Glass House Brands Master Diligence Binder Regulatory / Accounting / Licensing / FOIA-PRA Work Product Bundle Prepared July 10, 2026 Prepared from the full deliverables bundle at: /Users/icloudabe/GLASSHOUSE_DILIGENCE_FULL_BUNDLE_2026-07-10 Important caveat: This binder is research/request work product. It is not legal advice, accounting advice, or an accusation of wrongdoing. Nonpublic agency records still require PRA/FOIA/subpoena/company-request processes. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 1 Table of Contents 1. README / Bundle Overview 2. Memos 01–08 3. PRA / FOIA / Company Request Packets 4. Tables / Trackers 5. Source Index Glass House Brands Master Diligence Binder — research work product, not legal advice Page 2 README / Bundle Overview Glass House Brands diligence bundle Prepared: July 10, 2026 Matter: Public-record/regulatory diligence package concerning Glass House Brands Inc., Glass House Retail, LLC, NSJB Investments LLC, Glass House Camarillo Cultivation LLC, Beach Front/Beachfront-related entities, Rosenwald/Dalton-linked entities, NYSE uplisting exposure, DCC/local cannabis licensing, ASC 810 deconsolidation, July 2025 federal raid/labor exposure, Schedule III/adult-use boundary, and related-party governance. Important caveats • This is a research and diligence work-product bundle, not legal advice, accounting advice, or an accusation of wrongdoing. • It distinguishes public-record facts from allegations, exposure theories, and records that must be obtained by PRA/FOIA/subpoena/company request. • No PRA/FOIA requests have been filed by this bundle itself. The request letters are ready-to-submit templates and require requester identity/contact details. • No subpoenas have been issued; subpoena schedules are for counsel/investigator use in a properly authorized proceeding. • Some agency records may be withheld or redacted because of open investigations, law-enforcement exemptions, privacy, trade secrets, security plans, personnel records, or criminal-background information. Bundle contents Memos 1. memos/01_Master_Due_Diligence_Memo.md 2. memos/02_ASC_810_De_Facto_Control_Issue_Memo.md 3. memos/03_DCC_Local_Licensing_Matrix.md 4. memos/04_Federal_Raid_Labor_FOIA_PRA_Memo.md 5. memos/05_Related_Party_Governance_Memo.md 6. memos/06_Schedule_III_Adult_Use_NYSE_Memo.md 7. memos/07_Hemp_Export_Compliance_Addendum.md 8. memos/08_Missing_Agreements_Request_Memo.md 9. memos/09_Local_KB_Cross_Reference_Addendum.md Requests • requests/DCC_PRA_Citation_CCL21-0005116.txt • requests/DCC_PRA_GHR_NSJB_Ownership_Control.txt • requests/Local_Cannabis_PRA_Template.txt • requests/DHS_ICE_HSI_FOIA_Raid.txt • requests/CBP_FOIA_Raid.txt • requests/DOL_WHD_FOIA.txt • requests/CalOSHA_DIR_PRA.txt • requests/Company_Auditor_ASC810_Request.txt • requests/NYSE_SEC_Correspondence_Request.txt Glass House Brands Master Diligence Binder — research work product, not legal advice Page 3 • requests/Entity_Beneficial_Owner_Mapping_Request.txt Tables / trackers • tables/Related_Party_Ledger.csv • tables/Regulatory_Exposure_Matrix.csv • tables/Request_Tracker.csv • tables/Local_Cannabis_Agency_Matrix.csv • tables/Cross_Reference_Findings.csv • tables/KB_Confidentiality_Log.csv • source_index/Source_Index.csv • source_index/Source_Index.md Glass House Brands Master Diligence Binder — research work product, not legal advice Page 4 Memos Glass House Brands Master Diligence Binder — research work product, not legal advice Page 5 01_Master_Due_Diligence_Memo.md Master due diligence memo Executive summary The public record supports a high-priority diligence program around seven exposure categories: 1. ASC 810 / de facto control challenge. Glass House Brands filed public transaction documents showing Glass House Retail, LLC was separated for U.S. GAAP deconsolidation purposes, while Glass House retained 900 exchangeable units and extensive protection rights. The issue is whether Glass House truly lost control or retained power/economics sufficient to require consolidation. 2. DCC/local ownership-control approval gap. SEC transaction documents reference DCC and local cannabis regulatory approvals as closing conditions, but the approval records themselves are not publicly attached. 3. Federal raid/labor investigation exposure. Glass House publicly disclosed July 10, 2025 federal raids at two farms, immigration-warrant scope, reported mass detentions/arrests, reported minors, a contractor worker death, and remedial measures. 4. DCC Citation and Fine. DCC publicly lists a Citation and Fine for Glass House Camarillo Cultivation LLC, license CCL21-0005116, effective May 15, 2026. The fine amount and factual basis are not public on the listing page. 5. Related-party governance. Public filings disclose relationships and payments involving Beach Front Property Management, Jon A. Neu Insurance, 5042 Real Estate Investment, 3645 Long Beach LLC, Kazan Trust, and preferred equity held by insiders. 6. Schedule III/adult-use boundary. Glass House's NYSE thesis depends on separating medical/Schedule III from adult-use/non-medical cannabis exposure. 7. Missing CSA/notes/side letters. Unfiled documents may materially affect control, economics, and disclosure analysis. Public-record findings Deconsolidation document package The June 17, 2026 SEC Form 6-K exhibit index lists the core public documents: Material Change Report, Second Amended and Restated LLC Agreement, Class A Unit Purchase Agreement, Protection Agreement, Unaudited Pro Forma Financial Statements, and news release. The LLC Agreement states the deconsolidation transaction separates Glass House Retail from Glass House's consolidated financial statements for U.S. GAAP purposes; the Unit Purchase Agreement and Protection Agreement define the economics and control architecture. DCC Citation and Fine DCC's public compliance page lists a Citation and Fine for Glass House Camarillo Cultivation LLC, license CCL21-0005116, cultivation annual license, effective May 15, 2026. The entry identifies 4 CCR §17800, 4 CCR §15042, and BPC §26160 in the retrieved page. DCC also states its compliance-action table includes denials, citations, fines, suspensions, and revocations, and that APA Orders of Decision have not been issued for these table matters unless otherwise provided on final-decision pages. Federal raid/labor exposure Glass House's August 4, 2025 release states federal officers led by ICE/DHS raided two farms on July 10, 2025, under a warrant for evidence of possible Title 8 immigration violations; approximately 360 people were reported detained/arrested; nine Glass House employees were detained/arrested; approximately eleven minors were reportedly detained; one third-party contractor employee died from injuries sustained during the raid; and Glass House terminated two farm labor contractors, Glass House Brands Master Diligence Binder — research work product, not legal advice Page 6 implemented E-Verify/document review and age-gating controls, hired Guidepost Services, and signed a labor peace agreement. NYSE and Schedule III Glass House announced on June 25, 2026 that its subordinate voting shares were approved for NYSE listing and expected to trade as GLAS beginning June 30, 2026. The company connected the listing to the reclassification of medical cannabis to Schedule III. DEA materials show medical marijuana Schedule III actions and broader marijuana rescheduling proceedings are distinct regulatory actions. Hemp/export add-on On July 7, 2026, Glass House announced its first international sale of smokeable CBD biomass to Europe from Greenhouse 4 at the Camarillo Farm. This creates a new diligence lane around hemp registration, THC-threshold testing, export documentation, customs, buyer/import permits, EU member-state rules, product claims, and segregation from cannabis operations. Highest-value next actions 1. File DCC PRA for CCL21-0005116 citation/fine packet. 2. File DCC PRA for Glass House Retail / NSJB ownership-control approval and FIH records. 3. File local PRA requests to each retail-license jurisdiction. 4. Send company/auditor ASC 810 request for technical memo, CSA/MSA, Purchase Note, Repurchase/Put Note, side-letter certification, board/audit committee materials, and auditor sign-off. 5. File ICE/HSI, CBP, DOL/WHD, and Cal/OSHA/DIR records requests. 6. Build entity/beneficial-owner map using CA SOS, county recorder/assessor, UCC, SEC/SEDAR/SEDI, ADV, 13F/13D/13G, and DCC owner/FIH records. