Strange But True – Friends For Fullerton's Future

May 4, 2026May 4, 2026Behind Closed Doors

The Money Grab

Fullerton’s illustrious ad hoc Budget Sustainability Committee was treated to a marathon “we’re cut to the bone” presentation by the City’s department heads last Tuesday night.

One of the interesting concepts for revenue enhancement, albeit one-time, came from our Director of Public Works Stephen Bise.

It seems that over time, unrefunded “engineering” fees from City permit applicants adds up. Currently, the City has about $700,000 in such fees sitting idly in a Public Works account. According to Bise some of the fees were collected way back in the 1990s. The City Council would have to put its seal of approval on the deal and a notice to the rightful owners of this money would have to be made.

Similarly, funds gathered from contractor bonds and not claimed piles up, too. Bise reckons that ampount is $145,000. Presumably the same process for keeping that dough would be deployed.

This situation begs the obvious question: what responsibility does the City have to notify its customers that they have positive balances; or better yet, why can’t the Public Works Department simply write checks and return the money to its rightful owners before it piles up? There seems to be an unwritten rule that the money belongs in City funds (gathering interest at least) until such time, if any, that the owners request reimbursement. It really is a form of indirect “taking.” These individual amounts may be small, but as Director Bise indicated, are substantial in aggregate.

Apparently Fullerton made a grab of these bond funds a few years ago that had accumulated up to 2016. That amounted to $800,000. The next decade’s worth is now on the table, apparently. Can the Council resist seizing this cash? I wouldn’t bet against it.

As to the process of notification I admit my ignorance. Are such notifications made to the real owners or their heirs and assigns? I wonder. It would be so much easier to put a public notice in a “newspaper of record” where virtually nobody would ever see it; and then put it on a Council Agenda, posted 72 hours before the meeting where even fewer people would see it.

April 22, 2026April 26, 2026A Manfro All Seasons

When is An Audit Not An Audit?

by The Fullerton Harpoon24 Comments

Well, there she goes. Don’t worry. There’s more where that came from…

When a misleading City of Fullerton agenda proclaims: “Introduction of Special Fiscal Audit – Grant Thornton Risk Advisory Services.”

I assumed, wrongly, that somebody had already been hired to look into the misdirection of funds into the General Fund Reserves that should have gone some place else, a fact that has caused considerable embarrassment to our severely and habitually underinformed City Council. I also figured this firm was going to talk about what they found.

But no.

In fact, the firm of Grant Thornton Risk Advisory Services were brought before the council by the City Manager, Eddie Manfro, simply to make a sales pitch for their services. And what services.

Step one is to be some sort of forensic accounting exercise, a fishing expedition to explore the world of Fullerton’s accounting regime to see what, if anything, is amiss. Nobody said anything, but there must have surely been some internal squirming when the company rep kept using the word “fraud.” And that included our Finance Director and recently anointed City Treasure, Steven Avalos who was sitting in the pit.

The second phase of GTRAS’s endeavor was to explore how the City might improve efficiencies, save money, and help address Fullerton’s grim fiscal situation. Why this all-purpose company was suggested for this task seems odd, the two tasks having nothing to do with one another.

I’ll address the first project first. Why is it necessary at all to delve into Fullerton’s accounting with an audit? We have been told that there were seemingly honest bookkeeping errors – embarrassing, sure and it did alter the already dire projection of General Fund reserve draw downs, but fear not, all was well. The councilmembers kept talking about transparency and public trust, but what does that really mean? Is this serious or just a political pantomime?

Consider the following facts. GTRAS was picked by the City Manager under his own authority and just brought to the council to give them a chance to ratify the decision. That’s a sole source contract, and the public has no idea how much they will be paid, and won’t without a PRA request. Will added scope to the $100,000 contract be reviewed by anybody except the City Manager and Steven Avalos? If some sort malfeasance were actually discovered – purely by accident, of course – would offender(s) names be published? Is any of this going to discussed in Closed Session because it touches on employee issues? Who knows? The Council approved the deal, without knowing whatever it is or might be.

