Threats, lies and videotapes

The "Mutually Developed Strategy" to take Martin Luther King - Marcus Garvey Cooperative

By Carol Harvey

November 1, 2006

INTRODUCTION

In preparation for the mid-term elections, this three-part article about the history of the Redevelopment Agency in San Francisco's Fillmore District is a must-read.

Proposition 90 was placed on the November ballot to rid California of the Agency's gargantuan power of eminent domain.

After the Supreme Court's 2005 Kelo decision, a wave of rage swept the country against Redevelopment Agencies utilizing a powerful tool called "blight" to hand private developers the homes, businesses, and real estate of private citizens.

For a century, racist and classist motives have under-girded San Francisco Redevelopment Agency "takings."

The Redevelopment Agency has had a "black" history in the Fillmore and Bayview-Hunter's Point from which they have forced from whole African American communities.

Throughout U.S. history, Blacks were systematically driven from communities they built --- from great wealth in Tulsa, Oklahoma's Black Wall Street, to exciting enclaves like the Fillmore's "Harlem of the West" clubs where all the 40s and 50s jazz greats entertained.

Invited to San Francisco during the Second World War to work military and defense jobs, Blacks came in droves to the thriving Fillmore District, which bounced back after the 1906 earthquake and fire. Fillmore Street replaced Market Street as a booming business center.

After World War II restored U.S. wealth, Redevelopment wooed Justin Herman from HUD to direct the Agency. His white developers began to "modernize" San Francisco. Using "blight" and taxpayer money, Herman bulldozed lovely old Fillmore Victorians, jazz clubs, and businesses, leaving the landscape bleak.

Redevelopment let the place lie fallow for 20 years creating the slum it claimed it was trying to clear.

Renamed Western Addition by Redevelopment, the Fillmore never recovered.

During Lyndon Johnson's 1970s "War on Poverty," Federal funding gave grassroots financial power to poor communities enabling incorporation of cooperatives like the Fillmore's Martin Luther King - Marcus Garvey.

Ulysses Montgomery was a 1970s builder who found ways for these mostly African American's to use HUD and Redevelopment money to pay down mortgages on their own homes.

Ulysses Montgomery

Now, San Francisco's Redevelopment and HUD Agencies seek to "re-acquire" these African American holdings.

Bayview-Hunters Point is the prettiest, sunniest part of town, and Redevelopment wants it. There, it has launched the largest eminent domain "taking" in U.S. history.

At Spring 2006 Board of Supervisor meetings, the Agency promised protesting Hunters Point resident activists it would never repeat the Fillmore atrocity.

SFRA Executive Director, Marcia Rosen neglected to mention that 40 years ago Redevelopment rendered the Fillmore a slum, has not rebuilt it, and continues today what some call its racially motivated assault, abuse and neglect.

Executive Director of the San Francisco Redevelopment Agency, Marcia Rosen.
File photo (5/24/6) by Luke Thomas

In Part One of this article, King Garvey's original African American developer, Ulysses Montgomery, exposes Redevelopment's historical assault on Fillmore's African American holdings.

Part Two uncovers the campaign against the African American Western Addition business community. Upon purchasing a historically significant business, the New Chicago Barbershop, Charles Spencer came to know the Redevelopment Agency's neglect.

Part three makes transparent the attack on the King-Garvey co-op itself. After 30 years of carefully paying down their mortgage, the mostly elderly female shareholders of color risked losing their precious, now phenomenally valuable real estate to SFRA and HUD lies, extortion, and outright theft.

Some warn against traps embedded in Proposition 90 by Howie Rich, a conservative Republican.

Nevertheless, the Fillmore and King Garvey story illustrates why so many are taking assertive action to shut down Redevelopment agencies and stop eminent domain "takings" no matter what the cost.

Part 1: THREATS

Redevelopment in the Western Addition Jazz Time

Daniel Landry, stood in Gene Suttle Plaza near sidewalk engravings of the names "Rev. Hannibal Williams" and "Mary Helen Rogers," activists who fought hard against the Redevelopment Agency's infamous "Negro Removal" from the Fillmore District, which the agency renamed Western Addition.

I followed his wistful gaze to the top of the Fillmore Auditorium where someone in the post-earthquake 1920 Fillmore heyday had perched on a scaffold painting "Majestic Theater" in white on the now-faded bricks.

