# GLAS FOIA/PRA Request Templates ## Copy-paste ready for each agency ## GLOBAL PREAMBLE (use in every request) 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. --- ## 1. DCC CITATION PACKET — PRA **Submit to:** publicrecords@cannabis.ca.gov **Subject:** PRA Request — DCC Citation, Glass House Camarillo Cultivation LLC, CCL21-0005116 All records concerning the DCC Citation and Fine effective May 15, 2026, issued to Glass House Camarillo Cultivation LLC, license CCL21-0005116, including citation number, citation/order, fine amount, service records, inspection reports, investigator notes, right-of-access records, visitor/sign-in/sign-out records, licensee-records requests, correspondence, photographs/video, track-and-trace or licensee-record evidence, order of abatement, corrective-action plan, payment/collection status, appeal/hearing request, informal-conference request, conference decision, modified/dismissed/final citation, settlement, and final disposition. [GLOBAL PREAMBLE] --- ## 2. DCC OWNERSHIP-CONTROL APPROVALS — PRA **Submit to:** publicrecords@cannabis.ca.gov **Subject:** PRA Request — Ownership/Control Records, Glass House Retail / NSJB Investments All records from January 1, 2025 to present concerning any ownership, financial-interest-holder, change-of-control, change-of-ownership, change-of-DRP, license modification, or Form DCC LIC 027 / Form 27 submission involving Glass House Retail, LLC, GHB Usub, LLC, Glass House Brands Inc., NSJB Investments LLC, Jared Beilke, Nicholas Sarris, and any licensee or subsidiary transferred or proposed to be transferred to Glass House Retail, including but not limited to owner lists, financial-interest-holder schedules, entity/cap-table charts, Form DCC 9101 owner submittals, Form 27 submissions, license-change correspondence, local authorization letters, DCC approval/denial/acknowledgment letters, background/suitability determinations, and correspondence concerning whether Glass House retained control or financial interests. [GLOBAL PREAMBLE] --- ## 3. DHS/ICE/HSI/CBP — FOIA **Submit to:** FOIA.gov (DHS) and CBP SecureRelease **Subject:** FOIA — July 10, 2025 Federal Law Enforcement Operations at Glass House Facilities 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 search warrants, warrant applications, returns, inventories, operational plans, after-action reports, worksite enforcement records, I-9 audit records, Notices of Inspection, subpoenas, notices of intent to fine, seizure logs, detention/arrest aggregate data, age-category aggregate data, use-of-force reports, medical/emergency-response reports, communications with DOL/WHD, DCC, Cal/OSHA, Ventura County, Santa Barbara County, and USAO-CDCA, and records referencing Glass House Brands, Glass House Farms, Glass House Camarillo Cultivation LLC, G&K Produce LLC, Mission Health Associates, Farm Labor Contractors, Jaime Alanis Garcia, or George Retes. [GLOBAL PREAMBLE] --- ## 4. DOL/WHD — FOIA **Submit to:** FOIARequest@dol.gov **Subject:** FOIA — WHD Records, Glass House Brands / Glass House Farms All WHD records from January 1, 2024 to present concerning Glass House Brands, Glass House Farms, Glass House Camarillo Cultivation LLC, G&K Produce LLC, Mission Health Associates, and any farm-labor contractors providing labor to Glass House's Camarillo or Carpinteria facilities, including child-labor, MSPA, FLSA, wage-hour, I-9/work-authorization referral, payroll audit, complaint, inspection, settlement, citation, debarment, or enforcement records, and communications with DHS/ICE/HSI/CBP, DCC, Cal/OSHA, Ventura County, Santa Barbara County, or USAO-CDCA. [GLOBAL PREAMBLE] --- ## 5. CAL/OSHA / DIR — PRA **Submit to:** Online/intake form at dir.ca.gov **Subject:** PRA Request — Cal/OSHA Inspections 1837925.015 (Glass House Farm, LLC) and 1837914.015 (Art's Labor Service, Inc.), Jaime Alanis Garcia fatality, Camarillo The complete Cal/OSHA / DIR investigation files for **Inspection No. 1837914.015 (Art's Labor Service, Inc. — fatality/catastrophe inspection, accident activity 2320970, reported closed 10/28/2025)** and **Inspection No. 1837925.015 (Glass House Farm, LLC — safety inspection with a §342(A) citation, $5,000 proposed penalty, contested 12/02/2025, open)**, both arising from the July 10, 2025 incident and death of Jaime Alanis Garcia at the Glass House / Glass House Farms Camarillo facility. Include opening reports, incident reports, inspection files, employer/contractor identification (including which entity — Glass House Farm, LLC, Glass House Camarillo Cultivation LLC, or Art's Labor Service, Inc. — was cited for what), witness statements, photographs/video, hazard analyses, fall-protection and roof-access analyses, citations, proposed penalties, informal-conference and appeal/contest records, settlement/abatement documents, OSHA 