As for the second part of GTRAS offer, the City Manager announced that would be returned to the Council for approval of a $130,000 deal. At least someone might get the chance to ask some pertinent questions, such as why is this “economic development” effort needed, given that Fullerton has highly paid staff who enjoy employment as economic developers. What have these people been doing and why do they need outside help. These people have been on the payroll for years. What have they accomplished?

Sunaya Thomas, in charge of economic development, was in attendance. Her presence at the meeting was an almost begging of the question about her own success in this endeavor, the effort of bureaucrats that never even pays for itself.

I wonder if GTRAS will actually suggest something that might help, outside of taxes. Personally, I doubt if their suggestions would even pay for their own service. That we will probably never know because no one will talk about it. This will be an agreement with no metrics for success or failure, just more electronic billboards and hotel occupancy taxes. Staff reductions? Getting rid of all our brand new “firefighters” and ambulance drivers? Don’t be ridiculous.

Anyhow our brave Council voted unanimously to proceed down this dark corridor, protesting their sincere desire to pursue those most elusive prey: transparency and public trust. No one said much about accountability. They never do.

April 9, 2026April 9, 2026Ahmad Zahra

Trouble in College Park

by Disillusioned Ex-Hippy36 Comments

College Park is an old neighborhood adjacent to Fullerton Junior College. Back in 1979 the City designated it as an historic preservation zone. That was 46 years ago if you’re counting. The area is full of little bungalows and small spanishy looking houses. It’s a nice neighborhood even if you add in the dinky roundabouts on Wilshire – the brainstorm of Wild Ride Joe Felz, who certainly could not have navigated them on election night, 2016.

But I digress.

At the last City Council meeting a woman who lives on Cornell Avenue in the district complained about a building on her street under construction that was completely out of character with the neighborhood and the preservation rules, adopted in 1996, that are supposed to protect against such things. She kindly reminded the Council that she lives in D5 – Ahmad Zahra’s district.

So I went over to the 100 North block of Cornell Avenue and snapped some images.

Now I’m not an architect, but something is awfully wrong here. Yeah, it’s a big box with cheap, misaligned windows that is completely out of scale with the houses around it. Yikes. Check out the puny little rooflet over the cheapo Home Depot door.

How could this happen? It looks like somebody in City Hall dropped the melon with a loud plop. As I understand it, there is a staff process for reviewing these developments. Did it occur? I don’t know. But whether it did or didn’t happen, the problem is obvious. If it didn’t, why not? If they did what sort of knucklehead(s) could have approved this?

Eyesore is right.

At the meeting Development Director Sunaya Thomas preposterously claimed this hulking monster was somehow an ADU development – meaning a mere accessory dwelling unit, a “granny unit,” and that the City had no real control over the design of the beast; and also that it was up to the owner to figure out parking for his tenants! Up to the owner? Since when?

Of course Ms. Thomas is talking out of her backside, as is so often the case. The rules for preservation in the R2P zone are called out in the Municipal Code – Chapter 15.17.60, from which I quote:

All proposed development, including the rehabilitation of existing structures, will be reviewed for compliance with established design criteria and standards, specific to the preservation zones and identified significant properties. These adopted design criteria and standards, entitled “Design Guidelines for Residential Preservation Zones,” are intended to serve as a baseline — a set of elementary guidelines — by which a proposal will be evaluated.

Here are the the guidelines, supposedly unknown to the very person in charge of applying them to new development in preservation zones:

https://www.cityoffullerton.com/home/showpublisheddocument/1232/637436214735730000

I learned a long time ago that it’s almost impossible to make Fullerton planning bureaucrats do their jobs (see noise ordinance issues). The defensiveness and lack of shame will always prevail. But this is appalling. The rules are there to follow, not to pick and choose.

Thomas failed and failed badly. The Council was lied to on Tuesday night. Does anybody care?

Hopefully the D5 council representative Ahmad Zahra, who champions transparency and accountability, will get to the bottom of this fiasco.