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 7 02_ASC_810_De_Facto_Control_Issue_Memo.md ASC 810 / de facto control issue memo Objective Test whether the Glass House Retail deconsolidation is robust under ASC 810 or vulnerable to challenge by auditors, the SEC, NYSE, DCC/local regulators, or securities plaintiffs. Public structure • Glass House Retail, LLC is a California LLC. • NSJB Investments LLC acquired 100 Class A voting units for stated aggregate consideration of $2.5 million. • GHB Usub, LLC retained 900 Exchangeable Units that are non-voting/non-participating until conversion. • The transaction documents state the separation is intended to remove Glass House Retail from Glass House's consolidated financial statements for U.S. GAAP purposes. • The Pro Forma Financial Statements recognize a retained investment and remove Glass House Retail results from Glass House's consolidated presentation. Key ASC 810 questions 1. Is GHR a VIE? Investigate whether GHR has sufficient equity at risk and whether NSJB's equity is substantive. A key fact is that NSJB's $2.5 million purchase price appears to be funded by a Purchase Note rather than an independent cash investment. 2. Who has power over significant activities? Documents should be tested for who controls budgets, pricing, inventory procurement, staffing, hiring/firing, cash management, regulatory compliance, banking, leasing, license strategy, retail promotions, litigation, and vendor contracts. The unfiled CSA/MSA is likely decisive. 3. Are Glass House's rights protective or participating? The Protection Agreement includes broad consent rights over debt, equity issuance, distributions, mergers, asset sales, dissolution, NSJB affiliate related-party transactions, out-of-state expansion, cannabis-license-threatening conduct, criminal/material civil liability, and actions that could cause Glass House NYSE delisting or continued-listing failure. Counsel/accountants should determine whether these are merely protective rights or participating rights that retain power. 4. Does Glass House retain significant economics? Glass House retained 900 exchangeable units and recognized a retained investment. The pro forma impact is material to revenue and loss presentation. Analyze whether retained economics, repurchase/call/put provisions, notes, and side arrangements create a primary-beneficiary conclusion. 5. Are NSJB and its principals independent? Request source of funds, beneficial ownership, related-party questionnaires, DCC background materials, any Glass House support/guarantee, and communications showing whether NSJB acts independently. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 8 Documents required 1. Management ASC 810 memo. 2. Auditor concurrence/consultation memo. 3. Audit committee minutes and board decks. 4. CSA/MSA and service schedules. 5. Purchase Note and all note amendments. 6. Repurchase/Put Note form and terms. 7. Source-of-funds and beneficial-owner certifications for NSJB. 8. Side-letter/no-side-letter certificate. 9. DCC/local approval letters and owner/FIH submissions. 10. Accounting valuation/fairness materials. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 9 03_DCC_Local_Licensing_Matrix.md DCC and local cannabis licensing matrix DCC state-level targets CCL21-0005116 citation package Request all records concerning the DCC Citation and Fine effective May 15, 2026 against Glass House Camarillo Cultivation LLC, license CCL21-0005116, including citation/order, fine amount, service records, inspection/audit records, access/sign-in/sign-out records, licensee records requests, photos/video, corrective action, payment/collection, appeal/informal conference, settlement, and final disposition. Glass House Retail / NSJB ownership-control records Request all ownership/control/change-of-ownership records concerning Glass House Retail, LLC; NSJB Investments LLC; GHB Usub, LLC; Glass House Brands Inc.; Jared Beilke; Nicholas Sarris; and any retail licensee transferred or proposed for transfer to GHR. DCC regulatory concepts to test • Owners: individuals/entities meeting ownership thresholds or managing/directing/controlling operations. • Financial-interest holders: lenders, profit participants, sub-threshold equity holders, and other economic stakeholders. • Form 27 / DCC LIC 027: license modifications/change notifications. • License non-transferability: ownership changes and complete transfers require timely disclosure and, in some cases, new license approval before operations under new structure. Local agency targets Site DCC license Legal name Local agency targets Farmacy Berkeley C10-0000506-LIC ICANN LLC City of Berkeley Finance/business license; Planning/Development/permits Farmacy Isla Vista C10-0001190-LIC Farmacy Isla Vista LLC Santa Barbara County CEO Cannabis Regulation & Licensing; Planning & Development Farmacy Santa Ana C10-0000044-LIC Bud and Bloom City of Santa Ana Commercial Cannabis / Planning The Farmacy Santa Barbara C10-0000293-LIC Farmacy SB Inc. City of Santa Barbara cannabis permits The Farmacy SY C10-0001124-LIC SBDANK LLC Santa Barbara County cannabis licensing; Planning; Sheriff/background records NHC Grover Beach C10-0000388-LIC Natural Healing Center LLC City of Grover Beach Commercial Cannabis / Community Development NHC Lemoore C10-0000734-LIC NHC Lemoore LLC City of Lemoore Police Department; City Manager; Council; Clerk NHC Morro Bay C10-0000797-LIC NHC-MB LLC City of Morro Bay Community Development; permit committee; City Manager Glass House Brands Master Diligence Binder — research work product, not legal advice Page 10 Site DCC license Legal name Local agency targets NHC Turlock C10-0000988-LIC NHC Turlock LLC City of Turlock Police; Planning; City Clerk The Pottery LA C10-0000389-LIC The Pottery Inc. Los Angeles Department of Cannabis Regulation; DCR Access/licensing records Local records to request • Local cannabis permit/license applications and renewals. • Ownership/control transfer applications and approvals. • Local authorization letters to DCC. • CUP/development agreement files. • Business-license tax records, where disclosable. • Staff reports, council/commission packets, public hearing materials. • Inspection/fire/building/code-enforcement records. • Communications with DCC and Glass House/GHR/NSJB. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 11 04_Federal_Raid_Labor_FOIA_PRA_Memo.md Federal raid / labor FOIA-PRA memo Public facts to distinguish from allegations Glass House's public statement says federal officers led by ICE/DHS raided two farms on July 10, 2025 under a search warrant for evidence of possible Title 8 immigration violations. The company reported approximately 360 detentions/arrests, nine direct Glass House employees detained/arrested, reports of approximately eleven minors detained, a third-party contractor worker death, and post-raid remediation. This public record does not establish a final adjudication that Glass House knowingly employed minors, committed wage violations, or engaged in trafficking. Requests should use neutral language: "records concerning potential or alleged violations." Agencies and likely records ICE / HSI Likely records: investigation memoranda, worksite-enforcement records, I-9 audits, warrants/returns/inventories, detention aggregate data, operational plans, after-action reports, incident reports, communications with CBP/DOL/DCC/Cal-OSHA/USAO. CBP / Border Patrol Likely records: operational participation records, perimeter/security plans, incident logs, use-of-force records, body camera/video if any, detainee transport logs, deconfliction communications. DOL / WHD Likely records: child labor, MSPA, FLSA, farm-labor-contractor investigation files, payroll audits, complaints, settlements/citations, interagency communications. Cal/OSHA / DIR Likely records: fatality/serious-injury investigation concerning Jaime Alanis Garcia, employer/contractor identification, field notes, citations, penalties, photos/video, fall-protection/roof-access analyses. USAO-CDCA / Federal court Court warrant records are not obtained through FOIA. Use PACER and clerk/counsel procedures for warrant dockets, sealing orders, returns, and motions to unseal. Expected obstacles • FOIA Exemption 7(A): active law-enforcement proceedings. • Exemption 7(E): law-enforcement techniques/procedures. • Exemptions 6 and 7(C): privacy of workers, minors, detainees, and agents. • Exemption 4: confidential commercial information. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 12 • California PRA law-enforcement/investigatory exemptions for open Cal/OSHA/DCC investigations. Strategy 1. Submit narrow initial requests for date-bounded records from June 1, 2025 to August 31, 2025. 2. Submit broader contractor/labor requests from January 1, 2024 to present. 