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HomeMy WebLinkAboutC-20-76 Tradecraft Farms RedactedApplicant (Entity) Information Application Type Proposed Location Commercial Cannabis Business Permit Application C-20-76 Submitted On: Dec 04, 2020 Applicant Paula Brunelle paula@dubbros.com Applicant (Entity) Name: Tradecraft Farms Fresno - Fulton, LLC DBA: Tradecraft Farms Physical Address: 915 North Fulton Street City: Fresno State: CA Zip Code: 93728 Primary Contact Same as Above? No Primary Contact Name: Paula Brunelle Primary Contact Title: Authorized Representative / Chief Compliance Officer Primary Contact Address: 721 E. 5th Street Primary Contact City: Los Angeles Primary Contact State: CA Primary Contact Zip Code: 90013 Primary Contact Phone: Primary Contact Email: paula@dubbros.com HAS ANY INDIVIDUAL IN THIS APPLICATION APPLIED FOR ANY OTHER CANNABIS PERMIT IN THE CITY OF FRESNO?: Yes Select one or more of the following categories. For each category, indicate whether you are applying for Adult-Use (“A”) or/and Medicinal (“M”) or both Both Please make one selection for permit type. If making multiple applications, please submit a new application for each permit type and proposed location. Permit Type Retail (Storefront) Business Formation Documentation: Limited Liability Company Property Owner Name: Minh Duong & Hieu Duong Proposed Location Address: 915 N. Fulton Street City: Fresno State: CA Zip Code:Property Owner Phone: Supporting Information Application Certification 93728 Property Owner Email:Assessor's Parcel Number (APN): 452-114-17 Proposed Location Square Footage: 2831 List all fictitious business names the applicant is operating under including the address where each business is located: dba Tradecraft Farms; no other addresses where applicant-entity is currently operating. Has the Applicant or any of its owners been the subject of any administrative action, including but not limited to suspension, denial, or revocation of a cannabis business license at any time during the past three (3) years? No Is the Applicant or any of its owners currently involved in an application process in any other jurisdiction? Yes If so, please list and explain: Tradecraft Farms - Illinois, LLC; Applications Denied by State of IL; Plan to Correct application deficiencies and resubmit / Appeal once State advises on process. Tradecraft Farms - Missouri, LLC; Applications Denied by State of MO; Currently under Appeal. Owner Information I hereby certify, under penalty of perjury, on behalf of myself and all owners, managers and supervisors identified in this application that the statements and information furnished in this application and the attached exhibits present the data and information required for this initial evaluation to the best of my ability, and that the facts, statements, and information presented are true and correct to the best of my knowledge and belief. I understand that a misrepresentation of fact is cause for rejection of this application, denial of the permit, or revocation of a permit issued. In addition, I understand that the filing of this application grants the City of Fresno permission to reproduce submitted materials for distribution to staff, Commission, Board and City Council Members, and other Agencies to process the application. Nothing in this consent, however, shall entitle any person to make use of the intellectual property in plans, exhibits, and photographs for any purpose unrelated to the City's consideration of this application. Furthermore, by submitting this application, I understand and agree that any business resulting from an approval shall be maintained and operated in accordance with requirements of the City of Fresno Municipal Code and State law. Under penalty of perjury, I hereby declare that the information contained in within and submitted with the application is true, complete, and accurate. Iunderstand that a misrepresentation of the facts is cause for rejection of this application, denial of a permit or revocation of an issued permit. A denial or revocation on these grounds shall not be appealable (FMC 9-3319(d)). Name and Digital Signature true Title Authorized Representative, Chief Compliance Officer Please note: the issuance of a permit will be determined based on the application you submit and any major changes to your business or proposal (i.e. ownership, location, etc.) after your application is submitted may result in a denial. All applications submitted are considered public documents for Public Records Act request purposes. For details about the information required as part of the application process, see the Application Procedures & Guidelines, City of Fresno Municipal Code Article 33 and any additional requirements to complete the application process. All documents can be found online via this link. For questions please contact the City Manager’s Office at 559.621.5555. Owner Name: Barry Walker Owner Title: Chief Executive Officer Owner Address: 721 E. 5th Street Owner City: Los Angeles Owner State: CA Owner Zip: 90013 Has Owner Completed Background Check Application? Yes Ownership Percentage (%): 50 Owner Name: Thomas Gibb Owner Title: Chief Operating Officer Owner Address: 721 E. 5th Street Owner City: Los Angeles Owner State: CA Owner Zip: 90013 Business Name: Tradecraft Farms Application #: C-20-76 CANNABIS BUSINESS PERMIT APPLICATION REVIEW - RETAIL Points Possible All or None Exceptional Good Acceptable Applicant Score Evaluation Notes (Explain each time points are deducted) SECTION 1: BUSINESS PLAN 300 Points Possible for Section 1 Resume: Resumes Provided for All Owners: Score 5 5 5 Resumes Provided in 2-page Format: Score 2 2 2 Education: (select highest academic level among ownership team, cannabis specific education separately) Cannabis specific education/training (accredited)2 2 0 Not described High School Degree Reported: Score 4 4 - Bachelor's Degree Reported: Score 6 6 6 Master's Degree or Higher Reported: Score 8 8 - Experience: (among ownership team, select one at highest level) Regulated Cannabis Retail Ownership Experience CA 13 13 13 Regulated Cannabis Retail Experience CA (management level or below): Score 10 10 - Other Retail Business Experience Reported, More than 5 years: or 8 8 - Other Retail Business Experience Reported, Less than 5 Years: Score 5 5 - 1.1 Sub-Total:30 26 Construction Cost Estimate: Construction Cost Estimate Provided: Score 8 8 6 4 4 Very basic, just lists costs. Needs detail Construction Contingency Factor Included: Score 6 6 0 Not included All Labor, Trades, Materials, Supplies and Permits and other Cost Factors Identified: Score 6 6 4 2 2 Very basic, says that the lump sum includes permits, Reference Data Provided for Unit Cost Factors: Score 5 5 3 1 0 Not included Operation and Maintenance Cost Estimates: Operation and Maintenance Cost Estimate Provided: Score 8 8 6 4 6 Has some breakdown but needs more detailed cost All Labor, Trades, Materials, Supplies, Utilities, and other Cost Factors Identified: Score 6 6 4 2 4 Needs more detail Annual Cost Escalators for Operating Costs Provided: Score 6 6 4 2 0 Not included Reference Data Provided for Unit Cost Factors: Score 5 5 3 1 0 Not included 1.2 Sub-Total:50 16 Proof of Capitalization Specific to one or more Owners: Score 5 5 0 Not specific Proof of Capitalization Specific to Business Name/Address: Score 5 5 5 Proof of Capitalization Sufficient to Cover Proforma (3 months) and Construction Costs: Score 15 15 15 Certified Audited Financial Report Provided for one or more Owners: Score 5 5 0 Not included Score one of the following for a maximum 20 points: 1.1 Owner qualifications. Resumes are not to exceed two (2) pages per owner. (30 points possible) 1.2 A budget for construction, operation, and maintenance, compensation of employees, equipment costs, utility cost, and other operation costs.(50 points possible) 1.3 Proof of capitalization in the form of documentation of cash or other liquid assets on hand, Letters of Credit or other equivalent assets which can be verified by the City. (50 Points Possible) Criteria Narrative: Criteria Narrative: Capital source is 100% liquid (cash in owners bank, no debt obligation)20 20 - Capital souce is debt obligation (letter of credit/loan from individual or institution) 10 10 10 Capital consists of non-liquid assets (i.e. real property)8 8 - Capital consists of a mixture of liquid and non-liquid assets 15 15 - 1.3 Sub-Total:50 30 Three Years of Data Provided: Score 10 10 8 6 8 Needs more detail Total Gross Revenue Estimates Provided:3 3 3 Total Gross Revenue by Product Type (flower and manufactured) Identified:3 3 0 Not included Total Personnel Costs Provided:5 5 4 3 4 Has breakdown in salaries/jobs in previous section, Total Property Rental or Purchase Costs Provided:2 2 2 Total Utilities Costs Provided:2 2 2 Total Cannabis Product Purchase Expense Provided 2 2 2 All Contract Services Identified:2 2 2 Annual Net Revenue Identified:3 3 3 Annual Cost Escalators Identified:4 4 3 2 2 Very few costs shown as escalating, no explanations Annual Estimated Sales Tax Payments to State Provided:2 2 2 Annual Estimated Sale Tax Payments to City of Fresno Provided:5 5 0 Not included Annual Business Tax License and Cannabis Permit Fee Provided:2 2 2 Annual Net Income Provided:5 5 5 Scoring Guidance: full points for realistic figures for all three years. Dock points for severe miscalculations, unrealistic estimates, or providing less than the request three years. 1.4 Sub-Total:50 37 Hours of Operation Provided: Score 5 5 5 Hours of Operation Provided for all 7 days of the week: Score 3 3 3 Hours of Operation Provided for Holidays: Score 2 2 0 unspecified Opening and Closing Procedures Provided: Score 10 10 8 6 10 Scoring Guidance: full points for describing information in detail. Dock points for leaving information out or not providing enough detail. 1.5 Sub-Total:20 18 1.6.1 Fully describe the day-to-day operations if your applying for a retail permit: i. Describe customer check-in procedures.20 20 15 10 20 II. Identify location and procedures for receiving deliveries during business hours.10 10 8 6 10 iii. Identify the name of the Point-of-sale system to be used and the number of Point-of-Sale locations.10 10 10 Flowhub, 3 POS locations iv. The estimated number of customers to be served per hour/day.20 20 15 10 15 Did not describe source of estimation v. Describe the proposed product line to be sold and estimate the percentage of sales of flower and manufactured products.20 20 15 10 20 1.6 Daily operations. With as much detail as possible, the Business Plan should describe the day-to-day operations which meet industry best practices. This should include at a minimum the following criteria for each permit type in which you are applying for a permit. (100 points possible) 1.4 Pro forma for at least three years of operation. 1.5 Fully describe hours of operation and opening and closing procedures. (20 points possible) Criteria Narrative: Criteria Narrative: Criteria Narrative: vi. If proposed, describe delivery service procedures, number of vehicles and product security during transportation. (if no delivery service application must state this clearly for full points)20 20 15 10 15 Did not describe quantity of product authorized to be carried in vehicles. 1.6 Sub-Total:100 90 Section 1 Total:300 217 SECTION 2: SOCIAL POLICY AND LOCAL ENTERPRISE 400 Points Possible for Section 2 Description of Commitment to pay a Living Wage provided: Score 10 10 8 6 10 Definition of Living Wage Provided: Score 5 5 4 3 5 Living Wage Defined as Greater than Minimum Wage: Score 5 5 5 2.1 Sub-Total:20 20 Wages and Salary CCB Entry-Level Hourly Wage Greater than Minimum Wage 5 5 5 minimum CCB Entry-Level Annual Salary Greater than Median Household Income ($50,432)5 5 0 Health Care Benefits CCB Offers Medical Coverage to All Employees: Score 5 5 5 CCB Offers Dental Coverage to All Employees: Score 3 3 0 CCB Offers Vision Coverage to All Employees: Score 3 3 0 CCB Offers Health Reimbursement Account for Qualified Medical Expenses: Score 1 1 0 Employee Pays $0 for Employee Medical Premium: Score 3 3 0 Employee Pays $0 for Employee Dental Premium: Score 2 2 0 Employee Pays $0 for Employee Vision Premium: Score 2 2 0 Employee Pays less than $500 per month for Family Health Care Coverage (Medical, Dental, Vision): Score 2 2 0 Leave Benefits Number of Paid Vacation/PTO Days Per Year: (10+ days = excep; 6-9 days = Good; 3-5 days Acceptable)5 5 4 3 5 Number of Paid Holidays Per Year: (10 or more paid holidays = excep; 4-10 = Good; 1-3 Acceptable)5 5 4 3 0 unspecified Number of days paid time off for Sick/Medical time: (7+ days= Exceptional, 4-6 days = Good, 3 days = acceptable (8 hour day))5 5 4 3 4 Retirement Offers employee retirement plan 2 2 2 Offers company match for employee retirement plan 2 2 2 2.2 Sub-Total:50 23 CCB Provides Tuition Reimbursement for Certificates: Score 3 3 3 commits to reasonable accomdation and assistance but not specific Criteria Narrative: Criteria Narrative: Criteria Narrative: 2.1 Describe whether the Commercial Cannabis Business is committed to offering employees a Living Wage. (20 points possible) Scoring Guidance: https://livingwage.mit.edu/counties/06019 2.2 Briefly describe benefits provided to employees such as health care, vacation, and medical leave, to the degree they are offered as part of employment. (50 points possible) 2.3 Describe compensation to and opportunities for continuing education and employee training.(20 points possible) CCB Provides Tuition Reimbursement for associate degrees: Score 3 3 3 " CCB Provides Tuition Reimbursement for bachelor's degrees: Score 3 3 3 " CCB Provides Tuition Reimbursement for master's degrees: Score 3 3 3 " CCB Provides Tuition Reimbursement for Specialized Commercial Cannabis Business Operations Training: Score 3 3 3 " CCB Offers General Training for Health and Safety, Workplace Environment, Customer Service, etc. 5 5 4 3 5 5 2.3 Sub-Total:20 20 General Recruitment Plan Provided: Score 10 10 8 6 10 Social Policy Recruitment Plan Provided: Score 10 10 8 6 10 Recruitment Plan Includes Demographic Data for District, City or County: Score 10 10 8 6 0 Recruitment Plan Includes List of CBOs, Non-Profits and Public-Agency Hiring Partners: Score 10 10 8 6 10 Recruitment Plan Includes Hiring Targets (percentages) by Demographic Groups: Score 10 10 8 6 6 Includes FMC targets but does not set additional 2.4 Sub-Total:50 36 Owners Number of Owners:5 Number of Owners that live within the City of Fresno:1 Number of Owners that live in the County of Fresno:0 Number of Owners that Own a Business in the City of Fresno:0 51%+ ownership interest percent of the Owners live or own a business in the City: Score 80 80 - 51%+ ownership interest percent of the Owners live or own a business in the County: Score 40 40 - Less than 50 percent equity of the Owners live or own a business in the City (If no owners are local, score zero)20 20 20 Managers Number of Managers (salaried, non-owners) Number of Managers that live in the City of Fresno: Number of Managers that Own a Business in the City of Fresno: 100 percent of the Managers live or own a business in the City: Score 20 20 0 unspecified 75 to 99 percent of the Managers live or own a business in the City: Score 15 15 0 50 to 74 percent of the Managers live or own a business in the City: Score 10 10 0 Less than 50 percent of the Managers live or own a business in the City: Score 5 5 0 2.5 Sub-Total:80 20 Criteria Narrative: Criteria Narrative: Data, non-scored. Write response in Evaluation Notes column. Data, non-scored. Write response in Evaluation Notes column. IF full points achieved for Ownership category, don't score managers. Section is total of 80 points possible. 2.4 Describe the Commercial Cannabis Business plan to recruit individuals who meet the criteria listed in the Social Policy Section 9-3316 (b) (1) of the Fresno Municipal Code (FMC) and the percentage of local employees it hires. (50 points possible) 2.5 Describe the extent to which the Commercial Cannabis Business will be a locally managed enterprise whose owners and /or managers reside within or own a commercial business within the City of Fresno, for at least one year prior to March 2, 2020.(80 points possible) 2.6 Describe the number of employees, title/position and their respected responsibilities.(20 points possible) Criteria Narrative: Responsibilities Described for All Titles/Positions: Score 20 20 15 10 20 2.6 Sub-Total:20 20 Does CCB have more than five employees: 5 5 5 CCB has signed a peace agreement: Score 5 5 5 2.7 Sub-Total:10 10 Work Force Plan Provided: Score 10 10 8 6 10 Commitment to Local Hire Provided:10 10 8 6 10 50% committment Commitment to Offer Apprenticeships Provided:10 10 8 6 0 not mentioned Commitment paying for continuing education provided 10 10 8 6 10 Description of commitment to paying a living wage provide. (Score same as sec. 2.1)10 10 8 6 10 2.8 Sub-Total:50 40 CCB is willing to serve as Social Equity Business Incubator: Score 100 100 80 60 100 Mentorship and Training: Score yes Equipment Donation: Score Shelf Space: Score yes Legal Assistance: Score Finance Services Assistance: Score yes Other Technical Assistance: Score yes - financial resources Scoring Guidance: full points for willingness to serve with detailed plan offering at least three aspects mentioned above or of similar benefit. Less points for willingness to serve but vague or unclear commitment. Zero points if there is no clear commitment to serve as Incubator. 2.9 Sub-Total:100 100 Section 2 Total:400 289 SECTION 3: NEIGHBORHOOD COMPATIBILITY PLAN 300 Points Possible for Section 3 CCB will document complaints (time of complaint, nature of complaint, resolution of complaint): Score 10 10 8 6 10 Criteria Narrative: Criteria Narrative: 2.9 Describe whether the business is willing to serve as a Social Equity Business Incubator by offering support to local cannabis social equity businesses in the form of mentorship, training, equipment donation, a percentage of shelf space dedicated to Fresno equity business products, legal assistance, financial services assistance, or other technical assistance support.(100 points possible) 3.1 Describe how the CCB will proactively address and respond to complaints related to noise, light, odor, litter, vehicles, and pedestrian traffic.(50 points possible) Criteria Narrative: Data to inform score on first line of this section. Write response in Evaluation Notes column. 2.8.3. Commitment to pay a living wage to its employees 2.7 Describe whether the CCB has five (5) or more employees and whether it has signed a labor peace agreement allowing employees to unionize without interference. (10 points possible) 2.8 Provide a workforce plan that includes at a minimum the following provisions: (50 points possible) 2.8.1. Commitment for 30% of employees to be local hires; the business must show that it has either hired or made a good faith effort to hire bona fide residents of Fresno who have not established residency after the submission of an application for employment with the applicant/permittee. 2.8.2. Commitment to offer apprenticeships and/or compensation for continuing education in the field; and Criteria Narrative: CCB will established a dedicated contact person to receive complaints: Score 10 10 10 CCB will establish a dedicated phone number to receive complaints: Score 5 5 5 CCB will establish a dedicated email address to receive complaints: Score 5 5 5 CCB will establish a response time standard for returning complaint calls and emails: Score 5 5 5 CCB will schedule or participate in periodic community meetings to engage with residents about the CCB operation: Score 10 10 0 Info not provided Other measure unique to business (i.e. website complaint form)5 5 0 Info not provided Scoring Guidance: full points for detailed proactive plan addressing all aspects mentioned. Dock points for leaving out aspect, vagueness, or reactive plans. 3.1 Sub-Total:50 35 CCB will maintain a listserv of community residents to update and information residents of business operations. 10 10 0 Info not provided CCB will schedule or attend periodic community meetings (at least annually) to engage with residents about the CCB operation: Score 10 10 0 Info not provided CCB will prepare a community outreach and engagement plan: Score 50 50 40 30 0 Info not provided CCB will issue periodic Newsletters to community providing information about CCB operations 10 10 0 Info not provided CCB will hire residents from the community work at the CCB: Score 20 20 0 Info not provided Scoring Guidance: full points for detailed proactive plan. Dock points for leaving out aspect, vagueness, or reactive plans. 3.2 Sub-Total:100 0 CCB has identified sensitive receptors to nuisance odors in vicinity of business operations: Score 5 5 5 CCB has prepared a nuisance odor control plan: Score 10 10 8 6 10 Nuisance odor control plan identifies locations where fugitive emissions may exit the premise boundary: Score 5 5 0 Info not provided Nuisance odor control plan describes specific odor control measures to reduce fugitive emissions exiting the premise boundary: Score 5 5 5 CCB has established an odor reporting system: Score 5 5 5 CCB will install a nuisance odor monitoring system: Score 10 10 0 Info not provided 3.3 Sub-Total:40 25 CCB has identified the potential sources of nuisance odors for the business operation: Score 10 10 8 6 6 Needs more detail Scoring Guidance: full points for detailed proactive plan. Dock points for vagueness or reactive plans. 3.4 Sub-Total:10 6 Criteria Narrative: Criteria Narrative: Criteria Narrative: Criteria Narrative: 3.2 Describe how the CCB will be managed to avoid becoming a nuisance or having impacts on its neighbors and the surrounding community.(100 points possible) 3.3 Describe odor mitigation practices.(40 points possible) 3.4 Identify potential sources of odor. (10 points possible) Nuisance odor control plan describes specific odor control equipment: Score 10 10 8 6 8 Needs more detail Nuisance odor control plan describes specific odor control measures/techniques: Score 10 10 8 6 10 Odor control measures are identified for different nuisance odor sources: Score 10 10 10 3.5 Sub-Total:30 28 Nuisance odor control plan describes the operation, monitoring, and maintenance requirements for odor control measures: Score 10 10 10 Nuisance odor control plan describes the staff training required for system operations, maintenance, repair, and troubleshooting.10 10 10 3.6 Sub-Total:20 20 CCB has identified the sources of waste generated by the business operation: Score 10 10 0 Info not provided CCB has prepared a source-separation plan to segregate different sources of waste generated by business operations: Score 10 10 10 The source-separation plan identifies policy, procedures, and locations where different sources of waste are to be collected for disposal: Score 10 10 8 6 8 Needs more detail The source-separation plan describes specific measures to control the collection and disposal cannabis waste: Score 10 10 10 The name of licensed cannabis disposal company provided: Score 10 10 0 Info not provided 3.7 Sub-Total:50 28 Section 3 Total:300 142 SECTION 4: SAFETY PLAN 300 Points Possible for Section 4 Safety Plan Prepared by Consultant: Score 10 10 10 Safey Plan Assessed by Consultant: Score (if prepared by, also give points for assessed by)10 10 10 Safety Plan Prepared for CCB Address (specific proposed location): Score 10 10 10 Safety Plan includes Site Plan of Premise: Score 10 10 10 Safety Plan includes Building Layout Plan: Score 10 10 10 4.1 Sub-Total:50 50 Written Accident/Incident Procedure Provided: Score 20 20 15 10 10 listed who to call only Procedures Address Multiple Accident/Incident Scenarios: Score 10 10 8 6 10 Total Number of Scenarios Described: Score 8 Active Shooter Incident Described: Score 10 10 0 not mentioned 4.2 Describe accident and incident reporting procedures. (50 points possible) 3.7 Describe the waste management plan. (50 points possible) 4.1 The Safety Plan shall be prepared and/or assessed by a professional fire prevention and suppression consultant. (50 points possible) 3.5 Describe odor control devices and techniques employed to ensure that odors from cannabis are not detectable beyond the permitted premises. (30 points possible) 3.6 Describe all proposed staff odor training and system maintenance.(20 points possible) Criteria Narrative: Criteria Narrative: Criteria Narrative: Criteria Narrative: Data-write response in Evaluation Notes Column Robbery Incident Described: Score 10 10 0 not mentioned 4.2 Sub-Total:50 20 Evacuation Plan Provided: Score 20 20 15 10 20 Adequate Number of Evacuation Routes Identified: Score 20 20 15 10 20 Evacuation Route Distance to Public Right of Way: Score 10 10 8 6 10 4.3 Sub-Total:50 50 Location of Fire Suppression System Elements Identified: Score 10 10 0 Type of Fire Suppression System Elements Identified: Score 20 20 15 10 10 just mentioned fire alarm, no specifics Location of Fire Extinguishers Identified: Score 10 10 10 Adequate Number of Fire Extinguisher Locations Identified: Score 10 10 8 6 10 4.4 Sub-Total:50 30 Written Procedure for Fire Emergencies Provided: Score 20 20 15 10 0 no written proceedured Written Procedure for Medical Emergencies Provided: Score 20 20 15 10 0 none Cardiac Arrest Medical Emergency Described: Score 20 20 15 10 0 not mentioned Gunshot Wound Medical Emergency Described: Score 20 20 15 10 0 not mentioned Other Medical Emergency Conditions Described: Score 20 20 15 10 0 not mentioned 4.5 Sub-Total:100 0 Section 4 Total:300 150 SECTION 5: SECURITY PLAN 300 Points Possible for Section 5 Security Plan Prepared by Consultant: Score 10 10 10 Security Plan Assessed by Consultant(if prepared by, also give points for assessed by): Score 10 10 10 Security Plan Prepared for CCB Address (specific proposed location): Score 10 10 10 Security Plan includes Site Plan of Premise: Score 10 10 10 Security Plan includes Building Layout Plan: Score 10 10 10 5.1 Sub-Total:50 50 4.3 Describe evacuation routes. (50 points possible) Criteria Narrative: 4.5 Describe procedures and training for all fire and medical emergencies.(100 points possible) 5.1 The Security Plan shall be prepared and/or assessed by a professional security consultant.(50 points possible) 5.2 Premises (Security) Diagram. In addition to diagrams submitted for other sections of the application, applicants are expected to submit a premises diagram (or site plan) which, focuses on the proposed security measures and how they relate to the overall business. (Pursuant to CCR Title 16, Division 42, §5006. Premises Diagram). 5.2.1 The diagram shall be accurate, dimensioned and to scale (minimum scale ¼"). The scale may be smaller if the proposed location exceeds more than a 1/2-acre parcel but must not be printed on larger than an 11" x 17" sheet of paper. (Blueprints and engineering site plans are not required at this point of the application process) Criteria Narrative: Criteria Narrative: Criteria Narrative: Criteria Narrative: 4.4 Location of fire extinguishers and other fire suppression equipment. (50 points possible) Premises (Security) Diagram Provided: Score 20 20 15 10 15 Diagram is drawn to correct scale: Score 5 5 5 Diagram provides required details for premise: Score 5 5 0 Missing details Diagram shows the location of all security cameras: Score 5 5 5 Descriptions of activities to be conducted in each area of the premise 5 5 5 Limited-Access Areas Clearly Marked: Score 5 5 0 No mention Number and Location of All Security Cameras Identified: Score 5 5 5 5.2 Sub-Total:50 35 Intrusion Alarm and Monitoring System Identified: Score 15 15 15 Name and Contact Information for Monitoring Company Provided: Score 5 5 5 Total Points of Entry into Premise Identified: Score 5 5 5 All Points of Entry to be Alarmed Identified:5 5 5 Type of Alarm Identified (motion, infrared, glass break, etc.): Score 10 10 10 Backup Power Supply Identified: Score 10 10 10 5.3 Sub-Total:50 50 Written Cash-Handling Procedure Provided: Score 30 30 20 15 20 Dual-Custody is Practiced for all cash handling: Score 10 10 0 No mention of dual custody Video Surveillance Used to Monitor All Cash Handling: Score 20 20 0 No mention Armored Car Service Used for Bank Deposits: Score 10 10 10 All Cash Deposited weekly with Bank: Score 10 10 10 Onsite Vault Provided to Secure Cash Prior to Bank Deposit: Score 20 20 20 5.4 Sub-Total:100 60 CCB will use onsite security guards: Score 10 10 10 All onsite guards will be licensed and bonded: Score 10 10 0 No mention of being bonded All onsite security guards will be licensed to carry firearms: Score 10 10 10 Onsite security guards will be on duty before CCB opens for business: Score 10 10 10 Onsite security guards will be on duty after CCB closes for business: Score 10 10 10 5.2.3 Description of cannabis activity that will be conducted in each area of the premise. Commercial cannabis activities that must be identified on the diagram/site plan may include but are not limited to the following if applicable to the business operations; storage areas, batch sampling areas, loading/unloading of shipment areas, packaging and labeling, customer sales areas, training areas, employee break room areas, extractions, infusions, processing, and testing areas. 5.2.4 Limited-access areas, defined as areas in which cannabis goods are stored or held and only accessible to permittees, or its employees or contractors and areas used for video surveillance monitoring and storage devices (Pursuant to CCR Title 16, Division 42, §5000 (m) Limited-Access Area and §5042 Limited-Access Area. 5.2.5 Number and location of all video surveillance cameras. (50 points possible) 5.4 Briefly describe cash handling procedures which covers day to day transactions with customers, vendors armor carrier vehicles and transporting it to the bank.(100 points possible) 5.5 Discuss whether the CCB will utilize the services of on-site security guards. Include in the discussion: (50 points possible) 5.5.1 Number of guards. 5.5.2 Hours guards will be on-site. 5.3 Identify intrusion alarm and monitoring system including the name and contact information for the monitoring company (if the company has been selected).(50 points possible) Criteria Narrative: Criteria Narrative: Criteria Narrative: 5.5.3 Locations at which they will be positioned. 5.5.4 Guards' roles and responsibilities. 5.2.2 The diagram must be drawn to scale and clearly identify property boundaries, entrances, exits, interior partitions, walls, rooms, windows, and doorways. The activity in each room and the location of all cameras must be identified in the diagram. 5.5 Sub-Total:50 40 Section 5 Total:300 235 Section 1: Business Plan Total Points:300 217 Section 2: Social Policy & Local Enterprise Total Points:400 289 Section 3: Neighborhood Compatibility Total Points:300 142 Section 4: Safety Plan Total Points:300 150 Section 5: Security Plan Total Points:300 235 Total Points Achieved:1600 1033 64.56% TOTAL SCORE Criteria Narrative:            2    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  TABLE OF CONTENTS INTRODUCTION .......................................................................................................................... 3 1.1. Owner Qualifications and Resumes ..................................................................................... 5 1.2. Budgets .............................................................................................................................. 19 i. Construction Budget ...................................................................................................... 19 ii. Operations Budget ......................................................................................................... 19 iii. Maintenance Budget ...................................................................................................... 19 iv. Compensation of Employees ......................................................................................... 19 v. Equipment Costs ............................................................................................................ 20 vi. Utility Costs ................................................................................................................... 20 vii. Other Operating Costs.................................................................................................... 21 1.3. Proof of Capitalization ....................................................................................................... 21 1.4. Pro Forma Financial Statements ........................................................................................ 21 1.5. Hours of Operation and Opening and Closing Procedures ................................................ 28 i. Hours of Operation ........................................................................................................ 28 ii. Opening Procedures ....................................................................................................... 28 iii. Closing Procedures ........................................................................................................ 29 1.6. Daily Operations ................................................................................................................ 30 i. Emergency Contact ........................................................................................................ 30 ii. Signage and Notices ....................................................................................................... 30 iii. Maintenance of Premises ............................................................................................... 31 iv. Records and Recordkeeping .......................................................................................... 31 1.6.1. Daily Operations for Retail Permit ................................................................................. 32 i. Customer Check-In Procedures ..................................................................................... 32 ii. Location and Procedures for Receiving Shipments During Business Hours ................. 34 iii. Point of Sale System ...................................................................................................... 36 iv. Estimated Number of Customers to Be Served Per Hour and Day ............................... 37 v. Proposed Product Line ................................................................................................... 37 vi. Delivery Service Procedures .......................................................................................... 38 CONFIDENTIAL AND PROPRIETARY            3    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  INTRODUCTION Tradecraft Farms Fresno – Fulton, LLC dba Tradecraft Farms (the “Company”), is a partnership between seasoned cannabis industry professionals with a wealth of collective experience operating licensed cannabis operations across the supply chain. It is the Company’s mission—upon being awarded a commercial cannabis business license by the City of Fresno—to distinguish itself as a purveyor of premium cannabis products and to become known for providing an unparalleled customer experience. At a high level, the Company will operate a storefront cannabis retail business at 915 North Fulton Street in Fresno, California, in compliance with the City of Fresno’s1 requirements and California state laws and regulations.2 We will sell cannabis products sourced from distributors licensed by the California Bureau of Cannabis Control (“BCC”) that have passed regulatory compliance testing and quality-assurance inspection pursuant to Section 26110 of the California Business and Professions Code (“BPC”), and operate the business in full compliance with all State and local laws.3 The Company will serve adult-use customers over the age of 21 and qualified patients and primary caregivers over the age of 18 (with valid physician’s recommendations for medical cannabis) in-store and via delivery of customer orders prepared and dispatched from our licensed premises.4 The Company has built a management team composed of seasoned cannabis industry veterans who are extremely knowledgeable about cannabis retail business operations and are committed to bringing a successful and compliant retail cannabis business to the City of Fresno. Through their experience building and operating licensed cannabis businesses in multiple cities and states, the Tradecraft Farms team has learned that compliance lays at the crux of commercial success; one goal cannot be achieved without achieving the other. As such, the Company has developed this Business Plan to ensure consistent compliance with applicable state and local regulations outlined in the BPC and the Fresno Municipal Code. This Business Plan serves as a guidebook to the Company’s intended internal processes and will inform Company best practices.     1 Fresno Municipal Code (“FMC”). 2 References herein to California Code of Regulations, Title 16, Division 42 “Bureau of Cannabis Control” (“BCC”) § 5000, et seq. 3 FMC § 9-3309(f). 4 FMC § 9-3309(i).   CONFIDENTIAL AND PROPRIETARY 4  Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  CONFIDENTIAL AND PROPRIETARY Tradecraft Farms Fresno - Fulton, LLC Organizational Chart            5    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  1.1. Owner Qualifications and Resumes The below resumes and documentation, replete with numerous special business and professional qualifications and extensive cannabis business experience, unequivocally demonstrate that the Company is highly qualified to operate an all-inclusive, compliant, and elevated cannabis retail business in the City of Fresno. The owners and operators of Tradecraft Farms also own and operate over twenty affiliated cannabis licenses. The Executive Team participates in some capacity in the affiliated licenses that create a vertically integrated system. A complete list of licenses owned and operated by Tradecraft Farms owners and operators is included as Exhibit A for reference.   CONFIDENTIAL AND PROPRIETARY            6    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan    CONFIDENTIAL AND PROPRIETARY            9    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan    CONFIDENTIAL AND PROPRIETARY            11    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan    CONFIDENTIAL AND PROPRIETARY            14    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan    CONFIDENTIAL AND PROPRIETARY            17    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  CONFIDENTIAL AND PROPRIETARY            19    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  1.2. Budgets i. Construction Budget The Company anticipates capital expenses of approximately for construction costs, which will encompass building architectural plans and permits, and tenant improvements to ensure the space is built out for compliant commercial cannabis retail sales. ii. Operations Budget The initial Operation Budget includes start-up professional and licensing fees5, as well as rent and inventory, as follows: These estimates include application and permit fees paid to the City of Fresno’s Planning and Development Department in order to obtain all required land use approvals and/or entitlements, a Cannabis Business License Tax certificate,6 as well as the permit fee established by the City Council to cover the costs of administering the commercial cannabis business permit program.7 iii. Maintenance Budget Since Tradecraft Farms anticipates making significant up-front capital expenditures on improvements to its proposed building, the Company anticipates the maintenance costs to be minimal in the first year of operation. We anticipate approximately in repairs and maintenance in the first year, and each in years two through four. iv. Compensation of Employees The Company has set forth labor and employment practices that we are confident will meet and at times exceed the requirements set forth by the City of Fresno. We consider our team to be our most valuable resource. As such, the Company will offer employee training and continuing   5 FMC § 9-3316(e). 6 FMC §§ 9-3317(d), 9-3328. 7 FMC § 9-3317(h).   CONFIDENTIAL AND PROPRIETARY            22    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  Our Pro Forma is not based on estimates or a “model”, but rather is built from the actual financial data of an existing cannabis retail operation. More specifically, given similar operational and market conditions, the Company has taken the existing financial performance of our highly successful cannabis retailer located at 732 E. Vista Way in Vista, CA (C10-0000570-LIC) and extrapolated the below data based on the following assumptions: ● After having submitted a commercial cannabis business license application in December 2020, the City of Fresno will approve the Company’s commercial cannabis business application in the second quarter of 2021. ● The Company has spent approximately in professional fees to prepare its commercial cannabis business license application and will owe the City application fees upon submission, and license fees upon approval of the Company’s application. ● The Company had a construction budget and schedule prepared by our cannabis construction contractor, Everlasting Construction (“Everlasting”). The estimated construction budget for the Company’s proposed cannabis retail business is for construction and furniture, fixtures, and equipment. ● In the extensive experience of our Owners successfully developing cannabis retail operations in Southern California, upon approval of the Company’s commercial cannabis business license application, the development of the Company’s cannabis retail business will follow the timeline below. This timeline is based on the City’s anticipated decision to award licenses on about April 30, 2021. o May 2021: In the Company’s experience, it takes 45 to 60 days to prepare a building permit application and 30 to 60 days for local approval of said building permit application. The Company will submit its applications for building permits, Fire Department approvals, Health Department approvals, and any other required zoning and land use permits or approvals as soon as logistically and legally possible.8 o July 2021: Upon the approval of building permits, the Company will immediately commence construction according to the 13-week schedule from Everlasting below: Week 1: Demolition and setup Week 2: Underground plumbing Week 3: Framing/rough in for mechanical, electrical and plumbing (“MEP”) Week 4: Framing/MEP installation and low voltage rough in Week 5: Framing/MEP installation and low voltage rough in and roof work Week 6: MEP inspections, insulation and drywall Week 7: Finish all rooftop work and drywall Week 8: Painting and start MEP top out and trim Week 9: Install flooring Week 10: Install case, base, trim, cabinets, doors, and wall finishes   8 FMC § 9-3327. CONFIDENTIAL AND PROPRIETARY 23  Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  Week 11: Install MEP, low v trim out, cabinets, and wall finishes; touch up Week 12: Inspections for ADA, fire code, and parking lot compliance Week 13: Certificate of Occupancy approval and move in o September 2021: The Company will begin hiring and training employees in the month prior to opening. ●The Company’s cannabis retail business will commence operations in the fourth quarter of 2021 and will owe approximately in licensing fees to the State prior to legally commencing operations. As the City has yet to determine licensing fees, we will wait to calculate fees as appropriate. ●The Company agrees to contribute 1% of gross revenue to the Fresno Community Reinvestment Fund, established to support local social equity cannabis businesses. ●Additionally, the Company has committed to offer further community benefits in the form of partnerships with local non-profit organizations and has pledged contributions upwards of annually. ●The Company considers the first year of mortgage and the first three months of estimated operating expenses and inventory on hand as startup costs for a cannabis retail business. ●The Company’s Owners will serve as officers of the Company and perform vital executive roles for our cannabis retail business without the guarantee of salary compensation, but will pay all other employees a Living Wage plus benefits. As demonstrated in the below Pro Forma, in order to capitalize the above and develop the Company’s proposed cannabis retail business located at 915 North Fulton Street and have adequate funding for the first three months’ estimated operating expenses, inventory expenses, and other assorted startup costs for a cannabis retail business, Owners and Managers Barry Walker, Geoffrey Yeterian, and Thomas Gibb have direct access to at least in liquid assets held in the bank account of Dub Brothers Management, LLC, a licensed California cannabis company of which Mr. Walker is an Owner and Managing Member (Mr. Yeterian and Mr. Gibb are Officers of Dub Brothers Management, LLC). The Company has executed a Promissory Note with Dub Brothers Management, LLC, whereby the latter has committed to capitalizing the Company as needed for startup costs and initial operating expenses. Please see the attached Pro Forma Profit & Loss Statements for the years 2021, 2022, 2023, and 20249 on the following pages 24 through 27. 9 Because our Company’s projected opening date is August 2021, we have included a 2024 Pro Forma, which extends through the first three full years of operations.   