"I would walk home from Raphael Weill Elementary School, see that sign, and wonder about the '40s and '50s jazz era," he reminisced.

It was a splendorous flash in time. In the blocks surrounding the famous auditorium before Janis torched, Jay Leno killed, and Ted Nugent recently showcased, music rang from every corner.

As teenagers, Sugar Pie De Santo and her cousin, Etta James, practiced duets on their porch. Dressed to kill in minks and suits, folks strutted and strolled the crowded night streets. At the jazz clubs - Billie, Ella, Trane, and Monk --- played and sang up a storm.

Despite strong community opposition to Redevelopment, like the lighted arches with hanging glass globes, melted to scrap for the 1940s War Effort, the Fillmore clubs and their exploding energy were bulldozed into oblivion.

Today, jazz pours from the doors of the one remaining venue, Rasselas On Fillmore, keeping the memory alive.

Rather than see the Victorian jewel housing Jimbo's Bop City at 1690 Post torn down to make way for the Japantown complex, activist Essie Collins petitioned the Redevelopment Agency to move the building intact around the corner to 1712 Fillmore. There a branch of world-famous Marcus Books, devoted to African American literature, established in Oakland in 1960 by Drs. Raye and Julian Richardson, was installed in its San Francisco location.

The Redevelopment Agency forced one of Julian Richardson's publishing companies and other African American businesses to relocate from Fillmore street.

Richardson became a director for the Fillmore Community Development Association, organized by individuals and Western Addition organizations in opposition to the A-2 redevelopment project.

Ulysses Montgomery, a licensed California professional engineer developed methods to use Redevelopment to generate economic benefits "by and for the people" of Western Addition.

"Instead of fighting Redevelopment," he said, "Let's come up with a program where they give us the land and finance us so that we, the people, construct and own these buildings under the Redevelopment process."

Ulysses Jim Montgomery is an urbane world traveler of Cherokee, Black, and European descent who regards San Francisco's past and present with clear blue eyes.

Montgomery was raised in South Carolina, New Jersey, and Brooklyn. Columbia-educated with a 1952 M.I.T.construction-civil engineering degree, he was one of two Blacks out of 3,000 graduates.

Like most African Americans, his forebears are tough rebellious survivors of the British slave trades' brutal Middle Passage. A relative helped initiate the discrimination lawsuit, Brown v Board of Education. An ancestor, Angola Jamie, led one of the first slave revolts.

In the '60s, Julian Richardson and Ulysses Montgomery, who described his friend's family as "very close to me," worked with other black community leaders attempting to create what a Redevelopment brochure described as "more socially oriented housing for the Western Addition A-2 project area."

During President Lyndon B. Johnson's '60s War on Poverty, Mr. Montgomery developed and constructed the Martin Luther King Marcus Garvey Cooperative where Daniel Landry lives.

At M.I.T., Buckminster Fuller mentored him on "what architecture and economic development of buildings were supposed to do for people." He socialized with Boston University students, Martin Luther King, Jr, and Coretta Scott.

After graduation, he traveled to Africa developing projects in Angola, Nigeria, Ghana, and Liberia.

There he met W.E.B. DuBois, Malcolm X, Congo's Patrice Lumumba, Zimbabwe's Nkomo, and Kenyatta in Kenya. "All of these were friends," he said. He was with Nelson Mandella's group the day the great revolutionary was sentenced to prison.

In fall 1965, he returned to the United States bound for California to help reconstruct Los Angeles after the Watts riots, but "I was hijacked on the way by friends in San Francisco."

Johnson's War On Poverty "gave economic power to low income people in Cities."

Federal law mandated anti-poverty money could only be spent on programs reviewed and approved by the community. Thus, the Government granted the people effective control of utilization of Federal funds.

Between 1965 and 1970, Ken Simmons and Will Usury, both of the Congress of Racial Equality (CORE), "with the help of the people" designed the EOC (Economic Opportunity Council) implementation program which included elected executive policy neighborhood councils for Hunters Point and the Western Addition.

A people's vote for Ulysses' housing empowerment plan at Ben Franklin High School "got me started, and (established) my power base to develop housing in San Francisco by and for the people."

"Daniel Landry's father, Abe, is an old trooper," Ulysses said

"I was in the (New Chicago) barber shop getting a haircut, (with) Abe and a few people from the old Western Addition.