March 31, 2026April 2, 2026Boohooism

Jan Flory, Victim

by Mr. Peabody51 Comments

Sometimes you think you couldn’t make something up that is so ludicrous as to seem impossible.

And so it is with the case of Jan Flory vs. Fred Jung’s ballot statement that was determined on March 27th.

Not the outcome, per se, in which Jung had to change his designation from “Fullerton Mayor/Business owner” to “Fullerton Mayor/Businessman;” and had to remove from his statement the silly claim of opening 9 new parks and balancing a budget left unbalanced by predecessors.

No, Friends, the crazy, and unintentionally hilarious part was the last minute filing by Ms. Flory’s attorney meant to dodge a stay on the original writ of mandate. In this latest filing, Mr. Brett Murdock (who could not have possibly have composed it with a straight face) demanded immediate relief because Jung’s statement would cause poor Flory “irreparable harm.”

It’s pretty funny reading, all based on the premise that government is a business, and that business is hers:

“Petitioner Jan Flory is engaged in the business of government and politics“

A reputation is a terrible thing to waste…

The supposedly “practically libelous in nature” part is due to the implication that Flory – whose name does not even appear in Jung’s ballot statement – didn’t balance the budget during her fourth laborious canter around the Fullerton City Council track. This supposed assertion of her incompetence is said to impugn her professional political reputation; this so, so funny because every Friend is aware of Flory’s dismal record of incompetence and deceit on the City Council – from the years of Water Fund fraud, refusal to reform a culture of corruption at the FPD, Redevelopment disasters, and of course deficit spending, just to mention a few issues.

I have always hated you, and I always will…

And then there’s the specious and even more hilarious Murdock argument that if Jung were to win based on his ballot statement, it would deprive Flory of opportunities to possibly serve on one of the many County commissions and boards, some of which might offer remuneration:

“If published in the official election material, Jung is more likely to win the election. As a political opponent, Petitioner is unlikely to be appointed by the Supervisor to any of the County’s 85, (sic) boards, commissions and committees; whereas as a highly-qualified and prominent supporter of Traut, she may well earn an appointment.

Membership on a board or commission not only comes with political advantages, but pecuniary advantages as the County “pays certain board and commission members stipends for attending meetings.”

Other benefits—for which “it would be extremely difficult to ascertain the amount”—could accrue to prominent supporters of a winning candidate, including opportunities to be hired as staff counsel or prestige in the community as a lawyer or lobbyist.”

I can’t imagine which “community” would consider Flory as a lawyer – she quit her lawyering, good or bad, years and years ago. Flory the octogenarian lobbyist if Traut gets elected? Who’s kidding who? Her victimhood is based on not being able to be a political hack?

All of this adds up to very little, really, except to spread a little unintended humor to the good people of Fullerton.

March 10, 2026March 10, 2026Boohooism

What’s a Chamber of Commerce For?

by The Desert Rat9 Comments

A Friend has forwarded a press release from the North Orange County Chamber of Commerce. This used to be the Fullerton Chamber of Commerce that merged with other groups in neighboring towns, I’ve been told.

The Chamber is throwing itself a birthday party brunch in celebration of 133 years of existence. The fare, donuts, is in keeping with the odd year number to celebrate.

Notice that presentations will be made by Republic Services, the massive corporate trash hauler whose contract with Fullerton is up this year; and SCAG, the completely opaque regional agency responsible for the nonsensical 13,000 new housing units shoved up our backside by the Sacramento Affordable Housing Cartel (SAHC). That seems sooooo fitting.

For the past 30 years Fullerton Chamber of Commerce has gone from tax-fighter to weak little sister of Fullerton City Hall. Under the dim bulb Theresa Harvey, the Chamber became an auxiliary of the City, which is appropriate because after she left the Chamber she became the Chair of the CSUF Auxiliary – another totally opaque agency that plays monopoly with money with virtually no oversight.