CONFIDENTIAL AND PROPRIETARY            28    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  1.5. Hours of Operation and Opening and Closing Procedures i. Hours of Operation The Company will be open to retail customers between 10:00 a.m. and 10:00 p.m., Monday through Sunday (seven days per week)10, pursuant to the following daily schedule: ● Morning-shift personnel open the cannabis retail business for preparatory (non-public) operations at 8:00 a.m. ● Morning-shift personnel open the cannabis retail business for public operations at 10:00 a.m. ● From 10:00 a.m. to 10:00 p.m., the cannabis retail business is open to the public and customers may engage in the retail purchase of finished cannabis and cannabis products. ● During hours of operation, all restroom facilities will remain locked and under the control of managers on site.11 Customers will be granted access to restrooms and escorted by a member of management. ● Evening-shift personnel close the cannabis retail business for public operations at 10:00 p.m. All customers must be off the licensed premises by 10:00 p.m. ii. Opening Procedures ● The manager scheduled for the opening (morning) shift and security personnel disarm the alarm system and open the cannabis retail business for preparatory operations at 8:00 a.m. ● From 8:00 a.m. to 10:00 a.m., morning-shift personnel stage finished cannabis and cannabis products for display and ultimate retail sale to customers. The quantity of cannabis and cannabis products held on the sales floor will never exceed the amount sufficient to satisfy daily demand for a single day.12 ● Employees working the morning shift turn all computers and Point-of-Sale (“POS”) terminals and verify POS system functionality. ● The manager onsite for the morning shift verifies that the amount of cash on-site reconciles with closing cash balance from the previous business day. ● Staff ensure that all areas of the premises are clean and ready to accept customers, including the Lobby, Sales Floor, and Restroom. This includes sanitizing all surfaces and stocking the restroom with adequate soap and paper goods. ● Opening Staff check the store’s dedicated email inbox, voicemail, and website to ensure that all pending customer orders from the previous day were fulfilled. Any outstanding   10 FMC § 9-3310(a)(1); BCC § 5403. 11 FMC § 9-3310(a)(6). 12 FMC § 9-3310(a)(5).   CONFIDENTIAL AND PROPRIETARY            29    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  orders left unfulfilled from the previous day due to time constraints or receipt outside of ordinary business hours will be prepared and processed in accordance with company protocols. Staff will contact customers to notify them that their orders are available for pickup once the store opens for business (after 10:00 a.m.). ● Morning-shift employees open the cannabis retail business for public operations at 10:00 a.m. iii. Closing Procedures Employees working the evening shift are responsible for the following closing procedures: ● Close the cannabis retail business for public operations at 10:00 p.m. All customers must be off the premises prior to 10:00 p.m. ● Return unsold cannabis and cannabis products from the sales floor back to the secure cannabis storage area for overnight storage. ● Clean the lobby and restroom, empty all trash receptacles, and sanitize all surfaces. Closing staff must update the cleaning log according to denote completion of daily cleaning procedures. ● Empty all cash drawers and secure all available cash in the secure safe(s) onsite. ● The manager onsite at closing is responsible for closing out the POS system and reconciling all sales and inventory figures in the company’s POS system with the data represented in METRC to ensure the reported data within both systems aligns. ● Power down all computers and POS terminals. ● Check cameras before locking and leaving the store to ensure no suspicious persons or vehicles are loitering in the parking lot or surrounding areas. ● Once all systems and cash-on-hand has been reconciled, and all cash and inventory have been secured in their dedicated secure storage vaults for overnight storage, any remaining employees and security personnel onsite activate on the alarm, and exit the premises together. Only the authorized security patrol guard working the overnight shift will remain onsite after the completion of daily closing procedures.13 Any time the cannabis retail business is not open for operations the Company will ensure the following: ● The cannabis retail business will be securely locked with commercial-grade, non- residential door locks.14   13 FMC § 9-3310(b)(1)(xii). 14 FMC § 9-3310(b)(1)(xiv); BCC § 5403.1. CONFIDENTIAL AND PROPRIETARY 30  Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  ●The cannabis retail business’s alarm system will be active, and an overnight security monitoring service and on-site security patrol guard will monitor the premises to ensure no one attempts to get close to or enter the cannabis retail business.15 ●All cannabis products will be stored in a locked safe or vault.16 ●Only authorized employees and contractors of the Company will be allowed to access the cannabis retail business for valid business reasons outside of ordinary business hours upon receipt of approval from management.17 1.6. Daily Operations The Company will manage its daily operations in full compliance with Fresno and the State of California’s Operating Requirements.18 Cannabis will not be consumed by any person on the business premises.19 The sale, dispensing, or consumption of alcoholic beverages or tobacco products will not be allowed by any person on the premises.20 The Company will sell adult-use cannabis and cannabis products to individuals over the age of 21 and medicinal cannabis and cannabis products to individuals over the age of 18 with a valid physician’s recommendation. No physician will be on the premises at any time for the purpose of evaluating patients for the issuance of a medical cannabis recommendation.21 i.Emergency Contact The Company will provide the City Manager with the name and contact information of an on-site employee or owner to whom emergency notice can be provided at any hour of the day.22 ii.Signage and Notices All business identification signage will conform to the requirements of the FMC including application for a City sign permit.23 Exterior signage will be limited to that needed for identification only and will not contain any logos or information that identify the services or products offered at the business, nor will it be directly illuminated. Signs on the proposed building will not obstruct any entrance or exit to the building or any windows. Each entrance to the building will bear a clear and legible notice indicating that smoking, ingesting, or otherwise consuming cannabis or cannabis products on the premises or adjacent areas 15 FMC § 9-3310(b)(1)(iii); BCC § 5403.1. 16 FMC § 9-3310(b)(1)(vii). 17 FMC § 9-3310(b)(1)(xii). 18 FMC § 9-3310. 19 FMC § 9-3309(a). 20 FMC § 9-3309(b-c). 21 FMC § 9-3310(a)(2); BCC § 5404. 22 FMC § 9-3309(g). 23 FMC § 9-3309(h), § 15-2603. CONFIDENTIAL AND PROPRIETARY 31  Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  is prohibited.24 The building entrances will also bear clear and legible notices that no person under the age of 21, or under the age of 18 with a medical recommendation, is permitted to enter the premises.25 Finally, the Company will post the original copies of the commercial cannabis business permit and the business license issued by the City inside the business in a location readily visible to the public.26 iii.Maintenance of Premises The Company will maintain the premises and its infrastructure so that it is visually attractive and not dangerous to the health, safety and general welfare of employees, customers, surrounding properties, and the general public. Litter will be removed daily from the premises, including adjacent public sidewalks and the parking lot. These areas will also be swept and cleaned on at least a weekly basis.27 iv.Records and Recordkeeping The Company will maintain accurate books and records in an electronic format, detailing all of the revenues and expenses of the business, and all of its assets and liabilities. At least annually, the Company will file a sworn statement detailing the number of sales, gross sales, and taxes paid or due to be paid during the previous twelve-month period on a per-month basis. Annually, the Company will arrange for a financial audit of its operations by an independent Certified Public Accountant and submit it to the City. We will also submit to any regulatory compliance reviews or financial audits as requested by the City Manager.28 The Company will maintain up-to-date records of the names and contact information of anyone owning or holding an interest in the business, as well as a register of all officers, managers, employees, agents, and/or volunteers currently employed by the business. Upon request, we will provide access to these records to the City Manager.29 As detailed below, the Company will use Flowhub as its inventory control and reporting system to accurately document the present location, amounts, and descriptions of all cannabis and cannabis products until purchase.30 Subject to any restrictions under Health Insurance Portability and Accountability Act (“HIPAA”) regulations, the Company will allow the City to have access to the business's books, records, accounts, and any other data or documents relevant to its cannabis operations for the 24 FMC § 9-3309(h). 25 FMC § 9-3309(i)(2-3). 26 FMC § 9-3309(k). 27 FMC § 9-3309(n).   28 FMC § 9-3331(a). 29 FMC § 9-3331(b). 30 FMC § 9-3331(c). CONFIDENTIAL AND PROPRIETARY            32    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  purpose of conducting an audit or examination within 24 hours of receipt of the City’s request, unless otherwise stipulated by the City.31 1.6.1. Daily Operations for Retail Permit i. Customer Check-In Procedures Upon arrival onsite, customers, patients, qualified primary caregivers, and visitors will immediately enter into the building via our secure lobby, where they will be greeted by a staff member at the reception desk to have their identification (“ID”) verified. A receptionist will utilize an electronic identification-card scanner to verify the individual’s age,32 confirm the validity of their government issued identification, and check the customer in to Flowhub, the Company’s Point-of-Sale (“POS”) system. The following forms of ID will be accepted: (i) a document issued by a federal, state, county, or municipal government, or a political subdivision or agency thereof, including, but not limited to, a valid motor vehicle operator's license that contains the name, date of birth, height, gender, and photo of the person; (ii) a valid identification card issued to a member of the Armed Forces that includes the person’s name, date of birth, and photo; or (iii) a valid passport issued by the United States or by a foreign government. Only adult-use customers over the age of 21 and qualified medicinal cannabis patients over the age of 18 (with valid physician’s recommendations for medicinal cannabis) will be granted access to the cannabis retail business.33 Reception staff will utilize Flowhub’s proprietary “Nug” mobile card scanning device for seamless customer check-in and identity verification. The Nug mobile scanner offers the following enhanced capabilities: (i) instant customer check-in upon scanning a customer’s ID; (ii) customer age verification; (iii) built in fraud-detection (to ensure the validity and authenticity of IDs presented), and (iv) it enables staff to easily upload customer documentation to their individual Flowhub profile(s). For first-time customers, a unique customer profile is created within Flowhub immediately upon scanning the individual’s ID with the Nug mobile card scanner. In addition to identity and age verification, reception staff will also verify the validity of physician’s recommendations and state-issued medical cannabis ID cards presented by patients prior to allowing patients to access the retail sales floor. Documentation supplied by medicinal cannabis patients must adhere to the following standards: (i) only original physician’s recommendations; (ii) retail staff must be able to verify the recommendation directly with the issuing physician or with a reputable online service; and (iii) the recommendation must be issued by a physician currently licensed by the state of California. Once the validity of a patient’s recommendation and the issuing physician’s license is confirmed, a copy of the patient’s documentation will be added to the patient’s unique customer profile in Flowhub and stored in company files for a minimum of seven years.   31 FMC § 9-3331(d). 32 FMC § 9-3310(a)(3). 33 FMC § 9-3309(i)(1); BCC § 5404. CONFIDENTIAL AND PROPRIETARY            33    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  If the card-scanner clears the ID, but the receptionist still suspects that the ID is fraudulent, the receptionist will double-check the validity of the ID with onsite security personnel and conduct an online search for the customer’s name (via Google, Facebook, Instagram, Twitter, or another platform.) to see if the search shows any indication that the customer is underage. If an employee is still suspicious of an ID, they will use the F-L-A-G system for further verification: Feel, Look, Ask, Give back. If a customer ID is found to be fraudulent, the General Manager on duty will: ● Confiscate the fraudulent ID. ● Keep a copy of the ID and ID receipt for The Company’s records. ● Complete an incident report with notes about the situation (who, what, when, where, and why), attach a copy of the fraudulent ID to the incident report, and upload it into company records. ● Within 24 hours, the Company will turn over the fraudulent ID and a copy of the corresponding incident report to the Fresno Police Department. Additionally, a note or “flag” associated with the name on the fraudulent ID will be input into the POS system to automatically alert security and reception staff in case the purchaser or cardholder attempts to return. Customers attempting to utilize fraudulent IDs to access our cannabis retail business will be permanently banned from our store. However, Management has the discretion to allow previously banned customers to visit our store once they are of legal age, provided that they furnish the company with a letter of explanation deemed acceptable by upper management. If a customer ID is verified pursuant to the aforementioned company protocols and passes the feel, look, and ask tests, the ID will be returned to the customer and they will wait in our lobby area until they are granted access to the Retail Sales Area by a staff member.34 The entrance to the Retail Sales Area (“retail area”, “retail floor”, or “sales floor”) will remain locked at all times. All customers and visitors must be granted access electronically and “buzzed-in” to the retail floor to ensure limited and controlled access from the lobby area to the retail floor.35 Under ordinary operating conditions, it is company policy to maintain a ratio of a maximum of three (3) customers to each one (1) sales associate in the retail area. However, the Company will adjust its occupancy policy as needed to protect the health and safety of its customers and employees (in the event of a public health crisis, for example). In extenuating circumstances that require the Company to limit occupancy in order to comply with guidance issued by county and state public health authorities, the Company may conduct curbside ID verification, check-in, and pick-up of pre-ordered customer orders, if allowed by the BCC and the City of Fresno.36   34 FMC § 9-3310(b)(1)(i). 35 FMC § 9-3310(a)(4). 36 BCC § 5038. CONFIDENTIAL AND PROPRIETARY            34    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  Once granted access to the retail floor, verified customers may (i) interact with employees, (ii) observe securely displayed cannabis and cannabis products, and (iii) have limited and supervised interaction (touching and smelling, where possible) with securely displayed cannabis products. Interactions with products will only be conducted when safe to do so. Our knowledgeable sales associates will be available to answer any customer questions and educate customers on our various product offerings. Once customers have browsed the products available and determined the items they’d like to purchase (if applicable), they will be directed to the Cashier / Point-of-Sale stations to purchase and take possession of their processed orders of cannabis products. (Customers arriving onsite who have pre-ordered cannabis goods will be verified, granted access to the retail floor, and automatically routed to one of the Cashier / Point-of-Sale stations to pick up their prepared orders.) After completing their purchases, customers will be instructed to immediately exit the retail sales area. The Company will prohibit loitering by persons outside the facility both on the premises and within 50 feet of the premises.37 ii. Location and Procedures for Receiving Shipments During Business Hours38 The Company will prearrange the receipt and transportation of cannabis and cannabis products, and pre-authorized distribution transportation personnel will pre-schedule a time to arrive at the cannabis retail business. Prior to receiving or transporting cannabis and cannabis products, the Company will request a complete electronic shipping manifest, which will contain the following information to provide a clear chain of custody for the items being transported: (i) The Company’s name and license number; (ii) the distributor’s name and license number; (iii) the names of authorized transportation vehicle drivers; (iv) a list of all cannabis goods being transported, including a description of the quantity transported; (v) the METRC UIDs of the cannabis products; (vi) the time and location of departure; (vii) the time and location of expected arrival; (viii) the make, model, and license plate number of the transportation vehicle; and (ix) any other information required by the State of California or the City of Fresno.39 Upon arrival at the cannabis retail business, distribution / transportation personnel will check-in with a security guard, and the security guard will inform the onsite manager. The onsite manager will then allow the transportation personnel to enter the cannabis retail business and will provide the licensed distributor’s personnel a visitor badge and have them sign into a visitor log. The Company will keep the visitor log up-to-date and maintained for a period of at least seven (7) years.   37 FMC §§ 9-3309(l), 9-3310(b)(1)(v). 38 FMC § 9-3310(b)(3); BCC § 5049.  39 BCC § 5049. CONFIDENTIAL AND PROPRIETARY            35    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  Once signed in, security personnel will route authorized distribution personnel to the secure limited-access loading and unloading entrance, where our employees will help securely offload cannabis products from the distribution vehicle. The Company’s employees will then transfer the cannabis products to the secure Inventory Intake / Quality Control area for review. The onsite manager will then review the METRC shipping manifest and make sure it is accurate and has all the required information per Section 5314 of the BCC regulations. Our onsite manager will also review the official Certificate(s) of Analysis (COA) associated with the goods in question and verify the license number of the laboratory that performed the regulatory compliance testing. Authorized Inventory QC personnel will review the COAs accompanying all incoming shipments to confirm that the laboratory test results match the information on the cannabis product packaging. Once the regulatory compliance testing results are confirmed to be authentic and matching, our onsite manager, along with designated Quality Control personnel, will review the cannabis products to confirm that the cannabis products meet the packaging and labeling requirements outlined by the Department of Public Health.40 Once packaging and labeling has passed screening, our onsite manager will work with cannabis retail business staff to spot check all of the cannabis products to ensure that no products arrive damaged. If a cannabis product appears to be damaged, the Company will request the shipping manifest to be updated both in writing and in METRC. After all cannabis products have been spot checked, our onsite manager will ensure that all information matches what is shown in the transfers section of METRC and that the Unique Identifier (“UID”) in the online system matches the physical METRC tags that were provided to the Company. After verifying that (a) the cannabis products have (i) passed the quality assurance and inspection procedures contained in Section 26110 of the CA BPC, (ii) been issued a certificate of analysis pursuant to Section 26110 of the CA BPC, and (iii) all applicable METRC tags, and (b) that the shipping manifest that has all the information required pursuant to Section 5049 of the BCC Regulations, our employees will verify that the manifest also matches the cannabis products indicated online in METRC so that the Company can accept the transfer of cannabis products within METRC and assign the METRC tags issued to us under our license. The Company will remit payment to the distributor for excise taxes and any money owed before physically moving the cannabis products from the Inventory Intake / Quality Control Area to the Secure Cannabis Storage Area. The Company will only accept incoming shipments of cannabis goods and add them to our inventory after they have passed the aforementioned Quality Control screening process. After accepting a shipment of cannabis products, adding METRC tags and inputting the goods into our inventory records in Flowhub, employees will transfer the accepted cannabis products to the secure cannabis storage area. After the accepted cannabis products are secure in the designated cannabis storage area, the onsite manager, along with assistant managers, will transfer the cannabis products’ information from METRC into the Company’s POS and track and trace system,   40 California Code of Regulations, Title 17, Division 1, Subchapter 5, of the Manufactured Cannabis Safety Regulations, “Labeling and Packaging Requirements”.  CONFIDENTIAL AND PROPRIETARY            36    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  Flowhub, and add all necessary information as previously stated along with any additional information required by the City and State. Upon receipt of a shipment of cannabis products, the Company will create a record verifying receipt of the shipment and the details of the shipment. After accepting cannabis products from a licensed distributor, the Company will enter the following information into our internal point-of-sale tracking system: (i) The name and license number of the State licensed distributor providing the cannabis products; (ii) the name and employee number of the person entering the cannabis products into the Company’s internal point-of-sale tracking system; (iii) the best-by, sell- by, or expiration date of the cannabis products; (iv) the date of receipt of the cannabis products; (v) the METRC UID; (vi) the quantity, product name, and individual price, and applicable tax amounts; (vii) laboratory-test results; and (viii) any other information required elsewhere by the City or State.41 All records collected by the Company related to the receipt and acceptance of cannabis products will be maintained for a minimum of seven (7) years and will be made available by the Company to the officers, employees, or agents of the State or the City upon request.42 iii. Point of Sale System As detailed above, the company uses Flowhub as its POS and Track and Trace Systems.43 There will be three Point of Sale locations in operation at the retail cannabis business. Flowhub will provide tracking and reporting regarding all aspects of the cannabis business, including, but not limited to, cannabis tracking, inventory data, gross sales (by weight and by sale), and any other information deemed necessary by the City. The information will be compatible with the City’s recordkeeping systems and will have the capability to produce historical transaction data for review. The Company will obtain approval and authorization from the City Manager or its designee(s) prior to implementing Flowhub as its inventory management platform.44 The Company will provide the City with a unique user login to our Flowhub account to facilitate access to our inventory data in real-time. Further, the Company will be able to provide historical data using Flowhub’s reports functions that can access all sales, which can be either printed or provided via .CSV or PDF file depending on the City’s preference.45 The City can readily track the Company’s cannabis inventory via Flowhub by the following categories: (i) Licensed distributor name, (ii) product type (flower, concentrate, edibles, tinctures, etc.), (iii) price, (iv) area where cannabis product is located in the dispensary (retail floor, vault, delivery vehicle), (v) date of entry into system, or (vi) product name, weight, and count.46 The Company will keep and maintain all inventory and sales data on file for at least seven (7) years.47   41 BCC § 5049. 42 BCC § 5037; FMC § 9-3331. 43 FMC § 9-3310(b)(1)(xvi). 44 FMC § 9-3309(e). 45 FMC § 9-3331(a). 46 FMC § 9-3331(c). 47 BCC § 5037; FMC § 9-3331. CONFIDENTIAL AND PROPRIETARY            37    Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  Additionally, the Flowhub POS system automatically tracks customer sales, and has built- in protections that disable sales associates from completing sales transactions that would bring a customer’s aggregate daily purchases above the legal threshold48: ● Per BCC regulations, adult-use customers are allowed to purchase up to: o 28.5 grams of non-concentrated cannabis per day; o 8 grams of cannabis concentrate. o 6 immature plants ● For medicinal cannabis patients and their authorized primary caregivers, the following daily purchase limits apply: o 8 ounces of cannabis flower or the equivalent as provided in Health and Safety Code Section 11362.77; o 12 immature cannabis plants. iv. Estimated Number of Customers to Be Served Per Hour and Day The Company anticipates that about 15 to 30 customers will be served per hour and 175 to 300 customers served per day on a typical business day. During particularly busy days such as the unofficial cannabis holiday, April 20th (4/20), our cannabis retail business could serve up to 50 patients per hour and up to 500 customers per day. v. Proposed Product Line A critical component of the Company’s business model is its “Menu” and carrying and highlighting specific cannabis brands and products that the Company believes will be particularly well-suited for the Fresno market. With that point in mind, the Company recognizes that Fresno customers deserve the highest level of quality and options when it comes to products and brands, and emphasizes those products and brands with a higher mission and purpose such as “boutique”, “small batch”, “economically inclusive”, “natural”, “organic”, and “green”. To meet diverse customer needs, the Company expects to offer a wide variety of cannabis and cannabis products including: cannabis flower, cannabis pre-rolls, infused pre-rolls, vape cartridges, concentrates, edibles, tinctures, topicals, and capsules. The Company will advertise products for sale pursuant to all applicable marketing regulations. The expected volume of sales of flower versus manufactured products is about a 50-50 ratio based on the Company’s Owners’ previous experience operating cannabis retail businesses. The total estimated retail value of cannabis and cannabis products sold by the Company at ramp up will be approximately $8,500 per day and $250,000 per month, increasing over time. For reference and the opportunity to do more nuanced estimates, please see the Company’s three-year pro forma in section 1.4.   48 BCC § 5049.  CONFIDENTIAL AND PROPRIETARY 38  Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  The volume of inventory held within the retail sales area will be based on management’s reasonable assessment of the volume of inventory that management expects the store to sell in a given day. This assessment will be based on various factors, such as historical sales figures, the anticipated number of customers per day, and management’s expertise. Under no circumstances will the retail floor contain more inventory than is necessary to meet daily demand. vi.Delivery Service Procedures Upon approval by the City of Fresno, we will offer customer delivery to pre-verified customers. Customers will be able to place orders over the phone or online via Weedmaps or our website. Online ordering on our website will be powered by the I Heart Jane platform, which automatically integrates with Flowhub, and will update the cannabis retail business’s available inventory on the website in real time, matching the actual available inventory on site. The Company will utilize the 3rd party software system OnFleet, which also integrates with I Heart Jane and Flowhub technology, for delivery route optimization, order fulfillment, and vehicle tracking (GPS). Delivery personnel will be employees of the Company, and all delivery personnel will undergo mandatory training in the usage of Flowhub and OnFleet to process and fulfill delivery orders. Delivery personnel will also undergo training regarding specific regulatory requirements applicable to delivery operations. We anticipate that initially the volume of delivery will be fairly low, and so anticipate utilizing one delivery vehicle. Additionally, the Company will provide the Chief of Police or their designees with a list of the individual drivers and vehicles authorized to conduct delivery, along with a copy of each driver’s valid State-issued driver's license. During deliveries, the Company’s drivers will carry the following items in the secured vehicle at all times: (i) A copy of the Company’s permits, licenses, and approvals; (ii) the driver’s California Driver’s License; and (iii) the driver’s laminated identification badge issued by the Company. Delivery drivers will also maintain a copy of the delivery request, which will comply with State and City law regarding the protection of confidential medical information (in the case of orders placed by qualified medical patients or primary caregivers).49 The Company will only deliver cannabis and cannabis products to a physical address in the State of California, but will not deliver cannabis products to a physical address located on publicly owned land or any address on land or in a building leased by a public agency. Each dedicated delivery vehicle will be (i) insured at or above the minimum policy limits prescribed by the City and State; (ii) equipped with a secure lockable compartment for storing orders of cannabis goods that is separate from the body of the vehicle, and (iii) temperature controlled for the optimal storage of cannabis products during delivery. Furthermore, our delivery vehicle will not contain any exterior advertising, logos, or images that suggest or indicate that the vehicle is transporting cannabis or affiliated with cannabis operations.50 49 BCC § 5417. 50 FMC § 9-3310(a)(7); BCC § 5417. CONFIDENTIAL AND PROPRIETARY 39  Tradecraft Farms Fresno – Fulton, LLC Business Operations Plan  The Company will equip its delivery vehicles with an active vehicle alarm system and all doors and windows will be locked when unoccupied.51 The Company’s delivery vehicle drivers will ensure that cannabis and cannabis products are not visible to the public from the exterior of the delivery vehicle.52 During delivery, cannabis products will be locked in a fully enclosed box, container, or cage that is secured on the inside of the vehicle. However, no portion of the enclosed box, container, or cage will comprise any part of the body of the vehicle or trailer.53 Customers will place delivery orders through Weedmaps or the Company’s website, which will be supported by the I Heart Jane technology platform. Payment will be processed either online at the time of ordering via debit/ACH, or the customer will have the option to pay in cash upon delivery. Customer-submitted delivery orders are received at the Company’s premises by one of the Managers or sales associates on duty, who are notified of new customer delivery orders via dashboard notifications within the Company’s website. New orders will also automatically print to an onsite printer within the cannabis retail business. These systems will be continuously updating and refreshing, so employees will be alerted to new customer delivery orders in real time. At least one Assistant Manager is responsible for monitoring online platforms for new customer delivery orders, and delegating order assembly and fulfillment to appropriate members of retail staff. In processing delivery orders, we will request that customers provide us with an electronic copy of their government issued ID, and in the case of qualified patients or primary caregivers, a copy of their medical recommendation or primary caregiver registration card, prior to commencing the process of receiving a delivery order. The Company will first verify the medical recommendations and/or primary caregiver registration card directly with the issuing physician or a reputable online service, and only accept medical recommendations from licensed California physicians. When the delivery driver arrives, they will use a certified ID scanner to verify the ID as well as verify that the customer matches the ID that was sent via email. At the time of delivery, delivery drivers will ask patients and primary caregivers to present their documentation in person, to verify that the patient documentation matches what was sent via email. Once a delivery driver returns to the cannabis retail business, the driver will provide the signed delivery request receipt to the cannabis retail business employee who prepared the order and ensures that Flowhub was properly updated to denote completion of the sale and fulfillment of the delivery. The cannabis retail business employee will then enter the payment received into the cash register and scan the signed receipt, along with the final Flowhub receipt, and upload digital copies into company records. 51 BCC § 5417(c). 52 FMC § 9-3309(d). 53 BCC § 5417(b).  CONFIDENTIAL AND PROPRIETARY CONCLUSION Tradecraft Farms looks forward to bringing our vision, team of seasoned professionals, and safe and compliant operations to the City of Fresno. Most importantly, we look forward to growing and prospering together with the City. Exhibit A CONFIDENTIAL AND PROPRIETARY 1 PROOF OF PRIOR REGULATED CANNABIS OWNERSHIP AND EXPERIENCE: Licenses Owned and Operated by Tradecraft Farms’ Owners and Operators License Number License Type Agency Legal Business Name Location Status C11-0000686-LIC Distributor BCC Dub Brothers Management, LLC 3480 E 14th ST, Los Angeles, CA 90023 Active C11-0000421-LIC Distributor BCC Dub Brothers Management, LLC 721 E 5th St, Los Angeles, CA 90013 Active C13-0000136-LIC Distributor- Transport Only BCC Dub Brothers Management, LLC 1711-1721 Griffith Ave, Los Angeles, CA 90021 Active CCL19-0001404 Small Indoor Cultivation CDFA Dub Brothers Management, LLC 4121 Alameda St, Los Angeles, CA 90058 Active CCL19-0000826 Small Indoor Cultivation CDFA Dub Brothers Management, LLC 717 Stanford Avenue, Los Angeles, CA 90021 Active CCL19-0000827 Small Indoor Cultivation CDFA Dub Brothers Management, LLC 3480 E 14th ST, Los Angeles, CA 90023 Active CONFIDENTIAL AND PROPRIETARY 2 CCL19-0001110 Specialty Indoor Cultivation CDFA Dub Brothers Management, LLC 1711-1721 Griffith Ave, Los Angeles, CA 90021 Active CCL20-0000260 Specialty Indoor Cultivation CDFA Dub Brothers Management, LLC 2507 Main Street, Los Angeles, CA 90007 Active CCL20-0000257 Specialty Indoor Cultivation CDFA Dub Brothers Management, LLC 2515 Main Street, Los Angeles, CA 90007 Active CDPH-10003442 Type 6: Manufacturing CDPH Dub Brothers Management, LLC 721 E 5th St, Los Angeles, CA 90013- 2110 Active CDPH-10004002 Type 6: Manufacturing CDPH Dub Brothers Management, LLC 3480 E 14th ST, Los Angeles, CA 90023 Active C10-0000570-LIC MEDICAL Retailer BCC Manuel Migueles Collective dba Tradecraft Farms 732 E VISTA WAY, VISTA, CA, 92084 Active BL-00041170 MEDICAL Retailer with Delivery City of Vista, CA Manuel Migueles Collective dba Tradecraft Farms 732 E VISTA WAY, VISTA, CA, 92084 Active C12-0000331-LIC Microbusiness (with Retail) BCC Tradecraft Farms - Port Hueneme, LLC dba Tradecraft Farms 2597 BOLKER DR PORT HUENEME, CA 93041 Active PHCU-842 Microbusiness (with Retail) City of Port Hueneme, CA Tradecraft Farms - Port Hueneme, LLC dba Tradecraft Farms 2597 BOLKER DR PORT HUENEME, CA 93041 Active Conditional Use Permit No. 18-05 Medical Cannabis Cultivation and Manufacturing City of Lancaster, CA Tradecraft Ventures, LLC 43511 70TH STREET EAST, LANCASTER, CA, 93535 Active CONFIDENTIAL AND PROPRIETARY 3 LA-C-18-000240-APP Cultivation Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 4121 Alameda St, Los Angeles, CA 90058 Active LA-C-18-000242-APP Cultivation Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 717 Stanford Avenue, Los Angeles, CA 90021 Active LA-C-18-000238-APP Cultivation & Distribution Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 2507 Main Street, Los Angeles, CA 90007 Active LA-C-18-000239-APP Cultivation Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 2515 Main Street, Los Angeles, CA 90007 Active LA-C-18-000237-APP Cultivation & Distribution Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 1711-1721 Griffith Ave, Los Angeles, CA 90021 Active LA-C-18-000241-APP Distribution & Manufacturing Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 721 E 5th St, Los Angeles, CA 90013 Active LA-C-18-000243-APP Cultivation, Distribution, and Manufacturing Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 3480 E 14th ST, Los Angeles, CA 90023 Active CCBL #2120 Retailer City Of El Monte Tradecraft Farms – El Monte, LLC dba Tradecraft Farms 11518 Garvey Ave El Monte, CA 91732 Approved, in Development N/A* Retailer City of Fresno Tradecraft Farms Fresno – Fulton, LLC 915 N. Fulton St. Fresno CA 93728 *Application in Process N/A* Retailer City of Fresno Tradecraft Farms Fresno – Chinatown, LLC 925 China Alley, Fresno CA 93706 *Application in Process N/A* Retailer City of Fresno Tradecraft Farms Fresno – Ventura LLC 3594 East Ventura Ave., Fresno, CA 93702 *Application in Process CONFIDENTIAL AND PROPRIETARY 4 DAAA-41SI-ZOZZ Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 1046 E. 2nd, Edmond, OK 73034 Active DAAA-4JV6-UEY8 Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 777 Jenkins Ave, Norman OK 73069 Active DAAA-EJBN-XUTA Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 4327 NW 23rd, St., Oklahoma City, OK 73107 Active GAAA-4YTC-2JIN Commercial Grower Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 4327 NW 23rd, St., Oklahoma City, OK 73107 Approved PAAA-EYHW- NZDJ Commercial Processor Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 4327 NW 23rd, St., Oklahoma City, OK 73107 Approved DAAA-EJWE-6EU6 Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 111 W. ELM AVE, STILWATER, OK 74074 Active DAAA-41ZQ-KRIT Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 2017 S. Harvard Dr. Oklahoma City, OK 73128 Active GAAA-V1HO-TSCA Commercial Grower Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 2017 S. Harvard Dr. Oklahoma City, OK 73128 Active CONFIDENTIAL AND PROPRIETARY Exhibit B CONFIDENTIAL AND PROPRIETARY 2 Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   TABLE OF CONTENTS 2.1. Commitment to Living Wage .................................................................................................. 3  2.2. Employee Benefits ................................................................................................................... 3  A. Health Benefits................................................................................................................. 3  B. Vacation ........................................................................................................................... 4  C. Medical/Sick Leave ......................................................................................................... 4  D. Leave for Specific Circumstances ................................................................................... 4  E. Unpaid Personal Leave of Absence ................................................................................. 5  F. Workers’ Compensation .................................................................................................. 5  G. Retirement Benefits ......................................................................................................... 5  2.3. Continuing Education and Employee Training ........................................................................ 5  A. Regulatory Knowledge & Education ............................................................................... 5  B. Cannabis Knowledge ....................................................................................................... 6  C. Security Training ............................................................................................................. 7   D. Employee Education Assistance ...................................................................................... 7  2.4. Social Policy Compliance and Local Recruitment .................................................................. 8  2.5. Locally Managed Enterprise .................................................................................................... 9  2.6. Description of Staff Positions and Employee Roles and Responsibilities ............................. 10  A. Job Descriptions and Duties ........................................................................................... 10  2.7. Labor Peace Agreement ......................................................................................................... 13  2.8. Workforce Plan ...................................................................................................................... 13  2.8.1. Local Hire Commitment ..................................................................................................... 13  2.8.2. Commitment to Continuing Education and Employee Training ........................................ 14  2.8.3. Commitment to Living Wage ............................................................................................. 14  A. Overtime ........................................................................................................................ 14  B. Rest & Meal Periods ...................................................................................................... 15  2.9. Social Equity Business Incubator Program............................................................................ 15  CONCLUSION ............................................................................................................................. 17  Exhibit A: Labor Peace Agreement .............................................................................................. 18  4  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   employee’s medical benefits, or other contribution as may be required by the Affordable Care Act. Part-time employees will also be given an opportunity to participate in the Company’s employer- sponsored health plan following six months of employment with the Company, but at a reduced rate of plan sponsorship. All employees will receive details about benefits provided, contribution rates, and eligibility in their hiring packets. B. Vacation Tradecraft Farms will offer paid vacation time to employees. Employees will begin to accrue vacation following 90-days of employment with the Company according to the schedule below: Years of service Hours per year Hours accrual rate 0-4 years 80 .058 5+120 .061 C. Medical/Sick Leave All part-time, full-time, and temporary employees will receive medical/sick leave that is well in excess of the state of California’s requirements for paid sick leave.3 Our sick leave policy is as follows: (i) Lump Sum Method: The Company will provide eligible employees with five days or 40 hours of paid sick time. Employees will accrue sick time after being employed with the Company for at least 30 days. Time will be banked each year on the employee’s anniversary date; or (ii) Accrual Method: Employees will accrue one hour of paid sick leave for every 30 hours worked. D. Leave for Specific Circumstances The Company believes that employees should be able to take time off to address important life needs. Our Employee Handbook advises employees of the specific circumstances that warrant leave including: (i) Time off to Vote; (ii) Bereavement Leave; (iii) Jury Duty; (iv) Witness Duty; (v) Temporary Disability Leave; (vi) Volunteer Emergency Responder Leave; (vii) Victims of Felony Crime Leave; (viii) Civil Air Patrol Leave; (ix) School Leave for Disciplinary Matters; (x) Bone Marrow Donation Leave; (xi) Organ Donation Leave; (xii) Pregnancy Disability Leave; (xiii) Military Leave; (xiv) Military Spousal Leave; (xv) School Activities Leave; (xvi) Domestic Violence / Sexual Assault Leave; and (xvii) Rehabilitation Leave. 