In 1966, his new friend, EOC night watchman, Abe introduced Ulysses all around.

"Abe got into a tussle with people trying to stop (Ulysses' program). Somebody pulled out a knife and tried to cut his throat.

"That's my scar down the side of his face. He got that defending me."

Justin Herman got wind of Ulysses' plan.

"The first time I met (him) he came up to me (at the Agency) and said, 'I run the Redevelopment Agency, not you.'"

"A lot of people hated Justin Herman. We fought like cats and dogs, but when he gave his word, he kept it."

In 1966, Ulysses convinced Bob Pitts, HUD Regional Director, to freeze all financing for the Redevelopment Agency in San Francisco. Bob Pitts said "I was honest, and (my program) was in the best interests of the people." He told Justin Herman before Redevelopment got more funding they must change their plans to include the Ulysses' ideas.

Herman gave Ulysses Montgomery development rights to nonprofit housing corporations he helped community groups organize.

In 1973, Wilbur Hamilton, Redevelopment Executive Director and Gene Suttle Redevelopment Agency A-2 project manager, met with Ulysses. "They said HUD (would) cancel all mortgage guarantee allocations for my clients. They could stop it if I closed my business and left San Francisco."

"Neither Gene Suttle nor Wilbur Hamilton would ever have done that by themselves. They were told to do it," by two white men, HUD director, James Price and his Deputy, Bob Gillian, "and they did it reluctantly."

"To protect my clients' interests, I liquidated my consulting business and transferred my clients to friends."

"Why did HUD and Redevelopment do this?" I asked.

"I was Black. They didn't like my attitude.

" I was developing co-ops or nonprofits, for the People, by the People ... But mostly white developers and contractors wound up owning everything, and all the Blacks got is a chance to rent in a subsidized project."

Under President Johnson's Poverty Program, "Community groups got development rights for many (housing and cooperative) projects in Western Addition and Hunters Point.

"(Now) HUD, Redevelopment, and some profiteering carpetbaggers are taking back ownership and control from original African American community groups at Jackie Robinson and Northridge (housing complexes) in the Bayview." They are also after Unity Homes.

"In the Westren Addition, they want Marcus Garvey and Martin Luther King Co-op. The attack on King-Garvey is the core. (If) they take it, Amel Park, El Bethel and Friendship will go."

Part 2 - LIES

Charles Spenser stood in the Rincon Center old Art Deco post office at 101 Spear Street gazing at the colorful murals painted on the lobby walls depicting historical images of hostility against people of color.

Charles was raised in a close-knit Columbus, Georgia community. He remembers his father hiding him and his siblings under the bed during 1970s fire bombings.

In his 12-year career as a stockbroker before he bought the New Chicago Barbershop #3, 1551 Fillmore Street at Geary Boulevard in the Western Addition, he gained an insider's view of San Francisco sociopsychology and economy. Its treatment of African Americans is no different than in any other part of the country.

The New Chicago Barbershop has warm sunny feel with dark wood and comfortable chairs. He bought the business in 2002 to keep alive in the present a precious piece of the past. In the 1940's, a Mr. Walker from Chicago started this business.

Reggie Pettus, who was featured on PBS video "Hidden Cities: The Fillmore," still cuts hair there. He is a part of Fillmore history, familiar with Western Addition figures from Mary Rogers to Essie Collins.

Along with Ulysses Montgomery, and Abe Landry, all walks of African American life come to this neighborhood hub for haircuts. Danny Glover drops by just to chat when he visits his old neighborhood. On the walls are photographs of visitors like comedian, David Allen Grier, and regulars, like Ray Taliafero KGO progressive radio talk show host.

"The biggest thing I am doing is trying to keep the Barbershop alive. It is one of the last Old Fillmore businesses. People come by who got their haircut here when they were a kid. It's something the black community can identify with."

Charles, an self-assertive person who thinks and acts independently, knows many hard working, successful Black people like himself.

His strong individualism and social consciousness motivates him to clean up the parks on the weekend. Whether alone or with a group, it is an direct action he can take.

As past President of the Fillmore Jazz Preservation District Merchants' Association, Charles knows the Redevelopment Agency well.

He knows about the infamous time when beautiful old Victorian, home to thousands of Black families, were demolished, leaving a few buildings sticking up from the gray dirt like rotting teeth.

