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Who Is CABOC and Why Is It Teaching Lies?

Who Is CABOC and Why Is It Teaching Lies?
September 21, 2021
First Published: January 25, 2023

At least the tag line it rhymes.


Once upon a time, there was an organization named CaLBOC, the California League of Bond Oversight Committees.

A couple years ago, Jack Weir, formerly of Contra Costa [Fake] Taxpayers Association, started moving and shaking with the goal of reinventing CaLBOC. The result is California Association of Bond Oversight Committees ("CABOC").

CABOC is holding its first "virtual" conference on October 16, 2021 -- "Supporting Citizens' Bond Oversight Committee Members."

Purportedly, the conference is going to teach citizens' bond oversight committee members the ropes.

Some of the CABOC directors have moved forward to CABOC from CaLBOC -- Anton Jungherr and Nick Marinovich. We're familiar and have, over the years, spoken with both the legacy directors and all the newly minted directors, excepting Chris Hanson, Mac Moore, and Tom Rubin. All the directors except Mr. Weir, Mr. Rubin, Mr. Moore, and Ms. Hanson have been members of this site for many years. Mr. Weir, although we spoke to him very early on in our effort, has never shown the slightest interest.

What Does CABOC Teach?

What prompted this article was a claim in an e-mail sent on July 26, 2021 from CABOC promoting the October conference. Here's the quote from the newsletter.

FAQ: What is the Brown Act?

Excerpt: The Ralph M. Brown Act (Open Meetings), California Government Code Sections 54950 et seq, regulates many aspects of all government agency meetings including those of Citizens' Bond Oversight Committee (CBOC) meetings.

- The Brown Act is essentially a body of rules designed to ensure open government and fairness. Because of the complexities and potential penalties, we recommend that qualified legal counsel educate CBOC members and staff on the Brown Act at the beginning of their terms of service and that the advice of legal counsel be obtained in advance of any matters that may be questionable.

There were other Brown Act FAQs in the e-mail, the gist of which was that CABOC would be teaching these FAQs at its upcoming conference.

CaLBOC had been teaching the same thing for many years, but CaLBOC never gained much traction. Its lofty aspirations never came to fruition.

CABOC, on the other hand, has, apparently done some groundwork to try and identify who are members or former members of the hundreds of district oversight committees around the state. Now CABOC was going to raise some money by charging a fee to attend its conferences. (Much like C.A.S.H., see below.)

Having been on speaking terms with most of the directors over several years, we hoped to set them straight. If CABOC was going to be C.A.S.H.-lite, the taxpayers, who will end up funding CABOC in the same way that they already fund C.A.S.H., should at least be aware of what it's up to.

For CABOC to adopt C.A.S.H. positions under the guise of an independent organization just doesn't sit right with us.

C.A.S.H. and the Origin of the Brown Act Lie

It's pretty amazing. C.A.S.H. was organized in 1978 to fight Howard Jarvis' Proposition 13. While the Howard Jarvis Taxpayers Association ("HJTA") did fight against the passage of Proposition 39 in 2000, it has since pretty much lost interest in it. As a result, C.A.S.H. pretty much has done whatever it wants since then. It's well-funded with your tax dollars via annual membership and event fees from the vast majority of school and college districts in California. It also collects fees from a large number of members from the school bonds cartel who gorge themselves, at will, on both your general fund tax dollars and bond fund tax dollars. It's quite a lucrative racket, operated by a Sacramento lobbying firm that takes its cut.

After the passage of Proposition 39, C.A.S.H. went to town. C.A.S.H. members include plenty of lawyers, both general counsel and bond counsel, who feed at the taxpayer trough. Early on, its Legal Advisory Committee created a Proposition 39 Best Practices Handbook, ostensibly, "to guide school district personnel through the decisions of whether and how to hold a Proposition 39 bond election." It disclaims that the "guidance" is legal advice. For "legal" advice, districts would have to hire the high-priced lawyers themselves. In effect, however, the "guidance" has been a blueprint, from the point of view of those who profit on the backs of taxpayers, on how to exact (steal) billions of dollars annually from local taxpayers all over California.

The Handbook is a 73-page document in its last revised form (2006). It's written, not as a legal memorandum or brief, but as a way for districts to get their hands on more taxpayer money. This, of course, is the reason for the existence of C.A.S.H. in the first place. In other words, it's biased against taxpayers in every way.