3. Ask for aggregate/de-identified data to avoid privacy denial. 4. Ask for rolling productions and segregable non-exempt portions. 5. Track denials for administrative appeals and renewed requests once investigations close. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 13 05_Related_Party_Governance_Memo.md Related-party governance memo Objective Build a defensible related-party ledger and identify governance/document gaps after the NYSE uplisting. Publicly disclosed Glass House related-party categories 1. Beach Front Property Management Inc. — consulting agreement for M&A advisory and real-estate acquisition/financing services; majority-owned by an executive and certain board members. 2. Jon A. Neu Insurance — insurance brokerage services; majority-owned by Beach Front Property Management in public annual filing descriptions. 3. 5042 Real Estate Investment LLC — partially owned by an executive/board member; leases property to a subsidiary; consolidated in 2025 according to public disclosures. 4. 3645 Long Beach LLC — partially owned by an executive/board member; headquarters/lease relationship. 5. Kazan Trust dated December 10, 2004 — trust relationship tied to real-estate leasing. 6. Preferred equity holders — certain executive officers/directors hold preferred equity interests in GH Group. Rosenwald / Dalton / Beach Front mapping The public-source task is to determine whether Rosenwald Capital Management, Dalton Investments, Rosenwald Partners L.P., Beach Front I LLC, Beach Front Properties LLC, Beachfront-named entities, and family trusts/LPs are: • Glass House shareholders or beneficial owners. • Counterparties to leases, consulting, insurance, financing, or property transactions. • DCC owners or financial-interest holders. • Local cannabis permit applicants, owners, or control persons. • Related parties under SEC/IFRS/Canadian disclosure rules. No public final finding of illicit activity is established by this memo. The deliverable is a mapping and records-request schedule. Records to obtain • Related-party policy and annual questionnaires. • Audit committee/independent director approval minutes. • Agreements, amendments, invoices, and payment ledgers. • Lease appraisals, rent comps, broker files, insurance placement files. • CA SOS registrations, statements of information, assumed names. • County recorder/assessor deeds, leases, DOTs, UCC filings. • SEC Forms 3/4/5, 13D/G, 13F, ADV, SEDAR/SEDI insider reports. • DCC owner/FIH records and local cannabis ownership applications. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 14 06_Schedule_III_Adult_Use_NYSE_Memo.md Schedule III / adult-use boundary / NYSE memo Issue Glass House's NYSE uplisting was publicly tied to the reclassification of medical cannabis to Schedule III. The core suitability issue is whether the listed parent is meaningfully separated from non-medical/adult-use cannabis activity while retaining economics in Glass House Retail. Public facts • Glass House announced NYSE approval on June 25, 2026 and expected GLAS trading beginning June 30, 2026. • Glass House described the listing as not possible before recent medical cannabis Schedule III reclassification. • Glass House Retail was separated/deconsolidated as the dual-use business, while the parent retained non-voting/non-participating exchangeable units. • DEA materials distinguish medical marijuana Schedule III regulatory action from broader marijuana rescheduling proceedings. Diligence questions 1. What exactly did NYSE review regarding cannabis operations? 2. Did Glass House provide NYSE/SEC a legal memo on medical vs adult-use separation? 3. Does the listed parent retain adult-use economics or practical control through GHR agreements? 4. Are medical, adult-use, hemp, and export operations segregated in track-and-trace, accounting, inventory, personnel, and licenses? 5. Did public statements about interstate commerce/export go beyond existing legal authority? 6. Did any exchange, SEC, auditor, underwriter, or counsel raise comments about continued-listing suitability? Documents to request • NYSE listing application and all cannabis-related correspondence. • SEC comment/correspondence records, if any. • Outside counsel memoranda on CSA/Schedule III, adult-use separation, and exchange suitability. • Medical-only operational segregation policies. • Adult-use deconsolidation operating protocol. • Public statement review memos concerning interstate commerce, European export, and Schedule III. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 15 07_Hemp_Export_Compliance_Addendum.md Hemp / CBD export compliance addendum Trigger On July 7, 2026, Glass House announced completion of its first international sale of smokeable CBD biomass to Europe from Greenhouse 4 at the Camarillo Farm. Why it matters This expands diligence beyond cannabis licensing and NYSE Schedule III issues into hemp/export/customs/product-compliance issues. It may also affect public statements about interstate commerce, European medical cannabis export opportunities, and segregation of hemp vs marijuana operations. Documents to request 1. Hemp cultivation registrations/licenses for Greenhouse 4. 2. Certificates of analysis for all lots exported. 3. THC-threshold testing and sampling protocol. 4. Chain-of-custody and inventory records. 5. Export invoices, bills of lading, customs declarations, shipping manifests. 6. Buyer/importer permits and EU/member-state import compliance memo. 7. Product classification memo: hemp/CBD vs cannabis/marijuana. 8. Counsel review of "smokeable CBD biomass" export legality. 9. Any FDA/USDA/CBP/state hemp correspondence. 10. Segregation controls between hemp biomass and cannabis crop inventory. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 16 08_Missing_Agreements_Request_Memo.md Missing agreements and side-letter request memo Publicly filed documents The June 17, 2026 Form 6-K exhibit index publicly filed: • Material Change Report. • Second Amended and Restated LLC Agreement of Glass House Retail, LLC. • Class A Unit Purchase Agreement. • Protection Agreement. • Unaudited Pro Forma Financial Statements. • News Release. Missing or referenced-but-not-public documents 1. Consulting Services Agreement / Management Services Agreement. 2. Purchase Note for NSJB's $2.5 million purchase price. 3. Repurchase/Put Note form and any executed repurchase or put notes. 4. LLC Agreement Payoff Note, if any. 5. Lender consents and credit-facility waivers. 6. DCC and local cannabis regulatory approval letters. 7. Board/audit committee approvals. 8. Fairness/valuation materials. 9. Side letters, support agreements, oral agreements reflected in correspondence, guarantees, indemnities, working-capital commitments, shared-service schedules, tax-sharing agreements, payroll/IT/cash-management agreements. 10. No-side-letter certification. Why they matter The unfiled CSA/MSA and notes are central to ASC 810 and de facto-control analysis. If Glass House controls budgets, staffing, systems, procurement, pricing, compliance, cash, or retail operations through service agreements, the deconsolidation premise is vulnerable. If NSJB's economic risk is reduced by seller financing, guarantees, side arrangements, or repurchase mechanics, NSJB's independence and equity-at-risk may be vulnerable. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 17 09_Local_KB_Cross_Reference_Addendum.md Local KB / Prior-Resource Cross-Reference Addendum Prepared: July 10, 2026 Purpose: Cross-check the master Glass House diligence binder against local, non-public research resources and the Litigation KB indexes while respecting the KB's confidentiality rules. Confidentiality handling • I read the Litigation KB operating rules before using it. • I did not export or summarize the substance of any TRO-46b15 or AC-49765 record because the KB marks those case groups CONFIDENTIAL. • Metadata-only keyword counts were checked for those confidential case groups: TRO-46b15 had 31 Glass House / Beach Front / Rosenwald / Dalton keyword hits; AC-49765 had 1 such hit. The underlying content was withheld from this binder. • KB index rebuild (correction): The Litigation KB's own data had in fact been updated since the last index build — roughly 966 KB content files were newer than mcp/kb_index.sqlite (which was last built 2026-06-18), including new 8292 conciliation and TRO-46b15 filing packets dated 2026-07-09. Per the KB's binding maintenance rule, I therefore ran bun run mcp/build_index.ts. The rebuild reported docsIndexed: 10505, bodiesMissing: 0, docketRows: 352. I then checkpointed/normalized the