Then Redeveloped promised to rebuild the bulldozed blocks. But, instead the Agency left them fallow for 20 years, creating the blighted conditions which were the original excuse for razing homes.

It is common belief that Justin Herman, who became head of the Redevelopment Agency in 1959, built the Geary corridor from Downtown to the Ocean shunting traffic past Fillmore for the purpose of drying up African American businesses there. The naming of Justin Herman Plaza was his reward.

Musing on the Rincon Center mural, Charles considered the Embarcadero, an area Redevelopment actually redeveloped, making a major investment complete with mixed use buildings, high rises, businesses, shops and market rate and low income housing, infrastructure, roads, and rails. He compared it to the Agency's pathetic effort in the Fillmore, which Redevelopment renamed Western Addition.

Of the violence on the streets, Charles says, "I know many senior citizens and some kids --- there are certain blocks they don't visit because stuff happens."

"With no jobs, and no education, kids can't think clearly," he says. "If a kid grows up, and he can't think, add, count, somebody could take a simple thought, put it in his head, and it will stick."

Charles stated that the Agency destroyed the community and promised to rebuild it. However, "there is no reason to attack the Redevelopment Agency because the facts speak for themselves. After 40 years, they still haven't completed the project area."

Asking for Budget information, he and other merchants found when "contractors low bid with the Redevelopment Agency (for) contracts, it appears the Agency knowingly told them to contract with themselves, because they weren't being paid enough --- double dipping."

He has also discovered Redevelopment's pattern and practice of fast tracking preferred developers who are overwhelmingly white. "Their approval process goes quicker than developers who don't appear to be preferred or friendly developers."

Instead of investing in infrastructure improvements, Redevelopment spends taxpayer money on marketing and promotion. The Agency awards contracts to "consultants." One group, Cultural ID, organized the Preservation Jazz District to bring summer jazz performances into the Fillmore. "It's a little like throwing a house warming party before building the house," he observed.

Projects like the Jazz District do not address housing or jobs, the benefits Redevelopment promises when it undertakes to redevelop an area.

Redevelopment has not funded businesses that provide work or meaningful careers for people. "When we ask for jobs, people (hire us) six months as a flag waver on Third Street , or working Mcdonald's for (an) hourly rate that doesn't allow you to buy a home, rent an apartment, or get a car."

Charles Is aware there are San Francisco interests who have worked out a long term City Plan --- not just 10 years into the future, but 50 years ahead.

He has even seen drawings of one part of The Grand Plan for filling in the Fillmore-Geary underpass. Suddenly, you've got land. "What happens to land in San Francisco?" he asks. "You build stuff on it.

The Agency (is) saying, "Look, we are building Yoshis, so that's our economic development.

"The community was destroyed. It has not been rebuilt. Yoshis is not going to rebuild the community. Yoshi's could be a part of it, but it's not all of it.

"Yoshi's will need dishwashers and doormen but create no professional jobs with any real future."

"Part of the Plan on Fillmore is for the Black community to continue to transition out and other communities to transition in." King Garvey is an expendable Monopoly game piece.

Because "you need a healthy residential community to have a healthy business community, " when he heard HUD was threatening to foreclose on the King Garvey shareholders' property, he took it upon himself to meet Board President, Carlos Levexier. Carlos invited him to fall 2004 meetings at which he joined other community members, including the historian, John Templeton, and Dr. Raye Richardson, Marcus Books owner. He believes, were it not for their support and presence, the shareholders would have lost the property.

He wondered whether King Garvey residents, mostly elder women, understood they were not renters, but 30-year owners of homes in a property with world class value situated next to the Geary corridor. The property's accumulated equity, estimated at $56 million dollars, could secure their futures for the rest of their lives.

"They have fantastically valuable land that the Redevelopment Agency and the City want," he asserted.

Redevelopment's Fillmore achievements are high rises surrounded by fast food restaurants and chain stores like Subway and Foot Locker.

By jarring contrast to such superimposed artificiality, businesses like Marcus Books, Rasselas Jazz Club, Powell's Place, "The Look" Beauty Salon, Terry's Creations Boutique, the New Chicago Barbershop, and homes owned by King Garvey people of color represent the deep heart and soul of the community.

Charles well knows the social power in his thriving barbershop business.

"We have to rebuild the community ourselves."

