Town of Orleans - RFI SUBMISSION Marijuana Retailers
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RFI SUBMISSION
Marijuana Retailers
Strain LLC
submi9ng party
PREPARED FOR
Town of Orleans
MassachuseCs
John Kelly, Town Administrator
19 School Road Orleans, MA 02653
Adult-Use Marijuana Retailers RFI
Plan Date: March 17, 2021
Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021 Strain LLC, Proposer Table of Contents OVERVIEW..............................................................................................................................................1 I. Business Experience........................................................................................................1 II. Financial Details..............................................................................................................6 III. Details of Host Community Agreement (HCA).................................................................7 IV. Orleans Business details..................................................................................................9 V. LocaHon........................................................................................................................14 VI. Security and public safety.............................................................................................18 VII. Timeline and Process.....................................................................................................18 VIII. ApplicaHon Deposit.......................................................................................................19 IX. Other details.................................................................................................................20
Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
OVERVIEW
Strain LLC (“Strain”) is a cerYfied Social Equity ParYcipant majority-owned company, responding to the
Town of Orleans’ (the “Town”) RFI to demonstrate Strain’s qualificaYons to operate a Retail Marijuana
Establishment within the Town in accordance with applicable laws and regulaYons (M.G.L. c. 94G, et
seq.; 935 CMR 500.101). Strain proposes to establish a 2,000 to 3,000 SF Retail Marijuana Establishment
(with ample parking) and a co-located Home Delivery License in the Town of Orleans.
Business Experience
1. Describe your current Marijuana business related experience
Priscilla Brown is the Vice President of Strategy at Coyote Cannabis CorporaYon, a provisionally licensed
Tier I CulYvator and Marijuana Product Manufacturer in Uxbridge, MA. Priscilla has completed the
MassachuseCs Cannabis Control Commission’s Social Equity Training Program, which provided her with
in depth training on all aspects of starYng and running a compliant cannabis establishment under 935
CMR 500.00 et seq.
David Rabinovitz is the founder and CEO of NewCann Group LLC, a prospecYve marijuana licensee, is a
principal at CannaVentureLabs.com, which provides cannabis consulYng services for those seeking entry
into the cannabis industry. David and his partner also produce and deliver business, finance, and
strategy courses in the Social Equity Training Program.
Blake Mensing is the Founder & Chief Counsel of The Mensing Group LLC, which is MassachuseCs’ first,
and only, homegrown law firm exclusively dedicated to cannabis law in the Commonwealth. Blake is a
regulatory and permi9ng aCorney who has helped over 160 cannabis businesses in MassachuseCs with
local permi9ng, state applicaYons, and general regulatory compliance counsel on cannabis maCers.
Blake’s firm has helped secure approximately 40 licenses from the MassachuseCs Cannabis Control
Commission covering almost all available license types, from Microbusinesses, CulYvaYon,
Manufacturing, to Independent TesYng Labs.
Blake is also:
• The Founder and President of Coyote Cannabis CorporaYon, which again is a provisionally
licensed Tier I culYvator and co-located Marijuana Product Manufacturer
• A Co-Owner of Holyoke 420 LLC d/b/a Holyoke Cannabis, an operaYonal adult-use cannabis
retail establishment in Holyoke
• A Minority Owner of H&H CulYvaYon LLC, an applicant for a Tier III CulYvaYon and Marijuana
Product Manufacturing licenses
• A Minority Owner of Healing Calyx LLC, an Economic Empowerment applicant for retail and
delivery licenses in the City of Boston
• A Minority Owner of Mint Retail FaciliYes LLC, which is an adult-use retail applicant in the Town
of Belmont, and
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Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
• Chief Counsel of Squared Holdings LLC, which is seeking medical and adult-use licensure in
Michigan and New Jersey.
Blake also previously served as Counsel to the Hoban Law Group, the naYon’s largest cannabis business
law firm. In addiYon, Blake taught municipal process and Host Community Agreement process to the
state’s first Social Equity Training Program cohort.
2. List your execuHve team and their experience
Priscilla Brown, CEO & OperaHng Manager
• 6 years experience as a Business Analyst in the highly-regulated banking sector before entering
the legal cannabis space
• CerYfied Social Equity Applicant.
• Responsible for daily operaYons and expansion of the Strain brand.
• LinkedIn profile: hCps://www.linkedin.com/in/priscilla-b-4b291613/.
David Rabinovitz, MBA, CLFP, Finance and Business Manager
• A business consultant to engineering firms who has also consulted in the marijuana industry
across mulYple states for various clients since 2010.
• David is the Treasurer of MassCann, the oldest marijuana advocacy and educaYon organizaYon
in the state.
• David is a contract trainer for the Cannabis Control Commission Social Equity Training program
and mentors and advises numerous social equity program parYcipants.
• David is responsible for developing and implemenYng business strategy and planning for Strain
retail shops and related acYviYes (including social impact iniYaYves). He is also responsible for
monitoring financial performance.
• David is the CEO of NewCann Group, an enYty that was awarded a Host Community Agreement
for a retail store in Maynard, which was the state’s first such agreement that did not require a
locaYon and which David advocated for in an aCempt to set a precedent for the benefit for
Economic Empowerment and Social Equity applicants.
• David is a member of NaYck’s Awareness and EducaYon AcYon Team (formerly NaYck Together
for Youth). This Team is responsible for programs to minimize drug use and abuse amongst
NaYck’s student populaYon. Understanding the programs and goals of the Awareness and
EducaYon AcYon Team will be helpful in assuring Strain integrates well and responsibly into the
community.
• LinkedIn profile: hCps://www.linkedin.com/in/davidrabinovitz/
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Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
Blake M. Mensing, J.D., M.A., LL.M., Esq.
Director of Business Development and Compliance
• Served as Associate Town Counsel to Carlisle, Hamilton, Hopkinton, LiCleton, Reading,
Stockbridge, and Wellesley, MassachuseCs for three years.
• Established The Mensing Group LLC, MassachuseCs’ first, and only, law firm exclusively
dedicated to represenYng cannabis businesses pursue local permi9ng and state licensure.