SQLite journal, and verified integrity (ok) and the MCP test client (all six tools load; kb_search and kb_docket return results). This rebuild touched only the KB's own search index; it did not alter this diligence bundle's substantive content. Non-confidential local resources cross-checked The following local resources materially overlapped with, corrected, or expanded the binder: 1. /Users/icloudabe/law_firm_associations/AR-RES-20260709-GLAS_NYSE_EXPOSURE_DILIGENCE_8292.md 2. /Users/icloudabe/GLAS_Diligence_Package/00_GLAS_Complete_Diligence_Report.md 3. /Users/icloudabe/GLAS_Diligence_Package/glas_verification_and_actions.md 4. /Users/icloudabe/GLAS_Diligence_Package/glas_related_party_ledger.md 5. /Users/icloudabe/GLAS_Diligence_Package/glas_retail_research.md 6. /Users/icloudabe/GLAS_Diligence_Package/glass_house_brands_enforcement_research.md 7. /Users/icloudabe/GLAS_Diligence_Package/NSJB_Background_Investigation_Report.md 8. /Users/icloudabe/law_firm_associations/SESSION_OUTPUT_20260707_GLASSHOUSE/GLASSHOUSE_LABOR_ REPORT_20260707/00_FULL_REPORT.md 9. /Users/icloudabe/law_firm_associations/SESSION_OUTPUT_20260707_GLASSHOUSE/GLASSHOUSE_LABOR_ REPORT_20260707/EVIDENCE_REGISTER.md 10. /Users/icloudabe/law_firm_associations/AR-EXH-20260705-BEACHFRONT_PROPERTY_MAP_8292.md 11. /Users/icloudabe/law_firm_associations/JBR3_RECORDS_BINDER_20260617/06_BEACHFRONT/BEACHFRO NT_FINDINGS.md 12. Non-confidential Litigation KB indexes: 8292, LASC, GA1-criminal, and crosscase. Cross-reference findings to add to the diligence frame 1. NSJB independence / ASC 810 angle is stronger than the original binder framed Glass House Brands Master Diligence Binder — research work product, not legal advice Page 18 Prior local work identifies NSJB Investments LLC as a California LLC formed shortly before the June 2026 Glass House Retail transaction, with Jared Beilke and Nicholas Sarris tied to the same JML Law address. The public SEC documents already show the $2.5 million consideration was structured as a Purchase Note rather than cash. The cross-reference materials therefore sharpen the diligence issue from a generic "third-party investor" question to a targeted independence/equity-at-risk inquiry: formation timing, seller financing, source of funds, note recourse/security, principal independence, and any Glass House / Kazan / Rosenwald contacts or side arrangements. 2. The pro forma deconsolidation math issue should be elevated The verification pass flags a facial arithmetic/accounting issue in Exhibit 99.5: the filed note reportedly labels the gross assets derecognized as the "carrying value of net assets disposed" even though the same deconsolidation column also removes liabilities. On that reading, applying ASC 810-10-40-5 to net assets rather than gross assets would change the filed loss presentation into a gain-shaped result. This is not a final accounting conclusion, but it should be elevated in the ASC 810 request package as a direct auditor/company question. 3. DCC citation characterization needs tight discipline The most defensible formulation remains: DCC publicly lists a Citation and Fine for Glass House Camarillo Cultivation LLC / CCL21-0005116 effective May 15, 2026, but the public DCC table does not itself provide the full citation order, factual findings, fine calculation, or final appeal posture. Local cross-reference materials report a $21,000 amount and an age-verification/procedures theory from press/DCC-spokesperson reporting. Treat that as secondary until the actual DCC citation packet is produced. Do not call it an adjudicated child-labor finding. 4. Retail-license transfer / local approval gap is more specific Local cross-reference materials state that the relevant retail licenses remained active adult-use/medicinal licenses in their existing legal names after the transaction and that ownership/control approvals were not publicly visible. That reinforces the DCC/local PRA lane: owner lists, financial-interest-holder schedules, Form 27/DCC LIC 027 submissions, local authorization letters, and correspondence about whether NSJB/Beilke/Sarris were owners, managers, control persons, or financial-interest holders. 5. Disclosure-timing issue should be tracked against June 2026 filings The cross-reference memo flags that the June deconsolidation/uplist package should be checked against adverse-facts categories: federal raid/labor investigation, DCC citation, Cal/OSHA posture, wage-and-hour/labor litigation, related-party transactions, material weaknesses, covenant issues, and adult-use separation. The binder's disclosure-comparison section should therefore include a filing-by-filing checklist: FY2025 40-F/AIF, Q1 2026 interim financials, June 17 6-K deconsolidation package, June 18 investor deck, June 26 8-A12B/CERT, and first post-uplist quarterly disclosure. 6. The labor/raid record requires corrections and restraint Local labor materials emphasize: the Alanis fatality inspection and any Glass House safety citation should be separated by employer/entity and inspection number; a contested Cal/OSHA citation is not a final finding; DOL/WHD public determinations were not located; and no public final adjudication established that Glass House knowingly employed minors. This aligns with the binder's FOIA/PRA strategy but requires continued careful phrasing. 7. Related-party ledger should add the 3645 Long Beach / Beach Front entity cluster The Beach Front property-map materials and JBR3 records binder show a broader entity cluster around 3645 Long Beach Blvd and Beach Front Properties LLC, including RCM as a reported manager/member/related-person connection in local records. The related-party ledger should not stop at the SEC Note 18 items; it should add Beach Front Properties LLC, Beach Front I/II/III/IV/VIII and other SPEs, 1223 Anaheim, Eshelman, Arlington, Waterford JV entities, Beach Front Diversified Investments, Beach Front Vintage 2014, and any entities appearing in Beach Front investor letters or CA SOS records. Use these as mapping/discovery targets, not as proof of wrongdoing. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 19 8. Jocelyn Rosenwald / Beach Front role should be tracked separately from ownership proof Local records identify Jocelyn Rosenwald in a Beach Front operational/acquisitions/asset-management context and as a Glass House director/founder-side figure, but available local summaries caution that exact Beach Front equity percentages and family-trust lines remain unconfirmed. Keep role, management, contact, and equity ownership in separate columns. 9. Some prior theories should be killed or downgraded The cross-reference resources caution not to overstate: broad Section 16 delinquency theories for Canadian FPI directors/officers; hidden common ownership of NSJB absent direct proof; Pro-Tech/LPA theories without a primary source tying Glass House to a specific LPA; PPP-fraud overlays; or Alanis-liability theories against Glass House where the record points to claims against the United States or contractor/employer posture. These should be treated as killed, downgraded, or discovery-only unless new primary records emerge. 10. New watch items • Q2 2026 post-uplist financials: actual accounting treatment of the deconsolidation loss/gain and any auditor/company explanation. • DCC citation packet: fine amount, factual findings, appeal status, and whether records cite age-verification procedures. • DCC/local Form 27 and owner/FIH files: whether DCC/local agencies were told about the full GHR/NSJB structure. • Purchase Note / CSA / Repurchase-Put Note / side letters: independence, control, and economics. • SEDI / Canadian insider records: execution of any Form 144-related sales and founder voting/ownership changes. • Cal/OSHA / OSHAB / DOL / PACER: final posture for raid/fatality/labor matters. Effect on the master binder This addendum does not replace the existing binder. It adds a corrections/cross-reference layer and upgrades the highest-priority request targets. The safest next external-facing version should cite only primary public sources and should keep local KB/workproduct paths internal. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 20 PRA / FOIA / Company Request Packets Glass House Brands Master Diligence Binder — research work product, not legal advice Page 21 CBP_FOIA_Raid.txt Subject: FOIA Request — CBP / Border Patrol records concerning July 10, 2025 Glass House operations To: U.S. Customs and Border Protection FOIA Office Requester: [Name] Address: [Address] Email: [Email] Phone: [Phone] Pursuant to FOIA, please produce records from June 1, 2025 to present concerning CBP/Border Patrol participation in the July 10, 2025 law-enforcement operations at Glass House Brands / Glass House Farms facilities in Camarillo and Carpinteria, California. Please include: 1. Operational/tactical plans, deconfliction records, and after-action reports. 