Compassion Centers of America Dispensary

Introduction Compassion Centers of America, LLC (CCA) has submitted its application to receive a permit to operate a medical marijuana dispensary at 1539 7th Street NW. Our dispensary will sell medical marijuana products in full compliance with all District of Columbia laws and regulations. The CCA dispensary will only sell medical marijuana products to patients and caregivers registered with the DC Department of Health to purchase medical marijuana from the CCA dispensary. All medical marijuana products sold at the CCA dispensary will be purchased from cultivation centers licensed by the DC Department of Health to cultivate medical marijuana and to produce edible medical marijuana products. Compassion Centers of America, LLC plans to initiate permit applications for buildout immediately after receiving the approval for a medical marijuana dispensary permit on March 30, 2012 and after we have secured our license. The dispensary will be fully operational within five (5) months from issuance of a license, which will likely be in August 2012. CCA will follow strict security practices at all times. All CCA staff will undergo background checks through the Metropolitan Police Department and will be registered with the Department of Health as medical marijuana registered employees. All CCA employees will be required to wear their CCA uniforms and DOH registration identification at all times they are at work. CCA will modify the building in order to achieve the maximum security protection possible. Such modifications will include security doors between every point of access between unrestricted and restricted areas, bullet proof glass in exterior windows and fronting the customer service area, exterior lighting, and electronic monitoring throughout the building. Despite the intensive security measures that will be established and in evidence both inside and outside the building, the dispensary will present a comfortable and professional environment where patients will feel secure and cared for. CCA has a strong commitment to ensuring that our dispensary will be a positive addition 1

to the community. To that end, we will participate in Neighborhood Watch activities, attend neighborhood meetings, stay in close contact with MPD, and work with area ANCs, council staff, and other community stakeholders. Who We Are The Compassion Centers of America, LLC (CCA) was developed by Green Door, LLC, a California-based company that has received awards from that state for the safe and responsible operation of its dispensaries. CCA has a combined staff experience of 40 years in dispensing medical marijuana. Because many of the patients that use our medical marijuana suffer from cancer, HIV, and other diseases that compromise the immune system, we only dispense organically-grown medical marijuana that we test to ensure that it is free of environmental pollutants, fertilizers, and chemicals. The CCA staff has indepth and comprehensive experience in providing medical marijuana products to qualifying patients, working with departments of health to ensure safe dispensing with no diversion of products, and ensuring care and understanding to the often very ill patients that use of our dispensaries. In addition, CCA staff have considerable training and background in dispensing medical marijuana securely. Throughout the packaging and dispensing steps, we use our barcode inventory system to make sure that all plants and medical marijuana products are closely monitored, lab-tested, and inventoried. CCAs innovative and thorough inventory tracking system, rigorous testing protocols, and facility security practices enable us to dispense medical marijuana products, while preserving quality and safety and maintaining secure facilities.

Dispensary Layout & Appearance The appearance of our secure dispensary will be unremarkable and will feature minimal signage, none of which will include the word marijuana or any visual depictions of marijuana. Only a green cross logo, a known symbol of a medical marijuana dispensary, will be visible on the front of the dispensary along with a small sign identifying the site as that of the Compassion Centers of America, LLC. No exterior signage will be illuminated. All entrances and areas surrounding the dispensary will be adequately lit at all times and will be under electronic monitoring. No one but authorized staff, inspectors, and police will have access to the restricted areas of the dispensary. The build-out of the property will ensure that no medical marijuana will be visible by the public from any door or window. Once modified the facility layout will include: Secure Patient Intake Area: Where patient and caregiver registration and ID cards are checked by the security guard; Patient Lobby: Where patients and caregivers make their purchases and wait to exit the building securely;

Patient Bathroom: Located in the Patient Lobby for the convenience of our customers, as well as ADA compliant; Secure Customer Service Area (from which medical marijuana is sold to patients and caregivers by three sales associates working behind bulletproof glass); Weigh Room: Where medical marijuana from the cultivation center is weighed, reapportioned, packaged into sealed containers, and labeled in order that can be sold to patients and caregivers, as well as tested for purity and cannabinoid profiling; Secure Storage Room: Where all packaged and labeled medical marijuana is stored after business hours and before repackaging for sale in the weigh room; Employee Break Room and Locker Area: Where registered staff change into their uniforms, take breaks, etc.; Staff Bathroom Conference Room: Where management and staff hold meetings and conduct training; Office: Where dispensary operations are managed, office supplies are stored.

Handling and Storage of Medical Marijuana On Site All procedures for handling, repackaging for sale, and storing medical marijuana will occur behind closed, locked doors in the restricted area of the dispensary. From the time of delivery of medical marijuana from the cultivation center to the point of sale, at each stage the medical marijuana handled it is tracked and logged into inventory. By utilizing barcode inventory and scanning technology, CCA can easily label and scan each unit of medical marijuana as it is delivered, repackaged, stored at close of business, moved out of safe storage during business hours for sale, and when recorded and stored for waste disposal by MPD. At each stage that medical marijuana is reapportioned and packaged for sale, the medical marijuana is weighed, packaged in sealed containers, labeled with a unique barcode that records when the medical was handled and repackaged, where it was cultivated, and when it was delivered to the dispensary. No medical marijuana will ever be disposed of in the trash. All medical marijuana waste that is created on site will be weighed, packaged in sealed containers, labeled with a unique barcode, and stored in the secure storage area until it is collected by the Metropolitan Police Department for destruction per regulation. In accordance with DC law, the dispensary will only have on site enough medical marijuana products to serve our registered patients for one month. At close of business, the dispensary director will transfer all medical marijuana products into the secure storage room. All inventory of medical marijuana is reported to the 3

Department of Health twice yearly. Inventory records will be encrypted and secured for a period of no less than four years.