• Since its incepYon in April of 2018, the firm has offered a 20% discount to Economic
Empowerment applicants, Social Equity applicants, Microbusiness applicants, and Veterans.
• Served as Counsel to the Hoban Law Group, the country’s largest cannabis business law firm
with offices in 16 states and 4 countries.
• Co-owner of Holyoke 420 LLC d/b/a Holyoke Cannabis, a retail establishment in Holyoke, MA,
which is an operaYonal adult-use cannabis retail establishment.
• Co-Chair of the Boston Bar AssociaYon’s inaugural Cannabis Law symposium and current Advisor
on the BBA’s Cannabis Industry Advisory Group.
• Named a SuperLawyers Rising Star for Cannabis Law in 2019 and 2020.
• Founder and President of Coyote Cannabis CorporaYon, a Tier I culYvaYon and manufacturing
operaYon in Uxbridge, MA, that received provisional licensure on July 9, 2020.
• Founding Member of Elevate NE, a non-profit organizaYon dedicated to cannabis educaYon, de-
sYgmaYzaYon, and restoraYve social jusYce.
• Frequent speaker at cannabis trade shows on various topics including municipal process, Host
Community Agreement negoYaYons, restoraYve social jusYce and social equity, and state
regulatory compliance. Speaker at The Harvest Cup, New England Cannabis ConvenYon, CWCB
Expo, the Boston Freedom Rally, Springfield Cannabis ConvenYon, the NaYonal Business
InsYtute, amongst others.
• Guest lecturer at Cannabis Law & Policy Courses at Suffolk University Law School and Western
New England School of Law.
• Guest lecturer at a Babson MBA markeYng course.
• ContribuYng Editor to the Cannabis Law Digest
3. List other team members you feel differenHates you
None
4. When was your company officially launched/incorporated?
i. Date of OrganizaHon: June 5, 2020
ii. The name of the proposer: Strain LLC (“Strain”)
iii. The name of the contact person: Priscilla Brown
iv. The Company’s business address is 12 West Main Street, MaCapan, MA 02126
v. The telephone number of the contact person: (617) 970-3663 [mobile]
vi. The email address of the contact person: pbrown@hunterbrownip.com
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Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
5. Is your company incorporated or a non-profit?
Strain LLC is organized as a MassachuseCs for-profit domesYc limited liability company.
6. Do you currently have an exisHng or proposed culHvaHon facility and/or product
manufacturing establishment that will supply your retail operaHon?
Priscilla and Blake intend to provide products from Coyote Cannabis CorporaYon to the Orleans store.
Blake also intends to supply products from H&H CulYvaYon. In addiYon, Blake’s clients consist of nearly
40 licensed culYvators and manufacturers that have already expressed interest in selling their products
to Strain LLC.
7. If yes, where is your culHvaHon facility, square feet, and when did you start
growing?
Coyote Cannabis CorporaYon and H&H CulYvaYon LLC, which Blake is the founder of and stakeholder in,
respecYvely, will have a cumulaYve canopy of nearly 30,000 square feet at full buildout. For context, it
typically takes 10,000 square feet of culYvaYon canopy to supply one brick and mortar retail
establishment for a full year’s operaYons. Coyote is located in Uxbridge and H&H CulYvaYon is located
in Holyoke. Neither enYty has commenced culYvaYon as Coyote is compleYng its build out under a Tier I
CulYvaYon license and H&H CulYvaYon has a pending Tier III CulYvaYon applicaYon before the Cannabis
Control Commission.
8. Do you have future plans to add culHvaHon faciliHes at the proposed retail locaHon
or at another off-site locaHon?
We have no plans to add culYvaYon to the proposed retail locaYon. As one of our founders is also the
founder of licensed culYvator Coyote Cannabis (Uxbridge, MA) and a Minority Owner of H&H CulYvaYon
(Holyoke) that has applied for a Tier III culYvaYon license, and as such, we do not plan to establish a
second culYvaYon facility in Orleans.
9. If so, what is the proposed culHvaHon canopy for the culHvaHon facility and scope of
the product manufacturing establishment?
Not applicable to our proposal in Orleans.
10.Are you seeking a host community agreement for a culHvaHon facility or product
manufacturing establishment as part of the proposed Orleans host agreement?
No, but we are seeking a companion host community agreement for home delivery via a Marijuana
Delivery license.
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Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
11.How many medical dispensaries do you currently operate and what year were they
opened?
We do not own or operate medical dispensaries.
12.List current or future plans for medical dispensaries.
The MassachuseCs medical marijuana program requires licensees to be fully verYcally integrated, which
means that medical operators grow, process, manufacture, retail, and deliver their own products. It is
anYcipated the Cannabis Control Commission will de-integrate the medical program during the next
regulatory review process. In such an event, we plan to apply for a medical retail license, which will
allow us to sell and deliver to medical marijuana paYents, as a co-located marijuana operator (meaning
we will sell adult-use and medical products from the same facility). Blake is Chief Counsel of Squared
Holdings LLC, which is seeking medical and adult-use licensure in the states of Michigan and New Jersey.
13.What marijuana approvals do you currently have from the State of Massachusefs?
If you are currently in a process for approval, please explain.
Blake Mensing is the Founder and President of Coyote Cannabis CorporaYon which holds provisional
licenses as Tier I CulYvator and a Marijuana Product Manufacturing. Blake is also a Co-Owner of Holyoke
420 LLC d/b/a Holyoke Cannabis, an operaYonal adult-use retail cannabis establishment in Holyoke.
Priscilla Brown is Coyote’s VP of Strategy. Blake is also the Minority Owner of H&H CulYvaYon LLC, an
applicant for a Tier III CulYvaYon license and Marijuana Product Manufacturing license. Blake is a
Minority Owner of Healing Calyx LLC, an Economic Empowerment Applicant for retail and home delivery
in the City of Boston.
14.Please explain your plan for public awareness and educaHon for responsible use, or
any other plans you have for public awareness, educaHon and outreach.
Youth Use PrevenYon and EducaYon Services. We will assist the Town with, and parYcipate in,
community educaYonal programs on public health, drug abuse prevenYon (including youth use
prevenYon programs). David is a member of NaYck’s Awareness and EducaYon AcYon Team (formerly
NaYck Together for Youth).