2. Incident logs, use-of-force logs, crowd-control records, and emergency response records. 3. Body-worn camera/video, aerial/drone footage, photographs, and radio logs, if maintained. 4. Detainee transport logs and aggregate/de-identified detention data. 5. Communications with ICE/HSI, DHS, DOL/WHD, DCC, Cal/OSHA, USAO-CDCA, Ventura County, Santa Barbara County, or local law enforcement. 6. Records referencing Glass House Brands, Glass House Farms, Glass House Camarillo Cultivation LLC, Jaime Alanis Garcia, George Retes, or farm labor contractors at those sites. Please construe this request broadly but search in a targeted manner. If any portion of a responsive record is exempt, please produce all reasonably segregable non-exempt portions. Please provide records electronically. If records are withheld or redacted, please identify the exemption relied upon and provide an index or log sufficient to evaluate the withholding. Please provide rolling productions as records become available. If the request is unclear or too broad, please contact me before denying or closing the request. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 22 CalOSHA_DIR_PRA.txt Subject: California Public Records Act Request — Cal/OSHA fatality/serious-injury file, Jaime Alanis Garcia / Glass House Camarillo To: California Department of Industrial Relations / Cal/OSHA Public Records Requester: [Name] Address: [Address] Email: [Email] Phone: [Phone] Pursuant to the California Public Records Act, please produce the complete Cal/OSHA / DIR fatality or serious-injury investigation file concerning Jaime Alanis Garcia and the July 10, 2025 incident at the Glass House / Glass House Farms Camarillo facility. Please include: 1. Opening reports and inspection records. 2. Employer and contractor identification records. 3. Field notes, witness statements, photographs, video, diagrams, and exhibits. 4. Fall-protection, roof-access, greenhouse-access, emergency-egress, and hazard-analysis records. 5. Injury/illness logs, serious-injury/fatality reports, and required employer reports. 6. Citations, proposed penalties, abatement records, settlement records, appeal records, and final disposition. 7. Communications with DHS, ICE, CBP, HSI, DCC, DOL/WHD, Ventura County, Glass House, farm-labor contractors, security contractors, or other entities concerning the July 10, 2025 incident. Please construe this request broadly but search in a targeted manner. If any portion of a responsive record is exempt, please produce all reasonably segregable non-exempt portions. Please provide records electronically. If records are withheld or redacted, please identify the exemption relied upon and provide an index or log sufficient to evaluate the withholding. Please provide rolling productions as records become available. If the request is unclear or too broad, please contact me before denying or closing the request. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 23 Company_Auditor_ASC810_Request.txt Subject: Document Request — Glass House Retail deconsolidation, ASC 810, auditor review, and missing agreements To: Glass House Brands Inc. / Audit Committee / External Auditor / Counsel Please produce the following documents concerning the June 2026 Glass House Retail / NSJB transaction and deconsolidation: 1. Full ASC 810 consolidation/deconsolidation technical memo. 2. VIE analysis, primary-beneficiary analysis, power/economics analysis, and protective-vs-participating-rights analysis. 3. Auditor consultation, concurrence, comfort, or review documents. 4. Audit committee minutes, board minutes, board decks, and written consents approving or reviewing the transaction. 5. Executed Consulting Services Agreement / Management Services Agreement and all schedules/SOWs. 6. Executed Purchase Note for NSJB's $2.5 million purchase price. 7. Repurchase/Put Note forms and any executed notes. 8. LLC Agreement Payoff Note, if any. 9. Lender consents, waivers, credit-facility approvals, and senior secured lender correspondence. 10. DCC and local cannabis regulatory approval letters and related submissions. 11. Source-of-funds records and beneficial-owner certifications for NSJB and its principals. 12. Related-party questionnaires and independence certifications for NSJB, Jared Beilke, Nicholas Sarris, Kyle Kazan, GHB U 13. All side letters, guarantees, support agreements, indemnities, working-capital commitments, payroll/IT/cash-management/ 14. No-side-letter certificate signed by Glass House, GHB Usub, GHR, NSJB, NSJB principals, and counsel. 15. Valuation reports, fairness analyses, pro forma support schedules, and impairment/deconsolidation calculations. 16. NYSE and SEC correspondence concerning the transaction, cannabis operations, Schedule III, adult-use separation, and co Glass House Brands Master Diligence Binder — research work product, not legal advice Page 24 DCC_PRA_Citation_CCL21-0005116.txt Subject: California Public Records Act Request — DCC Citation and Fine for Glass House Camarillo Cultivation LLC / CCL21-0005116 To: California Department of Cannabis Control Email: publicrecords@cannabis.ca.gov Requester: [Name] Address: [Address] Email: [Email] Phone: [Phone] Pursuant to the California Public Records Act, please produce all records concerning the DCC Citation and Fine effective May 15, 2026, issued to Glass House Camarillo Cultivation LLC, license CCL21-0005116, including but not limited to: 1. Citation/order document and citation number. 2. Fine amount, fine calculation, and payment/collection status. 3. Service records and notices. 4. Inspection/audit reports, investigator notes, and compliance file materials. 5. Records concerning 4 CCR §17800, 4 CCR §15042, and BPC §26160, including right-of-access records, premises access records, visitor/sign-in/sign-out records, and licensee-records requests. 6. Photographs, videos, attachments, and exhibits. 7. Track-and-trace records or licensee-record evidence relied upon. 8. Orders of abatement, corrective-action plans, licensee responses, settlement discussions, and closure records. 9. Appeal/hearing requests, informal-conference requests, conference decisions, modified citations, dismissed citations, final dispositions, and any record showing whether the citation is final, appealed, paid, settled, withdrawn, or pending. Date range: January 1, 2025 to present. Please construe this request broadly but search in a targeted manner. If any portion of a responsive record is exempt, please produce all reasonably segregable non-exempt portions. Please provide records electronically. If records are withheld or redacted, please identify the exemption relied upon and provide an index or log sufficient to evaluate the withholding. Please provide rolling productions as records become available. If the request is unclear or too broad, please contact me before denying or closing the request. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 25 DCC_PRA_GHR_NSJB_Ownership_Control.txt Subject: California Public Records Act Request — Glass House Retail / NSJB ownership-control approvals and financial-interest-holder records To: California Department of Cannabis Control Email: publicrecords@cannabis.ca.gov Requester: [Name] Address: [Address] Email: [Email] Phone: [Phone] Pursuant to the California Public Records Act, please produce all records from January 1, 2025 to present concerning any ownership, financial-interest-holder, change-of-control, change-of-ownership, change-of-designated-responsible-party, license modification, or Form DCC LIC 027 / Form 27 submission involving any of the following: • Glass House Retail, LLC • NSJB Investments LLC • GHB Usub, LLC • Glass House Brands Inc. • GH Group Inc. • Jared Wesley Beilke • Nicholas Wayne Sarris • Kyle Kazan • Any licensee, subsidiary, or entity transferred or proposed to be transferred to Glass House Retail, LLC • Farmacy, Natural Healing Center, The Pottery, or other GHR-related retail licensees Please include: 1. Owner lists and owner submittals, including Form DCC 9101 or equivalent owner disclosures. 2. Financial-interest-holder schedules and related classifications. 3. Entity/capitalization charts, beneficial ownership charts, and organizational charts. 4. Form DCC LIC 027 / Form 27 submissions and all attachments. 5. DCC approval, denial, acknowledgment, deficiency, or information-request letters. 