3 California Labor Code § 246. CONFIDENTIAL AND PROPRIETARY 5  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   E. Unpaid Personal Leave of Absence Unpaid personal leave of absence may be granted, upon request, to regular full-time employees for important pressing personal needs subject to the following provisions: unpaid personal leave may only be requested once all other appropriate leave balances have been exhausted. The Company will attempt to hold an employee’s position open for the period of unpaid personal leave if such leave is six weeks or less. If leave is greater than six weeks, the employee, if qualified, will be entitled to the first reemployment opportunity available over the next six months. Employee health benefits will be continued in the same manner as received prior to the leave, if the leave is for six weeks or less, but the employee will be expected to remit payment for the employee's portion of the health insurance premium prior to departing for unpaid personal leave, and in an amount equivalent to the expected period of absence. If an employee requests leave which will extend beyond the 6-week period, he/she will be advised of his/her ability to enroll in continuing healthcare coverage through COBRA. F. Workers’ Compensation As required by law, the Company provides workers’ compensation benefits for the protection of employees with work-related injuries or illnesses. Workers’ compensation insurance provides coverage to employees who experience job related injuries or illnesses. If an employee is injured or becomes ill as a result of his/her job, it is the employee’s responsibility to immediately notify a supervisor of their injury in order to receive benefits. The Company will advise the employee of the procedure for submitting a workers’ compensation claim. If necessary, injured employees will be referred to a medical care facility. Employees should retain all paperwork provided to them by the medical facility. An employee’s report should contain as many details as possible, including the date, time, description of the illness or injury, and the names of any witnesses. A separate insurance company administers the worker’s compensation insurance. Representatives of this company may contact injured employees regarding their benefits under the plan. G. Retirement Benefits The Company will make retirement benefits available to full-time employees who work 30+ hours a week after working one year with the Company. Pursuant to its desire to provide a “living wage”, the Company shall look to provide a matching contribution of 3% to whatever the employee contributes to their retirement plan up to a maximum of 2.3. Continuing Education and Employee Training A. Regulatory Knowledge & Education The Company’s top priority when training employees is to ensure that employees understand rules and regulations that govern cannabis retail in order to run a safe and compliant workplace. The Company will ensure that initial employee training will be at least two hours long and cover the modules including: (i) Health and safety concerns related to cannabis use, including CONFIDENTIAL AND PROPRIETARY 6  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   the responsible use of cannabis, its physical effects, onset of physiological effects; (ii) Recognizing signs of impairment and appropriate responses in the event of overconsumption; (iii) Laws and regulations on driving under the influence; (iv) Prohibiting sales to minors; (v) Daily sales limits to customers and patients; (vi) Acceptable forms of identification as well as how to check identification and common mistakes made in verification; (vii) Safe and secure storage of cannabis; (viii) Compliance with all inventory tracking system regulations; (ix) Waste handling, management, and disposal; (x) Health and safety standards; (xi) Maintenance of records; (xii) Security and surveillance requirements; (xiii) Permitting inspections by the City and State; and (xiv) Packaging and labeling requirement for all cannabis and cannabis products. B. Cannabis Knowledge In addition to operations, the Company will train employees on general cannabis and cannabis product information to ensure that they are educated and can in turn be a resource for customers. Training will include detailed information on the following topics: (i) what cannabis is; (ii) the different ways cannabis is smoked, consumed, and applied; (iii) short-term and long- term effects of cannabis on the brain; (iv) suggested consumption methods and dosing guidelines; (v) understanding edible consumption and dosage; (vi) customer guidelines for responsible and safe cannabis usage; (viii) the physical effects of consuming cannabis and cannabis products; (ix) the mental effects of cannabis and cannabis products; (x) long-term effects of cannabis use; (xi) treatments for cannabis use disorder; (xii) effects of secondhand cannabis smoke; (xiii) cannabis as a possible gateway drug; (xiv) overdosing on cannabis; (xv) cannabis addiction; and (xvi) dangers of synthetic cannabinoids. Retail storefront employees will also be trained on how to interact with customers, give recommendations based on their requests, give advice, guidance, and counsel. Employees will not give medical treatment advice, as they are not licensed health professionals, and will be instructed to advise customers to consult a physician for medical advice. Tradecraft Farms expects all staff members to maintain a high level of fluency in the wide array of cannabis products we carry and be exceptionally knowledgeable about the varying cannabis products and strains available. As such, we offer routine and consistent employee training opportunities so that our retail staff can continuously refresh their product knowledge and live up to the Company’s high standards of service. Accordingly, the Company will maintain Product Information Sheets for all of the cannabis products we receive from our vendors and compile them in a binder that all staff can access, review, and reference at any time. These Product Information Sheets will include a description of each product, how it was cultivated or manufactured, as well as information on the anticipated effects. We will require employees to be tested on their Cannabis and Regulatory Knowledge and expect all employees to pass Product and Regulatory Compliance “Quizzes”. Employees will not be able to commence work for the Company until they successfully pass these quizzes and demonstrate that they are adequately knowledgeable and prepared to begin serving Tradecraft Farms’ customers. CONFIDENTIAL AND PROPRIETARY 7  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   C. Security Training The Company understands that having adequate security infrastructure is critical to the success of any cannabis business. We are keenly aware of the added security challenges that commercial cannabis retail businesses face, and we have taken extensive measures to develop professionally vetted policies, procedures, and systems that will provide comprehensive protection, not only to our physical store, but also to our employees and customers, as their health and safety is of paramount importance. The Company will train managers on how to use the security alarm system set up by the alarm company and then train all necessary employees on how the system works. It is critical that employees understand exactly what to do in the event of security breaches and threats. This understanding ensures employee and customer safety and gives law enforcement and security personnel the ability to respond to a specific rapid response without fear of injury. The Company’s Security Officer will provide specific training to management and employees in the following areas: (i) security awareness training; (ii) responding to a robbery attempts; (iii) interacting with a disruptive customer; (iv) alarm activation response; (v) attempted theft; (vi) working with local law enforcement; (vii) medical emergencies; (viii) proper use of the “panic button”; (ix) being a good witness/report writing; (x) theft and diversion training; (xi) OSHA compliance; and (xii) training developed for all compliance issues. In addition to the items listed above, our Chief Compliance Officer, Paula Brunelle, will work with security companies and with management to design and implement continued training in security related matters on a regular basis. Employees shall be tested on training content and must pass a comprehensive test by their third attempt in order to remain employed. All staff shall also go through periodic refresher seminars, as well as new training on any policy updates or changes in procedure. All emergency procedures will be rehearsed in periodic drills. In addition to training and drills, employees will receive official Company reference materials, written in plain language and presented in an easy-to-use outline format, explaining all operational, safety, and security policies and protocols. In developing our official safety and security policies, the Company has consulted licensed security and safety professionals from Barton Integration and Reax Engineering and will also consult with local law enforcement. We will work with local law enforcement to develop effective ongoing employee training seminars and practices, especially for the development of our policies and training procedures related to crime-prevention and security threat response. After participating in security-related training, all employees should know: (i) how to assess situations to determine the type and level of threat; (ii) how to respond to different kinds of security threats; (iii) which types of situations warrant the activation of panic buttons; and (iv) how to proceed when a security alarm is triggered or a panic button has been activated. D. Employee Education Assistance The Company will reasonably accommodate and assist any employee who wants to attend conferences, classes, or educational workshops, in particular educational workshops held by the Company, that will enable them to become more knowledgeable in cannabis products and CONFIDENTIAL AND PROPRIETARY 8  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   information systems, and thus better employees. In addition to mandatory employee training sessions regarding our POS system, online ordering platforms, and delivery fleet management system (FlowHub, WeedMaps, I Heart Jane, and OnFleet, respectively), we strongly encourage employee educational programs that highlight safe cannabis usage for consumers and security- minded practices to keep our customers, employees and the business safe, and to ensure that the Company provides the best retail experience for our customers. Tradecraft Farms will cover the costs associated with cannabis industry conferences, classes, and educational workshops that our employees wish to attend in order to facilitate their continuous education. The Company will be a leader in staff education, and by extension, consumer education regarding cannabis product use, safe consumption, the variety of strains available, differing methods of consumption, and the effects of each product and strain type. We will coordinate with medical professionals who are knowledgeable regarding cannabis and cannabinoid therapies to help employees understand safe practices. By employing this strategy our staff will have the tools to provide customers and patients with the most up-to-date information about cannabis and the ever-expanding list of ways it can potentially benefit the mind and body. 2.4. Social Policy Compliance and Local Recruitment Tradecraft Farms will take an all-inclusive approach to hiring and seeks to have a diverse workforce that adequately represents the vibrant community within which our business intends to operate. This value is aligned with Fresno Municipal Code 9-3316(b)(1). Tradecraft Farms is committed to ensuring that at least one-third of hours worked annually by Tradecraft Farms’ employees will be worked / fulfilled by employees who meet Fresno’s Social Policy Requirements, namely, individuals that satisfy one of the following criteria: (i) annual family income below 80% AMI; (ii) convicted for a cannabis related crime that could have been prosecuted as a misdemeanor or citation under current state law; (iii) lived in a low to moderate income census tract in the city for a minimum of three (3) years; (iv) veteran; or (v) former foster home youth who was in foster care as a minor; (vi) unemployed; or (vii) receiving public assistance.4 Additionally, should the Company be awarded a permit to operate a commercial cannabis retail store by the City of Fresno, the Company will provide the City with ongoing proof of compliance with the aforementioned social policy requirement. In order to execute our plan to hire a 50% local workforce and ensure local residents are prioritized, we will proactively target local candidates via direct outreach and by publicizing our open positions on local job boards, at local colleges including Fresno State and Fresno City College, in local newspapers, at community events, and at local area venues. We plan to participate with local community-based organizations and local job placement agencies to facilitate local recruiting, outreach, and candidate development. One such local program, Reading & Beyond, works to lift children, families, and neighborhoods in Fresno out of poverty, including through job placement efforts. We will work with Reading & Beyond to hire local candidates from disadvantaged circumstances whenever possible. 4 FMC § 9-3316(b)(1). CONFIDENTIAL AND PROPRIETARY 9  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   Furthermore, we intend to work with state and local agencies such as the Employment Development Department (EDD) to announce jobs, hold hiring events, and provide interview training to prospective candidates. We intend to cultivate deep connections to local nonprofits and community organizations in order to become a trusted employer and engaged neighborhood partner. In addition, our job training and educational programs will allow us to hire inexperienced local candidates who will benefit from on-the-job training programs, as opposed to hiring candidates from other geographical areas. Our goal is hire local residents who have historically suffered from low income and consistent barriers to employment and provide skills development through a management training program. This will result in an educated and trained workforce that we can promote to supervisor and management positions from within. By investing in the education and professional growth of our workforce, we hope to contribute to a better future for the neighborhood and the larger Fresno community. Local recruiting efforts will be documented in a detailed report we intend to issue on the first business day of January and the first business day of July each year that the business is operational. These semiannual reports will illustrate the Company’s candidate outreach efforts, including the number of persons interviewed, and details on who was hired to satisfy the good- faith local hiring requirement. As with all records, we will provide these reports to the City upon request. 2.5. Locally Managed Enterprise As described in detail in the Business Plan, we are deeply fortunate to have the local experience of Gerald (“Gerry”) Nickerson as our Regional Director of Community Relations and Social Policy. Gerry has been a Fresno resident since 1995 and has been a mentor to Tradecraft Farms’ co-founder Barry Walker since the 1980s. Gerry has dedicated his entire career to fundraising for local charities and local public schools. He is well-known and respected in the Fresno community, and we look forward to working together to successfully integrate our retail business into the Fresno community. Gerry has already demonstrated his unique skill set in identifying key community partners for Tradecraft Farms in Fresno, and we look forward to growing together. Tradecraft Farms values community participation and social responsibility—it is embedded into the company ethos and has always been a lifelong priority for our founders—and Gerry has the connections, skills, and experience to ensure that Tradecraft Farms’ is consistently working for and in service of improving the greater Fresno community at large. CONFIDENTIAL AND PROPRIETARY 11  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   4. Chief Compliance Officer The Company’s Chief Compliance Officer is the senior executive officer who is responsible for ensuring our retail business operates in compliance with State and City laws, and is responsible for company policies related to inventory tracking, reporting, and inventory controls, including procurement and quality control standard operating procedures. The Chief Compliance Officer works with management and employees to ensure compliance with cannabis product inventory and track-and-trace reporting. 5. Regional Director of Community Relations and Social Policy The Regional Director of Community Relations and Social Policy serves as the Company’s point-of-contact for on-site community relations to whom government representatives and members of the community can provide notice if there are operating problems associated with the Company’s retail storefront. The Director regularly engages with local community organizations and City representatives and is the bridge between the company and the surrounding community. 6. General Manager The General Manager (“GM”) is the day-to-day supervisor of the Company’s retail operation and has direct authority, control, or supervision over all personnel who engage in the retail sale and delivery of cannabis and cannabis products. The GM serves as a role model, liaison, and resource for retail staff concerning products and services, policies and procedures, industry news and changes in regulations. They ensure compliance with all state and local rules and regulations, and directly supervises the activity within the retail storefront to include staff training and education. The GM manages the receipt, storage and auditing of all inventory, and is responsible for ordering new inventory and supplies, and maintains accurate records. The GM resolves all inventory discrepancies and reconciliations while accurately documenting and recording all inventory movement in the company’s track and trace system and into the State’s track and trace software, METRC. The GM supervises Assistant Managers on all daily tasks consistent with established procedures with an emphasis on inventory control actions such as receiving, counting and inspecting all incoming cannabis products for quality and compliance; implement HR policies, programs, and systems in support of company initiatives; directs all compliance efforts for the company to minimize risk and deal with any internal conflicts. The GM conducts investigations, responds to unemployment claims, EEOC, DOL, and/or employee relation issues such as employee complaints, harassment allegations, and civil rights complaints. The GM conducts exit interviews, analyzes data, and conducts performance reviews with employees and monitors employee productivity, attitudes, and performance results. The GM also makes recommendations to the corporate management team for corrective action and continuous improvement. The GM maintains excellent facilities in a manner conducive to enhancing employee productivity and compliance, and ensures employee safety, wellness, health and welfare. CONFIDENTIAL AND PROPRIETARY 12  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   7. Assistant General Managers The Retail Assistant General Managers (“AM”) assist our GM with day-to-day operations of the cannabis retail storefront in accordance with the State of California, local regulations, and standards set by the Company. The AMs help maintain organization and operations at the retail storefront with detail to inventory duties. AMs also assist the sales team to ensure efficiency and customer satisfaction. The AMs provide support to the store manager and all employees, and patients/customers. Overall duties also include light cash-handling, training, policy and procedure updates, and keeping updated with industry news and cannabis product information. The AM provides management and leadership in the cannabis retail storefront to include monitoring all point-of-sale transactions. They respond to all staff questions, concerns, or suggestions within scope and reports to the GM for resolution. The AM directs and monitors sales representatives to accomplish goals of the days consistent with established operational procedures. The AM maintains records required by public health law and ensures quality assurance plans, including but not limited to plans to detect, identify, and prevent errors related to product packaging and labeling. The AM monitors employee productivity, attitudes, and performance results, and makes recommendations to the GM for corrective action and continuous improvement for product and policies. The AM responds to all patient/customer complaints, requests, concerns, suggestions and takes action when directed by the GM to resolve conflicts including responses and replies across social platforms. The AM manages the receipt, storage, record keeping, and auditing of all inventory, and maintains retail compliance and cleanliness. The AM performs inventory control actions such as receiving, counting, and inspecting for quality and compliance. The AM assists the GM with accurately documenting all inventory movements to be recorded in the company’s track and trace system and into the State’s track and trace software, METRC to identify the proper location and quantity of product at all time; and bi-monthly reconciliation inventory counts based on company requirements and works with the store manager to resolve all inventory discrepancies and light-cash handling. 8. Retail Sales Representatives Sales representatives (“SR”) assist guests, clients, vendors, and management. SRs assist the management team with the activities and operation of the retail store, while abiding by policies, procedures, and operational guidelines. SRs are responsible for customer service, checking out customers, and handling cash. They will warmly greet visitors in person or on the telephone, and answer questions or direct inquiries through proper channels. They accurately process payments from customers, and issue receipts, refunds, credits, and change. SRs establish or identify prices of goods, services or admission, tabulate bills using calculators, cash registers, and optical price scanners. They operate a cash register and itemize total purchases by recording prices, departments, taxable and nontaxable items and balance cash drawers by counting cash at beginning and end of work shift to ensure that amounts are correct and that there is adequate change. SRs help maintain a compliant and clean retail storefront and assures side-work completion every shift. They establish, develop, and maintain relationships with current and prospective customers to generate sales for cannabis products. SRs use information-based training to educate CONFIDENTIAL AND PROPRIETARY 13  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   customers with the SR expected to continue education on all products. They maintain product knowledge of all products in-store in order to communicate to customers and patients. They ensure the sales floor is properly stocked and the store is well maintained and clean. SRs promote a work environment that is positive, customer-service oriented, and compliant with established policies and procedures. 9. Delivery Drivers Delivery drivers have similar responsibilities to SRs, but with the added responsibilities of handling proper record receipts to be given and signed by customers and understanding safety and delivery compliance protocols for all deliveries. They must obey all traffic and cannabis laws and have necessary paperwork required by the City and State hard copy or electronically, at all times. Delivery drivers must also ensure safe driving and cannabis transportation protocols, including GPS monitored trip-planning. Drivers are responsible for ensuring that transactions are conducted safely and that they are regularly monitoring customer and personal safety, and security of products and cash. 10. Security Personnel The Company will hire a third-party security company that will ensure the safety of customers and employees and the security and protection of the premises and all company assets. This is accomplished through the use of foot patrols, an on-site professional presence, camera monitoring, escort procedures, access controls, and enforcement of company security policies. All security guards will be armed and certified by the Bureau of Security and Investigative Services. They will check the identification cards of all persons entering the lobby / check-in area to ensure that only individuals over the age of 21, or over 18 with a valid physician’s recommendation, are granted access to the retail sales area. 2.7. Labor Peace Agreement The Company has a deep commitment to labor and a strong relationship with United Food and Commercial Workers (“UFCW”). Attached as Exhibit A is a copy of the Labor Peace Agreement between Tradecraft Farms. In addition, the Owners / Members of the Company have entered into other labor peace agreements with UFCW in the state of California. Namely, Tradecraft Farms – El Monte, LLC, an affiliated retail cannabis business owned and managed by the Company’s executive team, has established a Labor Peace Agreement with UFCW. Tradecraft Farms is proud of its proven track record with labor and its exemplary treatment of employees and looks forward to opening and operating a Union Shop in the City of Fresno. 2.8. Workforce Plan 2.8.1. Local Hire Commitment As identified in Section 2.4., “Social Policy Compliance and Local Recruitment”, we aspire to hire at least 50% of employees who are bona fide residents of the City of Fresno. In fact, we are CONFIDENTIAL AND PROPRIETARY 14  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   generally so committed to local hiring that in our Oklahoma location, we have a 92% local hiring rate. We have similarly committed to local hiring in our other retail locations. Tradecraft Farms is committed to local hiring, not simply for compliance with City requirements, but because we fundamentally believe that local hires are the best community representatives and want to create hyper-local community benefit and social impact. We want the local communities in which we operate to directly benefit from job opportunities and want to offer local stakeholders opportunities for continuing education, professional development, and career advancement. Furthermore, should the Company be awarded a permit to operate a commercial cannabis retail store by the City of Fresno, the Company will provide the City with ongoing proof of compliance with the aforementioned local hiring commitment. 2.8.2. Commitment to Continuing Education and Employee Training The Company is committed to ongoing employee education and recurring employee training. In furtherance of this commitment, Tradecraft Farms intends to cover the reasonable costs and fees associated with any conferences, classes, or educational workshops that employees wish to attend in order to facilitate their continuing education. All retail employees will receive paid training on company policies, standard operating procedures, and cannabis product types and strains upon hiring, and prior to commencement of the job functions for which they were hired. Once employees are onboarded, we will reasonably accommodate any employee who wants to attend conferences, classes, or educational workshops, and will cover the costs associated with these educational opportunities. In particular, we will encourage employees to attend Company-sponsored workshops and trainings, which will enable them to become increasingly knowledgeable and capable employees that are better-equipped to serve customers. Additionally, employees will be paid for the hours spent in training and professional educational courses. In addition to mandatory paid employee training sessions regarding our POS system, online ordering platforms, and delivery fleet management system (FlowHub, WeedMaps, I Heart Jane, and OnFleet, respectively), we strongly encourage professional educational programs that highlight safety and security in cannabis, as this helps ensure that the Company can provide a best- in-class customer experience. The Company cover the cost of all associated fees associated. Tradecraft Farms will be a leader in educating its staff and thereby its customers about the different strains of cannabis, available methods of consumption, and the effects of each strain. 2.8.3. Commitment to Living Wage A. Overtime Non-exempt employees will be paid overtime (one and one-half times the regular rate of pay) for all hours worked over eight in one work-day, over 40 in one work week, and for the first eight hours of work performed on the seventh consecutive work day in one work week, without regard to the total number of hours worked in the previous six days. Overtime is paid at the rate of CONFIDENTIAL AND PROPRIETARY 15  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   double the regular rate of pay for every hour worked after the completion of eight hours worked on the seventh consecutive workday in any workweek. In addition, overtime is paid at the rate of two times the regular rate of pay for every hour worked after the completion of 12 hours worked in one workday. Tradecraft Farms’ General Counsel regularly consults with outside counsel that specializes in Labor and Employment Practices to ensure that company policies are compliant with California labor laws and that our employees are appropriately and fairly compensated. B. Rest & Meal Periods Non-exempt employees who work shifts over five hours in length are required to take an unpaid 45-minute meal period, to be taken before the end of the 5th work hour. Non-exempt employees who work in excess of 10 hours in a day are entitled to a 2nd, 45-minute meal period, to be taken before the end of the 10th hour. Meal periods should not be taken at the employee’s work area. 2.9. Social Equity Business Incubator Program Recently cities throughout the country have taken an important and highly commendable step of creating social equity programs to provide people who have been adversely impacted by the war on drugs and people without the resources with an opportunity to flourish in the burgeoning cannabis industry. However, creating and providing meaningful ownership and employment opportunities in such a highly regulated and competitive environment leads to difficulty in ensuring such owners and employees will actually have a viable chance of success. In addition, large companies often take advantage of equity applicants without a real plan to encourage entrepreneurship.   This purpose of sharing this perspective is to demonstrate the way in which Tradecraft Farms embraces the spirit of Fresno’s Social Equity Program and is committed to achieving a workable solution that provides the tools, space, and financial resources necessary to foster successful equity-owned cannabis businesses in Fresno via the creation of Tradecraft Farms’ Social Equity Business Incubator Program (the “Incubator Program”). Tradecraft Farms believes it is better to teach people to fish than to give them a fish, as this ensures that equity efforts maintain long-term sustainability, and are not merely reflected in an ownership percentage in an application. Through our Incubator Program, qualified start-up equity cannabis businesses will not only run their own businesses but obtain the necessary skills to succeed in a competitive landscape. Tradecraft Farms believes that creating a space for those who have been chronically disenfranchised, unfairly prosecuted, and systematically targeted is the first step towards meaningful change and building long term success. By partnering with those who are dedicated to learning and working hard, the incubator program can help nurture and foster true growth, upward mobility and mutual success. The Tradecraft Farms incubator program will provide all of the necessary resources to help businesses and social equity partners succeed in a competitive landscape. We will provide mentoring, real-industry immersion, networking, hands-on instruction, financial guidance, marketing support and a plethora of other resources. Our goal is CONFIDENTIAL AND PROPRIETARY 16  Tradecraft Farms Fresno –Fulton, LLC Social Policy and Local Enterprise Plan   to provide equity- and minority-owned businesses with a war chest of resources and guidance that will allow them to not only build successful companies but enhance their own personal growth in the process. Incubated social equity businesses partners will receive full access to Tradecraft Farms’ vertically integrated cannabis supply chain operated by Dub Brothers Management, LLC (Tradecraft Farms’ mutually owned affiliate), which includes expansive cultivation, manufacturing, and distribution capabilities, in addition to dedicated shelf space in Tradecraft Farms’ retail stores. Incubated equity business partners will receive comprehensive assistance with product manufacturing, packaging and labeling, branding, and marketing (as needed), giving them the support they need to take a product line from ideation to production, and ultimately, to market where it can be sold in Tradecraft Farms retail stores and beyond. We looked at decades of growth in Silicon Valley and the huge success of incubator programs that helped foster some of the strongest tech companies to create our own version of an incubator program which we believe will be just as effective and even more impactful. Similar to the technology incubator programs of Silicon Valley, we will be providing companies with: ●Access to Tradecraft Farms’ supply chain, including cultivation, manufacturing, distribution, and retail. ●A process which will give them access to tools and information needed to move forward. ●Direct access to a team of seasoned cannabis industry professionals and mentors for business advice and technical support. ●Critical Manufacturing, branding, and regulatory compliance support related to bringing cannabis products to market. ●Enterprise guidance, including financial, operational, and marketing support. ●Access to financial resources. As with any high growth industry, the rules of engagement are constantly changing, and the marketplace is evolving more quickly than most companies can keep up with. In the Tradecraft Farms Incubator Program, equity and minority owned companies will be granted access to a network of shared information and industry best practices, which will allow them to remain competitive, build a foothold in the marketplace, attract great partners, and create real enterprise value. Additionally, unlike other industries, the cannabis industry still faces incredible scrutiny and suspicion from federal regulators, legislators and the general public. The ever-changing regulatory landscape creates an onerous burden on most small companies, and the cost of compliance can be prohibitively expensive. As such, equity business participants in Tradecraft Farms’ Incubator Program will be given complimentary access to seasoned cannabis regulatory CONFIDENTIAL AND PROPRIETARY Exhibit A CONFIDENTIAL AND PROPRIETARY 1 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) LABOR PEACE AGREEMENT (Fresno) This Labor Peace Agreement ("Agreement") is entered into this 1st day of December, 2020 by and between Tradecraft Farms Fresno – Fulton, LLC (hereafter "Employer") and United Food and Commercial Workers International Union, and its designated Local, UFCW Local 8 (hereafter "Union"). This Agreement is entered into in accordance with applicable requirements of the California Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA), California B&P Code § 26000 et seq., and applicable local cannabis licensing ordinances and regulations. 1. This Agreement shall apply to the regular full time and regular part-time employees of Employer who work in the job classifications set forth in Exhibit "A" (the "Employees") at Employer's licensed cannabis business located at 915 North Fulton Street, Fresno, CA 93728 (the "Covered Facility"). If the Covered Facility relocates pursuant to its license under State or local law to another location within the geographic jurisdiction of Union, this Agreement shall apply to the Covered Facility at that new location. In the event Employer choses to operate the Covered Facility under a different "DBA", this Agreement shall nevertheless apply to that Covered Facility when using that new DBA. If Employer applies for a requisite license to operate one or more additional cannabis businesses within Union's geographic jurisdiction, Employer shall provide written notice of same to Union's Secretary-Treasurer (an email shall suffice), whereupon the Parties shall sign a New Location Agreement in the form attached hereto as Exhibit "C" to extend this Agreement to cover the regular full time and regular part-time Employees (as defined) working at that new location for a like Term as this Agreement. Exhibit C will be signed within 5 days of the Notice. 2. The Parties hereby establish the following procedure for the purpose of ensuring an orderly environment for the exercise by Employees of their rights under Section 7 of the National Labor Relations Act and to ensure compliance with MAUCRSA and all applicable local cannabis ordinances and regulations. 3. The Parties mutually recognize that Federal labor law guarantees Employees the right to form or select a labor organization to act as their exclusive representative for the purpose of collective bargaining with Employer, or to refrain from such activity. 4. Employer will take a neutral approach to the unionization of the Employees. Accordingly, Employer will not undertake any action or make any statement that will directly or indirectly state or imply opposition to Employees' selection of a collective bargaining agent, or preference for or opposition to any particular union as Employees' collective bargaining agent. The Union and its representatives will not coerce or threaten any employee in an effort to obtain authorization cards. CONFIDENTIAL AND PROPRIETARY 2 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) 5. The Union shall have reasonable access to the Employer’s worksite as set forth herein during regular business hours or when employees are required to work for the purpose of meeting with Employees to discuss their right to representation, employment rights under state law, and terms and conditions of employment. In doing so, the Union shall not disrupt the Employer’s business and will act consistently with the California Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA) and Local Cannabis Ordinances. Prior to taking access, the Union will send a letter to the Employer with the names of the individuals who may visit the location prior to its first visit. If the designated individuals change, the Union will update that notice. Then, Employer will cooperate with Union in making arrangement to permit the designated Union representatives to meet with employees in areas where the Employees will be able to speak to the Union representative without monitoring by the Employer, at a time when the employee is not regularly obligated to perform work duties. As part of that cooperation the Employer will share with the Union the particular staffing and layout of the facility to best ensure access while avoiding disruption of the business. To the extent Employer has video surveillance equipment throughout its facility, consistent with the law, the Parties agree that such equipment will not be utilized by Employer to garner information regarding concerted activity or workers' rights under this Agreement. 6. Within ten (10) days following receipt of a written notice from Union declaring an intent to organize Employees (an email to Employer shall suffice), Employer will furnish Union with a complete list of the regular full and part-time Employees referenced in Exhibit "A" showing their job classifications, departments, home addresses, and, if known, cell phone numbers and email addresses. The Employer will provide an updated complete list monthly, unless there is no change to the list. Union will keep all such Employee information furnished by Employer confidential and shall not use the information for any purpose other than the purposes of this Agreement or as required by law. Within ten days of receiving a request by Union, Employer also shall distribute the letter attached as Exhibit B to each Employee. 7. At the Union’s request, the Employer will arrange for a mandatory staff meeting to enable the Union to meet with all of the Employees referenced in Exhibit "A". If it is not feasible for the Employer to schedule a single meeting attended by all Employees, then Employer will cooperate with the Union to schedule a follow up meeting(s) for that purpose. The Employer shall schedule these meeting(s) so as to encourage maximum attendance. Any such meeting will be on paid time. The Parties shall schedule a date for the meeting at least one (1) week prior to the meeting. There shall be no advance announcement by the Employer to employees concerning the subject of the meeting. Rather, the Employer shall schedule the meeting in the same way that notice is provided for other mandatory meetings. Each meeting shall last no more than one (1) hour. At this meeting, Employer will inform Employees that it is neutral, does not object to their talking with Union and supporting a union, and that Employer will negotiate a collective bargaining agreement with Union if and when a majority of Employees who wish to be represented by the Union have designated Union as their exclusive collective bargaining representative. Union representatives will attend the meeting and after Employer has left the meeting, Union representatives will talk with Employees about the Union. CONFIDENTIAL AND PROPRIETARY 3 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) 8. The Union may request recognition as the exclusive collective bargaining agent for the Employees. Upon such request, a person mutually agreed to by Employer and Union, or if no agreement is reached then the Arbitrator identified in Paragraph 13, will conduct a review of Employees' authorization cards and membership information submitted by Union in support of its claim to represent a majority of the Employees. The review shall involve a comparison of the authorization card signatures of Employees to their W-4 or Form I-9 as furnished by Employer. Except where needed to resolve a concern about the authenticity of an Employee's signature, the identity of all union authorization card signers shall be kept confidential from Employer. Subject to the availability of a person mutually agreed upon or an Arbitrator identified in Paragraph 13, such review shall take place no more than fourteen (14) days after the Union's request, absent mutual agreement to extend time for review. The size of the unit to determine recognition will be determined by the size of the unit ten (10) days prior to the time the request for recognition is made. If the review establishes that a majority of Employees has designated Union to be their exclusive collective bargaining representative or joined the Union, Employer will officially recognize the Union as the Employees' exclusive collective bargaining representative. 9. Employer will not file a petition with the National Labor Relations Board for any election in connection with any demand for recognition provided for in this agreement. The Union and Employer will not file any Unfair Labor Practice charges with the National Labor Relations Board or any other type of legal claim in connection with any act or omission occurring within the context of this Agreement; arbitration under Paragraph 14 shall be the exclusive remedy. Union and Employer agree that if any other person or entity petitions the National Labor Relations Board for any election as a result of or despite recognition of the Union pursuant to this Paragraph, (a) Employer and Union each will request that the NLRB dismiss the petition on grounds of recognition bar or, if they have agreed to a collective bargaining agreement covering Employees at the time the petition is filed, on grounds of contract bar, (b) if the petition is not dismissed, Employer and Union shall agree to a full consent election agreement under Section 102.62(c) of the NLRB’s Rules and Regulations, and (c) Employer and Union shall at all times abide by the provisions of this Agreement. 10. If the Union is recognized as the exclusive collective bargaining representative as provided in Paragraph 8, negotiations for a collective bargaining agreement shall commence no later than 120 days from the date of recognition (or 45 days from a request by the Union to bargain a successor contract for a contract that has an impending expiration date) unless extended by mutual agreement by the parties. To ensure labor peace throughout the collective bargaining process, if the Parties are unable to reach agreement on a collective bargaining agreement within 9 months after recognition pursuant to Paragraph 8 (or upon 4 months after commencement of bargaining for a successor agreement), either party shall have the right to submit any unresolved issues for resolution to final and binding arbitration pursuant to Paragraph 13. The arbitrator identified in Paragraph 13 below shall be the Arbitrator, unless another Arbitrator is mutually agreed to by the Parties. The Arbitrator shall be guided by the following considerations: a) Proposals by the Parties during bargaining leading up to arbitration; b) Size and type of the Employer's operations; CONFIDENTIAL AND PROPRIETARY 4 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) c) Ability of the employees, through the combination of wages, hours and benefits, to earn a living wage to sustain themselves and their families; d) Employees' productivity; e) Employment standards and conditions at comparable retail or other licensed cannabis operations; f) Customer focused concerns; g) Responsible customer service in a clean and secure environment that assures customer and worker safety; h) A procedure that allows workers to raise and expeditiously resolve workplace disputes; i) Full Compliance with Local and State laws regulating cannabis businesses; j) Compliance with all labor and employment standards under Federal, State and Local laws covering the employees of the Employer; and k) Any other relevant economic or non-economic factors which the Parties have entered into evidence at the hearing. 