Police DRE Training. MassachuseCs’ Special Commission on OperaYng Under the Influence and Impaired
Driving developed 19 recommendaYons for state officials to consider. One recommendaYon calls for the
Municipal Police Training CommiCee to expand training of drug recogniYon experts. We would be
interested in working with the Orleans Police Department to sponsor and underwrite DRE training.
Senior EducaYon Services. We will work with the town and your Senior Center to support marijuana
educaYon programs for seniors and others interested in learning about the benefits of marijuana. This
will include informaYon on a variety of ailments including glaucoma, Parkinson’s, MulYple Sclerosis,
Crohn’s, HepaYYs C, ALS, cancer, and other diseases, but will not be medical advice as Strain is an adult-
use applicant.
Page 5Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
Veteran’s services. We will work with local veteran groups to assist veterans with PTSD or opioid pain
issues with beCer understanding cannabis and securing access, including providing discounted prices to
veterans according to need. We are very aCuned to veteran issues and The Green Rush (the weekly
show David co-hosts) recently had a well-received episode on cannabis and veterans and we believe
through our collecYve network we can bring value to area veterans.
While we are not medical professionals nor are we currently pursuing medical marijuana licensure in
MassachuseCs, we keep abreast of medical advancements and research into cannabis and new
informaYon is regularly published concerning studies and therapeuYc applicaYons for cannabis.
Training Workshops. We could host Business Training Workshops for residents interested in launching a
crat marijuana business. Social Equity program trainer, and Professor, Beth Goldstein has worked with
MassMEP and the Workforce Development Fund. Her firm is also one of the leading trainers for the
Social Equity training program. She is David’s fiancé and could be available to assist with such
workshops. We note the recent February 8, 2021, Cape Cod Times story, “Op2ons considered for
boos2ng business in Orleans,” and understand the Town’s interest in boosYng economic development.
15.Any other business experience you want to highlight.
We bring a team with deep experience. Blake was selected as a SuperLawyers Rising Star in cannabis
law for 2019 and 2020, a designaYon only granted to the top 2.5% of aCorneys in MassachuseCs
regardless of subject maCer. He is a former municipal law aCorney and served as associate town
counsel to seven municipaliYes. Blake understands the intersecYon of municipal issues and cannabis as
well or beCer than anyone in the Commonwealth.
David has nearly 40 years of business experience and serves as a consultant to C-level principals of
engineering firms in maCers of finance and strategy. He speaks at various industry events and co-hosts a
weekly cannabis talk show, The Green Rush, with Jimmy Young, on ProCannabis Business Media. David
closely follows local and naYonal market trends and his insights and guidance are regularly sought by
parYcipants in the state’s social equity training program.
Priscilla served as a Business Analyst in the highly-regulated banking industry which has set her up to run a
compliant cannabis business. In addiYon, Priscilla completed the Cannabis Control Commission’s 16-course Social
Equity Training Program, which includes a broad and deep curriculum that touches upon all aspects of starYng
and running a cannabis business in MassachuseCs.
Financial Details
16.Explain in detail your plan to finance your current Marijuana business.
We esYmate the cost to open the store at $1 million and expect to finance that with funding from the
principals, friends, and family.
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Strain LLC, Proposer
17.What credit line or funding source do you currently have? Please provide proof of
credit line and history of credit line or proof of other financing sources.
We do not plan to employ debt and will provide proof of funding at the Select Board PresentaYons as an
exhibit (we do not want the name of the financial insYtuYons or the accounts disclosed in a manner that
will create a public record due to idenYty thet concerns of certain close friends).
18.If you are planning future Marijuana businesses, how will you finance them?
This will be collecYvely our 4th license and based upon past success we believe we have a pipeline of
interested investors, subject to receipt of the HCA.
19.Do you agree to pay property taxes, even if you are a non-profit?
We are a for profit enYty and expect and agree to pay property taxes (real and personal) or PILOT fees
(payment in lieu of taxes if we were ever found to be tax exempt).
20.Detail any other financial informaHon you feel differenHates you from other
businesses.
None.
Details of Host Community Agreement (HCA)
21.Percentage of sales to Orleans
Pursuant to M.G.L. c.94G §3(5)(d), we are prepared to pay the maximum allowable community impact
fee of 3 percent of the gross sales of the marijuana establishment.
22.Yearly guaranteed money to Orleans
We will pay the 3% local opYon tax on cannabis retail establishments and an addiYonal 3% as a
community impact fee as a part of the Host Community Agreement.
23.Explain the guaranteed money vs percentage of sales in detail, if applicable.
Based upon oral arguments and the line of quesYoning from the jusYces at the MassachuseCs Supreme
Judicial Court in Mederi Inc. v City of Salem et al SJC-13010, argued Wednesday February 3, 2021, we
are loathe to agree to a payment guaranty as the jusYces seemed to imply such arrangements are not
legal and violate M.G.L. c.94G. We remain commiCed to pay Orleans the 3% local opYon tax and the 3%
community impact fee under the Host Community Agreement.
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Strain LLC, Proposer
24.Do you have the ability to pay all or a porHon of the first-year local impact fee up-
front?
Yes
25.Are you able to make payments at least quarterly?
Yes and quarterly payments seem to be standard throughout many communiYes. We would propose to
pay by calendar quarter. Hence, first quarter community impact fees would be payable within 21 days
of March 31st.
26.Will you pay for the Town’s cost to conduct an independent audit of annual sales
figures to ensure the Town’s impact fee accurately meets the requirements of the
HCA?
Yes, the costs of conducYng such an audit would be collecYble as a community impact fee under the
Host Community Agreement.
27.If not, please explain your plan for ensuring the accuracy of your payments to the
Town.
A cerYficaYon leCer from our independent outside cerYfied public accountant, issued annually to the
Town and breaking down sales by month and by quarter.
28.Are you planning to donate to a charity or non-profit that provides benefits to the
residents of Orleans?
Yes
29.If yes, please provide details of such donaHon and willingness to accept input from
the Town as to the recipient of such donaHons.
We would work with the Town to beCer understand where these donaYons are most needed and can
make the greatest impact. We are a community-concerned team.
