Criterion 1: Submission of Required Information Regarding Applicant & Facility Measure 1: The legal name of the proposed Alternative Treatment

Center is “Grow Well, Inc. The following supporting documents are included as Appendix A.  Certificate and Articles of Incorporation and By-Laws for the corporations  Organizing documents for associations  Evidence of nonprofit status  Certificate of Good Standing issued by the New Jersey Secretary of State Measure 2: At this time, Grow Well, Inc. is planning one facility for both the dispensary and plant-cultivation center, each will have its own designated entrance. Registered patients, caregivers, dispensary and administrative staff will utilize the dispensary-designated entrance. The dispensary is Not only where medical cannabis will be dispensed, but other holistic health services and educational support classes and programs will be available for registered patients. Cultivation staff will use the plant-cultivation entrance only. The plant cultivation will be used for growing, manufacturing, testing, and packaging. The proposed physical location has not been finalized; we are in discussion with the real estate leasing agent (Margaret “Meg” Worthington, GRI. of Stephen N. Frankel Real Estate, Inc, Inc. 4803 Atlantic Avenue, Ventnor, NJ 08408) and the governing body of Egg Harbor Township about two locations. The two proposed sites are located on the street level, in a brick and/or brick and steel constructed building; all properties provide easy access and ample parking for patients. Grow Well is investigating the feasibility of these properties as they relate to state regulations and ease of accessibility for our patients. Both properties are located in Egg Harbor Township and are owned by the same developer. We had a meeting February 10, 2011, with the Township’s Technical Review Committee to present and discuss our proposal for an ATC in their community. The township advised the property located in Zone General Commercial (GC) would be appropriate for Grow Well’s needs. The other property is located in an industrial zone (M1) would require a zoning variance. According to the developer he fells either location should be acceptable and is investigating this matter with the township. Supporting documents are included as Appendix B. Measure 3: Supporting documents providing evidence of compliance with the local zoning laws are included as Appendix C. Measure 4: Google Maps of the area provide walking and driving distances to the proposed ATC locations and identifies, geographically, the closest school in the area being over 1000 feet of the proposed sites. The distance to the closest school is 1.1


miles as noted on the maps, therefore the proposed sites are not located within a drug-free school zone. Supporting documents are included as Appendix D. Measure 5: Grow Well utilized the services of, a zip code data base company, to prepare a service area map showing all of the zip codes within a 45 mile radius of Egg Harbor Township, 08234. Supporting documents are included as Appendix E. Measure 6: Grow Well has provided the role, qualifications, name, address and date of birth of each staff member and the role, name, interest percentage, address and date of birth of each principal, officer, and board member of the ATC. For any individual(s) not yet identified, a statement of required qualifications and position description is included as Appendix F. Measure 7: Grow Well, Inc. does not have any disqualifying Drug Offenses  Neither the applicant nor any staff member, principals, officer, board member has been convicted of a felony under any Federal, state or local laws, relating to drug samples, wholesale or retail distribution, or distribution of a controlled substance;  Neither the applicant, nor any staff member, principal, officer, board member has been convicted of a felony under federal, state or local laws.  There is no past experience in the manufacturing or distribution of drugs or controlled substances by the applicant or any staff member, principal, officer, or board member.  No Applicant or any staff member, principal, officer, or board member, has ever furnished false or fraudulent materials in any application concerning drug manufacturing or distribution.  The Medical Director, Jeffrey S. Pollack M.D., holds an unrestricted NJ Medical License, unrestricted Controlled Dangerous Substances License, an unrestricted Drug Enforcement Administration License, and unrestricted added certificate in the DATA 2000 Waiver. He is registered and qualified to prescribe medical cannabis under the NJ Medical Marijuana Plan.  There are no known disqualifying factors for any of the individuals referenced above in Measure 7. Measure 8: Grow Well, Inc. does not currently have any creditors. Measure 9: The Board of Trustees of Grow Well, Inc. will exercise direct or indirect authority