Sale of Medical Marijuana Only patients or caregivers who produce their DOH registration to purchase medical marijuana at the CCA dispensary will be allowed to do so. First, patients must present themselves to security at the Patient Intake Area, where a security guard will verify through our database (linked with that of DOH) their status to purchase medial marijuana. Each patient or caregiver must their DOH medical marijuana registration card, a valid picture ID, and a physicians recommendation for medical marijuana. Only after they meet all the identification and registration criteria may they be admitted by security to the Patient Lobby. In the Patient Lobby, patients and caregivers may proceed to the Customer Service Area, where our Dispensary Associates will help them choose and purchase medical marijuana. In addition to this, the Associates will also check each patient or caregivers record to ensure that this person has not exceeded their 2-ounce maximum for month (a DC regulation).

All medical marijuana products dispensed or distributed to a qualifying patients or caregivers will be sealed in an opaque Compassion Center of America container that must bear a legible label, firmly affixed, that includes all of the following information: The name of the cultivation center where the medical marijuana was produced; The name of the CCA dispensary The quantity of medical marijuana contained within the sealed container; The cannabinoid profile of the medical marijuana contained within, including the THC level; A listing of any other ingredients besides medical marijuana contained within; The name of the recommending physician; The dispensing date that the medical marijuana was transferred to the qualified patient or caregiver; The qualifying patients or caregivers name and registration card number; A statement reading: This medical marijuana product is intended for medical use solely by the dispensary or patient to whom it is sold, and that any re-sale or redistribution of the medical marijuana to a third person is prohibited A statement reading: There may be health risks associated with the ingestion or use of this product. A listing of all chemical additives that were used in the cultivation of the medical marijuana including, but no limited to, non-organic and organic pesticides, herbicides and fertilizers; A listing of all the ingredients included in the ingestible product, in order from the most abundant to the least abundant ingredient; and A listing any potential food allergy ingredients, including milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soybeans. 4

No patient or caregiver will be permitted to open the sealed container of medical marijuana product on the premises. Patients and caregivers will receive written instructions with each purchase regarding the proper transport of medical marijuana. These instructions include the necessity of transporting medical marijuana directly to their registered home address or care facility, the prohibition of using medical marijuana at any other location, and the illegality of transferring medical marijuana to any other individuals. Any patients or caregivers who are not complying with these rules will be denied access to and service at our dispensary. Patients and caregivers will be required to enter and exit the building respectful of the surrounding community, and no loud, inappropriate, or illegal activity will be allowed within our dispensary or in the immediate area. In order to ensure the safety of our patients and to prevent the theft of medical marijuana from them, CCA will provide shuttle service to the Shaw-Howard University Metro stop, as well as valet service in front of the building for patients who drove to the dispensary.

Hours of Operation The dispensary business hours for patients and caregivers are Monday Saturday, 9:00AM 7:00PM. Deliveries will only be accepted at the dispensary Monday Saturday, 7:00AM 9:00AM. Security Every aspect of dispensary operations will be carried out with security in mind. Compliance and security are of the utmost importance of Compassion Centers of America, LLC, and we will uphold the highest security measures to secure all parts of the dispensary and prevent any diversion of medical marijuana to any individual or organization that is not legally registered to purchase or in any way receive medical marijuana under DC law. It is the responsibility of all CCA directors, managers, and staff members to ensure that diversion of medical marijuana does not occur and that patients and caregivers understand each aspect of purchasing and properly transporting medical marijuana, as well as acting responsibly as they enter and exit the dispensary. We will install and maintain all electronic recording security, alarm, and monitoring systems as outlined in the laws and regulations, including a hard-wired, professionally monitored robbery and burglary alarm system. We have identified and engaged the services of Sexton Executive Security, a professional security firm (registered in the District of Columbia), which will provide our security guards, professionally monitor our security systems, and train our staff in conflict resolution and procedures for handling violent incidents and emergencies (including calling the Metropolitan Police Department). In case of an incident, in addition to immediately notifying the 5

Metropolitan Police Department, we will notify the Department of Health within 24 hours (via electronic means) and provide a written report describing in detail the circumstances of the incident, including an inventory of stolen items, if such a theft had occurred. Each door of the dispensary is of steel construction and is constantly monitored electronically. The door to each room is equipped with a keypad entry system, which is programmed with individual access codes that are unique to each staff member. In this way, we can track access to every section of the dispensary. All areas of the facility will also be equipped with electronic camera monitoring and recording equipment. All areas will be monitored by these systems and by our security staff seven days a week, 24hours per day. Recording tapes for each camera will be retained for 60 days, will be made available to the Metropolitan Police Department and any government inspectors, upon request. Tapes will not be taped over. In addition to our regular electronic security monitoring, we will place a monitor in the Patient Intake Area that will face onto the street and which passersby can view from outside the building. This monitor will show passersby that our security cameras are constantly monitoring activities outside the building. We have employed this practice at some of our other locations and find that it is a strong deterrent to individuals who may otherwise engage in aggressive and/or criminal activities.