingual (Spanish) employee will be present during the hours of operation or
available via telephone. Alternative Center employees will be responsible for determining the
eligibility of individuals seeking entry into the facility and will conduct all patient transactions
and required data entry and receipt filings.
Receptionist
Employee is responsible for all patient check-ins and making sure all documents are on file for
each patient. Receptionist shall be responsible for answering inquiries received by email.
Employee will greet and check in patients as they enter the building, providing excellent patient
care, full compliance, and database accuracy. (This is the most routine task of the Receptionist).
Employee will answer the phones, receive and transfer calls to staff, and adhere to company
policies regarding what can and cannot be shared over the phone. Employee will maintain the
aesthetics of the reception area, ensuring a clean, organized, and well-stocked environment. The
employee will also ensure that the overall aesthetics meet our standard of excellence (flowers,
etc.).
12.10 EMPLOYMENT CONTRACTS

PLEASE SEE SECTION 17
SECTION 13
SAFETY DEPARTMENT
This manual delineates the policies and procedures for the Safety Department at this dispensary.
All employees working in the Safety Department must follow these policies and procedures.
13.2 ROLE OF THE SAFETY DEPARTMENT

The Safety department is critical to the success and well-being of the dispensary. Safety
Associates are the first contact for patients and visitors. Our department sets the standard by
which patients will judge the dispensary and the mission statement. Make each patient feel
welcome and a part of something special, which this organization indeed is. New patients should
be welcomed for the first time and returning patients should be welcomed back. Be polite,
attentive, and courteous. Use people's names when possible. Make eye contact when talking and
especially when listening. Smile often.
There are two overarching responsibilities that fulfill the role of the safety department:

1. It is the primary responsibility of all Safety Associates to constantly remain aware of their
surroundings and take immediate preventive measures to reduce the likelihood of injury
to anyone visiting the dispensary.
2. The secondary responsibility of Safety Associates is to protect Dispensary property from
theft, damage, or acts of vandalism, as well as maintaining a safe physical environment
for all staff, patients, and visitors.
To fulfill this overarching role, the dispensary has been divided into several “safety zones,” each
with their own unique guidelines and duties to be followed by the Safety Associate(s) assigned
that zone. These zone-specific duties are called “Post Orders.”
Although these Post Orders are general in nature, they shall be considered policy, and followed
as any other Company policy where applicable. As with any general order, the Safety Post
Orders may be modified or revised temporarily or permanently only by H. Alexander Zaleski
(President) or Safety Department Head. Temporary modifications may be verbal or written,
permanent modifications shall be written and added to the Safety Operations Manual.
13.3 OUR APPROACH TO SAFETY & SECURITY
13.4 EMPLOYEE SECURITY
13.5 DAILY LOG

The Daily Log Folder is kept at the podium and contains a tool called the “Daily Pass On.” The
Daily Pass On is completed throughout the prior day and closing, and contains important notes
and instructions for the current or following day(s). The daily break schedule is included on the
Daily Pass On. Only management may write on the Daily Pass On and all Safety personnel must
read the Daily Pass On upon arrival for their shift.

13.6 OPENING PROCEDURE BREAKDOWN
13.7 CLOSING PROCEDURE
13.8 PERSONAL SAFETY AND CRIME PREVENTION
13.9 EMERGENCY PREPAREDNESS PLAN




.
13.14 TORNADO WARNING PROCEDURES
Upon the notification of a tornado warning, employees and guests should stay in enclosed
offices, rooms, and hallways in the interior of the building - away from exterior walls and glassy
areas.
Winds up to 200 mph can occur in a tornado. The hazards of a tornado typically are flying
objects hazards. For maximum protection in offices, crouch down under a desk or table and
cover your head.
**PLEASE NOTE**
A COMPREHENSIVE SECURITY PLAN FOR THE BREAKWATER ALTERNATIVE
TREATMENT CENTER IS INCLUDED IN ALL MEASURES OF CRITERION 4 OF
THIS APPLICATION.
SECTION 14
INVENTORY CONTROL DEPARTMENT
This section delineates the policies and procedures for the Inventory Department of this
dispensary. All employees working in the Inventory Department must follow these policies and
procedures.
14.2 THE ROLE OF THE INVENTORY DEPARTMENT

First and foremost, the Inventory Department is responsible for the storing, tracking, counting,
and safekeeping of cash, medicine, and other dispensary products. All medicine is stored within
the Inventory Department, before and after it is processed, until it is sold to our patients.
14.3 INVENTORY DEPARTMENT ADMINISTRATION

Hours & Scheduling
The Inventory Department is open every day that the dispensary is open, however the busiest
days are Wednesdays, Thursdays, and Fridays. Thursday is busy in anticipation of heavy Friday
sales, and Friday is busy in preparation for heavy weekend sales.
The Inventory Department opens 2.5 hours before the dispensary opens (3 hours on Fridays).
The department closes after the dispensary closes, but not until all Sales POS stations have been
closed out for the day and all cash tills have been delivered to the Inventory Department.
14.4 GENERAL INVENTORY DEPT. POLICIES

Any policies that apply to all dispensary employees also apply to Inventory staff. In addition, the
following policies apply specifically to the Inventory Department:
Never leave large amounts of money or medicine alone anywhere except in Control.
All doors must stay locked and closed; only one door to a room may be left open when
moving items.
Control must stay locked unless someone is inside.
Never leave large amounts of money laying around in Control, even if the doors are
locked; always put away and store in the Big Bills Storage Box.

If you receive a call from another department while you are in the middle of something
important (like counting/sorting money), you must tell that person to wait a few minutes
or send another IM team member. Do not leave your task. You must finish your current
project before beginning a new one.
Any changes made to the POS must be reviewed and approved by an Inventory Manager
(e.g., product conversion vouchers, quantity adjustments, shake, by-product vouchers,
physical inventory adjustments, item-edits, etc.)
All money must be double-counted.
Physical Inventories must be conducted on a regular and timely basis, at least once every
six (6) weeks.
14.5 INVENTORY ASSOCIATE DAILY DUTIES

Upon Arrival
1. Arrive a couple minutes before Inventory Department open time, but do not clock in yet.
a. Store your non-essential personal items. No backpacks or other bags are allowed
on the Inventory Dept. floor.
b. Check the posted schedule for any changes. If you haven’t already, approve your
schedule by initialing in the space requested. If there’s a problem with the
schedule, discuss it with your supervisor.
c. Notify/remind your supervisor of any important issues, such as break restrictions,
appointments, or personal needs for today’s shift.
2. Once you’ve stored your personal belongings and are ready to start working, you may
clock in.
Priority #1: Build Sales Racks for the Day
Priority #2: Dispense Cash Funds & Prepare Cash Tills Throughout the Shift
3. Adhere to the break schedule in accordance with the policy set forth in the Employee
Handbook and as communicated by the Manager On Duty.
4. Restock any items that sell out throughout the day.
5. If delegated by the IM, count and reconcile the First Drop register tills at the appropriate
time.
6. The Processing Department closes at approximately 5pm. Upon their closing, all
processed and unprocessed items back to secure storage (GM Office or Control). Make
labels for the new finished products with Name, Item #, Voucher #, and price (on colored
labels). Affix each label on the corresponding product bin.
Dispensary Closing
1. Prior to dispensary closing, make sure all First Drops from today have been counted.
2. Prior to dispensary closing, move the empty sales racks into the holding area in the
Inventory Department. Also roll in two (2) black carts for money and edibles.
3. Complete all closing tasks as delegated by the IM or Manager On Duty.
14.6 CASH MANAGEMENT/TILL DROPS

Each Sales Floor Workstation is assigned a cash drawer containing a cash till. The dispensary
executes Till Drops twice every day, one at 1pm (midday) and one at 7pm (closing).
14.7 CREDIT CARD MACHINE ISSUES

Collect the settlement reports from each terminal in the morning, and stamp them with the
correct bar stamp.
14.8 MONTHLY INVENTORY COUNT