The Chamber became a lap dog, not a watch dog for the waste and dumbassery in City Hall. Ms. Harvey was a completely clueless puppet. Under her, the Chamber actually threw their lot in with the public employee unions in 2020 in support of the Measure S sales tax.

Parenthetically, the CSUF Auxiliary has become a final stop for local small-time influence shoppers like Harvey and her predecessor James Alexander, and that brought us the disastrous Elk’s Club/Universaity Heights faculty housing debacle.

Apparently there’s a new guy in charge at the Chamber, but I can’t say I’m hopeful. The Chamber should be promoting small businesses at City Hall, and promoting economy and efficiency in local government, not “tax your way out of it” boohooism. Will it?

Anyway, I thought back to the days in 1993 and 1994 when the Chamber stood up for businesses large and small, fighting City Hall on the unnecessary utility tax imposed by McClanahan, Bankhead, and A.B. Catlin. Those were fun times.

February 4, 2026February 4, 2026Ahmad Zahra

Bent History Bullshit

by Mr. Peabody35 Comments

Here’s an interesting bit from the “print edition” of the Fullerton Observer, proving that once again the Fullerton Klown Kar has no rearview mirror.

The subject is the reopening of the abandoned UP Park, and all you have to do is look at the photo op result to guess that a history re-write is in the works.

While we were basking in the Spring-like day, most of the USA was under an unrelenting, repressive assault by ice, snow, and freezing rain. All of the speakers took notice of who was in the audience, mainly the Fullerton residents who did not give up on the idea of a local park, rallying support for an incredible 20-plus years. Assemblywoman Sharon Quirk Silva recalled how she was on the City Council in 2004 when the idea of revitalizing Union Pacific Park was discussed. Persistence from Fullerton residents kept the idea alive, so keep that in mind.

There’s a who’s who of Fullerton libs who can’t seem to have their pictures taken often enough, especially over there on the far left – the tarnished antique Pilferin’ Paulette Chaffee, who did less than nothing to have the park reopened. But then again, neither did Vanessa Estrella, or Sharon Quirk, or Jesus Quirk-Silva.

And on the subject of Quirk and Quirk Silva, the reimagining of history is appalling. Quirk got on the City Council at the end of 2004 all right. But at that point the first Union Pacific Park was just completed – brand effing new. Her statement is obviously meant to ignore the long history of bureaucratic failure that led to toxic soil removal and closure of a third of the park, to finally fencing off the whole damn thing because of the hypes, borrachos and homeless campers.

But just as important as hiding ugly truth is promoting your own accomplishment – finally doing what was thought impossible – after a 20-year fight! And let’s not forget the other myth – the popular struggle from la communidad, all of it ginned up, when it existed at all, by patronizing gringos at the Center for Healthy Neighborhoods, etc.

The Big Q probably doesn’t want you to remember that she was on the Council for another 8 years after her mythical park revitalization “discussions” allegedly took place, and so if the park wasn’t “revitalized” under her careful stewardship, why not?

Then there’s her dopey, hare-brained husband, Jesus, who was on the council from 2016 through 2022. What was he doing to revitalize the park after it really was fenced off? Nada. That’s right fish farm fans. He and Ahmad Zahra, also mugging in the picture, were trying to illegally convert the parkland to an intrusive fenced off private event center. So much for “the community.” You couldn’t make this stuff up.

The Fullerton Observer sisters and these political types want us to forget the real history of the UP Park – a poisoned public nuisance created by and for City bureaucrats as a Redevelopment money plaything who’s history would be a civic shame, if anybody in City Hall had any shame.

Now maybe you think that this is all trivial, this whitewash of the past. Not so. The conditions which caused UP Park #1’s failure are still there, even as more millions are thrown at UP Park #2. No one is paying attention because nobody cares.

January 17, 2026January 17, 2026Ahmad Zahra

The Marovic Sidewalk

by Mr. Peabody22 Comments

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.