over the management or policies of the ATC. No other entities have authority directly or indirectly over the management or policies of Grow Well. Measure 10: As of yet, we have not finalized the site for the ATC, therefore, we do not have any parties having indirect interest in Grow Well, including interest in the land or the building. Measure 11: The cover sheet and attestation statement signed by Bonnie L. Johnson, Chief Executive Officer, who is authorized to make legally binding commitments on behalf of Grow Well, Inc., is included as the cover page. Criterion 2: Submission of Required ATC Operational Information Measure 1: Leonard and Bonnie L. Johnson will provide the funding and assets for Grow Well. They will contribute $300,000 if Grow Well is licensed as an ATC. Measure 2: Grow Well is comprised of a highly qualified and diverse team of professionals, including physicians, a chemist, biologist, marketer, horticulturist, certified teachers, and substance counselors all committed to excellence in products, services and support. Collectively Grow Well’s team represents over twenty years of experience in the Medical Cannabis industry (please see resumes and curriculum vitae in Appendix F). Together they will create a compassionate ATC where every patient will feel comfortable, safe and secure knowing they will receive unparalleled services every time they visit. Grow Well pledges to produce only the highest quality medical cannabis grown in an organically sustainable manner at an affordable price. Grow Well will improve the lives of its patients by utilizing a medical model with a strong research foundation in a diversified clinical platform. To achieve its objective, Grow Well has created three unique arms, all under the umbrella of one non-profit corporation. Eighty to 95% of the earnings in excess of expenses will fund these three initiatives. (1.) Complementary holistic therapies and services will be provided to enhance the lives of all Grow Well patients. (2) Testing and label identification, liquid chromatography will be utilized for cannabinoid profiling and pesticide detection. Additionally, microbiological screening, for mold and bacteria, will be performed on all medical cannabis flowers, tinctures, topical creams and any product containing cannabis. Grow Well wants its patients to know what is, and what is not, in their medicine. (3.) “Grow Smart,” the education and resource center, is dedicated to providing patient with all of the pertinent medical information, support services and agencies as it relates to their individual health needs. Grow Smart will also provide patients with seminars, workshops and


classes on; different methods of ingesting, non-psycho-active CBD rich strains, infusion and cooking classes, and substance use and misuse. Grow Well will satisfy its promise of producing the highest quality organic medical cannabis with the selection of F1breeder genetics; they are true breeding strains and show little variation in phenotype this will be cultivated in a closed end organic environment. One of Grow Well’s first objectives in providing the correct medical strains for its patients is to monitor its product and complementary service offerings to ensure they are properly matched to the needs of its patients. To achieve this information, Grow Well will enlist the services of it chemist, grow consultant, scientist and medical director to review the patient evaluation forms and provide input on Grow Well’s products and services. The Medical Advisory Board will then review their findings and suggestion(s) before a determination is made to change its offer of a particular strain or strains. The Medical Advisory Board, together with the chemist, medical director and scientist will develop a questionnaire and protocol for the patient assessment. Grow Well’s holistic services will be determined once a patient population profile has been defined, thereby choosing therapies and services that are optimally aligned with the needs of its patients. Once the complementary services are available they will be listed on the website with a schedule and appointment chart for self-scheduling by patients. A patient will also have the option of making an appointment by telephone. Abiding by the rules and regulations that establish, “No Loitering,” these services will only be provided by appointment. Once the Dispensary is operating, Grow Well’s scientist will conduct testing on all cannabis and cannabis products sold in the dispensary. Screenings for mold, purity of medicine, and pesticide residue will be a part of Grow Well’s routine quality assessment. Upon successfully passing all specifications and acquiring negative safety screening results, the products will be labeled accordingly and subsequently made available to patients for consumption. Pending licensing and approval by the State, Grow Well’s testing and labeling services, which is a patented system developed by a chemist could be utilized throughout the State to ensure a uniform standard of quality and purity in medication. It is an effort to move New Jersey forward in safety standards. The third arm of the corporation, “Grow Smart,” will begin partial operation with the opening of the dispensary. Reference materials and agency support service information will always be available to patients and caregivers. Schedules for classes, seminars and workshops will be listed on the website as well as posted within the dispensary. Patients and caregivers must register online for all classes and workshops. These services will be provided by appointment only to abide by the rules and regulations that establish “No Loitering.”