The dispensary conducts a physical count of all inventory every month to ensure absolute
accuracy and accountability. This is a huge undertaking, and therefore the entire Inventory
Department is involved. On the morning of an inventory count, the Inventory Manager will bring
breakfast in for the entire Inventory team to start the day off right and will then kick-off the day
with a pre-inventory meeting. While inventory counts may be arduous and require absolute
precision and concentration, it’s a wonderful opportunity to come together each month as an
entire team with a shared goal.
14.9 INVENTORY OPENING CHECKLIST

Collect settlement report slips verifying “settlement successful” from credit card
machines on floor.
Verify all registers are ready for opening. Log onto the POS and review daily sales
reports from previous day.
Line up racks in vault to easily view all cart contents.
Decide on how to build the board with the Inventory team, determining what to remove
from the Sales Floor, what to put on sale, and what to add.
Build the Processing Cart with bulk, edibles and concentrates. Log them out of the Safe
Log.
Delegate the following tasks to Inventory team members: morning restock, adding new
items, edibles, labeling/displays, and test results for both smokeables and concentrates.
When restocking is done, move the carts to the Sales Floor.
Make sure the Change Box has appropriate change and give to the Sales Manager.
Check in with the Sales Manager to make sure they have all they need, if anyone is sick,
or if additional staffing is needed.
Confirm all departments, all equipment, all medicine and all money resources are
accounted for and ready to go.
14.10 INVENTORY CLOSING CHECKLIST

Collect and reconcile all first drop register tills. Place the money and the corresponding
Z-Out report in the numbered envelope and secure them in the vault.
At approximately 7:45pm, begin preparations to close the Sales Counter. Pull out two
pushcarts, the display cart, and the sales racks and roll them to the holding area if
applicable.
When Safety gives the all clear, take all carts to the Sales Floor.
The Sales Manager will give Inventory the change box, closing tills, credit card receipts,
and closing checklists.
Secure all Sales Floor register tills and change box in the appropriate safe in the vault. All
carts, racks, and displays should also be secured in the vault. Turn off all counting
machines and lights. Lock down the vault and set alarm.
Turn off all lights and computers, and then clock out.
SECTION 15
EDUCATIONAL DEPARTMENT

We pledge to always put the well-being of our patients and the public good foremost in our
objectives. We want patients to be able to use the highest quality medicine available to alleviate
the symptoms of their illness and will always strive for positive patient utilization outcomes.
The medical marijuana program is similar to introducing a new pharmaceutical drug that is
undergoing clinical trials (Phase 1: Clinical Trials, Phase 2 Clinical Trials, etc). Breakwater’s
approach to the medical marijuana program is much like the early days of “pharmacy care”
which was much more of a hands-on approach to wellness and care.
Breakwater will endeavor to provide our patients with access to a complete medical marijuana
resource center. All of our services are designed to ensure that a patient’s transition into being a
legal patient is based on knowledge and compassion. We believe that the more knowledge we
can provide to our patients the more power they will have over their lives. Our services will
include in-depth consultations and solutions by compassionate caregivers, social workers and
legal support administered through Breakwater’s legal services program. Our goal is simple –
Positive Patient Outcomes. As active members of the medical marijuana community, the
Breakwater Alternative Treatment Center staff has the expertise to help people who have a
qualifying medical condition become a legal medical marijuana patient. Our offices are private,
confidential and secure. We are committed to providing only high quality patient services.
15.1 EDUCATIONAL POLICY
Each patient will be presented with a Breakwater Alternative Treatment Center informational
brochure, which will detail the various ingestion options, safe smoking techniques and all
potential side effects for the medical cannabis products available at the Center. In addition to
the brochure our Alternative Center employees will provide all requested information in detail
and answer any other questions the patient may have. We will also work with the Department
of Health and Senior Services to provide a list of Frequently Asked Questions concerning the
Medical Marijuana Program.
Breakwater Alternative Treatment Center will take pride in the care provided to patients.
Educating on the safest methods of ingestion is a key component in making a patient
comfortable and providing the most effective means of obtaining the optimum results for pain
management. Breakwater Alternative Treatment Center will offer multiple methods and product
options for the ingestion of medical cannabis.
We believe that vaporization is the best method to "smoke" medical cannabis; however, there are
many vaporizers out there. In an effort to help our patients we will always keep our ear to the
ground and understand all products on the market. We do trust and believe in the "Volcano"
vaporizer is a great product for vaporization purposes.
15.2 FREQUENTLY ASKED QUESTIONS

Each new registered qualifying patient who visits our Alternative Centers will be provided with
the Department of Health and Senior Services’ "Frequently Asked Questions" document, which
explains the limitations on the right to use marijuana in the State of New Jersey.
15.3 TRACKING USEFUL DATA

There is a need to document the self-reported uses and outcomes associated with medically used
marijuana and we will fully document and analyze all relevant patient data and use that
information to project current and future trends. We will partner, if possible, with a major New

Jersey University to collaborate with us and conduct long-term studies on all aspects of the use
of medical marijuana. All facets of our operation will be tracked (cultivation, inventory, curing
and sales) utilizing the latest software applications and fully integrate this data with complete
patient profiles and reactions. Detailed demographic data, self-reported treatment utilization,
treatment history, and diagnostic information will be obtained at baseline. Self-reported
symptom severity information will be collected at baseline and at 3 month intervals yearly
through standardized questionnaires that include assessment of quality of life, symptom severity,
depression, anxiety, stress, coping skills, optimism/pessimism, and more.
15.4 EXAMPLE OF EDUCATIONAL MATERIALS

Bracketed numbers (ex. [1]) refers to “References” listed at the end of this section
Using Your Medicine (Educational Materials)
The federal government classifies cannabis as a schedule 1 drug; a classification that implies
that cannabis has no legitimate medical use. This classification should be changed because
cannabis is recommended by a multitude of physicians for the treatment of many medical
conditions. Furthermore THC (the primary active compound in cannabis) is FDA approved and
is called dronabinol [6]. Dronabinol is marketed using the trade name Marinol [6].
There are many methods of using cannabis for the treatment of medical conditions. The
following information is intended to inform medical cannabis patients about the various options
available to them.
Please note: The only form options that BATC offers currently are flower/bud form, lozenges
and topical formulations. We understand the present Laws of the Medical Marijuana Program
are restricted to three forms, the following is provided for educational purposes only.
Smoking Cannabis
Smoking is popular among patients for several reasons:
1. Rapid onset: Smoking delivers active compounds quickly into the bloodstream and to
receptor sites via the lungs [4].
2. Simplicity: Compared to other dosage methods, smoking cannabis is simple, requiring
very little preparation time. Before smoking cannabis, the patient must simply separate
the buds into individual flowers and remove any stems [2]. Doing so ensures an even
burn and less need for flame application (less unwanted fumes=better-tasting, more
healthful smoke). To make this easy, use a handheld herb grinder or a pair of scissors and
a shot glass [2].
3. Easy dosage determination: smoked cannabis is effective almost immediately, allowing
the user to titrate the dose one puff at a time. This allows the user to get just the right
dose by gradually increasing the dose until effective [7].
Methods of smoking
a. Joint: (a.k.a. “marijuana cigarette” or “reefer”) Convenience of joints is key, as joints burn
for multiple puffs worth of cannabis after only being lit once and are easily transportable [2].
Joints also taste pleasant to most patients, and they don’t require breakable, expensive, or
conspicuous equipment [2]. A huge plus is efficient delivery of cannabinoids [3]. This is