David is part of a special crew (25+ years) at the Pan Mass Challenge that arrives one week before the
event and remains through mid-week following the event, to assist with set-up and break down
logisYcs. David coordinates the placement of excess food to shelters and kitchens and was instrumental
in the PMC receiving the Second Helping Award from the Greater Boston Food Bank. Through a program
David created, the PMC uses its excess supplies each year to support several other charity events from
Parkinson’s to Pediatric Cancer to Med Flight. David is also a Cancer-Kicker platelet donor with the Red
Cross and typically donates 26x per year. David volunteers as a mentor and coach to numerous social
equity program parYcipants seeking to start a marijuana business.
Doing right is in our DNA.
Page 8Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
30.Please explain any other potenHal financial benefits to the Town in your proposal.
We will bring an in-house home delivery service. Products sold from our Orleans store and delivered to
other Cape communiYes generate the 3% local sales (excise) tax for Orleans (regardless of where the
products are delivered) and Orleans also captures the community impact fee on those sales. Delivery
vehicles will be hybrid or electric (we prefer electric) and will be garaged in Orleans, generaYng excise
tax for the Town.
31.Describe if there are specific requirements that Orleans needs to provide to fulfill
your proposed host community agreement contract.
None
32.Any other details in the host agreement you feel differenHate you.
None
Orleans Business details
33.Size of retail store are you planning to open.
2,000 – 3,000 square feet with approximately half of the applicable square footage being dedicated to
the retail floor space and the other half of the square footage would be reserved for back of the house
operaYons, including our secure product vault.
34.Please provide a proposed plan/conceptual design for your retail store.
We do not have a conceptual design for the store as the space is quite large (7,400 SF) and we will need
only 2,000 to 3,000 for the store, we believe we will have a unique opportunity to create a memorable
customer experience. Furthermore, it is expected MassachuseCs will pass legislaYon in 2021 to allow
social consumpYon faciliYes to start licensing. These are essenYally cannabis bars where consumers can
visit and consume cannabis. Should Orleans elect to allow such faciliYes, we believe we could locate
such a facility within the 7,400 square foot premise. These factors will determine the proposed plan and
conceptual design for the store.
To provide a sense of what the store could look like, below are pictures from Blake’s current retail store,
Holyoke Cannabis.
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Strain LLC, Proposer
35.Proposed hours of operaHon.
We would seek the maximum hours permiCed under the Orleans Zoning Bylaw and we would hope that
those hours would match the hours of operaYon of any licensed package stores in the Town of Orleans.
36.Are you planning future expansion? What is your criteria/threshold to expand?
No, we do have expansion plans (beyond home delivery and the possibility of a social consumpYon
lounge should Orleans elect to parYcipate in that program).
Page 12Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
37.Do you plan to open for medical and/or recreaHonal sales on day 1 or in the future?
We are seeking an adult-use cannabis retail license and a delivery license, but not a medical license. At
such Yme as the Cannabis Control Commission verYcally de-integrates the medical program, we intend
to apply for a co-located medical retail license.
38.If you plan to open a culHvaHon and/or product manufacturing establishment in
connecHon with your retail business, what quality controls have you
implemented/plan to implement in your grow faciliHes, product development and
retail stores?
We have separate enYYes owned by Blake Mensing that has state of the art climate control systems, integrated
pest management, and that uYlize living organic soil culYvaYon methods which reduces the need for harsh
chemicals in the culYvaYon process. Coyote Cannabis CorporaYon and H&H CulYvaYon LLC will be producing
solventless cannabis concentrates, pre-rolled joints, cannagars, vaporizers, and a full line of edibles. We have
aCached Coyote Cannabis CorporaYon’s Quality Control and TesYng standard operaYng procedures, which are
the intellectual property of Blake Mensing.
39.List quality standards you follow (if applicable) for your culHvaHon and
manufacturing operaHons.
The Cannabis Control Commission requires detailed standard operaYng procedures in order to obtain
culYvaYon and manufacturing licenses, including quality control and tesYng standards, waste disposal
protocols, and the regulaYons prohibit the applicaYon of pesYcides. We have appended Coyote
Cannabis CorporaYon’s approved Quality and Control and TesYng Standard OperaYng Procedures to
this applicaYon.
40.If proposing a culHvaHon facility, please describe your renewable energy plan,
lighHng plan, water management plan and odor control plan.
Not applicable.
41.Any other details you want to provide for your proposed Orleans business.
We are a team of regular people, not backed by billionaire investors, and we strive to do good while
doing well. We are in the cannabis business because we love cannabis and social impact. This is not
something we are doing solely to make money. We actually care about being good corporate ciYzens
and good neighbors. Strain LLC is a Social Equity enYty and is majority owned by Priscilla Brown, a Black
woman and she is a member of the LGBTQ community. In addiYon, Blake’s mother lives in nearby
Harwich and the award of the Host Community Agreement would be a great excuse to make extra trips
down the Cape to see her.
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Strain LLC, Proposer
LocaHon
42.Do you have a specific locaHon under agreement? If so, please provide proof in the
form of a deed, lease agreement, purchase agreement, or lefer of commitment,
including as much detail as possible.
We have a LeCer of Intent to purchase the property at 5 Namskaket Road, Orleans (aCached hereto). If awarded
a Host Community Agreement we would enter into a Purchase and Sale Agreement with the current owner to
purchase the unit.
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Security and public safety
43.Define security plan for your retail store, including the parking area or grounds, in
detail.
We have a security plan that conforms to the requirements of 935 CMR 500.110. In light of the power of
the MassachuseCs Public Records Law, we respec|ully decline to furnish our security plan for fear that
its entry into the public domain would provide a roadmap for criminals to uYlize to breach our secured
facility. We will gladly share our full plan with the Orleans Police Department and subject it to their
approval and commentary. We have included Holyoke Cannabis’ PrevenYon of Diversion standard
operaYng procedures, which are the intellectual property of Blake Mensing.
44.Are you willing to work directly with the Orleans Police Department to develop and
implementaHon the security plan?
Absolutely, we would work with the Orleans Police Department to ensure that our facility was Yghtly secured.