Another objective of “Grow Smart” is to offer Continuing Medical Education classes (CME) and seminars for physicians. Ongoing training and workshops will be available for employees currently working in, or interested in the Medical Cannabis industry. Through collaboration with the country’s leading medical cannabis training center, Grow Well will conduct seminars for medical professionals and individuals desiring to work in the industry. These programs will be put into place once licensing has been granted. A business plan is included as APPENDIX G-1 . I The capital funding for the operation of Grow Well, Inc. as an Alternative Treatment Center, will be provided largely by, Leonard Johnson and his wife, Bonnie L. Johnson. Leonard and Bonnie L. Johnson will personally pledge $300,000 in cash to support Grow Well, Inc., if it is granted a license to operate as an Alternative Treatment Center in the Southern region of New Jersey. Based on Grow Well’s financial projects this should be sufficient working capital. If additional funding is needed Grow Well will seek funding from Venture Capitals. II. As a non-profit corporation, Grow Well pledges that a minimum of 5% and up to 20% of its revenue, in excess of expenses, will be allocated to Grow Well’s subsidy program, local and regional charities, nonprofit agencies, research initiatives, community events and programs that provide support to the patient population it serves. Grow Well is dedicated to providing patients with safe access to affordable medical cannabis regardless of one’s financial situation. Its mission is to enhance the quality of life for every patient that walks through the doors. No qualified patient will be turned away. A sliding scale based on individual needs will be incorporated into Grow Well’s fee structure for all medicinal products. Grow Well’s compassion program provides discounted medication to qualified registered patients of Grow Well that may not always have the means to purchase medical cannabis. A percent of the revenue from the operation of the ATC will be placed in a dedicated fund to cover a portion of, or all of the cost of medicine, holistic services and education programs. All patients are eligible to apply for subsidy. Subsidies will be based on financial need and will provide eligible patients certain services for free and discounts up to 80% off the retail cost of products. A portion of this fund will be used to assist indigent. The procedure for indigent patients will be the same as for subsidy patients. The Medical Advisory Board will develop and review the policies and procedures for this program.


III. Grow Well recognizes there is a legal requirement for all ATCs that cultivate and dispense medical cannabis to comply with the various regulations and the responsibility of safety to the community and the environment. Grow Well will adopt the principles of the “safest and most environmental conscious option” that adheres to the rules and regulations of the Medical Marijuana Program. Grow Well will apply a waste hierarchical approach to reduce, recycle, reuse, and remove.  All waste material will be documented in the computer system, date received/destroyed, method used, weight, strain, and origin. Each entry in the computer system is identified by the assigned access code given to each user.  Placed in a locked container (each container will be identified as to its origin)  Wasted stems and stalks will be mulched.  Mulched material will be removed to recycle bin(s). Leaves and unusable materials will be liquefied.  All waste materials will be removed to composting containers.  Liquefied waste will be added to the compost,  Thereby creating usable compost.  Any other waste will be recorded in the computer as unusable inventory, bagged and labeled with weight for removal by the New Jersey State Police for destruction. Patients and/or caregivers returning opened and partially used or unopened cannabis will be given a replacement equal to the amount and weight of the returned medicine. We want our patients to be satisfied, however we will document patient information and reason for returning to avoid constant returns.  Any unused medicine being returned by a patient must still be in our containers with the label attached.  Only bud tenders or management can return unusable cannabis.  Place unusable cannabis in designated return bag.  Bud tender returning unused medicine will enter the patient/caregiver’s information in the computer.  Enter the label information in the computer under damaged inventory and print the label; use the label to seal the bag.  Remove to damaged area for composting. Unusable plant trimming materials will be processed into oils. Processing includes the removal of trichomes, by ice-extraction, and then the same materials shall be rinsed and processed for oils. These oils will be used for topical and oral preparations.