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…

Although I can’t verify the rumor, Marovic finally got sick of paying legal bills last fall and decided to perform the scope of his original agreement. A status (secret) of the lawsuit popped up on the October 7th, 2025 City Council Closed Session agenda. This might have led to some new deal.

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.

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.

January 8, 2026January 8, 2026Ahmad Zahra

Dope Lobby Back to Work In Fullerton After Holidays

by The Fullerton Harpoon32 Comments

Yesterday our young and lively friend, sweet Elijah Manaserro published an article on the Fullerton Observer blog. I call it an article because it isn’t a news story – almost devoid of journalistic content – it is really an opinion essay.

Out of the blue our tender sprout decided to elevate an issue completely off the radar – illicit cannabis dispensaries. And he shares the turmoil caused by these unlicensed, unregulated stores. “Whack-a-mole” he calls it, and dramatically claims the cost of enforcement is “staggering.” Of course the cost isn’t staggering at all, but when you are acting on behalf of a huge, monied interest, hyperbole is okay, I guess.

Where the green shoot Elijah is going with this is clear. It’s same logic and language used by the Fullerton Observer and by “Dr.” Ahmad Zahra in the past to promote legal dispensaries. Since Fullerton can’t control the illegal activity, we might as well make it okay.

The good folks behind the legal dispensary push – the Dope Lobby – have been trying for years to get this use legalized in Fullerton, and it looks like they’re still hard at work – through the Observer and the green sprig Manaserro, the Zahra acolyte and possibly closed session confidante.

This issue is not peanuts to the Dope Lobby, which consists of two elements: the lobbyists for actual dispensary companies, and the local grocery store workers union who represent dues paying cannabis store workers.

A year ago the grocery workers local union UFCW 324, no doubt supported by the lobbyists behind the scenes, pumped a staggering $60,000 via the national HQ into a political action committee to get “Cannabis Kitty” Jaramillo elected to represent Fullerton’s 4th District. That effort failed, but the cash motivation endures.

The UFCW PAC paid $4000 to Andre Charles, husband of councilperson Shana Charles, to do some sort of work for the Team Jaramillo campaign; we can assume, I think, that Charles is certain to support a new cannabis ordinance, given her personal economic connection. This means that the Dope Lobby is still just one vote away from getting their majority in 2026 and a revitalized dope zone map.

Still don’t see connections? Guess who Zahra picked to be his representative on the so-called Sustainable Budget Committee?

Zahra chose Derek Smith, that’s who. He’s The government lobbyist for the cannabis workers a fact that has never excited young Elijah’s curiosity.

But now back to our fragile fleur of an “investigative reporter,” Manassero. He claims (dramatically, of course) that the illegal dispensaries have been “near schools” but conveniently doesn’t say which ones. The few addresses he cites to bolster his essay are no where near any schools. Of course in his dissertation he fails to mention that the previous dope ordinance, passed in the last hours of 2020, before a new council was sworn in, permitted dispensaries within 101 feet of our homes.

Finally, and inevitably, callow young Manaserro directs attention to the real issue: the budgetary benefits of cannabis sales taxes. This has always been a big motivator for MJ support in City Hall, given the fact that general sales tax increases, like 2020s Measure S, are difficult to pass. The proposed special sales taxes discussed last year need a two thirds majority to pass.

I don’t spark up doobs any more, but back in the day…hey that explains a lot about my life’s trajectory.

Here’s my prediction: as spring 2026 advances, we will see Fullerton Boohoo, Fullerton Angry, Fullerton Childish, and Fullerton Fun begin to advocate for legal cannabis stores, and harass the council majority to implement a new ordinance. As the August ballot deadline approaches we’ll hear even more racket from these people.

January 6, 2026January 6, 2026Ahmad Zahra

The Boutique Hotel to Nowhere, Rehash, Part 1

by Mr. Peabody20 Comments

Domer-Decorations — Hitching to Desert Center

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.

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.

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.

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.

December 9, 2025December 10, 2025A Manfro All Seasons

Something Fishy in Fullerton

by Grover Cleveland36 Comments

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.

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.

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.

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.