6. Local authorization letters and correspondence with local licensing authorities. 7. Background/suitability determinations, with legally required privacy redactions if necessary. 8. Correspondence or memoranda concerning whether Glass House Brands, GHB Usub, or any affiliate retained control, management rights, financial interests, or beneficial ownership after the Glass House Retail / NSJB transaction. 9. Records concerning the Class A Unit Purchase Agreement, LLC Agreement, Protection Agreement, CSA/MSA, Purchase Note, exchangeable units, conversion rights, call/put rights, or any side agreements. Please construe this request broadly but search in a targeted manner. If any portion of a responsive record is exempt, please produce all reasonably segregable non-exempt portions. Please provide records electronically. If records are withheld or redacted, please identify the exemption relied upon and provide an index or log sufficient to evaluate the withholding. Please provide rolling productions as records become available. If the request is unclear or too broad, please contact me before denying or closing the request. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 26 DHS_ICE_HSI_FOIA_Raid.txt Subject: FOIA Request — July 10, 2025 Glass House Brands / Glass House Farms raid records To: ICE / Homeland Security Investigations FOIA Office Requester: [Name] Address: [Address] Email: [Email] Phone: [Phone] Pursuant to the Freedom of Information Act, please produce records from June 1, 2025 to present concerning the July 10, 2025 federal law-enforcement operations at Glass House Brands / Glass House Farms facilities in Camarillo, California and Carpinteria, California, including records referencing Glass House Brands Inc., Glass House Farms, Glass House Camarillo Cultivation LLC, Glass House Brands, GH Group, Farm Labor Contractors providing labor at those sites, Jaime Alanis Garcia, George Retes, or the July 10, 2025 operations. Please include: 1. Search warrants, warrant applications, affidavits if unsealed or segregable, returns, and inventories. 2. Operational plans, risk assessments, after-action reports, execution logs, and incident reports. 3. Worksite enforcement records, I-9 audit records, Notices of Inspection, subpoenas, notices of intent to fine, and employer/contractor correspondence. 4. Seizure logs and property inventories. 5. Detention/arrest records in aggregate/de-identified form, including totals and age categories. 6. Use-of-force records and emergency medical response records. 7. Communications with CBP, DOL/WHD, DCC, Cal/OSHA, Ventura County, Santa Barbara County, USAO-CDCA, or local law enforcement. 8. Records concerning potential or alleged immigration, child labor, forced labor, trafficking, wage-hour, farm-labor-contractor, or workplace-safety violations. Please process this as a request for agency records; if court records are withheld because they are under seal, please identify the docket/case/matter number if legally permissible. Please construe this request broadly but search in a targeted manner. If any portion of a responsive record is exempt, please produce all reasonably segregable non-exempt portions. Please provide records electronically. If records are withheld or redacted, please identify the exemption relied upon and provide an index or log sufficient to evaluate the withholding. Please provide rolling productions as records become available. If the request is unclear or too broad, please contact me before denying or closing the request. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 27 DOL_WHD_FOIA.txt Subject: FOIA Request — WHD records concerning Glass House Brands / farm labor contractors / July 2025 raid To: U.S. Department of Labor, Wage and Hour Division Email: FOIARequest@dol.gov Requester: [Name] Address: [Address] Email: [Email] Phone: [Phone] Pursuant to FOIA, please produce all Wage and Hour Division records from January 1, 2024 to present concerning Glass House Brands Inc., Glass House Farms, Glass House Camarillo Cultivation LLC, GH Group, Farm Labor Contractors providing labor to Glass House's Camarillo or Carpinteria facilities, and the July 10, 2025 federal operations at those facilities. Please include: 1. Child-labor, MSPA, FLSA, wage-hour, payroll, or farm-labor-contractor investigation files. 2. Complaints, inspection records, investigator notes, settlement records, citations, penalties, debarment records, or closure memoranda. 3. Records concerning potential or alleged employment of minors, worker authorization, wage underpayment, farm-labor-contractor violations, forced labor, trafficking, retaliation, or related labor-law issues. 4. Communications with DHS, ICE, HSI, CBP, DCC, Cal/OSHA/DIR, Ventura County, Santa Barbara County, USAO-CDCA, or other federal/state/local agencies. 5. Records sufficient to identify the farm-labor contractors terminated by Glass House after the July 10, 2025 operations, to the extent maintained by WHD. Please construe this request broadly but search in a targeted manner. If any portion of a responsive record is exempt, please produce all reasonably segregable non-exempt portions. Please provide records electronically. If records are withheld or redacted, please identify the exemption relied upon and provide an index or log sufficient to evaluate the withholding. Please provide rolling productions as records become available. If the request is unclear or too broad, please contact me before denying or closing the request. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 28 Entity_Beneficial_Owner_Mapping_Request.txt Subject: Entity / beneficial-owner mapping request schedule Records to pull or request for Beach Front / Rosenwald / Dalton / Glass House related-party mapping: 1. California Secretary of State filings, statements of information, amendments, terminations, DBAs, and registered-agent histories for: • Beach Front Property Management Inc. • Beach Front Properties LLC • Beach Front I LLC • Beachfront-named entities associated with Kyle Kazan, Glass House, or related parties • Jon A. Neu Insurance • 5042 Real Estate Investment LLC • 3645 Long Beach LLC • 2000 De La Vina LLC • GH Group Inc. • Glass House Retail LLC • NSJB Investments LLC 2. County recorder/assessor records in Los Angeles, Ventura, Santa Barbara, San Luis Obispo, Kings, Stanislaus, and other relevant counties for deeds, leases, deeds of trust, options, easements, and assessor ownership records. 3. UCC searches for Glass House, GHR, NSJB, Beach Front entities, real-estate lessors, and related borrowers. 4. SEC/EDGAR and Canadian SEDAR+/SEDI records: • Forms 3/4/5 • 13D/13G • 13F • Form ADV / IAPD • Management information circulars • AIF/40-F/6-K exhibits 5. DCC owner/FIH records and local cannabis permit owner/control applications for the same entities/persons. 6. Agreements, invoices, and board approvals for related-party leases, consulting, insurance brokerage, financing, and preferred equity. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 29 Local_Cannabis_PRA_Template.txt Subject: Public Records Act Request — Cannabis ownership/control approval records for [LICENSEE / LOCATION] To: [Local Agency / City Clerk / County Clerk / Cannabis Licensing Office] Requester: [Name] Address: [Address] Email: [Email] Phone: [Phone] Pursuant to the California Public Records Act, please produce all records from January 1, 2025 to present concerning cannabis licensing, ownership, ownership transfer, change of control, financial-interest-holder disclosure, business-license change, local authorization, local cannabis permit renewal, or regulatory approval for: • Licensee/legal name: [LEGAL NAME] • DCC license: [C10 / other license number] • DBA/site: [DBA / address] • Glass House Retail, LLC • NSJB Investments LLC • Glass House Brands Inc. • GHB Usub, LLC • GH Group Inc. • Jared Beilke • Nicholas Sarris • Kyle Kazan Please include: 1. Local cannabis permit/license applications and renewals. 2. Ownership/control-transfer applications, notices, and approvals/denials. 3. Business-license change forms and approvals. 4. Local authorization letters to DCC. 5. CUP/development-agreement files, staff reports, council/commission packets, and hearing materials. 6. Background/suitability/owner-manager badge records, redacted as required by law. 7. Inspection, fire, building, zoning, police/code-enforcement records. 