Anyway, on page 17 of the C.A.S.H. Proposition 39 Best Practices Handbook you will find the single point of entry for this article -- the Brown Act (the open meetings act for all local governing bodies in California). Here, in its entirety, is what the Handbook says on the subject.

Meetings of and Documents Provided to the Committee

All Committee proceedings shall be open to the public and shall be subject to the provisions of the Ralph M. Brown Act. All documents received by the Committee and reports issued by the Committee shall be a matter of public record and be made available on an Internet website maintained by the governing body of the school district. [Education Code § 15280(b) ("EDC 15280(b)")]

Here's the actual relevant language from the statute cited as authority for the claim in the Handbook.

All citizens' oversight committee proceedings shall be open to the public and notice to the public shall be provided in the same manner as the proceedings of the governing board of the district. The citizens' oversight committee shall issue regular reports on the results of its activities. A report shall be issued at least once a year. Minutes of the proceedings of the citizens' oversight committee and all documents received and reports issued shall be a matter of public record and be made available on an Internet Web site maintained by the governing board of the district.

While the second sentence of the Handbook tracks the last sentence of the statute, the first sentence of the Handbook is a legal conclusion without any basis. In other words, the Legal Advisory Committee made it up out of thin air. The statute does not even come close to invoking the Brown Act.

For comparison, when the Legislature wants to invoke the Brown Act, here's how it does it. Education Code § 35145 ("EDC 35145")

All meetings of the governing board of any school district shall be open to the public and shall be conducted in accordance with Chapter 9 (commencing with Section 54950) of Division 2 of Title 5 of the Government Code. All actions authorized or required by law of the governing board shall be taken at the meetings and shall be subject to the following requirements:

(a) Minutes shall be taken at all of those meetings, recording all actions taken by the governing board. The minutes are public records and shall be available to the public.

(b) An agenda shall be posted by the governing board, or its designee, in accordance with the requirements of Section 54954.2 of the Government Code. Any interested person may commence an action by mandamus or injunction pursuant to Section 54960.1 of the Government Code for the purpose of obtaining a judicial determination that any action taken by the governing board in violation of this subdivision or Section 35144 is null and void.

The Legal Advisory Committee are all very smart lawyers. They knew when they wrote the Handbook that it wasn't true. (In fact, almost all the legal conclusions in the Handbook are not true.) Those very smart lawyers also knew, after experience with oversight committees for several years before the Handbook was first published, that they wanted to protect their clients (the districts) from the nuisance of having to deal with oversight committees. One of the easiest ways is to put the fear of God into the lay (not lawyers), ordinary people who were appointed to oversight committees. Invoking the Brown Act's criminal penalties, which have never been enforced, even for legislative bodies to which the act applies, was gold. In other words, it took oversight out of the hands of the oversight committee members and placed it in the district staff and governing body. As a result, in the 21 years since the passage of Proposition 39, there has never been any oversight, in accordance with the law, of the expenditures, either for Proposition 39 bond proceeds or Proposition 46 (2/3 voter passage) bond proceeds by any of the 536, according to CABOC, oversight committees in California. (If you think this broad generality is not true, bring us the evidence of what you claim to be oversight and we will disabuse you of the idea that there has ever been oversight.)

It's been so bad, that the Little Hoover Commission has held two public hearings on bond expenditure oversight, first in 2009, and again, only seven years later, in 2016, Little Hoover Commission Hearing on Bond Oversight (because none of the 2009 recommendations had been implemented). CABOC Director Chris Hanson and us each provided written testimony for the 2016 hearing. Former CaLBOC President Michael Turnipseed (Kern County [Fake] Taxpayers Assocation) provided oral testimony. Five years on, none of the 2016 recommendations have been implemented either.

Bond expenditure oversight of districts by oversight committees is the biggest fraud against taxpayers in terms of dollars (hundreds of billions) in the history of California. The "bullet train" train wreck is not even close. Yet Jon Coupal (HJTA) comments endlessly on the "bullet train" and never on district bond expenditures.

What Brown Act Provisions Apply to an Oversight Committee?

This would actually be funny if it were not so painfully serious.

Every oversight committee meeting conducted since January 1, 2019 has been illegal.

Why? One of the provisions of EDC 15280(b) requires that "notice to the public shall be provided in the same manner as the proceedings of the governing board." On January 1, 2019, an amended notice provision went into affect - Government Code § 54954.2 ("GOV 54954.2"). (That's the same statute expressly cited in Education Code 35145, above, that expressly applies to district boards.) No oversight committee has ever provided the notice, as required by law in the amendment, for any of its meetings subsequent to that date.