IV. Projected income statement for the first three years. – (For complete information, please refer to the Business Plan included as APPENDIX G). RAMP UP YEAR 2011 REVENUE FIRST FULL FISCAL YEAR 2012 SECOND FULL FISCAL YEAR 2013



Measure 3: Bonnie Johnson has over twenty years of marketing experience, with a strong concentration in the non-profits sector, as the Director of Special Events for the ShopRite LPGA Classic, a New Jersey Nonprofit Corporation. She developed and maintained the department’s budget; set projects, analyzed inflow and outflow, and organized events that helped to raise millions of dollars for local charities. Ms. Johnson also gained experience running her family’s property and casualty insurance agency. Dr. Pollack has been a physician since 1984, and has operated his private practice, Shore Internal Medicine, since 1990. He has worked for not-for-profit


corporations, such as Medical Director of Ocean Point Health Care Center as a board member of AtlantiCare. Criterion 3: Measure 1: On Thursday, February 9, 2011 at 9:45 am, Grow Well met with the Egg Harbor Township Technical Review Committee (TRC) to present its proposal to operate an Alternative Treatment Center – Cultivation/Dispensary in Egg Harbor Township, pending State licensing. Grow Well presented an overview of the entire operations, outlining its necessity; an area to cultivate and dispense medical cannabis, as well as an area to provide patients with support services such as education and holistic therapies. Grow Well identified three locations physically satisfying its criteria for the operation of an ATC. Two of the properties are located in, Zone M1, an industrial zone, and the other property is located in Zone GC, General Commercial. After discussing its mission and purpose, the TRC advised the facility located in GC would be the best fit, offering the broadest land use, allowing cultivation, dispensing, and any support services that are directly related to the main purpose of operation. The TRC advised that the next step would e to return to the TRC upon be granted licensing to operate as an Alternative Treatment Center in the southern region of New Jersey. Measure 2: The Egg Harbor Township Technical Revenue Committee said the proposed site, 202 W. Parkway Drive, Egg Harbor Township, and Block 404 Lot 15, as an allowable location for the operation of an ATC. The TRC presented Grow Well with a Zoning Interpretation Letter. Also attached is a letter from Atlantic County Executive, Dennis Levinson. Criterion 4 Measure 1; All information pertaining to patients shall be considered and treated as confidential healthcare information and protected in full compliance with, but not limited to state and federal laws and regulations, The Health Insurance Portability and Accountability Act (HIPPA), Medical Marijuana Program (MMP), and NJ Department of Health and Senior Services (NJDHSS). All records, correspondences and data associated with patients will be stored in our security code-access computer system or in locked file cabinets with limited access by employees, consultants and volunteers. All employees handling any confidential information regarding patients must receive training in the handle of confidential documents. Grow Well will institute a rigorous patient confidentiality policies and procedures plan to monitor and control patient information by utilizing a secure software program designed by SBI. MMC requires the proper security clearance


level to access information. The software will be customized to be State compliant. Grow Well will execute a Business Associate Agreement with HSS to enable the transfer of files that may be necessary in verifying patient/caregiver participation.

Measure 2:


Grow Well’s medical director was a former physicians at the Lighthouse Recovery Center locate in Mays Landing, (See attached CV Measure) Measure 3: All staff will receive as part of their training and orientation, important information on security measures. All prospective employees will require a background check before initiating employment. All potential employees will require a drug screening, including for cannabinoids prior to employ. All potential employees will require verification of their Identity. All potential employees will require reference verification before initiating employment. All employees will be issued an electronic photo ID card that must be used to enter secure areas of the facility, including the general work areas. The additional measure of Biometrics shall be needed to pass through certain areas. Biometrics may include a thumbprint analyzer or iris identifier. Certain areas will not allow non-authorized users access through this electronic gate. All access points will have time stamp automatically so that should there be a breech of security by Grow Well personnel, the exact time and person can be readily identified Measure 4: The plant cultivation center and the dispensary will be located in the same facility. Measure 5: The Medical Advisory Board shall advise the Board of Trustees on all matters medical Measure 6: Grow Well will monitor its products and services to ensure patients are receiving optimum benefits for their treatments. This will be accomplished by Grow Well’s software program that provides tracking of each patient as it relates to their medical selection and services. This information is input during every visit by Grow Well. On return visits patients will be given a questionnaire upon check in, the forms will only be identified by the patient number and matched once entered into the computer. The questionnaires will be reviewed by the medical director, scientist and chemist, to: 1. determine if the current regime is optimally aligned with the patients, 2. develop a plan of action, and 3. discuss their findings with the patient and send a follow-up report to the recommending physician. Criterion 5: Measure 1: In an effort to optimize security, Grow Well has consulted with Kriebel Security to devise a security system for its ATC. Kriebel Security is a bank security company providing security systems for over 3000 financial institutions and drive thru pharmacies.


