Bushala Brothers, Inc. has submitted an Conditional Use Permit (CUP) application to Fullerton’s Planning Department for the development of a restaurant on the unused Santa Fe Depot loading dock.
Now
The loading dock has been empty for decades. It was the object of an earlier City history of property acquisition. The western half the space was leased to BBI in the early 1990s, when the eastern portion was not yet owned by the Fullerton Redevelopment Agency. After the City acquired the portion east of Pomona Avenue, they declined to consolidate the lease of the entire loading dock until the past few years under City Manager Eric Levitt.
Friends will recall that the revised depot lease that now included the loading dock adjacent to the Bushala leasehold was the subject of a cooked-up controversy last summer by “Dr.” Ahmad Zahra and the Kennedy Sisters of the Fullerton Observer, a “controversy” brushed aside by the council majority who recognized the potential for this unused structure.
So the loading dock is on its way to becoming a new downtown Fullerton venue that will enliven the depot area within the Transportation Center.
After review by City staff the application will ultimately be submitted to the Planning Commission for approval.
A new year, and for Fullerton, lingering problems remain a municipal embarrassment, except that the people in charge don’t seemed particularly inclined to terminate them.
Formerly a public sidewalk
The seven year-old boutique hotel has lots of current actors’ fingerprints on it. And then there’s the decades old case of the hijacked sidewalk on Commonwealth and Harbor, heisted by the Florentine Crime Family in 2002, who put a permanent structure on it, attached to a building they didn’t even own. It has never been returned.
Zahra Congratulates Marovic (in green cap) for his lawsuit…against us.
The current owner of the adjacent structure and the business in it, Mario Marovic, made a deal with the City in 2022 to remove the offending structure.
Marovic reneged on the agreement, and boy he reneged hard. The demotion was to start in March 2023 and be done by that July. Nothing started except that Marovic filed some sort of claim and lawsuit against the City for some made up reason, and the the whole mess disappeared into the usual mists of Closed Session.
In the meantime, Marovic has continued to benefit from the add-on as an integral part of his bar – Mickey’s Irish Pub for three years, and counting.
Meet the new proprietor, same as the old proprietor…
According to the deal rumor, Marovic was supposed to start removing the addition this month, January 2026. If there was a behind the scenes agreement, it should have been made public, although the City lawyers would proclaim the lawsuits pending until the removal is complete, and therefore not subject to public airing in public. Of course that would make no practical difference, but that’s the way it is – secrecy for secrecy’s sake.
Still there, after all these years…
I can’t see Marovic settling anything, stalling has been so fun; but maybe his legal bills are costing him more than revenue from the dozen chairs within the “bump out.” It would be nice to see Fullerton play hardball with this scofflaw, but it probably won’t happen. If the add-on actually does go away, I bet the taxpayers get stuck with the legal bill.
In the meantime the small contingent of “transparency” whiners at City Council meeting, the Fullerton Observer and their tender young investigative reporter Sweet Elijah Manassero don’t seem at all curious about this twenty four year-old scandal. I wonder why.
Warning: Conceptual only, not to be taken seriously!
The other day I described the history of the idiotic Boutique Hotel – a notion to build a high-end hotel on the site of the East Santa Fe parking lot at the Depot. The idea was, and is so stupid that it astounds any commonsensical thinker. And even worse, as the “unsolicited,” exclusive deal became less and less likely, the concept became bigger and dumber. The approved plan more than doubled the density allowed by the Transportation Center Specific Plan.
City projects are virtually immortal if they look like work for eager “economic development” bureaucrats or look like they can be sold as accomplishment by people like Ahmad Zahra and Shana Charles, who think (or pretend to think) that their gullible followers can be fooled into believing something good is happening.
That can’t be good…
Except that nothing good is happening. Our City officials increased the value of the property ten-fold through entitlements, but sold it for its original value – a staggering subsidy of at least ten million bucks. And that subsidy was handed to TA Partners, a flimflam operation fronted by a couple of con men, Johnny Lu and Larry Liu, at the end of 2022.
In the three intervening years nothing has happened so far as the public knows, even as TA Partners’ legal and financial woes have become public; woes that certainly should have been known by our economic development experts in City Hall prior to signing a contract, but weren’t. Why not? And why is the project at least two years behind schedule? Don’t ask. Fullerton being Fullerton.
