STATE OF MICHIGAN

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

CANNABIS REGULATORY AGENCY

In the Matter of

Heritage Farms Manistee, LLC ENF No: 22-00336

License No(s).: AU-R-000593, AU-R-000333, AU-P-000170,
AU-G-C-000323, AU-G-C-000381, AU-G-C-000380, AU-G-C-000383
& AU-G-C-000382
_______________________________/

FORMAL COMPLAINT

The Cannabis Regulatory Agency (“Complainant”) files this formal complaint

against Heritage Farms Manistee, LLC (“Respondent”) alleging upon information and
belief as follows:

1. The Cannabis Regulatory Agency (CRA) is authorized under the Michigan

Regulation and Taxation of Marihuana Act (MRTMA), 2018 IL1, et seq., and Executive
Reorganization Order No.2019-2, MCL 333.27001, to investigate alleged violations of the
MRTMA and the Administrative Rule promulgated thereunder, take disciplinary action to
prevent such violations, and impose fines and other sanctions against applicants and
licensees that violate the MRTMA or Administrative Rules.

2. Section 8(1)(d) of the MRTMA provides that the Administrative Rules must ensure
the health, safety, and security of the public and integrity of the marihuana establishment
operations.

3. Respondent’s conduct as described below is a risk to public health and safety

and/or the integrity of marihuana establishment operations.

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER • P.O. BOX 30205 • LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Executive Reorganization Order 2019-2 created the Marijuana Regulatory Agency (MRA) as a Type I agency within the Department of
Licensing and Regulatory Affairs (LARA). MCL 333.27001(1)(a)(d). The MRA exercises its statutory powers, duties, and functions independent
of LARA’s direction. MCL 16.103. The MRA became the Cannabis Regulatory Agency (CRA) on April 13, 2022.

Formal Complaint
ENF No.: 22-00336 Page 1 of 6
CRA 5052
 FACTUAL ALLEGATIONS AND INTENDED ACTION OF THE CRA

4. Respondent holds an active state license under the MRTMA to operate multiple
adult use retailer establishments, multiple Class C grower establishments, and a
processor establishment in the state of Michigan.

5. Following an investigation, the CRA determined that Respondent violated the

MRTMA and/or Administrative Rules promulgated thereunder as set forth below:

a. On February 23, 2022, Respondent sent the CRA an email regarding its
state license.
b. Respondent’s signature block included a link to a website for a company
called Left Coast Holding Company, LLC (LCHC).
c. The webpage listed Respondent as an asset of LCHC and the CEO of
LCHC as William McKenzie, who is also an applicant of Respondent.
d. The COO listed on the webpage was not an applicant of Respondent.
e. While investigating this matter, the CRA came across a January 12, 2022
article that not only referred to Respondent as an asset of LCHC, but it also
referred to LCHC as the parent company of Respondent.
f. On April 14, 2022, when asked about LCHC, Respondent stated LCHC did
not exist yet and the website was only an attempt to generate interest in the
company.
g. Respondent also stated it was not yet affiliated with LCHC, but it would be
in the future after the amendment application was submitted and approved
by the CRA.
h. However, the website, article, and additional information reviewed during
the investigation suggest that LCHC is active and affiliated with
Respondent.
CANNABIS REGULATORY AGENCY
2407 NORTH GRAND RIVER • P.O. BOX 30205 • LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Executive Reorganization Order 2019-2 created the Marijuana Regulatory Agency (MRA) as a Type I agency within the Department of
Licensing and Regulatory Affairs (LARA). MCL 333.27001(1)(a)(d). The MRA exercises its statutory powers, duties, and functions independent
of LARA’s direction. MCL 16.103. The MRA became the Cannabis Regulatory Agency (CRA) on April 13, 2022.

Formal Complaint
ENF No.: 22-00336 Page 2 of 6
CRA 5052
 i. Respondent failed to notify and obtain approval from the CRA prior to
becoming affiliated with LCHC in violation of Mich Admin Code, R
420.802(3), which states licensees shall report to the agency any proposed
material changes to the marihuana business before making a material
change. A proposed material change is any action that would result in
alterations or changes being made to the marihuana business to effectuate
the desired outcome of a material change. Material changes, include, but
are not limited to, the following:
i. (a) Change in owners, officers, members, or managers.
ii. (c) The addition or removal of a person named in the
application or disclosed.
iii. (e) Any attempted transfer, sale, or other conveyance of an
interest in a marihuana license.
j. Respondent is also in violation of Mich Admin Code, R 420.803(1), which
states any change or modification to the marihuana business after licensure
is governed by the standards and procedures set forth in these rules and
any regulations adopted pursuant to the acts. Any material change or
modification to the marihuana business must be approved by the agency
before the change or modification is made.
k. On April 14, 2022, the CRA spoke to Respondent regarding its involvement
with Shryne Group, Inc. as the trademark for the dba “Authentic 231” is the
same as the trademark for Stiiizy brand, which is owned by Shryne Group,
Inc.
l. Respondent stated it made a verbal agreement with Shryne Group, Inc. to
manufacture its trademark vape cartridge, use its proprietary technology,
and to compensate Shryne Group, Inc. via an agreement with a licensed
facility.

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER • P.O. BOX 30205 • LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Executive Reorganization Order 2019-2 created the Marijuana Regulatory Agency (MRA) as a Type I agency within the Department of
Licensing and Regulatory Affairs (LARA). MCL 333.27001(1)(a)(d). The MRA exercises its statutory powers, duties, and functions independent
of LARA’s direction. MCL 16.103. The MRA became the Cannabis Regulatory Agency (CRA) on April 13, 2022.