11. In consideration of the covenants made herein, during the Term of this Agreement, the Union shall not engage in any work stoppage, picketing, boycott or other economic activity directed at the Employer's business (including, but not limited to any strike, sympathy strike, “slowdown”, public hand billing, public display of banners, demonstration directed at the employer, or refusals to handle merchandise (except as may be permitted by applicable provisions of Cal/OSHA). During the Term of this Agreement, Employer will not engage in a lockout of the Employees. If Employer lawfully recognizes any union besides the Union as the exclusive collective bargaining representative of Employees, this Agreement shall terminate immediately and without notice. 12. With the exception of trimming operations, once notice is given pursuant to Paragraph 6 above, Employer shall ensure that any subcontractor who may be engaged to do bargaining unit work shall be required to execute a LPA on the same terms as this Agreement at the time of the subcontracting, if at the time it is not represented by an exclusive bargaining agent. Noting in this section is intended to limit the scope of bargaining over subcontracting, including that of trimming operations if/when the Union is recognized. 13. The Union will cooperate with the Employer in efforts before State and Local Agencies on issues of common concern, including the licensing process, provided the CONFIDENTIAL AND PROPRIETARY 5 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) Employer complies with this Agreement and laws governing the rights of its workers. The Employer will extend the same cooperation to the Union on issues of common concern. 14. The Parties agree that any disputes over the interpretation or application of this Agreement shall be submitted to expedited and binding arbitration at a location to be mutually agreed within 25 miles of the Covered Facility, with an Arbitrator mutually agreed to by the Parties. If the Parties are not able to agree upon an arbitrator within 7 business days, they shall request from the Federal Mediation and Conciliation Service a list of five arbitrators who are members of the National Academy of Arbitrators and who have their principal office in Southern California. The Parties shall, within 14 days of receiving the list, select a permanent Arbitrator (“Arbitrator”) under this Agreement by alternately striking two names from the list. The Arbitrator shall be the last remaining name on the list after each side has stricken two names. The party to strike first shall be determined by coin toss. The fourth name stricken from the list shall be the Alternate Arbitrator (“Alternate Arbitrator”). The Arbitrator shall hear and decide all disputes submitted to arbitration unless the Arbitrator is unavailable for a hearing within 30 days from the date of submission, but the Alternate Arbitrator is available during such 30-day period, in which case the dispute shall be submitted to the Alternate Arbitrator for hearing and decision. The Arbitrator (or Alternate Arbitrator) shall conduct the arbitration according to the procedures established by the American Arbitration Association. The Arbitrator (or Alternate Arbitrator) shall also have the authority to order the noncompliant party to comply with this Agreement, including both remedies in equity and law. The Parties hereto agree to comply with any order of the Arbitrator (or Alternate Arbitrator), which shall be final and binding. The United States District Court for the Central District of California shall have exclusive jurisdiction over any action concerning arbitration under this Agreement. The Parties consent to the entry of any order of the Arbitrator (or Alternate Arbitrator) as the order or judgment of the Court, which includes the entry of findings of fact and conclusions of law. 15. This Agreement shall be in full force and effect (the "Term") from the date it is fully executed by Employer and the Union until the earlier of: (i) two (2) calendar years from the date of Employer's execution of the Agreement; (ii) or upon execution of a collective bargaining agreement or issuance of an interest arbitration award which concludes the collective bargaining agreement negotiations, either of which explicitly supersede this document. Employer shall notify Union in writing when it has hired a sufficient number of employees to become obligated to enter into a labor peace agreement under MAUCRSA and/or an applicable local cannabis licensing ordinance. This Agreement may only be extended by mutual agreement of the Parties in writing. 16. If any provision of this Agreement is deemed invalid or found to be contrary to law by a court of competent jurisdiction, such provision shall be of no force or effect; but the remainder of this Agreement shall continue in full force and effect. The Parties shall meet and negotiate in good faith with respect to any provision found to be in contravention of the law, not later than fourteen (14) days after a written request to do so by either party with the goal of addressing the issue raised. 17. This Agreement will bind all legal successors to the Employer. Accordingly, in the event of Employer's sale of a Covered Facility or a merger of Employer with another entity that is taking over the operation of a Covered Facility, Employer will require, as a CONFIDENTIAL AND PROPRIETARY 7 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) EXHIBIT A Description of the bargaining unit The job classifications will include all full time and regular part time hourly retail sales and support dispensary employees of the Employer working at the Covered Facility. The bargaining unit shall exclude all other employees including all managerial, supervisory and confidential employees and all guards employed by the Employer working at the Covered Facility as those terms are as defined by the National Labor Relations Act and applicable decisions of the NLRB. Once a full complement of workers is hired at the Covered Facility, Employer will notify Union within thirty (30) days of all Employee job titles. CONFIDENTIAL AND PROPRIETARY 8 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) EXHIBIT B Dear Employees: Our dispensary has been approached by United Food and Commercial Workers International Union and its Local UFCW 8. The UFCW is a labor union that represents cannabis workers throughout California. The Union has expressed an interest in organizing our employees. We believe that it is in the best interest of our employees, guests, and clients to resolve the issue of union representation as quickly as possible, and with minimum disruption. As required by applicable law, and to avoid what could be a lengthy and disruptive campaign, we have signed a Labor Peace Agreement with the Union. This letter will explain some basic terms of this Agreement ("the Agreement"). The Labor Peace Agreement gives the Union an opportunity to hold a meeting with our employees at the Facility on paid time to discuss unionization. We will also be providing the Union with a list of our employees' names, phone numbers, email addresses and home addresses where they can contact you. The Labor Peace Agreement guarantees employees the right to form or select a labor organization to act as their exclusive representative for the purpose of collective bargaining with their employer, or to refrain from doing so. Because the decision to join or not join the Union is yours to make, management will not be commenting on the matter. All managers and supervisors have been affirmatively instructed in their obligations under this agreement. Union representatives will also have the opportunity to contact Employees in the near future. The Union representative will explain the benefits of joining the Union and will ask each employee if he or she wants to join the Union. If an employee wants to join the Union, he or she will be asked to sign a card that states that they want the Union to represent them. By signing this authorization card, you are selecting the Union to serve as its exclusive collective bargaining representative. If an outside, neutral third party confirms that the Union has obtained signed authorization cards from a majority of the employees working at this Facility, we will recognize the Union as our employees' exclusive collective bargaining representative and will meet with the Union to negotiate in good faith over the terms of a collective bargaining agreement. I have written this letter to maintain our tradition of open, forthright communication. Again, the decision of whether or not to join the Union is your decision alone. Sincerely, /s/ CONFIDENTIAL AND PROPRIETARY 9 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) EXHIBIT C (After-Acquired Location Agreement) The Parties do hereby agree as follows: 1. The undersigned are Parties to the attached Labor Peace Agreement ("Agreement"), dated _________________, 20__. Paragraph 1 of the Agreement provides for the extension of that Agreement to the bargaining unit employees working at any facility within Union's geographic jurisdiction where the Employer has applied for the requisite licenses to operate a cannabis business during the Term. By signing below, the Parties hereby extend the Agreement to cover the regular full time and regular part time employees working in the bargaining unit job classifications working at the following location: Name: _______________________________________________________________ DBA (if any): __________________________________________________________ Address: _____________________________________________________________ _________________________________________________________CA 9________ 2. This Agreement shall be in full force and effect from the date it is fully executed by Employer and the Union until the earlier of: (i) five (5) calendar years from the date of Employer's execution of the Agreement; (ii) or upon execution of a collective bargaining agreement or issuance of an interest arbitration award which concludes the collective bargaining agreement negotiations, either of which explicitly supersede this document. FOR THE EMPLOYER: By: Title: Date: _________________________ FOR UFCW LOCAL 8 By: _____________________ Title: ___________________ Date: __________________ CONFIDENTIAL AND PROPRIETARY 3 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan Tradecraft Farms Fresno – Fulton, LLC, d.b.a. Tradecraft Farms (the “Company”), is composed of seasoned cannabis industry professionals whose collective experience operating licensed cannabis businesses in California makes them wise beyond their years. Our executive team prides itself on establishing authentic and meaningful relationships with t he communities in which they operate and is committed to bringing their family and community service-oriented ethos to the City of Fresno. It is our goal to operate an inclusive, elevated storefront cannabis retail business in the City of Fresno that seamlessly integrates into its surrounding neighborhood. It is our goal to establish relationships with the local community that are truly symbiotic. Accordingly, Tradecraft Farms will manage operations in a manner that mitigates potential nuisance or is detrimental to public health, safety or convenience. Furthermore, the Company will be mindful of the welfare of the greater Fresno community, and of people residing, working, visiting, or recreating near its business. The following policies, which collectively constitute our “Good Neighbor Plan,” are in place to demonstrate how the Company will satisfy its commitment to being a good neighbor, and how we will manage our staff and business operations in order to eliminate the possibility of negatively impacting the South Tower neighborhood.1 3.1. Response to Complaints i. Noise In an effort to avoid any noise disturbances to our neighbors and community, Tradecraft Farms will abide by the following policies: ●Exterior sounds that may emit from the cannabis retail business during regular business hours will not exceed 65 decibels (“dBa”) and will not exceed 60 dBa when the business is closed. We will make sure interior sounds do not exceed 50 dBA. ●If the noise level is continuous and goes beyond the reasonably allotted time, security will work with the Onsite Manager to ensure the noise is discontinued or stopped for a time period to the allowable exterior and interior sound level. ●Sounds associated with the maintenance of the cannabis retail business will be exempt from the above measures, but our Company will ensure these activities occur between the hours of 7:00 a.m. and 6:00 p.m. every day. Relatedly, sounds associated with the maintenance and inspection of emergency machinery, vehicles, or alarms will only occur between the hours of 7:00 a.m. and 6:00 p.m., Monday through Friday.2 ●At all times we will ensure that operations are compliant with the Fresno Noise Ordinance as set for in Fresno Municipal Code (“FMC”), Chapter 10, Article 1. 1 FMC § 9 -3307(d)(8). 2 FMC § 10-109. CONFIDENTIAL AND PROPRIETARY 4 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan We will give all neighboring businesses the Onsite Manager’s information to whom notice of any complaint can be provided, as well as the name and telephone number of an owner or manager of our Company. If our Company receives complaints of noise that is deemed outside of the parameters of the above, we will address the problem within an hour. ii. Light Outd oor lighting systems shall be designed and installed to comply with the following: ●The minimum requirements in the California Energy Code for Lighting Zones 1-4 as defined in Chapter 10 of the California Administrative Code; ●Backlight, Uplight, and Glare (“BUG”) ratings as defined in IES TM-15-11; and ●Allowable BUG ratings not exceeding those listed in the FMC. The only exceptions to the above outdoor lighting system requirements will be the following: ●Luminaires that qualify as exceptions in Section 140.7 of the California Energy Code; ●Emergency lighting; ●Building façade lighting meeting the requirements in Table 140.7-B of the California Energy Code, Part 6; and ●Custom lighting features as allowed by the local enforcing agency. For bot h interior and exterior lighting, we will utilize standard management practices and technologies for reducing glare, light pollution, and light trespass onto adjacent properties, and shall ensure compliance with the following standards: ●Exterior lighting systems will be provided for security purposes in a manner sufficient to provide illumination and clear visibility to all outdoor areas of the cannabis retail business, including all points of ingress and egress. Exterior lighting shall be stationary, fully shielded, directed away from adjacent properties and public rights of way, and of an intensity compatible with the neighborhood. All exterior lighting shall be California Building Code and Fresno Municipal Code (“FMC”) compliant.3 ●Outdoor lighting shall utilize energy-efficient fixtures/lamps, such as high-pressure sodium, hard -wired compact fluorescent , or other lighting technology that is of equal or greater energy efficiency. ●Interior light systems shall be fully shielded, includ ing adequate coverings on windows, to confine light and glare to the interior of the structure. The windows will also be tinted to help reduce light trespassing. 3 FMC § 9 -3310(b)(1)(iv); FMC §15-2508. CONFIDENTIAL AND PROPRIETARY 5 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan We will give all neighboring businesses the contact information for the Regional Director of Community Relations and Social Policy information as well as the name and telephone number of the Manager to whom notice can be provided in the event of a complaint regarding light pollution that is deemed outside of the parameters of the above. If our Company receives a complaint, Tradecraft Farms will respond within 48-hours. iii. Odor Trad ecraft Farms takes odor detection seriously. As described below, we make significant efforts to ensure that neighbors are unable to detect and odors from the premises. The Odor Detection Form, included as Exhibit A, shall be provided to anyone who suspects objectionable odors emanating from inside the cannabis retail business. The Odor Detection Form will be made available onsite by request. We will maintain records of all odor detection notifications and/or complaints that include the remediation measures employed. The records shall be made available to the City upon request and maintained for seven (7) years. iv.Litter Trad ecraft Farms will ensure outdoor trash receptacles are available near all exterior doors of the cannabis retail business, and the business will be regularly maintained in a safe, clean, and orderly condition. To ensure cleanliness, we will perform litter pick‐up twice a day, within 50 feet of the premises. This will include inspections for graffiti, which will be removed within 24 hours of detection. v.Vehicle Traffic Our proposed retail cannabis business will be located on a property that will have the requisite parking spaces required by the city. Our proposed retail business located at 915 North Fulton Street is 2,831 square feet, which requires seven (7) parking spaces per City requirements. Accordingly, we will add seven new dedicated parking spaces at the location. In addition, significant street parking is available on Fulton Street. The building is served by highways adequate in width and improved as necessary to carry the kind and quantity of traffic such use will generate.4 Trad ecraft Farms does not anticipate any issues with neighboring businesses due to parking or increased vehicle traffic from customers and patients visiting the cannabis retail business. Should any parking or traffic issue arise, a manager will work to add ress the community’s concerns and facilitate a workable solution. vi.Pedestrian Traffic Our Company will strive to contain all pedestrian traffic within the premises’ lobby and retail sales areas. We will be able to have three (3) customers waiting in the lobby and will have 4 FMC § 9 -3307(d) (5-6). CONFIDENTIAL AND PROPRIETARY 6 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan no more than three (3) customers for every one (1) employee in the retail area at a given time, with a maximum of twelve customers allowed on the sales floor at once, given that there are four (4) Point-of-Sale terminals/cashier stations. To mitigate loitering and pedestrian overflow we will offer express pick-up orders, and to the extent allowed by the City, Curbside pickup during the pandemic. These expedited services will help keep the flow of pedestrian traffic running smoothly and efficiently. The following describes the process that customers and patients will go through when entering the cannabis retail business: ●Customers enter the cannabis retail business via the lobby, and our reception employees verify the age and status of customers.5 ●Validated customers enter the retail sales area and (i) interact with our employees, (ii) observe securely displayed cannabis and cannabis products, and (iii) have limited and/or supervised interaction (touching, smelling, etc.) with securely displayed cannabis and cannabis products. ●Validated customers (i) purchase and take possession of processed orders of cannabis products at the Product Point -of-Sale Stations or (ii) return cannabis products that may be adulterated to our Company at the Point -of-Sale stations. ●After finishing their business purpose for visiting the cannabis retail business, customers are directed by employees to securely exit the cannabis retail business. A security guard will also walk the perimeter of the build ing every hour to ensure that no loitering occurs, and that no customers are inhibiting other pedestrians from leaving the premises or accessing other businesses in the area.6 If the lobby is at capacity, staff will kindly ask customers who are willing to wait to provide a phone number and wait in their vehicles. Once space in the lobby becomes available customers will be called and invited to enter the cannabis retail premises . 3.2. Nuisance and Impact Management Trad ecraft Farms’ Owners are entrepreneurs with experience founding business ventures across multiple industry sectors, and currently own and operate licensed cannabis storefront retailers with outstanding reputations in their communities. We begin to build this reputation before we even have a location because Tradecraft Farms believes that neighborhood compatibility starts with site selection. The proposed location for Tradecraft Farms’ cannabis retail business is in an existing building at 915 North Fulton Street in the South Tower District. The location is a standalone building. Neighboring buildings include the Resiliency Center/Fresno Police Chaplaincy, a CBD 5 FMC § 9 -3310(a)(3). 6 FMC § 9 -3310(b)(2)(vi). CONFIDENTIAL AND PROPRIETARY 7 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan store, an apartment building, and private residences. The site is zoned for Heavy General Commercial use and is not located within an 800-foot radius of any sensitive uses such as schools, daycares, or youth centers.7 As identified in the Zoning Inquiry Letter, the property is appropriately zoned for a commercial cannabis retail business. We plan to revitalize the vacant building and showcase the works of local artists in our store, as well as commission local artists—with the help of Fresno Arts Council, a local non-profit—to paint murals on our building exterior. The artistic enhancement of our building on North Fulton Street will help beautify the neighborhood and will fit in with the existing artistic character of the surrounding area and ensure that we are a benefit rather than a nuisance. The building, and the cannabis retail business therein, will be compatible with the surrounding character of the neighborhood and will reasonably blend in with existing buildings and the neighborhood.8 As part of our Good Neighbor Policy, we will implement and enforce the following operational requirements to prevent our storefront cannabis retail business from becoming a public nuisance: ●A Manager, to whom emergency notice can be provided, will be present in the cannabis retail business at all times during hours of operation. Tradecraft Farms will also provide employees, the City, and local businesses and residents with the name and telephone number of Manager to whom emergency notice may be provided twenty-four (24) hours a day. Contact information for Manager(s) shall be made readily available both via our Company’s website and on file with the City and State.9 ●Trad ecraft Farms will provide the City and all businesses and residences located within one hundred fifty (150) feet of the cannabis retail premises with the name, telephone number, and email address of a Manager to whom notice of problems associated with the business can be provided. The Manager will respond to any such complaints within forty- eight (48) hours of receipt of any complaint. ●The Company will prominently display a copy of its State and City-issued permits in a conspicuous location visible and accessible to customers and the public.10 ●At no time shall any of the following items be allowed in the cannabis retail business or on the property grounds: (i) any controlled substance, other than cannabis; (ii) any paraphernalia used for the ingestion of any type of controlled substance, including cannabis (except for cannabis accessories for incidental retail sale to customers); (iii) alcoholic beverages; or (iv) firearms, except in strict compliance with federal, state, and city laws and regulations. These prohibitions will be strictly enforced by employees and security personnel. 7 FMC § 9 -3307(a -c). 8 FMC § 9 -3307(e) (1-2). 9 FMC § 9 -3309(g). 10 FMC § 9 -3309(k). CONFIDENTIAL AND PROPRIETARY 8 Tradecraft Farms Freno - Fulton, LLC Neighborhood Compatibility Plan ●All retail cannabis products shall be cultivated, manufactured, and distributed by licensed businesses that maintain operations in full conformance with state and local regulations.11 ●To track and report on all aspects of the cannabis outlet, Tradecraft Farms will have in place a point-of-sale or inventory management tracking system, which shall have the capability to produce historical transactional data for review and be in compliance with METRC, the State’s track-and -trace system.12 ●Trad ecraft Farms will not sell alcoholic beverages or tobacco at the cannabis retail business and will prohibit the smoking, vaporization, ingestion, or consumption of alcohol, tobacco, or cannabis in any form at the cannabis retail business and on the cannabis retail business premises.13 No employee shall be under the influence of alcohol or drugs while on the premises. ●The Company will not have an onsite physician evaluating patients for issuance of a medicinal cannabis recommendation or identification card and we will not give or offer to give any form of remuneration to a physician if the physician or his or her immediate family have a “financial interest” (as that term is defined in Section 650.01 of the California Business and Professions Code (“B&P Code”) in the Company.14 ●Trad ecraft Farms will not distribute any form of advertising for physician recommendations for medicinal cannabis unless the advertisement bears the notice contained in Section 2525.5 of the B&P Code. ●We will not employ any person under 21 years of age at the cannabis retail business. We will not allow any individual under the age of 21 in the cannabis retail business unless the individual has a medical recommendation and is over the age of 18.15 Signage will be posted at the entrance to the business stating that: “No person under the age of 21 is permitted to enter the premises for adult-use sales”; and “no person under the age of 18 is permitted to enter the premises.” Persons 18 and over will only be permitted to enter the premises if they possess a valid physician’s recommendation for medicinal cannabis.16 ●Trad ecraft Farms will not discriminate or deny service to any patrons in violation of local, State, or federal laws and regulations. ●The Company will ensure that no outdoor storage of cannabis or cannabis products occurs at the cannabis retail business at any time and that cannabis or cannabis products, or 11 FMC § 9 -3309(f). 12 FMC § 9 -3309(e). 13 FMC § 9 -3309(a -c). 14 FMC § 9 -3310(a)(2). 15 FMC §§ 9-3309(i)(1, 4). 16 FMC § 9 -3309(i)(2-3). CONFIDENTIAL AND PROPRIETARY 9 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan graphics depicting cannabis or cannabis products, are not visible to the naked eye from the exterior of our business premises. Furthermore, cannabis products, or graphic descriptions thereof, will not be visible within or on our delivery vehicles.17 ●All areas recorded by the video surveillance system will at all times have adequate lighting to allow the surveillance cameras to effectively record images. ●All exterior windows, doors, loading and unloading docks or bays, and any points of ingress or egress into the cannabis retail business will be secured from unauthorized entry by commercial grade, nonresidential locks, and in a manner approved by the Fresno Police Department. The exterior of each of the foregoing areas will be illuminated during evening and early morning hours. The ingress and egress points of any storage areas for cannabis or cannabis products will be locked and secured at all times, and under the control of and accessible only by authorized personnel. ●All waste generated by or resulting from commercial cannabis activities shall be disposed of as required by law and pending disposal shall be stored in a locked and secure area that is under the control of and accessible only by authorized personnel. ●We will employ odor control devices and techniques to ensure that odors from cannabis and cannabis products are not detectable offsite of the cannabis retail business.18 ●Signage for the cannabis retail business will comply with the Fresno Municipal Code, including, but not limited to, seeking the issuance of a sign permit, if required.19 ●We will provide the following verbal (or written agreement) notices to customers and post notices in a minimum of 24 -point font conspicuously within the cannabis retail business: o “The sale or diversion of cannabis or cannabis products without a license issued by the City of Fresno is a violation of State law and the Fresno Municipal Code.” o “Secondary sale, barter, or distribution of cannabis or cannabis products purchased from a licensee is a crime and can lead to arrest.” o “Customers must not loiter in or near these premises and may not consume cannabis or cannabis products in the vicinity of this business or in any place not lawfully permitted. These premises and vicinity are monitored to ensure compliance.” o “WARNING: The use of cannabis or cannabis products may impair a person’s ability to drive a motor vehicle or operate heavy machinery.” o “CALIFORNIA PROP. 65 WARNING: Smoking of cannabis and cannabis- derived products will expose you and those in your immediate vicinity to cannabis 17 FMC § 9 -3309(d). 18 FMC § 9 -3309(j). 19 FMC § 9 -3309(h)(1). CONFIDENTIAL AND PROPRIETARY 10 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan smoke. Cannabis smoke and certain chemicals contained in cannabis are known to the State of California to cause cancer, birth defects or other reproductive harm. For more information go to www.P65Warnings.ca.gov.” o 12” x 12” signs at entrances, exits, parking lots, and other conspicuous places stating, “LOITERING, PUBLIC DRINKING, OR PUBLIC SMOKING, VAPING, INGESTING OR OTHERWISE CONSUMING CANNABIS ON THE PREMISES OR IN THE AREAS ADJACENT TO THE PROPERTY IS PROHIBITED; NO ONE UNDER THE AGE OF TWENTY-ONE SHALL BE PERMITTED WITHIN THE PREMISES EXCEPT A QUALIFIED PATIENT OVER THE AGE OF EIGHTEEN”.20 o 12" x 12" signs will be posted in conspicuous places in- and outside of the cannabis retail business stating, “THESE PREMISES ARE BEING DIGITALLY RECORDED; ALARM MONITORED”, notifying the public that the surveillance cameras and alarm monitoring system is operative and is actively monitoring. ●We will prevent loitering within 50 feet of the cannabis retail business. Our Company shall take all reasonable steps to discourage and correct conditions that constitute a nuisance in parking areas, sidewalks, alleys and areas surrounding the cannabis retail business and adjacent properties during business hours.21 “Reasonable steps” shall include immediately calling the Fresno Police Department upon observation of the activity and requesting that those engaging in activities that constitute a nuisance or are otherwise illegal to cease those activities, unless personal safety would be threatened in making the request. 3.3. Odor Mitigation The retail premises will have an air treatment system that will be professionally installed and properly maintained to ensure that cannabis odor is not detectable from adjacent properties, or the community. The main, and likely only, potential source of odor at the cannabis retail business will be the cannabis products. The air treatment system will consist, as described below, of carbon filtration on the exhaust side of the ventilation system and negative pressurization of the cannabis retail business in relation to the exterior ambient condition.22 Employees, customers, and patients shall immediately report odor to management, who will then take corrective action such as implementing upgrades to the system, to the cannabis retail business, or to the internal handling process of product within the cannabis retail business to further deter odors. 3.4. Potential Sources of Odor On the retail sales floor, the only potential odor concerns that we anticipate are from the cannabis product s. Our Company’s cannabis retail business will utilize technology, such as double-sealed doors and an air-scrubbing carbon unit, that will remove most, if not all odors from 20 FMC § 9 -3309(h)(3). 21 FMC §§ 9-3309(l), (n). 22 FMC § 9 -3309(j). CONFIDENTIAL AND PROPRIETARY 11 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan the area. To further reduce cannabis odors, all cannabis products will be stored in sealed packages, as required by State law, apart from a small quantity used for display purposes. 3.5. Odor Control Devices and Techniques An exhaust and ventilation system will be utilized to prevent both odors within the cannabis retail business areas, and off -site odors. The cannabis retail business’ operations shall not create dust, noxious gasses, odor, smoke, unsafe conditions, or other impacts that create a public nuisance or adversely affect the health or safety of the nearby residences or businesses. The industry standard for air filtration calls for an activated carbon filtration system, photo catalytic oxidation (“PCO”), or a similar air-scrubber system. These systems greatly reduce or eliminate odors that can be associated with cannabis products. For the proposed cannabis retail business, the configuration and design of the filtration system will be finalized during the building permit phase to allow for City input, thereby ensuring that the proper system is utilized. The filtration system ultimately installed will ensure that odors from cannabis are mitigated in the following locations: (i) off -site; (ii) adjacent properties; (iii) any public rights-of-way; and (iv) common tenant areas.23 Plans for our Company’s odor-combatting filtration system will be submitted to the City for approval. The air-scrubbing filtration system works to remove unwanted odors and impurities. The system creates negative pressure between the cannabis retail business interior and exterior, thus keeping any odors inside the cannabis retail business and not detectable from the outside. Meanwhile, a carbon-zeolite mixture and a true medical HEPA filter absorb and remove odors and gases. All areas of the premises will have sufficient ventilation to facilitate proper cannabis products storage and to provide a reasonable condition of comfort for each employee, consistent with their job. Restrooms shall be vented to the outside air by means of an openable, screened window, an air shaft , or a light-switch activated exhaust fan, consistent with building codes. 3.6. Staff Odor Training and System Maintenance Trad ecraft Farms incorporates and maintains adequate odor control measures such that the odors of cannabis cannot be detected from outside of the structure in which the business operates. We will regularly inspect and maintain its air filtration system to ensure that the odor mitigation system remains functional. We will also train staff in procedures and protocols for air quality and odor control, including procedures to implement when odors above baseline are detected, appropriate emergency response procedures for potentially harmful or noxious odors, best practices for minimizing the release of odors outside the cannabis retail business and for ensuring proper ventilation, and practices to ensure that the filtration system is on and functioning properly. The odor mitigation systems and plans will be updated regularly to maintain consistency with accepted and available industry specific technologies designed to effectively mitigate cannabis odors. 23 FMC § 9 -3309(j). CONFIDENTIAL AND PROPRIETARY 12 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan We will take all necessary precautions to ensure odors do not escape the premises. This includes intaking only pre-packaged cannabis and cannabis products. The combination of packaged products, and sophisticated filtration significantly reduces the possibility of any odors escaping the premises. The Company will train employees on how to detect, prevent, and remediate odor outside the cannabis retail business and all corrective options outlined herein. Should complaints about objectionable off -site odors be received, complaints will be recorded, and staff will be trained to take the following steps: (i) investigate the likely source of the odor; (ii) utilize on-site management practices to resolve the odor event; (iii) take steps to reduce the source of objectionable odors; (iv) determine if the odor traveled off -site by surveying the perimeter and making observations of existing wind patterns; and (v) document the event for further operational review. If staff is unable to take steps to reduce the odor-generating source, they are to immediately notify a Manager, who will find an appropriate resolution. If necessary, we will re-engage a licensed certified engineer or HVAC professional to review the issue and make recommendations for corrective action(s). 3.7. Waste Management Plan Our Company will destroy cannabis waste and by-products using a third -party waste hauler or by making arrangements with a licensed distributor to have cannabis products destroyed. Products will be eligible for destruction under the following circumstances: (i) if the cannabis products went unused; (ii) if internal quality control assessments determine that the cannabis products are unusable; (iii) if the cannabis products are subject to recall; or (iv) if the cannabis products have been. The Onsite Manager will log the following information into the waste management log before putting the prospective waste into the third-party waste hauler’s bin: ●Name and type of the cannabis goods; ●Unique identifier of the cannabis goods; ●Amount of the cannabis goods, by weight or count; ●The total wholesale cost of the cannabis goods, as applicable; ●The date the product was put into the waste bin; and ●Name and license number of the distributor involved in the activity or transaction. We w ill render cannabis or cannabis goods unrecognizable and unusable for all practical purposes. The rendering of cannabis products into cannabis waste shall be recorded by video surveillance cameras on site. Following the destruction of any cannabis products, an inventory record shall be generated from the third -party waste hauler with the following information: ●The reason the cannabis products were destroyed; ●The manner in which the cannabis and cannabis products were destroyed; ●The amount of cannabis products destroyed; ●The date and time upon which the cannabis products were destroyed; and ●Persons present during the destruction of the cannabis products. CONFIDENTIAL AND PROPRIETARY 13 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan Tradecraft Farms intends on using a full-service third -party waste hauler for the collection and disposal of cannabis waste. All authorized Tradecraft Farms employees will be trained in the waste management procedures. We will ensure that employees destroy cannabis products on-site to prepare them for collection and disposal by our contracted waste hauler, pursuant to the following operational procedures: ●Our Managers, along with at least one other staff member authorized to handle cannabis products acting as witnesses, will be present prior to the destruction of any cannabis products. ●Before the actual destruction of any cannabis products, the General Manager and other authorized personnel shall photographically depict the cannabis products as originally packaged. ●After photographing the cannabis products as originally packaged, the assigned personnel will transform the cannabis products into a cannabis waste by rendering the cannabis products unrecognizable and unusable for all practical purposes. ●The rendering of cannabis and cannabis products into cannabis waste will be recorded on the video surveillance system. ●Our contracted waste management vendor will provide a secure lockable storage bin for all waste earmarked for destruction. The bin is designed to ensure that, with proper use, no enclosed cannabis waste will cross contaminate cannabis products available for retail sale. ●The cannabis waste bin will be located and kept in a secure limited -access storage area that can only be accessed by authorized personnel using a electronic keycard (or code on a keypad), and a high-resolution video camera will be positioned to record a clear view of the cannabis waste storage bin so that any potential tampering is monitored and recorded. ●Upon commencement of operations, Tradecraft Farms will assess its waste hauling needs and establish a cannabis waste pick-up schedule that accommodates the volume of cannabis waste it regularly produces. We expect to produce minimal cannabis waste and anticipate arranging for pick-ups by an authorized third-party waste hauler as needed. CONCLUSION As d emonstrated in this Neighborhood Compatibility Plan, Tradecraft Farms is committed to ensuring the only impact we have on our surroundings is positive. We are concerned with ensuring that we maintain a safe, clean, odor-free premise that is welcoming to patients and customers. To ensure our compatibility, we will make sure that management personnel are easily accessible to our neighbors (either in-person or via telephone), and that community concerns are addressed timely and tactfully. We will provide a 24-hour contact to ensure that complaints or CONFIDENTIAL AND PROPRIETARY 14 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan concerns are addressed timely. We look forward to becoming a part of the Fresno community and are grateful for the opportunity to demonstrate our compatibility. CONFIDENTIAL AND PROPRIETARY 15 Tradecraft Farms Fresno - Fulton, LLC Neighborhood Compatibility Plan Exhibit A Odor Detection Form CONFIDENTIAL AND PROPRIETARY Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 1 of 21 SECTION 4: SAFETY PLAN TRADECRAFT FARMS FRESNO - FULTON, LLC 915 NORTH FULTON STREET FRESNO, CA 93728 PREPARED BY REAX E NGINEERING DECEMBER 1, 2020 Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 2 of 21 Table of Contents 1 Project Overview ............................................................................................................................ 2 2 Consultant Qualifications ................................................................................................................ 2 3 Accident and Incident Reporting ..................................................................................................... 4 4 Evacuation Routes .......................................................................................................................... 8 5 Fire Extinguishers and Fire Suppression Equipment ....................................................................... 9 6 Procedures and Training for Emergencies ..................................................................................... 11 7 General Building Fire and Life Safety Summary ........................................................................... 13 8 Future Modifications..................................................................................................................... 17 9 Conclusion.................................................................................................................................... 17 Appendix A: Evacuation Diagram ........................................................................................................ 19 Appendix B: Premises Safety Diagram ................................................................................................. 20 Appendix C: City of Fresno Commercial Cannabis Application Evaluation Criteria ............................. 21 1 Project Overview The project includes a tenant improvement (TI) to an existing building to develop a retail cannabis dispensary facility for Tradecraft Farms Fresno – Fulton, LLC (the “Company”) located at 915 North Fulton Street in Fresno, CA. The proposed tenant space is approximately 2,831ft². The building was constructed in 1965. This written plan considers all credibly possible fire scenarios which are mitigated by shortened egress travel distances. No reportable amounts of hazardous material will be located on site per CFC Section 407. No inhalation issues/threats are typically associated with mercantile operations. No testing or other processes are performed on site that require any hazardous gases, pesticides, or chemicals, other than common cleaning and housekeeping supplies found in most retail establishments. The plan will review the overall building fire and life safety features as well as emergency responder access to the facility. 