The land was deeded over to Johnny and Larry without even an approved set of conceptual plans. But the deed was encumbered after a fashion with development and construction milestones.
And here’s the Schedule of Performance mentioned above:
Read. Weep.
I don’t know what sort of plans have been submitted, if any, but I know that grading should have started at least 20 months ago and hasn’t. And look at that project completion deadline – a Certificate of Occupancy by 10/21/26. That’s only nine months from now. As this fiasco looks worse and worse, not a peep from our friends at Fullerton Angry and Fullerton Transparency about the initial giveaway or the state of the schedule. They have more important if less expensive “scandals” to rant about.
More work ahead…
Of course the paragraph tacked on to the Grant Deed, above, describes the covenants attached to the land, but that’s it. Other language talks about the City’s right to legal recourse if the conditions of the covenants are not met. That’s pretty toothless since lawsuits are always possible; there is no mention of Johnny and Larry surrendering their new asset, an asset whose entitlements could still make it worth a fortune. Why the City hasn’t already initiated legal action is a mystery worth speculating upon.
We all know that when it comes to Fullerton redevelopment boondoggles, nobody ever takes responsibility for failures. It’s just not good form to hold the masterminds accountable. Often it’s not enough to just keep quiet; sometimes staff actively tries to keep the boondoggle gasping for air so it can be reassigned to some new front man. That’s what I think must be happening now.
By the way, a majority of the current City Council has not voted for this hot mess. It’s a legacy mess.
It’s way past time to learn what’s going on, to find out what the status of the Boutique Hotel and Apartment monster and to find out why the City hasn’t pursued legal remedy to protect our interests.
The other day my FFFF colleague, Fullerton Harpoon, published a post on a possible move on the part of Fullerton’s annoying liberal claque to drum up support for legalizing cannabis dispensaries in town.
A Hip Hop Drug Guy
It’s really hard to get worked up over Doc HeeHaw’s illegal “hip hop drug guy,” and Fullerton Harpoon was quite right in pointing out the absurdity of the “it costs so much to crack down on illegal stores” as a good argument for legal dispensaries when the real reason to have them is to generate large amounts of cannabis sales taxes and fee revenue.
With the Fullerton budget in parlous condition, cannabis revenue derived from an intelligent program isn’t such an unreasonable idea.
Let’s quickly dive back into history when we examine the previous cannabis dispensary ordinance and its revocation in 2020 and 2021.
Throughout 2020 public discussion was held regarding a potential cannabis dispensary ordinance. Public input was clear people wanted a 1000 foot buffer from “sensitive receptors” such as schools, parks, and houses. In fact the consultant’s map that reflected this desire became known as “the People’s Map.”
That was the map approved for recommendation by Fullerton’s Planning Commission. But a funny thing happened on the way to the City Council.
Flory: Was I really hoodwinked?
The ordinance was pushed through by the Council 3-2, in the waning months of 2020, even though an election promised a new councilmembers. Jan Flory, Jesus Quirk-Silva, and of course Ahmad Zahra voted yes. Jennifer Fitzgerald and Bruce Whitaker voted no.
The problem that many saw was that in the modified plan there was now generous latitude of potential locations, even to have a dispensary 100 feet from a residential zone. This latitude was undoubtedly the result of dope lobby pressure on Zahra and Quirk-Silva to increase their opportunities as much as possible, and to “share the pain” as Quirk-Silva put it. The public could shove it where the sun didn’t shine.
The other obvious problem was that the ordinance invested the authority to approve cannabis licenses in the hands of the City Manager, who at the time was the incompetent Ken Domer; the decisions would be shrouded in secrecy instead of transparently, in public
The People’s Map had been sandbagged by Flory, Zahra and Quirk-Silva.
Just said no…
In December 2020 and in the early months of 2021 the two new councilmembers – Fred Jung and Nick Dunlap joined Whitaker in pulling the plug on the ordinance. No one has tried to resurrect the issue – yet.
So I have a modest proposal. Why not go back to the People’s Map? Why not go back to the earlier suggestions that would have banned these stores within 1000 feet of anybody’s residence? In addition, why not require street visibility from a Primary or Secondary arterial so everything is in plain view? Sure, almost all of the cannabis businesses would be in southwest Fullerton – Council District 5, so what? That’s the reality of Fullerton’s zoning code.