We're not going to go into the current notice requirements in depth here. We have already written extensively about them for many years. Briefly, the amended notice requirements require a direct, prominent link from the district's web site home page to a machine-readable agenda. In other words, the link goes directly from the home page to the current agenda and the agenda is capable of being indexed by search engines like DuckDuckGo. While there is a provision in the amended notice requirement for an "integrated agenda management platform," none of the popular subscriber-based systems like AgendaOnline (and its newest incarnation), BoardDocs, etc., meet the definition prescribed by the statute. Primarily, AgendaOnline and the others fail to meet the definition because they actively and purposefully prevent search engines from indexing any content within their systems.

Not unsurprisingly, any oversight committee that attempts to provide the notice in accordance with the law would likely be frustrated because its district governing body has never, since January 1, 2019, complied with the notice provision in the law either. This, despite the fact that the Legislature has expressly told the governing bodies to provide notice by citing the statute in Education Code 35145. (See above.) Laws? What laws? When local governing bodies, all retaining highly paid C.A.S.H. lawyers at taxpayer expense, won't even follow basic laws, you can be assured that the corruption is ubiquitous.

What's Wrong With Applying the Brown Act?

In one sentence, it puts a straight-jacket on activity by members of the oversight committee by making it so burdensome to the, mostly volunteer, committee members that no oversight is performed. Oversight committees only meet when the districts allow them to meet, at times that are convenient to district personnel and district invitees, to watch and listen to dog-and-pony-show presentations of all the projects underway. District staff monopolize the time with presentations so that there is no time for the review of actual expenditures, if detailed expenditures are even provided at all.

The Brown Act is used by C.A.S.H., both districts and their various counsel, as a cudgel. It serves no purpose other than to yoke an oversight committee to the Brown Act to scare them. An oversight committee is neither a sub-committee of a district, nor a legislative body in its own right. Its only function is to report its oversight findings to the public -- not the district.

To our knowledge, not a single oversight committee anywhere in California has ever hired its own lawyer to challenge any of the restrictions that C.A.S.H., via districts and their lawyers, force down the throat of the oversight committees. Of course it would be nearly impossible to find a lawyer who was an expert on oversight committees because all the lawyers that know anything about this area of law are conflicted through counsel agreements with districts. (Did you know that almost all districts execute counsel agreements with multiple C.A.S.H. law firms, whether or not they ever use the legal services, for the express purpose of preempting the field of experienced lawyers who can fight districts in court?)

Every set of oversight committee bylaws (all written by C.A.S.H. lawyers) reads the oversight committee the riot act of everything it must do (things in the district's interest, like approving the audits and pledging allegiance to the district via ethics rules) and everything it must not do, like violate the Brown Act or require anything from the district that would expose its bond proceeds expenditure fraud.

Los Angeles Unified: Corruption on Steroids

When we had a conversation with Mr. Crawley, one of the presenters at the upcoming conference, about the Brown Act issue, he mentioned that he was not an expert and looked to two other directors with more expertise. One of those directors was Mr. Rubin. You can read his biography on the CABOC web site.

Alarm bells went off immediately in our head. It was not the time to mention it to Mr. Crawley, though.

Mr. Rubin's expertise, per his bio, is working for Los Angeles Unified. Los Angeles Unified has never, ever, ever, ever conducted oversight of its Proposition 39 bond measures in accordance with the law. Never.

The district expends millions of dollars of bond proceeds for things like buses and an inspector general bureaucracy that are expressly prohibited under Proposition 39.

The district's purported oversight function predates Proposition 39. It has all kinds of crony members who all have a vested interest in getting bond money expended on things that benefit their political interests. Read the article in the Additional Reading section below.

Since Mr. Rubin has never been involved in any oversight under the laws written for that purpose, we challenge his influence in an organization that purportedly champions oversight.


Like the 2004 Attorney General Opinion 04-110 (another C.A.S.H. triumph of misinformation) that purports to override the plain language of the Constitution, the Brown-Act-for-oversight-committees claim has never been heard in a court. In both cases, the claims would lose in an honest court or in a jury trial. Therefore, the lawyers beholden to C.A.S.H. will never allow either of those claims to see the light of day in a court.