Formal Complaint
ENF No.: 22-00336 Page 3 of 6
CRA 5052
 m. Respondent entered into a non-disclosed agreement to use Shryne Group,
Inc.’s proprietary technology and to compensate the company via a
compensation agreement without prior approval from the CRA in violation
of Mich Admin Code, R 420.112a(1), which states a licensee may contract
with another party to use the other party’s intellectual property or for the
other party to provide management or other services necessary for the
operation of the licensee pursuant to a licensing or management agreement
approved by the agency.
n. Respondent is also in violation of Mich Admin Code, R 420.112a(2), which
states a licensee shall submit a complete, unredacted, signed copy of the
licensing, management, or other agreement to the agency for review and
approval prior to performance under the agreement. Approval by the agency
indicates an agency determination that it does not appear based upon the
information provided that the other party meets the definition of applicant.

THEREFORE, based on the above, the CRA gives notice of its intent to impose fines
and/or other sanctions against Respondent’s license, which may include the suspension,
revocation, restriction, and/or refusal to renew Respondent’s license.

Under MCL 333.27957 (1)(c) and Mich Admin Code, R 420.704(2), any party
aggrieved by an action of the CRA suspending, revoking, restricting, or refusing to renew
a license, or imposing a fine, shall be given a hearing upon request. A request for a
hearing must be submitted to the CRA in writing within 21 days after service of this
complaint. Notice served by certified mail is considered complete on the business day
following the date of the mailing.

Respondent also has the right to request a compliance conference under Mich Admin
Code, R 420.704(1). A compliance conference is an informal meeting at which
CANNABIS REGULATORY AGENCY
2407 NORTH GRAND RIVER • P.O. BOX 30205 • LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Executive Reorganization Order 2019-2 created the Marijuana Regulatory Agency (MRA) as a Type I agency within the Department of
Licensing and Regulatory Affairs (LARA). MCL 333.27001(1)(a)(d). The MRA exercises its statutory powers, duties, and functions independent
of LARA’s direction. MCL 16.103. The MRA became the Cannabis Regulatory Agency (CRA) on April 13, 2022.

Formal Complaint
ENF No.: 22-00336 Page 4 of 6
CRA 5052
Respondent has the opportunity to discuss the allegations in this complaint and
demonstrate compliance under the MRTMA and/or the Emergency Rules. A compliance
conference request must be submitted to the CRA in writing.

Hearing and compliance conference requests must be submitted in writing by one of

the following methods:

By Mail: Department of Licensing & Regulatory Affairs

Cannabis Regulatory Agency
P.O. Box 30205
Lansing, Michigan 48909

In Person: Department of Licensing & Regulatory Affairs

Cannabis Regulatory Agency
2407 North Grand River
Lansing, Michigan 48906

By Email: [email protected]

If Respondent fails to timely respond to this formal complaint, a contested case

hearing will be scheduled to resolve this matter.

Questions about this complaint should be directed to the Cannabis Regulatory

Agency’s legal section at (517) 284-8599 or [email protected].

Alyssa A. Digitally signed by Alyssa A.

Grissom
6/22/22
Dated: _______________ Grissom
By: _______________________________
Date: 2022.06.22 21:49:42 -04'00'

Alyssa A. Grissom
Legal Section Manager
Enforcement Division
Cannabis Regulatory Agency

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER • P.O. BOX 30205 • LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Executive Reorganization Order 2019-2 created the Marijuana Regulatory Agency (MRA) as a Type I agency within the Department of
Licensing and Regulatory Affairs (LARA). MCL 333.27001(1)(a)(d). The MRA exercises its statutory powers, duties, and functions independent
of LARA’s direction. MCL 16.103. The MRA became the Cannabis Regulatory Agency (CRA) on April 13, 2022.

Formal Complaint
ENF No.: 22-00336 Page 5 of 6
CRA 5052
In the Matter of

Heritage Farms Manistee, LLC ENF No: 22-00336

License No(s).: AU-R-000593, AU-R-000333, AU-P-000170,
AU-G-C-000323, AU-G-C-000381, AU-G-C-000380, AU-G-C-000383
& AU-G-C-000382
_______________________________/

PROOF OF SERVICE

I hereby certify that on ___________________________,

6/24/22 I mailed a copy of the Formal
6/22/22
Complaint dated ____________________ in the above captioned case by certified mail

(return receipt requested) to:

Heritage Farms Manistee, LLC

1129 N Washington Ave.
Lansing, Michigan 48906

Digitally signed by: Abby Rae Brooks

Abby Rae Brooks DN: CN = Abby Rae Brooks email =

[email protected] C = US O = Marijuana
Regulatory Agency OU = Legal Section
Date: 2022.06.24 08:50:42 -04'00'

Abby Rae Brooks

Departmental Technician
Cannabis Regulatory Agency
Department of Licensing & Regulatory
Affairs

CANNABIS REGULATORY AGENCY

2407 NORTH GRAND RIVER • P.O. BOX 30205 • LANSING, MICHIGAN 48909
www.michigan.gov/CRA
LARA is an equal opportunity employer/program

Executive Reorganization Order 2019-2 created the Marijuana Regulatory Agency (MRA) as a Type I agency within the Department of
Licensing and Regulatory Affairs (LARA). MCL 333.27001(1)(a)(d). The MRA exercises its statutory powers, duties, and functions independent
of LARA’s direction. MCL 16.103. The MRA became the Cannabis Regulatory Agency (CRA) on April 13, 2022.

Formal Complaint
ENF No.: 22-00336 Page 6 of 6
CRA 5052