2 Consultant Qualifications Reax Engineering has extensive experience in cannabis growing, manufacturing, and distributing in California, Nevada, and Oregon. Ronnie Thomas, FPE (Fire Protection) has been involved in both the development and peer review of various cannabis-related occupancies. He has presented on the fire and life safety aspects of the cannabis industry to the Society of Fire Protection Engineers Annual Conference, as well as to other regional and local entities. Ronnie is active both as a design engineer and 3rd party reviewer for private clients and municipalities with cannabis projects. He earned his M.S. in Fire Protection Engineering from Worcester Polytechnic Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 3 of 21 Institute and is a licensed Fire Protection Engineer in California (FP 1985) and Nevada (PE 25226). See Appendix C: Application Evaluation Criteria, Item 4.1 Figure 1: Project location Figure 2: Project site location Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 4 of 21 2.1 Applicable Codes, Standards and References This review is based upon the requirements of the following codes and standards: • 2019 California Building Code (CBC) • 2019 California Electrical Code (CEC) • 2019 California Mechanical Code (CMC) • 2019 California Fire Code (CFC) • City of Fresno Application Procedures & Guidelines for a Commercial Cannabis Business Permit dated October 19, 2020 • Fresno Municipal Code, Section 9-3310, Operating Requirements for a Cannabis Retail Business • Fresno Municipal Code, Chapter 10, Article 5, Fire Prevention 3 Accident and Incident Reporting1 The Company’s accident and incident reporting policy is designed to outline the purpose and procedure for reporting any accidents concerning personnel or customers at the facility. The Company is committed to enforcing all health and safety guidelines to avoid such occurrences and expects employees to comply. However, accidents are sometimes inevitable. The Company provisions in this case are to ensure all accidents are reported timely so they may be investigated, and so preventative measures can be reviewed and reinforced as applicable. This accident report policy affects all employees, customers, independent contractors, or other entities on the premises. On-the-job accidents that must be reported include any incidents that may cause minor or severe injuries or accidents. Accidents must be reported as soon as possible to provide immediate care. The sooner the cause or details of the accident are identified, the sooner the Company can establish preventative measures for the future. In accordance with the requirements of Cal OSHA 29 CFR 1910.35, 1910.36, and 1910.37, the following guidelines have been established to inform and train employees about emergency escape procedures, fire detection, fire prevention, protection and suppression activities, personnel accountability, medical and rescue responsibilities, and responses to other hazardous situations. Employees are expected to know how to initially respond to an emergency situation. Appropriate responses may be as simple as evacuating the area, summoning additional assistance, mitigating the hazard, or assisting a co-worker or customer in cases of accident, fire, illness, or injury. 1 Section corresponds to City of Fresno’s Commercial Cannabis Business Permit Application Evaluation Criteria Item 4.2. See Appendix C: Application Evaluation Criteria, Item 4.2, for reference. Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 5 of 21 The Emergency Action Plan will be made available to all employees upon request. A copy of the plan will be kept on premises at all times. 3.1 Reportable Incidents The Company encourages employees to report all accidents no matter how minor. Accidents that involve very minor injuries like small cuts, non-extensive bruises etc., that would not normally require any action on behalf of the company do not have to be reported, although employees can report them if they want with no repercussions. Accidents that involve (or could have involved) more severe injuries which require further investigation and action from the Company must be fully reported. Employees are obliged to report any of the following: • fatalities • damage to the head, skull, and face • damage to any of the senses (e.g. partial or complete loss of hearing, sight etc.) • incapacitation or dislocation of limbs that hinder functionality and movement (including paralysis and amputation) • damage to the skin (e.g. extensive burns, bruises, or cuts) • blows or injuries to the spine, back and ribs • harm to the nervous system or loss of consciousness through electrocution, hypothermia etc. • poisoning • contamination from hazardous substances or transmission of diseases • any other injury that requires hospitalization or medical care The accident must be reported immediately since insurance benefits may have to be approved after the investigation, particularly when the accident victim requires medical coverage. Employees are also required to report occurrences that may not have involved injuries or victims but could be potentially dangerous in that respect if repeated. These include but are not limited to: • slippery surfaces • water or gas leaks • breaking of window glasses or frames 3.2 Calling for Help Employees will be trained to call for help if a person: • is unconscious or unresponsive • has trouble breathing or is breathing in a strange way • has chest pain or pressure • is bleeding severely Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 6 of 21 • has pain or pressure in the abdomen that does not go away • is vomiting or passing blood • is having or has had a seizure • has a severe headache, slurred speech, tingling fingers, and/or dizziness • has ingested poison or suspected poison • is having an alcohol or drug related abuse or reaction • has injuries to the head, neck, or back • has injuries involving suspected broken bones, sprains, or dislocations • has experienced an electrical shock Employees will be trained to call the Police if the following is witnessed: • fire or explosion • downed electrical wire • significant flooding • hazardous material incident • suspicious odor of gas • motor vehicle accident • rescue activity The Emergency Action Plan shall be reviewed annually and will be changed sooner if any Facilities employee identifies problems. Concerns or corrective measures shall be referred to the Office of Environmental Health & Safety or to a representative of the Environmental Health & Safety Committee. 3.3 Fire Reporting Procedures The following procedures shall be followed when someone discovers a fire in the building, regardless of how large the fire is: 1. Close the door to the room where the fire is located. This will confine the fire to a smaller area. 2. Activate the closest fire alarm system. Pull stations are usually located next to an exit or stairwell door 3. Phone 911 to report the location of the fire. You or someone you designate must make the telephone call from a safe location as quickly as possible. Once you have given the dispatcher the information, wait until the dispatcher hangs up before you hang up because the dispatcher may need more information. 4. Extinguish or Evacuate If the fire is small and you have been trained to use the fire extinguisher, personnel may attempt to put the fire out pursuant to the Use of Fire Extinguishers protocols. If employees have not been Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 7 of 21 trained to use the fire extinguisher or if fire is too large to extinguish, they should evacuate the building and: 1. Go to the closest exit and proceed directly to your assigned area away from the building. The front of the building is the pre-designated area to meet for accountability reasons. 2. Notify others on your way out that this is a real fire but do not stop to force their evacuation. 3. Wait to be accounted for and stay in the area so that the fire department or police can ask questions about the building or fire. 4. If you have knowledge of the fire, such as location, size or cause, or if you are aware of a person trapped, immediately notify the first responders. Do not re-enter the building, until: 1. The fire alarm has been silenced, and 2. The fire or police department has indicated that it is acceptable to re-enter. 3.4 Accident Reporting Procedures When an employee witnesses or is involved in an incident they must report it to their immediate supervisor, HR department (personally, or by writing or by phone if the accident occurred remotely) or through an online system if applicable, within one week. If the employee anticipates an accident due to perceived negligence or inadequate safety, they must notify their supervisors or HR department as soon as possible so the accident can be prevented. Depending on the incident, official forms may have to be completed and submitted. The accident and any sustained injuries will be recorded to an accident database or file. The management will perform an internal investigation and/or request an investigation from authorities as appropriate. As a general rule, the employee or witness should provide the following information as accurately as possible: • The place of the accident • The date and time of the accident • The people involved or injured • Their position or involvement in the accident • Their actions immediately after the accident 3.5 Rescue and First Aid Procedures The facility will call for the necessary rescue and first aid services through Fresno Fire or Police Department, as appropriate, as well as through properly trained employees. To provide the best possible rescue and first aid services, the following policy is adopted for employees and or customers if a person has become ill or injured and needs assistance: Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 9 of 21 also to the exit access (corridors or intervening rooms that lead to the exit) and the exit discharge (the area past the exit doors which may include exterior ramps, steps, fire escapes and sidewalks.) Exit access and discharge will be maintained and unobstructed. Exits provide a safe and easily identifiable route out of a building in cases of emergency and allow swift and unhampered ingress for firefighters or other emergency personnel in the event of a fire or rescue. The facility’s designated exits meet the following criteria: • All illuminated “EXIT” signs are to be maintained. • All emergency lights powered by battery or emergency generator must be maintained. Accessible emergency lights will be tested weekly. • Exit doors will not be chained or locked from the inside except in those cases where the facility is being renovated or otherwise labeled to prevent initial entry. Employees will evacuate the facility along with any customers present through the closest available exit. Once outside of the building, they should proceed to the front of the building so that their supervisor can locate them. When notified of the emergency, the supervisor or designee shall immediately report to the front of the affected building to ensure that staff has evacuated safely. The supervisor should report his/her findings to responding Fresno Fire or Police Department personnel as soon as possible for accountability reasons. After employees evacuate the building and move to their assigned location in front of the building, they will remain there until they speak with their supervisors. They will not reenter the building until the fire alarm or other audible warning has been silenced and the Fresno Fire or Police Department has granted permission. See Appendix C: Application Evaluation Criteria, Item 4.3 5 Fire Extinguishers and Fire Suppression Equipment2 Portable fire extinguishers are required by CBC 906.1 and NFPA 10 to provide occupants a means to suppress a fire in the incipient phase. Proper selection and distribution of portable fire extinguishers are essential to having adequate protection for the building structure and the occupancy conditions within. Determination of the desired type of portable fire extinguisher depends on the character of the fire anticipated, building occupancy, specific hazards, and ambient temperature. Sizing of fire extinguishers is to be in accordance with Sections 906.3.1 through 906.3.4 for the appropriate hazard. Extinguishers are to be located in conspicuous, readily accessible locations 2 Correlates to Item 4.4. of Appendix C: Application Evaluation Criteria. See Appendix C for reference. Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 11 of 21 • Never turn your back towards the fire, even if you think it is out. 5.2 Fire Protection Systems The tenant space is not provided with a fire sprinkler system, which is permitted based on CFC Section 903. Group M occupancies do not require fire sprinklers when the total area is less than 12,000ft² or if the building is not more than 3 stories in height. See Appendix C: Application Evaluation Criteria, Item 4.4 6 Procedures and Training for Emergencies In accordance with the requirements of Cal OSHA 29 CFR 1910.35, 1910.36, and 1910.37, the following guidelines have been established to inform and train employees about emergency escape procedures, fire detection, fire prevention, protection and suppression activities, personnel accountability, medical and rescue responsibilities, and responses to other hazardous situations. Employees are expected to know how to initially respond to an emergency situation. Appropriate responses may be as simple as evacuating the area, summoning additional assistance, mitigating the hazard, or assisting a co-worker or customer in cases of accident, fire, illness, or injury. The Emergency Action Plan will be made available to all employees upon request. A copy of the plan will be kept on premises at all times. The Company’s top priority when training its employees will be for them to understand the rules and regulations that govern the dispensary in order to run a safe workplace. The Company will ensure that the initial employee training will be at least two hours long and includes Health and Safety Standards, Working with Local Law Enforcement, Medical Emergencies, and Being A Good Witness/Report Writing modules as part of this training. Employees will be tested on training content and must pass a comprehensive test by their third attempt to remain employed. All staff will also go through periodic refresher seminars, as well as new training on any policy updates or changes in procedure. All emergency procedures will be rehearsed in periodic drills. In addition to training and periodic drills, all employees will receive official Company reference material, written in plain English and presented in an easy-to-use outline format, explaining all operational, safety, and security policies and protocols. The Company believes that the more informed employees are, the better they can perform in emergency situations. To ensure all employees are properly trained, the Company utilizes the following approaches to employee training: (i) New hire training; (ii) hands-on training; and (iii) employee-to-employee training. Employees will be tested on this additional training content and must pass the test by their third attempt to remain employed. All employees will go through Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 12 of 21 annual refresher training, as well as new training on any policy updates or changes in procedure as they arise. The Company follows up new hire training by working one-on-one with new employees to review training materials with them. Regardless whether training is about cannabis products or emergency procedures, the Company believes it is important to follow up and test staff’s knowledge. Staff is expected to be able to articulate knowledge both verbally and by actions. This ongoing training with staff ensures employee retention and the ability to perform their duties under more stressful situations. Management will ask employees a series of increasingly complicated questions. The Company will work to do their best to ensure staff can be successful when being quizzed. The goal will not be to stump or frustrate the employees, but to work on building their confidence in being knowledgeable in all policies and procedures. Management will perform role-playing with employees. Although it can sometimes be an awkward training method at first, it is also very effective in rehearsing various emergency situations. Role-playing allows the Company to see if employees can effectively articulate information and allows them to demonstrate how employees handle themselves in various operational scenarios. Management will not focus on delivery/mimicry as is common with forced scenarios, but rather focus on employees’ knowledge and understanding of the training materials and decision-making in the role-playing scenarios. Employee-to-employee training is a great way for employees to learn information in a non- threatening way and this form of training is the ideal way for employees to learn from one another. The Company will utilize team-building exercises that allow everyone in the dispensary to come together without the pressures of daily routines. Management will also be responsible for assigning sales associates for training on any area where an employee requires additional training. All employees will be trained in safe evacuation and notification procedures in cases of actual or drill emergencies upon hiring and annually thereafter. Emergencies which may occur include, but are not limited to, a bomb threat, earthquake, explosion, fire, flood, gas leak, hazardous material incident, or personal injury accident. The training will address escape routes, notification of appropriate response agencies, instructions on activating a building fire alarm system, how and when to use a fire extinguisher, and what should be done after evacuating a building. At the appropriate times, but at least annually, a fire drill will be carried out. The fire drills are conducted to familiarize the staff and occupants with the sound of the fire alarm and to initiate the appropriate, desired response. See Appendix C: Application Evaluation Criteria, Item 4.5 Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 14 of 21 The maximum egress travel distance from any portion of the facility to an exterior door is approximately 71ft. This is less than the maximum of 250ft for Group M occupancies 7.3.2 Intervening Rooms Occupants are generally permitted to egress through an intervening room or space if the intervening space is not of a greater hazard, if the spaces are accessory to one another, and if the intervening space provides a discernable path to an exit based on CBC 1016.2. Exit access cannot be through a room that can be locked to prevent egress. 7.3.3 Exit Signage Exit signage and illumination will be provided in accordance with CBC Section 1013. Exit sign placement will be readily visible from any direction of egress travel. The egress path will be marked by readily visible exit signs to clearly indicate the direction of egress travel in cases where the exit or path of exit travel is not immediately discernable. Intervening means of egress doors will also be marked by exit signs. Internally illuminated exit signs will be listed and labeled in accordance with UL 924 and be illuminated at all times. Rooms that require only a single exit do not require exit signage. 7.3.4 Doors and Security The CBC requires minimum 32in and maximum 48in doors for egress purposes. The facility provides 34 in swinging doors for circulation. Electrified locking hardware is typically required for security and after-hours operations while staff is present. Locking egress doors from the inside is permitted based on CBC Section 1010.1.9.4 Item 2 for Group M occupancies. The electrified locking hardware will consist of either: • Electronic Strike (Installed in the Door Frame), or • Electrified Lever Set and Transfer Hinge (typically installed with pre-cored wood door or wired through a hollow metal man door. Electrified panic hardware will be provided on these doors in case of emergency in accordance with CBC Section 1010.1.10. Security grilles are permitted in accordance with CBC Section 1010.1.4.5 . Horizontal or horizontal sliding or vertical security grilles are permitted at the main exit and are required to be openable from the inside without the use of a key or special knowledge or effort during periods that the space is occupied. The grilles are to remain secured in the full-open position during the period of occupancy by the general public. Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 15 of 21 7.4 Fire Detection and Notification A smoke detection and notification system will be installed in accordance with CBC Section 907, NFPA. Manual pull stations will be provided at the exits and respond to a constantly monitored location. Duct detection will be installed in any systems providing over 2,000cfm or where required by the CMC. A keypad annunciator will be provided in a constantly attended location while the facility is open. A smoke detector will be provided by the fire alarm panel. Staff will be trained to escort customers to the nearest exit in case of emergency. The fire alarm will be monitored by Barton Integration. The point of contact is Kelley Poole, who may be reached at (949)-701-3447 or KelleyM@BartonIntegration.com. 7.5 Fire Resistive Interior Furnishings Precautions will be made to minimize the amount of combustible material located in each space. Interior wall and ceiling finishes will be in accordance with CFC Table 803.3. Rooms and enclosed spaces will have an interior wall and ceiling finish rating of not less than Class C. This classification requires a flame spread index (FSI) of not more than 200 and a smoke developed index (SDI) of not more than 450. Curtains, draperies, fabric hangings and similar combustible decorative materials suspended from walls or ceilings will be flame resistant in accordance with Section 806.4 and will not exceed 10 percent of the specific wall or ceiling area to which such materials are attached. 7.6 Knox Box Access Approval by Fresno Fire Department is required prior to moving or installing a Knox Box. The project team will coordinate with the Fresno Fire Department at (559) 621-4181 for ordering and installation. The location of the Knox Box will be in a conspicuous location near the front door/main entrance to the facility. 7.7 Fire Apparatus Site Access The nearest fire station is Fresno Fire Station 9 which is located approximately 2.1 miles away at 2340 North Vagedes Avenue, Fresno CA 93705. Access to the exterior walls of the tenant space are located within 150ft of fire lanes, which is considered the road adjacent to the site, in accordance with CFC Section 503.1.1. There are no gates or other restrictions to fire apparatus access on the property. A fire hydrant for fire department suppression activities is located approximately 200ft away at the corner of East Elizabeth and North Fulton Streets. 7.8 Premises General Safety Measures The facility has a number of standard operating procedures that aid in the overall fire safety plan, including: Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 16 of 21 • No use of open flames or smoking on or surrounding the premises. • Employees to conduct emergency evacuation drills at least annually. • Store materials in an orderly fashion, separated from heaters or heating devices by distance or shielding so that ignition cannot occur (CFC Section 315). • Reporting of emergencies, coordination with emergency response forces, emergency plans and procedures for managing or responding to emergencies will comply with the provisions of CFC Section 401. • Emergency evacuation drills will be conducted at least annually in accordance with CFC Section 405. • Hazard communication information will be prepared in accordance with CFC Section 407 to include Safety Data Sheets (“SDS”) for all hazardous materials and cleaning products located on site. • Clearly mark or otherwise identify individual containers in accordance with applicable federal regulations. No reportable amounts of hazardous material will be located on site per CFC Section 407. The amounts of hazardous material on site is limited to over the counter cleaning materials such as Green Cleaner, Windex, Lysol toilet bowl cleaner, Pine Sol, disinfecting sprays and wipes, Febreze, Swiffer Wet Jets, and hand sanitizers. The amounts stored will not exceed maximum allowable quantities in CFC Section 5001.5. However, the facility will still comply with CFC 407 with regards to labeling and identification, providing paper copies of SDS, and training employees with respect to first aid and accident reporting procedures. No inhalation issues/threats are typically associated with mercantile operations. No testing or other processes are performed on site that require any hazardous gases, pesticides, or chemicals. 7.9 Fire Prevention Plan It is the responsibility of each employee to correct or report unsafe conditions that could cause a fire, hamper emergency egress, or result in a personal injury accident. Therefore, it is the responsibility of each employee to: • Correct certain hazards at the time of discovery, such as replacing bulbs in exit signs and removing cardboard, paper, and other combustible material from exit paths. Report discharge or missing extinguishers and burned out emergency lights to the supervisor. • Notify the supervisor of hazards needing corrective action, such as hazardous materials left in the corridors, potential ignition sources, open (uncovered) electrical panels. • Contact the supervisor for corrective action, such as hazardous materials left in the corridors, potential ignition sources, open (uncovered) electrical panels, missing fire extinguishers, or burned out emergency lights. Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 17 of 21 7.10 Electrical Fire Safety Electrical wiring and devices will comply with the CEC requirements. The use of extension cords as a substitute for permanent electrical wiring is not permitted, and a C-10 licensed electrician will be enlisted, as required, for any modifications or repairs to the electrical system. The following general guidelines will be implemented for fire prevention measures: • Do not allow combustible material like cardboard, cloth, paper, and wood to be placed next to an ignition source such as a heater, furnace, pilot light, or electrical equipment. • No stored materials are permitted within 3 feet of an electric panel or similar type of equipment. • Electrical cords and outlets must not be overloaded or used improperly. • Electrical cords must be properly sized for the equipment they serve. • Never use a smaller diameter extension cord than the primary cord that serves the equipment. • Do not overload an outlet with several plugs at the same time. It is suggested that a small 5 or 6 outlet strip with its own circuit breaker be used. • Electrical cords must not pass through ceilings, doors, or walls except for custodial or shop activities where the door is held open for a limited time while the cleaning or other activity is being done and while the employee is on the floor of work activity 8 Future Modifications All future modifications and expansions with regards to the contents of this report are to be documented in amendments/addenda to this report or the permanent building plans. As required, the documents will be prepared by a design professional licensed by the State of California working within the area of their expertise. As appropriate, licensed design professionals will be included in the design of all building renovations/expansions. 9 Conclusion The preceding information summarizes a compliant fire/life safety code analysis for the Tradecraft Farms Fresno – Fulton, LLC facility. Combined with sufficient employee training, safe practices and good housekeeping, it is my professional opinion that the facility meets or exceeds code requirements for a storefront retail cannabis dispensary facility. If you have any questions or concerns, please contact me at (530) 448-2334 or thomas@reaxengineering.com. Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 18 of 21 Prepared by: James R (Ronnie) Thomas, II CA FPE License # 1985 Reax Engineering Fire Prevention and Suppression Plan December 1, 2020 Tradecraft Farms Fresno - Fulton, LLC Page 21 of 21 Appendix C: City of Fresno Commercial Cannabis Business Permit Application Evaluation Criteria Evaluation Criteria: 4. SAFETY PLAN Criteria required in Phases II and III The Safety Plan should consider all possible fire, medical and hazardous situations. Complete policy/procedures manuals are not required at this point in the application process. Please only provide a description for each criterion which incorporates the following provisions: 4.1. The Safety Plan shall be prepared and/or assessed by a professional fire prevention and suppression consultant. 4.2. Describe accident and incident reporting procedures. 4.3. Describe evacuation routes. 4.4. Location of fire extinguishers and other fire suppression equipment. 4.5. Describe procedures and training for all fire and medical emergencies. Exhibit A CONFIDENTIAL AND PROPRIETARY Exhibit B CONFIDENTIAL AND PROPRIETARY Wilma Quan, City Manager Jennifer Ruiz, Project Manager City of Fresno Office of Cannabis Oversight 2600 Fresno St. Room 2064 Fresno, CA 93 721 Dear Ms. Quan and Ms. Ruiz: December 1, 2020 Morgan Doizaki Central Fish Company 1535 Kern St. Fresno, CA 93706 I am writing in support of Tradecraft Farms' application for a commercial cannabis retail license in Fresno. As a local Chinatown business owner of Central Fish Company, a Fresno resident, and a Fresno community advocate involved with the Chinatovvn Fresno Foundation and Transform Fresno initiatives, I believe Tradecraft Farms is the right applicant to help establish a lucrative and safe cannabis industry in our city. Their business has shown a deep understanding and respect for the culture and history of the City of Fresno, dedication to increasing security and economic opportunity in their neighborhood, and devotion to investing in local causes. I am a member of the Board of Directors of the Chinatown Fresno Foundation and a member of the Fresno Transformative Climate Communities Collaborative ("Tran�form Fresno") Outreach and Oversight Committee and Transform Fresno Anti-Displacement Task Force, all of which work to, amongst other things, preserve Fresno's history, culture, and existing communities while promoting revitalization and growth in the city. Part of its potential for growth lies in Fresno's decision to allow the cannabis industry to enter our community. Tradecraft Farms has committed itself to preserving the historical integrity of its building and neighborhood while bringing them new life by supporting the local community and increasing economic opportunities for surrounding businesses. I believe in Tradecraft Farms' understanding and care for the culture of its neighborhood and I support its commitment to doing its part to preserve it while helping to introriuce a new industry to our community. Tradecraft Farms' presence in the community will contribute to the success of surrounding businesses by increasing traffic, promoting the visibility of the area, and increasing safety in the neighborhood. The nature of a cannabis retail business requires enhanced safety measures such as extensive exterior lighting and 24-hour security monitoring of the premises. These features will improve security for both Tradecraft Farms' business and the neighborhood smTounding it. All local business owners and residents will benefit from increased safety in the area as well as increased foot traffic, bringing new life and new economic opportunity to the community. Tradecraft Farms displayed its supp01t of local organizations long before submitting its application for a cannabis retail business license. It has pledged support to several local groups CONFIDENTIAL AND PROPRIETARY Wilma Quan, City Manager Jennifer Ruiz, Project Manager December 1, 2020 Page2 and initiatives, including an organization I'm affiliated with, the Chinatown Fresno Foundation. Tradecraft Farms has proven itself to be an active suppo11er of our local community. I am confident that granting Tradecraft Farms a license to operate in Fresno wou1a. be beneficia1 to tbe community and would help to reinvigorate the City's economy. I am happy to offer my support of Tradecraft Farms' application for a cannabis retail business license. Regards, o(o/+ Morgan Doizaki Owner, Central Fish Company Member, Transform Fresno Oversight and Outreach Committee Member, Transform Fresno Anti Displacement Task Force Member of the Board of Directors, Chinatown Fresno Foundation CONFIDENTIAL AND PROPRIETARY Exhibit C CONFIDENTIAL AND PROPRIETARY CONFIDENTIAL AND PROPRIETARY CONFIDENTIAL AND PROPRIETARY Exhibit D CONFIDENTIAL AND PROPRIETARY CONFIDENTIAL AND PROPRIETARY Exhibit E CONFIDENTIAL AND PROPRIETARY 11/30/2020 At Thanksgiving, Americans reach out to those in need | ShareAmerica https://share.america.gov/at-thanksgiving-americans-reach-out-to-those-in-need/2/2 ‘Happy chaos,’ but safety rst Gobble Gobble Give, launched in 1998, provides food and personal care items to the homeless each Thanksgiving. Paul Major, the group’s secretary, said the pandemic “has forced us to look closely at how we run our events.” The organization describes itself as “happy chaos, or a potluck party with a purpose.” It doesn’t host sit-down meal services, as soup kitchens or shelters typically do. So “maintaining social distance is much easier to manage,” Major said. Volunteers show up with donations of food, clothing and personal hygiene items to sort, pack and deliver to homeless communities. To reduce the risk of virus transmission, Gobble Gobble Give has capped the maximum on- site attendance at all locations, Major said. But the group is also attracting new partners. In Los Angeles, for instance, it will coordinate with the Hollywood Food Coalition, a charity that works with local churches and serves 200–250 meals each evening. Sherry Bonanno, the executive director of the Hollywood Food Coalition, said that her group is pleased to partner with a large community group whose volunteers “bring a lot of joy and fun” to events. The groups anticipate a long-term partnership, one that “exemplifies the United States’ volunteer spirit.” While Gobble Gobble Give exists to help the needy, the organization’s “secret,” Major said, is that it also transforms the lives of its volunteers “as it did mine.” Major first volunteered in 2008 and has participated every year since then. ShareAmerica is the U.S. Department of State's site for engaging foreign audiences on important global issues. Follow us on Facebook at facebook.com/ShareAmerica and on Twitter at twitter.com/shareamerica. SHARE  “I’ve seen and experienced rsthand what it means to put oneself in front of a stranger in need and oer a helping hand. The rewards of that kind of an experience are, in a word, immeasurable.”  — Paul Major CONFIDENTIAL AND PROPRIETARY Gobble Gobble Give Celebrates 21 Years Continuing to Expand Nationwide Feeding Thousands on Thanksgiving Morning in New York CLICK HERE TO VIEW GOBBLE GOBBLE GIVE NYC CHAPTER CLICK HERE FOR DOWNLOADABLE LINK FOR GOBBLE GOBBLE GIVE NYC CHAPTER Gobble Gobble Give - NYC Thursday, November 28th @ 8:00am - 12:30pm Church of the Intercession - 550 W. 155th, New York, NY 10032 Volunteers positions are filled however they are still in need of more food for drop off or donations which can be made by clicking the below link. Register here​: ​ ​www.gggnyc.org FACEBOOK​ / ​EMAIL​ / ​VOLUNTEER CONFIDENTIAL AND PROPRIETARY Los Angeles, CA (November 2019) - For over 20 years,​Gobble Gobble Give ​has delivered food, clothing and toiletries to the homeless across the country on Thanksgiving morning. Dedicated volunteers ​Rachel Terry ​and Tommy Cheng ​host the ​Gobble Gobble Give NYC Chapter at the Church of the Intercession in Harlem helping to gather the local community on Thanksgiving Day to feed those in their city. Interested volunteers can register beforehand at ​www.gggnyc.org for 45 minute shifts to serve food and deliver to local shelters in multiple locations around the city which will be assigned ahead of time. This is also a 100% green event, everything used is recycled and volunteers are asked to bring recyclable containers for all donations. Founded by accomplished entrepreneur and philanthropist Barry Walker,​Gobble Gobble Give is an initiative committed to effecting positive change in local communities throughout the United States. The ‘potluck for a purpose’ platform was initially created by Barry and a group of friends who started making an extra dish during their own Thanksgiving prep or grabbing an extra item when shopping to then give to a person in a need on the holidays. The organization has now grown to amazing heights delivering 27,000 meals last year alone and has engaged over 10,000 volunteers across the nation. This thriving organization is a prime example of what a community can do when it comes together to create change as they have grown from ​Echo Park in Los Angeles to ​Santa Monica​,​Downtown LA​,​Santa Ana​,​San Francisco​, two locations in ​San Diego​,​Las Vegas​,​Austin​,​Nashville​,​New York City​,​and Detroit adding new cities this year ​Boston​, ​Kansas City​, ​Long Beach, CA​, ​Washington D.C​.​, and ​Sacramento, CA​. What started as a group of friends in Los Angeles getting together on Thanksgiving morning to feed the homeless in their neighborhood has now expanded to over 17 cities nationwide. Together, volunteers from across the country take traditional holiday food, some gently used clothes, shoes, and blankets, to the streets, giving back to the people who need it most.​Gobble Gobble Give also enlists local hairdressers and make-up artists to provide free grooming services. Additionally both ​Ralph’s and ​Amazon Smile give back to the initiative when participants use their code at check-out. There are several ways to get involved at Gobble Gobble Give. Please visit the ​website under ​Ways to Help for further information regarding ongoing volunteer opportunities. Interested participants can also ​Sign up for their newsletter or follow them @GobbleGobbleGive on ​Instagram​, ​Twitter​, and ​Facebook​. CLICK HERE TO VIEW THE GOBBLE GOBBLE GIVE STORY For Media Inquiries Contact: Evolutionary Media Group Jennifer Gross / Julia Axelrod / Heather Kohos 323.658.8700 Jennifer@emgpr.com​ / ​Julia@emgpr.com​ / ​Heather@emgpr.com CONFIDENTIAL AND PROPRIETARY Exhibit F CONFIDENTIAL AND PROPRIETARY DUB Brothers is partnering with Cliff’s Texas Style Burritos in Compton with their Feed the People Vegan Hot Dog Cart to offer Free Lunches to the community. Feed The People Friday May 29, 2020 @ 12:00pm – 2:00pm Cliff’s Texas Style Burritos 408 W Alondra Blvd., Los Angeles, CA 90220 “Feed The People” is a monthly initiative to provide food insecure communities with Free Lunch Friday’s helping children and families affected by the loss of lunch programs they would normally get at local public schools. Los Angeles, CA. (May 27, 2020) DUB Brothers, a Los Angeles based company, and founders of the twenty year old Gobble Gobble Give Thanksgiving Day program, has expanded their philanthropic initiative FEED THE PEOPLE to bring sustenance to those facing food insecurities in cities across the country, starting with the city of Compton, CA. The FEED THE PEOPLE activation will provide “Free Lunch Friday” events with local restaurant partners and different local vendors, providing meals for children and families affected by the loss of lunch programs through school closures. “We will always aim to have a positive impact on the community around us and have witnessed first- hand the hardships and chronic adversity that has affected so many families and children during this time. The sudden loss of these school lunches that most children depend on, hit home with us and with amazing local partners like Cliff’s we hope to bring relief and a couple smiles to these families where we can.” – Barry Walker, co-founder Dub Brothers The first event will be in partnership with Cliff’s Texas Style Burritos (408 W Alondra Blvd. Compton, CA 90220) taking place on Friday, May 29, 2020 @ 12:00pm – 2:00pm; where patrons can enjoy the DUB Brothers’ world famous Vegan Chilli Cheese Dog cart along with Cliff’s tacos and side of their choice. Additionally DUB Brothers aims to support small businesses in the community by purchasing all food directly from vendors before each event. Cliff’s Texas Style Burritos has been a staple of the Compton community since 1992 and is a prime example of the hit small businesses have taken during this time. In this vein FEED THE PEOPLE aims to support the Compton community as a whole by compensating small businesses while giving back to local residents. Founded by brothers Brent Walker and Barry Walker, DUB Brothers, a cannabis company, has made philanthropy a pillar of the company with annual events Gobble Gobble Give which feeds the homeless in 24 cities nationwide. In 2010, Skid Row Xmas was launched to provide supplies to homeless encampments on Downtown LA’s Skid Row during the December holidays. Now, FEED THE PEOPLE is the company’s newest initiative that will encompass their already established events along with newer activations taking place which have been inspired by the public’s struggles during the current COVID-19 pandemic crisis that all are experiencing. ‘Cliffs’ which is owned by Cliff and Delores Williams started with a humble $1 Hot Dog Cart in the City of Compton, before moving into a brick and mortar near Compton’s Centennial High School serving authentic Mexican and American food. As one of the few African American Family Owned small businesses established and still serving in Los Angeles County and the City of Compton, since 1992, ‘Cliffs’ mission is to maintain our long time record of preparing excellent food with genuine care. For more information on FEED THE PEOPLE please visit: feedthepeople.la or follow @feedthepeoplela. For more information on DUB Brothers please visit: dubbros.com CONFIDENTIAL AND PROPRIETARY Exhibit G CONFIDENTIAL AND PROPRIETARY California Secretary of State Electronic Filing LLC Registration – Articles of Organization Entity Name: Entity (File) Number: File Date: Entity Type: Domestic LLC Jurisdiction: California Detailed Filing Information 1.Entity Name: 2.Business Addresses: a.Initial Street Address of Designated Office in California: b.Initial Mailing Address: .Agent for Service of Process: 4.Management Structure: 5.Purpose Statement:The purpose of the limited liability company is to engage in any lawful act or activity for which a limited liability company may be organized under the California Revised Uniform Limited Liability Company Act. Electronic Signature: The organizer affirms the information contained herein is true and correct. Organizer: Use bizfile.sos.ca.gov for online filings, searches, business records, and resources. Tradecraft Farms Fresno - Fulton, LLC 202028710533 10/09/2020 Tradecraft Farms Fresno - Fulton, LLC 721 E. 5th Street Los Angeles, California 90013 United States 721 E. 5th Street Los Angeles, California 90013 United States Paula D Brunelle 721 E. 5th Street Los Angeles California 90013 United States All LLC Member(s) Paula Brunelle LLC-12 Secretary of State Statement of Information (Limited Liability Company) IMPORTANT — Read instructions before completing this form. Filing Fee – $2.00 Copy Fees – First page $1.00; each attachment page $0.50; Certification Fee - $5.00 plus copy fees This Space For Office Use Only 1. Limited Liability Company Name (Enter the exact name of the LLC. If you registered in California using an alternate name, see instructions.) 2. 12-Digit Secretary of State File Number 3. State, Foreign Country or Place of Organization (only if formed outside of California) 4. Business Addresses a. Street Address of Principal Office - Do not list a P.O. Box City (no abbreviations) State Zip Code b. Mailing Address of LLC, if different than item 4a City (no abbreviations) State Zip Code CA _____________________ Date ____________________________________________________________ Type or Print Name of Person Completing the Form _________________________ Title __________________________________ Signature ªº ¬¼ c. Street Address of California Office, if Item 4a is not in California - Do not list a P.O. Box City (no abbreviations) State Zip Code If no managers have been appointed or elected, provide the name and address of each member. At least one name and address must be listed. If he manager/member is an individual, complete Items 5a and 5c (leave Item 5b blank). If the manager/member is an en ity, complete Items 5b and 5c (leave Item 5a blank). Note: The LLC cannot serve as its own manager or member. If the LLC has additional managers/members, enter the name(s) and addresses on Form LLC-12A (see instructions). 