As far as other revenue options go, two proposed special sales taxes on the 2026 ballot might not pass as they require 2/3 majority; even if the council waffles toward reverting to a general sales tax there would have to be 4 council votes to put it on the ballot. Are they there? Without these revenue sources the practical financial aspect of cannabis-generated revenue appears useful.
The same argument against a special or general sales tax increase is always there: why should everybody be asked to make a sacrifice for the city’s welfare when the City Council and the hundreds of municipal employees, whose salaries and benefits paid for by the public, have sacrificed nothing?
And here’s a final thought: why not restrict cannabis revenue to specific deployment – such as roads, sidewalks and street lights?
Difficult decisions such as who gets licenses and how many there should be remain. I’m not confident in our existing bureaucracy to regulate this use successfully, but to me an intelligent rethink of the issue that minimizes citizen concerns is not a bad idea at all.
2026 is here, portending all sorts of fun for Fullerton. Some haunting spirits will have to be propitiated, among them is the so-called “boutique hotel” fiasco, one of the parting gifts of former incompetent City Manager, Ken Domer left for his ultimate successor, Eric Levitt.
You will recall the project: a small, high end hotel at the train station, that over the years morphed into a massive housing project attached to it.
Grab it and consume it as fast as you can…
Domer was the facilitator of the stupid concept cooked up by our former Mayor-for-Hire, the lobbyist Jennifer Fitzgerald. His sole reason for being City Manager, in fact, appeared to be his willingness to enable Fitzgerald’s wish lists into fruition.
And Domer was the fellow who let the project move along, during the gestation – recommending a non-bid, exclusive negotiating agreement with Westpark LLC, a company that couldn’t build a birdhouse. Domer was fired in the spring of 2021 but his boutique child, an infant that should have been strangled in its crib, lived on, proving that make-work ideas supported by staff never die.
Looks good to me…
The years passed and Levitt became godfather to Domer’s baby. In this time his staff had uncovered a new and willing partner – TA Partners. Enter Johnny Lu and Larry Liu, two con artists who were already getting deep into debt and fraud elsewhere in Southern California.
Why is Johnny smiling?
By the end of 2022 the real disaster struck: on December 20, 2022, the City voted to approve an agreement to deed over its property, the value increased tenfold, without an approved project even in place. The supporters? Ahmad Zahra, Shana Charles, and inexplicably, Bruce Whitaker, the latter ignoring any of the warning signs that his instincts should have been screaming to him.
Warning: Conceptual only, not to be taken seriously!
Three years have passed. None of the milestones in the Development and Disposition Agreement have ben met. And nobody is talking about this fiasco, at least not in public. We have all learned that Larry and Johnny have pleaded guilty to fraud; that their project in Irvine collapsed, probably taken over by whatever investment bank was dumb enough to give them a construction loan.
Has the City even contemplated action? No closed session reporting has been forthcoming and no reasons given for why not. FFFF learned that the original Westpark guy, Craig Hostert’s family is suing Larry and Johnny for their hijacking of the project. They must see some sort of asset there. If so they are right.
Despite having failed to meet contractual deadlines, TA Partners owns this 1.7 acre parcel and is presumably paying their property taxes to keep it in the family. And the property has value thanks to a incompetent City Council majority.
They had me at boutique…
The entitlements approved by Whitaker, Zahra and Charles are worth a fortune, and can, with the City’s approval, be assigned to somebody else, a tactic that City bureaucrats have pursued in the past to keep embarrassing projects alive and kicking. But that may not work because only Zahra and Charles will keep voting for this disaster.
This fiasco is now seven years old and if there’s an end in sight, it isn’t even on the horizon.
One of our commenters recently pointed out the “reply” string on a Fullerton Observer post supposedly written by a guy named Kevin Curriston, a chap who doesn’t appear to be the literary type. Some of comments are pretty good. Naturally Sharon, the elder Kennedy Sister, leaps into the breach to validate the theme of the essay. Amy the Angry Little Bird is on hand too, to lend her support.
A guy named Brian calls bullshit on the supposition that 40 public commenters represent anybody but a small percentage of Fullertonions.
That premise is not well-received in Fullerton Boohooville.
I particularly like Brian’s wicked request for Kennedy to share some of Zahra’s vast filmography.