perhaps due to a joint’s lack of a filter or long piping before the mouth, to which sticky
cannabinoids adhere easily, reducing the amount of medicine that actually reaches the
patient’s body [3]. It is a skill to roll a good joint, however, novices uninterested in learning
how to do so should buy a joint-rolling machine or pre-rolled joints [2]. Before rolling a
joint, the patient should break the bud(s) into small, uniform pieces about the size of the
individual bud flowers or slightly smaller [2]. Stems should be removed from the flowers to
avoid foul, acrid smoke and possible holes poked in the rolling paper [2]. To roll a joint,
practice, practice, practice...or ask an expert at BATC for help. Some joint smokers prefer
unbleached rolling papers, hemp rolling papers, or clear, cellulose-based papers, which may
taste better and contain fewer impurities than traditional, bleached-white rolling papers.
**Patients should note that, while still remarkably safe, joints are one of the less-healthful
methods of dosage because they burn paper and glue along with cannabis, exposing users to
impurities not presented by some other alternative dosage methods [2]. Another downside is
waste: Some smoke is inevitably lost between inhalations, and there is usually leftover
cannabis in the “roach”, or the small, undesirable leftover part of a burned joint [2].
However, joints’ efficient delivery of cannabinoids—relative to other smoking methods—
may compensate for such waste [3].
b. Pipes: Pipes are an easy way to smoke cannabis, and can be broken down into two basic
categories: 1) Dry “Hand” pipes, and 2) Waterpipes [2].
c. Hand Pipes: These come in a (possibly overwhelming) variety of shapes, sizes, and materials,
but the basic mechanics are universal. To smoke a cannabis pipe:
4. Pack prepared buds into the bowl
5. Hold a flame directly over the medicine while simultaneously inhaling through the
mouthpiece [2].
6. Waterpipes: Mechanically, these are nearly identical to hand pipes, but use a chamber of
water to filter and cool the smoke before it is inhaled [2]. There are two main types:
bongs and bubblers, classified by either a large or a small filling chamber, respectively, in
which the smoke collects. The main proven advantage over dry pipes or joints is comfort;
smoke is cooled and free of hot ashes and particles [3]. *BEWARE: large “hits” of smoke
will cause light-headedness and an inclination to blacking out, and waterpipes make
accidentally taking a bigger-than-expected hit a possibility. Waterpipes are supposed by
many smokers to be a safer alternative to dry pipes or joints because the water filters tar
out of the smoke [2]. Unfortunately, as one test points out, water filtration removes THC
and other desirable active compounds more so than tar [3]. This means “in order to obtain
the same effective dose of THC, a smoker would end up taking in at least 30% more tars
from a waterpipe than from an unfiltered joint” [2]. However, water filtration may
remove water-soluble toxic gases such as carbon monoxide, which is linked to heart
disease, and aldehydes, which promote cancer [3], so more research is required to
determine whether waterpipes are beneficial or counterproductive [2].
**A problem with all pipe smoking is that you must suck on one side of the pipe, pulling air
and, along with the flame—lighter fluid fumes—over the cannabis, through the pipe, and into
your lungs to light the cannabis on fire. Grind your bud to minimize the need for a starting
flame. To avoid lighter fluid fumes, some patients light their pipe with an organic, beeswax-
covered hemp wick, or a magnifying glass under bright sunlight.
First time smoking? Use discretion, BATC's cannabis is highly potent! Don’t be alarmed though;
this is good news for the patient because it allows him or her to burn less plant material to get an

effective dose than with lower-potency cannabis [3,2]. This also means that, if the patient is new
to smoking, it may only take one substantial inhalation to get an effective dose. Start with a small
hit. Inhale deeply, exhale immediately (it is a myth that holding in the smoke will be more
effective), and WAIT for several minutes to feel the effects of the hit before taking the next so as
to minimize the dose [4].
In summary, if a patient wants the quickest relief possible (easy preparation, plus onset in
seconds [4]), and understands and accepts the possible risks inherent to smoking his or her
medicine, a pipe is the utensil of choice.
Our growing process and drying process are designed to prevent problems associated with fungi
that would affect the safety of our medicine. Buds will be inspected upon trimming and after
drying for the presence of mold, and samples from every batch will be sent to a laboratory for
testing.
Vaporization
Breakwater Alternative Treatment Center highly recommends this method to all patients. Good
vaporizers allow patients quick-onset relief and oral satisfaction similar to smoking without the
health risks associated with smoke [1]. They do this by delicately heating the cannabis to the
point that THC and other therapeutic substances change physical form, becoming gaseous [1].
The gas, or vapor, is then inhaled like smoke. The process leaves behind dry, slightly browned
buds that, rather than having gone up in smoke, simply lack richness in medicinal compounds
[2]. Studies show vaporizers significantly reduce carcinogens (cancer-causing agents), carbon
monoxide (linked to cardiovascular disease), and tar [1,2,3].
Lozenges
Lozenges are made in several ways. One way is to use edible gum such as Tragacanth or Acacia
to make a basic mucilage. Then we mix in a dried form of medicinal marijuana butter solution,
milk solution, oil solution or one of the three tincture solutions into the mucilage to make a paste
[2,4,8]. When the paste has cooled slightly, we cut the paste into various size lozenges depending
on dose. When it dries it is ready to be packaged and then stored in an airtight container. We will
offer sugar-free or unrefined brown sugar forms. [8] They are absorbed through the mucus
membranes of the mouth, and take effect in five to ten minutes [2,4].
Tinctures
Cannabis can be administered orally using cannabis tinctures [2]. Cannabis tinctures have a long
history of medical use in the United States [5]. As early as the 1850's American physicians
prescribed tincture of cannabis with successful results [5]. There are three types of cannabis
tinctures, made using alcohol and/or glycerine as solvents [4]. All three of these solutions may be
taken under the tongue with an eyedropper [2]. They are absorbed through the mucus membranes
of the mouth, and take effect in five to ten minutes [2,4]. Tincture dosage varies greatly
depending on the concentration of cannabis in the tincture [4]. Glycerine tinctures have the
advantages of tasting sweeter than alcohol tinctures, and being well suited for those who do not
consume alcohol [4]. Alcohol tinctures have the advantage of usually being more concentrated
than glycerine tinctures, thus less needs to be used for the desired effect [4]. Glycerine/alcohol
tinctures combine the advantages and disadvantages of glycerine tinctures and alcohol tinctures
[4]. Shake glycerine/alcohol tinctures to counteract separation [4].

Oral Administration
Not just brownies: In theory, cannabis food can be anything that contains substantial butter, oil,
milk, or alcohol, because cannabinoids are oil and fat-soluble and thus dissolve in these
ingredients [2].
Eating food enriched with cannabis offers patients several advantages:
1. No risk of damage to respiratory system.
2. Longer-lasting relief (up to 10 hrs.) [4]
3. Can be made with leaf, which costs less than high-grade bud [2]
Eating cannabis-laden foods also has distinct disadvantages for some patients:
1. Slower onset of effects (15min-3hrs) [2]
2. Proper dosage is difficult to gauge; many variables at play [4]
3. Cooking THC makes it slightly more psychoactive [2]
Dosage
Cannabis can be administered using tinctures, ingestion, smoking, vaporizing, and by other
methods. The effect of each method and the rate of onset when using each method varies.
Smoking and vaporization provide the fastest onset of effects of any method of administering
cannabis [4]. Effects can be felt almost instantly [4]. Tinctures are slightly slower to take effect
than inhalation methods; they start to take effect in five minutes or less [2]. Eating cannabis
infused foods or capsules is the slowest method of medicating with cannabis but it provides
longer lasting effects than other methods [2]. The effects of ingested cannabis may take from 30
minutes to longer than an hour to be noticeable, and may maintain peak intensity for one to two
hours before gradually diminishing over several hours [2]. The effects imparted by eating
cannabis are also pharmacologically different from those produced by other intake methods,
because THC is converted to 11-hydroxyl-THC in the liver when cannabis is eaten [2].
When using any cannabis preparation start with a small quantity, wait the proper amount of time
for the effects to take place, and then take more if necessary [5]. Dosage determination is most
easily accomplished using inhalation and tincture methods [2]. It is more difficult to determine
ingestion dosage than inhalation or tincture dosage, because the onset of effects is much less
rapid with ingestion [2]. The amount of food and type of food in the digestive tract also play
roles in determining effective ingestion dosage, further complicating the task [4]. Whatever the
method of intake, a lethal overdose of cannabis cannot be achieved [5]. Overdosing on cannabis
may produce unpleasant feelings such as drowsiness or anxiety, but users experiencing such
feelings should stay calm and wait for the effects of cannabis to diminish [4]. Users who fear the
possibility of unpleasant feelings from an overdose may wish to avoid cannabis edibles, as eating
cannabis is the most likely intake method to cause an overdose [2].
Potency
All of the varieties that BATC will offer are high, medium and low potent*. This is a BATC
policy for several reasons. One reason is high potency will save caretakers money by allowing
them to use less medicine. Another reason is highly potent varieties are healthier for those who
choose to smoke their medicine, because less plant material must be smoked to get the same dose