Additional Grow Well will hire a retired police sergeant, as head of the security with two addition guards for twenty-four hour physical protection. All areas containing Medical Cannabis and Cannabis products will be in a secure locked area requiring card and biometric entry. Entry cards are keyed to an individual’s level of responsibility, and granting access only during the designated work shift, to the area(s) that relate directly to their job. Security cameras will monitor areas where Cannabis products are stored. The name and telephone number of the president or designated staff member will be given to the police, and an as a security measure for the “staff person” an emergency number will be given to neighbors within 100 feet. Any discrepancies identified during inventory, diversion or theft, of and property including but not limited to funds, and Medical Cannabis products will be immediately reported to the property authorities by telephone, and followed up with a written report. Grow Well will notify the State immediately and not longer than 24 hours by telephone at (60) 826-4935. All Reportable incidences including but not limited to alarm activation breach of security and failure of the security system due to loss of electricity of malfunction, will be followed by a written notification within ten days. The exterior of the building will have sufficient lighting that remains with additional motion detector lighting. The proposed security system layout will be finalized once a site has been secured. The system Grow Well is planning to utilize is included as APPENDIX F Measure 2:The actual building where the cultivation and dispensing will be located has not been finalized; therefore the construction details are not available at this time. Grow Well is still negotiating the details as noted in Criterion 1: Measure 2. However we have contacted a security company and the Egg Harbor Township Police Department to assist with the development of the most effective and safe system. The township police department Officer Robin Lynd #15101 said they would come out and look at the site once we have received our license. We are to contact an Officer Palmenter, as he is the one who handles this type of request. The area where Cannabis and Cannabis products will be cultivated, manufactured store, packaged, and tested will have security cameras inside and outside the enclosed locked area. Individuals entering this area will need a high-level security clearance on their access card along with being identified as a biometric user.


All cured cannabis ready for dispensing will be stored in a TL 15 safe. Supporting information is included as APPENDIX H (See APPENDIX H–Criterion 5: Measure 1) Measure 3: Grow Well will use a constant production cycle to produce perpetual product. This is accomplished by using 3 phases of simultaneous growing areas consisting of a nursery, vegetation and bloom cycles. The plan allows for structured growth without affecting existing production operations. Production rooms may be built, modified and added as needed. A minimum of one room each shall be the basis for the startup with additional production rooms added. Full production shall consist of multiple rooms of each distinct type allowing for complete purging between cycles while maintaining full production quotas. As an example, a bloom cycle could be finished and then the room taken out of service, purged and recommissioned while another bloom room would be in full production. This allows for complete cleaning in between cycles while maintaining quality control and production levels. In essence it provides insurance in the way of multiple smaller crops rather than one large crop. I. Setup – 8 weeks after issuance - Prepare building, green rooms, bloom rooms, nursery, drying rooms, garden preparation area, dry storage, product storage, processing, shipping/receiving and disposal, to include electrical, plumbing and HVACs. Garden Master (grow consultant) shall verify installation of lighting and final testing. Complete purging of all production areas to be performed prior to activation. Limited Production – 13 weeks after issuance - Nursery, seed selection and sexing will be the first step. This will consist of planting, sexing, culling and selecting the mother plants to be cloned for Production. Many plants will be started to have a greater selection for vigor, production and uniformity. Only one female of each strain shall be selected for cloning and crop production. Early sexing techniques shall be used to prevent and control contamination from males. Green rooms will be planted with clones and grown for a 4 to 5 week period. Plant height shall be in the range of 3-6 feet with a canopy of 3-5 feet in diameter. Bloom rooms are expected to run up to 6 weeks. Production shall be configured by the square foot of canopy cover. First Production – 18 weeks of issuance - First production harvest is expected at 18 weeks. Production shall be no less than 0.5 oz of quality usable medicine per square foot of canopy. Production harvest information shall be recorded and documented. Future production harvest quotas and forecasts shall be set by this information.