A Mr. Matt Leslie reminds everybody that Zahra’s flipped on his first real decision and in doing so disenfranched a whole bunch of people when he appointed Jan Flory to complete Jesus Quirk-Silva’s term.
Matt LeslieThe author neglects to inform readers that Council member Ahmad Zahra did not attend this important meeting. Although it seems unlikely that other council members would have supported him for mayor, he had the opportunity to support Shana Charles for the position, but was not present to do so.Ed Response: Councilmember Zahra had a work trip out of town so did not attend the meeting.
BrianI see you seem to know a lot about council member Zahra, just what does he do for a living?
Sharon KZahra is a filmmaker. Currently the only Councilmember who doesn’t work is Jung. You can discover this kind of thing through the form 700 financial filings of each Councilmember. – though I notice Valencia has failed to file. Not sure why.
BrianWow, that is fascinating. Can you point me in the direction of some of his work?
AmyDunlap and Jung continue to gaslight the public and delude themselves by saying that public commenters are not representative.Every meeting brings new attendees infuriated by the actions of the majority, but Jung, Dunlap, and Valencia keep telling themselves the public’s voices don’t count. It seems they can’t bring themselves to accept that anyone could possibly disagree with their blatant corruption and repeated defiance of the wishes of the public.
BrianI’d imagine if you took two seconds to step outside your bubble, you may realize that in a town of 140,000+, 30 or 40 people don’t even represent a decimal of a percentage. And just because you comment, it doesn’t make your comments true. Much like this publication and the liberties it takes with the truth all the time.
Sharon KBrian – sounds like you are talking to yourself on that critique. Most people are busy with their lives and don’t pay that much attention. And of course over half of our town’s 140,000 or so residents are children. Others have jobs that interfere with council meeting hours, etc. Some don’t think it is possible to fight city hall. Some are just not interested. Having 40 people show up at a council meeting and speak on an issue is huge. If people didn’t come out we wouldn’t have any trails in town; there would be a polluting flour mill across from Amerige Heights; the toxic park and McColl dump site would not be cleaned up; our museum center would be high rise office building; we wouldn’t have saved FOX or Coyote Hills and much much more. Some politicians – just out for themselves and narrow special interests – can fool people for awhile but eventually the truth of their actions come out
AmyThose who disagree are welcome to attend a city council meeting, but for some reason they have not.Jung received unanimous opposition to his taking of the mayorship at the last meeting. Dozens of public comments unanimously supported creating a fund for immigrant support against ICE raids and kidnappings. Dozens still attended to beg city council not to kill the Walk on Wilshire – twice; the paltry number of voices in opposition were those financially aligned with Jung and Bushala. If opposition exists, it has yet to show up to city council meetings.
BrianLike I said, just because you comment, doesn’t make your comments true. With this statement you proved my point again. Full of inaccuracies. Do better.
AmyI don’t see how, but okay. I’m sure you know best.
Matt LeslieAmy, I opposed Walk on Wilshire for several reasons, not because I was “aligned” with anyone. Please be careful not to be dismissive of the concerns of those with opinions contrary to your own.
AmyI fully respect your right to your opinion, but I do disagree that the bollards – comparable to those used on nearly every trail in OC – were an actual impediment to cyclists traversing the Walk on Wilshire and merited removal of the whole thing. I definitely wouldn’t go so far as to say any opinion I disagree with is invalid. That would be absurd. But the argument seemed so ridiculous as to be disingenuous to me. Perhaps I’m reading too much into it.That said, as one of the fewer than 10 detractors, you’re certaintly entitled to your opinion. I hope the dismantling of the Walk on Wilshire that so many enjoyed brought you great happiness and satisfaction.
FrankStep out of your bubble pal.
Sharon KBrian – if you are talking to me – you are right — I guessed that there are way more children than there are at least according to the stats I just looked up that say there are only 32,000 children under 18 in Fullerton. But when you are figuring out percentages of people think about the fact that – according to the OC Registrar of Voters – only 7,432 voted for Jung; 9,546 for Dunlap and 3,489 for Valencia in the last election. That certainly does not make a majority. Some of those who voted for Jung, Dunlap are among those who have come to council and said they were unhappy with their votes on various things and felt fooled when the vote to keep Walk on Wilshire open – turned into an expansion suggested by the two – and then that vote was postponed until after the election and both Jung and Dunlap proceeded to vote no. Really the point is that we residents of town want a fun place to live that we are proud of where people want to visit and small businesses can thrive. Dulling it down by reducing unique features, curtailing music, outdoor patios, walking paths, safe bike paths, etc does not make our town attractive to anyone. And everything turns into a big fight with residents begging for good decisions. And I am not alone in really hating their recent decision to not help residents targeted by ICE and other weird unfair decisions like not following fair rotation so every district gets chance to have their representative as mayor.