5. Manager(s) or Member(s) a. First Name, if an individual - Do not complete Item 5b Middle Name Last Name Suffix b. Entity Name - Do not complete Item 5a c. Address City (no abbreviations) State Zip Code 6. Service of Process (Must provide either Individual OR Corporation.) INDIVIDUAL – Complete Items 6a and 6b only. Must include agent’s full name and California street address. a. California Agent's First Name (if agent is not a corporation) Middle Name Last Name Suffix b. Street Address (if agent is not a corporation) - Do not enter a P.O. Box City (no abbreviations) State CA Zip Code CORPORATION – Complete Item 6c only. Only include the name of the registered agent Corporation. c. California Registered Corporate Agent’s Name (if agent is a corporation) – Do not complete Item 6a or 6b 7. Type of Business a. Describe the type of business or services of the Limited Liability Company 8. Chief Executive Officer, if elected or appointed a. First Name Middle Name Last Name Suffix b. Address City (no abbreviations) State Zip Code 9. The Information contained herein, including any attachments, is true and correct. Return Address (Optional) (For communication from the Secretary of State related to this document, or if purchasing a copy of the filed document enter the name of a person or company and the mailing address. This information will become public when filed. SEE INSTRUCTIONS BEFORE COMPLETING.) Name: Company: Address: City/State/Zip: LLC-12 (REV 01/2017) 2017 California Secretary of State www.sos.ca.gov/business/be 20-E78265 FILED In the office of the Secretary of State of the State of California NOV 27, 2020 TRADECRAFT FARMS FRESNO - FULTON, LLC 202028710533 CALIFORNIA 93728 CA 90013 93728 CA915 N. Fulton Street Fresno 721 E. 5th Street Los Angeles 915 N. Fulton Street Fresno DeJute LOS ANGELES 721 E. 5th Street Los Angeles 90013 David 10880 Wilshire Blvd., STE 1900 90024 CA WalkerBarry Walker Los Angeles Retail Barry 721 E. 5th Street CA 90013 11/27/2020 Paula Brunelle Authorized Representative Page 1 of 2 LLC-12A - Attachment (EST 07/2016) 2016 California Secretary of State www.sos.ca.gov/business/be Attachment to Statement of Information (Limited Liability Company) LLC-12A Attachment This Space For Office Use Only A. Limited Liability Company Name B. 12-Digit Secretary of State File Number C. State or Place of Organization (only if formed outside of California) D. List of Additional Manager(s) or Member(s) - If the manager/member is an individual, enter the individual’s name and address. If the manager/member i s an entity, enter t he entity’s name and address. Note: The LLC cannot serve as its own manager o r member. First Name Middle Name Last Name Suffix Entity Name Address City (no abbreviations) State Zip Code First Name Middle Name Last Name Suffix Entity Name Address City (no abbreviations) State Zip Code First Name Middle Name Last Name Suffix Entity Name Address City (no abbreviations) State Zip Code First Name Middle Name Last Name Suffix Entity Name Address City (no abbreviations) State Zip Code First Name Middle Name Last Name Suffix Entity Name Address City (no abbreviations) State Zip Code First Name Middle Name Last Name Suffix Entity Name Address City (no abbreviations) State Zip Code First Nam e Middle Name Last Name Suffix Entity Name Address City (no abbreviations) State Zip Code 20-E78265 TRADECRAFT FARMS FRESNO - FULTON, LLC 202028710533 CALIFORNIA Geoffrey Yeterian 721 E. 5TH STREET LOS ANGELES CA 90013 Thomas Andrew Gibb 721 E. 5TH STREET LOS ANGELES CA 90013 Gerald K Nickerson Page 2 of 2 CONFIDENTIAL OPERATING AGREEMENT OF TRADECRAFT FARMS FRESNO – FULTON, LLC A CALIFORNIA LIMITED LIABILITY COMPANY DECEMBER 1, 2020         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 2 / 22 OPERATING AGREEMENT This Operating Agreement (the “Agreement”) of TRADECRAFT FARMS FRESNO - FULTON, LLC, a California limited liability company (the “Company”), is entered into as of December 01, 2020 by and among the Company, each Person identified on Schedule A attached hereto (the “Managing Members Schedule”) as of the date hereof as a Member and who has executed this Agreement or a counterpart thereof and each other Person who, after the date hereof, becomes a Managing Member of the Company in accordance with the terms of this Agreement by executing and delivering a joinder agreement hereto to the Company (collectively, the “Managing Members”), pursuant to the California Revised Uniform Limited Liability Company Act as set forth in Corporations Code Title 2.6, Corporations Code § 17701.01 et seq. (”RULLCA”) and subject to the Articles of Organization filed September 13, 2017. ARTICLE 1. DEFINITION OF TERMS 1.01 When used in this Agreement, the following terms, as defined here and in Corporations Code § 17701.02, have the following meanings: (a) “Act” means the California Revised Uniform Limited Liability Company Act, as set forth in Corporations Code Title 2.6, Corporations Code § 17701.01 et seq. (b) “Agreement” means this operating Agreement, as originally executed and as amended or restated. (c) “Articles” means the Articles of Organization for the Company required by Corp. Code § 17702.01. The term includes the articles as amended or restated. (d) “Available cash” of the Company means all cash funds of the Company on hand from time to time (other than cash funds obtained as contributions to the capital of the Company by the Members and cash funds obtained from loans to the Company), after (1) payment of all operating expenses of the Company as of such time, (2) provision for payment of all outstanding and unpaid current obligations of the Company as of such time, and (3) provision for a working capital reserve, as defined below. (e) “Bankrupt” or “bankruptcy” means, with respect to any person, being the subject of any order for relief under Title 11 of the United States Code, or any successor statute. (f) “Capital account” means the individual accounts established and maintained pursuant to Article 3. (g) “Contribution” means the benefit provided by a person to the Company, as defined in Corporations Code § 17701.02(c). The Members’ contributions are shown in Schedule A, including the Schedule as amended. (h) “Code” means the Internal Revenue Code of 1986, as amended. All references in this Agreement to sections of the Code include any corresponding provision or provisions of succeeding law. (i) “Company” means the California Limited Liability Company defined in Article 2. (j) “Entity” means any association, corporation, general partnership, limited partnership, limited liability Company, joint stock association, joint venture, firm, trust, business trust, cooperative, and foreign association of like structure. (k) “Manager” means a person that under this Agreement is responsible, alone or in concert with others, for performing the management functions set forth in subdivision (c) of Corporations Code § 17704.07, and who has voting rights in the Company. From time to time in this Agreement, a Manager may be referred to as a “Managing-Member”, “Member with management rights in the Company” or “Member with voting rights in the Company.” (l) “Member” means a person that has become a Member of the Company under Corporations Code § 17704.01 and has not dissociated from the Company under Corporations Code § 17706.02. (m) “Member Interest” of a Member means the percentage of the Member set forth opposite the name of the Member in Schedule A attached to this Agreement, as the percentage may be adjusted from time to time pursuant to the terms of this Agreement. (n) “Principal office” means the principal executive office of the Company, whether or not located in         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 3 / 22 California. (o) “Pro Rata Part” means the proportion that a percentage interest of a Member bears to the aggregate interest in the Company of all Members. (p) “Share” refers to an interest in the Company representing a contribution to capital. Whenever reference is made to “percentage interest,” a share may be converted into the same by dividing a Member’s number of shares by the total of all shares outstanding. (q) “Tax Matters Member” means the Member chosen pursuant to Internal Revenue Code § 6231(a)(7) to deal with the Internal Revenue Service on tax matters. (r) “Transferable Interest” in the Company means the right, as originally associated with a person’s capacity as a Member, to receive distributions from the Company in accordance with this Agreement, whether or not the person remains a Member or continues to own any part of the right. (s) “Transferee” means a person to which all or part of a transferable interest has been transferred, whether or not the transferor is a Member. (t) “Vote” means an action taken by a Managing-Member with voting rights in the company pursuant to an action requiring a vote under this Agreement. (u) “Quorum” means a majority of outstanding interests in the Company present at any meeting pursuant to Article 7 of this Agreement. (v) "Intellectual Property" means patents, rights to apply for patents, trademarks, trade names, service marks, domain names, copyrights and all applications and registration of such worldwide, schematics, industrial models, inventions, know-how, trade secrets, computer software programs, and other intangible proprietary information. (w) “Confidential Information” means intellectual property, confidential information, financial, and/or other business information pertaining to a Member’s, or the Company’s, business, products, and plans which are not published or readily available to the public and which are clearly labeled as confidential or proprietary, including, but not limited to, trade secrets, genetics, manufacturing techniques, research and development, product descriptions and features, marketing concepts and plans, software and data, training, pricing, sales techniques, lists of Companies and vendors, and other information which is received from the agents or employees pertaining to the business conducted by a Member or by the Company. (x) “Trade Secret” shall have the meaning set forth in Article 8.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 4 / 22 ARTICLE 2. ORGANIZATION OF COMPANY 2.01 Formation of Company The Members have formed a Limited Liability Company under the Act by properly executing and filing Articles of Organization pursuant to Corporations Code § 17702.01. The rights, duties, and liabilities of the Members are determined pursuant to the Act, the Articles, and this Agreement. If, however, there are any inconsistencies between this Agreement and the Act with respect to the rights or obligations of any Members, this Agreement shall, to the extent permitted by the Act, prevail and control. 2.02 Company Name The name of the Company is TRADECRAFT FARMS FRESNO - FULTON, LLC. The Company will transact business under that name. However, the Company may conduct business under another name if the Managing-Members think it advisable, provided that the Managing-Members comply with the Act and any other applicable laws, file fictitious name certificates and the like, and file any necessary amendments. 2.03 Company Purpose The purpose of the Company is to engage in any lawful act or activity for which a Limited Liability Company may be organized under the California Revised Uniform Limited Liability Company Act. 2.04 Place of Business The principal office of the Company will be located at: 915 N. Fulton Street, Fresno, CA 93728 2.05 Agent for Service of Process The name and business address of the Company’s initial agent for service of process is Registered Agents, Inc. Upon a majority vote of Managing-Members, the Company may remove and replace the Company’s agent for service of process at any time. 2.06 Operative Date of Agreement The provisions of this Agreement shall take effect on the date of execution of this Agreement as specified above. ARTICLE 3. MEMBERS AND MEMBER INTERESTS 3.01 Members Names, Addresses, and Initial Capital Contributions of Members. The names and addresses of the Members, their respective Member Interests in the Company and their initial capital contributions to the Company, if any, and are set forth on Schedule A, attached to this Agreement and incorporated by this Reference. 3.02 Initial Capital Contributions Each Member agrees to make the initial contribution set out in Schedule A within 30 days from the date of execution of this Agreement. Schedule A shall be amended from time to time to reflect any changes or adjustments in the respective contributions or percentage interests of the Members as required or permitted under this Agreement. 3.03 Voting of Members. On any matter presented to the Members for their vote, each Member shall have the voting rights set forth in Schedule A.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 5 / 22 3.04 Capital Accounts. An individual capital account shall be established and maintained for each Member and has been or shall be credited with the amount of each Member’s initial capital contribution to the Company. Each Member’s capital account shall be determined and maintained throughout the term of the Company in accordance with the requirements of the Section 704(b) Internal Revenue Code of 1986, its counterpart in any subsequently enacted Internal Revenue Code, and the applicable Treasury Regulations thereunder. 3.05 Capital Calls. The Members recognize that the income produced by the Company may be insufficient to pay the cost of operating the Company. The term “cost of operating the Company” shall include, without limiting the generality of said term, all real estate taxes and assessments and other state and governmental charges, insurance premiums, costs of repair and maintenance, cost of improvements, and the principal and interest payments required to be made on any loans or mortgages of the Company. If, in the opinion of the Managing Members, additional funds are required to pay the cost of operating the Company, such additional funds shall be contributed by the Members in proportion to their ownership of Member Interest. 3.06 Failure to Make Contribution Pursuant to Corporations Code § 17704.03, if a Member is required to make a contribution in accordance with this Agreement and fails to make that contribution within 30 days from the date of execution of this Agreement, that Member shall be obligated, at the option of the Company, to contribute cash equal to the value of the part of the contribution that has not been made. (a) A Member’s obligation to make a contribution to the Company is not excused by the person’s death, disability, or other inability to perform personally. (b) The obligation of a Member to make a contribution to the Company may be compromised only by a unanimous vote of Managing-Members. A conditional obligation of a Member to make a contribution to the Company shall not be enforced unless the conditions of the obligation have been satisfied or waived as to or by that Member. Conditional obligations include contributions payable upon a discretionary call of the Company before the time the call occurs. 3.07 Future Contributions No Member may be required to make any capital contribution to the Company other than that required under Section 3.01, except upon a majority vote of the Managing-Members. (a) All additional contributions made in accordance with this section shall be made on a pro rata basis in accordance with the respective percentage interests of the Members of the Company, unless the Managing-Members unanimously agree to a different method of determining contributions. If additional contributions are made other than on a pro rata basis, the respective percentage interests of the Members in the Company shall be adjusted to reflect the total respective contributions of the Members, and Schedule A of this Agreement shall be amended accordingly. (b) Any advance of money to the Company by any Member in excess of the amounts provided for in this Agreement or subsequently agreed to, will be deemed a debt due from the Company rather than an increase in the capital contribution of the Member. This liability will not entitle the lending Member to any increased share of the profits nor to greater voting power. 3.08 Member Loans or Services Except as specified in Schedule A, services by any Member to the Company which form the basis of compensation paid by the company may not be considered as contributions to the capital of the Company, and loans by any Member to the Company shall not be treated as capital contributions to the Company. Any compensation that the Company pays to a Member for services, and any payment made by the Company to a Member on that Member’s loan to the Company, shall not be treated as payment made to that Member acting in his, her, or its capacity as a Member under Internal Revenue Code § 707.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 6 / 22 3.09 Capital and Capital Accounts The initial Capital Contribution of each Member is set forth in Schedule A. No interest may be paid on any Capital Contribution. (a) The Company will establish and maintain an individual Capital Account for each Member pursuant to the applicable Treasury Regulations [§ 1.704-1(b)(2)(iv)]. (b) No Member has the right to withdraw his or her capital contribution or to demand and receive property of the Company or any distribution in return for his or her Capital Contribution, except as may be specifically provided in this Agreement or required by law. (c) In accordance with Corporations Code § 17707.05, upon dissolution and winding up, Members shall be entitled to return of their contributions as follows: on a pro rata basis in accordance with the Members’ interests in Schedule A as of the date of dissolution after all creditors and outstanding balances owed by the Company are paid in full or otherwise satisfied. (d) If the Members cannot agree to a valuation based on the fair market value of the interests, the value of the Company and the respective Members’ interests shall be determined pursuant to this Agreement. 3.10 Admission of Additional Members The Members may admit to the Company additional Members to participate in the profits, losses, available cash flow, and ownership of the assets of the Company on such terms as are determined by the Managing- Members. Admission of any additional Member requires a unanimous vote of Managing-Members. Any additional Members are allocated gain, loss, income, or expense by the method provided in this Agreement. (a) The ownership (equity) interest of any additional Member shall be determined by their percent ownership in the Company as reflected in an amended Schedule A made pursuant to section 3.01 of this Agreement. (b) A unanimous vote of Managing-Members shall be required to confer management rights upon a new Member. Absent such a vote, a new Member will not have management rights in the Company and will only be entitled to distributions in accordance with their percent interest in the Company (as set out in Schedule A). 3.11 Limitation on Liability Pursuant to Corporations Code § 17703.04(a), with respect to debts, obligations, or other liabilities of the Company, whether arising in contract, tort, or otherwise: (1) They are solely the debts, obligations, or other liabilities of the Company to which the debts, obligations, or other liabilities relate; and (2) they do not become the debts, obligations, or other liabilities of a Member, or Manager, solely by reason of acting in such for the Company. A Member or any employee will not be liable to the Company or to any other Member for any mistake or error in judgment or for any act or omission believed in good faith to be within the scope of authority conferred by this Agreement with the Company. The Member is personally liable only for any and all acts and omissions involving intentional wrongdoing including, but not limited to, a criminal act which results in a criminal conviction. 3.12 No Member Responsible for Other Member’s Commitment In the event that a Member (or a Member’s shareholders, partners, Members, owners, or affiliates) has incurred any indebtedness or obligation before the date of this Agreement that relates to or otherwise affects the Company, neither the Company nor any other Member has any liability or responsibility with respect to the indebtedness or obligation unless the indebtedness or obligation is assumed by the Company pursuant to a written instrument signed by all Members. Furthermore, neither the Company nor any Member is responsible or liable for any indebtedness or obligation that is subsequently incurred by any other Member (or a Member’s shareholder, partners, Members, owners, or affiliates). In the event that a Member (or a         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 7 / 22 Members’ shareholders, partners, Members, owners, or affiliates; collectively called the “liable Member”), whether before or after the date of this Agreement, incurs (or has incurred) any debt or obligation that neither the Company nor any of the other Members is to have any responsibility or liability for, the liable Member must indemnify and hold harmless the Company and the other Members from any liability or obligation they may incur in respect of the debt or obligation. 3.13 Transfer of Transferable Interests A transferable interest is personal property. A transferable interest may be evidenced by a certificate of the interest issued by Company in a record, and the interest represented by the certificate may be transferred by a transfer of the certificate. (a) With respect to a transfer in whole or in part of a transferable interest, a transfer does not by itself cause a Member’s dissociation or a dissolution and winding up of the Company’s activities. Subject to provisions regarding the death of a Member, a transfer does not entitle the transferee to participate in the management or conduct of the activities of the Company, or except upon dissolution, to have access to records or other information concerning the Company’s activities. (b) If any Member receives an offer from a prospective third-party purchaser to buy any portion of his or her Member Interest, he or she must first offer that interest to the remaining Members on the same terms and conditions as received from the third-party purchaser. 3.14 Indemnification All Members will be indemnified and held harmless by the Company from and against any and all claims of any nature, whatsoever, arising out of a Member’s participation in Company affairs. A Member will not be entitled to indemnification under this section for liability arising out of gross negligence, willful misconduct or breach by the Member of any provisions of this Agreement. 3.15 Rights of Transferees Pursuant to Corporations Code § 17705.02, a transferee has the right to receive, in accordance with the transfer, distributions to which the transferor would otherwise be entitled. However, the pledge or granting of a security interest, lien, or other encumbrance in or against any or all of the transferable interest of a transferor shall not cause the transferor to cease to be a Member or grant to the transferee or to anyone else the power to exercise any rights or powers of a Member, including, without limitation, the right to receive distributions to which the Member is entitled. Upon dissolution and winding up of the Company, a transferee is entitled to an account of the Company’s transactions only from the date of dissolution. A transfer of a transferable interest in violation of a restriction on transfer contained in this operating Agreement is ineffective as to a person having notice of the restriction at the time of transfer. 3.16 Rights of Transferors Pursuant to Corporations Code § 17705.02, and except as otherwise provided, when a Member transfers a transferable interest, the transferor retains the rights of a Member, other than the interest in distributions transferred, and retains all duties and obligations of a Member. (a) When a Member transfers a transferable interest to a person that becomes a Member with respect to the transferred interest, the transferee is liable for the Member’s obligations for contributions under Corporations Code § 17704.03 and liability for wrongful distributions under Corporations Code § 17704.06(c) known to the transferee when the transferee becomes a Member. (b) A Member may only transfer an interest to a person that becomes a Member with respect to the transferred interest only upon a unanimous vote of Managing-Members. (c) In the event that a Member’s interest in the Company is transferred or assigned as the result of a court order or Operation of Law, the trustee in bankruptcy or other person acquiring that Member’s interest in the Company will only acquire that Member’s economic rights and interests and will not acquire any other rights of that Member or be admitted as a Member of the Company or have the right to exercise any management or voting interests.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 8 / 22 3.17 Valuation of Interest In the absence of a written agreement setting a value, the value of the Company will be based off the fair market value appraisal of all Company assets (less liabilities) determined in accordance with generally accepted accounting principles. This appraisal will be conducted by an independent accounting firm agreed to by all Members. The results of the appraisal will be binding on all Members. (a) No allowance will be made for goodwill, intellectual property or other intangible assets, except where such assets have been reflected on the Company books immediately prior to valuation. 3.18 Death of Member Pursuant to Corporations Code § 17705.04, if a Member dies, the deceased Member’s personal representative or other legal representative may exercise the rights of a transferee under Corporations Code § 17705.02(c) and for purposes of settling the estate, the rights of a current Member under Corporations Code § 17704.10. The personal or legal representative of the deceased Member does not become a Member with respect to that interest. (a) If the personal or legal representative of the deceased Member intends to sell or otherwise transfer the deceased Member’s interest, the representative must first offer the Company a right of first refusal to repurchase the interest at its fair market value. 3.19 Defaulting Members. If any Member is unwilling or unable to make, within thirty (30) days, any or all of such Member’s proportionate contribution upon a capital call, then the other Members shall each have the right to make up such deficit amount in any proportion that they decide. If the other Members, or any one of them, makes a contribution pursuant to the foregoing, such Member(s) shall have the option to treat the contribution as (i) additional capital of the Company, or (ii) to treat the contribution as a loan to the defaulting Member. Such election shall be made, in writing, at the time the contribution is made. (a) If the contributing Members elect to treat their contribution as additional capital, then after such contributions are made, each Member’s percentage capital interest in the Company (and their respective interests in the net profits, net losses and cash flow) shall be adjusted and determined by dividing the total amount of capital contributed to the Company by such Member since the Company’s inception by the total amount of capital contributed to the Company since its inception by all Members. The resulting quotient, with respect to each Member, shall be the adjusted percentage interest of such Member in the capital of the Company (and in the net profits, net losses and cash flow). In accordance with such increased capital interest, the Company shall amend Schedule A to properly reflect such Members increased Member Interest in the Company. (b) If the contributing Members elect to treat their contributions as a loan to the defaulting Member, then no adjustment shall be made to the percentage capital interest of the contributing Members, and each Member’s share in the profits and losses and cash flow of the Company shall remain the same. The defaulting Member’s capital account shall be increased in the same amount as would occur if the defaulting Member had made the additional capital contribution in the amount of the loan. In addition, the defaulting Member’s share in the net profits, net losses and cash flow of the Company shall be adjusted, if necessary, as if he or she had made a contribution to the capital of the Company in the amount of such loan. The amount advanced by the Members on behalf of the defaulting Member shall be a debt of the defaulting Member to the contributing Members and shall bear interest at the prime rate or other rate agreed to in writing by all parties. Thereafter, all distributions of cash from the Company due to the defaulting Member shall be paid to the Members who elected to treat their contribution as loan until such time as the principal and interest of the loan is paid in full. ARTICLE 4. MANAGEMENT         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 9 / 22 4.01 Management by Members. The Company will be a Member-Managed, LLC; the Members as managers will manage the Company. Except as otherwise provided in this Agreement, each Member has the full and complete authority, power, and discretion to act for and bind Company in the ordinary course of Company's business. The management and conduct of the Company are vested in its Members pursuant to Corporation Code §17704.07. 4.02 Duty of Care. All Managing-Members must manage the Company with the skill, care and ability of an ordinary prudent person. 4.03 Officers. By a majority vote of the Members, the Members may appoint individuals as officers of the Company (the “Officers”) to carry on the business of the Company and may delegate to such Officers such power and authority as they deem necessary or advisable. An Officer is not required to be a Member of the Company. Any individual may hold two or more offices of the Company. Each Officer shall hold office until his or her successor is designated by the Members or until his or her earlier death, resignation, or removal. Any Officer may resign at any time upon written notice to the Manager. Any Officer may be removed by a majority vote at any time, with or without cause. A vacancy in any office occurring because of death, resignation, removal, or otherwise may, but need not, be filled in the same manner. 4.04 Duty of Loyalty No Member will engage in any business, venture or transaction, whether directly or indirectly, that might be competitive with the business of the Company or that would directly conflict with an interest of the Company. In the case of a Member, any potential conflict of interest will be deeded an involuntary dissociation of the offending Member and may be treated accordingly by the remaining Members. 4.05 Notwithstanding Section 4.04, a Member may engage in business which might be competitive with the business of the Company or a direct conflict of interest with the Company, provided that they (1) disclose the conflict to the Members, (2) such Members with management rights in the Company (Managing-Members) ratify the conduct by a majority vote, and (3) the terms of the business deal are fair and reasonable. 4.06 Forbidden Acts No Member may act in contravention of this Agreement. Any commission of the forbidden acts in this section will be deemed an involuntary withdrawal and wrongful dissociation of the offending Member, and may be treated accordingly by the remaining Members. No Member: (a) may intentionally permit the assignment of express, implied or apparent authority to a third party that is not a Member of the Company. (b) shall do any act which would make it impossible to carry on the ordinary business of the Company. (c) shall have the right or authority to bind or obligate the Company to any extent with regard to any matter outside the intended purpose of the Company. (d) shall confess a judgment against the Company. 4.07 Limited Liability of Members No Member shall be subject to liability under this section absent fraud, extreme recklessness or gross negligence in managing the affairs of the Company.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 10 / 22 ARTICLE 5. MEETINGS OF MEMBERS 5.01 Regular Meetings. Meetings of Members are governed by the California Revised Uniform Limited Liability Company Act, Corporations Code § 17704.07. Members shall, in good faith, attempt to hold meetings whenever necessary to conduct Company business, and to maintain the required formalities of a Limited Liability Company. However, nothing in this Agreement shall be construed so as to imply or expressly require Members to hold regular meetings or keep minutes. 5.02 Notice. If any action on the part of the Members is to be proposed at the meeting, then written notice of the meeting must be provided to each Member entitled to vote not less than ten (10) days or more than sixty (60) days prior to the meeting. Notice may be given in person, by fax, by first-class mail or by any other written communication, charges prepaid, at the Members’ address listed in Schedule A. The notice shall contain the date, time, and place of the meeting and a statement of the general nature of the business to be transacted there. 5.03 Quorum. Where a vote is required on an action proposed at a meeting, a quorum of outstanding interests in the Company must be present to make such a vote valid under this Agreement. At any meeting of Members, presence of Members entitled to cast at least 51 percent of the total votes of all Members entitled to vote at the meeting constitutes a quorum. 5.04 Consent by Members in Lieu of Meetings of Members. Subject to the applicable laws of the State of California, any action required or permitted to be taken at a Members' meeting may be taken without a meeting if the action is approved by the written consent of the Members entitled to vote on the action. The written consent must describe the action to be taken, be signed by all the Members entitled to vote on the action, and delivered to Company for inclusion in the Company minutes. The record date for determining Members entitled to take action without a meeting is the first date a Member signs the consent to that action. 5.05 Annual Meeting of Members Not Required. The Members may, but need not, hold an annual meeting and may hold additional regular meetings. Any action required or permitted to be taken by the Members at a meeting may be taken by the written consent of Members having not less than the minimum number of votes that would be necessary to authorize or take that action at a meeting at which all Members entitled to vote on that action at a meeting were present and voted. ARTICLE 6. VOTING RIGHTS 6.01 Votes Required to Act. Except as otherwise provided by law or in this Agreement, a Members Voting Interest shall equal their respective Voting percentages as set out in Schedule A. 6.02 Deadlock. If the Members are deadlocked on any matter or any decision, the Members must promptly select a mutually acceptable and independent individual who will, after good faith discussions with the Members, resolve the deadlocked matter (including, if necessary, by causing his or her vote in favor of a proposed resolution). Such individual shall be selected based on the unanimous vote of all Members. If the Members cannot agree on the selection of such an individual, any Member is entitled to request that an official of the local office of the American Arbitration Association ("AAA") appoint such an individual.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 11 / 22 6.03 Vote by Proxy. Pursuant to Corporations Code § 17704.07(o), the use of proxies shall be governed in the same manner as in corporations formed under the General Corporation Law, Corporations Code § 100 et seq. 6.04 Actions Without Meeting Pursuant to Corporations Code § 17704.07(n), any action that may be taken at any meeting of the Members may be taken without a meeting if a consent in writing, setting forth the action so taken, is signed and delivered to the Company within 60 days of the record date for that action by Members having not less than the minimum number of votes that would be necessary for that action at a meeting at which all Members entitled to vote thereon were present and voted. 6.05 Limitations on Power of Members as Managers. Notwithstanding the provisions above, none of the following acts shall be taken, sums expended, decisions made, or obligation incurred by any Member regarding a matter, until the same has been approved by at least a Two-Thirds (2/3rds) majority vote of the Members: (a) The transfer, exchange, or other disposition of all Company's assets, any significant portion thereof, or any significant interest in Company assets occurring as part of a transaction or plan. (b) The merger of Company with any other limited liability company, limited partnership, or corporation. (c) Contracting on behalf of Company of any debt, obligation, or liability on behalf of Company of more than $100,000, except for trade debt incurred in the ordinary course of Company's business and due within 12 months. (d) Making any single expenditure, or expenditures in any one year that in the aggregate are in excess of $100,000. (e) Approving the transfer of a Member Interest and the admission of a Transferee as a Member. (f) Amending the Articles or this Agreement. (g) Performing any act that would make it impossible to carry on the ordinary business of Company. (h) Making, executing, or delivering on behalf of Company any assignment for the benefit of creditors or any guarantee, indemnity bond, or surety bond, or any equivalent thereof. (i) Lending funds belonging to Company to any third party or extending to any person, firm, or corporation, credit on behalf of Company, except in the ordinary course of business or as set forth in this Agreement. (j) Changing the amount or character of Capital Contributions, or changing the character of the business of Company. (k) settle any lawsuit, action, dispute, or other proceeding or otherwise assume any liability [with a value equal to or in excess of $10,000 or agree to the provision of any equitable relief by the Company. ARTICLE 7. ALLOCATIONS: DISTRIBUTIONS AND INTERESTS 7.01 Allocation of Net Income, Net Loss, or Capital Gains Except as may be expressly provided otherwise in this Article 7, and subject to the provisions of Internal Revenue Code § 704(c), the net income, net loss, or capital gains of the Company for each fiscal year of the Company is allocated to the Members, pro rata in accordance with their percentage Member Interests in the Company. (a) If a Member, on formation of the Company or at any time thereafter, contributes property with an adjusted income tax basis different from the fair market value at which the property is accepted and credited to that Member’s capital account, then solely for income tax purposes and the         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 12 / 22 determination of each Member’s distributive share of the net Company profits and losses, any depreciation, depletion, gain, or loss with respect to that property shall, pursuant to Internal Revenue Code § 704(c) of 1986 and Treasury Regulations § 1.704-3, be allocated according to the traditional method with remedial allocations. (b) A Member’s interest in the Company will be considered personal property. 7.02 Cash Flow. The cash flow of the Company shall be the net profits and losses of the Company, according to Generally Accepted Accounting Practices (GAAP), plus depreciation and other noncash charges deducted in determining such profits and losses, minus principal payments on all mortgages, and any other cash expenditures which have not been deducted in determining the net profits and losses of the Company, and minus the amount reasonably determined by the Managing-Members to be necessary to maintain for the Company sufficient working capital and a reasonable reserve. The cash flow of the Company shall be determined separately for each fiscal year and not cumulatively. 7.03 Distribution or Retention of Cash Flow. Cash flow, as determined in accordance with this Article, shall be distributed to the Members in accordance with the following provisions. All distributions of cash flow shall be made in proportion to the Member Interest held by each Member. (a) The Company shall make mandatory pro-rata distributions to the Members for the payment of taxes in accordance with the following: (1)The amount distributable with respect to any year shall be equal to the aggregate amount of Federal, state and local income taxes payable by the Members with respect to the taxable income of the Company, assuming, for purposes of determining the amount of such distribution, that each Member will be taxed on the net amount set forth in the Member’s respective K-1 at the highest marginal individual Federal income tax rate for such year, and at the highest marginal individual state and local income tax rates applicable to any Member for each such taxable year; and (2) such distributions shall be payable at such time or times and in such amounts as will enable the Members to avoid penalties and interest otherwise payable on account of the failure to pay a sufficient amount of estimated taxes as required by law, which distributions shall be made at such time or times as may be determined by the Managers. (b) The balance of the cash flow remaining, if any, following the tax distributions described above, shall be distributed pro-rata to the Members at such times and in such amounts as the Managing Members in their reasonable discretion shall determine. 7.04 Banking and Company Funds The funds of the Company will be placed in such investments and banking accounts as will be designated by the Managing-Members. All withdraws from these accounts will be made by a duly authorized agent or agents of the Members as agreed by a unanimous vote of Managing-Members. Company funds will be held in the name of the Company and will not be comingled with those of any other person or entity. 7.05 Allocation of Income and Loss and in Respect of Interests Transferred If any interest in the Company is transferred, or is increased or decreased by reason of the admission of a new Member or otherwise, during any fiscal year of the Company, each item of income, gain, loss, deduction, or credit of the Company for the fiscal year must be assigned pro rata to each day in the particular period of the fiscal year to which the item is attributable (that is, the day on or during which it is accrued or otherwise incurred) and the amount of each item so assigned to any day shall be allocated to the Member based on his or her respective interest in the Company at the close of the day. For the purpose of accounting         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 13 / 22 convenience and simplicity, the Company may treat a transfer of, or an increase or decrease in, an interest in the Company that occurs at any time during a semimonthly period (commencing with the semimonthly period including the date of this Agreement) as having been consummated on the first day of the semimonthly period, regardless of when during the semimonthly period the transfer, increase, or decrease actually occurs (that is, sales and dispositions made during the first 15 days of any month are deemed to have been made on the 16th day of the month). 7.06 Distribution of Available Cash Interim distributions made before the dissolution and winding up of the Company will be made periodically, but not less frequently than at the end of each calendar quarter. The available cash of the Company, if any, will be distributed to the Members pursuant to their percent interests in the Company (as reflected in Schedule A). For any calendar quarter, available cash need not be distributed to the extent that the cash is required for a reasonable working capital reserve for the Company; the amount of the reasonable working capital reserve is to be determined by a majority vote of Managing-Members. No Member will have priority over any other Member for any Distribution. (a) Upon a majority vote of Managing-Members, the Company may issue distributions to a Member or Members in amount other than that which is determined by this Agreement (as reflected in Schedule A). (b) If, before a distribution is made, a Member leaves the Company by means other than wrongful dissociation or being expelled, that Member shall receive a cash distribution, if any, in proportion to the number of days that they served as a Member during the distribution period. (c) With the exception of dissolution and winding-up, distributions must be made in cash. Distribution of Company assets and equipment may be made during dissolution and winding-up as necessary to reimburse Members for their respective capital contributions to the Company, and to pay off any outstanding debts owed by the Company. 7.07 Charging Order If a creditor obtains a lien or a charging order against any Member’s Member Interest, the creditor or claimant shall only be considered a Transferee/Assignee and will be limited to the rights of such. The creditor or claimant shall have no right to become a Member or have rights to management participation nor have the right to participate as a Member or Manager in any regard to the affairs of the Company. The creditor or claimant shall only be entitled to receive the share of profits and losses, or the return of capital, to which the Member would otherwise have been entitled. (a) Upon a majority vote of Managing-Members, the Company may purchase any or all part of the Member Interest(s) that are subject to the charging order, bankruptcy, lien or other involuntary transfer at a discounted price. Written notice of such purchase shall be provided to the creditor or claimant. 7.08 Tax Matters Member. The Tax Matters Member of the Company, chosen pursuant to Internal Revenue Code § 6231(a)(7), is Geoffrey Yeterian, who has the same authority as granted by the Internal Revenue Code to a tax matters partner.