Phase 2 Full Production – 26 weeks - Additional vegetation and bloom rooms shall be commissioned at the rate of one set of rooms per 4 weeks until demand is determined to be met or desired limits reached. Crops are estimated to be cycled every 10 weeks through entire growing cycles of vegetation and bloom stages. II. Grow Well’s Garden Master is one of the founders of Stoney Girl Gardens; a world-recognized leader in developing, growing and producing the finest in true organic medical cannabis. Stoney Girl has over 12 years of experience with the Oregon Medical Marijuana Program producing, quantifying and clarifying safe, organic medicines for patients. Stoney Girl operates an educational university specializing in the techniques of the medical cannabis industry to include cultivation and safe dispensing mechanisms. Stoney Girl is currently responsible for 9 centers in successful operation in Oregon. Stoney Girl is the parent company of Sunny Girl Gardens, a manufacturer of 100 percent Organic-growing mediums, which included all fertilizers and soil less mediums required. Methods are within strict guidelines for ATTRA, USDA Organic and OMRI standards in accordance with the National Organics Standard Board. Stoney Girl Gardens is well published in most of the international industry journals and is considered the current top breeder of the world. III. Some of the best quality control comes from prevention. A culture of prevention and avoidance of contamination issues will be adopted and rigorously evaluated and enhanced as new knowledge and understanding is gained through future activities and developments. To ensure each safety and prevention step is always followed we will establish and continually update our Standard Operating Procedures (SOPs). It is important to note the scientific community has not fully developed a solid understanding of the manufacturing, storing, packaging, and general quality control of medicinal marijuana. Fortunately for us though, we have found some experts in the field from California that are prepared to help guide us through our efforts of providing excellent medicine to our patients. Product consistency will be accomplished through use of a continually controlled environment for cultivation, utilizing the same growth conditions from harvest to harvest, and utilizing the same genetics through the use of modern cloning techniques.


Purity and potency of medicinal marijuana will be determined in-house through the use of modern analytical equipment. High Performance Liquid Chromatography (HPLC) will be used to determine the weight percentages of major cannabinoids present in the products. Liquid Chromatography is superior to and has distinct advantages over Gas Chromatography techniques due to the nature of the cannabinoids produced by the plant. The plant's native carboxylic acid compounds, mainly tetrahydrocannabinoilc acid A (THCA), are sensitive to heat and if not analyzed properly will provide false results, which impact upon end dosing. As the Cannabis sativa L. cultivars do not directly produce D9-THC, but instead produce D9-THCA, it is critical that accurate detection of both compounds be performed by all testing laboratories. Recent relevant research on cannabinoid detection methods has described how liquid chromatographic techniques are the choice method to detect the exact amount of chemicals present in dried herbal marijuana products (Dussy, F., et. al., Forensic Science International, 2005, v. 149, p. 3, “Isolation of D9-THCA-A from hemp and analytical aspects concerning the determination of D9-THC in cannabis products”) by allowing for the detection of both D9-THC and D9-THCA. A comparative analytical technique currently being commonly employed is based on gas chromatographic methods that require excessively heating samples before they reach the desired detector. The required high temperatures employed in gas chromatographic analysis do not allow for detection of D9-THCA and have been shown to produce decomposition and oxidation products instead of the exact components present in the sample. Detection of D9THCA is critical when attempting to accurately analyze food or orally consumable-based marijuana products as these products are not intended to be heated further before consumption. Large amounts of D9-THCA being present provide different physiological effects, specifically nonpsycho-active effects, as opposed to larger amounts of D9-THC being present in an orally consumable product. Unique therapeutic effects are possible through finely tuned products containing both components. Therefore, based on recent peer-reviewed scientific literature, liquid chromatographic techniques will be employed for screening cannabinoids present in products provided and labels will subsequently include D9THCA reporting values. It is important to note that some physicians are now advocating the use of raw whole plant consumption, by consuming the fresh plant leaves and flowers through a juicing process, to allow for ingestion of large amounts of D9-THCA without significant quantities of D9-THC. Recent accounts by Dr. William Courtney are that these carboxylic acid cannabinoids, such as D9-THCA, are incredible antiinflammatory compounds. Understanding which cannabinoid compounds are present, along with their effective uses and dosing ranges, can only be determined with the use of adequate analytical technologies, such as our