of active compounds [2]. We will also only offer highly potent varieties, as this will aid in
simplifying the caretaker's task of choosing the right varieties for their individual needs. One last
reason for this policy is that it will help caretakers determine the appropriate dosage of each
variety.
*Each variety we offer is of different potency and has unique medicinal effects.
Tolerance
Heavy cannabis use will, over time, result in lowered sensitivity to the drug [2]. However, most
patients lose side effects over time, not medicinal efficacy [2]. To avoid gaining tolerance to
cannabis, patients should try different varieties of cannabis and different intake methods [2].
Addiction
Cannabis isn't physically addictive, however psychological dependence may occur [2]. This
means cannabis use may become habitual in some users [2]. When discontinuing cannabis use,
long-term heavy users may experience mild withdrawal symptoms including anxiety, difficulty
sleeping, and irritability [2].
References
[1] Armentano, P. (2009). Emerging clinical applications for cannabis and cannabinoids: a
review of the recent scientific literature 2000- 2009. Washington, DC: NORML Foundation.
[2] Gieringer, D., Rosenthal E., & Carter G. T. (2008) Marijuana medical handbook. Oakland,
CA: Quick America.
[3] Gieringer, Dale (2000). Marijuana water pipe and vaporizer study. Newsletter of the
Multidisciplinary Association for Psychedelic Studies, 6(3) Retrieved 6/19/2010,
from http://www.maps.org/news-letters/v06n3/06359mj1.html
[4] Lauve J., & Luttrell, H. (2010, Feb./Mar.) What is the right amount for me? Cannabis Health
News Magazine, 1, 2.
[5] Mikuriya, T. H. (Ed.). (2007) Marijuana: medical papers 1839-1972 (Vol. 1). Nevada
City, CA: Symposium Publishing.
[6] Joy, J. E. (1999) Marijuana and Medicine: Assessing the Science Base.
Washington, D.C.: National Academy Press.
[7] Earleywine, M. (2002) Understanding Marijuana: A New Look at the Scientific
Evidence. NY: Oxford University Press.
[8] Hoffman, David. (2002) The Complete Illustrated Guide to Holistic Herbal: A Safe and
Practical Guide to Making and Using Herbal Remedies. Element Books.
15.5 EDUCATION ON PACKAGING & LABELING

Packaging
Medical marijuana flowers will be distributed in airtight glass jars or plastic containers similar to
those used by pharmacies.
Lozenges will be packaged in appropriate plastic packaging and tightly sealed to keep contents
from spoiling.
Topical formulations will be package in appropriate tubes or plastic containers and tightly sealed
to keep contents from spoiling.
Labeling

Breakwater Alternative Treatment Center will use a comprehensive labeling system for all
medical cannabis useable goods and products available for purchase. All packaging will have a
label attached thereto specifying the following information:
a. A label containing any statements about the product other than those specified by law
shall contain the following statement prominently displayed, and in boldface type: “This
statement has not been evaluated by the Food and Drug Administration. This
product is not intended to diagnose, treat, cure, or prevent any disease.”
b. “This product is for medical use only and is not for resale”
c. Batch identification number
d. Contact information for Breakwater Alternative Treatment Center’s Help Hotline
e. Expiration date
f. Suggested Strain Classifications include but not limited to:
a. Sedative
b. Euphoric
c. Stimulatory
d. Sleep inducing
Specific to medical cannabis flower labels:

a. Strain type
b. Potency (Percentage breakdown of CBA’s, CBD’s and THC levels)
c. Quantity
Example of a potential description- “flowers/buds (4 grams)"
Specific to lozenges/topical formulation marijuana products:
a. “Strain”
b. “Potency”
c. “Quantity” contained (grams or ounces) based on dry weight before the manufacturing
process.
d. “Source” (cannabis flowers, leaves or both)
e. “Form”
f. Ingredients- under strict supervision every manufactured cannabis product from
Breakwater Alternative Treatment Center will include complete ingredients ordered by
weight, weight of product and allergy warnings.
a. Manufacturing process (how the CBA’s, CBD’s and THC has been extracted
from the marijuana)
i. Using alcohol and/or glycerin
ii. Oil
iii. Butter
iv. Milk
15.6 EDUCATION ON STRAINS

BATC will consistently provide:
1. Flying Dutchman's 'Original Haze'
This cultivar ('strain') is the true original haze. This cultivar was developed in the 1970's, but is
still considered an excellent plant for the stimulating characteristics of its medicinal effect. This

cultivar is considered to be a pure sativa with a classic laughter increasing effect. The flavor is
sweet and sour. This cultivar (strain) has been recommended for: Crohn’s Disease, epilepsy,
multiple sclerosis, and other-related illnesses.
2. Nirvana Seeds Standard 'Early Bud'

This is a fast flowering hybrid containing indica and sativa genetics. It has an effect that is
euphoric and mellow. This cultivar has a slightly spicy, fresh flavor.
3. Sensi Seed's 'Hindu Kush'

This cultivar comes from the Hindu Kush mountain range in the Afghanistan/Pakistan region. It
is considered to be a pure indica cultivar with a classic relaxing and slightly sedative effect. The
flavor is sandalwood- like with hints of sweetness.
BHCC will order seeds of these three cultivars and grow them to maturity. Before the seedlings
begin flowering cuttings will be taken from each seedling to serve as potential stock plants. The
harvested cannabis from each seedling female will be evaluated for potency using laboratory
techniques. After determining the potency of each seedling female, the females containing less
than ten percent THC will be further evaluated for additional characteristics, and a stock plant for
each variety will be chosen. Cuttings from the chosen seedlings will become BHCC's stock
plants for further propagation.
SECTION 16
CRITRICAL INCIDENT DEPARTMENT
The process of conducting a critical incident review will be divided into three steps:
16.1 Identify and record the incident
Describe what happened and how it affected the person, the reporting employee (you), and the
Alternative Center. Think about how it could have been avoided and what might be done to stop
it happening again.
16.2 Prepare for the review

The review should encourage mutual support and openness, and emphasize learning. Someone,
for example an external facilitator, should lead and chair the audit and make sure there is
protected time for all involved.
The lead should set ground rules such as confidentiality, having an open discussion, allowing
everyone to speak and participate in active listening, and not allocating blame.
16.3 Running the review

The questions on the form can be used to structure the review meeting. You might consider the
following points:
What happened? Did something go wrong? What things went well?
How did it affect the patient, you, and the practice?
Could it have been avoided?
Can it be stopped from happening again? What action needs to be taken by whom and
when?

What learning or development need has this highlighted for you (to put into your personal
development plan)?
What learning or personal development need has it highlighted for others?
16.4 Keeping a record

Keeping a log of all critical incidents can help identify patterns. If you re-audit an event you can
see whether you put into place the changes you agreed in the review. Please see a sample
“Critical Incident Report” on the following page.
Critical Incident Report

Critical Incident Submission Form
Please complete this form with as much information as possible. We will get back with you via
phone or e-mail if clarification is needed.
Your Name:
Title ______________________
First Name ___________________________
MI _______________________
Last Name ___________________________
Suffix ____________________
Facility address __________________________________________________________
Your e-mail address:________________________@_____________________________
Today's Date: / Month / Day /Year _____________________________________

Date of Incident: / Month / Day /Year ___________________________________
Location in Facility: _________________________________________________
Number of staff involved: ________________________
Names of staff: __________________________________________________________
Number of staff injured: __________________________
Names of staff injured: ____________________________________________________
Number of public involved: _______________________
Names of public: _________________________________________________________
Number of public injured: _________________________
Names of public injured: ___________________________________________________
Was a weapon used? : _____________
If a weapon what type(s)? : _________________________________________________
What agency was notified and by whom ? : ____________________________________
________________________________________________________________________
Description of Incident: ____________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
Management's response and any problems with it: _______________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