45.Do you agree to have periodic reviews with the Orleans Police Department to
discuss issues and concerns?
Yes, absolutely.
46.Will you agree to a traffic study, if requested?
Yes, if warranted.
47.Any security details you want to provide that you feel differenHates you?
One of our owners, Blake Mensing, operates an adult-use retail establishment and has deep regulatory
knowledge of the Commission’s security requirements as a pracYcing Cannabis ACorney. Holyoke Cannabis
passed both the post provisional license inspecYon and the final inspecYon with zero deficiencies, which the
invesYgator noted was not at all the norm.
Timeline and Process
48.Please describe the process you will go through from execuHon of a Host
Community Agreement to opening a retail store in Orleans, including a Hmeline.
Response deadline for RFI March 17, 2021
Preliminary Review completed April 1, 2021
Community Outreach MeeYngs by applicants April 2 – April 30, 2021
PresentaYons to Select Board May 17 and May 18, 2021
Select Board decision on finalists May 26, 2021
Host Community Agreement negoYaYons begin June 7, 2021
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Strain LLC, Proposer
Finalize HCA June 17, 2021
Based upon our experience with host community agreements (our team members have been involved with
nearly 90 HCAs and 40+ licenses in MassachuseCs), we believe the HCA can be finalized within ten days. We
completed a recent HCA with KP Law in similar Yming for a new home delivery HCA. Retail HCA terms are
generally well seCled instruments.
File ApplicaYon with Commission June 30, 2021
We expect to have our applicaYon filed with the Commission within ten days thereater (we have an exisYng
retail store and have all necessary Standard OperaYng Procedures (SOPs) in place and ready). Our goal would be
to file the applicaYon by June 30.
Secure any addiYonal local Permits September 15, 2021
Provisional License September 30, 2021
As a majority social equity-owned applicant, our applicaYon will be subject to expedited review and based upon
our experience with applicaYons, we foresee minimal RFIs (requests for informaYon) from the Commission and
would expect to receive a provisional license before September 30, 2021.
Complete Build-out September 30, 2021
Build-out could commence during the summer with a goal of being complete by September 30, 2021. We would
pursue all applicable local permits during the pendency of our state applicaYons.
Apply for Final License InspecYon October 31, 2021
This would allow us to apply for an inspecYon from the Commission with a goal of being recommended for a final
license by October 31, 2021 (the Commission recently announced it is hiring 10 addiYonal inspectors to keep the
process moving efficiently).
Receive AuthorizaYon to Commence OperaYons December 10, 2021
Thereater, we would aCempt to secure authorizaYon to commence operaYons within 45 days with a goal to
open for business before year end 2021.
ApplicaHon Deposit
Applicants will be required to submit an applicaYon deposit in the form of a Cashier’s Check or Bank Check, made
payable to “Town of Orleans” in the amount of $10,000, to cover the Town’s legal costs associated with review of
documents, including but not limited to the applicant’s proposed Host Community Agreement. Applicants not
selected by the Board of Selectmen will have their applicaYon deposit returned. If legal costs exceed the
applicaYon deposit, addiYonal funds will be requested before further consideraYon will be made on an
applicaYon. Upon full execuYon of a Host Community Agreement, and all other local approvals which may require
the Town’s legal review, any excess bid deposit for legal costs will be returned to the applicant.
Priscilla Brown is hand delivering our applicaYon and a Bank Check for $10,000, today, March 17, 2021.
Page 19Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
Other details
49.Please provide any other details that you feel differenHates your company
We are a unique team with two highly experienced cannabis professionals, a Social Equity applicant as our
majority owner, and we have collecYvely been involved in securing approximately 40 licenses as well as 90 Host
Community Agreements throughout the state. Blake holds three Marijuana Establishment licenses from the
Cannabis Control Commission and is parYcipaYng in six other license applicaYons as a Minority Owner, which
includes two license applicaYons with an Economic Empowerment Priority CerYficate Holder. We are customer
driven, and not solely profit moYvated. You are likely to hear a pitch from an applicant seeking to be the next
“Apple Store of Weed.” We are not those people. As you can see from the aCached photos of Holyoke Cannabis,
we will seek to fit the character of the neighborhood in Orleans rather than imposing our vision of what the
neighborhood should be.
Other mafers
Grading Criteria #7
We have also aCached the state-approved Holyoke 420 LLC d/b/a Holyoke Cannabis personnel policies to address
grading criterion number 7 in the Request for InformaYon as there was no other avenue to provide that
informaYon in the quesYons posed in the RFI. In addiYon, all staff will be required to annually take the state-
mandated Responsible Vendor Training course to ensure the ability to run a compliant operaYon.
Grading Criteria #8
Similarly, for grading criterion number 8, we have aCached Holyoke Cannabis’ inventory standard operaYng
procedures, which are the intellectual property of Blake Mensing and which we will adapt for use in Orleans.
Security Plan
As noted above, any applicant who furnishes a complete security plan as part of this applicaYon is exposing those
plans to public disclosure under the Public Records Law which absolutely obviates their efficacy. We will gladly
share the full security plan with the Orleans Police Department so that it is not subject to public disclosure.
Grading Criteria #9
We have done our best to address all of the grading criteria, but the Request for InformaYon did not contain
quesYons that hit all of the required metrics, including those addressed above and also specifically including
criteria number 9 on parking and traffic plans, which we will be happy to describe in detail to the Board of
Selectmen or as part of the special permit process before the Board of Appeals. The Town of Orleans
Zoning Bylaw, in SecYon 164-40.4 and SecYon 164-13 Schedule of Use RegulaYons, requires an adult-use retail
marijuana establishment to obtain a Special Permit from the Orleans Board of Appeals and the following
standards would apply:
5 Namskaket Road, Orleans, MA, is located in the General Business Zoning District and would, pursuant to
Warrant ArYcle 37 of the Special Town MeeYng of October 31, 2020, which the MassachuseCs ACorney General’s
Municipal Law Unit approved on December 8, 2020, require a special permit to be issued by the Board of Appeals
in order for Strain LLC to be eligible to operate an adult-use cannabis retail establishment.