300/301 logs, communications with DHS/ICE/CBP/HSI, DCC, Ventura County, and any contractor/employer representatives. [GLOBAL PREAMBLE] --- ## 6. LOCAL CANNABIS AGENCY PRA TARGETS For each retail dispensary site, submit a PRA request for ownership-change, transfer, or modification records related to the GHR deconsolidation: | Retail Site | DCC License | Local PRA Target | |---|---|---| | Farmacy Berkeley | ICANN LLC, C10-0000506-LIC | City of Berkeley Finance/business-license change records | | Farmacy Isla Vista | Farmacy Isla Vista LLC, C10-0001190-LIC | Santa Barbara County Cannabis Regulation & Licensing | | Farmacy Santa Ana | Bud and Bloom, C10-0000044-LIC | City of Santa Ana Commercial Cannabis / Planning | | The Farmacy Santa Barbara | Farmacy SB Inc., C10-0000293-LIC | City of Santa Barbara cannabis permit records | | The Farmacy SY | SBDANK LLC, C10-0001124-LIC | Santa Barbara County cannabis licensing | | NHC Grover Beach | Natural Healing Center LLC, C10-0000388-LIC | City of Grover Beach commercial cannabis files | | NHC Lemoore | NHC Lemoore LLC, C10-0000734-LIC | City of Lemoore police/city manager/council | | NHC Morro Bay | NHC-MB LLC, C10-0000797-LIC | City of Morro Bay cannabis permit committee | | NHC Turlock | NHC Turlock LLC, C10-0000988-LIC | City of Turlock Police/Planning/City Clerk | | The Pottery LA | The Pottery Inc., C10-0000389-LIC | LA Dept of Cannabis Regulation / Accela/DCR Access | --- ## 7. COMPANY/AUDITOR REQUEST PACKAGE — ASC 810 **Submit to:** Glass House Brands Investor Relations (ir@glasshousebrands.com), Audit Committee Chair, Macias Gini & O'Connell LLP 1. Full ASC 810 consolidation/deconsolidation memo 2. VIE analysis: variable interests, equity at risk, primary-beneficiary analysis 3. Power analysis: budgets, pricing, staffing, procurement, cash management, inventory, retail operations, compliance decisions 4. Economics analysis: exchangeable units, call/put rights, distribution caps, Purchase Note, repurchase notes 5. Protective-vs-participating-rights memo 6. Related-party/de facto-agent analysis for NSJB, Jared Beilke, Nicholas Sarris, Kyle Kazan, GHB Usub, Glass House Brands, and any affiliates 7. Auditor review/concurrence/comfort materials 8. Audit committee minutes approving deconsolidation 9. Board materials, fairness/valuation reports, and independent appraisals supporting $2.5M / $19.8M values 10. Certification that there are no side letters, oral agreements, guarantees, support letters, collateral agreements, working-capital facilities, or informal understandings altering control/economics 11. Consulting Services Agreement / Management Services Agreement (full text) 12. Purchase Note (full terms: principal, interest rate, maturity, security, acceleration) 13. Repurchase/Put Note forms 14. Lender consents under senior secured credit facility 15. NSJB source-of-funds and independence certifications --- ## 8. COURT-DOCKET MONITORING (CourtListener / PACER — not a records request) - **D.C. Circuit petitions for review of the April 28, 2026 medical-only Schedule III final order** — dockets confirmed via CourtListener: **No. 26-1106, SAM, Inc. v. DOJ** (filed May 4, 2026) and **No. 26-1130, State of Nebraska v. DOJ** (filed May 22, 2026); related district-court matter *Smart Approaches to Marijuana v. Kennedy*, **D.D.C. 1:26-cv-01081** (filed March 30, 2026), on appeal at **D.C. Cir. 26-5205**. Monitor the **stay motion** (DOJ response was due July 2, 2026). This order is the predicate for GLAS's NYSE listing eligibility — a stay or reversal is the single highest-impact external contingency. Set a CourtListener alert on 26-1106 and 26-1130. - **DEA ALJ rescheduling hearing** (broader rule; hearing window June 29 – July 15, 2026) — monitor for the ALJ's recommended decision. - **Melendez v. Glass House Camarillo Cultivation LLC** (LA County Superior Court; original complaint Dec 19, 2023; settlement order Nov 25, 2025) — pull the settlement/PAGA judgment for the labor-violation record. - **George Retes FTCA / civil-rights suit** (filed ~Feb 2026) and any USAO-CDCA criminal docket arising from the July 10, 2025 raid — monitor via PACER/CourtListener. --- ## PRIORITY ORDER 1. DCC citation packet — quickest likely hit; directly confirms fine amount and facts 2. DCC/local GHR/NSJB ownership-control approvals — directly tests licensing exposure 3. CSA/MSA + Purchase Note + side-letter certification — directly tests ASC 810 / de facto control 4. Cal/OSHA fatality file — high-value independent agency record 5. DOL/WHD files — key to minors/FLC exposure, though active investigations may be withheld 6. ICE/HSI/CBP FOIAs and PACER warrant monitoring — high value but likely heavy withholdings 7. Related-party ledger expansion — slower but important for NYSE governance and securities-disclosure theories