Matt LeslieAnd, by the way, if you want to talk about steamrolling over public opinion go watch the videos of Ahmad Zahra’s first council meetings in 2018. Dr. Zahra first voiced support for a special election to fill a vacant council seat, a position in line with nearly all public speakers on the issue during meetings. But he quickly changed his position entirely, aligning himself with a council majority who disregarded expressed public opinion in favor of an election and instead voted to appoint a someone to the vacant seat.Zahra’s swing vote to appoint a council member instead of holding an election disenfranchised an entire district of the city, instead foisting upon them an unelected representative for the two full years remaining in the council term. This decision was of much greater significance, in my opinion, than choosing a mayor from among sitting council members (something the appointed council member got to do). Where was the concern for “the public” then?
Somebody posted a comment the other day about some guy named Tim Johnson. I don’t know Tim Johnson, and I hadn’t even heard anything about him. I was directed to his performance at the last council meeting.
I would really worry about this guy’s mental and emotional well-being. Or I would if he weren’t such a puckered asshole.
You can watch his performance on the City Clerk’s website. His diatribe starts at 1:49:35 mark, right after young Oliver, the No Account of Montecristo.
It’s become a rather worrisome trend lately for the harangues of a few malcontents at council meetings to vent their angry spleen in increasingly agitated, even violent language and behavior. This Tim Johnson individual is a good example.
Constantly slapping the podium; offering wild gesticulations; pointing at councilmembers; shouting angry and abusive language; this seems to be this person’s stock-in-trade.
There was no substance in Mr. Johnson’s diatribe except hatred for Fred Jung who has not been sufficiently contributory to making Fullerton fun! Like his kindred spirits at said podium he seems to think insulting people is an effective way to get them to do what you want. He also seemed to think he has a right for councilmembers to look at him as he denigrates them.
A little research suggests Tim Johnson organizes a bike parade on the 4th of July. His web presence is something called “Fullerton Loves.” He is therefore qualified to determine right from wrong.
Like many other local oracles he approves of those who gives him attention. Nick Dunlap does, apparently, and so does the relentless self-promoter Shana Charles, the otiose councilmember from District 3. The cops and firepersons go to his parades, I guess. And that is the launching pad for his little rocket: Jung makes backroom deals in a cigar lounge, etc., etc.
I’m glad there is a police presence at council hearings as a handful of angry people try to shout down councilmembers with catcalls from the back rows. The obnoxious Kennedy Sisters have already been escorted out for disrupting meetings. Sooner or later civility is going to have to be enforced by the FPD.
It’s tomorrow, don’t be late for the Big Event. Let’s let Sanksa Kennedy of the Fullerton Observer spell it all out.
Why write about news when you can try to make your own! (Photo by Julie Leopo/Voice of OC)
The Grand Opening Ceremony will begin at 10 am at Independence Park, 801 West Valencia Drive, Fullerton. Be among the first to walk, bike, and enjoy this brand-new greenbelt trail connecting our neighborhoods with safe, beautiful, and sustainable pathways. This long-awaited project brings new trees, lighting, and enhanced recreation opportunities right to the heart of our community.
An initiative aimed at transforming an unsightly stretch along an old railroad spur into a vibrant community trail has faced multiple challenges and opposition from a few of the council members, even with $1.78 million in state funding backing it.
After significant community pressure, Council Member Dunlap ultimately changed his stance, voting in favor of the construction contract alongside fellow council members Zahra, Charles, and Valencia. In a not so surprising turn, Mayor Fred Jung stood alone in opposition to the project.
The Union Pacific Trail project stands as a testament to the community’s commitment to development, equity, and civic engagement. Residents are hopeful that this project will be the beginning of more green space for South Fullerton and will create a welcoming space for everyone.
Wow, that’s awful rosy, concluding as facts things that haven’t happened, and of course never will.