proposed liquid chromatograph. Figure 1 demonstrates some of the chemicals associated with cannabis and how they can be produced.

Grow Well will ensure that all medicinal products are of the highest quality, free of harmful pollutants, and meet all state standards. Periodic random sampling tests with be performed, the testing will include a comprehensive assessment of the botanical content information. Microbiological assays and chromatography (LC/MS) will be used to analyze the botanical features and screen for purity, potency and consistency within the strain(s). IV. Grow Well’s methods and procedures:  Grow Well will only use F1 breading genetics that are not hermaphroditic all plants grown will be from selected females. Clone reproduction will be performed to insure only female plants are used. Early detection for hermaphrodites will be conducted as a routine daily maintenance task. Careful monitoring throughout the vegetation and flowering cycles, rooms are sealed off from outside natural light and the required indoor lighting are on computerized timers and any indicator lights will either be in green (green light does not affect the light dark cycle of the plants) or concealed. The entrance to all grow areas will have double doors with the door leading into the sealed grow areas controlled by a biometric entrance. All 16

lab uniforms are color coded to grow room to further limit breeding, and/or contamination.  Trained, certified garden technicians and routine, logged inspections 3 times daily. Rooms are to be purged between every cycle. Routine screens and testing to be performed for molds and bacteria. Purity of medicinal products will be assured through a rigorous Analysis, including visual inspection with accompanying photograph, moisture content analysis, liquid chromatographic analysis to understand content and assure product consistency through the products chromatographic profile, along with pesticide residue and subsequent microbiological screening. Pesticide residue screening will be accomplished using similar methodologies to those currently published for food and agricultural products. Typical methodologies involve extraction and subsequent analysis using either a liquid or gas chromatograph coupled to a massspectrometer. Pesticides, fungicides or herbicides to be screened for will be those that were possibly previously applied to any cultivating efforts, or are specifically designated by the State. Microbiological screening will be accomplished using an optical based incubator platform provided currently to the pharmaceutical, cosmetics and dietary supplement markets. The methods of its operation have been validated against traditional plating techniques and have been demonstrated to screen for hundreds of different organisms in three different classes. Total Aerobic Counts, Enterobacteria Counts and Total Combined Yeast and Mold Counts are available in only 48 hours of testing time. These broad based screens have been utilized in testing botanical products and our testing will be performed at levels suggested for dried botanical products according to the United States Pharmacopoeia as shown according to the following table. USP CFU/g Total Aerobic Count < 105 Enterobacteria < 103 Total Yeasts & Molds < 103 Table 1: Microbiological Testing Limits in Colony Forming Units Per Gram (CFU/g).  Cleanliness, inspections, and natural eradication such as predator mites. No pesticides will be used. Preventing and protecting the plants from insect and disease will be achieved through daily routine microscopic inspection by the grow technician to check for the presence of any mold or pest. The grow technician will use a checklist to record their findings; information will be inputted into the computer to track and monitor the health of the plants throughout the growth cycle.