Page 20Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
Diversity
Our commitment to diverse hiring starts at the top with our majority owner being a Social Equity applicant, a
woman, Black, and a member of the LGBTQ community. We are commiCed to hiring diverse applicants, both
because it is the right thing to do, and because the Cannabis Control Commission’s regulaYons require a Diversity
Plan as a funcYon of licensure. We will seek to employ Orleans residents (goal of 50%), uYlize local contractors,
and aim to be staffed with at least 50% of the staff being made up of women, minoriYes, veterans, or members of
the LGBTQ community.
Please direct quesYons or requests for supplemental informaYon to:
Priscilla Brown
(617) 970-3663 [mobile]
pbrown@hunterbrownip.com
Blake Mensing
(617) 333-8725 [Direct]
blake@mensinggroup.com
Page 21Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
COYOTE CANNABIS CORPORATION
Procedures for Quality Control and TesYng of Product
Pursuant to 935 CMR 500.160, Coyote LLC (Coyote) will not sell or market any marijuana product that is not capable
of being tested by licensed Independent TesYng Laboratories. TesYng of marijuana products shall be performed by
an Independent TesYng Laboratory in compliance with the Protocol for Sampling and Analysis of Finished Medical
Marijuana Products and Marijuana-infused Products, as amended in November 2016 and published by the
MassachuseCs Department of Public Health. Every marijuana product sold will have a set of specificaYons which
define acceptable quality limits for cannabinoid profile, residual solvents, metals, bacteria, and pesYcides.
Coyote shall implement a wriCen policy for responding to laboratory results that indicate contaminant levels that
are above acceptable levels established in DPH protocols idenYfied in 935 CMR 500.160(1) and subsequent
noYficaYon to the Commission of such results. Results of any tests will be maintained by Coyote for at least one
year. All transportaYon of marijuana to or from tesYng faciliYes shall comply with 935 CMR 500.105(13) and any
marijuana product returned to Coyote by the tesYng facility will be disposed of in accordance with 935 CMR
500.105(12). Coyote shall never sell or market adult use marijuana products that have not first been tested by an
Independent TesYng Laboratory and deemed to comply with the standards required under 935 CMR 500.160.
Coyote’s policies include requirements for handling of marijuana, pursuant to 935 CMR 500.105(3), including
sanitary measures that include, but are not limited to: hand washing staYons; sufficient space for storage of
materials; removal of waste; clean floors, walls and ceilings; sanitary building fixtures; sufficient water supply and
plumbing; and storage faciliYes that prevent contaminaYon. All Coyote staff will be trained and ensure that
marijuana and marijuana products are handled with the appropriate food handling and sanitaYon standards. Coyote
will ensure the proper equipment and storage materials, including adequate and convenient hand washing faciliYes;
food-grade stainless steel tables; and temperature- and humidity- control storage units, refrigerators, and freezers.
Coyote’s Director of Compliance will provide quality control oversight over all marijuana products purchased from
wholesale suppliers and sold to licensed adult-use cannabis retail establishments within the Commonwealth of
MassachuseCs. All Coyote staff will immediately noYfy the Director of Compliance of any actual or potenYal quality
control issues, including marijuana product quality, facility cleanliness/sterility, tool equipment funcYonality, and
storage condiYons. All issues with marijuana products or the facility will be invesYgated and immediately recYfied by
the Director of Compliance, including measures taken, if necessary, to contain and dispose of unsafe products. The
Director of Compliance will closely monitor product quality and consistency, and ensure expired products are
removed and disposed.
All Coyote staff will receive relevant quality assurance training and provide quality assurance screening of marijuana
flower, to ensure it is well cured and free of seeds, stems, dirt, and contaminaYon, as specified in 935 CMR
500.105(3)(a), and meets the highest quality standards. All staff will wear gloves when handling marijuana and
marijuana products, and exercise frequent hand washing and personal cleanliness, as specified in 935 CMR
500.105(2). Marijuana products will be processed in a secure access area of Coyote.
Coyote management and inventory staff will conYnuously monitor quality assurance of marijuana products and
processes, and prevent and/or miYgate any deficiencies, contaminaYon, or other issues which could harm product
safety.
Page 22Adult-Use Marijuana Retailer RFI - Orleans March 17, 2021
Strain LLC, Proposer
Any spoiled, contaminated, dirty, spilled, or returned marijuana products are considered marijuana waste and
will follow Coyote procedures for marijuana waste disposal, in accordance with 935 CMR 500.105(12).
Marijuana waste will be regularly collected and stored in the secure-access, locked inventory vault.
Pursuant to 935 CMR 500.105(11)(a)-(e), Coyote shall provide adequate lighYng, venYlaYon, temperature,
humidity, space and equipment, in accordance with applicable provisions of 935 CMR
500.105 and 500.110. Coyote will have a separate area for storage of marijuana that is outdated, damaged,
deteriorated, mislabeled, or contaminated, or whose containers or packaging have been opened or breached,
unless such products are destroyed. Coyote storage areas will be kept in a clean and orderly condiYon, free
from infestaYons by insects, rodents, birds and any other type of pest. The Coyote storage areas will be
maintained in accordance with the security requirements of 935 CMR 500.110.
All tesYng results will be maintained by Coyote for no less than one year in accordance with 935 CMR
500.160(3).
Pursuant to 935 CMR 500.160(9), no marijuana product shall be sold or marketed for sale that has not first been
tested and deemed to comply with the Independent TesYng Laboratory standards.
Page 1HOLYOKE 420 LLC
STANDARD OPERATING PROCEDURES FOR INVENTORY CONTROL
INVENTORY PROCEDURES
HOLYOKE 420 LLC (“HOLYOKE 420” or the “Company”) will ensure that its inventory control
procedures meet or exceed all of the Massachusetts Cannabis Control Commission’s regulations found
at 935 CMR 500,00 et seq.
HOLYOKE 420 shall utilize a Commission-approved seed-to-sale software program capable of
interfacing with the Commonwealth’s METRC software platform and that include tags with unique
alpha-numeric codes to identify and track all marijuana and marijuana-infused products.