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 14 / 22 ARTICLE 8. PROTECTION OF TRADE SECRETS 8.01 Trade Secret “Trade Secret” as provided in the Uniform Trade Secrets Act (California Civil Code §3426.1(d)), includes certain Confidential Information and means, without limitation, information, including a formula, pattern, compilation, program, device, method, technique, or process that (a) derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use, and (b) is the subject of efforts that are reasonable under the circumstances to maintain its secrecy. As used herein, the term “Trade Secret” shall include without limitation any and all confidential information, intellectual property, customer lists, cannabis industry affiliations, technical information, know-how, formulas, cannabis genetics, prototypes, specifications, directions, instructions, protocols, procedures, results, analyses, raw material sources, manufacturing data, formulation or production technology, conceptions, ideas, innovations, discoveries, inventions, processes, methods, materials, devices, formulae, equipment, enhancements, modifications, technological developments, techniques, systems, tools, designs, drawings, plans, software, documentation, data, programs, and other knowledge, information, skills, and any combinations, modifications, variations, derivative works, and improvements of or relating to any of the foregoing. 8.02 Confidential As described herein, the Members hereto agree to maintain the strict confidences of any Trade Secret, which it may come to know or possess by virtue of this Agreement. Each Member acknowledges that the Trade Secrets, processes, methods, and technical information of the Company and of each individual member, and any other matters designated by all of the Members, are valuable assets critical to the success of the organization. (a) Unless he or she obtains the written consent of each Member of the Company, each Member agrees never to disclose to any individual or organization, except in authorized connection with the business of the Company, any Trade Secret, process, or other matter referred to in this Section while a Member of the Company, or at any later time, regardless if a member is no longer associated with the Company. No Member may use any other Member’s intellectual property or Trade Secret without prior written consent of the respective Member. (b) THE MEMBERS ACKNOWLEDGE AND AGREE THAT THIS SECTION SHALL SURVIVE THE TERMINATION OR CANCELLATION OF THIS AGREEMENT. 8.03 Member’s Intellectual Property Unless otherwise provided for in writing, all intellectual property, including without limitation, Trade Secrets, inventions, methods, Trademarks, Service Marks, Container Brand or otherwise, and their derivatives shall remain at all times the sole property of the respective Member who owned or possessed such intellectual property immediately prior to the execution of this agreement.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 15 / 22 ARTICLE 9. COMPANY RECORDS AND REPORTS 9.01 Required Books and Records At its California office, the Company shall maintain in writing, or in any other form capable of being converted into clearly tangible form, the following books and records in compliance with Corporations Code § 17701.13(a),(d): (a) A current list setting forth, in alphabetical order, the full name and last known business or residence address of each Member and of each holder of transferable interest in the Company, together with the contribution and the share in profits and losses of each Member and holder of a transferable interest. (b) A copy of the Company’s articles of organization and all amendments thereto, together with any powers of attorney pursuant to which the articles of organization or any amendments thereto were executed. (c) Copies of the Company’s federal, state, and local income tax or information returns and reports, if any, for the six most recent fiscal years. (d) A copy of this Agreement, and any amendments thereto, together with any powers of attorney pursuant to which any written operating Agreement or any amendments thereto were executed. (e) Copies of the Company’s financial statements, if any, for the six most recent fiscal years. (f) The books and records of the Company’s internal affairs for at least the current and past four fiscal years. (g) A current list of the full name and business or residence address of each Member. 9.02 Records and Accounting; Fiscal Year The books and records of the Company must be kept, and the financial position and the results of its operations recorded, in accordance with the accounting methods elected to be followed by the Company for federal and state income tax purposes. The books and records of the Company must reflect all Company transactions and must be appropriate and adequate for the Company’s business. The fiscal year of the Company for financial reporting and for federal income tax purposes is the calendar year. 9.03 The Managers shall close the accounting records at the close of each calendar year, and shall prepare and send to each Member a statement of such Member’s distributive share of income and expense— in the form of a Schedule K-1—for income and tax reporting purposes. 9.04 Access to Information (a) Pursuant to Corporations Code § 17704.10, upon the request of a Member or holder of a transferable interest, for purposes reasonably related to the interest of that person as a Member or a holder of a transferable interest, a Member in possession of the requested information shall promptly deliver, in writing, to the Member or holder of a transferable interest, at the expense of the Company, a copy of the information required to be maintained by Corporations Code § 17701.13(d)(1),(2),(4), and any written operating Agreement of the Company. (b) Each Member and holder of a transferable interest has the right, upon reasonable request, for purposes reasonably related to the interest of that person as a Member, or holder of a transferable interest, to each of the following: (1) To inspect and copy during normal business hours any of the records required to be maintained pursuant to Corporations Code § 17701.13. (2) To timely obtain in writing from the Company, after becoming available a copy of its federal, state, and local income tax returns for each year.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 16 / 22 ARTICLE 10. MEMBER’S DISSOCIATION 10.01 Causes of Dissociation (a) A person is dissociated as a Member from the Company upon any of the events specified in Corporations Code § 17706.02. (b) Events leading to the involuntary withdrawal of a Member from the Company will include, but will not be limited to: death of a Member; Member’s mental incapacity; breach of fiduciary duties of a Member, Bankruptcy of a Member; Operation of Law against a Member or upon commission of any of the prohibited acts described in Section 4.06 of this Agreement. (c) Expulsion of a Member can also occur on application by the Company or another Managing- Member, where it has been judicially determined that the Member has: engaged in wrongful conduct and adversely affected the Company’s business; or has willfully or persistently committed a material breach of this Agreement or a duty owed to the Company or the other Members. 10.02 Right to Dissociate Pursuant to Corporations Code § 17706.01(a), a person has the power to dissociate as a Member at any time, rightfully or wrongfully, by withdrawing as a Member by express will pursuant to Corporations Code § 17706.02(a). 10.03 Effect of Dissociation When a person is dissociated as a Member of the Company, under Corporations Code § 17706.03, the person’s right to participate as a Member in the management and conduct of the Company’s activities terminates. As a Member-Managed LLC, the person’s fiduciary duties as a Member end with regard to matters arising and events occurring after the person’s dissociation. Subject to applicable law, any transferable interest owned by the person immediately before dissociation in the person’s capacity as a Member is owned by the person solely as a transferee. A person’s dissociation as a Member of the Company does not of itself discharge the person from any debt, obligation, or other liability to the Company or the other Members that the person incurred while a Member. The involuntary withdraw of a Member shall have no effect upon continuance of the Company. 10.04 Wrongful Dissociation A person’s dissociation from the Company is wrongful pursuant to Corporations Code § 17706.01(b) only if either of the following apply to the dissociation: (a) The dissociation is in breach of an express provision of this Agreement. (b) The dissociation occurs before the termination of the Company and the person withdraws as a Member by express will; the person is expelled as a Member by judicial order under Corporations Code § 17706.02(e); the person is dissociated under Corporations Code § 17706.02(g) by becoming a debtor in bankruptcy; or in the case of a person that is not a trust other than a business trust, an estate, or an individual, the person is expelled or otherwise dissociated as a Member because it dissolved or terminated. 10.05 Liability for Wrongful Dissociation A person that wrongfully dissociates as a Member is liable to the Company and to the other Members for any damages caused by the dissociation. The liability is in addition to any other debt, obligation, or other liability of the Member to the Company or the other Members. (a) On purchase and sale resulting from the voluntary or involuntary dissociation of a Member, a dissociated Member will only have liability for Company obligations that were incurred during their time as a Member. Immediately upon purchase of a withdrawing Members interest, the Company shall prepare, file, serve and publish all notices required by law to protect the withdrawing Member from liability for future Company obligations.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 17 / 22 ARTICLE 11. DISSOLUTION AND WINDING UP OF COMPANY 11.01 Events Causing Dissolution Pursuant to Corporations Code § 17707.01, and except as otherwise provided in this Agreement, the Company shall be dissolved and its activities shall be wound up on the first to occur of the following events: (a) On the death, insanity, bankruptcy, retirement, resignation, or expulsion of any Member, unless at least 50 percent of the remaining Members consent to continue the Company within 90 days of the dissolution event. (b) On the failure of the Company to achieve its intended purpose as stated in this Agreement, unless the Members unanimously agree to continue the existence of the Company at that time. For purposes of this Section, the Company shall be deemed to have failed to achieve its intended purpose if and only if any of the following occur: (c) By unanimous vote of all the Managing-Members that the Company should be dissolved. (d) The passage of 90 consecutive days during which the Company has no Members. (e) Entry of a decree of judicial dissolution pursuant to Corporations Code § 17707.03. (f) At any earlier time at which dissolution may be required under applicable law. 11.02 Persons Who May Conduct Winding Up (a) Pursuant to Corporations Code § 17707.04, the Managers who have not wrongfully dissolved or dissociated from the Company, or if none, the Members, or if none, the person or persons signing the articles of organization, may wind up the Company’s affairs. The persons winding up the affairs of the Company shall give written notice of the commencement of winding up by mail to all known creditors and claimants whose addresses appear on the records of the Company. (b) The Members winding up the Company’s affairs shall be entitled to reasonable compensation on terms to be determined by a majority vote of the Managing-Members. 11.03 Distribution of Assets After Provision for Payment of Creditors. (a) Pursuant to Corporations Code § 17707.05, after determining that all the known debts and liabilities of the Company including, without limitation, debts and liabilities to Members who are creditors of the Company, have been paid or adequately provided for, the remaining assets shall be distributed among the Members according to their respective rights and preferences as follows: (1) To Members in satisfaction of liabilities for distributions pursuant to Corporations Code §§ 17704.04, 17704.05, or 17704.06. (2) To Members for the return of their contributions. (3) To Members in the proportions in which those Members share in distributions. (b) The payment of a debt or liability, whether the whereabouts of the creditor is known or unknown, has been adequately provided for if the payment has been provided for by either of the following means: (1) Payment has been assumed or guaranteed in good faith by one or more financially responsible persons or by the United States government or any agency thereof, and the provision, including the financial responsibility of the person, was determined in good faith and with reasonable care by the Members to be adequate at the time of any distribution of the Company’s assets pursuant to this Section. (2) The amount of the debt or liability has been deposited with the Controller of the State of California pursuant to Corporations Code § 2008. (c) The claims of each of the priority groups in Section (a), subsections (1)-(3) will be satisfied in full before satisfying the claims of the lower priority group. An excess of Company assets after liabilities or any insufficiency in Company assets in resolving liabilities under this section will be resolved by the Members in proportion to the profit and loss share of each Member as set out in this Agreement.         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 18 / 22 ARTICLE 12. DISPUTE RESOLUTION 12.01 Mediation/Arbitration. In the event of any controversy or claim arising out of or relating to this agreement, or a breach thereof, the Parties hereto shall first attempt to settle the dispute by mediation, administered by the American Arbitration Association under its Mediation Rules, or as otherwise agreed to in writing by both parties. If settlement is not reached within sixty (60) days after service of a written demand for mediation, the Parties agree any dispute, controversy or claim arising out of or relating in any way to the agreement including without limitation any dispute concerning the construction, validity, interpretation, enforceability or breach of the agreement, shall be exclusively resolved by binding arbitration upon a Party’s submission of the dispute to arbitration. The arbitration shall be conducted in accordance with the then existing Commercial Rules of the American Arbitration Association. In such an event, the number of arbitrators shall be one (1) and the place of arbitration shall be Los Angeles County, California. The parties agree that the arbitrator shall have authority to grant injunctive relief, specific performance or other forms of equitable relief to any party. It is specifically understood and agreed that any party may enforce any award rendered by bringing suit in any court of competent jurisdiction. Except as may be required by law, neither a party nor its representatives may disclose the existence, content, or results of any arbitration hereunder without the prior written consent of both parties. ARTICLE 13. COMPLIANCE WITH EQUITY SHARE REQUIREMENTS 13.01 To the extent that any provision of this Agreement, or part thereof, is or may be construed to be inconsistent with or in violation of the “Equity Share” requirements set forth in the Los Angeles Municipal Code section 104.20, such provision(s) shall be ineffective, unenforceable, and null and void. Upon a determination that any provision of this Agreement, or part thereof, is deemed ineffective, unenforceable, or null and void, the Members shall in good faith amend this Agreement so as to effect the original intent of this Agreement to the fullest extent permitted under Applicable Law. ARTICLE 14. MISCELLANEOUS PROVISIONS 14.01 Complete Agreement: Merger Clause This Agreement and the Articles of this Company constitute the complete and exclusive statement of the Agreement among the Members with respect to the subject matter described. As such, this is a fully integrated Agreement which cannot be contradicted by introduction of any extrinsic evidence. This Agreement contains the entire understanding between and among the Members and Parties and supersedes any prior written and oral statements, understandings and agreements between and among them exclusively respecting the subject matter of this Agreement; no representation, statement, or condition or warranty not contained in this Agreement, or the Articles (or any Amendments thereof) is binding on the Members or has any force or effect. 14.02 Governing Law This Agreement and the rights of the parties under this Agreement will be governed by, interpreted, and enforced in accordance with the laws of the State of California. 14.03 Amendments Pursuant to Corporations Code § 17704.07, any amendment to this Agreement shall require a majority vote of Managing-Members. 14.04 Waiver Failure by any party hereto to enforce any covenant, duty, agreement, term or condition of this Amendment, or to exercise any right hereunder, shall not be construed as thereafter waiving such covenant, duty, term,         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 19 / 22 condition or right; and in no event shall any course of dealing, custom or usage of trade modify, alter or supplement any term of this Amendment. 14.05 Severability If any provision of this Agreement is held to be illegal, invalid, or unenforceable under the present or future laws effective during the term of this Agreement, the provision is fully severable; this Agreement is construed and enforced as if the illegal, invalid, or unenforceable provision had never comprised a part of this Agreement; and the remaining provisions of this Agreement will remain in full force and effect and will not be affected by the illegal, invalid, or unenforceable provision; and there will be added automatically as a part of this Agreement a provision as similar in terms to the illegal, invalid, or unenforceable provision as may be possible and be legal, valid, and enforceable. 14.06 Additional Documents and Acts Each Member agrees to execute and deliver additional documents and instruments and to perform all additional acts necessary or appropriate to effectuate, carry out, and perform all of the terms, provisions, and conditions of this Agreement and the transactions contemplated by it. 14.07 No Third Party Beneficiary This Agreement is made solely and specifically among and for the benefit of the parties to it, and their respective successors and assigns, subject to the express provisions of the Agreement relating to successors and assigns, and no other person has or will have any rights, interest, or claims under this Agreement as a third-party beneficiary or otherwise. 14.08 Tax Consequences This Company is intended to be treated as a partnership for the purposes of state and federal income tax. (a) Members acknowledge that the tax consequence of each Member’s investment in the Company is dependent on each Member’s particular financial circumstances. Each Member will rely solely on the Member’s financial advisors and not the Company. The Company makes no warranties as to the tax benefits that the Members receive or will receive as a result of the Member’s investment in the Company. (b) By signing this Agreement, Members understand that, because the Company is subject to pass through taxation, each Member will be personally responsible for their own tax liability arising from distributions made under this Agreement. 14.09 Title to Company Property Legal title to all property of the Company must be held and conveyed in the name of the Company. 14.10 Reliance on Authority of Person Signing Agreement In the event that a Member is not a natural person, neither the Company nor any Member will (1) be required to determine the authority of the individual signing this Agreement to make any commitment or undertaking on behalf of the entity or to determine any fact or circumstance bearing on the existence of the authority of the individual, or (2) be required to see to the application or distribution of proceeds paid or credited to individuals signing this Agreement on behalf of the entity. 14.11 Warranty of Each Member Each Member agrees, represents, and warrants that at the time he or she executes this Agreement, either (a) He or she is under no legal obligation, by way of judgment, Agreement, contract, or otherwise, specifically including but not limited to any employment Agreement, marital settlement Agreement, prenuptial or postnuptial Agreement, non-marital property Agreement, or creditor’s Agreement, that conflicts with the terms of this Agreement or might impede that Member’s ability to comply with the terms of this Agreement, including but not limited to those provisions of this         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 20 / 22 Agreement respecting the operation and management of the Company or dealing with the transfer or interests in the Company; or (b) That if he or she is under any legal obligation referred to in Section (a), above, he or she shall supply, at the time he or she executes this Agreement, a signed consent by each person legally to entitled to enforce that obligation, in substantially the form of the spousal consent form attached to this Agreement, modified as appropriate to the circumstances and approved by all the other Members of the Company, by which that person legally entitled to enforce the obligation agrees to be bound by all provisions of this Agreement. 14.12 Execution of Spousal Consent Each Member who is a married person agrees that at the time that Member executes this Agreement, he or she shall supply a signed consent by that Member’s spouse, in the form attached to this Agreement, by which that Member’s spouse agrees to be bound by the provisions of this Agreement. 14.13 Multiple Counterparts This Agreement may be executed in several counterparts, each of which is deemed an original but all of which constitute one and the same instrument. However, in making proof only one copy signed by the party to be charged is required. 14.14 Binding Effect Subject to the provisions of this Agreement relating to transferability, this Agreement is binding on and inures to the benefit of the Members, and their respective distributees, successors, and assigns. 14.15 Notices Any notice to be given or to be served on the Company or any party to this Agreement in connection with this Agreement must be in writing and is deemed to have been given and received when delivered to the address specified by the party to receive the notice. Notices must be given to each Member at the address specified in Schedule A. Any Member or the Company, at any time, may designate any other address in substitution of the foregoing address to which notice will be given by giving written notice to the other Members and the Company. [Signature Page Follows]         CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 21 / 22 IN WITNESS WHEREOF, the undersigned have executed this Agreement, to be effective as of the date the Articles of Organization of the Company are accepted for filing by the Secretary of State. Executed: December _____ , 2020 TRADECRAFT FARMS FRESNO – FULTON, LLC _______________________________________________ ________________________ Barry Walker Date CEO _______________________________________________ ________________________ Geoffrey Yeterian Date CFO _______________________________________________ ________________________ Thomas Gibb Date COO _______________________________________________ ________________________ Gerald Nickerson Date Regional Director of Community Relations & Social Policy 1             CONFIDENTIAL Operating Agreement TRADECRAFT FARMS FRESNO - FULTON , LLC p. 22 / 22 SCHEDULE A Contributions and Percentage Interests of Members of Tradecraft Farms Fresno – Fulton, LLC DATED: December 1, 2020 Member Name Address Contribution Description Value of Contribution Allocation of Profits/Loses (Equity %) Voting Rights (Voting %) Barry Walker 721 E. 5th Street Los Angeles, CA 90013 Experience and future services 50%50% Geoffrey Yeterian 721 E. 5th Street Los Angeles, CA 90013 Experience and future services 22.5%22.5% Thomas Gibb 721 E. 5th Street Los Angeles, CA 90013 Experience and future services 22.5%22.5% Gerald Nickerson 341 W. Escalon Avenue Fresno CA 93704 Experience and future services 5%5%         INDEMNIFICATION AND HOLD HARMLESS AGREEMENT FOR COMMERCIAL CANNABIS BUSINESS PERMIT APPLICATION To the fullest extent permitted by law, the City of Fresno (City) shall not assume any liability whatsoever with respect to having issued a commercial cannabis business permit pursuant to Fresno Municipal Code Section. 9-3333 or otherwise approving the operation of any commercial cannabis business or cannabis retail business. In consideration for the submittal of an application for a commercial cannabis business permit application and/or issuance of a cannabis business permit, and to the furthest extent allowed by law, Applicant does hereby agree to indemnify, hold harmless and defend the City and each of its officers, officials, employees, agents and volunteers from any and all loss, liability, fines, penalties, forfeitures, costs and damages (whether in contract, tort or strict liability, including but not limited to personal injury, death at any time and property damage) incurred by City, Applicant or any other person, and from any and all claims, demands and actions in law or equity (including reasonable attorney's fees and litigation expenses), arising or alleged to have arisen directly or indirectly out of the issuance of a cannabis business permit. Applicant’s obligations under the preceding sentence shall not apply to any loss, liability, fines, penalties, forfeitures, costs or damages caused solely by the gross negligence, or caused by the willful misconduct, of City or any of its officers, officials, employees, agents or volunteers. Applicant must, at the time of permit issuance, maintain insurance at coverage limits and with conditions thereon determined necessary and appropriate from time to time by the City Manager. Applicant shall conduct all defense at his/her/its sole cost. The fact that insurance is obtained by Applicant shall not be deemed to release or diminish the liability of Applicant, including, without limitation, liability assum ed under this Agreement. The duty to indemnify shall apply to all claims regardless of whether any insurance policies are applicable. The duty to defend hereunder is wholly independent of and separate from the duty to indemnify and such duty to defend exists regardless of any ultimate liability of Applicant. The policy limits do not act as a limitation upon the amount of defense and/or indemnification to be provided by Applicant. Approval or purchase of any insurance contracts or policies shall in no way relieve from liability nor limit the liability of Applicant, its officials, officers, employees, agents, volunteers or invitees. City shall be reimbursed for all costs and expenses, including but not limited to legal fees and costs and court costs, which the city may be required to pay as a result of any legal challenge related to the city's approval of the applicant's commercial cannabis business permit. The City may, at its sole discretion, participate at its own expense in the defense of any such action, but such participation shall not relieve any of the obligations imposed hereunder. This Indemnification and Hold Harmless Agreement shall survive the expiration or termination of the Application and/or Permit. The undersigned acknowledges that he/she (i) has read and fully understands the content of this Indemnification and Hold Harmless Agreement; (ii) is aware that this is a contract between the City and Applicant; (iii) has had the opportunity to consult with his/her attorney, in his/her discretion; (iv) is fully aware of the legal consequences of signing this document; and (v) is the Applicant or his/her/its authorized signatory. Signed on this day of 2020. Applicant Signature City Employee Signature Print Name and Company Name Print Name Address Title Telephone Number Telephone Number Barry Walker, Tradecraft Farms Fresno - Fulton, LLC 721 E. 5th Street, Los Angeles CA 90013 17 November www.tradecraftfarms.com December 4, 2020 Wilma Quan City of Fresno Office of the City Manager 2600 Fresno Street Fresno, CA 93721 559.621.5555 Cannabis.regs@fresno.gov Re: Fresno Applications Procedures and Guidelines for a Commercial Cannabis Business Permit, Page 3, Supplemental Application Requirements: Cal-OSHA Statement Dear Ms. Quan: Please accept this correspondence on behalf of Tradecraft Farms Fresno – Fulton, LLC (the “Company”), submitted concurrently with our storefront commercial cannabis retail license application to the City of Fresno. This correspondence is submitted in compliance with the Fresno Applications Procedures and Guidelines for a Commercial Cannabis Business Permit, page 3, Supplemental Application Requirements: Cal-OSHA Statement. Should the Company’s license application be approved by the City, the Company hereby affirms that it will comply with the City and State Cal-OSHA employee training requirement(s) outlined in the Fresno Municipal Code, Section 9-3316(c) and the California Business and Professions Code, Section 26051.5(11)(A). Specifically, within one year of receiving a commercial cannabis business permit from the City of Fresno, the Company will employ one supervisor and one employee who have completed a Cal-OSHA 30-hour industry outreach course offered by a duly authorized training provider. The selected training provider will be authorized by a Cal-OSHA Training Institute Education Center to provide the course. Thank you, ________________________________ Barry Walker Owner / CEO Tradecraft Farms Fresno – Fulton, LLC PLANNING AND DEVELOPMENT DEPARTMENT 2600 Fresno Street • Third Floor Jennifer K. Clark, AICP, Director Fresno, California 93721-3604 (559) 621-8277 FAX (559) 498-1026 November 19, 2020 Please reply to: Rob Holt (559) 621-8056 Barry Walker Tradecraft Farms Fresno – Fulton LLC 721 E 5th St Los Angeles, CA 90013 Dear Applicant: SUBJECT: ZONING INQUIRY NUMBER P20-03953 REQUESTING INFORMATION REGARDING CANNABIS RETAIL FOR PROPERTY LOCATED AT 915 NORTH FULTON STREET (APN 452-141-17) Thank you for your inquiry regarding the allowance of new cannabis retail uses. The requested information about cannabis retail uses was analyzed using Article 27, Chapter 15 of the Fresno Municipal Code (FMC) of the City of Fresno. Please note, all research for this inquiry is based on existing land development of the subject property. If there are multiple buildings on the subject property, this research was based on the address provided in the request. This research does not take into effect of future development unless provided in your application request. With that, research of a proposed cannabis retail business on the subject property conveys the following: 1. All cannabis retail businesses must be located on property zoned DTN (Downtown Neighborhood), DTG (Downtown General), CMS (Commercial Main Street), CC (Commercial Community), CR (Commercial Regional), CG (Commercial General), CH (Commercial Highway), NMX (Neighborhood Mixed-Use), CMX (Corridor/Center Mixed- Use), RMX (Regional Mixed-Use), and must meet all of the requirements for development in these zones, including, but not limited to, parking, lighting, building materials, etc. The subject property is zoned CMS, which is one of the allowable zone districts for cannabis retail businesses. Development standards of the CMS zone district are available in Sections 15-1203, 15-1204, and 15-1205 of the FMC. The subject location meets the zone district requirement, per Section 15-2739.B.1.a of the FMC, for a cannabis retail business. 2. All building(s) in which a cannabis retail business is located shall be no closer than 800 feet from any property boundary containing the following: (1) A cannabis retail business; (2) A school providing instruction for any grades pre-school through 12 (whether public, private, or charter, including pre-school, transitional kindergarten, and K-12); (3) A day care center licensed by the state Department of Social Services that is in existence at the time a complete commercial cannabis business permit application is submitted; and, (4) A youth center that is in existence at the time a complete commercial cannabis business permit is submitted. Zoning Inquiry P20-03953 915 North Fulton Street Page 2 November 19, 2020 The subject property is not located within 800 feet of the property boundary of any of the above-mentioned uses. The subject building meets the separation requirements, per Section 15-2739.B.1.b of the FMC, for a cannabis retail business. 3. Prior to commencing operations, a cannabis retail business must obtain a Cannabis Conditional Use Permit from the Planning and Development Department per Section 15- 2739.N of the FMC. 4. No more than 2 cannabis retail businesses may be located in any one Council District. If more than 14 are ever authorized by Council (more than 2 per Council District), they shall be dispersed evenly by Council District. The subject property is in Council District 3. There are currently no cannabis retail businesses located in Council District 3. This location requirement is satisfied for a cannabis retail business. Please review the entirety of Article 33, Chapter 9 (Cannabis Retail Business and Commercial Cannabis), and Section 15-2739 (Adult Use and Medicinal Cannabis Retail Business and Commercial Cannabis Business) of the FMC to understand other requirements of cannabis retail businesses, including but not limited to, application requirements, signage, etc. This information was researched by the undersigned per the zoning request. The undersigned certifies that the above information contained herein is believed to be accurate and is based upon, or relates to, the information supplied by the requestor. The City of Fresno assumes no liability for errors and omissions. All information was obtained from public records held by the Planning and Development Department. A copy of the Fresno Municipal Code may be obtained by contacting the City Clerk’s office at 559-621-7650. The Fresno Municipal Code may also be searched on the Internet, free of charge, by going to www.fresno.gov. If you have questions regarding this matter, please contact me by telephone at 559-621-8056 or at Robert.Holt@fresno.gov. Cordially, Rob Holt, Planner III Development Services Division Planning and Development Department 1 PROOF OF PRIOR REGULATED CANNABIS OWNERSHIP AND EXPERIENCE: Licenses Owned and Operated by Tradecraft Farms’ Owners and Operators License Number License Type Agency Legal Business Name Location Status C11-0000686-LIC Distributor BCC Dub Brothers Management, LLC 3480 E 14th ST, Los Angeles, CA 90023 Active C11-0000421-LIC Distributor BCC Dub Brothers Management, LLC 721 E 5th St, Los Angeles, CA 90013 Active C13-0000136-LIC Distributor- Transport Only BCC Dub Brothers Management, LLC 1711-1721 Griffith Ave, Los Angeles, CA 90021 Active CCL19-0001404 Small Indoor Cultivation CDFA Dub Brothers Management, LLC 4121 Alameda St, Los Angeles, CA 90058 Active CCL19-0000826 Small Indoor Cultivation CDFA Dub Brothers Management, LLC 717 Stanford Avenue, Los Angeles, CA 90021 Active CCL19-0000827 Small Indoor Cultivation CDFA Dub Brothers Management, LLC 3480 E 14th ST, Los Angeles, CA 90023 Active 2 CCL19-0001110 Specialty Indoor Cultivation CDFA Dub Brothers Management, LLC 1711-1721 Griffith Ave, Los Angeles, CA 90021 Active CCL20-0000260 Specialty Indoor Cultivation CDFA Dub Brothers Management, LLC 2507 Main Street, Los Angeles, CA 90007 Active CCL20-0000257 Specialty Indoor Cultivation CDFA Dub Brothers Management, LLC 2515 Main Street, Los Angeles, CA 90007 Active CDPH-10003442 Type 6: Manufacturing CDPH Dub Brothers Management, LLC 721 E 5th St, Los Angeles, CA 90013- 2110 Active CDPH-10004002 Type 6: Manufacturing CDPH Dub Brothers Management, LLC 3480 E 14th ST, Los Angeles, CA 90023 Active C10-0000570-LIC MEDICAL Retailer BCC Manuel Migueles Collective dba Tradecraft Farms 732 E VISTA WAY, VISTA, CA, 92084 Active BL-00041170 MEDICAL Retailer with Delivery City of Vista, CA Manuel Migueles Collective dba Tradecraft Farms 732 E VISTA WAY, VISTA, CA, 92084 Active C12-0000331-LIC Microbusiness (with Retail) BCC Tradecraft Farms - Port Hueneme, LLC dba Tradecraft Farms 2597 BOLKER DR PORT HUENEME, CA 93041 Active PHCU-842 Microbusiness (with Retail) City of Port Hueneme, CA Tradecraft Farms - Port Hueneme, LLC dba Tradecraft Farms 2597 BOLKER DR PORT HUENEME, CA 93041 Active Conditional Use Permit No. 18-05 Medical Cannabis Cultivation and Manufacturing City of Lancaster, CA Tradecraft Ventures, LLC 43511 70TH STREET EAST, LANCASTER, CA, 93535 Active 3 LA-C-18-000240-APP Cultivation Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 4121 Alameda St, Los Angeles, CA 90058 Active LA-C-18-000242-APP Cultivation Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 717 Stanford Avenue, Los Angeles, CA 90021 Active LA-C-18-000238-APP Cultivation & Distribution Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 2507 Main Street, Los Angeles, CA 90007 Active LA-C-18-000239-APP Cultivation Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 2515 Main Street, Los Angeles, CA 90007 Active LA-C-18-000237-APP Cultivation & Distribution Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 1711-1721 Griffith Ave, Los Angeles, CA 90021 Active LA-C-18-000241-APP Distribution & Manufacturing Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 721 E 5th St, Los Angeles, CA 90013 Active LA-C-18-000243-APP Cultivation, Distribution, and Manufacturing Los Angeles Dept. of Cannabis Regulation Dub Brothers Management, LLC 3480 E 14th ST, Los Angeles, CA 90023 Active CCBL #2120 Retailer City Of El Monte Tradecraft Farms – El Monte, LLC dba Tradecraft Farms 11518 Garvey Ave El Monte, CA 91732 Approved, in Development N/A* Retailer City of Fresno Tradecraft Farms Fresno – Fulton, LLC 915 N. Fulton St. Fresno CA 93728 *Application in Process N/A* Retailer City of Fresno Tradecraft Farms Fresno – Chinatown, LLC 925 China Alley, Fresno CA 93706 *Application in Process N/A* Retailer City of Fresno Tradecraft Farms Fresno – Ventura LLC 3594 East Ventura Ave., Fresno, CA 93702 *Application in Process 4 DAAA-41SI-ZOZZ Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 1046 E. 2nd, Edmond, OK 73034 Active DAAA-4JV6-UEY8 Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 777 Jenkins Ave, Norman OK 73069 Active DAAA-EJBN-XUTA Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 4327 NW 23rd, St., Oklahoma City, OK 73107 Active GAAA-4YTC-2JIN Commercial Grower Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 4327 NW 23rd, St., Oklahoma City, OK 73107 Approved PAAA-EYHW- NZDJ Commercial Processor Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 4327 NW 23rd, St., Oklahoma City, OK 73107 Approved DAAA-EJWE-6EU6 Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 111 W. ELM AVE, STILWATER, OK 74074 Active DAAA-41ZQ-KRIT Commercial Dispensary Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 2017 S. Harvard Dr. Oklahoma City, OK 73128 Active GAAA-V1HO-TSCA Commercial Grower Oklahoma State Department of Health Sugar Leaf, LLC dba Cali Roots 2017 S. Harvard Dr. Oklahoma City, OK 73128 Active Bureau of Cannabis Control (833) 768-5880 Adult-Use and Medicinal - Microbusiness License Provisional Distributor Retailer Cultivator (less than 10K sq ft) Cultivator Type Indoor LICENSE NO: C12-0000331-LIC LEGAL BUSINESS NAME: Tradecraft Farms - Port Hueneme, LLC PREMISES: 2597 BOLKER DR PORT HUENEME, CA 93041-1726 VALID: 10/8/2020 EXPIRES: 10/8/2021 Non-Transferable Prominently display this license  as required by Title 16 CCR § 5039    LLC-12 Secretary of State Statement of Information (Limited Liability Company) IMPORTANT — Read instructions before completing this form. Filing Fee – $20.00 Copy Fees – First page $1.00; each attachment page $0.50; Certification Fee - $5.00 plus copy fees This Space For Office Use Only 1. Limited Liability Company Name (Enter the exact name of the LLC. If you registered in California using an alternate name, see instructions.) 2. 12-Digit Secretary of State File Number 3. State, Foreign Country or Place of Organization (only if formed outside of California) 4. Business Addresses a. Street Address of Principal Office - Do not list a P.O. Box City (no abbreviations) State Zip Code b. Mailing Address of LLC, if different than item 4a City (no abbreviations) State Zip Code CA _____________________ Date ____________________________________________________________ Type or Print Name of Person Completing the Form _________________________ Title __________________________________ Signature   c. Street Address of California Office, if Item 4a is not in California - Do not list a P.O. Box City (no abbreviations) State Zip Code If no managers have been appointed or elected, provide the name and address of each member. At least one name and address must be listed. If he manager/member is an individual, complete Items 5a and 5c (leave Item 5b blank). If the manager/member is an en ity, complete Items 5b and 5c (leave Item 5a blank). Note: The LLC cannot serve as its own manager or member. If the LLC has additional managers/members, enter the name(s) and addresses on Form LLC-12A (see instructions). 5. Manager(s) or Member(s) a. First Name, if an individual - Do not complete Item 5b Middle Name Last Name Suffix b. Entity Name - Do not complete Item 5a c. Address City (no abbreviations) State Zip Code 6. Service of Process (Must provide either Individual OR Corporation.) INDIVIDUAL – Complete Items 6a and 6b only. Must include agent’s full name and California street address. a. California Agent's First Name (if agent is not a corporation) Middle Name Last Name Suffix t a corporation) - Do not enter a P.O. Box ions) State Z CORPORATION – Complete Item 6c only. Only include the name of the registered agent Corporation. c. California Registered Corporate Agent’s Name (if agent is a corporation) – Do not complete Item 6a or 6b 7. Type of Business a. Describe the type of business or services of the Limited Liability Company 8. Chief Executive Officer, if elected or appointed a. First Name Middle Name Last Name Suffix b. Address City (no abbreviations) State Zip Code 9. The Information contained herein, including any attachments, is true and correct. Return Address (Optional) (For communication from the Secretary of State related to this document, or if purchasing a copy of the filed document enter the name of a person or company and the mailing address. This information will become public when filed. SEE INSTRUCTIONS BEFORE COMPLETING.) Name: Company: Address: City/State/Zip: LLC-12 (REV 01/2017) 2017 California Secretary of State www.sos.ca.gov/business/be 18-D91412 FILED In the office of the Secretary of State of the State of California NOV 30, 2018 TRADECRAFT FARMS - PORT HUENEME, LLC 201829510104 CALIFORNIA 90013-2110 CA 90013-2110 90013-2110CA721 E. 5TH STREET LOS ANGELES 721 E. 5TH STREET LOS ANGELES 721 E. 5TH STREET LOS ANGELES Henschel 721 E. 5TH STREET LOS ANGELES 90013-2110 James CA WalkerBarry Consumer Packaged Goods 11/30/2018 Damian Martin Attorney at Law Page 1 of 2 LLC-12 Secretary of State Statement of Information (Limited Liability Company) IMPORTANT — Read instructions before completing this form. Filing Fee – $20.00 Copy Fees – First page $1.00; each attachment page $0.50; Certification Fee - $5.00 plus copy fees This Space For Office Use Only 1. Limited Liability Company Name (Enter the exact name of the LLC. If you registered in California using an alternate name, see instructions.) 2. 12-Digit Secretary of State File Number 3. State, Foreign Country or Place of Organization (only if formed outside of California) 4. Business Addresses a. Street Address of Principal Office - Do not list a P.O. Box City (no abbreviations) State Zip Code b. Mailing Address of LLC, if different than item 4a City (no abbreviations) State Zip Code CA _____________________ Date ____________________________________________________________ Type or Print Name of Person Completing the Form _________________________ Title __________________________________ Signature   c. Street Address of California Office, if Item 4a is not in California - Do not list a P.O. Box City (no abbreviations) State Zip Code If no managers have been appointed or elected, provide the name and address of each member. At least one name and address must be listed. If he manager/member is an individual, complete Items 5a and 5c (leave Item 5b blank). If the manager/member is an en ity, complete Items 5b and 5c (leave Item 5a blank). Note: The LLC cannot serve as its own manager or member. If the LLC has additional managers/members, enter the name(s) and addresses on Form LLC-12A (see instructions). 