Suggestions for how this could have been prevented: _____________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
I have read and agree to abide by this Employee Manual.
Employee Signature:______________________________Date: ____________________
Witnessed by:___________________________________Date: ____________________
For: Breakwater Alternative Treatment Center Corp.
SECTION 17- SAMPLE EMPLOYMENT CONTRACTS
PLEASE NOTE:
SECURITY PERSONNEL EMPLOYMENT CONTRACTS ARE PROPRITARY
General Manager:
EMPLOYMENT AGREEMENT
Breakwater Alternative Treatment Center Corp., a Non-Profit New Jersey Corporation,
located at 222 Jefferson Blvd., Suite 200, Warwick, New Jersey 02888, hereinafter referred to as
“Employer” and____________________________________of
___________________________________________, hereinafter referred to as “Employee”, in
consideration of the mutual promises made herein, agree as follows:
ARTICLE 1. TERM OF EMPLOYMENT
Section 1.01 Employment Term. Employer hereby employs Employee and Employee
hereby accepts employment with Employer for the period beginning on 2011
and terminating on 2013 (the “Term”), unless sooner terminated pursuant to Article 4 of
this Agreement.
ARTICLE 2. DUTIES AND OBLIGATIONS OF EMPLOYEE
Section 2.01. General Duties. Employee shall serve as the General Manager of the
Corporation dispensary and cultivation sites. In such capacity, Employee shall do and perform all
services, acts, or things necessary to perform her responsibilities as determined by H. Alexander
Zaleski, COO. Employee shall specifically be responsible for the following. The General
Manager will be responsible for oversight of all activities at the dispensary and the cultivation

site. Responsibilities include implementing cultivation and harvesting protocols, inventory
management, report generation, patient management, data entry supervision, sales tax reports
and fire and police liaison. Employee shall devote his/her full working time, efforts, ability, and
attention to the business of Employer during the Term and shall not be engaged in any other
business activity, whether or not for gain or profit, during such period.
Section 2.02. Noncompetition. During the Term, Employee shall not, directly or
indirectly, own, manage, operate, join, control, be employed by, or participate in the ownership,
management, operation or control of, or be connected in any manner with, any business that is
competitive with the business of Employer. At no time during the Term shall Employee interfere
with, disrupt or attempt to disrupt the relationship, contractual or otherwise, between Employer
and any of Employer’s customers, clients, suppliers, consultants or employees.
ARTICLE 3. COMPENSATION OF EMPLOYEE
Section 3.01. Base Salary. As compensation for her services to be performed hereunder
during the Term, Employee shall receive a base salary of $______________ a year payable in
equal installments of $____________ on the first and fifteenth day of each month. Employer
shall deduct from said sum, all applicable Social Security, Federal, State and local taxes.
Section 3.02 Benefits and Vacation. During the agreement term, the Employee
shall be entitled to participate in, to the extent they exist, the benefit plans and programs
(including without limitation; retirement plan participation and health insurance) and receive ten
(10) days paid vacation per year.
Section 3.03 Business Expenses. Upon submission of itemized expense statements in
the manner specified by the company, the Executive shall be entitled to reimbursement for
reasonable expenses duly incurred by Employee in performance of the Employee’s duties under
this agreement in accordance with the policies and procedures established by the company. All
business expenses in excess of one hundred ($100.00) dollars shall be approved by the Employer
prior to undertaking same.
ARTICLE 4. TERMINATION OF EMPLOYMENT
Section 4.01. Termination. (a) Employer may terminate this Agreement: (1) upon the
death of the Employee; (2) upon the disability, either physically or mentally, of Employee
whether totally or partially so that the Employee is unable to perform her duties aggregating 60
days during this contract.
Section 4.02. Termination for Cause (a) Employer reserves the right to terminate this
Agreement at any time during the Term hereof if the Employee breaches any of the duties which
it is required to perform under the provisions of this Agreement, the Employee Confidentiality
Agreement, or the Non-Compete Agreement or commits acts of dishonesty, fraud,
misrepresentation or other acts of moral turpitude.
(b) Employer may at its option terminate this Agreement for the reasons stated in this
Section by giving written notice of termination to the other party without prejudice to any other
remedy to which it may be entitled either at law, in equity, or under this Agreement, and
termination shall be effective immediately upon the giving of such written notice.
(c) The notice of termination required by this Section shall specify the ground (s) for the
termination and shall be supported by a statement of all relevant facts. Termination shall take
effect immediately.
(d) Upon Termination of this Agreement for any reason whatsoever, Employer shall pay
to Employee all sums then due Employee hereunder on the effective date of termination.
ARTICLE 5. GENERAL PROVISIONS

Section 5.01. Arbitration. (a) Subject to subparagraph (b) hereafter, any controversy or
claim arising out of this Agreement, or the breach thereof, shall be settled by binding arbitration
before the American Arbitration Association in New Jersey, in accordance with the Commercial
Arbitration Rules of the American Arbitration Association then in effect, and judgment upon the
award rendered by the Arbitrator may be entered in any Court having jurisdiction. The cost of
the Arbitration shall be borne in such proportions as the Arbitrator shall decide.
(b) Notwithstanding, the provisions of subparagraph (a) hereinabove, this Agreement
shall be governed by and construed in accordance with the laws of the State of New Jersey. Any
party may seek injunctive or other equitable relief in any controversy or claim arising out of this
Agreement, or in the breach thereof, in the Supreme Court of the State of New Jersey for the
County of New Jersey or the United States District Court for the Southern District of New
Jersey.
Section 5.02. Notices. Any notices to be given hereunder by either party to the other
shall be in writing transmitted by personal delivery or by mail, registered or certified, postage
prepaid with return receipt requested. Notices delivered personally shall be deemed
communicated as of the second day after the date of mailing.
Section 5.03. Attorney’s Fees and Costs. If any arbitration or action at law or in
equity is necessary to enforce or interpret the terms of this Agreement, the prevailing party shall
also be entitled to reimbursement for reasonable attorney’s fees, costs and necessary
disbursements.
Section 5.04. Entire Agreement. This Agreement supersedes any and all other
Agreements, either oral or in writing, between the parties hereto with respect to the employment
of Employee by Employer and contains all of the covenants and agreements between the parties
with respect to that employment in any manner whatsoever.
Section 5.05. Modifications. Any modification of this Agreement will be effective only
if is in writing and signed by Employer and Employee.
Executed as of , at___________________, New Jersey.
By
Dispensary Manager:
Breakwater Alternative Treatment Center Corp of New Jersey, a Non-Profit New Jersey
Corporation, located at 222 Jefferson Blvd., Suite 200, Warwick, New Jersey 02888, hereinafter
referred to as “Employer” and of
hereinafter referred to as “Employee”, in consideration of the mutual promises made herein,
agree as follows:

and terminating on 2013 (the “Term”), unless sooner terminated pursuant to Article 4 of this
Agreement.
Section 2.01. General Duties. Employee shall serve as the Manager of Alternative
Treatment Center of the Corporation dispensary. In such capacity, Employee shall do and
perform all services, acts, or things necessary to perform her responsibilities as determined by H.
Alexander Zaleski. Employee shall specifically be responsible for the following. Employee will
be responsible for the supervision of all Alternative Treatment Center employees to assure that
they are properly performing their duties. The manager will also be responsible for preparing
weekly inventory and sales reports. In addition, the manager will be the primary person
responsible for the reporting of a fire, intrusion or other emergency. Employee shall devote
his/her full working time, efforts, ability, and attention to the business of Employer during the
Term and shall not be engaged in any other business activity, whether or not for gain or profit,
during such period.

Section 3.01. Base Salary. As compensation for her services to be performed
hereunder during the Term, Employee shall receive a base salary of $_____________ a year
payable in equal installments of $_________ on the first and fifteenth day of each month.
Employer shall deduct from said sum, all applicable Social Security, Federal, State and local
taxes.

effect immediately.

Jersey.
disbursements.
Section 5.05. Modifications. Any modification of this Agreement will be effective only if
is in writing and signed by Employer and Employee.