Part 3 - VIDEOTAPES

The energetic Sharon Jones has a global understanding of the community history of Martin Luther King Marcus Garvey Square Cooperative. A devout Roman Catholic and shareholder since 1982, she vowed to help right wrongs perpetrated on the coop. She represents a core group determined to retain home ownership.

Trained by the Peace Corps and Montessori educators, she taught pre-school and elementary children. She received an M.A.in English from the University of Michigan and met her husband, her adopted daughter's African-American father.

Sharon Jones

This community of low income African and Korean-American families and senior women, are shareholders with Section 8 subsidized affordable rents, paying down their mortgage year-by-year to buy their own homes. Developer, Michael Strausz, estimated accumulated equity at $46 million dollars.

Sharon's neighbor, Barbara Meskunas, Board Chairman National Association of Housing Cooperatives, lives across the street. She helped connect King Garvey with a funding source, The National Cooperative Bank.

Stated Meskunas, "200 homeowners live in my neighborhood." "(They) own shares of a limited equity coop. (They are), better neighbors than if they were renting."

Many believe King Garvey's troubles began in 1968 when HUD loan officer, William H. Harrison, oversaw its construction. Years later, in 2002, Harrison became management agent and participant at a nexus of serious problems.

Sharon, a board member since 2000, described 37 years of confusing events implicating the Redevelopment Agency and HUD.

- Shareholders' requests for repairs were ignored by HUD-approved Agents.

- Payments of inflated sums were paid to HUD-approved staff and Agents. .

- HUD threatened to foreclose if shareholders installed a board elected to replace a corrupt one.

- In 1998, the co-op's "urban myth" a "cesspool of drugs, gangs, and guns," made news, inviting HUD foreclosure for unsafe conditions. An SFPD, State, and Federal narcotics squad burst in at 5:30 a.m shutting off co-op power. "Flash-bang" grenades" blew doors off hinges. Officers held at gunpoint and cuffed seniors and children with no criminal records, arresting 11 youths. They "uncovered" three pot leaves, seeds, and three unloaded guns. The "gang" was a basketball team organized by Daniel Landry.

Even with four HUD property inspections per year, one man had a door-sized hole in his roof, and beleagered Bridgette Daniels, raising children with asbestos, mold, and mildew, was forced to cook under a ceiling leaking raw sewage in one of 10 homes the fire department evacuated.

Harrison's staff relocated Bridgette's family to four co-op units equally bad. Sharon believes they hoped Bridgette's loud complaints would spur the Board to approve a tax credit plan Harrison proposed to fund home repairs. It would reduce these homeowners to renters without equity.

Desperate, Ms Daniels, followed by 40 others, ran to the City Health Department and Human Rights Commission investigator, Emil de Guzman who contacted the Justice Department's Booker T. Neal, The Mayor, City Attorney, Supervisor Ross Mirkarimi, City Department heads, HUD officials and Redevelopment Agency staff.

Later, Sharon learned these frantic visits to City Departments tripped off "secret meetings," in person and by phone between HUD, SFRA, and City officials.

With curious simultaneity, a HUD property evaluation score reported two months earlier, dropped from 10 above passing to 22 below passing.

On March 8, 2005, Mayor Gavin Newsom wrote HUD Regional Director, Richard Rainey, requesting the Government "not terminate rental assistance or foreclose"...(to allow) "time to enable the City to work with the residents to address the massive problems existing at the project."

On March 24, 2005, Rainey responded. "It appears from your letter that the City no longer wishes to pursue""our mutually developed strategy" including "the terminating of the Section 8 project-based contract initiating foreclosure."

Richard Rainey exposed a "partnership" which "mutually developed" a "strategy" foreclosing King Garvey. Rainey expressed "appreciation for the cooperation of the City and County, and (Mayor's Office of Housing Director), Matt Franklin, (Redevelopment Department Director), Olsen Lee, and District 5 Supervisor, Ross Mirkarimi.

Rainey casually cc'd this letter to the King Garvey Co-op Board. Sharon showed it to Ulysses Montgomery and Michael Strausz.

The two developers recalled a January 2005 meeting with Olsen Lee who confided "The Agency intends to re-acquire all of San Francisco's African American-owned housing projects." Later Lee appeared in March 2005 co-op Task Force meetings, at which he offered "help" without mentioning SFRA's intentions.