8. Communications with DCC or other agencies concerning ownership/control, Glass House Retail, NSJB, or the June 2026 transaction. Please construe this request broadly but search in a targeted manner. If any portion of a responsive record is exempt, please produce all reasonably segregable non-exempt portions. Please provide records electronically. If records are withheld or redacted, please identify the exemption relied upon and provide an index or log sufficient to evaluate the withholding. Please provide rolling productions as records become available. If the request is unclear or too broad, please contact me before denying or closing the request. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 30 NYSE_SEC_Correspondence_Request.txt Subject: Request for NYSE / SEC / counsel correspondence concerning cannabis operations, Schedule III, and deconsolidation To: Glass House Brands Inc. / Counsel / Exchange Listing Counsel Please produce all records concerning NYSE listing or continued-listing review, SEC comments/correspondence, and counsel analyses relating to: 1. Glass House Brands' NYSE listing application and approval. 2. Medical cannabis Schedule III reclassification. 3. Separation of medical cannabis from adult-use or dual-use cannabis operations. 4. Glass House Retail deconsolidation and retained non-voting/exchangeable units. 5. Whether Glass House Brands consolidates or controls any entity involved in non-medical/adult-use marijuana. 6. NYSE suitability, continued-listing risk, qualitative listing standards, and public-interest considerations. 7. Public statements about interstate commerce, medical cannabis export to Europe, hemp/CBD export, and related opportunities. 8. Any SEC, NYSE, auditor, underwriter, bank, counsel, or investor comments about the transaction. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 31 Tables / Trackers Glass House Brands Master Diligence Binder — research work product, not legal advice Page 32 Cross_Reference_Findings.csv Priority Cross-reference item Why it matters Action / Local source path binder effect High NSJB formed shortly Sharpens ASC 810 Add source-of GLAS_Diligence_Package/NSJB_Background_Investigation_ before transaction; equity-at-risk and -funds, note r Report.md; law_firm_associations/AR-RES-20260709-GLAS_ principals tied to JML Law; independence ecourse/secur NYSE_EXPOSURE_DILIGENCE_8292.md seller-financed Purchase inquiry ity, and Note independence certifications to ASC 810 request High Pro forma deconsolidation Potential material Elevate as GLAS_Diligence_Package/glas_verification_and_actions.md loss/gain arithmetic issue accounting/auditor direct auditor/ question company question in ASC 810 memo and post-Q2 watch item High DCC citation $21k / Avoid overclaiming; Keep public GLAS_Diligence_Package/00_GLAS_Complete_Diligence_R age-verification theory is preserve exact DCC fact eport.md; DCC portal secondary until citation citation request separate from packet press/spokes person amou nt/theory High Retail license Directly tests PRA Form 27, law_firm_associations/AR-RES-20260709-GLAS_NYSE_EXP transfer/ownership-control DCC/local approval owner/FIH, OSURE_DILIGENCE_8292.md gap remains unresolved and adult-use local separation authorization files for each C10 High June disclosure package Potential securities Add law_firm_associations/AR-RES-20260709-GLAS_NYSE_EXP should be compared disclosure/stalenes filing-by-filing OSURE_DILIGENCE_8292.md across adverse-facts s issue disclosure categories checklist Medium-High Cal/OSHA/DOL/raid Avoid treating Keep GLAS_Diligence_Package/glass_house_brands_enforcement records require contested citations/ FOIA/PRA _research.md; labor report entity-specific restraint allegations as final targets but findings phrase as alle ged/potential and track final status Medium-High 3645 Long Beach / Beach Expands Add Beach law_firm_associations/AR-EXH-20260705-BEACHFRONT_P Front SPE cluster and related-party ledger Front ROPERTY_MAP_8292.md; JBR3_RECORDS_BINDER_202 RCM connection and discovery map Properties 60617/06_BEACHFRONT/BEACHFRONT_FINDINGS.md LLC/SPEs to entity mapping; separate role from equity proof Medium Jocelyn Rosenwald role vs Avoid conflating Separate JBR3_RECORDS_BINDER_20260617/06_BEACHFRONT/B ownership proof distinction operational columns for r EACHFRONT_FINDINGS.md role/directorship ole/contact/eq with equity uity/managem percentage ent/control Medium Killed/downgraded Prevents Add caution law_firm_associations/AR-RES-20260709-GLAS_NYSE_EXP theories: broad Section 16, overstatement to final-facing OSURE_DILIGENCE_8292.md; labor report hidden NSJB ownership, use and PPP fraud, Pro-Tech request without primary tie strategy Glass House Brands Master Diligence Binder — research work product, not legal advice Page 33 Priority Cross-reference item Why it matters Action / Local source path binder effect Internal Confidential KB hits exist Must not export or Only litigation_kb/TRO-46b15 and litigation_kb/AC-49765 index in TRO-46b15/AC-49765 summarize metadata counts confidential content counts recorded; content withheld Glass House Brands Master Diligence Binder — research work product, not legal advice Page 34 KB_Confidentiality_Log.csv Resource Keyword hits Handling litigation_kb/TRO-46b15/index.jsonl 31 CONFIDENTIAL: no substance exported or summarized litigation_kb/AC-49765/index.jsonl 1 CONFIDENTIAL: no substance exported or summarized litigation_kb non-confidential indexes 1498 Metadata/abstract-level cross-reference used only for internal issue spotting litigation_kb/mcp/kb_index.sqlite n/a REBUILT 2026-07-09 via bun run mcp/build_index.ts (index was stale: ~966 newer KB files); integrity ok; docs 10505; test client passed Glass House Brands Master Diligence Binder — research work product, not legal advice Page 35 Local_Cannabis_Agency_Matrix.csv Site DCC license Legal name Likely local Request focus PRA target Farmacy Berkeley C10-0000506-LIC ICANN LLC City of Business-license ownership/name/location changes; local Berkeley authorization Finance; Planning & Development Farmacy Isla Vista C10-0001190-LIC Farmacy Isla Vista Santa Ownership >20% transfers; local permit/authorization LLC Barbara County CEO Cannabis Regulation & Licensing; Planning & Development Farmacy Santa Ana C10-0000044-LIC Bud and Bloom City of Santa Regulatory Safety Permit; new/change of ownership Ana Commercial Cannabis / Planning The Farmacy Santa C10-0000293-LIC Farmacy SB Inc. City of Santa Permit renewal/transfer/change records Barbara Barbara Cannabis Permits The Farmacy SY C10-0001124-LIC SBDANK LLC Santa Local permit, owner/background records Barbara County; Planning; She riff/backgroun d NHC Grover Beach C10-0000388-LIC Natural Healing City of Grover Commercial cannabis permit, ownership ≥5% records Center LLC Beach Community Development NHC Lemoore C10-0000734-LIC NHC Lemoore LLC City of Regulatory permit and project development agreement Lemoore Police/City M anager/Counc il/Clerk NHC Morro Bay C10-0000797-LIC NHC-MB LLC City of Morro CCO permit, conditions, transfers Bay Community D evelopment/C ity Manager NHC Turlock C10-0000988-LIC NHC Turlock LLC City of CUP/development agreement and cannabis permits Turlock Police /Planning/City Clerk The Pottery LA C10-0000389-LIC The Pottery Inc. Los Angeles DCR licensing/ownership/DCR Access records Department of Cannabis Regulation Glass House Brands Master Diligence Binder — research work product, not legal advice Page 36 Regulatory_Exposure_Matrix.csv Rank Exposure Public facts Missing Primary next action records 1 ASC 810 / de facto control GHR ASC 810 Send company/auditor request deconsolidation memo, docs public; Glass auditor House retained signoff, exchangeable units CSA/MSA, and protection notes, side rights letters 2 DCC/local SEC docs Approval File DCC and local PRAs ownership-control approval reference letters, gap DCC/local owner/FIH approvals schedules, Form 27s, local authorization 3 Federal raid/labor Glass House Warrants/retu File FOIA/PRA; PACER monitoring investigation disclosed rns, ICE/CBP/ ICE/DHS-led raids, DOL/CalOSH detentions, A files reported minors, worker death, remediation 4 DCC Citation and Fine DCC public entry Fine amount, File DCC citation PRA for factual CCL21-0005116 narrative, effective appeal/finality 05/15/2026 5 Related-party governance Beach Front, Jon Full agreeme Pull ledger docs and audit committee approvals A. Neu, 5042, nts/invoices/a 3645, Kazan Trust pprovals/own disclosures ership 6 Schedule III/adult-use NYSE uplist tied to NYSE/SEC/c Request NYSE/SEC/counsel files boundary medical Schedule ounsel III; GHR separated memos and as operating dual-use/adult-use segregation vehicle records 7 Missing CSA/notes/side Public exhibit Executed Company/auditor request and subpoena schedule letters package omits CSA, CSA/MSA and Purchase notes Note, Repurc