We've written a lot of in-depth analysis on the issue of oversight. (See below.) Jack Weir's CABOC appears to be on the side of making money from oversight training, rather than fostering actual oversight. That puts CABOC on the same side as C.A.S.H..

CABOC, for whatever reason, is overly reliant on people and firms that deal with the West Contra Costa Unified School District or Sweetwater Union High School District. Both of those districts have been the subject of scandals involving the misuse of bond proceeds. No one in those districts has ever been prosecuted. In West Contra Costa Unified, a forensic audit sparked by a whistle-blower, not the oversight committee, cost over a million dollars when it was presented in 2018. The so-called oversight committee agreed (even though it has no authority to agree to misuse of bond proceeds) to allow half of the cost of the audit to be paid from bond proceeds. The taxpayers in West Contra Unified were screwed twice, once by the criminal conduct of the district trustees, administration, and vendors, then again by the oversight committee.

For promoting C.A.S.H. positions on almost every important issue (like the Brown Act), including lobbying for changes in the law to give C.A.S.H. more "legal" ways to screw the taxpayers, we give CABOC, in its current incarnation, a grade of a big fat F. We question how an organization infused with those who have watched over rampant fraud in connection with bond fund expenditures has the chutzpah to teach others the ins and outs of oversight in the taxpayer interest.

Even if the directors are well-meaning, all appear to have or have had careers in day jobs involving government administration. The bias of lifetimes in government work make them much more likely to excuse the rampant corruption, than to root it out.

Additional Reading (for Site Members)

The following is a little editorial to give you our reasoning on reversing our decision not to publish the article.

The article above was written on September 10, 2021. We gave notice to CABOC on that date that the article was intended to be published on September 21, 2021. On September 17, 2021, Mr. Jungherr hosted a Zoom call to which CABOC board members and we were invited. Mr. Rubin did not join the call. Other than we, only Mr. Weir and Mr. Jungherr spoke. As a result of that call, the board members on the call agreed to stop pushing its emphasis on teaching the Brown Act. That's why we didn't publish the article.

To document the understanding, we archived CABOC's FAQ page on September 18, 2021. The Brown Act question was number 21 on that date. We archived the FAQ page again on October 21, 2021. The Brown Act question (21) was completely removed. At that point, we believed the issue was dead. (TIP: CABOC has started to use a new method to display its FAQ that is not capable of displaying. When you click on an individual FAQ, nothing displays. You can see the actual text of any FAQ, however, by viewing the source code for the page in your browser and then searching for the FAQ that is of interest to you.)

Fast forward to October 2022. Another site member had sent a citizens' bond oversight committee ("CBOC") a formal cure or correct letter under the Brown Act regarding two oversight committee meetings held on October 27, 2022. Mr. Rubin personally attended those meetings as well. When the district's counsel stated that the district would not comply, on behalf of the oversight committee, with the notice provision (GOV 54954.2) of the Brown Act mandated by EDC 15280(b), the member sent the CBOC a formal cease and letter under the Brown Act.

Fast forward to January 22, 2023. A few days prior, the district's counsel responded to the cease and desist letter to the CBOC. The member asked for Mr. Rubin's perspective on the response. Mr. Rubin responded and the response was forwarded to us.

TAR: Yes, absolutely, CBOCs are required to adhere to the Brown Act by statute.

This damn problem just won't die.


So, since the "governing board of the district" [citing EDC 15280(b)] is subject to the Brown Act (technically, this is the California Open Meetings Act), so is the CBOC. -- BY CALIFORNIA LAW, VERY SPECIFICALLY REQUIRED.

What is mentioned in the 15280(b) comprehends everything in the Brown Act.

Since 15280(b) clearly says that it is under the Brown Act, it is under the Brown Act.

End of discussion. Checkmate. Roger, Wilco, Over, and Out (which no one in the military ever says). Topic closed. Time to go home.

This comes up so often that CABOC adopted FAQ34:

As part of the CABOC legislative agenda, we're trying to get specific language added to the Brown Act (in the Government Code) that says, right there in the Government Code, that CBOCs are subject to the Brown Act.

There are a lot of people who haven't done the full research who have stated that CBOCs are not subject to the Brown Act and have even ridiculed those who say that it is.


As a result of Mr. Rubin's reply and the change to the CABOC FAQ page, we decided to publish the article above.


This Addendum was written on September 18, 2021, but no one ever saw it. It provides further analysis to support the position that the Legislature knew what it was doing and did not consider a CBOC was a legislative body subject to the Brown Act.