By
Alternative Treatment Center Provider:
referred to as “Employer” and of
hereinafter referred to as “Employee”, in consideration of the mutual promises made herein,
agree as follows:
Agreement.
Section 2.01. General Duties. Employee shall serve as a Alternative Treatment
Center provider of the Corporation dispensary. In such capacity, Employee shall do and perform
all services, acts, or things necessary to perform her responsibilities as determined by H.
Alexander Zaleski. Employee shall specifically be responsible for the following. Employee will
be required to communicate clearly and show compassion for all patients entering the facility. A
bi-lingual (Spanish) employee will be present during the hours of operation or available via
telephone. Alternative Treatment Center employees will be responsible for determining the
eligibility of individuals seeking entry into the facility and will conduct all patient transactions
and required data entry and receipt filings. Employee shall devote his/her full working time,
efforts, ability, and attention to the business of Employer during the Term and shall not be
engaged in any other business activity, whether or not for gain or profit, during such period.
Section 3.01. Base Salary. As compensation for her services to be performed
hereunder during the Term, Employee shall receive a base salary of $____________ a year
payable in equal installments of $_______ on the first and fifteenth day of each month. Employer
shall deduct from said sum, all applicable Social Security, Federal, State and local taxes.

effect immediately.
Jersey.
disbursements.
Section 5.04. Entire Agreement. This Agreement supersedes any and all other Agreements,
either oral or in writing, between the parties hereto with respect to the employment of Employee
by Employer and contains all of the covenants and agreements between the parties with respect
to that employment in any manner whatsoever.

By
Dispensary Receptionist:
referred to as “Employer” and of hereinafter
referred to as “Employee”, in consideration of the mutual promises made herein, agree as
follows:
Agreement.
Section 2.01. General Duties. Employee shall serve as a Receptionist of the Corporation
Dispensary site. In such capacity, Employee shall do and perform all services, acts, or things
necessary to perform her responsibilities as determined by H. Alexander Zaleski. Employee
shall specifically be responsible for the following. Employee is responsible for all patient check-
ins and making sure all documents are on file for each patient. Receptionist shall be responsible
for answering inquiries received by email. Employee will greet and check in patients as they
enter the building, providing excellent patient care, full compliance, and database accuracy. (This
is the most routine task of the Receptionist). Employee will answer the phones, receive and
transfer calls to staff, and adhere to company policies regarding what can and cannot be shared
over the phone. Employee will maintain the aesthetics of the reception area, ensuring a clean,
organized, and well-stocked environment. The employee will also ensure that the overall
aesthetics meet our standard of excellence (flowers, etc.). Employee shall devote his/her full
working time, efforts, ability, and attention to the business of Employer during the Term and
shall not be engaged in any other business activity, whether or not for gain or profit, during such
period.

during the Term, Employee shall receive a base salary of $________ a year payable in equal
installments of $________ on the first and fifteenth day of each month. Employer shall deduct
from said sum, all applicable Social Security, Federal, State and local taxes.
effect immediately.

Jersey.
disbursements.
By
Chief Cultivator (Horticulturist):

referred to as “Employer” and Joseph Bender of 604 Devils foot Road, Unit 32, North
Kingstown, RI 02852, hereinafter referred to as “Employee”, in consideration of the mutual
promises made herein, agree as follows:
this Agreement.
Section 2.01. General Duties. Employee shall serve as the Horticulturist of the
services, acts, or things necessary to perform her responsibilities as determined by H. Alexander
Zaleski, COO. Employee shall specifically be responsible for the following. Employee will have
direct control over all aspects of the growing, harvesting and curing process and will conduct
routine inspections of all equipment to assure that it is in proper working order. Employee shall

devote his/her full working time, efforts, ability, and attention to the business of Employer
during the Term and shall not be engaged in any other business activity, whether or not for gain
or profit, during such period.
during the Term, Employee shall receive a base salary of $_____________ a year payable in
equal installments of $___________ on the first and fifteenth day of each month. Employer shall
deduct from said sum, all applicable Social Security, Federal, State and local taxes.

effect immediately.

Jersey.
disbursements.
Joseph Bender

By
Cultivation Assistant:
located at 222 Jefferson Blvd., Suite 200, Warwick, New Jersey 02888, New Jersey, hereinafter
referred to as “Employer” and of hereinafter referred to as
“Employee”, in consideration of the mutual promises made herein, agree as follows:

this Agreement.
Section 2.01. General Duties. Employee shall serve as the Cultivation Assistant of the
services, acts, or things necessary to perform her responsibilities as determined by Joseph
Bender. Employee shall specifically be responsible for the following. Employee will take
direction from their manager (Horticulturist) as well as follow directions from senior
management. Job duties include checking nutrient levels and evidence of pest infestations,
performing the cloning, harvesting, trimming, drying, curing, processing and packaging of all
medical cannabis. Employee shall devote his/her full working time, efforts, ability, and attention
to the business of Employer during the Term and shall not be engaged in any other business
activity, whether or not for gain or profit, during such period.
during the Term, Employee shall receive a base salary of $___________ a year payable in equal
installments of $____________ on the first and fifteenth day of each month. Employer shall

effect immediately.
Jersey.
disbursements.

By
Baker:

located at 222 Jefferson Blvd., Suite 200, Warwick, New Jersey 02888, New Jersey, hereinafter
referred to as “Employer” and of hereinafter referred to as
“Employee”, in consideration of the mutual promises made herein, agree as follows:
this Agreement.
Section 2.01. General Duties. Employee shall serve as a Baker of the Corporation
Cultivation site. In such capacity, Employee shall do and perform all services, acts, or things
necessary to perform her responsibilities as determined by H. Alexander Zaleski. Employee
shall specifically be responsible for the following. The baker will be responsible for all baked
goods. The baker must follow the recipes and fully disclose all ingredients used. In conjunction
with a cultivation assistant, the baker is responsible for all packaging of products and ensuring
proper labels are attached. Employee shall devote his/her full working time, efforts, ability, and
attention to the business of Employer during the Term and shall not be engaged in any other
business activity, whether or not for gain or profit, during such period.
during the Term, Employee shall receive a base salary of $__________ a year payable in equal
installments of $_________ on the first and fifteenth day of each month. Employer shall deduct
from said sum, all applicable Social Security, Federal, State and local taxes.

effect immediately.
Jersey.
disbursements.

By
Transporter:
referred to as “Employer” and of hereinafter
referred to as “Employee”, in consideration of the mutual promises made herein, agree as
follows:
this Agreement.
Section 2.01. General Duties. Employee shall serve as the Transporter of Medical
Cannabis of the Corporation dispensary and cultivation sites. In such capacity, Employee shall
do and perform all services, acts, or things necessary to perform her responsibilities as
determined by H. Alexander Zaleski, COO. Employee shall specifically be responsible for the
following. Employee will be responsible for the transportation of medical cannabis from the
cultivation site to the dispensary site(s). It is BATC's intention to employ retired law
enforcement officers for the role of transporters. Law enforcement personnel are very
experienced in keeping detailed records and at data entry. Additionally, they are trained in
personal safety issues and the importance of safety in the workplace. These will all be
responsibilities of the medical marijuana transporter. Employee shall devote his/her full working
time, efforts, ability, and attention to the business of Employer during the Term and shall not be
engaged in any other business activity, whether or not for gain or profit, during such period.
during the Term, Employee shall receive a base salary of $____________ a year payable in equal
installments of $___________ on the first and fifteenth day of each month. Employer shall

effect immediately.
Jersey.
disbursements.

Executed as of , at , New Jersey.