5. Manager(s) or Member(s) a. First Name, if an individual - Do not complete Item 5b Middle Name Last Name Suffix b. Entity Name - Do not complete Item 5a c. Address City (no abbreviations) State Zip Code 6. Service of Process (Must provide either Individual OR Corporation.) INDIVIDUAL – Complete Items 6a and 6b only. Must include agent’s full name and California street address. a. California Agent's First Name (if agent is not a corporation) Middle Name Last Name Suffix b. Street Address (if agent is not a corporation) - Do not enter a P.O. Box City (no abbreviations) State CA Zip Code CORPORATION – Complete Item 6c only. Only include the name of the registered agent Corporation. c. California Registered Corporate Agent’s Name (if agent is a corporation) – Do not complete Item 6a or 6b 7. Type of Business a. Describe the type of business or services of the Limited Liability Company 8. Chief Executive Officer, if elected or appointed a. First Name Middle Name Last Name Suffix b. Address City (no abbreviations) State Zip Code 9. The Information contained herein, including any attachments, is true and correct. Return Address (Optional) (For communication from the Secretary of State related to this document, or if purchasing a copy of the filed document enter the name of a person or company and the mailing address. This information will become public when filed. SEE INSTRUCTIONS BEFORE COMPLETING.) Name: Company: Address: City/State/Zip: LLC-12 (REV 01/2017) 2017 California Secretary of State www.sos.ca.gov/business/be 20-E49529 FILED In the office of the Secretary of State of the State of California NOV 06, 2020 TRADECRAFT FARMS - EL MONTE, LLC 201907010207 CALIFORNIA 91732 CA 90013 91732 CA11518 Garvey Avenue El Monte 721 E. 5TH STREET LOS ANGELES 11518 Garvey Avenue El Monte DeJute 721 E. 5th Street Los Angeles 90013 David 10880 Wilshire Blvd., STE 1900 90024 CA WalkerBarry Retail 11/06/2020 Paula Brunelle Authorized Representative Page 1 of 2 Bureau of Cannabis Control (833) 768-5880 Medicinal - Retailer License Provisional Storefront LICENSE NO: C10-0000570-LIC LEGAL BUSINESS NAME: MANUEL MIGUELES COLLECTIVE PREMISES: 732 VISTA WAY E VISTA, CA 92084-5577 VALID: 8/20/2019 EXPIRES: 8/19/2021 Non-Transferable Prominently display this license  as required by Title 16 CCR § 5039    Cannabis Delivery Business Permit The person, firm or corporation named below is granted this permit pursuant to the provisions of VMC Chapter 5.96, Licensing of Cannabis Delivery, for delivery from the business location identified below. Issuance of this business permit is not an endorsement nor certification of compliance with other laws. This permit is revocable at any time as provided in VMC Chapter 5.96. Verification of an active permit may be made by contacting the City Clerk’s Office. City Clerk’s Office 200 Civic Center Dr. Vista, CA 92084 (760) 639-6125 This permit has been issued in accordance with section 5.96.060 of the City of Vista Municipal Code. Business: Tradecraft Farms Vista 732 E. Vista Way Vista, CA 92084 Issue Da 06/08/2020 Delivery Permit er: FDL20-008 COPY LLC-12 Secretary of State Statement of Information (Limited Liability Company) IMPORTANT — Read instructions before completing this form. Filing Fee – $20.00 Copy Fees – First page $1.00; each attachment page $0.50; Certification Fee - $5.00 plus copy fees This Space For Office Use Only 1. Limited Liability Company Name (Enter the exact name of the LLC. If you registered in California using an alternate name, see instructions.) 2. 12-Digit Secretary of State File Number 3. State, Foreign Country or Place of Organization (only if formed outside of California) 4. Business Addresses a. Street Address of Principal Office - Do not list a P.O. Box City (no abbreviations) State Zip Code b. Mailing Address of LLC, if different than item 4a City (no abbreviations) State Zip Code CA _____________________ Date ____________________________________________________________ Type or Print Name of Person Completing the Form _________________________ Title __________________________________ Signature   c. Street Address of California Office, if Item 4a is not in California - Do not list a P.O. Box City (no abbreviations) State Zip Code If no managers have been appointed or elected, provide the name and address of each member. At least one name and address must be listed. If he manager/member is an individual, complete Items 5a and 5c (leave Item 5b blank). If the manager/member is an en ity, complete Items 5b and 5c (leave Item 5a blank). Note: The LLC cannot serve as its own manager or member. If the LLC has additional managers/members, enter the name(s) and addresses on Form LLC-12A (see instructions). 5. Manager(s) or Member(s) a. First Name, if an individual - Do not complete Item 5b Middle Name Last Name Suffix b. Entity Name - Do not complete Item 5a c. Address City (no abbreviations) State Zip Code 6. Service of Process (Must provide either Individual OR Corporation.) INDIVIDUAL – Complete Items 6a and 6b only. Must include agent’s full name and California street address. a. California Agent's First Name (if agent is not a corporation) Middle Name Last Name Suffix t a corporation) - Do not enter a P.O. Box ions) State Z CORPORATION – Complete Item 6c only. Only include the name of the registered agent Corporation. c. California Registered Corporate Agent’s Name (if agent is a corporation) – Do not complete Item 6a or 6b 7. Type of Business a. Describe the type of business or services of the Limited Liability Company 8. Chief Executive Officer, if elected or appointed a. First Name Middle Name Last Name Suffix b. Address City (no abbreviations) State Zip Code 9. The Information contained herein, including any attachments, is true and correct. Return Address (Optional) (For communication from the Secretary of State related to this document, or if purchasing a copy of the filed document enter the name of a person or company and the mailing address. This information will become public when filed. SEE INSTRUCTIONS BEFORE COMPLETING.) Name: Company: Address: City/State/Zip: LLC-12 (REV 01/2017) 2017 California Secretary of State www.sos.ca.gov/business/be 18-D76403 FILED In the office of the Secretary of State of the State of California NOV 14, 2018 DUB BROTHERS MANAGEMENT, LLC 201504010057 CALIFORNIA 90013 CA 90013 90013 CA721 E. 5th Street Los Angeles 721 E. 5th Street Los Angeles 721 E. 5th Street Los Angeles Henschel 721 E. 5th Street Los Angeles 90013 James CA WalkerBarry Consumer Packaged Goods 11/14/2018 Damian Martin Attorney at Law Page 1 of 2 Bureau of Cannabis Control (833) 768-5880 Adult-Use and Medicinal - Distributor-Transport Only License Provisional LICENSE NO: C13-0000136-LIC LEGAL BUSINESS NAME: DUB BROTHERS MANAGEMENT, LLC PREMISES: 1711 Griffith AVE Los Angeles, CA 90021 VALID: 10/23/2019 EXPIRES: 10/22/2021 Non-Transferable Prominently display this license  as required by Title 16 CCR § 5039    Notice of Local Authorization for State Temporary License Dear applicant: The Department of Cannabis Regulation (DCR) is currently reviewing your application for processing pursuant to Los Angeles Municipal Code (LAMC) Sec. 104.08 and has yet to determine whether you meet all eligibility criteria under LAMC Sec 104.08(a).  DCR recognizes that Phase 2 applicants must obtain a temporary license from the state licensing agencies before the end of the year to be eligible for a state provisional license. Accordingly, while DCR continues to review your application, it immediately authorizes you to apply for a state temporary license.  Your local authorization letter to provide to the state licensing agencies is attached. However, if you have not identified an actual business premises yet, you may not submit this letter to the state. This local authorization means that DCR will grant permission for the commercial cannabis activity identified in your application only if DCR determines that you meet all eligibility criteria under LAMC Sec. 104.08(a).  If DCR determines you are not eligible for processing pursuant to LAMC Sec. 104.08, it will revoke your local authorization and inform the state licensing agencies of such. This local authorization shall not create, confer or convey any vested or nonconforming right to engage in commercial cannabis activity in the City of Los Angeles, and it may not be sold, assigned, or otherwise transferred to another person or entity. At this time, you do not have authorization from DCR to engage in commercial cannabis activities in the City of Los Angeles, and you may not do so until the following three conditions are met:  1. You obtain a state temporary license or provisional license;  2. DCR determines you are eligible for processing pursuant to LAMC Sec. 104.08(a); and  3. DCR issues you a Temporary Approval for the same activity type(s) covered by your state temporary license of provisional license.  Please email cannabis@lacity.org if you have any questions regarding this local authorization. LOCAL AUTHORIZATION NOTIFICATION Applicant Name: James Henschel     Business Name: Dub Brothers Management, LLC  Local Application No.: LA-C-18-000237-APP  Business Premises Address: 1711 GRIFFITH AVE, LOS ANGELES, CA 90021  Commercial Cannabis Activity Type{1}(s): Medical Cultivation Small Indoor Medical Distributor Adult-Use Distributor Adult-Use Cultivation Small Indoor {1} Manufacturer Level 1 local authorization covers any eligible combination of  the Type 6, N, P, and S commercial cannabis license activities offered by the State of California. The Los Angeles Department of Cannabis Regulation (DCR) grants authorization to the applicant to engage in the above-referenced commercial cannabis activity type(s) at the business premises address listed above. Applicant must satisfy all conditions set by DCR before and when conducting commercial cannabis activity pursuant to this authorization.  Notice of Local Authorization for State Temporary License Dear applicant: The Department of Cannabis Regulation (DCR) is currently reviewing your application for processing pursuant to Los Angeles Municipal Code (LAMC) Sec. 104.08 and has yet to determine whether you meet all eligibility criteria under LAMC Sec 104.08(a).  DCR recognizes that Phase 2 applicants must obtain a temporary license from the state licensing agencies before the end of the year to be eligible for a state provisional license. Accordingly, while DCR continues to review your application, it immediately authorizes you to apply for a state temporary license.  Your local authorization letter to provide to the state licensing agencies is attached. However, if you have not identified an actual business premises yet, you may not submit this letter to the state. This local authorization means that DCR will grant permission for the commercial cannabis activity identified in your application only if DCR determines that you meet all eligibility criteria under LAMC Sec. 104.08(a).  If DCR determines you are not eligible for processing pursuant to LAMC Sec. 104.08, it will revoke your local authorization and inform the state licensing agencies of such. This local authorization shall not create, confer or convey any vested or nonconforming right to engage in commercial cannabis activity in the City of Los Angeles, and it may not be sold, assigned, or otherwise transferred to another person or entity. At this time, you do not have authorization from DCR to engage in commercial cannabis activities in the City of Los Angeles, and you may not do so until the following three conditions are met:  1. You obtain a state temporary license or provisional license;  2. DCR determines you are eligible for processing pursuant to LAMC Sec. 104.08(a); and  3. DCR issues you a Temporary Approval for the same activity type(s) covered by your state temporary license of provisional license.  Please email cannabis@lacity.org if you have any questions regarding this local authorization. LOCAL AUTHORIZATION NOTIFICATION Applicant Name: James Henschel     Business Name: Dub Brothers Management, LLC  Local Application No.: LA-C-18-000240-APP  Business Premises Address: 4121 ALAMEDA ST, LOS ANGELES, CA 90058  Commercial Cannabis Activity Type{1}(s): Medical Cultivation Small Indoor Medical Distributor Adult-Use Distributor Adult-Use Cultivation Small Indoor {1} Manufacturer Level 1 local authorization covers any eligible combination of  the Type 6, N, P, and S commercial cannabis license activities offered by the State of California. The Los Angeles Department of Cannabis Regulation (DCR) grants authorization to the applicant to engage in the above-referenced commercial cannabis activity type(s) at the business premises address listed above. Applicant must satisfy all conditions set by DCR before and when conducting commercial cannabis activity pursuant to this authorization.  Notice of Local Authorization for State Temporary License Dear applicant: The Department of Cannabis Regulation (DCR) is currently reviewing your application for processing pursuant to Los Angeles Municipal Code (LAMC) Sec. 104.08 and has yet to determine whether you meet all eligibility criteria under LAMC Sec 104.08(a).  DCR recognizes that Phase 2 applicants must obtain a temporary license from the state licensing agencies before the end of the year to be eligible for a state provisional license. Accordingly, while DCR continues to review your application, it immediately authorizes you to apply for a state temporary license.  Your local authorization letter to provide to the state licensing agencies is attached. However, if you have not identified an actual business premises yet, you may not submit this letter to the state. This local authorization means that DCR will grant permission for the commercial cannabis activity identified in your application only if DCR determines that you meet all eligibility criteria under LAMC Sec. 104.08(a).  If DCR determines you are not eligible for processing pursuant to LAMC Sec. 104.08, it will revoke your local authorization and inform the state licensing agencies of such. This local authorization shall not create, confer or convey any vested or nonconforming right to engage in commercial cannabis activity in the City of Los Angeles, and it may not be sold, assigned, or otherwise transferred to another person or entity. At this time, you do not have authorization from DCR to engage in commercial cannabis activities in the City of Los Angeles, and you may not do so until the following three conditions are met:  1. You obtain a state temporary license or provisional license;  2. DCR determines you are eligible for processing pursuant to LAMC Sec. 104.08(a); and  3. DCR issues you a Temporary Approval for the same activity type(s) covered by your state temporary license of provisional license.  Please email cannabis@lacity.org if you have any questions regarding this local authorization. LOCAL AUTHORIZATION NOTIFICATION Applicant Name: Paula Brunelle     Business Name: Dub Brothers Management, LLC  Local Application No.: LA-C-18-000238-APP  Business Premises Address: 2507 S MAIN ST, LOS ANGELES, CA 90007  Commercial Cannabis Activity Type{1}(s): Medical Cultivation Small Indoor Medical Distributor Adult-Use Distributor Adult-Use Cultivation Small Indoor {1} Manufacturer Level 1 local authorization covers any eligible combination of  the Type 6, N, P, and S commercial cannabis license activities offered by the State of California. The Los Angeles Department of Cannabis Regulation (DCR) grants authorization to the applicant to engage in the above-referenced commercial cannabis activity type(s) at the business premises address listed above. Applicant must satisfy all conditions set by DCR before and when conducting commercial cannabis activity pursuant to this authorization.  LA-C-18-000239-APP (Temporary Approval) Page 2 Dub Brothers Management, LLC business premises from the business premises diagram filed with the application without the prior written approval of DCR. 5. The applicant shall comply with all applicable provisions the Los Angeles Municipal Code, including but not limited to the Los Angeles Fire Code and the Los Angeles Building Code, and obtain all required permits or other authorizations before installing, operating or using any appliances, equipment, or machinery on the business premises. 6. The applicant shall pay all outstanding City business tax obligations as determined by the Los Angeles Office of Finance. Social Equity Program Participation 1. The applicant shall not be eligible for a license pursuant to LAMC Section 104.08 unless it qualifies for the Social Equity Program as Tier 1, Tier 2 or Tier 3 Social Equity Applicant. 2. If DCR finds during its review of the application that the applicant does not meet the requirements to be a Tier 1 or Tier 2 Social Equity Applicant, the applicant shall meet the requirements to be a Tier 3 Social Equity Applicant as defined in LAMC Section 104.20(e) as currently defined or amended or DCR will revoke the applicant’s Temporary Approval and the applicant will not be eligible for a license pursuant to LAMC Section 104.08. Approved By: _________________________________ Date: _________________________________ Sr. MA I 9/29/2020 Notice of Local Authorization for State Temporary License Dear applicant: The Department of Cannabis Regulation (DCR) is currently reviewing your application for processing pursuant to Los Angeles Municipal Code (LAMC) Sec. 104.08 and has yet to determine whether you meet all eligibility criteria under LAMC Sec 104.08(a).  DCR recognizes that Phase 2 applicants must obtain a temporary license from the state licensing agencies before the end of the year to be eligible for a state provisional license. Accordingly, while DCR continues to review your application, it immediately authorizes you to apply for a state temporary license.  Your local authorization letter to provide to the state licensing agencies is attached. However, if you have not identified an actual business premises yet, you may not submit this letter to the state. This local authorization means that DCR will grant permission for the commercial cannabis activity identified in your application only if DCR determines that you meet all eligibility criteria under LAMC Sec. 104.08(a).  If DCR determines you are not eligible for processing pursuant to LAMC Sec. 104.08, it will revoke your local authorization and inform the state licensing agencies of such. This local authorization shall not create, confer or convey any vested or nonconforming right to engage in commercial cannabis activity in the City of Los Angeles, and it may not be sold, assigned, or otherwise transferred to another person or entity. At this time, you do not have authorization from DCR to engage in commercial cannabis activities in the City of Los Angeles, and you may not do so until the following three conditions are met:  1. You obtain a state temporary license or provisional license;  2. DCR determines you are eligible for processing pursuant to LAMC Sec. 104.08(a); and  3. DCR issues you a Temporary Approval for the same activity type(s) covered by your state temporary license of provisional license.  Please email cannabis@lacity.org if you have any questions regarding this local authorization. LOCAL AUTHORIZATION NOTIFICATION Applicant Name: James Henschel     Business Name: Dub Brothers Management, LLC  Local Application No.: LA-C-18-000242-APP  Business Premises Address: 717 STANFORD AVE, LOS ANGELES, CA 90021  Commercial Cannabis Activity Type{1}(s): Medical Cultivation Small Indoor Medical Distributor Adult-Use Distributor Adult-Use Cultivation Small Indoor {1} Manufacturer Level 1 local authorization covers any eligible combination of  the Type 6, N, P, and S commercial cannabis license activities offered by the State of California. The Los Angeles Department of Cannabis Regulation (DCR) grants authorization to the applicant to engage in the above-referenced commercial cannabis activity type(s) at the business premises address listed above. Applicant must satisfy all conditions set by DCR before and when conducting commercial cannabis activity pursuant to this authorization.  Bureau of Cannabis Control (833) 768-5880 Adult-Use and Medicinal - Distributor License Provisional LICENSE NO: C11-0000686-LIC LEGAL BUSINESS NAME: DUB BROTHERS MANAGEMENT, LLC PREMISES: 3480 14TH ST E LOS ANGELES, CA 90023-3819 VALID: 7/5/2019 EXPIRES: 7/4/2021 Non-Transferable Prominently display this license  as required by Title 16 CCR § 5039    LA-C-18-000243-APP (Temporary Approval) Page 2 Dub Brothers Management, LLC business premises from the business premises diagram filed with the application without the prior written approval of DCR. 5. The applicant shall comply with all applicable provisions the Los Angeles Municipal Code, including but not limited to the Los Angeles Fire Code and the Los Angeles Building Code, and obtain all required permits or other authorizations before installing, operating or using any appliances, equipment, or machinery on the business premises. 6. The applicant shall pay all outstanding City business tax obligations as determined by the Los Angeles Office of Finance. Social Equity Program Participation 1. The applicant shall not be eligible for a license pursuant to LAMC Section 104.08 unless it qualifies for the Social Equity Program as Tier 1, Tier 2 or Tier 3 Social Equity Applicant. 2. If DCR finds during its review of the application that the applicant does not meet the requirements to be a Tier 1 or Tier 2 Social Equity Applicant, the applicant shall meet the requirements to be a Tier 3 Social Equity Applicant as defined in LAMC Section 104.20(e) as currently defined or amended or DCR will revoke the applicant’s Temporary Approval and the applicant will not be eligible for a license pursuant to LAMC Section 104.08. Approved By: ___________________________________ Date: ___________________________________ Sr. MA I 9/29/2020 Bureau of Cannabis Control (833) 768-5880 Adult-Use and Medicinal - Distributor License Provisional LICENSE NO: C11-0000421-LIC LEGAL BUSINESS NAME: DUB BROTHERS MANAGEMENT, LLC PREMISES: 721 E 5TH ST LOS ANGELES, CA 90013-2110 VALID: 6/19/2019 EXPIRES: 6/18/2021 Non-Transferable Prominently display this license  as required by Title 16 CCR § 5039    Dub Brothers Management, LLC Dub Brothers Management, LLC 721 E 5TH ST LOS ANGELES, CA 90013-2110 ADULT AND MEDICINAL CANNABIS PRODUCTS PROVISIONAL CDPH-10003442 ype 6: Non Volatile Solvent Extraction 06/12/2020 06/12/2021 Notice of Local Authorization for State Temporary License Dear applicant: The Department of Cannabis Regulation (DCR) is currently reviewing your application for processing pursuant to Los Angeles Municipal Code (LAMC) Sec. 104.08 and has yet to determine whether you meet all eligibility criteria under LAMC Sec 104.08(a).  DCR recognizes that Phase 2 applicants must obtain a temporary license from the state licensing agencies before the end of the year to be eligible for a state provisional license. Accordingly, while DCR continues to review your application, it immediately authorizes you to apply for a state temporary license.  Your local authorization letter to provide to the state licensing agencies is attached. However, if you have not identified an actual business premises yet, you may not submit this letter to the state. This local authorization means that DCR will grant permission for the commercial cannabis activity identified in your application only if DCR determines that you meet all eligibility criteria under LAMC Sec. 104.08(a).  If DCR determines you are not eligible for processing pursuant to LAMC Sec. 104.08, it will revoke your local authorization and inform the state licensing agencies of such. This local authorization shall not create, confer or convey any vested or nonconforming right to engage in commercial cannabis activity in the City of Los Angeles, and it may not be sold, assigned, or otherwise transferred to another person or entity. At this time, you do not have authorization from DCR to engage in commercial cannabis activities in the City of Los Angeles, and you may not do so until the following three conditions are met:  1. You obtain a state temporary license or provisional license;  2. DCR determines you are eligible for processing pursuant to LAMC Sec. 104.08(a); and  3. DCR issues you a Temporary Approval for the same activity type(s) covered by your state temporary license of provisional license.  Please email cannabis@lacity.org if you have any questions regarding this local authorization. LOCAL AUTHORIZATION NOTIFICATION Applicant Name: James Henschel     Business Name: Dub Brothers Management, LLC  Local Application No.: LA-C-18-000241-APP  Business Premises Address: 721 5TH ST, Los Angeles, CA 90013  Commercial Cannabis Activity Type{1}(s): Medical Distributor Medical Manufacturer Level 1 Adult-Use Distributor Adult-Use Manufacturer Level 1 {1} Manufacturer Level 1 local authorization covers any eligible combination of  the Type 6, N, P, and S commercial cannabis license activities offered by the State of California. The Los Angeles Department of Cannabis Regulation (DCR) grants authorization to the applicant to engage in the above-referenced commercial cannabis activity type(s) at the business premises address listed above. Applicant must satisfy all conditions set by DCR before and when conducting commercial cannabis activity pursuant to this authorization.  1 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) LABOR PEACE AGREEMENT (Fresno) This Labor Peace Agreement ("Agreement") is entered into this 1st day of December, 2020 by and between Tradecraft Farms Fresno – Fulton, LLC (hereafter "Employer") and United Food and Commercial Workers International Union, and its designated Local, UFCW Local 8 (hereafter "Union"). This Agreement is entered into in accordance with applicable requirements of the California Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA), California B&P Code § 26000 et seq., and applicable local cannabis licensing ordinances and regulations. 1. This Agreement shall apply to the regular full time and regular part-time employees of Employer who work in the job classifications set forth in Exhibit "A" (the "Employees") at Employer's licensed cannabis business located at 915 North Fulton Street, Fresno, CA 93728 (the "Covered Facility"). If the Covered Facility relocates pursuant to its license under State or local law to another location within the geographic jurisdiction of Union, this Agreement shall apply to the Covered Facility at that new location. In the event Employer choses to operate the Covered Facility under a different "DBA", this Agreement shall nevertheless apply to that Covered Facility when using that new DBA. If Employer applies for a requisite license to operate one or more additional cannabis businesses within Union's geographic jurisdiction, Employer shall provide written notice of same to Union's Secretary-Treasurer (an email shall suffice), whereupon the Parties shall sign a New Location Agreement in the form attached hereto as Exhibit "C" to extend this Agreement to cover the regular full time and regular part-time Employees (as defined) working at that new location for a like Term as this Agreement. Exhibit C will be signed within 5 days of the Notice. 2. The Parties hereby establish the following procedure for the purpose of ensuring an orderly environment for the exercise by Employees of their rights under Section 7 of the National Labor Relations Act and to ensure compliance with MAUCRSA and all applicable local cannabis ordinances and regulations. 3. The Parties mutually recognize that Federal labor law guarantees Employees the right to form or select a labor organization to act as their exclusive representative for the purpose of collective bargaining with Employer, or to refrain from such activity. 4. Employer will take a neutral approach to the unionization of the Employees. Accordingly, Employer will not undertake any action or make any statement that will directly or indirectly state or imply opposition to Employees' selection of a collective bargaining agent, or preference for or opposition to any particular union as Employees' collective bargaining agent. The Union and its representatives will not coerce or threaten any employee in an effort to obtain authorization cards. 2 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) 5. The Union shall have reasonable access to the Employer’s worksite as set forth herein during regular business hours or when employees are required to work for the purpose of meeting with Employees to discuss their right to representation, employment rights under state law, and terms and conditions of employment. In doing so, the Union shall not disrupt the Employer’s business and will act consistently with the California Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA) and Local Cannabis Ordinances. Prior to taking access, the Union will send a letter to the Employer with the names of the individuals who may visit the location prior to its first visit. If the designated individuals change, the Union will update that notice. Then, Employer will cooperate with Union in making arrangement to permit the designated Union representatives to meet with employees in areas where the Employees will be able to speak to the Union representative without monitoring by the Employer, at a time when the employee is not regularly obligated to perform work duties. As part of that cooperation the Employer will share with the Union the particular staffing and layout of the facility to best ensure access while avoiding disruption of the business. To the extent Employer has video surveillance equipment throughout its facility, consistent with the law, the Parties agree that such equipment will not be utilized by Employer to garner information regarding concerted activity or workers' rights under this Agreement. 6. Within ten (10) days following receipt of a written notice from Union declaring an intent to organize Employees (an email to Employer shall suffice), Employer will furnish Union with a complete list of the regular full and part-time Employees referenced in Exhibit "A" showing their job classifications, departments, home addresses, and, if known, cell phone numbers and email addresses. The Employer will provide an updated complete list monthly, unless there is no change to the list. Union will keep all such Employee information furnished by Employer confidential and shall not use the information for any purpose other than the purposes of this Agreement or as required by law. Within ten days of receiving a request by Union, Employer also shall distribute the letter attached as Exhibit B to each Employee. 7. At the Union’s request, the Employer will arrange for a mandatory staff meeting to enable the Union to meet with all of the Employees referenced in Exhibit "A". If it is not feasible for the Employer to schedule a single meeting attended by all Employees, then Employer will cooperate with the Union to schedule a follow up meeting(s) for that purpose. The Employer shall schedule these meeting(s) so as to encourage maximum attendance. Any such meeting will be on paid time. The Parties shall schedule a date for the meeting at least one (1) week prior to the meeting. There shall be no advance announcement by the Employer to employees concerning the subject of the meeting. Rather, the Employer shall schedule the meeting in the same way that notice is provided for other mandatory meetings. Each meeting shall last no more than one (1) hour. At this meeting, Employer will inform Employees that it is neutral, does not object to their talking with Union and supporting a union, and that Employer will negotiate a collective bargaining agreement with Union if and when a majority of Employees who wish to be represented by the Union have designated Union as their exclusive collective bargaining representative. Union representatives will attend the meeting and after Employer has left the meeting, Union representatives will talk with Employees about the Union. 3 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) 8. The Union may request recognition as the exclusive collective bargaining agent for the Employees. Upon such request, a person mutually agreed to by Employer and Union, or if no agreement is reached then the Arbitrator identified in Paragraph 13, will conduct a review of Employees' authorization cards and membership information submitted by Union in support of its claim to represent a majority of the Employees. The review shall involve a comparison of the authorization card signatures of Employees to their W-4 or Form I-9 as furnished by Employer. Except where needed to resolve a concern about the authenticity of an Employee's signature, the identity of all union authorization card signers shall be kept confidential from Employer. Subject to the availability of a person mutually agreed upon or an Arbitrator identified in Paragraph 13, such review shall take place no more than fourteen (14) days after the Union's request, absent mutual agreement to extend time for review. The size of the unit to determine recognition will be determined by the size of the unit ten (10) days prior to the time the request for recognition is made. If the review establishes that a majority of Employees has designated Union to be their exclusive collective bargaining representative or joined the Union, Employer will officially recognize the Union as the Employees' exclusive collective bargaining representative. 9. Employer will not file a petition with the National Labor Relations Board for any election in connection with any demand for recognition provided for in this agreement. The Union and Employer will not file any Unfair Labor Practice charges with the National Labor Relations Board or any other type of legal claim in connection with any act or omission occurring within the context of this Agreement; arbitration under Paragraph 14 shall be the exclusive remedy. Union and Employer agree that if any other person or entity petitions the National Labor Relations Board for any election as a result of or despite recognition of the Union pursuant to this Paragraph, (a) Employer and Union each will request that the NLRB dismiss the petition on grounds of recognition bar or, if they have agreed to a collective bargaining agreement covering Employees at the time the petition is filed, on grounds of contract bar, (b) if the petition is not dismissed, Employer and Union shall agree to a full consent election agreement under Section 102.62(c) of the NLRB’s Rules and Regulations, and (c) Employer and Union shall at all times abide by the provisions of this Agreement. 10. If the Union is recognized as the exclusive collective bargaining representative as provided in Paragraph 8, negotiations for a collective bargaining agreement shall commence no later than 120 days from the date of recognition (or 45 days from a request by the Union to bargain a successor contract for a contract that has an impending expiration date) unless extended by mutual agreement by the parties. To ensure labor peace throughout the collective bargaining process, if the Parties are unable to reach agreement on a collective bargaining agreement within 9 months after recognition pursuant to Paragraph 8 (or upon 4 months after commencement of bargaining for a successor agreement), either party shall have the right to submit any unresolved issues for resolution to final and binding arbitration pursuant to Paragraph 13. The arbitrator identified in Paragraph 13 below shall be the Arbitrator, unless another Arbitrator is mutually agreed to by the Parties. The Arbitrator shall be guided by the following considerations: a) Proposals by the Parties during bargaining leading up to arbitration; b) Size and type of the Employer's operations; 4 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) c) Ability of the employees, through the combination of wages, hours and benefits, to earn a living wage to sustain themselves and their families; d) Employees' productivity; e) Employment standards and conditions at comparable retail or other licensed cannabis operations; f) Customer focused concerns; g) Responsible customer service in a clean and secure environment that assures customer and worker safety; h) A procedure that allows workers to raise and expeditiously resolve workplace disputes; i) Full Compliance with Local and State laws regulating cannabis businesses; j) Compliance with all labor and employment standards under Federal, State and Local laws covering the employees of the Employer; and k) Any other relevant economic or non-economic factors which the Parties have entered into evidence at the hearing. 11. In consideration of the covenants made herein, during the Term of this Agreement, the Union shall not engage in any work stoppage, picketing, boycott or other economic activity directed at the Employer's business (including, but not limited to any strike, sympathy strike, “slowdown”, public hand billing, public display of banners, demonstration directed at the employer, or refusals to handle merchandise (except as may be permitted by applicable provisions of Cal/OSHA). During the Term of this Agreement, Employer will not engage in a lockout of the Employees. If Employer lawfully recognizes any union besides the Union as the exclusive collective bargaining representative of Employees, this Agreement shall terminate immediately and without notice. 12. With the exception of trimming operations, once notice is given pursuant to Paragraph 6 above, Employer shall ensure that any subcontractor who may be engaged to do bargaining unit work shall be required to execute a LPA on the same terms as this Agreement at the time of the subcontracting, if at the time it is not represented by an exclusive bargaining agent. Noting in this section is intended to limit the scope of bargaining over subcontracting, including that of trimming operations if/when the Union is recognized. 13. The Union will cooperate with the Employer in efforts before State and Local Agencies on issues of common concern, including the licensing process, provided the 5 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) Employer complies with this Agreement and laws governing the rights of its workers. The Employer will extend the same cooperation to the Union on issues of common concern. 14. The Parties agree that any disputes over the interpretation or application of this Agreement shall be submitted to expedited and binding arbitration at a location to be mutually agreed within 25 miles of the Covered Facility, with an Arbitrator mutually agreed to by the Parties. If the Parties are not able to agree upon an arbitrator within 7 business days, they shall request from the Federal Mediation and Conciliation Service a list of five arbitrators who are members of the National Academy of Arbitrators and who have their principal office in Southern California. The Parties shall, within 14 days of receiving the list, select a permanent Arbitrator (“Arbitrator”) under this Agreement by alternately striking two names from the list. The Arbitrator shall be the last remaining name on the list after each side has stricken two names. The party to strike first shall be determined by coin toss. The fourth name stricken from the list shall be the Alternate Arbitrator (“Alternate Arbitrator”). The Arbitrator shall hear and decide all disputes submitted to arbitration unless the Arbitrator is unavailable for a hearing within 30 days from the date of submission, but the Alternate Arbitrator is available during such 30-day period, in which case the dispute shall be submitted to the Alternate Arbitrator for hearing and decision. The Arbitrator (or Alternate Arbitrator) shall conduct the arbitration according to the procedures established by the American Arbitration Association. The Arbitrator (or Alternate Arbitrator) shall also have the authority to order the noncompliant party to comply with this Agreement, including both remedies in equity and law. The Parties hereto agree to comply with any order of the Arbitrator (or Alternate Arbitrator), which shall be final and binding. The United States District Court for the Central District of California shall have exclusive jurisdiction over any action concerning arbitration under this Agreement. The Parties consent to the entry of any order of the Arbitrator (or Alternate Arbitrator) as the order or judgment of the Court, which includes the entry of findings of fact and conclusions of law. 15. This Agreement shall be in full force and effect (the "Term") from the date it is fully executed by Employer and the Union until the earlier of: (i) two (2) calendar years from the date of Employer's execution of the Agreement; (ii) or upon execution of a collective bargaining agreement or issuance of an interest arbitration award which concludes the collective bargaining agreement negotiations, either of which explicitly supersede this document. Employer shall notify Union in writing when it has hired a sufficient number of employees to become obligated to enter into a labor peace agreement under MAUCRSA and/or an applicable local cannabis licensing ordinance. This Agreement may only be extended by mutual agreement of the Parties in writing. 16. If any provision of this Agreement is deemed invalid or found to be contrary to law by a court of competent jurisdiction, such provision shall be of no force or effect; but the remainder of this Agreement shall continue in full force and effect. The Parties shall meet and negotiate in good faith with respect to any provision found to be in contravention of the law, not later than fourteen (14) days after a written request to do so by either party with the goal of addressing the issue raised. 17. This Agreement will bind all legal successors to the Employer. Accordingly, in the event of Employer's sale of a Covered Facility or a merger of Employer with another entity that is taking over the operation of a Covered Facility, Employer will require, as a 7 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) EXHIBIT A Description of the bargaining unit The job classifications will include all full time and regular part time hourly retail sales and support dispensary employees of the Employer working at the Covered Facility. The bargaining unit shall exclude all other employees including all managerial, supervisory and confidential employees and all guards employed by the Employer working at the Covered Facility as those terms are as defined by the National Labor Relations Act and applicable decisions of the NLRB. Once a full complement of workers is hired at the Covered Facility, Employer will notify Union within thirty (30) days of all Employee job titles. 8 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) EXHIBIT B Dear Employees: Our dispensary has been approached by United Food and Commercial Workers International Union and its Local UFCW 8. The UFCW is a labor union that represents cannabis workers throughout California. The Union has expressed an interest in organizing our employees. We believe that it is in the best interest of our employees, guests, and clients to resolve the issue of union representation as quickly as possible, and with minimum disruption. As required by applicable law, and to avoid what could be a lengthy and disruptive campaign, we have signed a Labor Peace Agreement with the Union. This letter will explain some basic terms of this Agreement ("the Agreement"). The Labor Peace Agreement gives the Union an opportunity to hold a meeting with our employees at the Facility on paid time to discuss unionization. We will also be providing the Union with a list of our employees' names, phone numbers, email addresses and home addresses where they can contact you. The Labor Peace Agreement guarantees employees the right to form or select a labor organization to act as their exclusive representative for the purpose of collective bargaining with their employer, or to refrain from doing so. Because the decision to join or not join the Union is yours to make, management will not be commenting on the matter. All managers and supervisors have been affirmatively instructed in their obligations under this agreement. Union representatives will also have the opportunity to contact Employees in the near future. The Union representative will explain the benefits of joining the Union and will ask each employee if he or she wants to join the Union. If an employee wants to join the Union, he or she will be asked to sign a card that states that they want the Union to represent them. By signing this authorization card, you are selecting the Union to serve as its exclusive collective bargaining representative. If an outside, neutral third party confirms that the Union has obtained signed authorization cards from a majority of the employees working at this Facility, we will recognize the Union as our employees' exclusive collective bargaining representative and will meet with the Union to negotiate in good faith over the terms of a collective bargaining agreement. I have written this letter to maintain our tradition of open, forthright communication. Again, the decision of whether or not to join the Union is your decision alone. Sincerely, /s/ 9 Tradecraft Farms Fresno – Fulton, LLC (LPA) 1422448v1) EXHIBIT C (After-Acquired Location Agreement) The Parties do hereby agree as follows: 1. The undersigned are Parties to the attached Labor Peace Agreement ("Agreement"), dated _________________, 20__. Paragraph 1 of the Agreement provides for the extension of that Agreement to the bargaining unit employees working at any facility within Union's geographic jurisdiction where the Employer has applied for the requisite licenses to operate a cannabis business during the Term. By signing below, the Parties hereby extend the Agreement to cover the regular full time and regular part time employees working in the bargaining unit job classifications working at the following location: Name: _______________________________________________________________ DBA (if any): __________________________________________________________ Address: _____________________________________________________________ _________________________________________________________CA 9________ 2. This Agreement shall be in full force and effect from the date it is fully executed by Employer and the Union until the earlier of: (i) five (5) calendar years from the date of Employer's execution of the Agreement; (ii) or upon execution of a collective bargaining agreement or issuance of an interest arbitration award which concludes the collective bargaining agreement negotiations, either of which explicitly supersede this document. FOR THE EMPLOYER: By: Title: Date: _________________________ FOR UFCW LOCAL 8 By: _____________________ Title: ___________________ Date: __________________