 All equipment and rooms shall be sanitized with chlorine compounds as per health regulations (i.e. chlorine purging and bromide cleansing for machinery) prior to use. Rooms shall be purged between cycles. Purging consists of complete treatment of all equipment including room with chlorine sanitizers. Diseased plant materials shall be disposed of directly through secure disposal and shall not be further processed. All waste material will be placed in bags, removed from the grow area and documented in the computer system with date/time removed, weight, strain(s), and room(s) unusable cannabis was removed from (vegetation, flower, and/or mother room) date/time destroyed, method used. Follow procedures for mulching and recycling as set forth in destroying unusable cannabis. All grow areas will be painted with a white reflective paint for easy cleaning and disinfecting. Plants will be on trays and raised with an automatic watering system. Limit access to a need to basis by authorized personnel only. All authorized individuals are required to wear the proper uniform attire. Each grow area will be color-coded with corresponding uniforms to prevent cross contamination. Clean grow rooms daily, removing all dead leaves daily.  Large carbons filtered exhaust systems. Negative pressure intake with filtered and HEPA cleaned air purification system to prevent airborne contamination. Trim the bottom of the plants to increase airflow around and between the plants.  The timely identification of a male plant is crucial to the success of the harvest. The methods Grow Well will employ to keep the environment free from flowering male plants are, ensuring that female plants are not pollinated in seed production and hybridization is prevented by only working with high quality feminized F1 breeding genetics. Females shall be culled and selected as mother plants. All production plants shall be clones from the selected female plant. No males shall be propagated or introduced to facility. Propagation shall be through cloning of a single female. Routine inspections and use of known female clones will prevent contamination. If by chance seeds are germinated they will be removed immediately by cutting the plant near the base and removing the plant before any of the flowers open. All plants will be sexed at a separate location. The grow area will be under quarantine and only female plants will be allow at this location. Below is a sample of the photos the grow technician will be supplied during their daily inspections.


It is can be very difficult to detect when a male plant enters the stage of flower development. The tip of the branch where a bud would develop will start to grow what looks like a little cluster of small balls, whereas the female plant will sprout small white hairs.  Grow Well will utilize the same system SBI designed to track the cultivation process for seed to sale. The system was originally designed for large nurseries with extensive inventories. All culture measures can be track and monitor with data and visual history. o Maintains and tracks the condition of each plant o Has an area for photos showing progress of the plant o Hand held inventory units allows for immediate updating of culled plants, wet cure transfer, dry cure transfers and new plants.  The product selection will start with flowers and tinctures, topical creams will be added the following year. Depending on patient needs, Grow Well will consider adding lozenges at a later time.  Most cannabis consumed for recreation is THC dominant, high in THC low in CBD. Until recently new studies are showing the benefits of cannabidiol (CBD) the non-psychoactive cannabinoid. When the THC and CBD levels have a 1:1 ratio the therapeutic benefits are increased, offering a wider range of benefits without the psycho-activity. Grow Well will start with the following strains and adjust if needed. Cannaton, A CBD rich strain 19

White Widow – recommended for multiple sclerosis, epilepsy and other seizure related illness Sour Diesel, recommended for muscle spasms, anti-nausea, anti-emetic and appetite stimulant  Grow Well has contracted with SBI a software design company of programs for the medical cannabis industry. This system tracks the process form seed to sale. Including vendor, inventory, strain and identification. It assigns control number, monitors cultivation care, success of the strain to the comment of the patients. The system has a security level access code allowing only authorized users to access or view sensitive information.  Provides live module monitoring of the grow site at all time to prevent theft and illegal activity  Interfaces with QuickBooks for accounting and accurate recording keeping.  Electronic Card Key and Biometric access is required by all qualified users to gain access to cultivation areas. Monitored alarm system with panic features. Video surveillance in and out. Personnel onsite. A sample of the biometric system Grow Well will utilize on the access door leading to the areas where cannabis is cultivated, manufacturer, tested and stored,



 Products will be packaged in nitrogen flushed and vacuum-sealed containers for longer-term storage. Products for immediate use will be packaged in a clean and sterile fashion into sealed medicine containers that will be properly labeled with their content and other relevant information as necessary. An example of a product label reporting weight percentages is shown below.

 Use of gloves, hair nets, smocks, hand washing, and food handling techniques as per health code. All employees shall be required to enter and complete a safe food handling course. Food Service Industry Standards shall be followed throughout entire process.




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