The Company shall maintain a real-time inventory pursuant to 935 CMR 500.105(8)(c) and (d), with
said real-time inventory to include all marijuana and marijuana-infused products in its facility
inventory. 935 CMR 500.002 provides the following definition: Real-time Inventory or Seed-to-sale
tracking means an electronic system that provides the electronic tracking of an individual cannabis or
marijuana plant, including its cultivation, growth, harvest and preparation of cannabis or marijuana
products, if any, and final sale. It will also be able to track registered marijuana establishment agents’
involvement with any marijuana or marijuana-infused products located at the retail establishment
facility. At all retail points of sale at the facility, HOLYOKE 420’s registered marijuana establishment
agents shall utilize the seed-to-sale tracking methodology approved by the Commission under 935
CMR 500.000.
HOLYOKE 420 shall:
• Establish inventory controls and procedures for the conduct of inventory reviews, and shall
further establish comprehensive inventories of marijuana products in the retail establishment;
• Conduct a monthly inventory of marijuana in the retail establishment (including products
present in the facility’s limited access areas);
• Conduct a comprehensive annual inventory;
• Promptly transcribe inventories if taken by use of an audio recording device. The record of each
inventory shall include but not limited to:
◦ Inventory Date
◦ Inventory Summary
◦ Findings (if necessary)
◦ Names, signatures, and titles of the registered marijuana establishment agent(s) who
conducted the inventory.Registered marijuana establishment agents that identify any discrepancies during inventory will report such discrepancy to the Commission if an internal audit and investigation fails to resolve the discrepancy. Discrepancies caused by diversion or theft will be promptly reported (and in no event longer than 24 hours after discovery, pursuant to 935 CMR 500.110(7)(a)(1)) to the Cannabis Control Commission and the Town of Holyoke’s Police Department. No marijuana product, including marijuana, shall be sold or otherwise marketed for adult-use that is not capable of being tested by Independent Testing Laboratories, except as allowed under 935 CMR 500.000. HOLYOKE 420 will adhere to all applicable tax laws in the Commonwealth, including, but not limited to, the laws regarding taxation, filing, seizure, and audit.
HOLYOKE 420 LLC
Personnel Policies
HOLYOKE 420 LLC (“HOLYOKE 420”) has drafted and instituted these personnel policies to provide
equal opportunity in all areas of employment, including hiring, recruitment, training and development,
promotions, transfers, layoff, termination, compensation, benefits, social and recreational programs,
and all other conditions and privileges of employment, in accordance with applicable federal, state, and
local laws. HOLYOKE 420 shall make reasonable accommodations for qualified individuals with
demonstrated physical or cognitive disabilities, in accordance with all applicable laws. In accordance
with 935 CMR 500.101(2)(e)(8)(h), HOLYOKE 420 is providing these personnel policies, including
background check policies, for its adult-use Marijuana Establishment that will be located in the Town
of Holyoke, MA.
Management is primarily responsible for seeing that equal employment opportunity policies are
implemented, but all members of the staff share the responsibility for ensuring that, by their personal
actions, the policies are effective and apply uniformly to everyone. Any employee, including managers,
that HOLYOKE 420 determines to be involved in discriminatory practices are subject to disciplinary
action and may be terminated. HOLYOKE 420 strives to maintain a work environment that is free from
discrimination, intimidation, hostility, or other offenses that might interfere with work performance. In
keeping with this desire, we will not tolerate any unlawful harassment of employees by anyone,
including any manager, co-worker, vendor or clients.
In accordance with 935 CMR 500.105 (1), General Operational Requirements for Marijuana
Establishments, Written Operating Procedures, as a Marijuana Establishment, HOLYOKE 420 has and
follows a set of detailed written operating procedures for each location. HOLYOKE 420 has developed
and will follow a set of such operating procedures for each facility. HOLYOKE 420’s operating
procedures shall include, but are not necessarily limited to the following:
(a) Security measures in compliance with 935 CMR 500.110;
(b) Employee security policies, including personal safety and crime prevention techniques;
(c) A description of the Marijuana Establishment’s hours of operation and after-hours contact
information, which shall be provided to the Commission, made available to law enforcement
officials upon request, and updated pursuant to 935 CMR 500.000.
(d) Storage of marijuana in compliance with 935 CMR 500.105(11);
(e) Description of the various strains of marijuana to be cultivated, processed or sold, as applicable,
and the form(s) in which marijuana will be sold;
(f) Procedures to ensure accurate record-keeping, including inventory protocols in compliance with
935 CMR 500.105(8) and (9);
(g) Plans for quality control, including product testing for contaminants in compliance with 935
CMR 500.160;
(h) A staffing plan and staffing records in compliance with 935 CMR 500.105(9);
(i) Emergency procedures, including a disaster plan with procedures to be followed in case of fire
or other emergencies;
(j) Alcohol, smoke, and drug-free workplace policies;(k) A plan describing how confidential information will be maintained;
(l) A policy for the immediate dismissal of any marijuana establishment agent who has:
1. Diverted marijuana, which shall be reported to law enforcement officials and to the
Commission;
2. Engaged in unsafe practices with regard to operation of the Marijuana Establishment, which
shall be reported to the Commission; or
3. Been convicted or entered a guilty plea, plea of nolo contendere, or admission to sufficient
facts of a felony drug offense involving distribution to a minor in the Commonwealth, or a
like violation of the laws of another state, the United States or a foreign jurisdiction, or a
military, territorial, or Native American tribal authority.
(m) A list of all board members and executives of a Marijuana Establishment, and members, if any,
of the licensee must be made available upon request by any individual. 935 CMR 500.105(1)
(m) requirement may be fulfilled by placing this information on the Marijuana Establishment’s
website.
(n) Policies and procedures for the handling of cash on Marijuana Establishment premises
including but not limited to storage, collection frequency, and transport to financial
institution(s).
(o) Policies and procedures to prevent the diversion of marijuana to individuals younger than 21
years old.
(p) Policies and procedures for energy efficiency and conservation that shall include:
1. Identification of potential energy use reduction opportunities (including but not limited to
natural lighting, heat recovery ventilation and energy efficiency measures), and a plan for
implementation of such opportunities;
2. Consideration of opportunities for renewable energy generation, including, where
applicable, submission of building plans showing where energy generators could be placed
on the site, and an explanation of why the identified opportunities were not pursued, if
applicable;
3. Strategies to reduce electric demand (such as lighting schedules, active load management
and energy storage); and
4. Engagement with energy efficiency programs offered pursuant to M.G.L. c. 25, § 21, or
through municipal lighting plants.