Saska is still promoting the same old lie that this boondoggle “connects neighborhoods.” It doesn’t even connect to Phase 1!
It’s a total waste of money, but it sure is short…
Poor Sanka doesn’t seem to grasp the nonsense of an unsightly stretch being the heart of “our community.” Not mentioned is the fact that the unsightly stretch is still there, like it always was and hoping that a silly (and expensive) trail will transform anything is just preposterous wishful thinking.
In Sinka’s tiny brain spending money equates to “equity” regardless of outcome – that’s already been decided by the two dozen drumbeaters for the Trail to Nowhere. She reminds us about the $1.8 million from the State as a reason this should have always been an easy call. She neglects to inform Observers that the City’s cost ballooned from $170,000 to $630,000; but hey it’s a testament, alright. A testament to stupidity and lousy stewardship of public money.
How many of the people who promoted this mess in rhapsodic terms will even be around in a year’s time to calculate the running costs, the graffiti, the crime, the lack of usage, the dead and dying vegetation? None, of course.
Tomorrow this utter waste of $2.3 million will have a hundred parents. In December 2026 it will be an orphan.
“Dr.” Ahmad Zahra, the immigration fraud, battery and vandalism perp, and false police report submitter, that’s who. He’s craved the title for five years and his record of attacking and insulting and questioning the morality of his colleagues has kept him from getting it.
The Council appointment vote is coming up next Tuesday and one thing I will bet on is that the Dubious Doctor from Damascus will not get the job, no matter how many boohoos show up to wail and gnash their at the horror of the injustice.
Gloves are so Nineteenth Century…
Obviously, Fred Jung, our current front man, wants the exalted title since he’s running for County Supervisor.
Look at me!
And then there’s the otiose, self-important windbag Shana Charles. She is (inexplicably) our current Mayor Pro Tem; she might nominate her running buddy Zahra for Mayor, but will be perfectly happy to receive the Mayor title for herself. Can she get three votes? Only if she gets nominated and Nick Dunlap goes along with it, like he did when he bafflingly nominated her to be Mayor Pro Tem a year ago. But if he does that he will surely incur the wrath of the powerful Lincoln Club, a big money Republican outfit that has supposedly endorsed Jung.
My prediction is a third year of Jung’s mayoralty, a year in which a sales tax increase will be the big issue for Fullerton voters. I see Jamie Valencia appointed Mayor Pro Tem, unless for some reason Dunlap wants that, which seems unlikely.
Am I right?
If I am, expect another one of those self-pity party monologues from Zahra about how his enemies (unnamed) are out to get him and how he has worked valiantly on behalf of the dispossessed untermenschen of District 5. Count on a ten minute discourse with many pained and pregnant pauses as he scans the audience and no one in particular.
Tune in to the Council meeting on December 16th to find out.
On last Tuesday’s City Council closed session agenda, an item popped up that surely bears close examination.
This is about an appeal regarding a decision involving “post retirement employment.” That means it involves CalPERS the massive pension program for public employees in California. Obviously CalPERS came down on these four individuals listed for violating terms of retirement, terms meant to make retirement a serious decision. I’m moderately familiar with the rules. The basic ones are that if you are officially retired you can’t go back to work for any CalPERS agency for more than 960 hours a year, and you can’t take on the responsibilities of a full-time employee.
Gone, not quite forgotten…
Friends may remember Jeff Collier, former City Manager of Whittier, who was the “Interim” City Manager after Steve Danley (an OCERS retiree and therefore eligible), for a while in 2021-22. Did Collier work more than 960 hours? Can an “Interim” qualify to get around CalPERS restrictions? I don’t know.
Pfost came to Pfullerton…
I don’t remember a Cindy Collins, but a do recall Gregory Pfost, retired head planner from Laguna Beach who washed up on Fullerton’s shore.
A Manfro all seasons…
Finally, there’s Eddie Manfro, retired City Manager from dysfunctional Westminster who hired on a few years back as an HR consultant, I think, and became the de facto HR Director. He is now the Interim City Manager.
The one thing all these individuals have in common is that they were and are, well-aware of the limitations placed on CalPERS retirees, so whatever the violations are that are being appealed, should have been avoidable.
I would like to know how Fullerton got stuck with this embarrassment and who is paying the legal costs for the waiver process and the appeal. I get the feeling we are paying.