hase/Put Note, side-letter certification 8 Hemp/export add-on July 7, 2026 hemp COAs, export/ Hemp/export compliance request biomass sale to customs, Europe announced import permits, hemp registrations Glass House Brands Master Diligence Binder — research work product, not legal advice Page 37 Related_Party_Ledger.csv Entity Public relationship / issue Known public Exposure Next records amount or fact theory Beach Front Majority-owned by Fees disclosed in Related-party Agreement, amendments, invoices, audit committee approval, Property executive and certain prior reports; services, CA SOS, ownership Management Inc. board members; request full ledger arm's-length consulting agreement for pricing, M&A and real-estate independent acquisition/financing approval services Beach Front Appears in some Needs confirmation Naming/entity CA SOS, filings, insurance agreements, invoices, ownership Properties LLC descriptions/naming issue ambiguity; to reconcile with Beach possible Front Property undisclosed Management related party if separate Beach Front I LLC Named target for mapping; Not confirmed Potential relat CA SOS, recorder, UCC, SEC/SEDAR, DCC/local ownership direct Glass House ed-party/entit relationship not confirmed y overlap in public pass Jon A. Neu Insurance brokerage; Insurance Broker Broker agreements, commission schedules, invoices, board Insurance majority-owned by Beach brokerage compensation approvals Front entity per filings expenses and disclosed procurement fairness 5042 Real Estate Partially owned by Rent and Lease Lease, appraisal, rent comps, ownership, consolidation memo Investment LLC executive/board member; consolidation economics, property leased to disclosed valuation, subsidiary; consolidated in consolidation, 2025 conflict approval 3645 Long Beach Partially owned by Rent disclosed HQ lease Lease, renewals, rent comps, approvals, ownership LLC executive/board member; related-party lease relationship pricing/approv al 2000 De La Vina Target entity for Not confirmed Potential real- SOS, recorder/assessor, Glass House footnotes, leases LLC historical/property estate/affiliate mapping; direct current overlap relationship not confirmed in public pass Kazan Trust dated Trust tied to Lease/rent Family trust Trust-controlled entity records, leases, approvals Dec. 10, 2004 executive/board member disclosed related-party and real-estate lease historically disclosure disclosures Rosenwald Capital Investment adviser/RCM ADV materials Beneficial IAPD/ADV, 13D/G, SEDAR/SEDI, shareholder ledgers Management target; direct Glass House identify owner/affiliate related-party transaction RCM/Rosenwald mapping not confirmed Partners relationship Dalton Investments Rosenwald/Dalton Dalton public Beneficial ADV, 13F, 13D/G, SEDAR/SEDI, fund docs mapping target; direct materials identify owner/affiliate Glass House related-party James B. mapping transaction not confirmed Rosenwald III role Rosenwald Partners RCM general partner ADV target Beneficial ADV schedules, LP records if obtainable, SEC/SEDAR L.P. relationship target owner/private holdings fund relationship mapping NSJB Investments Third-party investor in 100 Class A voting Independenc SOS, beneficial owners, source funds, note, DCC/local LLC GHR voting units units for $2.5M e/equity-at-ris approvals purchase price via k/control note per SEC docs Glass House Brands Master Diligence Binder — research work product, not legal advice Page 38 Request_Tracker.csv Request Target Status Priority File/template Notes DCC citation packet DCC PRA Template ready High requests/DCC_PRA_Citation_CCL21-0005116.txt Need requester identity; likely quickest high-value production DCC DCC PRA Template ready High requests/DCC_PRA_GHR_NSJB_Ownership_Control.txt May be ownership/control redacted for approvals background/ proprietary info Local cannabis Cities/counties Template ready High requests/Local_Cannabis_PRA_Template.txt Customize approvals for each license/site ICE/HSI raid records ICE/HSI FOIA Template ready High requests/DHS_ICE_HSI_FOIA_Raid.txt Expect Exemption 7(A)/privacy redactions CBP raid records CBP FOIA Template ready Medium-High requests/CBP_FOIA_Raid.txt Submit separately from ICE DOL/WHD labor DOL WHD FOIA Template ready High requests/DOL_WHD_FOIA.txt Child labor/ records MSPA/FLSA /FLC focus CalOSHA fatality file DIR/CalOSHA PRA Template ready High requests/CalOSHA_DIR_PRA.txt Likely redactions if open investigation ASC 810/company Company/auditor/counsel Template ready Highest requests/Company_Auditor_ASC810_Request.txt Requires co docs unsel/investo r/company process NYSE/SEC/cannabi Company/counsel/NYSE/S Template ready Medium-High requests/NYSE_SEC_Correspondence_Request.txt Public SEC s correspondence EC channels FOIA possible; NY SE/company request depends authority Entity mapping SOS/County/UCC/SEC/D Schedule ready Medium requests/Entity_Beneficial_Owner_Mapping_Request.txt Research CC/local process rather than one request Glass House Brands Master Diligence Binder — research work product, not legal advice Page 39 Source Index Source_Index.csv Source URL Use SEC 6-K Exhibit Index - Glass House Brands, https://www.sec.gov/Archives/edgar/data/184873 Lists public deconsolidation exhibit package: June 17, 2026 1/000110465926074968/tm2617929d1_6k.htm material change report, LLC agreement, unit purchase agreement, protection agreement, pro forma financials, release. SEC Ex. 99.2 - Second Amended and Restated https://www.sec.gov/Archives/edgar/data/184873 Creates GHR unit structure; NSJB/GHB Usub LLC Agreement of Glass House Retail, LLC 1/000110465926074968/tm2617929d1_ex99-2.h members; exchangeable units; tm board/management provisions; no-control/deconsolidation mechanics. SEC Ex. 99.3 - Class A Unit Purchase https://www.sec.gov/Archives/edgar/data/184873 NSJB purchase of Class A voting units, purchase Agreement 1/000110465926074968/tm2617929d1_ex99-3.h note, regulatory approval closing conditions, tm call/put provisions. SEC Ex. 99.4 - Protection Agreement https://www.sec.gov/Archives/edgar/data/184873 Negative covenants, consent rights, 1/000110465926074968/tm2617929d1_ex99-4.h reporting/access, investigation rights, tm NYSE-delisting protection. SEC Ex. 99.5 - Unaudited Pro Forma Financial https://www.sec.gov/Archives/edgar/data/184873 Pro forma deconsolidation impact, retained Statements 1/000110465926074968/tm2617929d1_ex99-5.h investment, revenue/net-loss changes, loss on tm deconsolidation. DCC Compliance Actions Page https://www.cannabis.ca.gov/cannabis-laws/com Lists DCC citations/fines and disciplinary actions, pliance-action-records/ including CCL21-0005116 Glass House Camarillo Cultivation LLC entry. DCC PRA Requests Page https://www.cannabis.ca.gov/about-us/public-rec DCC public records request channel and ords-act-requests/ limitations; publicrecords@cannabis.ca.gov. DCC License Search Resource https://www.cannabis.ca.gov/resources/search-fo Official DCC resource for verifying licensed r-licensed-business/ cannabis businesses. Glass House/GlobeNewswire Raid Update https://www.globenewswire.com/news-release/2 Company statement on July 10, 2025 federal 025/08/04/3126473/0/en/glass-house-brands-pro raids, detentions/arrests, minors reports, worker vides-updates-to-recent-events.html death, remediation. Glass House/GlobeNewswire NYSE Uplist https://www.globenewswire.com/news-release/2 NYSE approval, expected trading under GLAS Release 026/06/25/3317437/0/en/glass-house-brands-an on June 30, 2026, statements on Schedule III. nounces-uplist-to-nyse.html Glass House/GlobeNewswire Hemp Export https://www.globenewswire.com/news-release/2 First international sale of smokeable CBD Release 026/07/07/3323058/0/en/glass-house-brands-co biomass to Europe; Greenhouse 4/Camarillo mpletes-first-international-hemp-sale.html hemp claims. DEA Marijuana Rescheduling Regulatory Actions https://www.dea.gov/marijuana-rescheduling-reg DEA regulatory-action hub for medical marijuana ulatory-actions Schedule III and broader marijuana rescheduling processes. NYSE Continued Listing https://www.nyse.com/regulation/continued-listin NYSE continued-listing monitoring and g qualitative/quantitative standards overview. FOIA.gov How-To https://www.foia.gov/how-to.html FOIA request requirements: written request, reasonable description, agency FOIA office. DOL WHD FOIA https://www.dol.gov/agencies/whd/foia Wage and Hour Division FOIA process, email, record-description guidance. Cal/OSHA DIR PRA https://www.dir.ca.gov/dosh/pra-Requests.html Cal/OSHA public records request process. Glass House Brands Master Diligence Binder — research work product, not legal advice Page 40