There are some who go to the Brown Act's own definition, in Government Code § 54952 ("GOV 54952"), to determine whether the Brown Act applies. That's appropriate in some cases and not in others. Courts and lawyers are familiar with the legal canon that states the specific rules the general, meaning more specific language in a statute overrides more general language in another statute.

The Brown Act definition is the general. It tries to accommodate, in a single place, all the bodies to which the Brown Act applies.

In the case of school districts, the Legislature, specifically, applied the Brown Act to the local governing bodies. That rule, therefore, overrules the definition in GOV 54952. Any analysis of GOV 54952 as to its application to school districts is preempted by the specific statute.

So too is the case of the citizens' bond oversight committee. EDC 15280(b) specifically describes the requirements with which it must comply. It preempts any other less specific statute, such as GOV 54952.

So for a school district, the Brown Act applies because of EDC 35145, not because of GOV 54952. Similarly, for an oversight committee, the two parts of open meetings law that the Legislature deemed appropriate are stated specifically, to the exclusion of all other sections of the Brown Act.

To be crystal clear, the two rules are 1) that oversight committee proceedings must be open to the public, and 2) that oversight committees must provide notice in accordance with GOV 54954.2 because that is the specific manner in which school districts are required to provide notice. Note the school districts were already subject to GOV 54954.2 because of the first sentence in EDC 35145. The legislature specifically made school districts subject to GOV 54954.2

How the Brown Act Applies to School Boards?

In the past, we had not paid much attention to EDC 35145, primarily because it invoked the Brown Act for school districts in an all-inclusive way. The sentence starts off with the scope, "All meetings ..." The second sentence, however, starts off with the scope "All actions ..." That second sentence has two subsections, (a) and (b). The scope of subsection (a) is the minutes. The scope of subsection (b) is the agenda.

In August 2020, we objected to the failure of the Los Angeles Unified School District to provide notice of a special meeting adding a $7 billion bond to the ballot three days before the filing deadline. The general counsel for the district responded to our letter claiming that GOV 54954.2 did not apply because it was a special and not a regular meeting.

The general counsel's claim was new to us. In researching the claim, we did indeed find that, technically, the posting of an agenda is not required for a special meeting under GOV 54956.2 or the school district corollary EDC 35144. However, there are very specific rules for special meetings regarding public notice that are quite different and much more burdensome than GOV 54954.2.

We should have gone back to EDC 35145. It specifically invokes the rules of GOV 54954.2 for posting agenda for governing bodies of school districts in subsection (b). It also invokes EDC 35144. This was new insight for us.

While the general rules of the Brown Act apply to school districts, two of those rules are expressly overridden by the Education Code. One of those overrides is specified in EDC 35145(b). The other is provided in EDC 35144. That provision specifically overrides the Brown Act for special meetings. We suspect that school districts hold special meetings frequently without implementing all of the requirements for a special meeting. We suspect that a reasonable interpretation by a court would lead to the conclusion that failure of school districts to comply with EDC 35144 or EDC 35145 would make actions taken at those meetings voidable.

Note that meetings for community college districts have different rules. Those rules are found at EDC 72121, EDC 72121.5 (the public can place items on the agenda), and EDC 72129 (special meetings). This was quite an eye-opener to us. The surprise here is the EDC 72121 does not invoke the Brown Act.

The main point to take away from this is that, if you wish to hold these rogue local governing bodies accountable, you must know the controlling statutes.

The secondary point is this: If you think you know it all, you don't.

The following is new material added for the January 25, 2023 publication of this article.

CABOC's Position on the Application of the Brown Act to CBOCs

Although we did not archive it, FAQ 34.1 first appears in an archive dated May 29, 2022. So the reversion of the Brown Act on CABOC's web site occurred sometime between October 21, 2021 and that date.

From FAQ 34.1,

While the open meeting requirement does not explicitly reference the Ralph M. Brown (Open Meeting) Act, most school districts and CBOCs have interpreted the requirement [EDC 15280(b)] to establish that CBOC public meetings should be noticed and held in accordance with Brown Act provisions. CABOC agrees with this position [Emphasis added.]