HUD, providing Federal funds, and Redevelopment, State and City bond money, often "double team" on projects.

In his letter, Richard Rainey promised to "consider delaying any further actions (pending) a realistic plan that solves the Project's long-term problems."

If King Garvey did not cure its "physical, financial, and security issues," Rainey's "strategy" advised a four-step plan.

1. Cancel Section 8 rent subsidy.

2. Foreclose and re-acquire the property.

3. Hand King Garvey to Redevelopment

4. "The City could create a mixed-use development embracing affordable home ownership, rental housing, and units for the homeless."

Sharon reported that HUD, SFRA, The Mayor, and City Departments, did not inform King Garvey of their "mutually developed strategy."

Instead, beginning March 12, 2005, City "Task Force," "helpers," met with shareholders, facilitated by Justice's Neal and Human Rights Commission's De Guzman. Present were Mayor's office officials, Sup. Mirkarimi's and Nancy Pelosi's Aides, Redevelopment Department Director, Olsen Lee's A-2 management staff, Health Department asbestos experts, pro bono attorneys, and supportive community members.

Raymond Washington videotaped these meetings.

Mirkarimi and Olsen Lee described the arduous road ahead. King Garvey had two months to devise a "Plan." Olsen Lee committed Redevelopment staff and funds to work on solving financial, security, and environmental problems acceptable to HUD, though HUD could reject it.

Characteristically, Redevelopment, hired "consultants."

Asian Neighborhood Design, Inc estimated $56 million total, $26 to $30 million for repairs. A.N.D. based their report on visitation of six units. They claimed friable asbestos necessitated complete rehabbing of all 211 units. Not all units had asbestos problems.

A 2003 structural assessment by a King Garvey-paid engineer, Thomas K. Butts, estimated repairs worth $16 million dollars. Work meeting Public Health requirements was completed by December 2005.

Sharon believed A.N.D.quadrupled the Butts report, ignoring the completed work.

After months of meetings, sometimes three a week, in which shareholders were subjected to role-playing games wearing little hats, on Thursday, June 28, 2005, HUD Operations Officer, J. Patrick Goray, arrived to drop the hammer.

"You are not keeping up your end of the bargain. The property deteriorated because there wasn't enough money for operating expenses or to maintain the project".

"But, you said, 'Give us a chance. We will fix the problems.'"

Good news: "You invited in good management, made operational improvements, raised the (market rate unit) rent," hired an architect to do an analysis (Mr. Butts) and identify repairs to the property.

Bad News: "Unfortunately, you didn't take the next step --- follow through to get repair money and do repairs."

Surprised Board members wondered why Asian Neighborhood Design and Goray overlooked repairs quickly done by Harrison after Bridget Daniels brought in inspectors.

Goray ordered shocked shareholders to present a strategy to HUD identifying repairs and get a Plan to acquire $26-30 million dollars on his desk by Monday or he would foreclose.

They saw themselves evicted, sitting in the street with their belongings.

Goray further rocked the Board citing Redevelopment-paid Connolly Consultant's four "options." They said just one option could raise sufficient money covering $56 million in costs, a tax credit plan depriving them of home ownership.

Sharon called J. Patrick Goray's presentation "evil."

"Why?"

1. "Who, in one weekend, could refute with another plan that $56 million was needed?

2. ""Instead of moving, shareholders lived in squalor. They aged and became sick believing one day they would own this property.

3. They paid down the mortgage for 30 years, with 13 years to pay 3.5 million. Thirty years they begged HUD for repairs. Inspectors walked through ignoring them. Now damage was used to threaten eviction.

HUD, Redevelopment, The City appeared to have led them by the nose through a setup, with foreclosure an advance "mutually developed strategy. "

On the video, Daniel Landry wistfully watches the action.

Sharon saw Dan survive his at-risk teens, become a parent, business owner, community member, run for D5 Supervisor and confront the City about Western Addition police brutality.

Daniel, the community's hope, survived Redevelopment trashing his neighborhood. To be effective, he must live secure in his cooperative home.

Like Sharon, Bridgette, Raymond Washington, and Daniel, most owners determine to keep their property. Shel Schreiberg, the HUD regulations expert attorney Sharon spent all her assets locating, is helping develop a plan pro bono--- NOT a tax credit plan --- to do so.

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