By______________________________________

BUSINESS PLAN

DISCLAIMER
This Business Plan (and any and all drafts and parts thereof) is based upon information
supplied by Breakwater Alternative Treatment Center, its President, and is being furnished on a
confidential basis, solely for use by prospective investors in and/or potential strategic business
associates of the company (collectively ‘recipient’). The use or distribution of this Business Plan
to any other parties or for any other purposes is not authorized.
Neither the company, nor any of its respective employees, contractors, affiliates or
representatives makes any representation or warranty, express or implied, as to the accuracy or
completeness of any of the information contained in this Business Plan or in any other written or
oral communication transmitted or made available to a recipient. .
Material portions of the information presented in this Business Plan constitute ‘forward-
looking statements’ which can be identified by the use of forward-looking terminology such as
‘may’, ‘will’, ‘expect’, ‘anticipate’, ‘estimate’, ‘plan’, or ‘continue’ or the negative form thereof
or other variations thereon or comparable terminology. Such forward-looking statements
represent the subjective views of the management of the company, and management’s current
estimates of future performance are based on assumptions which management believes are
reasonable but which may or may not prove to be correct. There can be no assurance that
management’s views are accurate or that management’s estimates will be realized, and nothing
contained herein is or should be relied on as a representation, warranty or promise as to the
future performance or condition of the company. Industry experts may disagree with these
assumptions and with management’s view of the market and the prospects of the company.
The sole purpose of the Business Plan is to assist a recipient in deciding whether to
proceed with further investigation but this Business Plan does not purport to contain all material
information that an interested party might consider in investigating the company. A recipient
should conduct his or her own independent analysis and investigation. This Business Plan shall
not be construed to indicate that there has not been any change in the financial condition,
business, operations, plans or other affairs of the company since the date of preparation. The
company does not expect to update or otherwise revise this Plan to reflect any such changes.
Introduction
The Breakwater Alternative Treatment Center (“Breakwater”) concept was created to infuse
horticultural innovation and sympathetic treatment into the medicinal marijuana industry.
Breakwater is committed to combining mental and physical health in a format previously
inaccessible to terminal and other patients. Breakwater plans to bring this concept to fruition
through the use of “green” growing techniques to create an affordable medicinal marijuana
product in a concerned and compassionate setting bringing both physical and mental relief to
qualifying patients.
New Jersey. For example, BATC will establish a fund and allocate a percentage of excess funds
to pay for patient licenses and medicine for those patients that cannot afford to pay themselves.

At no time will excess revenue inure to the benefit of any individual person or member of
After evaluating the medical marijuana industry nationwide and taking into account the needs of
patients in New Jersey, Breakwater Alternative Treatment Center has determined estimates for
an Alternative Treatment Center located City of Manalapan located in Monmouth County and a
cultivation site in New Egypt located in Ocean County. We have chosen these cities due to our
long established relationships with community leaders and residents within the City of
Manalapan as well as New Egypt and the surrounding areas.
The Concept
BATC will produce the highest quality medicinal marijuana using the most environmental and
cost effective growing techniques. Employing a growing system using organic pest controls,
sunlight and recyclable water and resources, Breakwater will produce the finest product at the
lowest cost. This method will ultimately enable Breakwater to pass its production savings on to
its patients. Along with its medicinal marijuana production, Breakwater intends to provide free
Chiropractic services and a library of information on the use of medicinal marijuana and holistic
healing.
The initial growing facilities will consist of a single 120ft. x 60ft. greenhouse located at a secure
facility providing its own structural security in addition to the security provided by Breakwater.
The growing location as proposed is adequate to hold a minimum of 12 greenhouses (minimum
production capabilities of 1,320 pounds at one given time) allowing Breakwater to expand its
growing facilities as the needs of its patients increase.
In addition to the proposed growing facilities, Breakwater shall maintain a handicapped
accessible dispensary center in the centrally located part of Monmouth County in the City of
Manalapan allowing its patients ready access to recommended medicinal marijuana and the
additional services provided by Breakwater, including but not limited to:
Charitable Initiatives and Servicing of Indigent Patients

The members of the BATC management team have been proponents of using medical cannabis
for alternative patient treatment for over twenty-five years. Whether through a personal
qualifying medical condition, through family members or friends, the BATC team has
experienced firsthand the positive benefits that Medical Marijuana provides to those who need it
most. Some of the health issues our team members have personally confronted include, but are
not limited to: various cancers, Multiple Sclerosis (MS), severe chronic pain, glaucoma, and
other severe pain conditions, and various other current approved conditions. BATC is fully
committed to providing medical cannabis to low-income qualifying patients to eliminate
disparities in access and treatment for our patients. Each year BATC will commit a percentage of
its net operating revenue to patient programs as well as another portion to other non-profit and
charitable organizations like Good Tree Farm in New Jersey that support BATC’s mission and
will invest in research and treatment efficacy studies affiliated with New Jersey colleges and
universities. Any profits after expenses will be re-invested in the business to improve services to
patients and implement energy efficient technologies in order to reduce the company’s carbon
footprint. In addition, BATC will provide the following services as part of our commitment to
operate as a non-profit corporation:

a. Patient Activist Resource Center
The Breakwater Alternative Treatment Center endorses active participation in advocacy,
public policy-making and social promotion of the medical cannabis movement. BATC will
establish an on-site Patient Advocacy Resource Center to enable patients and family
members to gain more knowledge about medical marijuana and provide advocacy tools to
help promote public awareness of the benefits of medical marijuana.
b. Reading Library
Free educational literature on medical cannabis will be available in the on-site reading library
in the dispensary and will provide patients with reading materials covering topics such as
cannabinoids research, pain and stress management and holistic approaches to health and
wellness. BATC will consult research studies by such recognized authorities as Raphael
Mechoulam, PhD, the father of our modern understanding of the nervous system and
cannabinoids system, and many of his successors to develop an easy to understand program
and approach to explain the effects of THC and cannabinoids on the body.
c. Alternative Care Assistance Program

BATC is fully committed to providing medical cannabis to low-income qualifying patients to
eliminate disparities in access and treatment. BATC will seek guidance from the New Jersey
Department of Health and Senior Services (NJDHSS) to determine the most appropriate
approach to providing assistance to patients who are unable to afford the cost of medical
cannabis, such as those populations covered under SSI or other assistance programs.
One of BATC’s primary goals is to give back to the community and it intends to do as much
as it can with the resources available. BATC has been working with CMMNJ and the patients
of New Jersey to understand the local medical cannabis market and the needs of the patients
on SSI and others with low incomes. BATC understands there is a growing demand for
medical cannabis at an affordable price. Most of those being assisted through caregivers are
receiving excellent care at an affordable price but not all are receiving the care they deserve
and some just need more medicine. BATC is familiar with patients as well as caregivers who
have served them in New Jersey. BATC will never sell products or provide them to those
with low incomes that fail to meet strict purity and quality control standards.
d. Healthy Incentives Program

BATC will offer incentives to patients who choose healthy ingestion methods. Breakwater
Alternative Treatment Center's Rewards Program is a way to encourage patients to select
healthy and safe ingestion methods and wellness activities. There is no cost or activation fee
of any kind. Our advanced web-based system assigns each patient their own profile and will
automatically track their healthy activities.
Incentives will be given to those who buy:
Vaporizes as a method of ingestion
Healthier Lozenge choices (produced with Light Olive Oil, organic brown sugar and
sugar-free)
And many more healthy ingestion options will be available
e. Holistic Services

BATC will offer referrals, complementary and reduced fee holistic services to patients in
order to promote a healthy lifestyle. BATC is developing partnerships with qualified
professionals throughout New Jersey to bring these services to patients.
f. Unused Excess (Returned) or Unusable Marijuana

We will accept unused excess (returned) marijuana from registered patients or caregivers but
we will not redistribute it. Instead it will be destroyed by a method approved by the NJDHSS.
All returned or unusable marijuana will be turned over to the New Jersey State Police for
destruction. The mechanics of the turnover and the frequency will be determined after
consultations with appropriate commanders in the New Jersey State Police Department. We will
weigh any amount received from outside sources and will set aside at a minimum an equal
amount of our own product to distribute to those that cannot afford marijuana for medical
purposes. We stand behind all of our products and guarantee that consistency of quality will be
maintained. We will offer full refunds for any of our products distributed that the patient is not
satisfied with, no questions asked. See also Exhibit 2- “Greenhouse Quote” (Attached)
Price of Medical Marijuana