As far as notice is concerned, one does not have to "interpret" EDC 15280(b). It expressly requires notice for regular meetings in accordance with GOV 54954.2. For special meetings, notice would be under EDC 35144, which is substantially the same as GOV 54956.2. Based on the unrebutted fact (see discussion in main article) that no CBOC in the entire state is providing notice either under GOV 54954.2 (since January 1, 2019) or under EDC 35144, why isn't CABOC raising that issue in its FAQ?

Instead, CABOC agrees with "interpreting" EDC 15280(b) to mean that CBOCs are subject to the entire Brown Act. Another legal canon is that courts only "interpret" statutes when the plain language is vague or ambiguous. There are plenty of rules on how to interpret statutes, which are beyond the scope of this article.

CABOC also claims that "most school districts and CBOCs" have done this interpretation without even a single example of where this "interpretation" was discussed at a governing body or CBOC meeting. If you attend any governing body or CBOC meetings, it won't take you too long to determine that these bodies are incapable of interpreting anything. The fact is, that they are not authorized to "interpret" anything. Only courts are authorized to interpret statutes. Just ask them.

To the contrary, both governing bodies and CBOCs are under the spell of the district's counsel. That's who writes their bond measures. That's who tells them what they can and can't do. In relation to local school bond measures, that counsel is actually the district's bond counsel, which has a conflict of interest in relation to the CBOC, because it represents the district. Bond counsel also has a direct financial interest in the sweetheart deal it makes with the district to provide legal services that depend on the issuance of bonds.

For the typical CBOC, the district currently hires either its bond counsel or its financial advisor to provide training on the Brown Act. That's more taxpayer money going to conflicted parties. If you've ever attended one these trainings, it's all about putting the fear of God into the minds of CBOC members to prevent them ever overcoming their Stockholm syndrome. The CBOC's captors and abusers are the district and its advisors who will do everything in their considerable power to avoid any oversight whatsoever.

Will CABOC Do More Harm Than Good?

This is not our only grievance with CABOC. Most recently, it has been developing so-called "best practices" for bylaws. CABOC has shared the first draft. It's absolutely terrible. In our opinion, CABOC is on a path that will make taxpayer-oriented oversight worse, if that is even possible, by giving its "trainings" and "best practices" the imprimatur of an independent body of self-proclaimed experts. Why?

In our opinion, most of the CABOC initiatives will go nowhere, primarily because CABOC has some fundamental misunderstandings. For example, a CBOC is not a legal entity with standing in a court of law. It can't even bring a School Bond Waste Prevention Action (Education Code § 15284) in its name.

One of the usual suspects has introduced the concept of a memorandum of understanding ("MOU"). In this context, the purported "best practices" MOU is based on the completely illegal Los Angeles Unified CBOC MOU, which has never complied with Proposition 39 or the Education Code in the last 22 years. (See Additional Reading, above.) It sounds good, but a CBOC has no standing. An MOU can't be enforced, despite CABOC claims to the contrary. MOUs are often considered "soft" contracts. "Soft" means there are no penalties for violating an MOU. They are often used by labor unions to get exclusive privileges for union work generically known as project labor agreements, which are never enforced by school districts, although they could be. A CBOC is not a labor union or any other legally organized entity.

CABOC certainly has an agenda. The agenda goes well beyond its stated mission of implementing the recommendations of the 2016 Little Hoover Commission Report. Before it goes off tilting at windmills, CABOC would likely benefit from the advice of competent counsel. It would certainly put a crimp in its plans if it had some pushback from someone with some expertise. But that's just wishful thinking on our part. The CABOC board knows it all -- "End of discussion. Checkmate. ... Topic closed. Time to go home." When CABOC mixes good advice with bad advice, you don't know what you can trust. That begs the question. What beneficial purpose, in its current incarnation, does CABOC serve?


Your written or verbal comment is invited. We will publish either a short, less than 100 words, comment or a link to a lengthier comment from your web site (no social media platforms, except GAB). We will also link to audio or video recordings where the entire recording is on this topic. We will publish comments in chronological order, as received. The comment must be sent from a verifiable e-mail address by the author, that includes a contact phone number (for verification only). We will publish the author's name and short job or vocation designation, city, and state or country, along with the unedited comment.

We have invited written comment from CABOC directors well in advance of publishing this article.

If CABOC, or C.A.S.H., brings to our attention evidence of any factual errors in this article, we will correct them. We are not likely to change any of our evidence-based conclusions without demonstrable evidence that CABOC is truly an advocate for actual oversight, i.e., protecting taxpayers.


To date (May 27, 2024), we have received no written factual errors or comments.

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