In accordance with 935 CMR 500.105(2), all of HOLYOKE 420’s current owners, managers and
employees that are involved in the handling and sale of marijuana will successfully complete
Responsible Vendor Training Program, and once designated a “responsible vendor” require all new
employees involved in handling and sale of marijuana to complete this program within 90 days of hire.
This program shall then be completed annually and those not selling or handling marijuana may
participate voluntarily. HOLYOKE 420 shall maintain records of responsible vendor training
compliance, pursuant to 935 CMR 500.105(2)(b). Responsible vendor training shall include: discussion
concerning marijuana effect on the human body; diversion prevention; compliance with tracking
requirements; identifying acceptable forms of ID, including medical patient cards; and key state and
local laws.All employees of HOLYOKE 420 will be duly registered as marijuana establishment agents and have
to complete a background check in accordance with 935 CMR 500.030(1). All marijuana establishment
agents will complete a training course administered by HOLYOKE 420 and complete a Responsible
Vendor Program in compliance with 935 CMR 500.105(2)(b). Employees will be required to receive a
minimum of eight hours of on-going training annually pursuant to 935 CMR 500.105(2)(a).
In accordance with 935 CMR 500.105 (9), General Operational Requirements for Marijuana
Establishments, Record Keeping, HOLYOKE 420’s personnel records will be available for inspection
by the Commission, upon request. HOLYOKE 420’s records shall be maintained in accordance with
generally accepted accounting principles. Written records that are required and are subject to inspection
include, but are not necessarily limited to, all records required in any section of 935 CMR 500.000, in
addition to the following:
The following HOLYOKE 420 personnel records:
1. Job descriptions for each employee and volunteer position, as well as organizational
charts consistent with the job descriptions;
2. A personnel record for each of HOLYOKE 420’s marijuana establishment agents.
Such records shall be maintained for at least 12 months after termination of the
individual’s affiliation with HOLYOKE 420 and shall include, at a minimum, the
following:
a. all materials submitted to the Commission pursuant to 935 CMR 500.030(2);
b. documentation of verification of references;
c. the job description or employment contract that includes duties, authority,
responsibilities, qualifications, and supervision
d. documentation of all required training, including training regarding privacy and
confidentiality requirements, and the signed statement of the individual indicating
the date, time, and place he or she received said training and the topics discussed,
including the name and title of presenters;
e. documentation of periodic performance evaluations;
f. a record of any disciplinary action taken; and
g. notice of completed responsible vendor and eight-hour related duty training.
3. A staffing plan that will demonstrate accessible business hours and safe cultivation
conditions;
4. Personnel policies and procedures; and
5. All background check reports obtained in accordance with 935 CMR 500.030.
Following closure of a Marijuana Establishment, all records must be kept for at least two years at the
expense of the Marijuana Establishment and in a form and location acceptable to the Commission.
HOLYOKE 420 understands that in the event that HOLYOKE 420 were to close, all records will be
kept for at least two years at the expense of HOLYOKE 420.HOLYOKE 420, LLC
Prevention of Diversion
HOLYOKE 420, LLC’s (“HOLYOKE 420”) anti-diversion procedures include methods for identifying,
recording, and reporting diversion, theft, or loss and for correcting all errors and inaccuracies in
inventories. The integrity of the supply chain in every stage from seed to sale shall be protected through
anti-diversion methods using a comprehensive security system. All employees shall receive anti-
diversion training as part of their initial and subsequent training. HOLYOKE 420 has worked diligently
to foster a work environment that values employees and that demands a culture of professional
responsibility to mitigate risk and create a safe work environment that our employees take pride in.
Pursuant to 935 CMR 500.105(1)(l), HOLYOKE 420’s written operating procedures will include a
policy for the immediate dismissal of any marijuana establishment agent who has diverted marijuana.
HOLYOKE 420 will perform periodic supply chain risk assessments to minimize weak spots and
ensure continuity in the supply of high-quality independently-tested cannabis products. Any and all
discrepancies identified in HOLYOKE 420’s inventory system during a routine or special audit shall
immediately be recorded and investigated as to the root cause. Pursuant to 935 CMR 105(13)(b), any
incidents of diversion that occur during transport between marijuana establishments shall be duly
reported to the Cannabis Control Commission and the applicable law enforcement authorities at the
local and state levels not more than 24 hours of discovery of any incident. In addition, discrepancies
shall be recorded and reported according to HOLYOKE 420’s incident response plan.
In accordance with 935 CMR 500.140(4), all on site transactions are limited to one ounce of marijuana
to a customer per transaction. Random and routine monitoring and surveillance cameras shall be
performed by security personnel.
Inventories will be highly restricted, secured, and surveilled areas with posted limited access. Only
managers or designated inventory staff shall have security designations to access stored inventory.
Monthly inventory checks in compliance with 935 CMR 105(8)(c)(2) will be conducted. A retail
marijuana establishment agent’s inventory shall remain locked and accessible only to that agent and a
manager. The manager shall conduct routine and random auditing of retail marijuana establishment
agents’ inventory. Sales shall be documented, recorded and stored using seed-to-sale inventory
tracking. Surveillance cameras shall record and store all transactions in compliance with 935 CMR
500.110(5)(a)(4).
A copy of the shipping manifest shall be transmitted to the receiving dispensary prior to transport. All
dispensary deliveries shall be processed prior to leaving a marijuana establishment in accordance with
935 CMR 500.105(13)(a)(7). Pursuant to 935 CMR 500.105(13)(a)(6) all vehicles transporting
marijuana products will be staffed with a minimum of two marijuana establishment agents and one
agent shall remain with the transportation vehicle at all time. Delivery routes and times will be
randomized as required by 935 CMR 500.105(13)(a)(12). Once the delivered products are accounted
for, they shall be stored in the securely locked, and continuously monitored, safe room, which shall be a
limited access area.You can also read