Just like prescription pharmaceuticals or over the counter medications, there are many different
types of medicinal cannabis. Certain plants are better at treating certain illnesses than others.
This will cause cost to vary depending on the particular medicine. But, generally, our price range
will be $240 to $280 per ounce. To those who qualify for government support will be on a
sliding cost scale from providing free medicine (to those who need it most) up to a reduced cost
of $200 dollars an ounce. Please refer to the sliding scale presented in Section 9.7 of the
Operations Manual.
Development Timeline
The expectation is for a 6-7 month ramp-up to fully establish a growing location. The timeline
(See Question 13 “Startup Timetable”) shows the duration each critical milestone will take,
and then the subsequent major milestones in establishing a fully operational growing center and
dispensary.
Management Team
Richard S. Lefkowitz, ESQ. – Chief Executive Officer (CEO) & Board Member
H. Alexander Zaleski, ESQ. – Chief Operating Officer (COO) & Board Member
Dr. Hisham Moharram, PhD – Chief Cultivator & Board Member
Capital Requirements and Summary Financial Projections

A detailed description about the amount and source of the equity and debt commitment for the
proposed dispensary that demonstrates the immediate and long-term financial feasibility of the
proposed financing plan, the relative availability of funds for capital and operating needs; and the
financial capability to undertake the project.
a. Equity and Debt Commitment

The Company has projected capital requirements of approximately $825,000 to commence
and maintain initial operation and expansion. To insure adequate capitalization, the Company
is presently capitalized with $1,500,000 borrowed from BlueMark Asset Management Corp.
at a favorable rate (5 percent), commencing upon the issuance of a permit by the State of
New Jersey. The loan will enable us to continue business operations and startup costs without
the need to pay any interest expenses during the first 4 years of operation.
After extensive review of other established facilities and established growing and dispensary
centers, BATC believes that $1,500,000 is more than sufficient capital to cover all startup
and initial operating expenses including but not limited to preparation of both sites, legal
compliance, insurance, initial payroll with fringe benefits, supplies, office expenses, utilities,
leasehold expenses, taxes and other business overhead. Additional sums remain available, if
necessary, to fund BATC’s longer term financing needs until BATC becomes self-sustaining.
The startup equity is currently being held in escrow by the law offices of Jonathan Fisher,
Esq. in the sum of One Million five hundred Thousand Dollars ($1,500,000.) for the benefit
of Richard S. Lefkowitz the CEO and H. Alexander Zaleski the COO. The source of the
equity comes from a privately financed loan that has been fully committed to and pledged for
this project. Please see Exhibit 1 “Loan Guarantee” (Attached)
b. Accessing Startup Capital

The funding is liquid and remains available to cover capital and operating needs,
immediately upon receipt of BATC’s permit.
c. Project Feasibility
As stated above, BATC, through the loan proceeds, will have all the funds necessary to build
and operate the previously described cultivation site and dispensary. Our Management Team,
Board of Directors, Medical Advisory Board and Consultants possess the requisite expertise
and commitment to ensure the success and sustainability of the project.
Income Statement
Breakwater has set forth a three-year plan employing an expansion model based on anticipated
patient needs using data collected from medicinal marijuana dispensaries in other States within
the United States. The Company will begin operations with one growing greenhouse and one
dispensary. In anticipation of the need for expansion, Breakwater has accumulated working
capital of $1,500,000. Based on Breakwater’s research and projections, this initial $1,500,000 in
working capital is sufficient to finance all of the potentially necessary expansion as well as all
necessary startup costs. In short, Breakwater is fully financed at inception. All Greenhouses shall
be located in one secure location, while the proposed dispensary shall be strategically placed in
the Central Region of the State of New Jersey providing ready access to patients taking into
account both regional population and proximity to major roadways.
Below is a complete Income Statement for the Company’s initial three years of operation.
PLEASE NOTE: The provided projection does not include interest payments on $1,500,000
borrowed capital, when in fact the Company projections call for approximately $825,000 in
borrowed capital. The loan will enable us to continue business operations and startup costs
without the need to pay any interest expenses during the first 4 years of operation.


Expansion Plan
At the conclusion of the first year of operation, BATC will decide, in cooperation with the
NJDHSS, if there is a need for additional services. If the Department of Health and Senior
Services allows we would like to add our own transportation vehicles to transport patients who
lack access to public transportation and bring them to Breakwater Alternative Treatment Center’s
dispensary. We believe that our dispensary location would support the population density and
ease of access to the majority of the citizens in the Central Region of New Jersey. Under our
current business model forecasts, BATC sees additional demand for its services beginning
around March of 2013. If these models are correct, BATC will begin the necessary planning for
expansion towards the end of 2012. BATC understands that Alternative Treatment Centers are a
new model for providing medical marijuana to qualifying patients in New Jersey and that
demand could change dramatically and patient numbers could increase due to improved access to
safe, high quality medical cannabis. BATC intends to be prepared to meet fluctuations in patient
load and product demand in order to ensure sufficient supply of medical cannabis to qualifying
patients in New Jersey.


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Breakwater Alternative Treatment Center

Application for the Operation of a Medicinal Marijuana Alternative Treatment Center

Breakwater Alternative Treatment Center, Corp. (BATC) is comprised of an accomplished

Our Management Team includes:

Our Medical Advisory Board includes:

Breakwater Alternative Treatment Center p.1 of 210

BREAKWATER ALTERNATIVE TREATMENT CENTER, CORP.

Breakwater Alternative Treatment Center p.2 of 210

Proposed Legal Name: Breakwater Alternative Treatment Center Corp.

¾ Certificate and Articles of Incorporation and By-Laws for corporations

Breakwater Alternative Treatment Center p.3 of 210

Dispensary Address: 400 Madison Avenue

Breakwater Alternative Treatment Center p.4 of 210

Dispensary Location (ATC)

Breakwater Alternative Treatment Center p.5 of 210

Breakwater Alternative Treatment Center p.6 of 210

Breakwater Alternative Treatment Center p.7 of 210

Directors of Breakwater Alternative Treatment Center Corp.

Breakwater Alternative Treatment Center p.8 of 210

2. H. Alexander Zaleski, ESQ. (Alex) – owning 50%

Breakwater Alternative Treatment Center p.9 of 210

3. Dr. Hisham Moharram, PhD

Breakwater Alternative Treatment Center p.10 of 210

6. Joseph Bender, Horticulturist (Joe)

Breakwater Alternative Treatment Center p.11 of 210

7. Amy Klauber, ESQ.

Breakwater Alternative Treatment Center p.12 of 210

Direct Management Oversight:

2. H. Alexander Zaleski (Alex)

3. Dr. Hisham Moharram, PhD

Breakwater Alternative Treatment Center p.13 of 210

1. Bluemark Asset Management Corp.

Breakwater Alternative Treatment Center p.14 of 210

3. Sheldon Gross Realty, Inc.

5. Joan E. Zaleski (CFP)

8. Certified Information Systems Security Professional (CISSP)

Breakwater Alternative Treatment Center p.15 of 210

Breakwater Alternative Treatment Center p.16 of 210

PLEASE NOTE: ALL OF “APPENDIX G” INCLUDED BELOW IN PAGES 65-143 MUST

8:64-9.1 Alternative treatment centers policies, procedures and records.

Breakwater Alternative Treatment Center p.17 of 210

PLEASE SEE THE “BUSINESS PLAN” SECTION WITH OF THIS APPLICATION.

1. Dr. Hisham Moharram, PhD

Breakwater Alternative Treatment Center p.18 of 210

2. Richard S. Lefkowitz, ESQ

3. H. Alexander Zaleski, ESQ. (COO)

H. Alexander Zaleski (Alex) is a 1969 graduate of Fordham College, School of Business

Breakwater Alternative Treatment Center p.19 of 210

2. Management of medical and hazardous waste pickups and disposal.

3. Hiring capable employees

Breakwater Alternative Treatment Center p.20 of 210

4. Computer systems and business software experience

Breakwater Alternative Treatment Center p.21 of 210

Breakwater Alternative Treatment Center p.22 of 210

Breakwater Alternative Treatment Center p.23 of 210

PLEASE NOTE: “APPENDIX G: OPERATIONS MANUAL” (INCLUDED BELOW IN

Breakwater Alternative Treatment Center p.24 of 210

Record Keeping and Security

Breakwater Alternative Treatment Center p.25 of 210

Breakwater Alternative Treatment Center p.26 of 210

PLEASE REFER TO SECTION 15 OF “APPENDIX G: OPERATIONS MANUAL” TO

Breakwater Alternative Treatment Center p.27 of 210

Please see the following pages “Using Your Medicine”